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

Case 1 :07-mj-00198 Document 4 Filed 10/19/2007 Page 1 of 3 I
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, I ) ‘
Plaintiff l I
)
v. g Cr1m1nal Action No. @1, , Q % M _
DOUGLAS MOON, )
Defendant. 5
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3l42(e) and (i). In support of the motion, the United States alleges the
V following:
1. Eligibilig 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
I __;_ 10+ year drug offense I
___ Felony, with two prior convictions in above categories
___ Minor victim
___ Possession! use of firearm, destructive device or other dangerous weapon
___ Failure to register under 18 U.S.C. § 2250 `
___Q{_ Serious risk defendant will flee F | |_ E D
__i{__ Serious risk obstruction of justice `
OCT l 9 2007
`E
illitiéillilttfllllt __,___,_;

Case 1 :07-mj-00198 Document 4 Filed 10/19/2007 Page 2 of 3 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): T
__Q_(__ Defendanfs appearance as required T
_;__ Safety of any other person and the community A
I 3. Rebuttable Presumption. The United States will invoke the rebuttable
prestunption against defendant under § 3 l42(e). The presumption applies because (check one or
both):
_)g_ Probable cause to believe defendant committed 10+ year drug offense
____ Previous conviction for "eligible" offense committed while on pretiial
bond
4. Time For Detention Hearing. The United States requests the court conduct
l the detention hearing, V
__ At first appearance
_;_ 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):
n l. At the time the offense was committed the defendant was:
___ (a) on release pending trial for a felony; V
__ (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.

Case 1:07-mj—OO198 Document 4 Filed 10/19/2007 Page 3 of 3
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.
DATED thisig day of October , 2007.
- Respectfully submitted,
COLM F. CONNOLLY
Un` d States At orney
BY:
Lesley . Wolf
Assistant United States Attorney

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