Esta Margarita Volksen was indicted on charges relating to possession and distribution of cocaine. After a hearing, the district court ordered Volksen to be detained without bond until trial. We affirm.

Volksen was charged in ten counts of a fourteen-count indictment with conspiracy to possess with intent to distribute cocaine, distribution of cocaine, and use of communication facilities to commit these offenses. At Volksen's first appearance before the magistrate, the government requested a detention hearing, and the magistrate held the hearing several days later. After the hearing, the magistrate ordered Volksen detained until trial because the magistrate found probable cause to believe Volksen committed an offense for which the maximum term of imprisonment is ten years or more and because Volksen was involved in drug trafficking. Volksen filed a motion in the district court to revoke the magistrate's order, and the district court ordered the magistrate to hold an additional hearing. After this hearing, the magistrate declined to revoke his previous detention order because Volksen had not rebutted the presumption established by the Bail Reform Act of 1984, 18 U.S.C. Sec. 3142(e)1 that no condition or combination would assure the safety of the community if she were released pending trial.

Volksen then filed a motion in the district court requesting a hearing de novo before the district judge to reconsider the magistrate's detention order. The district court granted this motion and held the requested hearing. After the hearing, the district court affirmed the magistrate's order of detention. In addition to affirming the magistrate's findings of fact, the district court found that Volksen likely would flee the jurisdiction if she were released pending trial. Volksen appeals.

Volksen first contends that the government failed to comply with relevant provisions of the Bail Reform Act of 1984 in requesting the magistrate to order her detained pending trial. Specifically, Volksen contends that she was not given adequate notice of the government's intention to seek pretrial detention and that the government failed to make a written motion to hold a detention hearing. Volksen also contends, citing United States v. Chimurenga, 760 F.2d 400 (2d Cir.1985), that because of the government's procedural errors, the rebuttable presumption against pretrial release established by 18 U.S.C. Sec. 3142(e) should not arise.

These contentions are meritless. Volksen's initial appearance before the magistrate occurred on March 1, 1985, and the magistrate appointed counsel for her at that time. When the government made its oral motion for pretrial detention at a hearing on March 6, Volksen did not object or seek a continuance. Volksen's counsel did not seem surprised by the motion and indicated that he understood the rebuttable presumption provisions of Section 3142(e). Contrary to Volksen's contention, 18 U.S.C. Sec. 3142(f)(1) does not expressly require the government to make a written motion for pretrial detention. Finally, Volksen's reliance on the Chimurenga case is misplaced. That case held that section 3142(e)'s rebuttable presumption does not apply where the government has not yet charged the accused with an offense enumerated in section 3142(e). Chimurenga is inapplicable here because Volksen had been charged with the drug offenses at the time of the detention hearing.

Volksen next contends that the district court's finding that no condition or combination of conditions will reasonably assure the safety of any other person and the community was not supported by clear and convincing evidence because the government presented no evidence as to the various conditions of bail available. This contention is meritless. Because drug crimes were charged in the indictment, section 3142(e)'s rebuttable presumption against pretrial release applied and the magistrate and the district court ruled that Volksen did not present evidence sufficient to rebut this presumption. In addition, the magistrate and the district court found that the government evidence went beyond the presumption to show that Volksen was a narcotics trafficker.

The magistrate's and district court's findings are clearly correct and their rulings are supported by clear and convincing evidence. The government presented evidence of Volksen's participation in numerous drug and unlawful firearms transactions. Although Volksen presented the testimony of her friends and neighbors that she would not flee or sell drugs if released on bond, the government presented overwhelming evidence that Volksen had dealt heavily in drugs before her arrest on state drug charges in June 1984. Finally, the government presented evidence that Volksen was associated with the Bandido motorcycle gang in Houston and that Volksen had told an informant that she would flee to Canada rather than go to prison. Contrary to Volksen's contention, the magistrate and the district court considered the various factors outlined in section 3142(g).2 The magistrate and the district court committed no error in ruling that the government presented sufficient evidence to support an order of pretrial detention.

Finally, Volksen presents several constitutional challenges to the Bail Reform Act of 1984. Because these arguments are not fully briefed, but are merely stated in conclusory fashion, we need not and do not address their merit. For the foregoing reasons, the judgment of the district court is

AFFIRMED.