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

Gggagse 1 Dogypaentgq / AP?2/2007 Page 1 of 3
{C/Q)
IN THE UNITED STATES DISTRICT COURT
FOR 'I`l-IE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, 3
v. g Criminal Action No. 07- l‘1°e M
MANUEL MEDLEY, I
Defendant. {
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 (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 of violence (18 U.S.C. § 3156)
___ Maximum sentence life imprisonment or death
_)L 10+ year drug offense
__ Felony, with two prior convictions in above categories
__ Minor victim _,
_X_ Possession! use of firearm, destructive device or other dangerous weapon
__ Failure to register under 18 U.S.C. § 2250
_)L_ 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):
_X_ Defendant's appearance as required
_2(__ Safety of any other person and the community

Case 1:07-cr-00140-GIVIS Document 2 Filed 10/22/2007 Page 2 of 3
3. Rebuttable Presumgtion. The United States will invoke the rcbuttable
presumption against defendant under § 3 l 42(e). (lf yes) The presumption applies because
(check one or both):
j_<__ Probable cause to believe defendant committed 10+ year drug offense or A
firearms offense, 18 U.S.C. § 924(c), or a federal crime of terrorism, or a specified
offense 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
_X_ After continuance of ;_ 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):
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. 4.
___ 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-00140—Gl\/IS Document 2 Filed 10/22/2007 Page 3 of 3
DATED this 22nd day of October, 2007,
Respectfully submitted,
COLM F. NNOLLY
United St s Attorney
BY:
S eede
As t United States Attorney

Case 1:07-cr-00140-GMS

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Filed 10/22/2007

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Case 1:07-cr-00140-GMS

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Case 1:07-cr-00140-GMS

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