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 )
V. 1 A I
` . ) Criminal Action No. 08-05-SLR
. TERRENCE ROSS )
a/ka! “Turl<:man" )
_ 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. Eligibilig of Case. This case is eligible for a detention order because case involves (check
r all that apply):
; Crime ofviolence (18 U.S.C. § 3156)
L Maximum sentence life imprisonment or death ‘
L 10+ year drug offense
i Felony, with two prior convictions in above categories
i(_ Minor victim; possession or use of firearm, destructive device or other
l dangerous weapon; or failure to register under 18 U.S.C. § 2250 _
____)_§___ 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):
I A Defendant’s appearance as required
_____X___ Safety of any other person and the community U

_ Case 1:08-cr-00005-SLR Document 8 Filed O1/31/2008 Page 2 of 2
3. Rebuttable Presumption. The presumption applies because (check one or both):
%Probable cause to believe defendant(s) committed 10+ year drug offense or
firearms offense, 18 U.S.C. § 924(c)
_ Previous conviction for "eligible" offense coimnitted while on pretrial bond
4. Time For Detention Hearing. The United States requests the court conduct the detention
hearing,
_____ At first appearance _
A After continuance of L days (not more than 3).
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):
l. 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.
DATED this 3 lst day of J anum , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: ¥` 2 g
E a H. Eismiistein
· ssistant United States Attorney

Case 1:08-cr-00005-SLR

Document 8

Filed 01/31/2008

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Case 1:08-cr-00005-SLR

Document 8

Filed 01/31/2008

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