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Motion for Pretrial Detention and Hearing — No. 4:21-mj-07289 (Dkt. 4, E.D. Mo.)

Summary

A Motion for Pretrial Detention and Hearing, Doc. 4 filed November 6, 2021 in the Eastern District of Missouri (Case 4:21-mj-07289-SPM), United States v. Perez Reed, filed by U.S. Attorney Sayler A. Fleming and Assistant U.S. Attorney C. Ryan Finlen. The government says the defendant was charged by complaint that day with interstate transportation of a firearm with intent to commit a felony under Title 18, Section 924(b), supported by an affidavit from FBI Special Agent Kassandra L. McKenzie. It states that he was the last person seen with two victims found shot to death in Kansas and that, when arrested on November 5, 2021, he had a .40 caliber semi-automatic pistol matching shell cases from unsolved shootings in St. Louis in September 2021. It asks for detention under Section 3142(g).

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“Motion for Pretrial Detention and Hearing — No. 4:21-mj-07289 (Dkt. 4, E.D. Mo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/motion-for-pretrial-detention-and-hearing-no-4-21-mj-07289-dkt-4-e-d-m-ea758ad12e/, SHA-256 2d9fd57385a8422b35a415228f0ca9e4842336fb9015620246e0c73358a61988.

Full text

  Case: 4:21-mj-07289-SPM Doc. #: 4 Filed: 11/06/21 Page: 1 of 2 PageID #: 13




                               UNITED STATES DISTRICT COURT
                               EASTERN DISTRICT OF MISSOURI
                                     EASTERN DIVISION

 UNITED STATES OF AMERICA,                           )
                                                     )
                Plaintiff,                           )
                                                     )
 v.                                                  ) No.     4:21 MJ 7289 SPM
                                                     )
 PEREZ REED,                                         )
                                                     )
               Defendant.                            )

                 MOTION FOR PRETRIAL DETENTION AND HEARING

       The United States of America, by and through its Attorneys, Sayler A. Fleming, United

States Attorney for the Eastern District of Missouri, and C. Ryan Finlen, Assistant United States

Attorney for said District, and hereby moves the Court to order Defendant detained pending trial

pursuant to Title 18, United States Code, '3141, et seq.

      As and for its grounds, the United States of America states as follows:

       1.      On November 6, 2021, the United States charged Defendant by complaint with

interstate transportation of a firearm with intent to commit a felony in violation of Title 18, United

States Code, Section 924(b).

       2.      In support of its complaint, the United States included an affidavit from FBI Special

Agent Kassandra L. McKenzie. As Special Agent McKenzie’s affidavit explained, Defendant was

the last person seen with Victim D.I. four days prior to law enforcement finding Victim D.I. shot

to death. Additionally, the Defendant was the last person seen with Victim R.F. four days before

law enforcement found Victim R.F. shot to death.

       3.      When law enforcement arrested Defendant of November 5, 2021, Defendant was

in possession of a .40 caliber semi-automatic pistol. That is the same caliber of firearm that matches

shell cases found at unsolved shootings across St. Louis during September 2021. At least six
   Case: 4:21-mj-07289-SPM Doc. #: 4 Filed: 11/06/21 Page: 2 of 2 PageID #: 14




victims were shot, many fatally, with the same firearm. Defendant lived in St. Louis, but had

traveled from St. Louis to Kansas during when Victims D.I. and R.F. were shot in Kansas with a

firearm consistent with the .40 caliber firearm used in the St. Louis shootings.

         4.     Pursuant to Title 18, United States Code, Section 3142(g), the weight of the

evidence against Defendant, the Defendant’s history and characteristics, and the nature and

seriousness of the danger to any person or the community that would be posed by Defendant’s

release warrant Defendant’s detention pending trial.

         WHEREFORE, the United States requests this Court to order Defendant detained prior to

trial.

                                                       Respectfully submitted,

                                                       SAYLER A. FLEMING
                                                       United States Attorney

                                                       s/ C. Ryan Finlen
                                                       C. RYAN FINLEN, #6305918(IL)
                                                       Assistant United States Attorney

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