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

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K700 I [JD
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE .
UNITED STATES OF AMERICA, )
Plaintiff, g ·
v. ) Criminal Action N0. 07- In
I JOHN E. MANNTNG, ) FILED UNDER SEAL
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. § 3 l42(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 ofviolence (18 U.S.C. § 3156)
_ Maximum sentence life imprisonment or death
_ 10+ year drug offense
_ Felony, with two prior convictions in above categories
__X___ Minor victim l
__ 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
no conditions of release which will reasonably assure (check one or both):
_ Defendants appearance as required i
__2(_ Safety of any other person and the community l

Case 1 :07-cr-00151-SLR Document 4 Filed 10/26/2007 Page 2 of 3
3. Rebuttable Presumption. The United States WILL NOT- invoke the e
rebuttable presumption against defendant under § 3 l 42(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
l offense 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, -
l _ At first appearance
_)L After continuance of L 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:
___ (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; I i
1 (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. i
_ 3. The defendant may flee or pose a danger to any other person or the community.

Case 1:07-cr-00151-SLR Document 4 Filed 10/26/2007 Page 3 of 3
6. Other Matters.
DATED this 26th day of October , 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
/ ~ Z t . /
BYE 4A(1.aAlAW1.iA.4A ·· J n
Christopher J. Bu
Assistant United States Attorney
I

Case 1:07-cr-00151-SLR

Document 4

Filed 10/26/2007

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Case 1:07-cr-00151-SLR

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Case 1:07-cr-00151-SLR

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