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

Case 1 :07-cr—QQ§[,,@?;a}JJi}/wa/DbCld1}Ie‘¤t 4 (0 *·1»?vI'ed61#l/O’6/@{97 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA )
Plaintiff, l 3
v. ) Case No. 07- Q IQ W1
COLLIN ROMEO COLE, g
Defendant. 3
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: _
1. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply):
___ Crime of violence (18 U.S.C. § 3156) ? E D
__ Maximum sentence life imprisonment or death i
l my W 5 2007
___ 10+ year drug offense J
__)_§__ Felony, with two prior convictions in above categori s D%§>§ Tégg§£\£§gE
____ Minor victim
___ Possession! use of firearm, destructive device or other dangerous weapon
_____ Failure to register under 18 U.S.C. § 2250 i
;(_ 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):
lm Defendants appearance as required
_X_ Safety of any other person and the community
l

Case 1:07-cr—00162—JJF Document 4 Filed 11/06/2007 Page 2 of 3
3. Rebuttable Presumption. The United States `WILL NOT invoke the
rebuttable presumption against defendant under § 3142(e). (If yes) The presumption applies
because (check one or both):
__ 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 ( l 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). -
5. Temporary Detention. The United States requests the temporary detention of
the defendant for a period of _______days (not more than l0) so that the appropriate officials can
be notified since (check I or 2, and 3): 3
1. At the time the offense was committed the defendant was:
i _____ (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; l
____ (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.

Case 1:07-cr—00162—JJF Document 4 Filed 11/06/2007 Page 3 of 3
6. Other Matters.
DATED this @1% day of , 2001.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY; gg · 51/MQI,
Christopher J. Burke
Assistant United States Attorney

Case 1:07-cr-00162-JJF

Document 4

Filed 11/06/2007

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Case 1:07-cr-00162-JJF

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Case 1:07-cr-00162-JJF

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