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

i Case 1 :07-mj—OO237—UNA Document 6 Filed 12/05/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ) F
Plaintiff, 3 E
v. l Case No. 07-237-M A
MARK RYAN HOFFMAN, l
Defendant. 3
Ei
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant, I
pursuant to 18 U.S.C. § 3 l42(e) and (fj. In support of the motion, the United States alleges the I
following: ‘
l. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply): J E
A Crime ofviolence (18 U.S.C. § 3156) Q
____ Maximum sentence life imprisonment or death
__ 10+ year drug offense _
______ Felony, with two prior convictions in above categories
L Minor victim
_ Possession! use of firearm, destructive device or other dangerous weapon
; Failure to register under 18 U.S.C. § 2250
_; Serious risk defendant will flee
____ Serious risk obstruction of justice
2. Reason For Detention. The court should detain defendant because there are Q
no conditions of release which will reasonably assure (check one or both): i
J__{_ Defendant's appearance as required i Q
_X_ Safety of any other person and the community l
..,.... _ ..,.. i

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3. Rebuttable Presumption. The United States WILL invoke the rebuttable 1
presumption against defendant under § 3l42(e). (lf yes) The presumption applies because
(check one or both):
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 II
offense with minor victim (18 U.S.C. § 2252A(a)(2)).
___ Previous conviction for "eligible" offense committed while on pretrial bond ti
4. Time For Detention Hearing. The United States requests the court conduct
the detention hearing,
___ At first appearance
;(_ 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 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; l
___ (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 anoffense;
___ (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.

t Case 1:07-mj—OO237—UNA Document 6 Filed 12/05/2007 Page 3 of 3
6. Other Matters. l
DATED this day of , 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY;
Christophe J. Bur Q
Assistant United States Attorney g

Case 1:07-mj-00237-UNA

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