Motion for Detention - Page 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

UNITED STATES OF AMERICA

V.

JESUS PEREZ FUENTES

NO. 3:22-MJ-323-BK

 

MOTION FOR PRETRIAL DETENTION

The United States moves for pretrial detention of defendant, Jesus Perez Fuentes, 

pursuant to 18 U.S.C. §3142(e) and (f). 

1. Eligibility of Case. This case is eligible for a detention order because the case 

involves (check all that apply):

 Crime of violence (18 U.S.C. §3156);

 Maximum sentence life imprisonment or death 

 x 10 + year drug offense 

 Felony, with two prior convictions in above categories

 x Serious risk defendant will flee 

 x Serious risk obstruction of justice 

 Felony involving a minor victim

 Felony involving a firearm, destructive device, or any other 

dangerous weapon

 Felony involving a failure to register (18 U.S.C. § 2250) 

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Motion for Detention - Page 2

2. Reason for Detention. The Court should detain the defendant because there are 

no conditions of release which will reasonably assure (check one or both): 

 X the defendant’s appearance as required 

 X Safety of any other person and the community 

3. Rebuttable Presumption. The United States will/will not invoke the rebuttable 

presumption against defendant because (check one or both): 

 x Probable cause to believe the defendants committed 10+ year drug 

offense or firearms offense, 18 U.S.C. §924(c)

 Probable cause to believe defendant committed a federal crime of 

terrorism, 18 U.S.C. §2332b(g)(5)

 Probable cause to believe defendant committed an offense involving 

a minor, 18 U.S.C. §§1201, 2251

 Previous conviction for “eligible” offense committed while on 

pretrial bond

Pursuant to Fed. R. Crim. P. 32.1(a)(6) and 18 U.S.C. § 3142(a), the government 

opposes any motion by the defendant for release pending trial. The defendant cannot 

show by clear and convincing evidence that he is not a flight risk or a danger to the 

community. See Fed. R. Crim. P. 32.1(a)(6). The government asserts that there is no 

condition or combination of conditions that would reasonably assure the defendant’s

presence at trial. 18 U.S.C. § 3142(a)(3). For these reasons, the government asks that the 

defendant be detained pending trial in this case.

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4. Time For Detention Hearing. The United States requests the Court conduct the 

detention hearing, 

 At first appearance 

 x After continuance of 3 days (not more than 3).

DATED this 31st day of March 2022.

Respectfully submitted,

CHAD E. MEACHAM

UNITED STATES ATTORNEY

 

/s/ L. Rachael Jones

L. RACHAEL JONES

Assistant United States Attorney

State Bar of Texas No. 24032481

1100 Commerce Street, Third Floor

Dallas, Texas 75242-1699

Telephone: 214-659-8600

Email: rachael.jones@usdoj.gov

CERTIFICATE OF SERVICE

I hereby certify that I filed this motion with the United States District Clerk for the 

Northern District of Texas and a copy will be provided to the defense counsel of record in 

accordance with the Federal Rules of Criminal Procedure. Certified on this 31st day of 

March 2022.

 

/s/ L. Rachael Jones

L. RACHAEL JONES

Assistant United States Attorney

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