USA v. Bridges et al

MOTION

N.D. Cal.January 28, 2016

1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BRIAN STRETCH (CABN 132612) Acting United States Attorney DAVID R. CALLAWAY (CABN 121782) Chief, Criminal Division KATHRYN HAUN (DCBN 484131) WILLIAM FRENTZEN (LABN 24421) STEPHANIE HINDS (CABN 154284) Assistant United States Attorneys 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 Telephone: (415) 436-7200 FAX: (415) 436-7234 Kathryn.haun@usdoj.gov William.frentzen@usdoj.gov RAYMOND N. HULSER (MABN 551350) Chief, Public Integrity Section RICHARD B. EVANS (DCBN 441494) Trial Attorney 1400 New York Avenue, N.W. Washington, D.C. 20005 Telephone: (202) 353-7760 Richard.B.Evans@usdoj.gov Attorneys for United States of America UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION UNITED STATES OF AMERICA v. SHAUN W. BRIDGES (A/K/A “NUMBER 13”), Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. CR 15-0319-001 RS UNITED STATES’ MOTION TO TERMINATE DEFENDANT’S MOTION FOR SELF- SURRENDER AND MOTION TO UNSEAL ARREST WARRANT AND [PROPOSED] ORDER Case 3:15-cr-00319-RS Document 116 Filed 01/28/16 Page 1 of 4 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The government submits the instant filing to terminate the defendant’s pending motion for self- surrender that was filed yesterday. Pursuant to the warrant issued under seal by this Court last night for the arrest of Shaun Bridges, the government hereby apprises the Court that Bridges was successfully arrested without incident this morning. During the execution that warrant, and based on facts that remain under seal before this Court, the government recovered the following items: two “pelican style” bags which contained: identity documents; a passport card in Bridges’ name; a notarized copy of Bridges’ passport; corporate records for at least 3 different offshore entities ranging from Nevis to Belize to Mauritius, including one that Bridges created on October 28, 2015 after he had pleaded guilty in this case; a Samsung cell phone; and a thumb drive. Also located in those bags were documents relating to his wife’s, Ariana Esposito’s, attempts to obtain citizenship in another country. Government agents also found a MacBook with the serial number scratched off, an ipad tucked between a bedroom mattress, and bulletproof vests, at least one of which had Secret Service markings and thus is believed to have been stolen from the government. It should be noted that this was not the sum of evidence agents recovered – rather, the government is only including facts here that it believes are relevant to the defendant’s risk of flight. In light of the defendant’s arrest, and possibly for other reasons contained in filings that remain under seal, BOP has apprised government counsel that it is in the process of redesignating the defendant to another BOP facility. Today, the defendant filed a motion in the District of Maryland for his release from custody and self-surrender to a BOP facility. His motion was denied by Magistrate Judge Sullivan based, in part, on the arrest warrant issued by this Court. Defendant, therefore, remains in the custody of the USMS pending BOP’s redesignation. The government submits that his continued post-sentencing detention in the custody of the USMS is appropriate under 18 U.S.C. § 3143, and all of the foregoing, and given all of the additional facts contained in the under seal filings of yesterday. // // // // // Case 3:15-cr-00319-RS Document 116 Filed 01/28/16 Page 2 of 4 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 In light of the defendant’s arrest, the government moves to unseal the defendant’s arrest warrant. However, the government seeks to have the facts filed in support of that warrant (and the attached Exhibit) remain under seal given that they discuss new criminal conduct that the government is currently investigating. A Proposed Order is attached. DATED: January 28, 2016 Respectfully submitted, BRIAN J. STRETCH Acting United States Attorney ________/s/_________________ KATHRYN HAUN STEPHANIE HINDS WILLIAM FRENTZEN Assistant United States Attorneys RICHARD B. EVANS Public Integrity Section Case 3:15-cr-00319-RS Document 116 Filed 01/28/16 Page 3 of 4 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [PROPOSED] ORDER For the reasons set forth above, the Defendant’s Motion for Early Self-Surrender is DENIED; For good cause shown, the Arrest Warrant is hereby ordered unsealed and the Government’s filing of yesterday in this case shall remain under seal until further order of this Court. ___________________________ HON. RICHARD SEEBORG United States District Judge Case 3:15-cr-00319-RS Document 116 Filed 01/28/16 Page 4 of 4