Case 4:18-cr-00049-JED Document 37 Filed in USDC ND/OK on 08/14/20 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OKLAHOMA
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Case No. 18-CR-00049-JED
)
ADRIAN ROBERT JONES, )
)
Defendant. )
MOTION FOR DETENTION HEARING
Pursuant to 18 U.S.C. §§ 3142 (e) and (f), the United States of America hereby
requests that the Court hold a hearing to determine whether any condition, or combination
of conditions, as set forth in 18 U.S.C. § 3142(c), will reasonably assure the appearance of
the Defendant as required and the safety of any other person and the community.
The detention hearing requested herein is sought based upon the following:
☐ The offense charged is a crime of violence.
☐ The Defendant is charged under 18 U.S.C. § 924(c) and is subject to the
rebuttable presumption provisions of 18 U.S.C. § 3142(e).
☐ The offense charged carries a maximum sentence of life imprisonment or
death.
☐ The offense charged carries a maximum term of imprisonment of ten (10)
years or more pursuant to 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.), and the Defendant is subject to the rebuttable presumption
provisions of 18 U.S.C. § 3142(e).
Case 4:18-cr-00049-JED Document 37 Filed in USDC ND/OK on 08/14/20 Page 2 of 3
-2-
☐ The offense charged is a felony which was committed after the Defendant
had been convicted of two or more prior offenses described in 18 U.S.C.
§ 3142(f)(1)(A) through (C), or two or more state or local offenses that
would have been offenses if a circumstance giving rise to federal
jurisdiction had existed, or a combination of such offenses.
☐ The offense charged involves a minor victim. 18 U.S.C. § 3142(f)(1)(E).
☒ The offense charged involves the 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 involves a failure to register under 18 U.S.C. §
2250. 18 U.S.C. § 3142(f)(1)(E).
☒ The existence of a serious risk that the Defendant will flee.
☐ The existence of a serious risk that the Defendant will obstruct or attempt to
obstruct justice, threaten, injure or intimidate, or attempt to threaten, injure
or intimidate, a prospective witness or juror.
☒ Release of the Defendant would create a serious danger to the safety of
other persons or the community. 18 U.S.C. § 3142(b) and (g)(4).
☐ This revocation matter is brought under 18 U.S.C. § 3148. Defendant is
subject to the “penalty” provisions of 18 U.S.C. § 3147, the release
provisions in 18 U.S.C. § 3142(g)(3)(B) and the rebuttable presumptions in
18 U.S.C. § 3148(b).
Respectfully submitted,
R. TRENT SHORES
UNITED STATES ATTORNEY
/s/ Christopher J. Nassar
Christopher J. Nassar, OBA No. 31167
Assistant United States Attorney
110 West Seventh Street, Suite 300
Tulsa, Oklahoma 74119
(918) 382-2700
Case 4:18-cr-00049-JED Document 37 Filed in USDC ND/OK on 08/14/20 Page 3 of 3
-3-
CERTIFICATE OF SERVICE
I hereby certify that on the 14th day of August, 2020, I electronically transmitted
the foregoing document to the Clerk of Court using the ECF System for filing and
transmittal of a Notice of Electronic Filing to the following ECF recipient:
/s/ Christopher J. Nassar
Christopher J. Nassar, OBA No. 31167
Assistant United States Attorney
110 West Seventh Street, Suite 300
Tulsa, Oklahoma 74119
(918) 382-2700