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

Case 1 :08-cr-00010-JJF Document 6 Filed O2/06/2008 Page 1 of 2
qi if IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA 3
V. g Criminal Action No. 08- [ ¤
GERALD CROOKS )
Defendant. ` )
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendants,
pursuant to 18 U.S.C. § 3142(e) and (f). In support of the motion, the United States alleges the
following: _
1. Eligibility of Case. This case is eligible for a detention order because case involves (check _
all that apply):
‘ L Crime ofviolence (18 U.S.C. § 3156)
____ Maximum sentence life imprisonment or death
__ 10+ year drug offense
i L Felony, with two prior convictions in above categories
L Minor victim; possession or use of firearm, destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250
L Serious risk defendant will flee
L Serious risk obstruction of justice
2. Reason For Detention. The court should detain the defendant(s) because there are no
conditions of release which will reasonably assure (check one or both):
l L Defendant’s appearance as required
L Safety of any other person and the community

Case 1 :08-cr—OOO10—JJF Document 6 Filed O2/06/2008 Page 2 of 2
Q 3. Rebuttable Presumption. The presumption applies because (check one or both):
_ Probable cause to believe def`endant(s) committed 10+ year drug offense or U
firearms offense, 18 U.S.C. § 924(c)
__ 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
_)L After continuance of _L_ days (not more than 3).
5. Temporary Detention. The United States request the temporary detention ofthe 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):
I 1. At the time the offense was committed the defendant was:
n __ (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.
n _ 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.
DATED this 6th day of Februa;r_v , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
i BY: /7L S »··—·-—-—
a H. Eisenstein
Assistant United States Attomey

Case 1:08-cr-00010-JJF

Document 6

Filed 02/06/2008

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Case 1:08-cr-00010-JJF

Document 6

Filed 02/06/2008

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