Free Sealed Motion - District Court of Delaware - Delaware

r Case 1 :O6—cr-00020-SLR Document 19 Filed O9/27/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
OF DELAWARE
UNITED
: Filed Ex Parte and Under Seal
Plaintiff 1
l v. Criminal Action No. 06-20-SLR
TANY A BOWIE,
Defendant. I
MOTION FOR REVOCATION OF PRETRIAL RELEASE
NOW COMES the United States of America, by and through its undersigned attorneys,
Colm F. Connolly, United States Attorney for the District of Delaware, and Beth Moskow-
Sclmoll, Assistant U.S. Attorney, and hereby respectfully moves, pursuant to 18 U.S.C. § 3148,
for the revocation of the defendant’s pretrial release status. This motion is based upon the
following facts:
1. The defendant appeared for her initial appearance before the Magistrate Judge on
March 8, 2006, and was placed on pretrial release supervision.
I 2. On August 16, 2006, the defendant appeared before this Court and entered a guilty
plea to two counts of passing counterfeited securities in violation of 18 U.S.C. § 5l3(a). The
Court permitted the defendant to remain on release status pending sentencing.
3. One of the conditions of the defendant’s release was that she not commit another
Federal, state or local crime. It is this condition that the United States respectfully submits the
defendant has violated.
4. A fraud investigator for one of the victims of the crime to which the defendant
pleaded guilty, the Marniaxx Corporation, notified myself and the case agent, U.S. Secret Service

Case 1:06-cr-00020-SLR Document 19 Filed O9/27/2006 Page 2 of 3
Special Agent Michael Armstrong, that she had identified several additional counterfeit checks
that had been passed by the defendant at Marshalls stores since the defendant entered her guilty
plea. In passing these additional counterfeit checks, the defendant used the names "Aiana Yates"
and "Stormi Young." The fraud investigator identified the checks as having been written by the
defendant based on the defendant’s distinctive handwriting.
5. On September 27, 2006, the fraud investigator forwarded the following items to
Special Agent Armstrong and me: (a) a photograph of the defendant writing a check at a
Marshalls store on September l0, 2006, the same date that "Storn1iYoung" passed three
counterfeit checks at that Marshalls store; and (b) photographs of the defendant in a Marshalls
store on August l2, 2006, the same date that “Aiana Yates" passed two counterfeit checks at that
Marshalls store. l l
6. Both the fraud investigator and Special Agent Michael Armstrong are prepared to
testify to the facts contained in this motion. The evidence supporting this motion has been sent A
to the U.S. Probation Office.
WHEREFORE, for all the foregoing reasons, the United States respectfully requests that
a warrant be issued for Tanya Bowie and that she appear before the Court for a Revocation
Hearing to determine whether she is in violation of the conditions of her release.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: ` N 2. QEWQL/LQ Q Q;
Beth Moskow-Schnoll
Dated: September 27, 2006 Assistant United States Attorney
A 2

Case 1:06-cr-00020-SLR Document 19 Filed O9/27/2006 Page 3 of 3
ORDER
Considered and so ordered this [0% day of O¤»j@ bw , 2006.
Honorable Sue Lgobinson
Chief U.S. District Judge
3