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
UNITED STATES OF AMERICA, )
Plaintiff] g
v. g Criminal Action No. 07- .:796 'M
I REMIGIO CAMACHO, i
l Defendant. i
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. Eligibility of Case. This case is eligible for a detention order because case involves
(check all that apply):
____ Crime ofviolence (18 U.S.C. § 3156)
I A Maximum sentence life imprisonment or death
__Z§_(_______ l0+ year drug offense
_ Felony, with two prior convictions in above categories
_ Minor victim
L Possession! use of firearm, destructive device or other dangerous weapon
_ Failure to register Luider 18 U.S.C. § 2250 l
L Serious risk defendant will flee
_ Serious risk obstruction of justice

Case 1:07-cr—OO166—JJF Document 4 Filed 12/12/2007 Page 2 of 3
2. Reason For Detention. The court should detain defendant because there are no
conditions of release which will reasonably assure (check one or both):
__; Defendant's appearance as required
j_(__ Safety of any other person and the community
3. Rebuttable Presumption. The United States will/will not invoke the rebuttable
presumption against defendant under § 3 142(e). (If yes) The presumption applies because (check
one or both): I
_)L_ 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 t ) 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 __3__ days (not more than 3). i
5. Temporary Detention. The United States request the temporary detention of the
defendant for a period of 3 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. p
L 3. The defendant may flee or pose a danger to any other person or the
community.

Case 1:07-cr—OO166—JJF Document 4 Filed 12/12/2007 Page 3 of 3
6. Other Matters.
DATED this 12th day 0f December , 2007.
Respectfully submitted,
COLM F. CONNOLLY
. United States Attorne
-
www
David L, Hall .
_ , Assistant United States Attorney

Case 1:07-cr-00166-JJF

Document 4

Filed 12/12/2007

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Case 1:07-cr-00166-JJF

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Case 1:07-cr-00166-JJF

Document 4

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