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 p
UNITED STATES OF AMERICA, ) _
Plaintiff] l
v. l Case No. 07-227M _
IULIO GONZALEZ, l F I D
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· MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to IS U.S.C. § 3142(e) and (t). 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): S
__ Crime ofviolence (IS U.S.C. § 3156)
1 Maximum sentence life imprisonment ordeath
__ 10+ year drug offense
_____ Felony, with two prior convictions in above categories
i Minor victim
_____ Possession! use of Erearm, destructive device or other dangerous weapon
__ Failure to register under 18 U.S.C. § 2250
_____ Serious risk defendant will flee
i Serious risk obstruction of justice

Case 1:07-cr-00158-G|\/IS Document 5 Filed 11/15/2007 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):
L_ Defendants appearance as required
_i 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 prestntnption 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 ( ) with minor victim
_i 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
j 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 [ O 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.
J _’£_ 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
A community.

Case 1:07-cr-00158-G|\/IS Document 5 Filed 11/15/2007 Page 3 of 3
6. Other Matters. ·
DATED this l5th day of November , 2007.
Respectfully submitted,
COLM F. CONNOLLY .
United States Attorney
By:
Keith M. Rosen
Assistant United States Attorney

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