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. S Criminal Action N0. 07- 907/W
ROBERT S. BUCKLEY, g
Defendant. g
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3I42(e) and (f). In support of the motion, the United States alleges the
A following:
l. Eligibilig of Case. This case is eligible for a detention order because case involves
(check all that apply): r_______
K Crime ofviolence (18 U.S.C. § 3156) l E D l
I; _—`“_`l
_ Maximum sentence life imprisonment or death I E E EQU?
_ 10+ year drug offense
_ Felony, with two prior convictions in above categories
L Minor victim
_ Possession! use of fireann, destructive device or other dangerous weapon
__ Failure to register under 18 U.S.C. § 2250
A Serious risk defendant will flee
__ Serious risk obstruction of justice

Case 1:07-cr-00156-GIVIS Document 4 Filed 10/26/2007 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):
A Defendant's appearance as required
A_ 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 l42(e). (If yes) The presumption applies because (check
one or both):
E Probable cause to believe defendant committed
a
specified offense ( 2*2* (A { 1,2 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 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):
_ 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 ofthe 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-00156-GIVIS Document 4 Filed 10/26/2007 Page 3 cf 3
DATED this Z (J day of Q 6/A , 2007.
Respectfully submitted,
COLM F,ۤ)NNOLLY
Unite tqtés Att me /
· . I l, .
' mcnd Falgcwski _
Assistant United States Atttu/rney

Case 1:07-cr-00156-GMS

Document 4

Filed 10/26/2007

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Case 1:07-cr-00156-GMS

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Case 1:07-cr-00156-GMS

Document 4

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