Free Motion to Detain Pending Trial - District Court of Delaware - Delaware

· ry r Case 1 :08-mg2823QLA\1/A/h Qppjgnnegbii; Bjlegi/()2yj,1g£2008 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
) . . .
v. ) Criminal Action No. 08- B 7· IM]
JONATHAN AMATO, i
Defendant. g
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3142(e) and (f). In support of the motion, the United States alleges the
following:
l. Eligibilig; of Case. This case is eligible for a detention order because case involves
(check all that apply): A
L Crime ofviolence (18 U.S.C. § 3156)
___ Maximum sentence life imprisonment or death
__ l0+ year drug offense
____ Felony, with two prior convictions in above categories
L Minor victim
_; Possession! use of firearm, destructive device or other dangerous weapon
__ Failure to register under 18 U.S.C. § 2250
25 Serious risk defendant will flee
____ Serious risk obstruction of justice

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2. Reason For Detention. The court should detain defendant because there are no
conditions of release which will reasonably assure (check one or both):
é Defendant's appearance as required
K Safety of any other person and the community
3. Rebuttable Presnmption. The United States will/will not invoke the rebuttable
presumption against defendant under § 3 l42(e). (If yes) The presumption applies because (check
one or both):
_>_;< Probable cause to believe defendant committed r
specified offense the ° i C h 2, /#(K}
__ Previous conviction for "eligible" offense committed while on pretrial bond
4. Time For Detention Hearing. The United States requests the court conduct the
detention hearing,
__ At first appearance
X After continuance of i_ days (not more than 3). r
5. Temporary Detention. The United States request the temporary detention of the
defendant for a period of days (not more than 10) so that the appropriate officials can be
notified since (check 1 or 2, and 3): _
_ 1. At the time the offense was committed the defendant was:
__ (a) on release pending trial for a felony;
___ (b) on release pending imposition or execution of sentence, appeal
of sentence or conviction, or completion of sentence for an offense; -
____ (c) on probation or parole for an offense. _ _
___ 2. The defendant is not a citizen of the U.S. or lawfully admitted for
permanent residence.
__ 3. The defendant may flee or pose a danger to any other person or the
` community.

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6. Other Matters.
Dated:
Respectfully submitted,
COLM F. CONNO · J
Unit d tt_1·ne_ 1 l_.,- [
¥`r___A lu *-7* , »"`. ll fl 6%:5:;;;-F' · In J5;-V
By: V M at at {
Edmond Falg ki
Assistant United Stat? Attorney A

Case 1:08-mj-00037-UNA

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