Court filing

Government’s Sentencing Statement for Defendant Jon Hallford — United States v. Hallford (Dkt. 88, D. Colo.)

Summary

The Government's Sentencing Statement for Defendant Jon Hallford in United States of America v. Jon M. Hallford, Criminal Case No. 24-cr-00113-NYW, in the U.S. District Court for the District of Colorado, filed March 6, 2025. The United States asks the Court to impose a 180-month (15-year) term of imprisonment, the maximum contemplated in the plea agreement and consistent with the Presentence Report. A footnote states that the Court rejected the binding plea agreement on February 24, 2025 and that the defendant elected on March 5, 2025 to proceed under Rule 11(c)(1)(B). The statement lists sentencing enhancements it says apply, including ten or more victims and sophisticated means, and alleges that the Hallfords submitted false death certificates to the State of Colorado.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Filed March 6, 2025 in Jon M. Hallford; one of 24 filings from this case.

Record facts

Court	U.S. District Court for the District of Colorado
Filed	2025-03-06

Cite this document

“Government’s Sentencing Statement for Defendant Jon Hallford — United States v. Hallford (Dkt. 88, D. Colo.).” U.S. District Court for the District of Colorado, No. 1:24-cr-00113, Doc. 88, filed 2025-03-06. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-carie-l-hallford-cod-233031/2025-03-06-gov-uscourts-cod-233031-88-0-doc-88/, SHA-256 8b473a82ffe7b23833a78d484992bc62120c91609c226c0c66819106c2f7f4ec.

Full text

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 1
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO

Criminal Case No. 24-cr-00113-NYW

UNITED STATES OF AMERICA,

Plaintiff,

1. JON M. HALLFORD,

Defendant.

GOVERNMENT’S SENTENCING STATEMENT FOR DEFENDANT JON HALLFORD

The United States of America respectfully files this Sentencing Statement for

Defendant Jon Hallford.

The Government requests that the Court sentence the Defendant to a 180-month

(15-year) term of imprisonment, which is the maximum amount of prison time

contemplated in the parties’ plea agreement1 (Jon Hallford Plea Agreement, at 3 [#52])

and consistent with the recommendation contained within the Presentence Report

(“PSR”), Exhibit A, R-1 [#73-1].

1
On February 24, 2025, the Court rejected the parties’ plea agreement and stated that it
would not be bound by the parties’ stipulated sentencing range (between 78 months to
180 months imprisonment) pursuant to Rule 11(c)(1)(C). [#79, Minute Order]. On March
5, 2025, the Defendant elected to proceed pursuant to Rule 11(c)(1)(B), as confirmed in
the parties’ Plea Supplement. [#85]. Accordingly, the Court may sentence the Defendant
up to the statutory maximum of 20 years imprisonment for the present offense. However,
because the Government agreed as part of the original plea agreement not to seek a
sentence higher than 15 years’ imprisonment, the Government remains consistent with
this position and recommends a 15 years of imprisonment.

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 2
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Here, the PSR states that the advisory guideline range is 78 to 97 months

imprisonment. Id. The matter before the Court is not an ordinary case, however, and the

extraordinary harm suffered by the victims and community in this case warrant a

significantly higher sentence than recommended by the guidelines. By separate pleading,

the Government sets forth the basis upon which it seeks a sentence above the applicable

guidelines. In order to impose a 180-month sentence, the Court would need to find that

an upward variance and/or upward departure from the guidelines is appropriate.

Sentencing Factors 18 U.S.C. § 3553(a)

(1) Nature and Circumstances of Offense

The Defendant pled guilty to Count 11 of the Indictment charging him with

Conspiracy to Commit Wire Fraud in violation of 18 U.S.C. § 1349. The PSR provides a

detailed and comprehensive review of the pertinent facts describing the Defendant’s role

and participation in the underlying offense and thus, the Government does not repeat all

of the facts here.2 PSR ¶¶ 10-45. It is important to note that the Defendant has stipulated

that the underlying facts are true and correct as set forth in his Plea Agreement and

incorporated within the PSR as part of relevant conduct. PSR ¶ 9. Further, the Defendant

has agreed as part of the sentencing guidelines calculations that various sentencing

enhancements apply including: ten or more victims, sophisticated means, conscious or

reckless risk of death or serious bodily injury, vulnerable victim, and abuse of trust. PSR

¶¶ 85-87, 89-90.

2 The Government has contemporaneously filed a Motion Seeking an Upward Variance
Pursuant to 18 U.S.C. § 3553(a) and/or an Upward Departure Pursuant to U.S.S.G. §
2B1.1 and § 5K2.0. Within such Motion, the Government discusses facts and information
relevant to the offense conduct. Here, the Government incorporates by reference such
pleading and any pertinent facts set forth therein.

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 3
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When evaluating the nature of the offense conduct, it is important to keep in mind

the multiple ways in which the Hallford’s scheme harmed others.

The easiest harm to quantify is the economic harm. The scheme defrauded

approximately 190 funeral-home victims of monetary funds. Put simply, the Defendant

knowingly failed to provide proper cremations or burial services for 190 bodies despite

contractually promising the families otherwise. PSR ¶ 22. Instead, the victims paid

approximately $189,371 in aggregate for funeral services which the Defendants failed to

ever provide. PSR ¶ 145. The Defendant and his wife often lied to the victims and next of

kin by providing concrete mix instead of cremains. PSR ¶ 26. In this respect, the crime

was a classic bait and switch swindle. As a result, the Defendants’ business, Return to

Nature, reaped an unjust financial windfall for services which it never rendered -- all to

the economic detriment of the victims.

The economic harm also included the Hallfords’ efforts to deceive the U.S. Small

Business Administration (“SBA”) out of approximately $882,300 in Covid-relief funds

through fraudulent loan statements and certifications. Despite receiving these funds

through November 2021—well after the date by which bodies were accumulating at

Penrose—the Hallfords did not use any of these funds to remedy past wrongs or to treat

victims with dignity, but they instead converted much of the money to satisfy personal

greed. For example, they misused the loan proceeds to purchase a $92,000 vehicle along

with spending it on frivolous personal expenditures. PSR ¶ 42. In a May 9, 2022 text

message, Jon Hallford reflected on his personal spending of COVID-relief loans, and

ignoring the mounting horror at Penrose, still did not consider doing the right thing but

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 4
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instead weighed only the options of personal extravagance and building “a several

hundred dollar nest egg”:

(Government Exhibit 1, p. 1). Ultimately, the SBA (i.e. – taxpayers) was deprived of these

funds, and it is unlikely to recoup such losses given the Defendant’s indigency and

imminent prison sentence.

The Hallfords’s crimes also resulted in harms that were difficult or impossible to

quantify in monetary terms. The Hallfords submitted false death certificates to the State

of Colorado which subsequently had to be amended. PSR ¶ 24. Similarly, third party

businesses who provided cremation services for Return to Nature sometimes

misidentified bodies within their own records based on misrepresentations by the

Hallfords, exposing them to unnecessary liability. PSR ¶ 25. On at least two occasions,

the wrong remains of bodies were buried by the Hallfords. This conduct resulted in two

subsequent exhumations and forced families to go through the relived trauma of reburying

a loved one. PSR ¶ 26. And each third-party entity that was harmed had to update records

and to follow processes that necessarily resulted in notifying and obtaining information

from victims. These notifications resulted in renewed angst and anxiety for victims who

were already grieving and who have expressed in victim impact letters that one effect of

the Hallfords’ actions was that they have been unable to obtain meaningful closure.

Victims, some whom entrusted multiple family members to the Hallfords’ care,

have remarked that the harm is not limited to the 190 families who received confirmation

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 5
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and some measure of certainty that their loved ones were found in Penrose. It extends to

the hundreds of other customers of Return to Nature who received services and urns from

the Hallfords during the period covered by the fraud scheme, many of whom may remain

uncertain for the rest of their lives about the contents of the urn they received. As many

victims eloquently described, sometimes the only way to process grief over the death of

a loved one is to speak to an urn that is buried under a tree, or placed in a sacred spot in

a home, and the Defendant’s crime took away that solace for hundreds of grieving

families.

Nor was the harm limited to customers of Return to Nature funeral home. The

nature of the Defendant’s crime impacted the entire community in and around Colorado

Springs by eroding the public’s trust and confidence in the funeral-home industry.

Although impossible to measure the full extent of such harm, individuals anywhere within

the Colorado Springs area were left to doubt the legitimacy of funeral-home businesses

going forward. As a result, the Defendant’s conduct tarnished the image of other reputable

businesses who honestly provided essential services in this sensitive area.

In the course of swindling the victims out of their money, the Defendant also

inflicted untold trauma on the families who trusted him. This trauma makes the

Defendant’s fraud scheme far worse than a routine fraud case. To the horror of some of

the victims, they later learned from law enforcement that their loved ones’ bodies had

been left to decay and decompose in unimaginable circumstances at the Penrose

location. The Defendant’s actions resulted in extreme emotional distress for numerous

victims at a time when many were still grieving the loss of a loved one.

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 6
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The Government cannot adequately capture in words the extent of the victims’

pain, as it is incalculable in depth and scope. Rather, the multiple victim impact statements

submitted to the Court provide the best description of the damage caused by the crime

along with the range of emotions felt by the victims which includes despair, disbelief,

betrayal, anger, vengeance, sadness, frustration, and grief, etc. Regrettably for many of

the victims, the wounds caused by the indignities of the offense have been so great that

it has been difficult for them to move on in their lives. Some victims have described

suffering physical and medical infirmities due to the offense. Victims have underwent

counseling and therapy in the aftermath. Many victims had traveled far distances and

participated in sacred ceremonies to obtain closure and honor the wishes of the

deceased, only to find out months or years later the ashes they spread did not belong to

their loved ones, and that the sacred place where they visited and grieved in an attempt

to honor the dead did not contain their loved ones’ remains. The trauma this caused for

family members is incalculable: they thought they were burying or spreading ashes of a

wife near a husband, or burying ashes in a military cemetery or special place like Hawaii

or Tahoe, or under a tree or bench that they could visit for the rest of their lives, only to

find out and have to process death anew months later. The victims’ letters provide vivid

pictures of the harm stemming from the Defendant’s crimes and the resultant doubts and

uncertainties, such as how the bodies of their loved ones were treated while at Penrose,

how many times they were moved or lifted, how their privacy and dignity interests were

violated, and countless other unanswerable questions.

In sum, the toll caused by Jon Hallford’s conduct has been enormous and

immeasurable. The negative emotional, health, psychological, financial, and societal

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 7
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consequences for the victims from the offense and others collaterally impacted must be

taken into account at sentencing in order for there to be any justice in this case.

(2) History and Characteristics of the Defendant

As it relates to the Defendant’s history and characteristics, the Defendant has no

notable criminal record. The present case represents his first felony conviction. PSR

¶¶ 97-102. Based on the underlying conduct, the Defendant is also awaiting sentencing

in state court for multiple felony counts for abuse of corpse in violation of C.R.S. 18-13-

101.

However, the Defendant’s formal criminal record paints an incomplete picture

related to his history and characteristics given the scope and length of this crime. The

Defendant’s fraudulent conduct spanned four years (September 15, 2019, to October 5,

2023), and impacted the families and next of kin of 190 individuals. In the course of

operating his business and carrying out his fraud scheme, the Defendant regularly

interacted with the victims on multiple occasions over an extended period. To keep the

horrific fraud scheme hidden, the Defendant told countless lies to the families and

engaged in daily, deliberate falsehoods to victims and their families at moments of

vulnerability and after multiple interactions designed to build trust. The lies started with

Return to Nature’s upfront commitments about treating each deceased person with

dignity. These initial lies were followed by formal contractual promises that the remains

of the deceased would be well-cared for and properly handled in a dignified manner.

Eventually, the Hallfords provided grief-stricken family members with urns full of concrete

mix. When some victims asked directly what was in the urn, the Hallfords looked them in

the eye and lied. All the while, the Defendant was falsely reassuring the victims that he

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 8
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truly cared for their deceased loved ones. In the midst of this conduct, the Defendant

entered the macabre Penrose building on a daily basis, where he was confronted with the

magnitude of his crime. There he continuously stacked bodies like cord wood as human

decomposition fluid pooled on the floor and the awful stench from rotting corpses

permeated the air. To cover up his conduct, the Defendant covered the windows and

doors of his building, caused false death certificates to be filed with the state, and in a

handful of instances, even caused the burial of a wrong body in a grave.

Approximately one year into his fraud scheme, the Defendant sent a text to Carie

Hallford on October 6, 2020 which showed the depth of his callousness:

PSR ¶ 65 (Government Exhibit 1, p. 2). In another text to Carie Hallford, on May 5, 2020,

the Defendant expressed his lack of care for the victims:

PSR ¶ 64 (Government Exhibit 1, p. 3). Remarkably, despite recognizing that his conduct

was illegal and would likely result in imprisonment, the Defendant made no efforts to

change for another three years. The Defendant clearly had a self-awareness that his

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 9
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conduct was inhumane and warranted prison time. In one text message, for example, on

April 6, 2023, he stated:

PSR ¶ 64 (Government Exhibit 1, p. 4). The Defendant’s text communications ring loud

and clear: he was not concerned about the families seeking his services in a time of need

but only with covering his tracks and avoiding personal responsibility.

In short, the Defendant’s repeated and callous behavior during the four-year period

of the fraud scheme is more relevant to his history and characteristics than his lack of

formal criminal history.

(3) Seriousness of Offense, Promote Respect for Law, and Provide Just Punishment

Here, the Defendant’s criminal conduct warrants a substantial prison sentence to

account for the seriousness of the offense, to ensure that others have a healthy respect

for the law, and to provide just punishment. The Defendant’s conduct while defrauding

funeral home customers was by any measure horrific and morbid. The Defendant and his

wife took advantage of victims who were at their lowest point given the recent loss of a

loved one. The fragile emotional state of many of the victims during their bereavement

cannot be overstated. While the victims were emotionally vulnerable due to their gut-

wrenching grief, the Defendant played a central role in carrying out the underlying fraud.

Instead of dutifully performing cremations for the recently deceased in a dignified

manner—as was his contractual and moral obligation—the Defendant abused multiple

corpses. In doing so, he violated the sacred trust that the victims and the next of kin

placed in him. The Defendant participated in the ultimate indignity by allowing 190 bodies

to remain in various states of decay and decomposition at his business despite promising

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 10
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victims that Return to Nature would guide the families through the bereavement process

in a dignified way. As reflected in many of the victim statements to the Court, the

Defendant’s conduct caused untold emotional distress which will haunt many of the

victims forever and replaced happy final memories of victims’ loved ones with the

horrifying images of the way the Defendant left their corpses to decay. By sentencing the

Defendant to a lengthy prison sentence, the Court can restore some semblance of justice,

albeit imperfect. A lengthy prison sentence will signal to others that the law must be

respected and that individuals like the Defendant who decide to violate society’s basic

norms will ultimately be accountable for their actions.

The Defendant also needs punished for the over $800,000 in Covid-relief funds

which he fraudulently obtained. The funds were specifically earmarked for qualifying

individuals who suffered from adverse business consequences during the pandemic.

Sadly, the Defendant took improper advantage of the government relief plan designed to

help small businesses. The relief funds—if properly applied—could have been used by

the Hallfords to conduct proper cremations and burials for their customers. Instead, the

Defendant and his wife lied on the initial loan application to obtain the funds and then

misused the funds to support a spendthrift lifestyle, squandering the funds on jewelry,

cosmetic medical procedures, cryptocurrency, entertainment and vacations. The

Defendant’s flagrant abuse of such funds under the current circumstances warrants a

substantial prison term.

(4) Afford Adequate Deterrence and Protect the Public from Further Crimes

As noted above, the Defendant’s underlying fraud scheme abused the victims’ trust

and resulted in substantial financial losses for the victims as well as unjustified emotional

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 11
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trauma and social harm. Instead of using the victims’ hard-earned money for promised

cremations or burials, the Defendant and Carie Hallford pocketed funds for their personal

benefit while failing to provide funeral services. The Defendants knowingly and repeatedly

allowed deceased bodies to languish, unattended in deplorable conditions. The

Defendants also exploited SBA Covid-relief programs intended to provide a lifeline for

struggling small businesses for personal expenses.

To ensure general deterrence for like-minded fraudsters in the future, the

Government requests that the Court impose a substantial imprisonment sentence of 180

months. Such a sentence will send the message to the public that similar criminal conduct

will be treated seriously by the law and that participation in such a scheme will always

result in meaningful prison time. The Defendant not only committed the financial crime of

wire fraud but in doing so, he gravely overstepped societal norms related to the treatment

of human remains. Others inclined to engage in this criminal conduct should be put on

notice that substantial imprisonment will inevitably result should they follow in the same

misguided path.

There is also a need for specific deterrence as it relates to Jon Hallford. He is 45

years old and maintains the ability to gain employment in the future. He knew what he

was doing was wrong but weighed the benefits and risks of crime and decided to continue

acting for his own benefit rather than treating the individuals entrusted to his care with

dignity and respect. To ensure that innocent members of the public are protected and the

Defendant is prevented from returning to his deceitful business practices, the Court

should impose a substantial imprisonment sentence.

(5) Provide Defendant with Needed Educational or Vocational Training, or other
Medical Care or Correctional Treatment

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 12
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The PSR does not indicate that the Defendant has any particularized needs in

connection with his sentence. He appears to be in good health and physical condition; he

has no apparent substance abuse issues. PSR ¶¶ 114, 117-118. The Defendant has a

high school degree and has completed various general studies at a bible college; he also

obtained an “applied science degree in funeral services” in 2004 from the Dallas Institute

of Funeral Service. PSR ¶¶ 119-120. The Defendant’s work experience since 2004 has

been working in the funeral business, including working for his parents’ funeral home from

2009 to 2013. PSR ¶¶ 121-123. Finally, it does not appear that the Defendant suffers

from any mental health illness. PSR ¶ 116.

In sum, the PSR does not report that the Defendant has any particular educational,

vocational, medical or physical conditions that require special consideration as part of his

sentence.

(6) Need for Sentence to Avoid Unwarranted Disparities Among Defendants
With Similar Records Found Guilty of Similar Conduct

Conducting a meaningful disparity analysis between the Defendant and other

similar defendants is of limited value given the paucity of reported cases involving

defendants engaging in similar conduct. Here, the Government conducted a canvas of

the federal reporter looking for similar cases but was unable to find any congruent ones

save one.

Specifically, United States v. Megan Hess and Shirley Koch, 106 F.4th 1011 (10th

Cir. 2024) involved conduct implicating some of the same factual issues involved in the

present matter. In Hess, the defendants were a mother and daughter team who each pled

guilty to the offense of mail fraud in connection with the operation of their family funeral

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 13
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home and body broker business. Id. at 1020-21. Among other things, Hess and Koch

worked together to defraud hundreds of customers by falsely representing that they would

provide a cremation or burial services for the victims’ next of kin. Id. at 1020. Instead, the

duo “frequently … exceeded the authority which they obtained” as it related to decedents’

remains. Id. at 1019. In numerous cases, “body parts beyond those which were

authorized, if not entire bodies, would be sold [by Hess and Koch] typically for purposes

not even contemplated or agreed to by the victims.” Id. Like here,3 “families were given

cremains ‘that were represented as that of their loved ones when that was not true.’

Instead, those cremains were either replaced or mixed with the remains of others.” Id.

At sentencing, Judge Arguello imposed an upward variant sentence as to each

defendant. Hess received the statutory maximum of 240 months imprisonment while Koch

received 180 months. Id. 1022. The Tenth Circuit remanded the matter for resentencing

as to both defendants based on various guideline issues. The case remains set for

resentencing on April 21, 2025, so the final sentence has yet to be imposed.

Nonetheless, the Court may look to Hess for some limited guidance when

conducting its disparity analysis and considering whether an upward variance is

appropriate. Like in Hess, the present case is nothing like the run-of-the-mill fraud scheme

that primarily results in economic harm to immediate victims. Instead, the Defendant’s

conduct breeched all bounds of societal norms and decency when he chose to

continuously allow 190 bodies to rot and decay in their funeral home, contrary to the

wishes of the families and terms of the victims’ funeral contracts. Like in Hess, the

3 “The Hallfords – in a number of instances – provided the decedent’s family members,
friends, or designated next-of-kin with an urn filled with dry concrete mix instead of the
actual cremains of the deceased.” PSR ¶ 26.

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 14
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Defendant betrayed all trust which families placed in him to properly handle the remains

of loved ones in a dignified manner. Instead, the Defendant and his wife defiled and

disrespected the remains of the loved ones, deceived the families by providing concreted

mix rather than actual cremains, and carried out their cruel conduct for a four-year period.

In short, the parallels between the two cases is noteworthy, and certainly supports

the imposition of a sentence significantly higher than recommended by the advisory

guidelines. Aside from Hess, there appears to be a dearth of cases with a similar fact

pattern as the present one. The macabre nature of the underlying offense along with the

Defendants’ calculating and callous manner in which they carried it out makes it a unique

outlier, with few other cases for comparison. Consequently, the Government’s

recommended sentence would not result in a disparate outcome as there is a lack of

similarly situated defendants from which to make a meaningful comparison. Ultimately

when fashioning its sentence in the present matter, the Court will necessarily need to

consider the various aggravating factors which make the criminal conduct so unique.

(7) Need to Provide Restitution to Victims

The victims are entitled to a substantial amount of restitution as part of the

sentence in this case. As noted in the PSR, there are two financial victims for purposes

of restitution in this case: (1) the victims from the funeral home fraud scheme, and (2) the

U.S. Small Business Administration. Exhibit A, R-1. Under federal law 18 U.S.C.

§ 3664(i), the individual victims harmed by the Hallfords are entitled to priority while the

SBA’s right to restitution is secondary.

As noted in many victim impact statements, the families of the deceased have

suffered immeasurably as a result of the underlying offense. Undoubtedly, receiving any

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 15
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restitution payments as soon as possible would certainly be of a benefit to such victims.

Nonetheless, the need for the victims to be recompensed must be balanced against the

other important factors set forth in § 3553(a) such as ensuring just punishment and the

protection of the public. Unfortunately, it does not appear from the Defendant’s financial

condition that he will be in a position to make any meaningful restitution payments in the

near future given that he is indigent and has virtually no assets. PSR ¶¶ 126-130.

WHEREFORE, the Government requests that the Court impose an imprisonment

sentence to 180 months imprisonment.

Respectfully submitted this 6th day of March, 2025.

J. Bishop Grewell
Acting United States Attorney

By: s/ Tim Neff
Tim Neff
Assistant United States Attorney
United States Attorney’s Office
1801 California Street, Suite 1600
Denver, Colorado 80202
Telephone: (303) 454-0100
Fax: (303) 454-0405
E-mail: Tim.Neff@usdoj.gov
Attorney for the Government

By: s/ Craig G. Fansler
Craig G. Fansler
Assistant United States Attorney
United States Attorney’s Office
1801 California Street, Suite 1600
Denver, Colorado 80202
Telephone: (303) 454-0100
Fax: (303) 454-0405
E-mail: Craig.Fansler2@usdoj.gov
Attorney for the Government

Case No. 1:24-cr-00113-NYW Document 88 filed 03/06/25 USDC Colorado pg 16
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CERTIFICATE OF SERVICE

I certify that on this 6th day of March, 2025, I electronically filed the foregoing
GOVERNMENT’S SENTENCING STATEMENT FOR DEFENDANT JON HALLFORD
with the Clerk of the Court using the CM/ECF system which will send notification of such
filing to counsel of record in this case.

By: s/Ilmira Allazova
Legal Administrative Specialist
United States Attorney’s Office

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