NOTICE OF REQUEST FOR DETENTION filed by Plaintiff USA as to Defendant Arman Manukyan — USA v. Manukyan (Dkt. 3)

Record facts

Summary

The government's notice of request for detention in United States v. Arman Manukyan, No. 2:20-mj-03710-DUTY, in the U.S. District Court for the Central District of California, filed August 10, 2020 as Doc. 3. On a checklist form, the government marks a request for pretrial detention under § 3142(e) because no conditions will reasonably assure the defendant's appearance or the safety of other persons and the community. It also marks that it is entitled to a detention hearing under § 3142(f) based on a serious risk that the defendant will flee and a serious risk of obstruction of justice or intimidation of witnesses or jurors. The continuance sections are left blank. The five-page notice is signed by Assistant United States Attorney Andrew Brown of the Major Frauds Section.

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NICOLA T. HANNA
United States Attorney 
BRANDON D. FOX
Assistant United States Attorney 
Chief, Criminal Division 
ANDREW BROWN (Cal. Bar No. 172009) 
Assistant United States Attorney 
Major Frauds Section 
1100 United States Courthouse 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-0102 
Facsimile: (213) 894-6269 
E-mail: 
andrew.brown@usdoj.gov 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
UNITED STATES DISTRICT COURT 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
UNITED STATES OF AMERICA, 
Plaintiff,
v.
ARMAN MANUKYAN, 
Defendant.
No.
GOVERNMENT’S NOTICE OF REQUEST 
FOR DETENTION 
Plaintiff, United States of America, by and through its counsel 
of record, hereby requests detention of defendant and gives notice 
of the following material factors: 
1.
Temporary 10-day Detention Requested (§ 3142(d)) on the
following grounds:
a. present offense committed while defendant was on
release pending (felony trial), (sentencing),
(appeal), or on (probation) (parole); or

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PM
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LODGED
CLERK, U.S. DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
BY: ___________________ DEPUTY

08/10/2020
AP
Case 2:20-mj-03710-DUTY     Document 3     Filed 08/10/20     Page 1 of 5   Page ID #:24

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  b. defendant is an alien not lawfully admitted for 
permanent residence; and 
 
  c. defendant may flee; or 
 
  d. pose a danger to another or the community. 
X 
  2. Pretrial Detention Requested (§ 3142(e)) because no 
condition or combination of conditions will reasonably 
assure:
X 
  a. the appearance of the defendant as required; 
X 
  b. the safety of any other person and the community. 
 
  3. Detention Requested Pending Supervised Release/Probation 
Revocation Hearing (Rules 32.1(a)(6), 46(d), and 18 U.S.C. 
§ 3143(a)): 
 
 a. defendant cannot establish by clear and convincing 
evidence that he/she will not pose a danger to any 
other person or to the community; 
 
  b. defendant cannot establish by clear and convincing 
evidence that he/she will not flee. 
 
  4. Presumptions Applicable to Pretrial Detention (18 U.S.C. 
§ 3142(e)): 
 
  a. Title 21 or Maritime Drug Law Enforcement Act 
(“MDLEA”) (46 U.S.C. App. 1901 et seq.) offense with 
10-year or greater maximum penalty (presumption of 
danger to community and flight risk); 
 
  b. offense under 18 U.S.C. §§ 924(c), 956(a), 2332b, or 
2332b(g)(5)(B) with 10-year or greater maximum 
penalty (presumption of danger to community and 
flight risk); 
Case 2:20-mj-03710-DUTY     Document 3     Filed 08/10/20     Page 2 of 5   Page ID #:25

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  c. offense involving a minor victim under 18 U.S.C. 
§§ 1201, 1591, 2241, 2242, 2244(a)(1), 2245, 2251, 
2251A, 2252(a)(1)-(a)(3), 2252A(a)(1)-2252A(a)(4), 
2260, 2421, 2422, 2423 or 2425 (presumption of danger 
to community and flight risk); 
 
  d. defendant currently charged with an offense described 
in paragraph 5a - 5e below, AND defendant was 
previously convicted of an offense described in 
paragraph 5a - 5e below (whether Federal or 
State/local), AND that previous offense was committed 
while defendant was on release pending trial, AND the 
current offense was committed within five years of 
conviction or release from prison on the above-
described previous conviction (presumption of danger 
to community). 
X 
  5. Government Is Entitled to Detention Hearing Under 
§ 3142(f) If the Case Involves: 
 
  a. a crime of violence (as defined in 18 U.S.C. 
§ 3156(a)(4)) or Federal crime of terrorism (as 
defined in 18 U.S.C. § 2332b(g)(5)(B)) for which 
maximum sentence is 10 years’ imprisonment or more; 
 
  b. an offense for which maximum sentence is life 
imprisonment or death; 
 
  c. Title 21 or MDLEA offense for which maximum sentence 
is 10 years’ imprisonment or more; 
Case 2:20-mj-03710-DUTY     Document 3     Filed 08/10/20     Page 3 of 5   Page ID #:26

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  d. any felony if defendant has two or more convictions 
for a crime set forth in a-c above or for an offense 
under state or local law that would qualify under a, 
b, or c if federal jurisdiction were present, or a 
combination or such offenses; 
 
  e. any felony not otherwise a crime of violence that 
involves a minor victim or the possession or use of a 
firearm or destructive device (as defined in 18 
U.S.C. § 921), or any other dangerous weapon, or 
involves a failure to register under 18 U.S.C. 
§ 2250; 
X 
  f. serious risk defendant will flee; 
X 
  g. serious risk defendant will (obstruct or attempt to 
obstruct justice) or (threaten, injure, or intimidate 
prospective witness or juror, or attempt to do so). 
 
  6. Government requests continuance of  
 days for 
detention hearing under § 3142(f) and based upon the 
following reason(s):
//
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//
//
//
//
Case 2:20-mj-03710-DUTY     Document 3     Filed 08/10/20     Page 4 of 5   Page ID #:27

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  7. Good cause for continuance in excess of three days exists 
in that: 
Dated: August 10, 2020 
Respectfully submitted, 
NICOLA T. HANNA
United States Attorney 
BRANDON D. FOX
Assistant United States Attorney 
Chief, Criminal Division 
Andrew Brown 
       
 
ANDREW BROWN 
Assistant United States Attorney 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
Case 2:20-mj-03710-DUTY     Document 3     Filed 08/10/20     Page 5 of 5   Page ID #:28

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