An ex-Finks bikie accused of throwing a loaded gun out of his moving car while being chased by police is in protective custody in jail amid fears for his life, a court has heard.
The threats to Jayden Kierce's safety were revealed during his bail application in Wollongong Local Court on Thursday.
Jayden Kierce, 21, has been in custody for two months after he was arrested and charged with a host of firearms and driving offences stemming from two alleged police pursuits through Blacktown and Lake Illawarra suburbs, less than 12 hours apart.
Documents tendered to court indicate police will allege Kierce, whose licence is currently suspended, drove a Toyota Rav 4 at a top speed of 158km/h during the alleged chase, parts of which occurred in a signposted 70km/h zone in the early hours of Saturday, September 5.
It is alleged Kierce was involved in a second police chase when he returned to the Illawarra on the Saturday afternoon.
Police will allege Kierce drove the same Rav 4 at speed along Port Kembla streets, prompting the second chase, but it too was stopped for safety reasons.
Kierce was arrested at McDonald's at Warrawong a short time later.
Meanwhile, police discovered a loaded, shortened .22 calibre rifle in a front yard near a small child on Horne Street, which they will allege Kierce threw from the vehicle during the pursuit.
Police will use telephone intercepts of Kierce's phone to allege he drove to Blacktown to get a firearm, made previous attempts to get a "pop, pop" (a small firearm) and asked his girlfriend and friend to retrieve the loaded firearm he allegedly threw from the car before police could seize it.
Kierce was already on bail on nine gun charges after being arrested in August following a raid at his dad's Mount Warrigal home and a storage facility at Unanderra.
Police will allege they discovered a homemade gun, as well as an air rifle, ammunition and a Taser. Kierce allegedly admitted he'd made the gun about a year before after watching a video on YouTube.
During a previous search warrant at Kierce's former Cringila home, police found about 300 ecstasy tablets they allege belonged to him for the purpose of supply.
In court on Thursday, Kierce's defence lawyer Caitlin Drabble sought to have her client released from jail, where she said he had been in 24/7 isolation due to threats on his life, making custody particularly "onerous" for him.
Ms Drabble tried to strengthen her client's chances by submitting the prosecution's case was weak as it relied on a police officer's identification of Kierce's "mullet" hairstyle.
She also said the telephone intercepts of Kierce's phone, which he had when arrested, did not prove her client was the person talking on the phone.
Ms Drabble said Kierce had been clean from drugs for two months and was due to become a father for the first time, providing him with clarity into the serious nature of his alleged crimes.
She said those reasons, along with an injury to Kierce's hand; an expected lengthy delay in court proceedings and living with his grandfather, could mitigate the risk of Kierce committing further serious offences and endangering the safety of the community.
While Magistrate Claire Girotto said she sympathised with Kierce's situation in prison, she said she could not be satisfied he would not re-offend as he was already on bail at the time of the alleged police pursuit and because he was facing serious charges, which could land him in prison for 14 years.
In total, Kierce is facing 27 charges. He will reappear in court on November 10.
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