IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v. No. 21-03017-MJ-WJE
CRAIG ALAN CRAGHEAD,
Defendant.
GOVERNMENT’S MOTION FOR PRETRIAL DETENTION
AND CONTINUANCE OF HEARING DATE
COMES NOW the United States of America, by and through Teresa A. Moore, the Acting
United States Attorney for the Western District of Missouri, and moves the Court, pursuant to Title
18, United States Code, Section 3142, to detain the Defendant, Craig Alan Craghead, without bond
pending trial on the instant matter. The Government also moves for a continuance of three (3)
days for a hearing on this Motion as provided in Title 18, United States Code, Section 3142(f).
A. Grounds for the Motion
In support of the motion to detain, the Government asserts as follows:
(1) There is probable cause to believe that the Defendant committed five felonies, as
an Indictment was returned on or about June 9, 2021, charging the Defendant with two counts of
production of child pornography in violation of 18 U.S.C. 2251(a), cyberstalking in violation of
18 U.S.C. 2261A(2)(B), and two counts of interstate communications with intent to extort.
(2) As charged in Counts 1 and 2, the Defendant faces a minimum term of
imprisonment of fifteen (15) years, a maximum term of imprisonment of thirty (30) years, and a
fine of up to $250,000.
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(3) The Indictment charges the Defendant with a felony “involving a minor victim
under section 2251(a).” 18 U.S.C. § 3142(f)(1)(E).
(4) The Government hereby requests that the Court hold a hearing to determine
whether any condition or combination of conditions will reasonably assure the appearance of the
Defendant, the safety of any other person, or the safety of the community. 18 U.S.C. §
3142(f)(1)(E).
(5) Moreover, the Government asserts that the particular facts of this investigation
show that he is a danger to the community, that he is not amenable to supervision, and is a flight
risk. Specifically, the defendant, who was a teacher and track coach, created a false identity of a
teenage boy to induce two minor females to produce pornographic images of themselves. The
defendant then used a second false identity to extort the minor females into continuing to produce
pornographic images by threatening to disburse the images to their friends and family. The
defendant’s actions caused a great deal of emotional distress to the minor females. A search
warrant to SnapChat revealed the defendant was speaking with multiple minor females and
contained multiple images of self-produced child pornography.
(6) The Government submits that there is clear and convincing evidence that there are
no conditions which the Court could place on the Defendant’s release which would reasonably
assure his future appearance in Court and the safety of the community. See 18 U.S.C. §
3142(g)(1). Among the factors the Court may consider are: (1) the nature and circumstances of
the offense, including whether the offense involves minor; (2) the weight of the evidence; (3) the
history and characteristics of the Defendant, including character, lack of employment, past
conduct, criminal history, history related to drug or alcohol abuse, whether the Defendant was on
probation/parole at the time of the arrest or when the offense occurred, his conduct while on release
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on earlier charges, and also while confined; and (4) the nature and seriousness of the danger to the
community to any person a release of the Defendant might pose. Because of all these
considerations and more, the Government requests that a detention hearing be held and that the
Defendant be detained. See generally, United States v. Sazenski, 806 F.2d 846, 848 (8th Cir.
1986); United States v. Warren, 787 F.2d 1237, 1338 (8th Cir. 1986).
(7) The Government reserves the right at the hearing to further expand its claims that
the Defendant is both a risk of flight and a danger to the community, and that no conditions or set
of conditions can ensure his appearance or the community’s safety. The Government may file an
additional motion detailing additional factors once the pretrial report has been completed, and the
Defendant’s criminal history is more particularly set forth.
(8) The Government requests three (3) days to prepare for the hearing to be set pursuant
to the instant motion. See 18 U.S.C § 3142(f). The Defendant can ask for additional time. Id.
B. Relief: Request for Detention.
For all of the reasons set forth above, the Government requests that the Court detain the
Defendant without bond based on dangerousness and risk of flight, and find that no condition or
set of conditions can both assure the Defendant’s appearance at trial and the safety of the
community.
Respectfully submitted,
Teresa A. Moore
Acting United States Attorney
By /S/
Ashley S. Turner
Assistant United States Attorney
Missouri Bar No. 62314
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing was delivered on June 17,
2021, to the CM-ECF system of the United States District Court for the Western District of
Missouri.
/S/
Ashley S. Turner
Assistant United States Attorney
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