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, )
Plaintiftl g n
v. i Criminal Action No. 07-149 ··· ‘{‘ SLK
DARNELL Moruus, i
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. § 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): i
; Crime ofviolence (18 U.S.C. § 3156) F I I-
__ Maximum sentence life imprisonment or death I IIIQV Q 1 2007 1
J 10+ year drug offense
LIS. DISTRICT COURT I
__ Felony, with two prior convictions in above categori DEBM OF DELAWARE I
__ Minor victim
___ Possession! use of firearm, destructive device or other dangerous weapon
g__ Failure to register under 18 U.S.C. § 2250 T
__\{ 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
_,[_/ Safety of any other person and the community
I
I
I

Case 1 :07-cr-00149-SLR Document 25 Filed 1 1/21 /2007 Page 2 of 3
3. Rebuttable Presumption. The United States will/will not invoke the
rebuttable presumption against defendant under § 3142(e). (If yes) The presumption applies
because (check one or both):
Aobable 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 speciied
offense ( ) with minor victim
_ Previous conviction for "eligible" offense committed while on pretrial bond
4. Time For Detention Hearing. The United States requests the comt conduct
the detention hearing,
; At first appearance
L After continuance of L days (not more than 3).
5. Temporagy 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):
l. 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 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-00149-SLR Document 25 Filed 11/21/2007 Page 3 of 3
6. Other Matters.
S"
DATED this 2/ day Ot 44.~.W£/ , zoofiu 5
n L I Respectfully submitted,
R - COLM F. CONNOLLY
_ y United States Attorney · I
BY:
Keith M. Rosen
Assistant United States Attorney
1

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