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

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE I
UNITED STATES OF AMERICA, ) l
Plaintiff, i 1
l v. g Criminal Action No. 08- '
RYAN EVANS, g
Defendant. g
MOTION FOR DETENTION HEARING
NOW COMES the United States and respectfully moves for the pretrial detention of the
defendant, pursuant to 18 U.S.C. § 3142(e) and (D. In suppoit of the motion, the United States
alleges the following:
1. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply):
_ Crime ofviolence (18 U.S.C. § 3156)
; Maximum sentence life imprisomnent or death
L 10+ year drug offense ` =
________ Felony, with two prior convictions in above categories i
_ Minor victim
F___X_ Possession! use of firearm, destructive device or other dangerous Weapon
_ Failure to register under 18 U.S.C. § 2250 p
A Serious risk defendant will flee
___ Serious risk obstruction of justice
2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both): i
__)L Defendants appearance as required i
__Q_(_ Safety of any other person and the community l

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3. Rebuttable Presumption. The United States will invoke the rebuttable
presumption against defendant rurder § 3142(e). (If yes) The presumption applies because
l (check one or both): l l
A Probable cause to believe defendant committed 10+ year drug offense or
firearms offense, 18 U.S.C. § 924(c), or a federal crime of terrorism, or a specified
offense ( } with minor victim
_ 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 i_ days (not more than 3).
5. Temporag Detention. The United States requests the temporary detention of
the defendant for a period of _days (not more than 10) so that the appropriate officials can i
be notified since (check 1 or 2, and 3): i
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.
l 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 this 10th day of J anuagy, 2008. i
l
Respectfully submitted, A
COLM F. CONNOLLY
United States Attorney J
BY: méwagf _ l
Robert J. Prett an
Assistant United States Attorney

Case 1:08-cr-00007-SLR

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