Case 2:18-mj-01396-RCM Document 3 Filed 10/29/18 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA
Magistrate No. 18-1396M

V.

ROBERT BOWERS

REQUEST FOR DETENTION
AND NOW comes the United States of America, by its attorneys, Scott W. Brady,
United States Attorney for the Western District of Pennsylvania, and Troy Rivetti and Soo C. Song,
Assistant United States Attorneys for said District, and, pursuant to 18 U.S.C. §§ 3142(e) and (f),
hereby requests detention of the above-named defendant, and sets forth the following material
factors in support thereof:
IZI

1.

That no condition or combination of conditions will reasonably assure
the appearance of defendant as required and the safety of any other
person and the community because:

IZI

a.

Defendant is a danger to any other person or the community,
and/or;

IZI

IZI

b.

Defendant is a flight risk.

2.

That the government is entitled to a detention hearing based upon the
following:

IZI

a.

Defendant is charged with a crime of violence as defined in 18
U.S.C. § 3156; or

IZI

b.

Defendant is charged with an offense for which the maximum
sentence is life imprisonment or death; or

 Case 2:18-mj-01396-RCM Document 3 Filed 10/29/18 Page 2 of 4

0

C.

Defendant is charged with an offense for which a maximum term
of imprisonment of 10 years or more is prescribed in the
Controlled Substances Act (21 U.S.C. § 801 et seq.), the
Controlled Substances Import and Export Act (21 U.S.C. § 951 et
seq.), or the Maritime Drug Law Enforcement Act (46 U.S.C.
App. § 1901 et seq.); or

D

d.

Defendant is presently charged with a felony and has been
convicted of two or more offenses described in subparagraph a-c
above, or two or more State or local offenses that would have been
offenses described in subparagraphs a-c above if a circumstance
giving rise to Federal jurisdiction had existed, or a combination of
such offenses; or

•

e.

Defendant is charged with a felony which 1s not a cnme of
violence, but which involves: a minor victim, possession or use
of a firearm or destructive device (as those terms are defined in 18
U.S.C. § 921) or any other dangerous weapon, or the failure to
register under 18 U.S.C. § 2250 (as required by the Sex Offender
Registration and Notification Act); or

IZI

f.

That a serious risk exists that defendant will flee; or

IZI

g.

That a serious risk exists that defendant will obstruct or attempt to
obstruct justice, or threaten, injure, or intimidate, or attempt to
threaten, injure, or intimidate, a prospective witness or juror.

 Case 2:18-mj-01396-RCM Document 3 Filed 10/29/18 Page 3 of 4

•

3.

That a rebuttable presumption arises that no condition or combination
of conditions will reasonably assure the safety of any other person and
the community, in that the present case involves an offense described in
paragraphs 2a-2e above and:

•

a.

Defendant has been convicted of a Federal offense described in
subsection 2a-2e above, or of a State or local offense that would
have been an offense described in subsection 2a-2e above if a
circumstance giving rise to Federal jurisdiction had existed; and

•

b.

The offense described in paragraph 3a above was committed while
defendant was on release pending trial for a Federal, State or local
offense; and

•

c.

A period of not more than five years has elapsed since the date of
defendant's conviction or release from imprisonment for the
offense described in paragraph 3a, whichever is later.

~

4.

That a rebuttable presumption arises that no condition or combination
of conditions will reasonably assure the appearance of defendant as
required and the safety of the community, in that there is probable cause
to believe that:

•

a.

Defendant committed an offense for which a maximum term of
imprisonment of ten years or more is prescribed in the Controlled
Substances Act (21 U.S.C. § 801 et seq.), the Controlled
Substances Import and Export Act (21 U.S.C. § 951 et seq.), the

 Case 2:18-mj-01396-RCM Document 3 Filed 10/29/18 Page 4 of 4

Maritime Drug Law Enforcement Act (46 U.S.C. App. § 1901 et
@:.);or
IZI

b.

Defendant committed an offense under 18 U.S.C. §§ 924(c),
956(a), or 2332b, or an offense involving a minor victim under
Sections
2251A,

1201, 1591, 2241, 2242, 2244(a)(l), 2245, 2251,
2252(a)(l),

2252(a)(2),

2252(a)(3),

2252A(a)(l),

2252A(a)(2), 2252A(a)(3), 2252A(a)(4), 2260, 2421, 2422, 2423,
or 2425 of Title 18.

D

5.

A Continuance of _ _ _ _ _ day(s) is requested for the detention
hearing based upon the following reasons:

•

6.

Good cause for a continuance in excess of three days exists in that:

Respectfully submitted,
SCOTT W. BRADY
United States Attorney

By:

TR0{~7L
Assistant U.S. Attorney
PA ID No. 56816

By:

~c~

SOOC. SONG
Assistant U.S. Attorney
DC ID No. 457268