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Home Court filings Carie L. Hallford case — U.S. District Court, D. Colo. Reporter’s Transcript — United States v. Hallford (Dkt. 139, D. Colo.)

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Reporter’s Transcript — United States v. Hallford (Dkt. 139, D. Colo.)

Summary

A Reporter's Transcript of the Sentencing Hearing in United States of America v. Jon M. Hallford, Criminal Action No. 24-cr-113-NYW-1, in the U.S. District Court for the District of Colorado, filed August 13, 2025. The transcript records proceedings before Judge Nina Y. Wang commencing on the 27th day of June, 2025 in Denver, with Tim R. Neff and Craig G. Fansler for the government and Laura H. Suelau for the defendant. The opening pages cover the presentence investigation report and its addenda and the court's rulings on the defendant's objections, including to a special condition of supervised release and to the report's description of the cremation process. The transcript closes with the certificate of court reporter Kevin P. Carlin.

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 August 13, 2025 in Jon M. Hallford; one of 24 filings from this case.

Record facts

CourtU.S. District Court for the District of Colorado
Filed2025-08-13

Cite this document

“Reporter’s Transcript — United States v. Hallford (Dkt. 139, D. Colo.).” U.S. District Court for the District of Colorado, No. 1:24-cr-00113, Doc. 139, filed 2025-08-13. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-carie-l-hallford-cod-233031/2025-08-13-gov-uscourts-cod-233031-139-0-doc-139/, SHA-256 a3e68075fef6c3037a7159d824729578009c6ced4545f8880dac370b88470c4d.

Full text

Case No. 1:24-cr-00113-NYW   Document 139 filed 08/13/25   USDC Colorado   pg 1
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                                                                             1




   1                     IN THE UNITED STATES DISTRICT COURT

   2                          FOR THE DISTRICT OF COLORADO

   3    Criminal Action No. 24-cr-113-NYW-1

   4     UNITED STATES OF AMERICA,

   5             Plaintiff,

   6             vs.

   7     Jon M. Hallford,

   8             Defendant.

   9    ---------------------------------------------------------------

  10                             REPORTER'S TRANSCRIPT

  11                               Sentencing Hearing

  12    ---------------------------------------------------------------

  13            Proceedings before the HONORABLE NINA Y. WANG, Judge,
        United States District Court for the District of Colorado,
  14    commencing on the 27th day of June, 2025, in Courtroom A902,
        United States Courthouse, Denver, Colorado.
  15

  16                              APPEARANCES
        For the Plaintiff:
  17    TIM R. NEFF and CRAIG G. FANSLER, United States Attorney's
        Office, 1801 California Street, Suite 1600, Denver, CO 80202
  18

  19
        For the Defendant:
  20    LAURA H. SUELAU, Federal Public Defender's Office, 633 17th
        Street, Suite 1000, Denver, CO 80202
  21

  22

  23

  24
        Reported by KEVIN P. CARLIN, RMR, CRR, 901 19th Street, Room
  25    A259, Denver, CO 80294, (303)335-2358


         Proceedings reported by mechanical stenography; transcription
                             produced via computer.

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   1                              P R O C E E D I N G S

   2          (Proceedings commenced at 9:06 a.m.)

   3                THE COURT:     Good morning.     We are on the record in

   4    United States of America versus Jon M. Hallford, case number

   5    24-cr-113-NYW-1.     I'm United States District Judge Nina Wang.

   6    Counsel, would you enter your appearance and introduce anyone

   7    who is seated at the table with you.

   8                MR. NEFF:     Yes, Your Honor.     Good morning.     Tim Neff

   9    appearing on behalf of the Government.          Seated with me at

  10    counsel table is co-counsel Craig Fansler.          Also with me at

  11    counsel table is Special Agent Andrew Cohen with the FBI, and

  12    Chris Adams, special agent with Colorado Bureau of

  13    Investigation.

  14                THE COURT:     Good morning.

  15                MS. SUELAU:     Good morning, Your Honor.        Laura Suelau

  16    on behalf of Jon Michael Hallford, who is present in custody.

  17    Also at counsel table is Amanda Carroll, federal public defender

  18    investigator, and Laura Ownby, federal public defender intern.

  19                THE COURT:     Good morning.     All right.     The Court notes

  20    that Mr. Hallford is present in person with his counsel.

  21    Counsel, are you ready to proceed?

  22                MR. NEFF:     Yes, Your Honor.     We are.

  23                MS. SUELAU:     Yes, Your Honor.

  24                THE COURT:     The record reflects that the defendant was

  25    charged by indictment on April 10th, 2024, that's docket entry


                                Kevin P. Carlin, RMR, CRR

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   1    number one, on 15 felony counts, comprised of 13 counts of wire

   2    fraud and aiding and abetting, and two counts of conspiracy to

   3    commit wire fraud.      The defendant made his initial appearance on

   4    April 15th, 2024.     It's docket entry number six.       And he was

   5    arraigned on April 18th, 2024.        It's docket entry number 16.         At

   6    that time, he entered a plea of not guilty as to each of these

   7    counts.

   8                On September 12th, 2024, defendant filed with this

   9    Court a notice of disposition.        That's at docket entry number

  10    40.   On October 24th, 2024, Mr. Hallford appeared before this

  11    Court for a change of plea hearing, during which he withdrew his

  12    plea of not guilty as to count 11 of the indictment charging the

  13    conspiracy to commit wire fraud, in violation of 18 USC Section

  14    1349, tendered a plea of guilty to that count, and was adjudged

  15    guilty of count 11.      That's docket entry number 51.

  16                The Court indicated that it would reserve the issue as

  17    to whether to accept the plea agreement that was made pursuant

  18    to Rule 11(c)(1)(C) of the Federal Rules of Criminal Procedure

  19    that binds the Court to a particular sentencing -- sentence or

  20    sentencing range if accepted after review of the presentence

  21    investigation report.

  22                The United States probation office filed the

  23    presentence investigation report on February 20th, 2025.             That's

  24    at docket entry number 73.       After review of the presentence

  25    investigation report, by order dated February 24th, 2025, the


                               Kevin P. Carlin, RMR, CRR

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   1    Court informed the parties that it intended to reject the plea

   2    agreement that had been made pursuant to Rule 11(c)(1)(C).

   3    That's docket entry number 79.

   4              That minute order set a hearing for March 4th, 2025,

   5    and indicated that Mr. Hallford should be prepared to either

   6    withdraw from the plea agreement or proceed pursuant to Rule

   7    11(c)(1)(B).    On March 4th, 2025, Mr. Hallford appeared before

   8    the Court for a status hearing, during which the Court made

   9    formal findings about the proposed plea agreement and rejected

  10    it.   That's docket entry number 84.

  11              Mr. Hallford informed the Court that he intended to

  12    move forward with his guilty plea as to count 11, and the United

  13    States and Mr. Hallford executed a plea agreement supplement

  14    indicating such.     That's docket entry number 85.

  15              The purpose of today's hearing is for me to determine

  16    the sentence for count 11.       Mr. Hallford, is there anything

  17    about your condition today that would make you unable to

  18    understand what's going on?

  19                THE DEFENDANT:     No, Your Honor.

  20                THE COURT:    And during this proceeding, at any time if

  21    you need to speak with your attorney, you can let me know, and

  22    we will make those necessary arrangements.          All right?

  23                THE DEFENDANT:     Yes, Your Honor.

  24                THE COURT:    Ms. Suelau, have you and your client read

  25    and discussed the presentence investigation report that's docket


                               Kevin P. Carlin, RMR, CRR

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   1    entry number 64, the revised presentence investigation report

   2    that's docket entry number 75, and then there are three

   3    addendums thereto which are at docket entry 80 -- sorry --

   4    docket entry number 74 is the first addendum, docket entry

   5    number 111 is the second addendum, and docket entry number 114

   6    is the third addendum?

   7                MS. SUELAU:     Yes, Your Honor.

   8                THE COURT:     Ms. Suelau, I understand that the

   9    defendant has many objections to the PSR, but none of them

  10    impact the calculation of the advisory guidelines; is that

  11    correct?

  12                MS. SUELAU:     Yes, Your Honor.

  13                THE COURT:     All right.   And so let me go through the

  14    categories of objections, and I'd like to understand what's

  15    still at issue that we need to resolve today.          With respect to

  16    the categories of objections, I understand that paragraphs 47,

  17    53, 60, and 79 all pertain to Mr. Hallford's objection to the

  18    characterization that he and his codefendant and wife, Carie

  19    Hallford, evaded or attempted to evade law enforcement; is that

  20    right?

  21                MS. SUELAU:     Yes, Your Honor.

  22                THE COURT:     Paragraphs 49 and 65 pertain to

  23    Mr. Hallford's objection to the assertion that there may be

  24    additional unaccounted-for victims that were water cremated,

  25    destroyed with lye, or otherwise disposed; is that correct?


                               Kevin P. Carlin, RMR, CRR

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   1                MS. SUELAU:    Yes, Your Honor.

   2                THE COURT:    Paragraphs 57 and 49 pertain to

   3    Mr. Hallford's objection to the description of the cremation

   4    process.

   5                MS. SUELAU:    That's 57, Your Honor, and 49.

   6                THE COURT:    I'm sorry.    Fifty-seven and 49.        I thought

   7    that's what I said.

   8                MS. SUELAU:    Yes.

   9                THE COURT:    Paragraphs 84, 69, and 77 pertain to

  10    Mr. Hallford's objection to the loss amount stipulated by the

  11    parties -- loss amounts beyond what's stipulated to by the

  12    parties in the plea agreement?

  13                MS. SUELAU:    Yes, Your Honor.

  14                THE COURT:    Paragraphs 45, 48, 49, 57, 62, 64, 66, 67,

  15    and 110 all pertain to Mr. Hallford's objections to certain

  16    factual statements contained in those paragraphs?

  17                MS. SUELAU:    Yes, Your Honor.

  18                THE COURT:    And then finally, Mr. Hallford objects to

  19    the imposition of a special condition of supervised release

  20    number seven, which includes an occupation restriction that

  21    includes, quote, a body broker business, because he contests and

  22    alleges that he never engaged in the business of being a body

  23    broker, and he has never engaged or profited from the illegal

  24    sale of human remains; is that right?

  25                MS. SUELAU:    Yes.


                               Kevin P. Carlin, RMR, CRR

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   1                THE COURT:     All right.     Then, Mr. Neff, it appears

   2    that the Government also filed objections to the PSR, and I

   3    believe one may remain after the revision of the PSR, which

   4    deals with whether or not the $15,000 of EIDL advances should be

   5    part of the restitutionary amount; is that right?

   6                MR. NEFF:     That's correct, Your Honor.

   7                THE COURT:     Okay.     All right.    And then my

   8    understanding is that the other two issues that pertain to

   9    whether or not the interest should be included in the amount of

  10    loss for the purposes of the calculation of the base offense

  11    level and the offense level as well as whether or not any civil

  12    judgments would or could offset the liability for restitution

  13    here, both of those have been resolved in the revised PSR; is

  14    that right?

  15                MR. NEFF:     Yes.     That's my understanding.

  16                THE COURT:     All right.     So, let me understand whether

  17    or not the Government wishes to present evidence as to any of

  18    the disputed issues with respect to the PSR?

  19                MR. NEFF:     No, we don't, Your Honor.

  20                THE COURT:     And does the defense wish to present any

  21    evidence as to the disputed issues in the PSR?

  22                MS. SUELAU:     No, Your Honor.

  23                THE COURT:     Now, let me also understand, we received

  24    the third addendum to the presentence investigation report,

  25    which was the updated restitution which details specific payees


                                Kevin P. Carlin, RMR, CRR

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   1    for which restitution is sought.          That total amount is

   2    $193,966.18.    That remains unchanged.           And is that stipulated to

   3    by the parties?

   4                MR. NEFF:     Yes.     I believe it is, Your Honor.

   5                MS. SUELAU:     Yes, Your Honor.

   6                THE COURT:     Okay.     All right.     So, then let's turn to

   7    the issues with respect to the disputed categories, Ms. Suelau.

   8    So, with respect to paragraphs 47, 53, 60, 79, that pertain to

   9    the characterization that they evaded or attempted to evade law

  10    enforcement, my understanding is that the defendant doesn't

  11    necessarily object to the facts as stated, but he objects to the

  12    characterization that those facts should lead to the inference

  13    that he attempted to evade or evaded law enforcement; is that

  14    right?

  15                MS. SUELAU:     That's correct, Your Honor.        With the

  16    exception of the facts omitted -- I guess we object to the facts

  17    that were omitted from the warrant, which was cited to in the

  18    presentence report, but other than that, the objection is

  19    essentially to the conclusion that those facts without

  20    additional facts as provided in the objection would lead to the

  21    conclusion that Mr. Hallford attempted to evade law enforcement.

  22                THE COURT:     All right.     So, the Court, because the

  23    objection -- the facts that are included in the PSR are not

  24    objected to, based on the factual content, the Court determined

  25    that no finding is necessary regarding the objection as to the


                                Kevin P. Carlin, RMR, CRR

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   1    character -- characterization of those facts.            The Court can

   2    draw its own reasonable inferences, does not take necessarily

   3    the inference that is drawn by the PSR as fact, and will not

   4    take into account that characterization in imposing a sentence.

   5    Any further argument with respect to that category of objection?

   6                MS. SUELAU:    No, Your Honor.

   7                THE COURT:    Okay.   Then paragraphs 49 and 65 pertain

   8    to Mr. Hallford's objection that there was assertion that there

   9    may be additional unaccounted-for victims who were water

  10    cremated, destroyed with lye, or otherwise disposed of.               And

  11    again, it appears that Mr. Hallford's objections are not -- do

  12    not pertain to the factual statements of whether or not the

  13    materials such as lye or a water machine were found, but that

  14    the objections were to the inferences that were drawn in the PSR

  15    from those facts.     But the revised presentence investigation

  16    report, as I understand it, reflects Mr. Hallford's position

  17    with respect to those issues; is that correct?

  18                MS. SUELAU:    Yes, Your Honor.        And I have no

  19    additional argument on those issues.

  20                THE COURT:    All right.    So, again, the Court

  21    determines that no finding is necessary to those objections,

  22    because the disputed or objected-to conclusion will not be taken

  23    into account in imposing a sentence.         However, the Court can

  24    draw its own reasonable inferences from those uncontested facts.

  25    The Court notes that there are victim statements from customers


                               Kevin P. Carlin, RMR, CRR

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  1    of Mr. Hallford, his codefendant, and Return to Nature that

  2    indicate that beyond the weight of the remains or cremains given

  3    back to the loved ones, that they -- there were certain victims

  4    who indicated that they received cremains that were inconsistent

  5    with the physical characteristics of their deceased loved ones

  6    that would remain intact after cremation, such as a dental

  7    bridge for an individual who no longer had any teeth and was not

  8    cremated with his dentures.

  9               That might suggest or may be the basis to draw an

 10    inference that there may be other victims of the wire fraud that

 11    would not be able to be identified because of the status of the

 12    remains.

 13               Paragraphs 57 and 49 pertain to Mr. Hallford's

 14    objection to the description of the cremation process.              Again,

 15    Mr. Hallford's objections will not be -- or those types of

 16    statements will not be taken into account in imposing the

 17    sentence, and so therefore the Court determines that no finding

 18    is necessary with respect to his objections to the description

 19    of the cremation process.

 20               Now, paragraphs 84, 69, and 77 pertain to

 21    Mr. Hallford's objections to loss amounts not stipulated to by

 22    the parties in the plea agreement.        My understanding is the

 23    $15,000 of the EIDL loan advances does not impact the -- does

 24    not impact the calculation of any advisory guidelines, and the

 25    parties have stipulated to the loss amounts that are contained


                              Kevin P. Carlin, RMR, CRR

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  1    in addendum -- the third addendum; is that correct?

  2                 MR. NEFF:     Yes.     That is correct, Your Honor.

  3                 MS. SUELAU:     Yes, Your Honor.     The objection is that

  4    the interest from those loans should not be counted.

  5                 THE COURT:     As part of restitution?

  6                 MS. SUELAU:     As either part of loss or part of

  7    restitution.

  8                 THE COURT:     Okay.     So, what is the Government's

  9    position with respect to interest as being part of the

 10    restitution amount?

 11                 MR. NEFF:     Well, we cited the relevant case law.          Our

 12    position is we had agreed not to seek the restitution off of the

 13    COVID money, 119,000 or so plus.           So, we are not seeking that at

 14    this time.     Legally speaking, I believe the Court would have the

 15    right to impose that as part of restitution.           The interest can

 16    be included in restitution.           We cited the cases on that, but we

 17    are not seeking it.

 18                 THE COURT:     All right.     So, the Court will not include

 19    that interest amount, only because the Government has indicated

 20    that it has no witnesses to present.           The Government bears the

 21    burden of establishing what restitution amount may be ordered.

 22    Restitution may only be ordered for losses actually resulting

 23    from the offense of conviction.           That's United States versus

 24    West, 6467 -- I'm sorry -- F.3d 745, 751, Tenth Circuit, 2011.

 25               The Government bears the burden of proving the amount


                                Kevin P. Carlin, RMR, CRR

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  1    of loss by a preponderance of the evidence.          That's United

  2    States versus Galloway, 509 F.3d 1246, 1253, Tenth Circuit,

  3    2007.

  4               It bears that same burden regarding the subordinate

  5    question of what harms are properly included in the loss

  6    calculation, because they're the result of an offense.              That's

  7    United States versus Anthony, 942 F.3d 955, 964, Tenth Circuit,

  8    2019, citing United States versus Wells, 873 F.3d 1241, 1265,

  9    Tenth Circuit, 2017, quoting 18 USC Section 3664(e).

 10               In light of the fact that the Government has not

 11    presented any additional evidence, and that amount is not

 12    contained in the third addendum to the presentence investigation

 13    report that is stipulated, the Court finds that the Government

 14    has failed to carry its burden of proof with respect to

 15    including the interest amount in the amount of restitution, and

 16    accordingly, the Court will not include that in its calculation

 17    of restitution.

 18               In addition, for the same reasons, the Court will not

 19    include the amount of $15,000 of the EIDL advances as part of

 20    the restitution or the part of the amount of loss, for the same

 21    reason that there has been no additional evidence that has been

 22    presented by the Government, and the Court finds that the

 23    Government has not carried its burden of proof as to those

 24    amounts.    In so ruling, the Court makes clear that it is not

 25    making a ruling that such amounts could not or should not be


                              Kevin P. Carlin, RMR, CRR

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  1    included in the restitutionary amount, only that the Government,

  2    in failing to present any additional evidence, has failed to

  3    carry its burden.        So, that objection is sustained.

  4               Anything with respect -- anything in addition --

  5    anything in addition with that category of objections?

  6                 MR. NEFF:     Nothing for the Government.

  7                 MS. SUELAU:     No, Your Honor.

  8                 THE COURT:     Paragraphs 45, 48, 49, 57, 62, 64, 66, 67,

  9    and 110 pertain to Mr. Hallford's objections to certain factual

 10    statements contained in those paragraphs.           The first addendum,

 11    which is docket entry number 74, indicates that the Govern -- or

 12    the probation office has made notes in the revised PSR as to

 13    Mr. Hallford's various objections to those paragraphs.              Anything

 14    in addition that we need to address after the revision to the

 15    PSR, Ms. Suelau?

 16                 MS. SUELAU:     Your Honor, we would just be asking for

 17    paragraph 67 to be struck for the reasons outlined in the

 18    objection.

 19                 THE COURT:     Is it 67 or 68 in the revised PSR?

 20                 MS. SUELAU:     One moment, Your Honor.     It's paragraph

 21    68 in docket entry 110.        So, we're asking that be struck.

 22                 THE COURT:     All right.   What's the Government's

 23    position with respect to that?

 24                 MR. NEFF:     No objection to that, Your Honor.

 25                 THE COURT:     All right.   So, the Court will sustain the


                                Kevin P. Carlin, RMR, CRR

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  1    objection to paragraph 68 before the -- and we'll ask the

  2    probation office to take that paragraph out before the

  3    presentence investigation report is conveyed to the Bureau of

  4    Prisons.     So, the objection to that is sustained.

  5                With respect to Mr. Hallford's last objection to

  6    special conditions of supervised release number seven, I think

  7    that's most appropriately discussed and argued by counsel in the

  8    context of addressing what the appropriate sentence in this case

  9    would be.     Any objections to that procedure, Counsel?

 10                 MR. NEFF:     None.

 11                 MS. SUELAU:     I'm sorry.     In regard to special

 12    condition seven, I believe that has been amended.

 13                 THE COURT:     Oh.     I apologize.   Let me look.     It has.

 14    So, that has been resolved.           Thank you, Ms. Suelau.      All right.

 15                Then I will note for the record that the Court accepts

 16    all undisputed portions of the presentence investigation report

 17    as its findings of fact with respect to sentencing.               So,

 18    formally, the Court finds that no finding is necessary regarding

 19    the objections to the presentence investigation report, because

 20    the controverted matters have been addressed through the

 21    revision of the report, will not be taken into account in

 22    imposing sentence, or will not affect the sentence.

 23                Neither the Government nor the defendant has challenged

 24    any other aspect of the presentence investigation report.

 25    Therefore, the remaining factual statements and guideline


                                Kevin P. Carlin, RMR, CRR

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  1    applications are adopted as the Court's finding of fact

  2    concerning sentencing.

  3               The Court will also grant the Government's motion for a

  4    one-level decrease based on United States sentencing guideline

  5    section 3E1.1(b) for acceptance of responsibility.            That's

  6    docket entry number 78.

  7               Based on the Court's resolution of the disputed issues

  8    and the granting of the Government's motion, it concludes that

  9    the total offense level is 28.          Defendant's criminal history

 10    category is one, which results in an advisory guideline range of

 11    78 to 97 months, one to three years of supervised release, a

 12    fine range of 25,000 to $250,000, and a special assessment of

 13    $100.

 14               I guess I formally find that the loss amount pursuant

 15    to section 2B1.1(b)(1)(H) as calculated in the presentence

 16    report paragraph 84 is not applicable, because the Government

 17    has not established its burden of proof with respect to that

 18    loss amount, and therefore should also be amended before the

 19    presentence investigation report is conveyed to the Bureau of

 20    Prisons.

 21               Any other rulings that counsel believes that I need to

 22    make before we move on?

 23                MR. NEFF:     I don't believe so.       No, Your Honor.

 24                MS. SUELAU:     Not for Mr. Hallford, Your Honor.

 25                THE COURT:     All right.     According to Federal Rule of


                               Kevin P. Carlin, RMR, CRR

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  1    Criminal Procedure 32(i)(4), before imposing sentence the Court

  2    must provide the defendant's attorney, the defendant, and

  3    attorney for the Government an opportunity to speak, as well as

  4    giving the victims an opportunity to be reasonably heard.              As I

  5    understand it, Mr. Neff, we have a number of victims who wish to

  6    be heard during this proceeding; is that right?

  7                 MR. NEFF:    Yes, we do, Your Honor.

  8                 THE COURT:    All right.   And then, thank you.        If you

  9    could silence your telephones, the Court would appreciate that.

 10    All right.     So, what we will do is, Ms. Suelau, you will have

 11    the first opportunity to speak on your client's behalf as to the

 12    sentence that you believe is appropriate in this case.              Then,

 13    Mr. Neff, you will have an opportunity to speak with respect to

 14    what the Government believes is appropriate.          Now, then I would

 15    have the victims speak.       Mr. Neff, it doesn't matter to me

 16    whether or not the victims go before you or go after you.

 17               And then finally, Mr. Hallford, before the Court

 18    imposes any sentence, you will have an opportunity to address

 19    the Court, if you would like, but you have no obligation to

 20    speak.    Does counsel have any thoughts with respect to the order

 21    of presentation today?

 22                 MR. NEFF:    No, Your Honor.    I would anticipate, just

 23    to let the Court know, after Ms. Suelau goes, having the victims

 24    speak, and then I would plan to speak afterwards, just for

 25    planning purposes for counsel and the Court.


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  1                 THE COURT:     That's fine.    Ms. Suelau?

  2                 MS. SUELAU:     May I confer with my client, Your Honor?

  3                 THE COURT:     You may.

  4                 MS. SUELAU:     That procedure is fine, Your Honor.

  5    Thank you.

  6                 THE COURT:     All right.     Ms. Suelau?

  7                 MS. SUELAU:     Your Honor, in a recent letter from one

  8    of the victim families to this Court, that individual said that

  9    this sentencing -- Mr. Hallford's sentencing's today closes a

 10    chapter for that family, and that after that, we, quote, will

 11    reclaim our lives.        Today begins the process of truly moving

 12    forward.     And for whatever else is said or argued at this

 13    hearing, it's my and Mr. Hallford's hope that his acceptance of

 14    responsibility and his acknowledgment of fault here will in fact

 15    allow for that process -- that healing process to truly move

 16    forward.

 17               Many of the victims in their letters wrote about

 18    Mr. Hallford's actions, that they interrupted or prolonged or

 19    aggravated their grief process in the loss of their loved ones,

 20    and clearly some of the grief over that loss has manifested, and

 21    fairly so, in anger against Mr. Hallford.           And from the

 22    beginning, Mr. Hallford has understood and acknowledged that

 23    anger, acknowledged that grief, and taken whatever actions he

 24    has at his disposal to help with that grief process.

 25               He knows he was wrong.        He's admitted he was wrong.        He


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  1    doesn't now or has not offered any excuse for his conduct.               It

  2    is, however, my job and this Court's role to ensure that his

  3    conduct in this case is not sentenced solely on a place of grief

  4    and emotion, but in a manner that is consistent with the law.

  5    So, I want to start with addressing some of the Government's

  6    arguments raised in their response to my filing and my request

  7    for a sentence of 120 months, and that is our request today.

  8               First, in regards to the role the state sentence has or

  9    doesn't have or should or shouldn't play or that this Court

 10    should or shouldn't give consideration, the Government

 11    encourages this Court to not, quote, abdicate its authority to

 12    the State for Mr. Hallford's treatment of the corpses involved

 13    in this case, and should suggest that somehow this Court's

 14    consideration of the fact of that case would be inconsistent

 15    with federal law.      The Government goes on to say, the state

 16    court judge may or is likely to commit error in that

 17    Mr. Hallford could escape punishment altogether.           That list of

 18    terrible hypotheticals is just not the reality here.

 19               So, I want to back up and walk us through kind of the

 20    procedure of this case, which is that back in November 2023,

 21    Mr. Hallford was arrested and charged with 268 counts for money

 22    laundering, forgery, theft, and abuse of a corpse.           Then the

 23    Government here charged Mr. Hallford with 15 counts of wire

 24    fraud.    I will also remind this Court that prior to 2020, those

 25    abuse of the corpse charges were misdemeanor charges in


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  1    Colorado.

  2                And when they were revised to be felony charges, the

  3    State of Colorado said, essentially, federal charges related to

  4    the fraud aspect of these types of cases are not enough.             We

  5    want to have our own type of crime that addresses the harm done

  6    here.   And then -- but by charging Mr. Hallford after those

  7    state charges here, the Government kind of implicitly said,

  8    there's other conduct here not covered by the state.            And I

  9    agree, there is some conduct here not covered by the state, most

 10    notably the Small Business Administration fraud.

 11                And I will point out that that -- the loss of the Small

 12    Business Association -- Administration, SBA, drives a lot of the

 13    guideline here.       And without that loss, Mr. Hallford's guideline

 14    range would start at 51 months, but now the Government says that

 15    these cases are actually identical harm, and this Court should

 16    address the same harm as if the state prosecution doesn't exist.

 17                But either this Court recognizes that there's two

 18    separate sovereigns prosecuting Mr. Hallford for identical

 19    conduct, and takes that into account as fairly called for by

 20    5G1.3, or you say they're addressing different harms altogether.

 21    And the Government proposes that it's both, that the answer

 22    should be that this Court be blind to the fact of the state

 23    prosecution and Mr. Hallford's plea of guilt in that case, but

 24    also in Your Honor's sentence to capture the whole harm of both

 25    cases in this sentence.


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  1               First, I don't think this -- it's fair to engage in

  2    speculation about what will or will not happen in that case or

  3    presume that a judge in another jurisdiction would commit error.

  4    The reality is Mr. Hallford has pleaded guilty in that case.             He

  5    is set to proceed to sentencing.        The sentence that the parties

  6    have stipulated to is 20 years.        Mr. Hallford's conduct in this

  7    case indicates that he is very unlikely to withdraw from that

  8    plea agreement or take another path.         He has every intention of

  9    proceeding to sentencing in that case.

 10               But in any case, this Court shouldn't substitute its

 11    own judgment for the State of Colorado, and instead should just

 12    assume that Mr. Hallford has been charged, justice will be

 13    effectuated in that Court in the way justice is designed to be

 14    effectuated, and that the fact of those charges and the fact of

 15    Mr. Hallford's plea in that case and his potential sentence in

 16    that case is relevant when fashioning a sentence here.

 17               Now, I want to be clear, I agree that the treatment of

 18    corpses at the Penrose facility is relevant conduct here, and

 19    I'm not asking this Court to ignore it, but there's no world in

 20    which Mr. Hallford will escape punishment if Your Honor

 21    prioritizes the crime we're actually here for.

 22               The point is that this Court has to consider we are

 23    asking for an above guideline sentence.         The Government is

 24    asking for an above guideline sentence, and the question is what

 25    number is appropriate?      And in fashioning that, this Court can't


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  1    and shouldn't ignore the charges in the state, and, you know,

  2    what the Government is inviting the Court to do would be by

  3    extension, for example, saying to this Court, you don't have the

  4    authority to order a state run -- a sentence to run consecutive

  5    or concurrent.        We just ignore that that is a thing altogether.

  6               But United States versus Stetzer -- or Setzer addressed

  7    this question in another way, and this Court's authority and

  8    consideration in another way by saying because in that case both

  9    Mr. Setzer and the Government argued that because district

 10    courts can't possibly know what might happen in an anticipated

 11    state sentence, then they might get their sentence wrong,

 12    essentially.

 13               And the Tenth Circuit rejected that argument and said

 14    no, we entrust district courts to impose a sufficient but not

 15    greater than necessary sentence in consideration of state

 16    sentences, even when they're anticipated.             And Setzer also

 17    addressed the kind of fear mongering by the Government about

 18    what the state will or will not do or may or may not mess up,

 19    and said in our American system of dual sovereignty, each

 20    sovereign, whether federal or state, is responsible for the

 21    administration of its own justice system.

 22               And so in fashioning a sentence, Your Honor has to

 23    trust that -- consider that Mr. Hallford is facing those charges

 24    and trust that that sovereign will administer its own justice

 25    system, and instead focus here on the crime Mr. Hallford is


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  1    charged with and committed in violation of federal law, which is

  2    wire fraud.

  3                I also want to address the Government's disparity --

  4    their response to my disparity analysis.             And it boils down to

  5    them essentially saying there's only one case this Court should

  6    consider for the purposes of disparity, and that's United States

  7    versus Hess, but in so doing, the Government is making a few

  8    explicit and implicit assertions that this Court should not

  9    follow.     First, the Government's essentially saying that cases

 10    involving funeral homes and the mistreatment of corpses are the

 11    most egregious wire fraud, and so that all other sentences

 12    sentenced under 2B1.1 are less serious, and these fall into

 13    their own category.

 14                But that requires this Court to make some moral and

 15    religious judgment about, you know, what conduct -- egregious

 16    conduct is or isn't worse than other egregious conduct.                And I

 17    think the point of the cases I highlighted was to say there was

 18    harm done here.       There was more than monetary harm done here,

 19    and how do Courts look at a fraud case when there's more than

 20    monetary harm done here?        But I don't think it's fair to

 21    conclude this type of case is necessarily the most egregious of

 22    all wire fraud cases.

 23                I will use a case called United States versus Castaldi,

 24    743 F.3d 589, that's Seventh Circuit, 2014, as an example.                   And

 25    there the district court in Mr. Castaldi's sentencing for wire


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  1    fraud read out loud and summarized letters from victims about

  2    how he had deprived them of their life savings, college money

  3    for children, money saved for retirement, money for medical

  4    care, life insurance money, and one of his last victims

  5    described how he convinced her to take a 200,000-dollar mortgage

  6    out on her home and invest it with him.         That money is lost.

  7    Her home is lost, and she's an elderly woman left destitute.

  8               The cases I cited in my filing also implicate people's

  9    medical decisions, the targeting of elderly people on fixed

 10    incomes, elected officials who sold their power for influence in

 11    the United States jeopardizing security interests.           Each of

 12    those cases, what's different about those is although we have

 13    that aggravated harm, each of those individuals also lived

 14    lavish lifestyles, by contrast to Mr. Hallford, who was living

 15    very much a middle class life, renting a three-bedroom home for

 16    his family in Colorado Springs.

 17               But they were all living lavish and extravagant

 18    lifestyles, and many of those individuals refused to accept

 19    responsibility, and all of those individuals have a higher

 20    applicable guideline range, yet each of them received a sentence

 21    less than 180 months.      So, I just don't think it's accurate to

 22    say the harm here is worse than all that harm.          They both

 23    involve significant harm above and beyond what we typically

 24    think of for wire fraud, but this Court should reject the notion

 25    that this type of conduct is necessarily more harmful than that


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  1    other type of harm.

  2               The second assumption the Government would like this

  3    Court to make is that the only marker this Court should consider

  4    is the Hess case, and says these cases were all but identical.

  5    As I noted in my filing, there are several significant

  6    differences with the Hess case: greater loss to victims and

  7    customers, the length of the scheme, and the secondary profit of

  8    the body-brokering business.

  9               I know the Government said something along the lines

 10    of, you know, we don't know when Mr. Hallford would have ended

 11    this just because he was arrested, but we don't sentence people

 12    based on conduct they might have -- they might commit in the

 13    future or might have committed in the future but for the arrest.

 14    I mean, that's true of any case; right?         We sentence for what

 15    people actually did, but the critical difference with the Hess

 16    case is the body-brokering aspect.

 17               First, that is evidence of a more contrived scheme on

 18    behalf of Ms. Hess.      In other words, she always knew that she

 19    would not return the remains to loved ones.          She set up an

 20    organization for that purpose.        She always knew she intended to

 21    sell those body parts for profit, versus Mr. Hallford, who did

 22    execute legitimate services for many customers, over 900

 23    customers, and did not set up a funeral home for the purpose of

 24    engaging in another separate illegal activity.

 25               He also did not profit twice from his business.           And


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  1    not in small part, the Hesses' conduct eliminated any

  2    possibility that the victim families in those cases could

  3    eventually have their loved ones back and find closure.             The

  4    bodies were simply gone.       And Ms. Hess and Ms. Koch never faced

  5    any penalty in the State of Colorado.         When they committed that

  6    conduct, it was misdemeanor conduct, and they were not charged.

  7    Mr. Hallford is facing the significant sentence in the State.

  8               But finally, even if you say, okay, the Hess case is

  9    the only case, at her resentencing, Ms. Hess' applicable

 10    guideline range was 121 to 151 months.         Therefore, her 240-month

 11    sentence, which was 89 months above that, was a 59 percent

 12    increase from the top of the applicable guideline range.

 13               The Government's requested variance here, 83 months

 14    above 97 months, is an 86 percent increase above the top of the

 15    applicable guideline range.       So, that would, I think, implicitly

 16    mean that Mr. Hallford's conduct was worse, and it deserves a

 17    greater increase.      An 86 percent increase, as Your Honor knows,

 18    is extraordinary in cases -- you know, by comparison, in cases

 19    where an individual comes in, cooperates with the Government,

 20    testifies in front of a jury, at risk to themselves, their

 21    safety, their family, those individuals, the Government says get

 22    maybe up to at most a 30 percent decrease.

 23               So, when we're looking at what percentage do we go

 24    above or below the guidelines, I think that's a good anchor for,

 25    okay, this is an extraordinary in the other direction, and


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  1    that's still only up to 30 percent.         In reverse, we have

  2    86 percent above the applicable guideline range?

  3               But we also have a final problem with the Government's

  4    position that Hess should be this Court's only anchor, and that

  5    is that the Government presumes the sentence in Hess was

  6    reasonable, and says, essentially, notwithstanding the appeal,

  7    even if -- that only one data point should be considered

  8    reasonable, and that data point is Judge Arguello's judgment,

  9    and that this Court should do that -- rely on that,

 10    notwithstanding the appeal, not knowing the fullness of the

 11    3553(a) factors considered in that case, and assuming -- saying

 12    yes, I agree, Judge Arguello's sentence that was 13 -- 13 years

 13    for Ms. Koch and 18 years for Ms. Hess, higher than the national

 14    average for fraud, is the appropriate anchor.

 15               But the whole purpose of the sentencing guidelines was

 16    to bring some uniformity to sentencing to avoid that kind of

 17    wild disparity, and that's why guidelines are the benchmark and

 18    should be the benchmark in federal sentencing, or are the

 19    benchmark pursuant to the Supreme Court jurisprudence, not the

 20    judgment of one individual judge.

 21               And so the Government's encouragement of this Court to

 22    ignore all the other data that Mr. Hallford has presented

 23    presents a problem.      And what if for example in the future

 24    Mr. Hallford -- the Hess sentence and the Koch sentence are

 25    overturned?    Then what happens with that singular data point?


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  1               The data that we actually have about fraud sentences

  2    tell us that someone with Mr. Hallford's criminal history

  3    category, with Mr. Hallford's offense level, renders most people

  4    at an average of 61 months.       We're not asking for 61 months.

  5    We're recognizing the harm here.        We're asking for twice that

  6    national average, but three times that average is greater than

  7    necessary.

  8               Finally, in their response, the Government talks about

  9    how essentially, because Mr. Hallford has acknowledged that this

 10    case is outside the heartland of the traditional fraud case,

 11    then it must necessarily be 180 months.         It's true, this is

 12    outside the heartland of a traditional fraud case, but that

 13    doesn't just mean once we're outside of the guidelines we're

 14    completely unreined or unbridled by any consideration of them or

 15    any consideration of similar conduct.         It's just saying, this is

 16    an aggravated case as compared to the average case.

 17               Again, the average is 61 months.         So, the guidelines,

 18    which have repeatedly been found to already be inflated, put us

 19    at a top of 97 months, and we're saying 23 months above that is

 20    the appropriate mark.      The Government is saying nine years above

 21    that is the appropriate mark.        That's greater than necessary.

 22               I just want to briefly address Mr. Hallford's history

 23    and characteristics, because for whatever else the victim

 24    families may think about Mr. Hallford, and fairly so, that's --

 25    this case is not the whole of who he is or the whole of his


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  1    history and characteristics.        He is also a father who will not

  2    see his children meet many milestones such as graduations,

  3    weddings, things of that nature.         He is a husband who will not

  4    see his wife for a decade or more.         He is a son who received

  5    news yesterday that his father is likely to die in the next few

  6    days of Alzheimer's, and he will not be there for that death or

  7    to comfort his mother or anything like that.

  8               He will likely miss also the death of his mother in the

  9    next ten years.       He's a brother.    He's a friend, and he is

 10    beloved by people.       And no matter how heinous this conduct was,

 11    those are still relevant considerations for Your Honor when

 12    imposing a sentence.

 13               I think it's also relevant to consider that

 14    Mr. Hallford has been publicly shamed, ridiculed, and disgraced.

 15    He's lost his career.       He's lost his reputation.       People have

 16    made life-sized voodoo dolls in his likeness.           There's

 17    documentarians and podcasters and newscasters who all think they

 18    know him and are talking about how evil he is.           That is what he

 19    is going to be living with, that consequence as well.

 20               And he certainly did reprehensible things.          He

 21    acknowledges that.       But he did not start Return to Nature, this

 22    business, with the purpose or the intention of doing those

 23    reprehensible things.       He made some awful decisions over the

 24    course of four years, but he's still a human being.            And he's

 25    still a human being who spent the first 40 years of his life


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  1    living a law abiding life, being a husband, a father, a son, all

  2    of those things.

  3               But he will spend whatever sentence Your Honor imposes,

  4    the rest of his life defined by this four-year period.               So, the

  5    question is in addition to this 20-year state sentence, how long

  6    does Mr. Hallford need to spend in federal prison?            And it's our

  7    position that 120 months properly reflects all those things and

  8    finally reflects the fact that he has accepted responsibility

  9    here.

 10               He's not eschewed blame.       He's not pointing fingers.

 11    He's not minimizing.       He's contrite.     He's accepting from the

 12    beginning.     He has been consistent in his message to me, which

 13    is, I don't want to do any more harm here.           I want to accept

 14    responsibility.       I know I was wrong.

 15               He read every single letter submitted to this Court

 16    from the victims.       He knows the harm he's caused.       He's

 17    intimately familiar.       He knows everything they think about him,

 18    and he accepts all of that.        That's even more remarkable in

 19    light of the fact that he was essentially told, you could be

 20    facing five years more than you initially thought when you

 21    entered the plea of guilt, and he still said, that's okay.                  I

 22    don't want to re-victimize these families.

 23               He's accepted everything that has come his way, and he

 24    gets it.     So, in light of that, 120 months reflects all of those

 25    things and is the appropriate but not greater than necessary


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  1    sentence in this case.

  2                We're also asking Your Honor to recommend designation

  3    at either El Reno FCI or Texarkana.          Those facilities are within

  4    driving distance from his family, and they also offer UNICOR and

  5    other rehabilitative programming.

  6                Unless Your Honor has any questions, I have nothing

  7    further.

  8                 THE COURT:    Thank you, Ms. Suelau.       All right.

  9    Mr. Neff, I have a list of individuals who would like to be

 10    heard.     Will you just be calling them one by one?

 11                 MR. NEFF:    Yes.     If I could, Your Honor?    I would note

 12    for the Court there has been some modification.            There were a

 13    handful of people who could not travel here or be here, so we

 14    may have to strike a couple names.          I also would like to note

 15    there were two additional people who did show up and are asking

 16    to be heard.     I would ask leave of the Court to include them.           I

 17    just received notice basically yesterday, one this morning, but

 18    we are dropping three, and I'm asking essentially to add two, I

 19    think is what it will be.

 20                 THE COURT:    That's fine.

 21                 MR. NEFF:    Okay.     With that said, Your Honor, if I

 22    could -- if I could call the first victim who would like to

 23    speak?     And that would be Crystina Page.         Ms. Page, if you could

 24    come up here, please.       Thank you.

 25                 THE COURT:    All right.     For all of the victims who


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  1    would like to be heard, it would be helpful when you come to the

  2    podium after Mr. Neff states your name for you to state your

  3    name and spell it so our court reporter can accurately record

  4    it.

  5                MS. PAGE:      Give me ten seconds, please, Your Honor.

  6    Good morning, Your Honor.           Thank you again for hearing us.          We

  7    appreciate it.        My name is Crystina Page, and I stand before you

  8    today not just as a grieving mother, but as one voice among

  9    thousands forever altered by the actions of Return to Nature

 10    Funeral Home.

 11                THE COURT:      Okay.     Ms. Page, I'm going to stop you.

 12    Just say your name, and spell it for our court reporter.

 13                MS. PAGE:      I'm sorry.     Crystina Page.

 14    C-R-Y-S-T-I-N-A, P-A-G-E.

 15                THE COURT:      Thank you, Ms. Page.      Go ahead.

 16                MS. PAGE:      Thank you.     I stand before you today not

 17    just as a grieving mother, but as one voice among thousands

 18    forever altered by the actions of Return to Nature Funeral Home.

 19    What happened here is more than fraud.           It's desecration, it's

 20    trauma, and it is a betrayal so deep that no sentence will ever

 21    fully balance the scales.

 22               I speak today not only for my son, David Jaxon Page,

 23    but for every person whose final moments were denied dignity and

 24    for every family whose grief was manipulated and multiplied.

 25    The numbers are staggering, but the numbers alone don't show the


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  1    weight of what was done.       So, I offer a visual, and I'm asking

  2    Beth, who is a co-victim and now friend, to step forward and

  3    help me with this very quickly.

  4                This is 191 beads that represent the 191 that were

  5    found in the building, but the 191 found were only the bodies.

  6    In addition to those 191 bodies, there are thousands of people

  7    who have been affected by the finding of those.           And

  8    unfortunately, the 191 found were not the only affected.            The

  9    number we've been given is 1,178 clients of Jon Hallford's.

 10    That means there's roughly 987 people still not represented in

 11    the system.

 12          (Pause in the proceedings.)

 13                 MS. PAGE:    And along with those 987 are the thousands

 14    of people affected by those bodies who were not accounted for.

 15                Is wasn't just the 191 that were left in that building.

 16    This is a community forever changed.         It wasn't just 191 people

 17    affected.     Every single person who loved my son, who loved my

 18    friend's children, brothers, sisters, mothers, fathers,

 19    grandparents, grandchildren, and cousins, our community will

 20    forever be changed by the actions of Jon Hallford, and there is

 21    no sentence that could possibly be enough.          Thank you again,

 22    Your Honor, for hearing us.

 23                 THE COURT:    Thank you, Ms. Page.

 24                 MR. NEFF:    Your Honor, at this time the Government

 25    would ask that Cori Cusack-Sperry please step forward.


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  1                 THE COURT:    So, before you start, your name and the

  2    spelling, please.

  3                 MS. CUSACK-SPERRY:    Thank you, Your Honor.      My name is

  4    Cori Cusack-Sperry.       C-O-R-I, C-U-S-A-C-K, S-P-E-R-R-Y.        My

  5    mother was Barbara Jean Cusack.        She died on November 21st,

  6    2019.   Her body was among the first to be dumped at the Penrose

  7    building.     She was there for nearly four years.        It's difficult

  8    to quantify the amount of generational trauma inflicted by the

  9    intentional negligence perpetrated by Jon Hallford.           My mother

 10    was my best friend.       We did everything we could to honor her

 11    final wishes, only to discover that Jon Hallford desecrated her

 12    remains and destroyed all of our good intentions.

 13                Although I felt extreme grief and anger, I could not

 14    focus on myself, because my son, who adored his grandmother,

 15    quickly spiraled into deep depression.         It was only after

 16    spending thousands of dollars on a hospital visit, therapy, and

 17    counseling, and ultimately an emotional support dog that my son

 18    finally began to heal from his anger and sadness.           Everyone in

 19    my family was deeply traumatized by this situation.           I believe

 20    the longest jail time possible is warranted for Jon Hallford due

 21    to his callous and thoughtless treatment of all of our beloved

 22    family members who entrusted him.

 23                Rather than treating the deceased with care and

 24    consideration, he was discarding their bodies like trash, and

 25    then using the funds intended to properly lay them to rest for


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  1    his own personal enjoyment and enrichment.             When the

  2    investigation first began, he lied to law enforcement officers

  3    and then fled.        At no time since his arrest has he publicly

  4    shown an ounce of remorse or regret, nor has he ever attempted

  5    to help families as they desperately tried to find out where

  6    their loved ones' bodies were left.

  7                At what point has he showed contrition?          Where has he

  8    made amends?     I personally think he should be locked up for the

  9    rest of list life.        Your Honor, please do not give Jon Hallford

 10    any special treatment or consideration.           He deserves the same

 11    lack of consideration and indifference that he showed to the

 12    hundreds of families that he victimized.

 13                 THE COURT:     Thank you, Ms. Cusack-Sperry.

 14                 MR. NEFF:     Your Honor, I believe in addition there

 15    will be -- the Government would like to call Colton Sperry, who

 16    I believe is the son of Ms. Cusack-Sperry.

 17                 THE COURT:     Colton, if you can say your name, and

 18    spell your name.

 19                 MR. SPERRY:     Hello, Your Honor.       My name is Colton

 20    Sperry.     C-O-L-T-O-N, S-P-E-R-R-Y.       My grandma was Barbara Jean

 21    Cusack.     She died on November 21st, 2019.          My grandma was like a

 22    second mom to me.        We were so close, and I loved her so much.

 23    When I found out that Jon Hallford left her body in that

 24    building for years, I became very angry, sad, and depressed.                It

 25    got worse after I decided to go to a witness cremation, because


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  1    I wanted to make sure they were doing what they told us they

  2    would do with her body this time.

  3                I felt like my grandma died for a second time, but this

  4    time it was so much more worse, because she was treated so

  5    badly.     I miss my grandma so much, and I felt so sad for her

  6    that I told my mom if I died too, I could be with my grandma in

  7    Heaven and talk to her again.        I lost trust in everyone and

  8    cried almost every day.       My mom and dad were so worried about me

  9    that they took me to a hospital for a mental health check.

 10                The physiologist at the hospital recommended that our

 11    family got counseling through Judi's House to help me in my

 12    grief.     I went to counseling for several months, but didn't get

 13    really any help that helped me.         My parents ended up spending

 14    several thousand dollars on an emotional support dog for me.

 15    This dog, my dog Twinky is the only thing that actually helps me

 16    feel better when I am sad or mad about what happened to my

 17    grandma.

 18                Please give Jon Hallford the longest sentence possible,

 19    because he hurt hundreds of people.         He could have used that

 20    money to do the right thing, but he didn't care about any of the

 21    victims nor their families.       He chose to leave those bodies in

 22    that building and rot to spend the money on himself.           Jon

 23    Hallford deserves the full sentence.

 24                 THE COURT:    Thank you.

 25                 MR. NEFF:    At this time, the Government would also


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  1    ask, is there a Derrick Johnson here who would like to make a

  2    statement?

  3                 MR. JOHNSON:   Hello, Your Honor.      My name is Derrick

  4    Johnson.     D-E-R-R-I-C-K, J-O-H-N-S-O-N.      In one of the most

  5    grotesque discoveries in modern American funeral history, 191

  6    human bodies were left to rot in filth, stacked, decaying,

  7    melting into one another in a building that became a tomb of

  8    lies.

  9               My mother, Ellen Lopes, was one of them.         She was not

 10    treated as a human being.       She was treated as waste.      They all

 11    were.   As I said, my name is Derrick Johnson, and I've traveled

 12    over 3,000 miles to be able to come here and give this impact

 13    statement of how this affected me, my family, the community.

 14    I'm a teacher, a coach, a husband, a father, and a son, the only

 15    child of Ellen Lopes, whom we entrusted her final moments to the

 16    care of a business that pretended to honor the dead while

 17    instead desecrating them in ways that words fail to even

 18    capture.

 19               My mother was a pillar in Southern Colorado Springs, a

 20    surrogate mother to many, a woman who would literally give her

 21    last to anyone that had less, a traveler, a giver, a soul so

 22    magnetic she built a family that spanned the globe.           Even more

 23    so through social media.       She was surrounded by love when she

 24    died on February 12th of 2023 in hospice.

 25               We did everything right.      We made plans to honor her


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  1    last wishes to be cremated and have her ashes spread on Maui so

  2    that she could watch over her only son and her grandchildren.

  3    We paid for a cremation, and we trusted Return to Nature to

  4    honor her wishes.      We took the fake ashes that they gave me,

  5    which was really concrete powder, and we had a funeral.             We

  6    planted a tree with that underneath it.         All of that means

  7    nothing now.     There's no closure to anyone that knew her.             I

  8    don't even think that's possible.        It's just a tree of lies now.

  9                Within 30 minutes of her passing, Return to Nature

 10    arrived and took her away.       That was the last time that she was

 11    treated with any dignity.       From there she was driven to the

 12    Penrose House of Horrors and rolled out like freight, discarded,

 13    and thrown into a festering sea of death.

 14                To this day, I lie awake at night wondering, was she

 15    naked?    Was she stacked on top of others like lumber?         Was she

 16    at the bottom, crushed by the weight of strangers in a similar

 17    betrayal?     Did she rot in silence with her soul hovering above

 18    in disbelief?     I torment myself with visions of her decomposing,

 19    skin sloughing off, and liquid seeping into the floor, rats and

 20    maggots feasting.      That house was literally hell.

 21                These conditions meant nothing to the demented mind of

 22    Jon, to the point that he could order burgers covered in

 23    decomposition fluid.       I also wonder, if he could think of food

 24    in a time like that, what else could he stomach?           This nightmare

 25    was not a mistake.      It was calculated.     Jon and his wife, Carie,


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  1    made this their lifestyle, executing their sick plan again and

  2    again and again, a minimum of 191 times.

  3                And while the bodies rotted in secret, they lived, they

  4    laughed, and they dined.       They traveled.       They bought luxury

  5    vehicles, shopped in Vegas.       My mom's cremation money likely

  6    helped pay for a cocktail, a day at the spa, a first class

  7    flight.     They didn't use money for refrigeration, burials, or

  8    dignity.     They used it to feed their appetite.

  9                Even when handed a lifeline, COVID relief funds, they

 10    didn't even stop.      They didn't try to make things right.          They

 11    doubled down on the selfishness.        Not once did they or have they

 12    shown reason or remorse, and their lack of these things is

 13    almost as disturbing as the crime itself.            Not once did they

 14    pause to consider the human cost.        I wonder if they prayed for

 15    forgiveness even once, or did they only pray for more victims as

 16    their cash ran low?

 17                The fact that they enjoyed what they were getting out

 18    of it to such a high degree that they wouldn't stop themselves

 19    makes them sadistic, truly.       What they did wasn't just illegal.

 20    It was inhuman, and it was soul-killing.

 21                My trust in people has been shattered.         I walk around

 22    with paranoia now, thinking everyone has a secret.            I needed

 23    therapy, spiritual counseling, and medication, and still the

 24    nightmares follow me.       I can't even enjoy movies, music.         Even a

 25    Disneyland ride with my children, Pirates of the Caribbean, with


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  1    skeletons laying around everywhere, brought me to tears.             Hear

  2    that again.    A mental breakdown in the happiest place on earth.

  3    Everything reminds me of the grotesque truth.           October is

  4    unbearable because of Halloween.         Decorations make me nauseous.

  5               The only dream I've had of my mother since her passing

  6    came the day they demolished that building.           She waved to me,

  7    maybe good-bye, maybe hello, but since then only darkness.

  8               This experience has ruined so much of who I was.           I am

  9    not the same father, husband, or teacher that I was before.               I'm

 10    haunted.    We all are.     And the saddest part is that this didn't

 11    have to happen.       Jon and Carie chose this path.       They chose it

 12    daily, and they monetized grief and made a mockery of death.

 13               According to the Cambridge dictionary, "ruthless" means

 14    not thinking or worrying about any pain caused to others.             That

 15    word is not strong enough for what they are, but it fits.             They

 16    were in a position of trust with our loved ones, and with

 17    families at their most vulnerable, and they desecrated both of

 18    them, one physically, and one mentally.

 19               If justice means anything, if fairness still matters,

 20    then for the 191 lives stolen from peace in that building, for

 21    the hundreds of unknown victims, and for the thousands of

 22    families that have been plunged into this trauma, for the total

 23    absence of humanity in their actions, I ask the Court to impose

 24    the maximum sentence possible.         Please let this be a reminder

 25    and a statement of the future that death should be sacred, and


                               Kevin P. Carlin, RMR, CRR

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  1    those that violate that trust deserve no leniency.           Thank you.

  2                THE COURT:     Thank you, Mr. Johnson.

  3                MR. NEFF:     Cecilia Converse.     Is Ms. Converse here?

  4                MS. CONVERSE:     Cecilia Converse.     C-E-C-I-L-I-A,

  5    Converse, C-O-N-V-E-R-S-E.       I don't have a speech, and everyone

  6    has so eloquently explained the way all of us have felt.             I took

  7    my daughter, Amber Nichol Haines.        I trusted this business.         I

  8    was supposed to hear back in three days if I was even able to

  9    make the decision to have her cremated or not, and then of

 10    course she would have to go to Denver.          And three days later, I

 11    called, and she was already ready.        So, instantly, I knew

 12    something was off.       And I -- obviously it's not something you

 13    would ever even imagine that someone could do something like

 14    that, take my beautiful child and just throw her in a pile.

 15               And like he said, when you have thoughts of how many

 16    people were on top of her?       Was she in a bag?     I mean, just --

 17    it's just vile and disgusting, and I just want to make sure that

 18    this individual gets at least 20 years.          I think that would be

 19    the minimum.     Thank you.

 20                THE COURT:     Thank you, Ms. Converse.

 21                MR. NEFF:     Ms. Beth Gannon.     Is Ms. Gannon here?

 22                MS. GANNON:     Thank you, Your Honor.     My name is

 23    Elizabeth Gannon.       E-L-I-Z-A-B-E-T-H, G-A-N-N-O-N.      Your Honor,

 24    thank you for allowing me to share my personal statement today.

 25    Again, my name is Elizabeth Gannon.          My father's name is Edward


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  1    Peter Lynch.     My mother's name is Darlene Christy Lynch.           In

  2    addition to the obvious grief and heartbreak, I have tried to

  3    come to terms with the abhorrence I feel knowing that

  4    approximately 200 bodies were tossed without any empathy for the

  5    grieving loved ones and the family members.            There was no

  6    compassion shown towards each of the sacred bodies that were

  7    once living and breathing human beings, and very loved people.

  8               One of the most difficult feelings that I personally

  9    cannot get past is the overwhelming feeling of shame and guilt,

 10    because it was my choice to choose Return to Nature.             I

 11    personally feel this overwhelming shame and guilt because as I

 12    said, it was my decision and my decision alone to use the

 13    services of Return to Nature for both of my parents.             My mom and

 14    dad did not make that choice before they passed.             They didn't

 15    choose Return to Nature.         I chose Return to Nature.      No other

 16    family member made this decision.          Nobody else was involved.       It

 17    was me alone.     It is my poor decision that caused this to happen

 18    to my parents.        Simply myself.

 19               When I initially learned of this heartbreaking

 20    situation, I chose only to share the information with my husband

 21    and no one else due to this, again, overwhelming guilt that I

 22    feel of such a poor decision that I have made.            I didn't even

 23    tell my two grown sons about what had happened to their

 24    grandparents.     And it wasn't until later, when Alisha from the

 25    FBI convinced me that I should do so, because sooner or later


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  1    they would figure it out, and they should really hear it from

  2    me.

  3               To this day, this very day, I still have not told my

  4    sister what has happened.       She lives out of state.       She has no

  5    idea what happened to our parents to this day.

  6               Although I have a wide network of family and friends, I

  7    have only told a small handful, possibly ten, that's it, that I

  8    am personally affected by this case.         Of those small hand --

  9    that small handful of people, each one of them has told me that

 10    I shouldn't feel guilty.       I did nothing wrong.       That it's Jon

 11    Hallford that did everything wrong.         He should feel guilty.

 12               But I have to say, my feelings are my feelings.            My

 13    feelings are the same today two years later as they were on day

 14    one when I heard about this.       My feelings don't change based on

 15    what somebody says to me.       My feelings are deep in my heart, and

 16    they will not change.

 17               Jon Hallford took nearly $900,000 of government funds

 18    meant to help provide a much needed service following the

 19    difficult COVID period, but it turns out he was not providing a

 20    compassionate, reliable service.        He stole money from grieving

 21    customers as well as the federal government to use for a selfish

 22    luxury lifestyle.      He did this willfully and knowingly.

 23               The horrific actions he engaged in has sentenced me to

 24    a lifelong impact of guilt and mistrust.            Since I have to suffer

 25    this sentence, it is only appropriate that Jon Hallford must


                              Kevin P. Carlin, RMR, CRR

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  1    also suffer a lifelong sentence.        With all this being said,

  2    despite the incredible weight that I care for allowing myself to

  3    get involved and trust the people at Return to Nature, I refuse

  4    to let Jon Hallford's action take over my life.           I will continue

  5    to live a very fulfilled life with my husband, my children, and

  6    my grandchildren.        This, Your Honor, Jon Hallford cannot take

  7    away from me.     Thank you.

  8                 THE COURT:     Thank you, Ms. Gannon.

  9                 MR. NEFF:     Is Ms. Tanya Wilson here?

 10                 MS. WILSON:     Good morning, Your Honor.     My name is

 11    Tanya Wilson.     T-A-N-Y-A, Wilson, W-I-L-S-O-N.        Excuse me for a

 12    second.     Thank you for allowing me to speak before the Court

 13    today.     I stand here on behalf of my mother, Yong Anderson, who

 14    was one of the family members discovered in the Return to Nature

 15    Funeral Home.     I'm also going to apologize up front, because it

 16    seems like I have a lot to say.

 17                For the past 20 months, I've had to sit in this anger

 18    and in this unimaginable grief, trying to process this whole

 19    nightmare.     There are a million words, but none seem big enough

 20    to accurately describe this in a way where anyone who wasn't a

 21    victim could possibly understand.

 22                My mother was the strongest woman I know.        She was the

 23    heart of our family.        She came to this country and worked three

 24    jobs at any given time to support her children.           She was tough

 25    and stubborn.     She was practical, the kind of woman who didn't


                                Kevin P. Carlin, RMR, CRR

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  1    waste time complaining, because she didn't have that luxury.

  2    But she loved us fiercely, and she loved her grandchildren with

  3    that same no-nonsense devotion.        She hid away the scars from her

  4    life and sacrificed for us to give us the life that she didn't

  5    have.

  6               So my mom deserved peace in death.        She deserved

  7    dignity.     She deserved so much more than to be dumped into a

  8    building left to rot, and she deserves for Jon Hallford to spend

  9    the rest of his life in prison for it.         I remember very clearly

 10    the day my mother died.       My brother and I were with her and held

 11    her hands as she took her last breath.         In our culture, the way

 12    a person is treated after death is important.          My brother and I

 13    took this role very seriously, and we did our very best to honor

 14    those traditions, to show her our love and our gratitude for

 15    everything that she had done for us in life.

 16               We bathed her.     We brushed her hair.     We put her

 17    favorite moisturizer on her face.        We dressed her in a

 18    traditional hanbok, but we added big soft socks, because her

 19    feet were always cold.      We left her gold bracelet on her wrist,

 20    the one that she had worn since I was a child.          And we tied a

 21    norigae to her honbak for luck on her journey, white to

 22    symbolize our grief.

 23               My mom wanted her ashes to be released in the ocean in

 24    Hawaii, so my brother and I, along with family and friends, flew

 25    to Hawaii.     We chartered a boat, and we sailed off the coast of


                              Kevin P. Carlin, RMR, CRR

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  1    Diamond Head as the sun was setting.         We released her into the

  2    water while the gentle waves carried her away.          It was

  3    beautiful, and it was perfect, and my mom would have loved it.

  4    So, we honored our culture.       We honored her wishes.

  5                We honored her, and then we made the mistake of

  6    trusting Jon and Carie Hallford to do the same.           And now I'm

  7    left horrified that it was all just a sick, twisted, and cruel

  8    lie.

  9                They came into my brother's house the day my mother

 10    died.     They talked about sending her with the blanket that I had

 11    made for her years ago.       They said they preferred to use

 12    something personal to wrap her up in, something from home.               We

 13    thought they were being thoughtful, but looking back, I now know

 14    they were just saving themselves a body bag.

 15                They also knew of our plans to release her ashes in

 16    Hawaii, a place that meant something to her, and still, still

 17    they looked us in the eye with a smile on their face, handed us

 18    a bag of concrete, promising us that they took good care of my

 19    mother.     What kind of monsters do you have to be to do something

 20    like that?

 21                Your Honor, I know we are here for wire fraud, but the

 22    fraud went far deeper than their financial crimes.           The fraud

 23    was just the vehicle that allowed them to keep deceiving

 24    families, to keep hiding bodies, to keep turning death into

 25    profit.     So, the name of the charge may be wire fraud, but the


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  1    impact is so much more.         Every morning for over a four-year

  2    period, the Hallfords woke up and made the calculated decision

  3    to betray grieving families like mine.           They didn't even attempt

  4    to rectify a fraction of the devastation they caused when they

  5    spent the pandemic money on themselves.

  6               And now, I can't even walk in a Home Depot anymore

  7    without feeling like throwing up every time I see those plastic

  8    storage totes they used to store the bodies in, of babies in.              I

  9    can't even look at pictures of my mother anymore without my

 10    thoughts being dragged back to Penrose, back to those mental

 11    images of the stacked bodies and the odors.

 12               Like Derrick said, I stay awake at night wondering,

 13    which room was my mom in?         Was she on the floor?      Was she on one

 14    of the tables?        Did she have other bodies stacked on top of her,

 15    or was she the one that Jon Hallford shoved off the gurney into

 16    inches of toxic fluids just so he could roll in the next loved

 17    one to be lost and forgotten?

 18               And I can't find that shelf in my mind or in my soul

 19    where all of those thoughts and feelings belong.             There's no

 20    place to set it down, because it consumes me, my thoughts, my

 21    memories, and my dreams.         Jon and Carie Hallford didn't just

 22    break the law.        They shattered lives.     They devastated thousands

 23    of families.     Nearly 1,200 families entrusted their loved ones

 24    to them.

 25               So, just imagine if the ashes that held a sacred spot


                                Kevin P. Carlin, RMR, CRR

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  1    in your home for years that you whispered your grief to may not

  2    be your person, and that you will never know for certain.

  3    Imagine not knowing if your loved one who was buried is actually

  4    in that grave that you stood over and cried over.             The

  5    Hallfords' greed and callousness has destroyed the trust of an

  6    entire community who now looks at the entire industry with

  7    suspicion.

  8               I read their character letters from his mother, his

  9    son, his friends, and they would like for you to see a good man,

 10    a caring father, a remorseful son.          They say he's taken

 11    accountabilities by pleading guilty, that he can be

 12    rehabilitated.        But this isn't about his future.       This is about

 13    justice for the victims.         Admitting guilt after being caught

 14    isn't accountability.        Trying to flee the state after the

 15    discovery of your crimes isn't accountability.

 16               What defines a person isn't all the good things -- good

 17    deeds that everyone can see.         It's what you do behind

 18    everybody's back when you think no one is looking that reflects

 19    who you truly are, and Jon Hallford has shown us who he truly

 20    is.   He placed his greed over his own family over our families,

 21    and he knew the consequences of his actions.            He even stated it

 22    in one of his own texts about going to prison when he wasn't

 23    joking about getting people juice on him right before he orders

 24    lunch.

 25               He chose to abandon his family, so it will be his fault


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  1    that he won't be there when his parents pass away or when his

  2    son gets married.      He made those decisions.      He chose to abandon

  3    his family when he chose to lie to grieving families and stuff

  4    bodies into rooms to rot while handing out bags of concrete.

  5                But what stood out to me the most in one of the letters

  6    was the claim that he didn't kill anyone, that he didn't

  7    physically harm anyone, so that somehow justifies a lighter

  8    sentence.     But I will tell you that I wish he had physically

  9    harmed me instead, because physical wounds can be healed, but

 10    what he did, what they did, that can't be healed.           And yes, it's

 11    true he didn't kill my mother, but he did annihilate her

 12    dignity.

 13                The bracelet that I mentioned, her favorite one that

 14    she wore my entire life, the white norigae that we attached to

 15    her honbak for luck, those were returned to us after her body

 16    was discovered, and they were given to us in a red plastic bag

 17    that had "biohazard" written across it.         So, I have to ask, in

 18    what world is it okay for a son to have to clean his own

 19    mother's decomposing flesh out of the links of her bracelet?

 20    Because that's what my brother had to do.

 21                The norigae discolored, disintegrated, saturated with

 22    toxic fluids from my mother's decomposing body and possibly the

 23    bodies of others that surrounded her, we don't know.           So, is

 24    that all somehow acceptable simply because he didn't kill her,

 25    and simply because the charge today is wire fraud?


                              Kevin P. Carlin, RMR, CRR

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  1                Up until that moment I think I was clinging to some

  2    kind of protective denial, some version of this nightmare that I

  3    could emotionally survive.       I heard the words "decomposing" and

  4    "rotting" and "bug infested," and I read the affidavits and saw

  5    the news reports, but nothing, nothing prepares you for the

  6    moment when you're handed the evidence of that horror, and in a

  7    red plastic biohazard bag.

  8                Seeing all those abstract words suddenly become a

  9    reality broke something in me, and I will never be whole again.

 10    Grief is supposed to be normal.        It's a part of the life cycle.

 11    It's natural and expected and something that we'll all

 12    experience at some point.       But this, this isn't normal.        The

 13    Hallfords took our grief and our mourning, and they twisted it

 14    into something so horrific that I feel like I'm in a walking

 15    nightmare, and I can't wake up from it.

 16                Your Honor, I'm begging for the maximum sentence

 17    possible.     Twenty years isn't enough.      They preyed on the

 18    vulnerable not once, not by accident.         This wasn't a mistake.

 19    Please help send a message to us, to the community, to others

 20    who are even thinking about exploiting a family's grief, that

 21    the dignity of the dead and the peace of the families that are

 22    left behind are still worth protecting, and they will not go

 23    without punishment.       Thank you.

 24                 THE COURT:    Thank you, Ms. Wilson.

 25                 MR. NEFF:    Just for planning purpose, Your Honor, I


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  1    want to let the Court know that I believe I have approximately

  2    four more people.        I don't know what time the Court will want to

  3    take its break.       I can continue.

  4                 THE COURT:     Why don't we get through all the victims,

  5    and then we will take a quick break.

  6                 MR. NEFF:     Yes, Your Honor.    Ms. Lisa Ostly.       Is

  7    Ms. Ostly here?

  8                 MS. OSTLY:     Hello.   My name is Elisabeth Ostly.           It's

  9    spelled E-L-I-S-A-B-E-T-H, O-S-T-L-Y.          Your Honor, my name is

 10    Elisabeth Ostly, and I stand before you as a bereaved daughter,

 11    and as a member of the countless families whose loved ones were

 12    dishonored by the abhorrent actions committed by Jon Hallford.

 13    While his federal offenses may appear to be merely victimless,

 14    white collar crimes, the actual gravity cannot be overstated,

 15    for its impact is deep, and its wound on our souls can never

 16    heal.

 17                Jon committed wire fraud and spent his ill-gotten gains

 18    on personal items like luxury cars, vacations, jewelry, and

 19    cosmetic surgeries.        Jon gave nearly 200 families urns of

 20    powdered concrete instead of their committed remains.            Jon

 21    maintained the fraud for years by covering doors and windows of

 22    the Penrose building, fabricating false death certificates, and

 23    lying to federal -- to funeral providers, regulatory bodies, and

 24    families.

 25                Jon stole our money instead of using those payments to


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  1    cremate our loved ones, instead of choosing to let our loved

  2    ones decay all together in that doomed building in Penrose.

  3    These acts are not mere negligence.           They represent prolonged

  4    intentional deceit over years, betraying vulnerable people at

  5    their most fragile moments.

  6                The desecration of my father's remains has shattered

  7    the sanctity of his final farewell, leaving my family and me in

  8    a perpetual state of disbelief and sorrow.            The knowledge that

  9    my father, Bruce Ostly, who lived his life with dignity and

 10    compassion, was denied his last wish to be returned to the Earth

 11    with respect, has been an agonizing burden we will forever bear.

 12                The pattern of egregious misconduct in both the

 13    handling of deceased individuals and the exploitation of

 14    pandemic relief funds represents a profound moral and legal

 15    breach.     Jon Hallford should be sentenced to the maximum

 16    allowable under federal law, not only to reflect the severity of

 17    his crimes, but also to ensure justice is served for victims,

 18    deter others from similar violations, and hold trust in

 19    institutions designed to protect the living and honor the dead.

 20    Thank you.

 21                 THE COURT:     Thank you, Ms. Ostly.

 22                 MR. NEFF:     Is Ms. Krista Johnsen here?

 23                 MS. JOHNSEN:     My name is Krista Johnsen.       K-R-I-S-T-A,

 24    J-O-H-N-S-E-N.        I had another nightmare last night, a nightmare

 25    of having everything stolen.         I am the daughter of Dale Marion


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  1    Johnsen.    She lived to almost 90 years old.        She and my dad were

  2    married just shy of 50 years.        And since my dad served in the

  3    U.S. Army during the Korean War, and he predeceased my mom by

  4    almost 20 years, he was buried at the National Veterans Cemetery

  5    in Dayton, Ohio, with all due military honors.          When my mom died

  6    in October of 2020, we used Return to Nature as a funeral home

  7    to cremate her body and to send those cremains to the Dayton

  8    National Cemetery.

  9               Because of COVID, we decided to wait until the next

 10    year to have her cremains shipped to Dayton to be buried

 11    alongside my dad.      And we left them, her supposed cremains, with

 12    Return to Nature during that time.        That's what the Hallfords

 13    led us to believe.      It's not what happened.      Like others here,

 14    the Hallfords left my mom's body to rot in an un-air-conditioned

 15    room for several years.       They shipped something, not my mom's

 16    cremains, from Colorado, and they even charged us extra for the

 17    shipping to the National Cemetery in Dayton.

 18               I flew there and buried who knows what alongside my

 19    father on the sacred grounds of the military cemetery.              And that

 20    cement or cat litter or whatever it was was buried with my dad

 21    in a hallowed military cemetery for several years.

 22               In October of '23, I got a call from the FBI that my

 23    mom's body had been identified in the building with the other

 24    Return to Nature Funeral Home scandal bodies.          I was filled with

 25    shock and anger and sadness and horror that I had failed my mom


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  1    when I hired Return to Nature to care for her remains.              I had

  2    not conceived of a world where swindlers would prey on people

  3    with their recently departed loved ones, much less that this

  4    would happen to me and my family.

  5                My mom was my best friend.      When we moved out to

  6    Colorado six years ago from Illinois, my husband and I bought a

  7    house that had an unfinished basement, and we built a fully

  8    handicapped accessible apartment for her so that she could age

  9    in place and be close, and I could take care of her as her

 10    health declined.

 11                Taking care of her at the end of her life was an honor.

 12    She was a brilliant woman who had a difficult life.           Among other

 13    things, she had an accident in college, and part of her spine

 14    was fused together, but that didn't stop her.          She was a teacher

 15    her whole life, but she taught four- to five-year-olds how to

 16    read and write in a couple of different schools for many years.

 17    She loved to problem solve, to read, and to travel.           She loved

 18    learning about health and nutrition.         She loved public

 19    television and murder mysteries like Agatha Christie novels.

 20    Her lifelong mantra was to leave a place better than how she

 21    found it, and even in her 80s she was on an accessibility

 22    committee of a board of the Brookfield Public Library in

 23    Illinois.

 24                She grew up in Chicago, Iowa, and Ohio.        She graduated

 25    from Northwestern University with an education degree before


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  1    this was a common thing to do.        She studied abroad in France in

  2    the 1950s, and became fluent in French.         She made sure all of

  3    her kids lived abroad and were fluent in another language, and

  4    we went to some of the finest universities in the nation.             I

  5    feel such a sense of shame around what happened, even though

  6    logically I know it is not my fault.         I was tricked, and I feel

  7    angry about that.      My mom did so much for me throughout her

  8    life, and I feel like I failed her in this final act of getting

  9    her properly buried with my dad.

 10               There's also another layer to this, which is that a

 11    friend of mine, Elizabeth Gannon, already testified, and that

 12    is -- I referred her after my parents -- my mom died, I referred

 13    her to Return to Nature.       And I know she said in her testimony

 14    that the decision was completely hers, and she doesn't in any

 15    way try to make me feel guilty about having made this referral,

 16    I still feel what I feel.

 17               This crime made me pay thousands of dollars for her

 18    supposed cremation.      I had to fly to Dayton and rebury my mom's

 19    ashes at my dad's gravesite.       I also had to take days away from

 20    my job going to -- I've been going to some therapy around this,

 21    because some of the things the injuries -- because they are

 22    mental, they're more long lasting.

 23               Like others, I'm a changed person.        I'm much less

 24    positive than I used to be.       I'm less trusting, and I view the

 25    world through a distrustful lens.        I recently interviewed a


                              Kevin P. Carlin, RMR, CRR

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  1    person to be a dog sitter, house sitter, and I just couldn't

  2    hire someone, because of the trust issues.

  3                As I'm the founder and sole proprietor of a nonprofit

  4    organization, and I have faced challenges in development of that

  5    organization stemming from this, what happened with the

  6    Hallfords.     I have managed to maintain essential operations, but

  7    I have not advanced the organization as I had originally

  8    planned.

  9                There is something so sacred about end-of-life rituals.

 10    Every culture has them.       Even some animals, like elephants have

 11    them.   My mom's dead body being so horrifically treated for

 12    several years feels like such an awful end to such a wonderful

 13    life, and peace of mind around this has been taken from me

 14    forever.     She did not deserve this ultimate abuse of her corpse,

 15    and I am left dealing with the aftermath.

 16                My life has been indelibly altered, and not for the

 17    good.   And I am working through the healing process.          I

 18    respectfully request more than the maximum sentence for Jon

 19    Hallford.     He does not deserve leniency, just as my mom's body,

 20    my parents' gravesite, and the Dayton Military Cemetery did not

 21    deserve to be desecrated.

 22                 THE COURT:    Thank you, Ms. Johnsen.

 23                 MR. NEFF:    If we could call Kailynn Page, please.

 24                 MS. PAGE:    Hello.   My name is Kailynn Page.

 25    K-A-I-L-Y-N-N, P-A-G-E.       I'm not a good public speaker, so bear


                                Kevin P. Carlin, RMR, CRR

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  1    with me.

  2                THE COURT:     It's all right, Ms. Page.

  3                MS. PAGE:    Your Honor, members of the court, and

  4    everyone listening, my name is Kai.         My big brother, David, was

  5    one of the individuals involved in this case, and his body was

  6    left on the floor of Return to Nature for a whole four years.

  7    My brother's decomposing body was stacked on top of others,

  8    thrown into a pile, left like trash, a burden to be dealt with

  9    later.

 10               I remember David with a smile on his face.         He brought

 11    joy to those who knew him, to me.        This tragedy has affected my

 12    entire family, along with hundreds of others.          I stand here

 13    today for our little brother, Cisco; our dads; grandma; and

 14    every member of David's family.        All of us were profoundly

 15    affected because we loved David deeply, and believe his body

 16    deserved dignity even in death.

 17               The shock of discovering that his body was mistreated

 18    for so long and that the ashes we were given weren't even his

 19    has been devastating beyond words.        The betrayal is something no

 20    family should ever have to experience, and it is a wound that

 21    can never fully heal.

 22               Jon Hallford, I am disgusted by your actions.            I am

 23    disgusted by who you have shown yourself to be.           You treated

 24    human beings, people who were loved deeply, as if they were

 25    trash to be hidden away and forgotten.         You made a choice day


                               Kevin P. Carlin, RMR, CRR

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  1    after day to keep doing it.       You lived with the smell, the

  2    sight, and the horror of what you caused, and you did nothing.

  3    You could have stopped at any point, and you didn't.

  4               You disgust me because you were comfortable in that

  5    filth and in that cruelty.       You disgust me because you didn't

  6    even have enough decency to pretend to care, even now that

  7    you've been caught.      We don't even see your face.       I don't

  8    believe you truly feel the weight of what you've done.              You only

  9    feel the weight of finally facing consequences, and I'm not sure

 10    if you even care based on past text messages and your actions as

 11    a whole.    Everything you and your partner did shows you did it

 12    all for your own selfish reasons.        You didn't have value for our

 13    loved ones, and that I will never understand.          You have been a

 14    stain on what it means to be human.

 15               I want the Court and everyone here to understand that

 16    this wasn't an accident.       This was deliberate.     You acted out of

 17    selfishness and cowardice, not desperation.          You made the

 18    conscious choice to betray hundreds of families and the

 19    conscious choice to desecrate the people we loved and still

 20    love.

 21               You even considered getting rid of my brother and

 22    others in a giant hole like some vile soup.          Who thinks that

 23    they could go through with that?        You would have if you could

 24    have, and it makes me sick.       Instead of never letting this

 25    happen in the first place, you went on far -- for at least four


                              Kevin P. Carlin, RMR, CRR

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  1    years worrying about how to cover it up and save yourselves.

  2    Make money and strive, no matter the cost.

  3                You couldn't even have respect for yourselves.           Where

  4    was your moral compass?       I do find peace knowing that in this

  5    life or the next, you will face justice for what you've done.                I

  6    can't say I know what you deserve.        I don't.     But no sentence

  7    could ever undo what you did.        No apology can undo this, and

  8    nothing will give David or any of the other victims the dignity

  9    you stole from them.

 10                But I hope you live every single day of your life

 11    thinking of how utterly vile your actions were, and how you will

 12    be remembered not for anything good, but for the horrific harm

 13    you chose to cause.      We will never forget, and neither will you.

 14    I wish I knew there was something in you that truly felt bad.                I

 15    will never know, even if you say it, but you did that to

 16    yourself.

 17                To the families of the other victims, to those who

 18    still don't know if their loved ones were involved in this case,

 19    and to everyone affected, whether you had to see it, hear about

 20    it, live through it, or are still waiting in the dark, I am so

 21    deeply sorry for what you've gone through.           You didn't deserve

 22    this, and none of us did.       I stand here today not only for my

 23    brother David, but for all of you as well.

 24                Thank you, Your Honor, and thank you to everyone here

 25    today for giving me the chance to speak for my brother and for


                              Kevin P. Carlin, RMR, CRR

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  1    all of us who have been forever changed by this tragedy, and

  2    good-bye, Jon.

  3                MR. NEFF:     Samantha Naranjo?     Is Ms. Naranjo here?

  4                MS. NARANJO:     Good morning, Judge Wang.

  5                THE COURT:     Good morning.

  6                MS. NARANJO:     Thank you for allowing me to speak

  7    today.    My name is Samantha, S-A-M-A-N-T-H-A.         My last name is

  8    Naranjo, N-A-R-A-N-J-O.        My grandmother Dorothy Tardif was one

  9    of the 189 bodies found inside Return to Nature building in

 10    Penrose, Colorado.       I stand in front of you today due to the

 11    actions done by Jon Hallford and his wife, Carie Hallford.

 12               Today, you have the daunting task of sentencing Jon

 13    Hallford for his crimes in regard to -- sorry -- in regards to

 14    conspiracy to commit wire fraud.         As we all know, this crime is

 15    because of another crime in state court, a horrendous and

 16    inhumane nightmare that my family and I will always be haunted

 17    by.

 18               Because of the crimes this couple committed, we were

 19    given Quikrete mixed with unknown remains.           We thought it was my

 20    grandmother and mixed them with her husband and her son, who

 21    passed prior to her.       I will forever be carrying around

 22    someone's loved one that I can never identify.           I had to cremate

 23    my grandmother.       I, as her grandchild, even though she has five

 24    children, one year and two months after she passed away.             My

 25    grandmother gained weight while rotting with 188 other bodies in


                               Kevin P. Carlin, RMR, CRR

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  1    a building covered in bugs, seeping from all four corners.

  2                I've shown up for countless court dates, both state and

  3    federal.     I sat and watched the building of said crimes be

  4    demolished by the Environmental Protection Agency.           I've

  5    appeared via Webex and spoke to the state capitol in regards to

  6    a bill to license and regulate the funeral home industry.            I met

  7    the governor at his mansion as he signed the bill into law.              I

  8    sat in person via Webex with department regulatory agencies to

  9    help implement regulations and licensing for the funeral home

 10    industry.     I sat with and spoke with -- via Webex with state and

 11    federal prosecutors.       I've met government officials from federal

 12    agents to deputy coroners, state representatives, to the city

 13    mayor.     I've held a gathering honoring all 1,178 victims and

 14    their families, bound together as we share each other's loved

 15    ones, a newfound family that has connected us in a way that no

 16    one should ever have to, as well as we can all relate and help

 17    each other get through this horrific situation.

 18                I have and will forever be scarred by Mr. Hallford and

 19    his wife, Ms. Hallford.       These individuals took money for a

 20    service that they not only failed to do, but in the process to

 21    cover it up, the lack of service, they desecrated our loved

 22    ones' bodies in such a disrespectful manner that not only

 23    crosses a moral line, but also any religious outlook.           These

 24    people did this without any sign of remorse.

 25                So, while this Court is looking at these crimes in a


                              Kevin P. Carlin, RMR, CRR

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  1    financial perspective, to us families, these crimes impact us in

  2    ways no money could ever make up for.         There's no way to put a

  3    dollar amount on a monetary value to our lifelong suffering.

  4    Not only did this couple violate the rights of our loved ones,

  5    but our beautiful state left us unprotected by people like Jon

  6    and Carie Hallford.

  7               I strongly believe by holding the highest statutory

  8    maximum penalty to these criminals, you are helping us families

  9    who are still fighting to protect our state from future monsters

 10    like the Hallfords.        Thank you kindly for your time today, and

 11    thank you generously for setting a standard for our beautiful

 12    state, for not just me, my child after me, but also everyone who

 13    lives in the State of Colorado.          We all deserve this respect.

 14    Thank you.

 15                 THE COURT:     Thank you.

 16                 MR. NEFF:     Your Honor, we do have one more.     I'm

 17    sorry.    I did have one more additional witness, and that would

 18    conclude the victim portion.        If I could call that witness?

 19                 THE COURT:     Yes, please.

 20                 MR. NEFF:     Thank you, Your Honor.    Ms. Chandra Savage.

 21                 MS. SAVAGE:     My name is Chandra Savage.

 22    C-H-A-N-D-R-A, S-A-V-A-G-E.        In May of 2020, during the height

 23    of the pandemic, when everything was uncertain and nothing was

 24    normal, we were at our loved one's bedside caring for him,

 25    saying our final goodbyes, and comforting him until he took his


                                Kevin P. Carlin, RMR, CRR

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  1    final breath.     We watched kind, caring, humbled me, and loved

  2    deeply slip away.

  3                Due to financial constraints, we were unable to honor

  4    his final wishes.      And with a heavy heart, we had to make the

  5    decision to have our loved one cremated against his wishes.

  6    With a list provided by hospice, I was given the daunting task

  7    of making the call.      Return to Nature had five-star reviews,

  8    with only one negative review about parking, and a beautiful

  9    website that was well thought out.

 10                Carie Hallford was the first to answer my call.         It was

 11    a professional conversation, and assuring me that our loved one

 12    would be taken care of with respect and dignity, and that a tree

 13    would be planted in his memory.        That never happened.     I

 14    provided the information requested, and we anxiously awaited

 15    his -- the arrival.

 16                Jon Hallford arrived alone and ill-prepared.        Due to

 17    the configuration of his home, he was unable to get the gurney

 18    into the house, so instead of finding someone else to help him,

 19    he tasked myself and two of his nephews with placing our

 20    lifeless loved one on a sling and carrying his body out to a

 21    gurney.

 22                But the trauma didn't stop there.       He lowered the head

 23    of the gurney first, and all of the fluids that our loved one

 24    had been struggling to breathe through ended up on his face.

 25    Jon simply wiped it off with a sheet and placed that same sheet


                              Kevin P. Carlin, RMR, CRR

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  1    over our loved one in front of us with no remorse, and carried

  2    on about his merry way.

  3               I've been in healthcare for over 20 years, and I work

  4    side by side with the local funeral homes who picked up our

  5    beloved elderly from our facility.        I knew -- I felt something

  6    in my heart, something was wrong.        But being in healthcare as a

  7    nurse, an infection preventionist and scheduling, I had a firm

  8    understanding of how the pandemic had affected business and

  9    staffing, so I brushed the red flags off, under the rug.            What

 10    else was I supposed to do?       Add to the family trauma, and demand

 11    we carry his body back inside and wait for the next time -- the

 12    next person to show up, hoping that it would be better?

 13               We planned an outdoor service to lay our loved one's

 14    remains to rest at the foot his brother's grave site, next to

 15    his father.    I called Return to Nature to inquire when his

 16    cremains would be ready for pickup, and that the cremains could

 17    be placed in an urn and pendants we had purchased online.

 18    Although I had not received a bill yet or even been informed of

 19    payment methods, Mr. Hallford's wife informed me -- was quick to

 20    inform me that until the services were paid in full, and that

 21    they could not -- the cremains could not be picked up, and that

 22    transferring the cremains to the urn would result in additional

 23    fees.   My final conversation with Return to Nature had shifted

 24    from professional and empathic during my initial contact, to

 25    abrupt and cold.


                              Kevin P. Carlin, RMR, CRR

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  1                I received the balance due via email and paid it in

  2    full online within minutes so that my brother-in-law could

  3    collect our loved one's cremains, hoping to put this experience

  4    behind us.     However, in October 2023, after my brother-in-law

  5    delivered vacuum trucks to return to Return to Nature for his

  6    employee as part of the cleanup effort, it became abundantly

  7    apparent that our experience with Return to Nature was far from

  8    over.     And instead of our experience being traumatic, it would

  9    become an unfathomable nightmare.

 10                I have had to overcome feelings of immense guilt,

 11    anger, and sadness for contacting and paying Return to Nature

 12    for services, or lack thereof.        My experience with Return to

 13    Nature was my first experience ever dealing with the funeral

 14    industry outside of my hometown, where the funeral home owner

 15    and director had always remained kind, supportive,

 16    compassionate, professional, and for many of us, they were our

 17    neighbor, our friend, or our classmate.         He didn't act like Jon

 18    Hallford, thank God.

 19                Return to Nature has deeply affected my sense of trust

 20    and security during already disheartening times.           Undoubtedly my

 21    brother-in-law has struggled with the thought of delivering

 22    vacuum trucks to possibly clean up his own uncle's decomposition

 23    fluids.     My family has been forced to relive the loss of our

 24    loved one, and his memory has been tainted with a horrific

 25    debacle of Return to Nature.


                              Kevin P. Carlin, RMR, CRR

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  1               We do not know if we received his cremains, cement, or

  2    someone else's loved one.        We don't know who we put to rest at

  3    the foot of his brother, next to his father.            And now, we have

  4    to find a way to accept the unthinkable.            We may never know.

  5    The owners of Return to Nature are not nor were they ever real

  6    honest and caring like their website said, like his Facebook

  7    said, like his Instagram said.        I looked before I ever used him.

  8    They are just a disgusting disgrace to the funeral industry that

  9    has done nothing but lie and prey on families during difficult

 10    times.

 11               They have mentally -- they have created mistrust and

 12    mental anguish for thousands of family members who have been

 13    forced to relive the loss of their loved ones.            If they had one

 14    ounce of humanity left, they would dig deep in their burning

 15    souls to give family closure with the actual truth of what they

 16    did with our loved ones' bodies.          I am angry they have created

 17    so much unnecessary emotional trauma, and are not deserving of

 18    the many tears that I have cried over their disgusting,

 19    inhumane, criminal behavior.        I pray that you have to lie awake

 20    in your prison cell tormented by the ghastly scene that you left

 21    behind for many years.       Thank you.

 22                THE COURT:     Thank you very much, Ms. Savage.          All

 23    right.    Mr. Neff, is that -- are those all the victims?

 24                MR. NEFF:    Yes.    I believe that is all the victims,

 25    Your Honor.    So, that concludes the portion of the victim


                               Kevin P. Carlin, RMR, CRR

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  1    presentation.

  2                THE COURT:     All right.   So, we will take a quick

  3    break, about five to ten minutes just so that people can get up

  4    and stretch, go to the restroom, and then we will resume.            We

  5    will be in a brief recess.

  6          (Recess at 11:09 a.m., until 11:22 a.m.)

  7                THE COURT:     Mr. Neff, at this time I will give you an

  8    opportunity to speak on behalf of the Government as to which

  9    sentence you believe is appropriate in this case.

 10                MR. NEFF:     May it please this Honorable Court,

 11    Counsel, Your Honor, in this case, the Government is -- under

 12    the terms of the plea agreement, the most we could ask for is 15

 13    years imprisonment, and that's what we're asking for, the max

 14    that we negotiated under the terms of the plea.           It's clearly

 15    warranted and justified.

 16               To some extent, it's difficult to follow on the heels

 17    of the 12 individuals who just spoke here in open court, who

 18    showed a lot of courage, strength, sadness, emotion, because

 19    their words really do speak a lot louder than mine.           They were

 20    the affected ones.       They were the injured ones, and their voices

 21    were the strongest.       It's hard not as a human to sit here and

 22    listen to what we just saw in this courtroom, and listen to and

 23    not be touched and moved.       That is our human condition, and it

 24    was very powerful.

 25               And it was powerful for a reason, because this crime


                               Kevin P. Carlin, RMR, CRR

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  1    did not have to occur.      This crime was senseless.       This crime

  2    was so deep on so many levels.        As noted by a number of these

  3    individuals, the defendant has pled guilty to and is before the

  4    Court on the offense of wire fraud.         It's a statute.    It's a

  5    fraud case.     And let's be clear here, there was absolutely a

  6    swindle here.     There was monetary damage.        The Hallfords

  7    promised these families a burial and cremation of their loved

  8    ones.   Jon Hallford looked these people in the eye, shook their

  9    hands, promised them he'd take care of their loved ones, showed

 10    up at their houses, collected the bodies.

 11               His wife participated in this, and they gave them the

 12    impression that all things would be taken care of with due

 13    respect, and they collected payment for that.           That's part of

 14    the fraud.    It is a fraud.     It does involve loss in that

 15    respect.

 16               But on October 5th of 2023, when the Fremont County

 17    Sheriff's Office obtained a warrant and entered the Penrose

 18    location, found the 191 decomposing bodies, it was clear that it

 19    was indeed a big fraud.       The money that people had paid for the

 20    funeral or the cremation was all for nought.           The cumulative

 21    loss for these people was $193,000.         So, as I sit here, yes,

 22    this is a wire fraud case.       It involved lies and deceit, and

 23    people lost money in the tune of $193,000.           So, it fits the

 24    definition and a classic textbook case of fraud.

 25               But any reasonable, normal person who hears the facts


                              Kevin P. Carlin, RMR, CRR

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  1    of this case and the relevant conduct that this Court can

  2    consider in this case knows that this was no garden variety

  3    fraud.    There was incalculable harm to the next of kin and

  4    families that we've heard from who are here or in their papers

  5    or can't attend.       There was untold emotional damage, trauma,

  6    guilt, rage, all these experiences these people have said,

  7    they're so real, and we've heard about it.

  8               The pain, the grief, the torment continues to this day,

  9    as we've heard.       We've heard people say it will haunt them until

 10    the day they die.       The number of people we've heard have had to

 11    go into counseling and therapy to cope with the offense and its

 12    effects, some have even lost confidence and trust in humanity.

 13    They're forever damaged by this crime.          How horrible is that to

 14    think their trust in humanity has been taken because of this?               A

 15    number of them suffer from night terrors, sleepless nights.

 16    They have physical ailments due to what occurred here.               Some

 17    take medications now that they never dreamed of taking to sooth

 18    and deaden the emotional pain from this.

 19               So, to say all this and note that yes, this is a fraud

 20    case, yes, it involved economic damage, but as pointed out by

 21    these people, and there can be no dispute about it in this

 22    courtroom, this crime was a violation of all societal norms,

 23    decency, all boundaries and societal norms that allows for

 24    respect of the deceased were crossed and just blown right by

 25    year after year, body after body by this man and his wife.


                               Kevin P. Carlin, RMR, CRR

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  1               The respect that we have in our society, in our culture

  2    we have traditionally given to allow families to grieve for

  3    their loved ones and to memorialize the death of their loved

  4    ones in their own unique ways.        We heard about that based on

  5    family traditions, based on culture, based on customs, based on

  6    religious views.      That's unique and individual to people in our

  7    society, and that's valued in our society.

  8               However, that sacred rite, for no lack of a better

  9    word, and that opportunity to bury one's loved ones in a

 10    dignified and honorable fashion was stolen, make no doubt about

 11    it, by this defendant, and that's why he's before this Court.

 12    This crime indeed, as many people have said and acknowledged,

 13    but it bears repeating, was the ultimate betrayal of trust.

 14    When people were at their weakest, most vulnerable moment while

 15    mourning their loved one, they were taken advantage of.               Yes,

 16    this case does fall way outside the heartland of typical fraud

 17    cases, and yes, this case does warrant a maximum penalty as I'm

 18    allowed to argue for under the plea agreement, which is 15

 19    years.

 20               Now, I can't speak in the voice that we heard from this

 21    podium, the people who here live and present, but there's just a

 22    handful of statements that I think -- there's excerpts from that

 23    I'd like to note to the Court, because as I've indicated, I'm

 24    just an attorney making statements here.            The strongest impact

 25    and the most important point the Court can hear is from these


                              Kevin P. Carlin, RMR, CRR

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  1    victims and what happened.       So, I'd like to just quote from a

  2    number of their statements.

  3               There was one particular victim who was not able to be

  4    here today because of the travel, and she had car problems, but

  5    I do want to read her statement and emphasize the loss that she

  6    had, because I believe it is unique, and it's something the

  7    Court should hear.      This relates to Ms. Jataesha McCann.

  8    Ms. Jataesha McCann was writing on behalf of her deceased child:

  9               This crime pertaining to the Hallfords has affected me

 10    and my loved ones in a horrific, heartbreaking way.           It is a

 11    terrible thing that these individuals have done.           We all trusted

 12    them with our loved ones, someone who has meant the world to us.

 13    We were reassured that they will safely and properly take care

 14    of our loved one.      I am emotionally damaged.      I went four years

 15    thinking that my little infant's ashes were safe with me.             The

 16    day I received the call that something terrible had happened, my

 17    heart shattered into a million pieces again.          No, I was not

 18    fully healed from losing my child.        I was still losing --

 19    grieving the loss of my baby.        Then to hear that he was not

 20    properly cremated broke me and my family again.

 21               During this time, I pushed away a lot of my loved ones

 22    because I was livid, so much rage inside of me.           I have night

 23    terrors of this matter.       It is gut-wrenching.     It is hard for me

 24    to sleep at night.      I have a four-year-old son that I must care

 25    for, so I have no choice but to be strong for him.           I am seeking


                              Kevin P. Carlin, RMR, CRR

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  1    counseling.    I put it off for so long, because I'm afraid to

  2    talk about the situation, because it is disgusting.

  3               I will have to suffer with what the Hallfords have done

  4    for me the rest of my life of my time on this Earth.             Every day

  5    I must go through the pain of knowing that this horribleness is

  6    never going to change.        It will always be there to affect me.

  7    All of the victims are awarded compensation for this.             Yes, we

  8    should be compensated, but no amount of money can change what

  9    these individuals have done.         No amount of money can fix the

 10    pain that each one of us has experienced.             No amount of money

 11    will ever justify why people are so cruel and nasty.             We all

 12    deserve justice.

 13               From the words of Ms. McCann, who lost her newborn and

 14    trusted that her child would be cremated with dignity.                Those

 15    are her words.        That's the pain he caused.

 16               In addition, a couple other statements or excerpts, I

 17    just note for the Court I felt were worthy of mentioning.                We

 18    heard from Rodney Sefcovic, S-E-F-C-O-V-I-C.             His mother was

 19    Ilke Lopez, and in part, I quote from his victim impact

 20    statement:

 21               The impact of this crime has not only taken away my

 22    trust in people, but also destroyed my faith in humanity.                When

 23    someone passes away, that is the final act of their life, and it

 24    should be treated with the utmost respect.             To know that Ilke

 25    was denied even that basic dignity is something I will never be


                                Kevin P. Carlin, RMR, CRR

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  1    able to reconcile.      This betrayal has left me asking questions

  2    no one should ever have to ask themselves.            What will happen to

  3    my body when I die?      This will haunt me for the rest of my life.

  4                And he concludes, the emotional trauma of this

  5    discovery has been especially devastating for me, because I live

  6    with traumatic brain injury.       The stress and anxiety have made

  7    my condition significantly worse.        Immediately after I learned

  8    the truth, I had to take an entire month off of work just to

  9    cope.     Since then, I have missed weeks of work because I've been

 10    unable to function.      This crime has taken a toll not only on my

 11    mind and spirit, but on my livelihood.

 12                From the words of yet another victim, why did this have

 13    to occur?     This could have been stopped.         There was no need for

 14    this to occur over the course of four years but for the

 15    decisions of this man.

 16                Finally, I would use the last statement from an

 17    individual by the name of Charles Schweiss.            His excerpt reads

 18    as follows:     The crime has forever changed me, my wife, and my

 19    family.     I have lost trust in almost all humans.         Any mention of

 20    this case in the news reopens the deep wound, sending me into

 21    sleepless nights filled with restless thoughts of what mom --

 22    mom endured.     I now take medication to sleep, while my wife

 23    attends counseling to deal with the trauma.            The weight of

 24    knowing what was in the urn that I kissed in the 2020 contained

 25    nothing of my mother is unbearable.         The anger I feel is beyond


                              Kevin P. Carlin, RMR, CRR

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  1    words.     The Hallfords deserve nothing less than the maximum

  2    sentence.

  3                This poor man kissed the urn of his mother-in-law at

  4    the funeral, and now he felt embarrassed and shamed.           Why should

  5    he have to carry that?        Why should he have to take that through

  6    his life?     But he's just one of many people that have to take

  7    these things.     The story about Mr. Johnson and the Pirates of

  8    the Caribbean, unreal.        Unbelievable.     The man is just trying to

  9    enjoy a family day out with his family, and this intrusion comes

 10    into his mind because of what happened to his family.           This is

 11    not just wire fraud.        This goes into a whole 'nother realm of

 12    criminal conduct that needs to be addressed with the Court's

 13    sentence.

 14                So, let's talk about this.        I know some of the victims

 15    have mentioned it.      It's part of the case, but it needs to be

 16    addressed here, and it needs to be talked about in open court.

 17    I know it's difficult, but a lot of the victims have alluded to

 18    it.   The conditions at the Return to Nature Penrose facility

 19    were graphic, were brutal, defies imagination.           I know the Court

 20    has provided by the Government pictures from inside there as

 21    part of the Government's sentencing statement.           We had those

 22    sealed.     It was part of Agent Andrew Cohen's search warrant

 23    affidavit, and it shows the pictures that occurred there.

 24                So, I know the Court has seen that, but in this public

 25    forum as we have this sentencing, it's important to make sure we


                              Kevin P. Carlin, RMR, CRR

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  1    do understand what it was.         It was a house of horrors on

  2    steroids, no doubt about it.         Even the most depraved Hollywood

  3    director would dare to even present the conditions in a movie,

  4    because it would be declared obscene as a matter of law, because

  5    it was so grotesque and too offensive for public viewing.

  6    Ghoulish and macabre do not even begin to describe what occurred

  7    inside of his funeral home.

  8                This has to be acknowledged.        This is part and parcel

  9    of the conduct, the relevant conduct that this Court has to

 10    consider.     As already alluded to by people in this case in the

 11    presentence report, we had the bodies stacking in the

 12    decomposition within the building.          Bodies were in fact stacked,

 13    as someone said, like lumber, higher and higher.             Law

 14    enforcement agents couldn't even fit into certain rooms, there

 15    were so many bodies stacked so high when they first entered the

 16    building.

 17                Bodies were wrapped in tarps and duct tape.            Some

 18    bodies were just left in body bags.           Other bodies were left

 19    unclothed or partially clothed.          Some were just left on gurneys,

 20    some on the floor, haphazardly strewn across the building.                     The

 21    facility had no air conditioning and coolant when law

 22    enforcement entered.        All of the bodies were in various states

 23    of decay and decomposition, just rotting away, completely

 24    unattended to.        Some had flesh.    Some had bones.     Sometimes in

 25    between.


                                Kevin P. Carlin, RMR, CRR

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  1               Sometimes the bodies had moss and fungus growing on

  2    them.   There was human decomposition.          As alluded to, someone's

  3    brother, the last victim -- that's in fact true.             There was so

  4    much decomposition, when the FBI first went in, they tried to

  5    put boards down so they could walk through and find the right

  6    bodies and take them out.         Because the pooling of decomposition

  7    was so great on the floor, they finally got a pumper truck to

  8    pump it out of the building.

  9               Home Depot buckets were under tables where the bodies

 10    were, and it was collecting human decomposition as it melted, as

 11    someone said, as it dripped into the bucket.            As someone said,

 12    the decomposition was seeping out all corners of the building.

 13    That's true.     Up the walls.      It was horrendous.      The bugs -- I

 14    don't need to go any further.          Yes.   There was bugs, flies,

 15    larva, and all states within that building.

 16               The smell was overwhelming, difficult to breathe.               It

 17    was overpowering.        It was so bad, after the FBI agents went in

 18    and had paper inside the building -- like paper to write notes

 19    on, it smelled so bad afterwards, they had to transfer all that

 20    to clean paper so it wouldn't be in their files.             That stench of

 21    human decomposition was so bad, the camera equipment that they

 22    took inside the building, it absorbed -- the rubber pieces on

 23    that video and camera equipment absorbed the smell of

 24    decomposition.        It was so bad they had to destroy and get rid of

 25    their camera equipment.         That's how bad it was in this building.


                                Kevin P. Carlin, RMR, CRR

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  1                And as alluded to ultimately, the building was torn

  2    down by the EPA, because it was essentially a toxic waste dump.

  3    Think about that.       It didn't get to go to the regular waste

  4    disposal location.       It had to go to a hazardous waste site

  5    because of what he and his wife allowed to occur within there.

  6                And then of course law enforcement had to respond.

  7    People like Special Agent Chris Adams with CBI, who is at the

  8    table, and Andrew Cohen with the FBI, they were just one of many

  9    and a team of various law enforcement agencies who got involved

 10    in this case.     Fremont County Sheriff's Office, Fremont County

 11    Coroner's Office, El Paso County's Coroner's Office.

 12                It was so bad at Penrose that they had to actually call

 13    in a military special team from the Air Force who helps with

 14    large-scale disasters to help recover and then identify the

 15    bodies.     At Penrose, the recovery process, the agents worked in

 16    40-minutes-at-a-time shifts.        That was all they could take being

 17    in the building, and then they had to come out, because the

 18    conditions were so horrific.

 19                So, the FBI rotated three teams of approximately six to

 20    seven people at a time for 40 minutes only.           Before they would

 21    go in, they had to wear hazmat suits.          That's Tyvek body suits,

 22    protective boots, gloves, respirators, full respirators.             The

 23    conditions were horrific.        The bodies were heavy.      They were in

 24    horrible shape.       It was extremely hot.     The environment was

 25    overwhelming, extremely distressing, and disturbing.


                               Kevin P. Carlin, RMR, CRR

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  1                Afterwards, a number of the agents received counseling

  2    and debriefings to deal with what they had seen in there.                After

  3    the bodies were recovered and they'd come outside, there was a

  4    whole contamination zone set up with a bunch of other agents who

  5    would just clean off the agents who had been inside, and there

  6    were medics there to give them IVs and to check their vitals to

  7    make sure they were holding up under these conditions.                That was

  8    just the first scene.

  9                After that the bodies had to be -- they were recovered

 10    at that point.        They were escorted by the highway state patrol

 11    over to the morgue in El Paso County.           And at that location,

 12    they had to rent and pay for several refrigerator trailers so

 13    that the bodies could initially be stored before they were taken

 14    inside to the coroner's office, where the daunting task of

 15    collecting fingerprints, looking for medical bracelets, checking

 16    dental records or ultimately DNA -- DNA sampling was used to

 17    identify.

 18                This whole process took from two to three weeks total

 19    between the recovery through the identification process.                This

 20    needs to be stated.        This was a horrendous scene.       It was all

 21    caused by the defendant's conduct, along with his wife.

 22                So, when we ask for the 15 years, what are some of the

 23    factors that the Government wants the Court to think about and

 24    consider?     Well, as noted by a lot of people, this went on -- it

 25    wasn't a one-time, isolated incident.           It went on for four


                                Kevin P. Carlin, RMR, CRR

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  1    years.     It involved lie on top of lie and deceit on top of

  2    deceit.     It's hard to imagine where, when he's showing up after

  3    two years, three years, and he's already collected 100 bodies in

  4    this building, he's yet still willing to lie to people, look

  5    them in the face and say, I will take care of your loved one.

  6    It's a lie on top of a lie.

  7                It makes it so horrendous to think that he acted in

  8    this way.     And as alluded to by someone, there was surveillance

  9    camera from -- cameras from inside the building.           The defendant

 10    had that as part of his system there, and it's identified in

 11    paragraph 52 of the presentence report, but it does describe an

 12    incident where -- and I will just read from the report.

 13                A review of surveillance cameras that were located on

 14    the property revealed an incident on September 9th of 2023 in

 15    which Jon Hallford entered the building with a body on a cart.

 16    The interior camera shows multiple deceased bodies in the room

 17    with one on a gurney.       Jon Hallford dumped, I emphasize dumped,

 18    the body on the ground, on the floor, and wiped down the

 19    decomposition from the gurney onto the other bodies in the room,

 20    as that specific gurney was needed.         That's someone's father,

 21    grandfather, child, son, mother, was just dumped on the floor.

 22    This was the environment that he went to on a regular basis and

 23    conducted business.      He knew what was going on in there.        He

 24    knew it, but he continued.

 25                And let's get some insight into his mind.        I want to


                              Kevin P. Carlin, RMR, CRR

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  1    just cite two quotes that we provided the Court, but they're

  2    worth noting.     Bodies started to collect without being buried or

  3    cremated in September of 2019.        Only eight months into the

  4    crime, he's texting his wife, and I will use his language and

  5    what he said to his wife in a text to her on May 5th of 2020.

  6    This was part of our sentencing statement:

  7                I don't give a fuck about this family.        I will give a

  8    fuck about what's happening in Penrose, our not going to prison,

  9    and getting the fuck out of this community.          My one and only

 10    focus is keeping us out of jail.        What is yours, question mark?

 11                Eight months into this, that's his mindset.         I don't

 12    care about anybody else.       I just don't want to go to prison, and

 13    I want to get out of this community.         Then, forward to

 14    October 6th of 2020, one year into the crime.          And that's when

 15    he has a exchange -- or he writes this again to Carie, the

 16    codefendant in this case, his wife:

 17                By December 6th, we need to begin cleaning and

 18    restoring the building in Penrose to be out by December 31st.

 19    Options, A, build a new machine, ASAP.         B, dig a big hole and

 20    use lye.     Where?   C, dig a small hole and build a large fire.

 21    Where?     D, I go to prison, which is probably what's going to

 22    happen.

 23                Yes, indeed, that's happening.      And it should happen,

 24    and it's going to happen shortly.

 25                The defendant kept taking money and stacking bodies


                              Kevin P. Carlin, RMR, CRR

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  1    even after he knew prison was inevitable for what he did.              In

  2    the course of that, they even buried two wrong bodies -- this is

  3    a man who doesn't care -- at a national cemetery, a veteran of

  4    our community at Pikes Peak National Cemetery, he put the wrong

  5    body in there.        Not only was it traumatizing for the veteran's

  6    family when they found out, but the poor lady who wasn't

  7    supposed to be in the grave, when she was contacted and her door

  8    was knocked on, their whole family had to go through grief

  9    because they found out their mother wasn't in fact cremated, and

 10    the remains that they had were in fact not of their mother.

 11               And as indicated, some people can say it better than

 12    me, so I won't belabor it, he had a chance to fix all this.

 13    He -- through his lies, he managed to get approximately $800,000

 14    from the COVID -- from the Small Business Administration to keep

 15    his business going during the pandemic.           That money was to be

 16    used to keep the lights on and make sure he could give his

 17    clients what they needed, his customers the service as they

 18    buried their loved ones.

 19               If he had taken just a portion of that, 100,000,

 20    $200,000, whatever, he could have bought a retort, which is

 21    effectively a cremation machine, and he could have perhaps

 22    started to undo the wrongs that he had done, and clean it up.

 23    He could have just stopped taking bodies when he realized he

 24    didn't have anything to do with them.           He had numerous options

 25    to put an end to this early on, even at a point where he knew he


                                Kevin P. Carlin, RMR, CRR

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  1    was going to prison, but he just kept trucking right on down the

  2    road.

  3                Please send me your check, give me your credit card.           I

  4    will take your money.       You bet I will take care of your loved

  5    one.     All the while he's blowing the money from the Government

  6    on the things we already heard about, lavish lifestyle trips,

  7    entertainment, plastic surgery, SUV, college tuition, and the

  8    list goes on.     It was greed, simple greed.

  9                Well, I'm about done here.      I'm about to my closing,

 10    but I would like to just end with a couple things.           Your Honor,

 11    as counsel actually quoted from Ms. Stokes at the start, there

 12    was a last-minute statement from a victim in this case that I

 13    thought can kind of put a capstone or a conclusion on what has

 14    occurred here, and what needs to occur here.          And it is from in

 15    fact victim Margarita Stokes.        It was provided to the Court, and

 16    again, I would like to just touch on a couple of her points that

 17    she said, because I think they can bring this together.

 18                She writes, the ashes we received, the ashes we

 19    believed were my mothers, are now a haunting question mark.

 20    You, Mr. Hallford, stole from us the certainty of her resting

 21    place.     You stole the peace that comes with knowing my family's

 22    loved ones was treated with dignity.         You deliberately turned a

 23    moment of deep sorrow into a source of ongoing anguish and

 24    doubt.     This was not only a professional failing on your part,

 25    it was an intense personal violation that has left indelible


                              Kevin P. Carlin, RMR, CRR

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  1    scars on my family.      We are left to wonder whose remains we

  2    have, and this is a torment no family should ever endure.

  3                Towards the end of her letter she states, when your

  4    time on Earth concludes, Mr. Hallford, you will face an internal

  5    reckoning for the heinous actions you committed.           The weight of

  6    your deception, the disrespect you showed to the deceased, and

  7    the pain you inflicted on grieving families will be a burden you

  8    will carry into eternity.       There is no escaping the spiritual

  9    consequences of such a profound betrayal of trust and human

 10    decency.

 11                And in her concluding portion she states, today,

 12    however, marks a turning point for my family.          The uncertainty,

 13    the anger, the feeling of violation, they have consumed our

 14    thoughts and stolen our peace.        This sentencing closes a

 15    chapter.     We will reclaim our lives.      We are taking back the

 16    emotional energy and mental space that your horrific deeds have

 17    occupied.     Today, we begin the process of truly moving forward,

 18    leaving you and your deplorable actions in the past where they

 19    belong.

 20                The sentence you impose here today, Your Honor, will be

 21    a pivotal and important part of the start of the healing process

 22    for many of these victims here and who are not in this

 23    courtroom.     It will allow them, as Ms. Stokes said, to start,

 24    perhaps, to reclaim their lives.        It will allow them the chance

 25    to restore their dignity, possibly restore their faith in


                              Kevin P. Carlin, RMR, CRR

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  1    humanity by giving them some sense that there is justice, there

  2    is some just punishment in our society.

  3               And hopefully, hopefully, this sentence we're asking

  4    for will allow them to once again find peace in their lives,

  5    which they so richly deserve after all the pain and suffering

  6    that they have gone through due to this man's actions.              For all

  7    of these reasons, Your Honor, we are asking for the upward

  8    departure, and we are asking you sentence Jon Hallford to 15

  9    years' imprisonment.      Thank you.

 10                THE COURT:    Thank you, Mr. Neff.      Mr. Hallford, at

 11    this time, I want to give you an opportunity to address the

 12    Court with anything you'd like me to know as I make my

 13    sentencing decision.      You are under no obligation to speak, but

 14    if you would like to say something, I would be glad to listen.

 15                MS. SUELAU:    Would Your Honor like Mr. Hallford to go

 16    to the podium or remain seated?

 17                THE COURT:    He can remain seated.

 18                THE DEFENDANT:     Your Honor and all those that are

 19    present here today, and to all those who are not, James 1:8, a

 20    double-minded man is unstable in all his ways.          That verse sums

 21    me up during the four years of Penrose.         We opened Return to

 22    Nature Funeral Home to make a difference, to facilitate change

 23    within our industry, to do a better job by way of the

 24    environment, and to do something good and right.

 25               Then everything got completely out of control,


                              Kevin P. Carlin, RMR, CRR

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  1    especially me.        No words of mine can ever justify my horrible

  2    actions.     No words of mine can ever undo the deep and lasting

  3    harm my actions have caused.         What was meant to be a soft place

  4    for grieving families to land turned into a nightmare for all

  5    those who trusted us.        However, the victims of Penrose are not

  6    just limited to those families.          They also include the community

  7    first responders, law enforcement, the El Paso Coroner's Office,

  8    the Fremont County Coroner's Office, and all those involved with

  9    the cleanup of Penrose, who all have to live with the horrible

 10    memories of that place.

 11                I have no idea how to express the amount of regret or

 12    the amount of sorrow I feel towards everyone.            I am so deeply

 13    sorry for my actions.        Please believe me when I say this is not

 14    me.     Penrose is not who I am.       I made so many mistakes.       I am

 15    sorry to my children, who are also victims of my decisions.                  I

 16    love my children, and I ask them to please forgive me for my

 17    sins.     My actions have harmed my whole family, costing my

 18    children their father and my parents their son.

 19                To my family, I love you all.        Please forgive me.         I do

 20    not recognize who I was during those four years.             I was living a

 21    double life.     I was unstable towards my wife and my children, my

 22    parents, my sister, pulling away from my friends and our

 23    business, unstable in every way.          Living with the guilt of my

 24    actions destroyed my soul, and it changed who I am.             I have

 25    never been so lost.        I hated myself.     I still hate myself for


                                Kevin P. Carlin, RMR, CRR

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  1    what I've done.

  2               All the victims deserve peace and an absolution.            All I

  3    can offer is my deepest apology and assurance that nothing like

  4    this will ever happen again.       I will carry the regret of my

  5    actions with me for the rest of my life, every single day.

  6               I will not disrespect or dishonor any victim by blaming

  7    my actions on someone else.       I am responsible for what -- for my

  8    choices, and for my role in what took place.          I wish that I

  9    could undo the harm that I have caused.         I know I can't, but I

 10    do accept responsibility for causing that harm.           Thank you.

 11                THE COURT:    Thank you, Mr. Hallford.      Although I may

 12    not mention all of them, I have carefully considered the factors

 13    set forth in 18 USC Section 3553(a).         My responsibility here is

 14    to determine a sentence that is sufficient but not greater than

 15    necessary to comply with the purposes set forth in section

 16    3553(a)(2).    In considering the sentencing guidelines, I do not

 17    start from the presumption that the guidelines are reasonable.

 18    Instead, I must make an individualized assessment based on the

 19    facts presented.

 20               The factors that I consider according to the statute

 21    are the nature and circumstances of the offense; the history and

 22    characteristics of the defendant; the need to reflect the

 23    seriousness of the offense, to promote respect for the law, and

 24    to provide just punishment for the offense; the need to afford

 25    adequate deterrence to criminal conduct; the need to protect the


                              Kevin P. Carlin, RMR, CRR

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  1    public from further crimes of this defendant; the need to

  2    provide the defendant with needed educational or vocational

  3    training, medical care, or other correctional treatment in the

  4    most effective manner; the kinds of sentences available; the

  5    kinds of sentence and sentencing range established for someone

  6    who commits this category of offense and has this criminal

  7    history level set forth in the sentencing guidelines; any

  8    pertinent policy statements in the sentencing guidelines issued

  9    by the sentencing commission pursuant to 28 USC Section

 10    994(a)(2) and in effect at the date this defendant is sentenced;

 11    the need to avoid unwarranted sentencing disparities among

 12    defendants with similar records who have been found guilty of

 13    similar conduct; and the need to provide restitution to any

 14    victims of the offense.

 15               The Court begins this discussion with the nature and

 16    circumstances of the offense.        As an initial matter, the Court

 17    turns its clear eye to the elements of the crime to which

 18    Mr. Hallford is pleading guilty in this court, conspiracy to

 19    commit wire fraud.      The elements of that criminal offense are,

 20    first, that the defendant agreed with at least one other person

 21    to violate the law, to knowingly commit wire fraud.           Second, the

 22    defendant knew the essential objective of the conspiracy.

 23    Third, the defendant knowingly and voluntarily involved himself

 24    with the conspiracy.      Fourth, there was an interdependence among

 25    members of the conspiracy, that is the members in some way or


                              Kevin P. Carlin, RMR, CRR

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  1    manner intended to act together for their shared mutual benefit

  2    within the scope of the conspiracy charged.            And fifth, that the

  3    defendant acted with the specific intent to defraud.

  4               The elements of wire fraud are, first, that the

  5    defendant devised or intended to devise a scheme to defraud as

  6    alleged in the indictment.         Second, the defendant acted with the

  7    specific intent to defraud.         Third, the defendant used or caused

  8    another person to use interstate or foreign wire communications

  9    for the purposes of carrying out the scheme.            Fourth -- and

 10    fourth, the scheme was deployed by false or fraudulent

 11    pretenses, representations, or promises that were material.

 12               A scheme to defraud is conduct intended to -- intended

 13    to or reasonably calculated to deceive persons of ordinary

 14    prudence or comprehension.         A scheme to defraud also includes a

 15    scheme to deprive another of money, property, or the intangible

 16    right of honest services.

 17               An intent to defraud means an intent to deceive or

 18    cheat someone.        A representation is false if it's known to be

 19    untrue or is made with reckless indifference as to its truth or

 20    falsity, and a representation would also be false when it

 21    constitutes a half truth or effectively omits or conceals a

 22    material fact, provided it is made with an intent to defraud.

 23    And a false statement is material if it has the natural tendency

 24    to influence or is capable of influencing the decision of a

 25    person or entity to which it is addressed.


                                Kevin P. Carlin, RMR, CRR

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  1               The Court begins with these legal elements,

  2    Mr. Hallford, not to provide a law school lesson to you, the

  3    attorneys, or those in the gallery.         The Court begins here

  4    because it frames its entire analysis of the Section 3553(a)

  5    factors and the sentence that the Court has determined to be

  6    sufficient but not greater than necessary to comply with those

  7    factors.

  8               In doing so, the Court recognizes that there is a state

  9    case involving the abuse of corpse felonies to which you have

 10    pled guilty.     But to the extent that there is any confusion, the

 11    Court wants to make clear that it is those elements, the

 12    elements of deceit and falsehood, that guides its consideration

 13    in the sentence here today.

 14               Mr. Hallford, you and your wife and codefendant, Carie

 15    L. Hallford, were joint owners in Hallford Homes, LLC, which

 16    operated under the trade name of Return to Nature.           You operated

 17    Return to Nature Funeral Home from approximately August of 2017

 18    through October of 20 -- October 5th, 2023, at which point it

 19    was closed by the State of Colorado law enforcement and

 20    regulatory officials.

 21               You ran your funeral business from two locations,

 22    including one in Colorado Springs and one located at 31 Werner

 23    Road, Penrose, Colorado.       In 2017, as reflected in your own

 24    sentencing statement, you gave an interview to a newspaper about

 25    the start of Return to Nature, and I read your quote therein.


                              Kevin P. Carlin, RMR, CRR

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  1    When I -- Return to Nature encouraged its customers not to

  2    embalm or preserve bodies with chemicals, he said.            When I

  3    started learning about green burial, I started thinking, why on

  4    Earth have we been doing this all this time, and how many times

  5    have I facilitated a final moment with a family member, and

  6    they've smelled or experienced formaldehyde, Jon said.               That's

  7    where it really sunk in that I'm not going to do this anymore.

  8    This is our passion.      I'm not going -- I'm not going to just

  9    leave the industry.      I'm going to find a better way to do it.

 10               Later on, the article notes that you say, in the

 11    funeral business, there are no guidelines, so when a body is

 12    being embalmed, whatever excess formaldehyde mixture is left in

 13    the tank just goes right down the drain.            It's not neutralized.

 14    It goes straight back into our water system that's eventually

 15    recycled or used.

 16               Beginning on or about September 15th, 2019, despite

 17    those words, despite knowing that the funeral business -- or

 18    perhaps because you knew that the funeral business lacked

 19    guidelines, and continuing through October 5th, 2023, you

 20    offered various services and products to the members of the

 21    public, including funeral burials and cremations.            You

 22    advertised your business to potential customers using the

 23    internet website which stated, among other things, in the

 24    frequently asked questions section, Return to Nature Funeral

 25    Home is a unique family owned and operated Colorado Springs and


                              Kevin P. Carlin, RMR, CRR

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  1    Penrose mortuary service.       We operate with three generations of

  2    funeral service experience and education.           Our family is here to

  3    serve your family and to guide you through every step of the

  4    bereavement process.      We cater to your family and provide your

  5    loved one with the utmost professional care and discretion.               Our

  6    family serving your family for over 80 years.

  7                You and your wife typically met customers and offered

  8    either burial or cremation using services of the Return to

  9    Nature Funeral Home.      The customers included individuals making

 10    their own funeral arrangements prior to death, family members,

 11    or friends of the recently deceased or next of kin of the

 12    deceased.

 13                Then you would enter a contract for goods and services

 14    with customers related to the services to be provided in

 15    connection with burial or cremation.         When a customer selected

 16    cremation, you would agree as part of the contract to arrange

 17    for the body of the deceased to be cremated.           Afterwards, you

 18    agreed to return the cremains, also referred to as ashes, to the

 19    family member, friend, or designated next of kin.

 20                When a customer selected funeral burial, you agreed to

 21    provide a burial of the deceased at a designated cemetery as

 22    well as supply a specific kind of coffin purchased by the

 23    customer.     And in addition to these written contracts, you

 24    verbally promised and represented to customers they would --

 25    that you would provide either cremation or burial as set forth


                              Kevin P. Carlin, RMR, CRR

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  1    within the terms of the contract.

  2               A fee for these services for the end of life services

  3    were not only contracted, but the cost of each contract varied

  4    based on the goods and services that the customer believed he or

  5    she was purchasing.       They commonly ranged between 900 and $1,500

  6    for cremations.       Costs of burials were substantially higher than

  7    the cremations in most cases, and you were paid by your

  8    customers through various means, including cash, check, and

  9    credit card.     Many of the customers paid Return to Nature with

 10    credit cards, using a payment processing service Square, Inc.,

 11    later known as Block, Inc., which operated within interstate

 12    commerce and was located outside of Colorado.

 13               But despite the promises in both written contracts and

 14    through verbal interactions, the Hallfords failed to provide

 15    even basic core services that are promised to its customers,

 16    either a cremation or burial of their particular loved one.

 17    Nonetheless, you continued to collect payment from such

 18    customers for the funeral services and goods despite not

 19    fulfilling their commitment to provide such service.            And at

 20    times, the Hallfords also collected payment for cremation or

 21    burial costs from an insurance company, a government entity, or

 22    third parties connected to the deceased.

 23               Beginning as early as September of 2019 and continuing

 24    through 2023, you failed to cremate or bury approximately 190

 25    bodies in connection with this scheme, and as a result,


                               Kevin P. Carlin, RMR, CRR

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  1    collected in excess of $130,000 from victims for cremation or

  2    burial services which you never provided.

  3               The Hallfords attempted to conceal the fraudulent

  4    activity by allowing 190 bodies, approximately, to remain in

  5    various states of decay and decompensation within the Penrose

  6    location in Penrose, Colorado.        And you concealed that gruesome

  7    collection of bodies by preventing outsiders from entering the

  8    building, covering the windows and doors of the building to

  9    limit viewing from outside, providing false statements to others

 10    regarding the foul odor emanating from the building and the true

 11    nature of the activity occurring inside.

 12               You routinely prepared death certificates for the

 13    deceased, then filed or caused to be filed such certificates

 14    with the Colorado state's electronic death registry.           On many of

 15    the death certificates of the 190 bodies found in the Penrose

 16    location, Ms. Hallford with your assistance falsely stated that

 17    the method of disposition was either by cremation or burial when

 18    truth of fact you knew that no disposition of certain bodies had

 19    been done at all, because they were left decomposing at the

 20    Penrose location.

 21               At times you misrepresented to and concealed from

 22    third-party business conducting cremation on behalf of Return to

 23    Nature Funeral Home the true identities of some of the bodies

 24    being submitted for cremation, and as a result, third-party

 25    businesses at times misidentified within their own records the


                              Kevin P. Carlin, RMR, CRR

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  1    identities of the bodies that they were cremating.           In a number

  2    of instances, you provided the decedent's family members,

  3    friends, or designated next of kin with cremains filled with

  4    dried concrete mix instead of the actual ashes of the deceased.

  5    On at least two occasions you arranged for and provided the

  6    wrong body to a cemetery burial resulting in incorrect remains

  7    being buried in a gravesite plot, while concealing this fact

  8    from the next of kin.

  9               A review of surveillance cameras that were located on

 10    the property revealed an incident on September 9th, 2023, where

 11    you entered some sort of contract with the family of the

 12    deceased to provide end of life services, but instead, on

 13    September 9th, 2023, you entered the building with a body on the

 14    cart.   The interior camera shows that multiple deceased bodies

 15    in the room with one on a gurney -- you dumped, Mr. Hallford,

 16    the body from the gurney onto the floor, wiped down the

 17    decomposition from the gurney from the other bodies in the room,

 18    as that specific gurney was needed.         That's in the PSR at

 19    paragraph 51.

 20               Victim Jack Denis Edward Jackson's gravesite was

 21    exhumed from the Evergreen cemetery.         He had died on July 12th,

 22    2018.   That's before the alleged beginning of the conspiracy on

 23    September of 2023.      Investigators located instant messages

 24    between the Hallfords regarding the burial of Jackson in which

 25    you wrote, I'm also 99 percent sure there is a dead baby in the


                              Kevin P. Carlin, RMR, CRR

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  1    casket with him, and it was not opened at the cemetery.             The

  2    body recovered was not that of Jack Denis Edward Jackson, and

  3    there is no infant recovered.        That's in the PSR at paragraph

  4    55.

  5                On October 5th, 2023, the FBI state law enforcement

  6    officers and the regulatory officials searched and processed the

  7    Penrose location.      Within the Return of Nature [sic] building,

  8    officials recovered multiple human remains in various states of

  9    decay.     The conditions within the Penrose location presented an

 10    extremely hazardous environment for all first responders and

 11    other members of the public who may have encountered the

 12    building.     Workers entering the building were required to wear

 13    specialized hazmat gear, and they were only allowed to remain

 14    within the facility for brief intervals due to the toxic

 15    environment.

 16                Law enforcement officers and any member of the public

 17    who encountered the location were at risk for contracting

 18    illness and thus suffering serious bodily injury.           After exiting

 19    the building, workers were required to follow a rigorous

 20    decontamination protocol to ensure the safety of their health.

 21                Later, the Environmental Protection Agency condemned

 22    the entire building at the Penrose location after determining it

 23    to be a toxic waste site unfit for further human usage and a

 24    serious health threat to others who might encounter it in the

 25    future.     Ultimately, on April 20th, 2024, the EPA razed the


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  1    building to the ground.       The EPA then disinfected the building

  2    materials and foundation and later transferred the debris to an

  3    offsite hazardous waste dump.

  4               On October 26th, 2023, after the discovery, victim

  5    Melvin M. Utton, Junior's, gravesite was exhumed from the Pikes

  6    Peak National Cemetery after his remains were recovered from the

  7    Penrose location.      Inside the casket was the body of a heavily

  8    decomposed female wrapped in duct tape and plastic sheets.               A

  9    review of the records identified the female's date of death as

 10    March 20th, 2020, and her cremation took place at Roselawn's

 11    crematorium.     However, Roselawn had no record of her cremation.

 12    That's in the PSR at paragraph 54.

 13               During the same time period, Mr. Hallford, you engaged

 14    in a separate scheme to defraud the Small Business

 15    Administration that provided emergency assistance to small

 16    business owners suffering adverse economic effects caused by the

 17    COVID-19 pandemic.      All told, you received over $880,000 from

 18    the SBA by at least falsely stating that you were not engaged in

 19    any illegal activity, when in truth in fact, you and

 20    Ms. Hallford were jointly engaged in a separate ongoing wire

 21    fraud and scheme to defraud the customers of their business,

 22    Return to Nature.

 23               To receive those funds, you also falsely certified on

 24    security agreements for each of these loans that all the loan

 25    funds would be primarily used for personal, family, or household


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  1    purposes.     But once you received the 883 -- I'm sorry --

  2    $882,300 from the SBA, and those occurred in April of 2020, May

  3    of 2021, and November of 2021, you used it for your own personal

  4    use and personal benefit by spending the funds on things such as

  5    a vehicle, multiple vacations, entertainment, dining, tuition

  6    for a minor child, cryptocurrency, cosmetic medical procedures,

  7    jewelry, various goods, and merchandise from Amazon, and the

  8    payments to other vendors unrelated to the business.

  9                And what does this all mean in plain English?           Because

 10    I have been reading from the legal documents filed in this case.

 11    It means, Mr. Hallford, for at least four years, and five if I

 12    extend it to the time period of the incorrect burial, you and

 13    your wife met with people, told them you were very sorry for

 14    their loss, assured them you would take care of their loved ones

 15    and provide them a respectful and dignified end of life

 16    experience, either through natural burial or cremation that was

 17    better for the worth [sic], and you did nothing of the sort.

 18                You not only defrauded them of their money,

 19    Mr. Hallford, but you did so knowingly, that you did not provide

 20    them with services that they were securing for their loved ones

 21    who had passed away, but also for their surviving family member

 22    and friends.     You defrauded them into believing them -- that you

 23    were helping them fulfill the promises that they had made to

 24    their loved ones at their ends of life.         You lied to them about

 25    what you did with their loved ones' bodies, and then you


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  1    returned to them concrete mix that was not anyone's ashes, and

  2    in some cases you buried individuals in graves that were not the

  3    graves of their own.

  4               You lied to the Government that instead of loans to

  5    help small businesses ride out the devastation of the COVID-19

  6    pandemic, you took the money, and you did not fix Penrose, but

  7    you spent it on personal things.        And then you lied again when

  8    you were discovered in October of 2023.         You told the Colorado

  9    Department of Regulatory Agencies that you were using the

 10    building in Penrose to learn how to do taxidermy, and that you

 11    knew that you had a problem there.        That's docket entry 77, at

 12    paragraph 48.

 13               I turn to the history and characteristics of the

 14    defendant now to talk briefly -- well, actually, none of this is

 15    brief, and so I apologize for that.         Mr. Hallford, the Court

 16    notes that you have no criminal history, and unlike so many of

 17    the individuals that come before the Court in this context,

 18    either wire fraud or other felony offenses in the federal

 19    system, you were raised in a small town in Oklahoma with two

 20    parents and a stable upbringing.        You experienced no abuse.        You

 21    had a comfortable lifestyle, and you had stable employment from

 22    it appears 2004 until 2023.

 23               Your history, as noted by your counsel in your

 24    sentencing statement, indicates that you wanted to be a minister

 25    at some point in your life, but you became disillusioned because


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  1    the person that you admired most in the ministry was found to be

  2    engaging in extramarital affairs and deceiving the parishioners.

  3    And so it is sad and difficult, Mr. Hallford, that you have

  4    chosen a similar path of deceiving people who relied upon you

  5    and who relied upon you in potentially one of the most

  6    vulnerable time periods in their life.

  7               Your character, Mr. Hallford, during this time is

  8    reflected by some of the contemporaneously -- communications

  9    that you and your wife, and who is also your codefendant, were

 10    having during this time period.        Some of those text messages are

 11    reflected in paragraph 65 of the PSR, but the Court took the

 12    time to read and review all 4,000 pages of text messages that

 13    were provided in discovery, and pulled out some of the most

 14    egregious ones that we will cover later today.

 15               I'm sorry I'm panicked.      If anyone smells Penrose and

 16    enters the building or smells decomp, word will spread like

 17    fire.   I'm completely freaking out.        That's in May of 2019.       And

 18    yet, the scheme continued.

 19               The fat one by herself will decompose the fastest,

 20    because I didn't open the door to contain the 72 degrees that's

 21    in there, as opposed to the 85, almost 90 that's in the building

 22    where she is sitting.      That's sent in July of 2019.

 23               So, that's difficult for the Court to understand that

 24    the air conditioning actually went out in July of 2023, as you

 25    posit, when in July of 2019, you were already trying to


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  1    decompose bodies by leaving the door open to the heat.

  2               I don't give be a fuck about this family.         All I give a

  3    fuck about what's happening in Penrose are not going to prison

  4    and getting the fuck out of this community.           My only -- my one

  5    and only focus is keeping us out of jail.           What's yours?    That's

  6    in May of 2020.

  7               In May of 2020, Mr. Hallford, you received hundreds of

  8    thousands of dollars from the COVID relief funds through

  9    IEDL [sic].    You talked in the text messages with your wife at

 10    that time to try to fix Penrose, and yet you didn't do anything.

 11    You didn't use that money to fix Penrose.           You didn't stop the

 12    scheme at that time, and I note that some of the victims here

 13    speaking today, their loved ones were given to you after May of

 14    2020 to help them with their end-of-life decisions.

 15               It wouldn't hurt to get a couple folding tables for

 16    Penrose so we don't have to put anyone else on the floor.             That

 17    was sent in April of 2023.       And if your plan for me is to Jill

 18    myself and then pin Penrose on me, they will still get your

 19    phone data.    If we get divorced, Penrose will come out, and they

 20    will check our phones.      And once it does, there won't be any

 21    hiding your involvement.       We either have to fix all of this, or

 22    we have to begin living a horrible existence together until this

 23    is all over.     That's July of 2023.

 24               If Penrose were to get exposed, we lose -- we both lose

 25    everything anyway.      We can't allow that to happen.       We can't


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  1    allow our family to be destroyed.        I don't know what's happening

  2    with the kids, but I know I'm willing to do whatever it takes to

  3    fix it.     That's sent August of 2023, just a few months before

  4    you were discovered.

  5                You objected to these text messages reflected in

  6    paragraph 65 as not reflecting moments of regret and reflection

  7    as noted in other omitted text messages.            And so to address this

  8    concern, the Court took it upon itself to read over 4,000 pages

  9    of text messages to get a clearer picture of your

 10    characteristics.      What the Court found, however, is when you

 11    express regret and reflection, it is not about the families that

 12    you were deceiving or committing wire fraud against the Small

 13    Business Administration, taking money and spending it on other

 14    things, not on business expenses.

 15                Instead, what I see is an individual who is taking

 16    money from individual families and from the government and using

 17    it as you see fit in order to try to float your family, and no

 18    money, no incidents, nothing, that suggests that you are at all

 19    remorseful about what is happening to the families or those

 20    bodies.

 21                And one thing I was particularly struck by when I

 22    looked through these text messages, Mr. Hallford, is the utter

 23    lack of identification of the individuals.            I could only find a

 24    handful of text messages that you exchanged with your

 25    codefendant where you even refer to the individual by their


                              Kevin P. Carlin, RMR, CRR

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  1    name.   Otherwise, you're talking about bodies, objects, things

  2    that you were picking up from one location and transmitting to

  3    another location.

  4               You were talking about who is going to cover what, but

  5    you're never talking about remorse that you have been

  6    perpetuating this wire fraud against these families who have

  7    trusted you with their end-of-life determinations.           And we will

  8    go over some of these shortly.

  9               You're sending lists of things to do on your off time.

 10    You're talking about cleaning up Penrose.           You're talking about

 11    as early as November 2nd, 2024, I don't trust that you wouldn't

 12    turn witness on me.      This is to your wife and codefendant.             You

 13    seriously want to talk about divorce in Tulsa that day?              It

 14    stuck with me and has never been far from my mind.           I don't know

 15    what to do about Penrose, and I will be the one going down for

 16    it.

 17               Your concern is that you are going to have to take

 18    accountability and responsibility one day for it.           Your concern

 19    is not in these messages that I've read that the people that

 20    have trusted you not with their money -- of course they have

 21    trusted you with their money -- but trusted you with the

 22    end-of-life determinations, the promises and wishes.           The ones

 23    that you are deceiving out of that security, none of these

 24    messages refer to that.

 25               In May of 2019, you texted, I'm sorry I'm panicked.


                              Kevin P. Carlin, RMR, CRR

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  1    I'm freaking out.        In May of 2020, we just now have a grip on

  2    Penrose, and we're days away from getting this rolling.               I do

  3    not have fucking time for this.          The same day you wrote, I

  4    literally just told you, it was not my problem.             I'm not doing

  5    anything with it.        I have other things to do, so either figure

  6    it out or cancel it.        The fact that you would even ask this

  7    morning shows that you have no concern for what little time I

  8    have getting this fucking done or the amount of time I've

  9    already put into it.        What I'm doing right now is saving us from

 10    going to fucking prison.         Right this very second, we have a very

 11    small window of grip on Penrose.

 12               And yet that very small window closed, Mr. Hallford,

 13    without you doing a single thing to rectify the situation.                  In

 14    fact, despite your lawyer's arguments in your sentencing

 15    statement that you were really trying to serve everyone else you

 16    could, and your own statements that it just got overwhelmed and

 17    out of control, on May 12th, 2020, even knowing that you had

 18    bodies stacking up already in Penrose, you asked your wife,

 19    where are you?        Will you check Penrose, please?       And why aren't

 20    we getting any new calls?

 21               And she responds, we have a couple pendings on the

 22    hook.

 23               You were actively soliciting other people for your

 24    business knowing full well you were going to take their money,

 25    and you were not going to give them the services that they


                                Kevin P. Carlin, RMR, CRR

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  1    asked.

  2                On May 15th, 2019, you indicate, I would just prefer to

  3    involve the boys, which I assume refers to your sons, as little

  4    as possible until Penrose is not disgusting inside or out.                On

  5    June 4th, 2020, after the first two -- June 4th, 2020, after the

  6    first of the SBA loans were funded, you indicated you were

  7    frustrated.     I'm sorry.    I assure you it's not for any other

  8    reason than trial or error.       It's R&D.    It's learning as you go.

  9    I'm trying.     I'm beyond freaking.     We're getting everything we

 10    want right now, and that fucking Penrose could screw everything.

 11    No one wants those bodies gone more than I do.          I'm sorry.

 12                Well, Mr. Hallford, I'm here to assure you that there

 13    are people who wanted those bodies taken care of in a way more

 14    than you did, and you failed them in that hour.           You deceived

 15    them, and you took their money, and you made them promises with

 16    full knowledge that you were never going to fulfill those

 17    promises.

 18                In September of 2020 -- and this is just an example of

 19    the fact that these individuals were not individuals to you.

 20    They were not people, and they were not names.          You said to

 21    Ms. Hallford, I'm thinking that if I can put a body in and then

 22    we make that removal at Penrose in the morning at 5:00 a.m. or

 23    so, then we would have time to come down here and put that body

 24    away, take the body out of the tank, clean up, and be out of

 25    here and headed back towards the Springs by when it's time for


                              Kevin P. Carlin, RMR, CRR

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  1    him to take over being on call.        What do you think?

  2               That is just an example of the lack of individual

  3    identification that you showed these individuals and the

  4    families who again you deceived, made representations to, took

  5    their money through wire, and defrauded them.

  6               The Government highlighted your statement, but the

  7    Court will also pass on it from October of 2020, by

  8    December 6th, we need to begin cleaning and restoring the

  9    building in Penrose, and be out by December 31st.           Options,

 10    build a new machine, ASAP.       B, dig a big hole and use lye.

 11    Where?    C, dig a small hole and build a large fire.         Where?      D,

 12    I go to prison, which is probably what is going to happen.

 13               Finally, the Court highlights, because it does really

 14    highlight the two types of wire fraud that is before the Court

 15    today, on April 7th, 2021, after you had been given the first of

 16    three EIDL loans from the Small Business Administration, and

 17    before you got the second, you texted your wife, do you

 18    understand if we get the $350,000, it will completely get us out

 19    of debt and handle Penrose?

 20               And she responded, I know, exclamation mark,

 21    exclamation mark, exclamation mark.         Penrose, exclamation mark.

 22    And you got that $350,000, and you did nothing with it to

 23    rectify the Penrose situation.        And you continued the deceit and

 24    the lies for two additional years.

 25               Mr. Hallford, you and your counsel have both spent time


                              Kevin P. Carlin, RMR, CRR

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  1    conceding the seriousness of the offense, and your attorney

  2    argues that 120 months is just punishment for the offense.                She

  3    also argues that the Court should not focus on the emotional

  4    distress caused by the treatment of the bodies or their various

  5    loved ones because you've pled guilty and will be separately

  6    sentenced in state court for the non-fraud harm that this -- his

  7    actions in a separate concurrent prosecution for abuse of

  8    corpses.

  9               For the reasons I have discussed earlier, this Court

 10    finds that the fraud that you perpetuated is inextricably

 11    intertwined with the resulting harm that has befallen the

 12    victims in this case.      The seriousness of this offense for wire

 13    fraud cannot be appropriately quantified simply through the

 14    statements of the individuals who are here today, because some

 15    people could not be here.       In each of these cases, you made

 16    promises to those individuals that you would take care of the

 17    end-of-life needs for their loved ones or promised the third

 18    party that you would do so.

 19               With respect to the SBA loans, you took that money from

 20    the Government and promised the Government that you would use it

 21    to -- for business purposes, and not for personal purposes, and

 22    yet you didn't do that.       You didn't do that, and you even --

 23    when you recognized that if you got that additional money, you

 24    could get yourself out of debt and that you could take care

 25    Penrose, you could take care of both of your objectives,


                              Kevin P. Carlin, RMR, CRR

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  1    essentially, that you've talked about here today, to take care

  2    of your family and to take care of Penrose, and then that money

  3    taken over and over and over again from the SBA -- because there

  4    was a third payment in November of 2021 -- was actually not used

  5    to rectify the situation or to stop the scheme or to do anything

  6    to resolve the issues at Penrose.        Instead, as the Government

  7    indicated, you just persisted on.

  8               The sheer impact is reflected by the names that are

  9    reflected in docket entry number 114-1, listing all of the

 10    individuals who have claimed restitution and listing the names

 11    of their loved ones who have been deceased today.           I will not

 12    take the time, although I think it would be appropriate to

 13    reflect the sheer seriousness of this offense, to read each

 14    individual name, because it will take enough time.           But I do

 15    note for the record that these names of the loved ones who have

 16    passed away are reflected at docket entry 114-1, which is the

 17    first -- I'm sorry -- the third addendum that was filed on

 18    June 25th, 2025.      And the sheer number of names and the fact

 19    that the Court cannot read them all because of timing reflects

 20    the seriousness of this offense.

 21               The Court has also determined in terms of this sentence

 22    that I'm about to pronounce and considered the need to avoid

 23    unwarranted sentencing disparities among defendants with similar

 24    records who have been found guilty of similar conduct and the

 25    need to provide restitution to any victims of the offense.


                              Kevin P. Carlin, RMR, CRR

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  1               I will begin briefly by the restitution, which

  2    obviously is going to be a required component of this judgment

  3    that I enter.     But as the victims who do not just include the

  4    individual family members who made those end-of-life decisions

  5    or the family and friends who were impacted by those end-of-life

  6    decisions, but also the first responders, the law enforcement

  7    officers, the individuals who had to clean up, raze, and know of

  8    this, you've impacted not only these individuals, but the

  9    community as a whole and the funeral home industry as a whole.

 10               Your fraud has resulted in many of these victims

 11    stating in their impact statements that they are unable to trust

 12    anyone else in their community or anyone else in the funeral

 13    home industry with those end-of-life determinations.           And your

 14    fraud, not necessarily the abuse of corpse that you will be

 15    sentenced separately, has kicked off a chain reaction within the

 16    community that this sentence appropriately considers in terms of

 17    determining the appropriate sentence.

 18               Now, there was much argument made about needing to

 19    avoid unwarranted sentencing disparities among defendants with

 20    similar conducts who have been found guilty -- I'm sorry -- with

 21    similar records who have been found guilty of similar conduct,

 22    but as stated by many of the victims here today and the

 23    Government, this Court concludes by looking at the record as a

 24    whole, looking through the lens of the elements of wire fraud,

 25    looking and focusing on those elements of deceit and fraud, that


                              Kevin P. Carlin, RMR, CRR

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  1    this is no ordinary wire fraud case, and nor could it ever be.

  2               And the supposition that somehow the Hess case and the

  3    conduct of those individuals was the maximum and everything else

  4    should work downwards from there, this Court respectfully

  5    disagrees.    There is a threshold that the law gives me, which is

  6    a maximum sentence for wire fraud, but that doesn't mean that

  7    the worst conduct is the maximum, and then I move down from

  8    there.    There has to be some calculation that some threshold

  9    conduct meets the maximum sentence, because that maximum

 10    sentence not only takes into account the calculation of

 11    accountability for wire fraud, but also in its best form, the

 12    Sentencing Reform Act and the sentencing guidelines tends and

 13    tries to take into account also the humanity of the defendant

 14    who stands before me.

 15               And, Mr. Hallford, I have also attempted to account for

 16    your humanity in this sentence.        Your -- these statements of

 17    your own, I focused on those statements, because those

 18    statements are the statements that drove this Court's

 19    determination with respect to the sentence.

 20               It is for all of these reasons that the Court will vary

 21    from the advisory guideline range for the following -- for those

 22    reasons, and pursuant to the Sentencing Reform Act of 1984, it

 23    is the judgment of this Court that the defendant Jon M. Hallford

 24    is hereby committed to the custody of the Bureau of Prisons to

 25    be imprisoned for a term of 240 months.         The term of


                              Kevin P. Carlin, RMR, CRR

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  1    imprisonment imposed by the judgment will run concurrently with

  2    your sentence anticipated in El Paso County Court case number

  3    2023-CR-4849.

  4               Upon release from imprisonment, you shall be placed on

  5    supervised release for a term of three years.          Within 72 hours

  6    of release from custody of the Bureau of Prisons, you shall

  7    report in person to the probation office in the district to

  8    which the defendant is released.        While you are on supervision,

  9    you must not commit another federal, state, or local crime, and

 10    you must not unlawfully possess a controlled substance.             You

 11    must refrain from any unlawful use of a controlled substance.

 12    You must submit to one drug test within 15 days of release from

 13    imprisonment, and a maximum of 20 tests per year of supervision

 14    thereafter.

 15               You must make restitution in accordance with 18 USC

 16    Sections 3663(a) and 3663 -- I'm sorry.         3663 and 3663(a), or

 17    any other statute authorizing a sentence of restitution.             You

 18    must cooperate in the collection of DNA as directed by the

 19    probation officer.      You must comply with the standard conditions

 20    adopted by the Court in general order 2020-20.

 21               The Court finds that the following special conditions

 22    of supervised release are determined to be reasonably related to

 23    the factors enumerated by 18 USC Section 3553(a) and 18 USC

 24    Section 3583(d).      Further, based on the nature and circumstances

 25    of the offense and the history and characteristics of this


                              Kevin P. Carlin, RMR, CRR

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  1    particular defendant, the following conditions do not constitute

  2    a greater deprivation of liberty than is reasonably necessary to

  3    accomplish the goals of sentencing.

  4                One, if the judgment imposed a financial penalty or

  5    restitution, you must pay the financial penalty or restitution

  6    in accordance with the scheduled payment sheets of this

  7    judgment.     You must also notify the Court of any changes in

  8    economic circumstances that might affect your ability to pay the

  9    financial penalty or restitution.

 10                Two, you must incur [sic] new credit charges or open

 11    additional lines of credit without approval of the probation

 12    officer, unless you are in compliance with the periodic payment

 13    obligations imposed pursuant to the Court's judgment and

 14    sentence.

 15                Three, you must provide the probation officer access to

 16    any requested financial information and authorize the release of

 17    any financial information until all financial obligations

 18    imposed by the Court are paid in full.

 19                Four, you must apply any monies received from income

 20    tax refunds, lottery winnings, inheritances, judgments, and any

 21    anticipated or unexpected financial gains to the outstanding

 22    court ordered financial obligation in this case.

 23                Five, if you have any outstanding financial

 24    obligations, the probation office may share any financial or

 25    employment documentation relevant to you with the asset recovery


                              Kevin P. Carlin, RMR, CRR

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  1    division of the United States Attorney's Office to assist in the

  2    collection of that obligation.

  3               Six, you must participate in a program of cognitive

  4    behavioral treatment approved by the probation officer, and

  5    follow the rules and regulations of such program.           The probation

  6    officer in consultation with the treatment provider will

  7    supervise your participation in the program as to modality,

  8    duration, and intensity.       You must pay for the cost of treatment

  9    based on your ability to pay.

 10               Seven, you must engage in an -- you must not engage in

 11    an occupation, business, profession, or volunteer activity that

 12    would require or enable you to be involved in the funeral,

 13    cremation, or burial business without prior permission of the --

 14    your probation officer.

 15               Eight, any business you operate during the term of

 16    supervision must be approved by the probation officer.              You must

 17    operate under a formal registered entity, and you must provide

 18    the probation officer with the name of the business entity and

 19    its registered agents.      You must maintain business records and

 20    provide all business documentation and records as requested by

 21    the probation officer.

 22               The determination of restitution -- you must make

 23    restitution to the victims in the amounts indicated in the

 24    presentence and -- presentence investigation report and related

 25    attachments.     The total restitution amount is reflected in the


                              Kevin P. Carlin, RMR, CRR

Case No. 1:24-cr-00113-NYW   Document 139 filed 08/13/25   USDC Colorado   pg
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  1    third addendum to the presentence investigation report of

  2    $193,966.18 to the victims, and $876,447.56 to the Small

  3    Business Administration, for a total of $1 million --

  4    $1,070,413.74.

  5               It is ordered that restitution be jointly and severally

  6    with the following codefendant: Carie L. Hallford, case number

  7    24-cr-113-2, to be determined.        Once restitution is determined,

  8    each victim shall receive an approximately proportional payment

  9    based on the victim's share of the total loss.

 10               You are ordered to pay a special assessment fee of $100

 11    due and payable immediately.       The Court finds that the defendant

 12    does not have the ability to pay a fine, so the Court will waive

 13    the fine in this case.      The Court has determined that the

 14    Court -- the defendant does not have the ability to pay interest

 15    on the final restitution amount, and it is ordered that the

 16    interest requirement is waived for restitution.

 17               It's ordered that the payment of the monetary

 18    obligation shall be due as follows:         The special assessment and

 19    restitution obligations are due immediately.          Any unpaid

 20    restitution balance upon release from incarceration shall be

 21    paid in monthly installment payments during the term of

 22    supervised release.      The monthly installment payments will be

 23    calculated as at least ten percent of the defendant's gross

 24    monthly income.

 25               Pursuant to Rule 32.2 of the Federal Rules of Criminal


                              Kevin P. Carlin, RMR, CRR

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  1    Procedure, the defendant must forfeit his interest in the

  2    following property to the United States: a money judgment in the

  3    amount of proceeds obtained by the defendant in the scheme.

  4                The defendant is advised of his right to appeal the

  5    sentence.     If you so desire to appeal, a notice of appeal must

  6    be filed with the clerk of the court within 14 days after the

  7    entry of judgment, or the right to be -- right to appeal will be

  8    lost.   If the defendant is unable to afford an attorney on

  9    appeal, the Court will appoint one to represent you.           And if you

 10    so request, the clerk of the court must immediately prepare and

 11    file a notice of appeal on behalf of the defendant.

 12                Mr. Hallford, today you have talked about your actions

 13    depriving your parents and your family, including your children,

 14    of moments in their lives, and the Court has accounted for that

 15    in determining the sentence.       And I -- I empathize with the fact

 16    that those individuals who are important in your life will not

 17    have you be part of their life for quite some time.

 18                I very much hope that you are sincere and you follow

 19    through in the fact that you would like to live your life in a

 20    different way than you did in those four years, and you actually

 21    contribute to the community.       And hopefully, if that can occur,

 22    that there will be some healing not only with respect to the

 23    individuals impacted by the wire fraud that was conducted

 24    through -- from at least September of 2019 through October of

 25    2023, but that those individuals, including your parents and


                              Kevin P. Carlin, RMR, CRR

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  1    your children, can look at you and know that you have taken full

  2    accountability for the actions that have occurred.

  3               I wish you luck, Mr. Hallford.       It's ordered that the

  4    defendant is remanded to the custody of the United States

  5    Marshal.

  6               Anything further on behalf of the Government?

  7                MR. NEFF:     No, Your Honor.    Thank you.

  8                THE COURT:     Anything further -- oh.     I will make the

  9    recommendation of designation to the facilities as requested by

 10    the defendant, El Reno or Texarkana.

 11                MS. SUELAU:     Thank you, Your Honor.     We would also ask

 12    as requested in our sentencing statement that Your Honor not

 13    order the payment of restitution during the period of

 14    imprisonment.

 15                THE COURT:     I've already waived the interest, but I'm

 16    going to have the order of restitution be due and payable

 17    immediately, as previously ordered.

 18                MS. SUELAU:     Understood.     Also, for purposes of the

 19    record, given recent Tenth Circuit precedent on waiver, I object

 20    to Your Honor's sentence as substantively unreasonable,

 21    specifically, but among other things, Your Honor to rely on

 22    Mr. Hallford's conduct during the course of this offense

 23    particularly.

 24               Reliance on text messages between 2019 and 2020, when

 25    Pepper versus United States, that's 562 U.S. 476, 2011, directs


                               Kevin P. Carlin, RMR, CRR

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  1    Your Honor to consider all conduct by Mr. Hallford, including

  2    before the instant offense and the conduct that's happened -- or

  3    rehabilitation that's happened since the instant offense, the

  4    statements of remorse, his expressions of acceptance of

  5    responsibility today, and through his persistence in maintaining

  6    the plea agreement.      So, for those and -- for those reasons

  7    outlined in our sentencing statement, we object to Your Honor's

  8    sentence as substantively unreasonable.

  9                THE COURT:    Thank you.    Anything else?     All right.

 10    Thank you very much.      We will be in recess.

 11          (Proceedings concluded at 12:45 p.m.)

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                              Kevin P. Carlin, RMR, CRR

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  1                             REPORTER'S CERTIFICATE

  2

  3

  4               I, KEVIN P. CARLIN, Official Court Reporter for the

  5    United States District Court for the District of Colorado, a

  6    Registered Merit Reporter and Certified Realtime Reporter, do

  7    hereby certify that I reported by machine shorthand the

  8    proceedings contained herein at the time and place

  9    aforementioned and that the foregoing pages constitute a full,

 10    true, and correct transcript.

 11               Dated this 7th day of August, 2025.

 12

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                                              Kevin P. Carlin, RMR, CRR
 17                                           Official Court Reporter

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                              Kevin P. Carlin, RMR, CRR

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