Joint Motion to Continue Motions Deadline — United States v. Hallford (Dkt. 38, D. Colo.)

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A joint motion to continue the motions deadline in United States of America v. Jon M. Hallford and Carie L. Hallford, Case No. 24-cr-00113-NYW, in the U.S. District Court for the District of Colorado, filed August 15, 2024 as Document 38. Both defendants, through attorneys Laura H. Suelau and Chaz Melihercik, and the government, through Assistant United States Attorneys Tim Neff and Craig Fansler, ask the Court to move the pretrial motions deadline from August 30 to September 13, 2024. They state that trial is set for October 15, 2024 and that they are negotiating a plea agreement and believe there is a high likelihood the matter will be resolved that way. Defense counsel are reviewing voluminous discovery and the government must confer with the alleged victims.

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Case No. 1:24-cr-00113-NYW Document 38 filed 08/15/24 USDC Colorado pg 1 of 3




                             IN THE UNITED STATES DISTRICT COURT
                                FOR THE DISTRICT OF COLORADO

CASE NO. 24-cr-00113-NYW

UNITED STATES OF AMERICA,

                Plaintiff,

v.

1.      JON M. HALLFORD,
2.      CARIE L. HALLFORD,

                Defendants.


                 JOINT MOTION TO CONTINUE MOTIONS DEADLINE


        Jon M. Hallford and Carie L. Hallford, through their respective attorneys, Laura H. Suelau and

Chaz Melihercik, and the government, through Assistant United States Attorneys Tim Neff and Craig

Fansler, respectfully move this Court to continue and reset the deadline for Pretrial Motions from

August 30 to September 13, 2024. In support of this Motion, the parties state:

        1.      Trial in this matter is presently set to proceed October 15, 2024, and pretrial motions

are due August 30, 2024.

        2.      The parties are in the process of negotiating a plea agreement and believe there is a

high likelihood this matter will be resolved by such an agreement.

        3.      The parties each have individual tasks that must be completed before reaching a final

agreement. Counsel for the Hallfords, for example, are continuing to diligently review voluminous

discovery, confer with and advise their clients, and communicate with the Hallfords’ respective

attorneys in El Paso County. Likewise, counsel for the government must confer with the alleged

victims in this case.

        4.      Should this matter not result in a disposition, the parties will require additional time to

prepare for trial. In either case, the parties do not anticipate proceeding to trial on October 15, 2024.

Case No. 1:24-cr-00113-NYW Document 38 filed 08/15/24 USDC Colorado pg 2 of 3




       5.      Counsel for the Hallfords and the government do not reasonably believe that they will

be able to either reach a disposition or determine how much additional time is necessary to prepare

for trial, on or before August 30, 2024.

       6.      In addition to the tasks outstanding, counsel for Mr. Hallford is on leave August 30,

2024. That leave was planned before her appointment in this case.

       7.      Counsel for the parties reasonably believe they can file a Notice of Disposition or, less

likely, a Motion for an Ends of Justice continuance, on or before September 13, 2024.

       8.      For the foregoing reasons, the parties respectfully request this Court continue the

deadline for filing pretrial motions by two weeks, to September 13, 2024.


Respectfully submitted,

VIRGINIA L. GRADY                                              MELIHERCIK LAW, LLC
Federal Public Defender

s/ Laura H. Suelau                                             s/ Robert C. Melihercik
LAURA H. SUELAU                                                ROBERT CHARLES MELIHERCIK
Assistant Federal Public Defender                              7765 Wadsworth Blvd., Suite 746327
633 17th Street, Suite 1000                                    Arvada, CO 80006
Denver, CO 80202                                               Telephone: (720) 707-2854
Telephone: (303) 294-7002                                      chaz@meliherciklaw.com
FAX: (303) 294-1192                                            Attorney for Defendant Carie Hallford
laura_suelau@fd.org
Attorney for Defendant Jon Hallford



COLE FINEGAN                                                   COLE FINEGAN
UNITED STATES ATTORNEY                                         UNITED STATES ATTORNEY

By: s/ Tim Neff                                                By: s/ Craig Fansler
TIM R. NEFF                                                    CRAIG G. FANSLER
Assistant U.S. Attorney                                        Assistant U.S. Attorney
United States Attorney’s Office                                United States Attorney’s Office
1801 California Street, Suite 1600                             1801 California Street, Suite 1600
Denver, CO 80202                                               Denver, CO 80202
Telephone: (303) 454-0200                                      Telephone: (303) 454-0100
tim.neff@usdoj.gov                                             craig.fansler2@usdoj.gov
Attorney for Government                                        Attorney for Government

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Case No. 1:24-cr-00113-NYW Document 38 filed 08/15/24 USDC Colorado pg 3 of 3




                                  CERTIFICATE OF SERVICE

      I hereby certify that on August 15, 2024, I filed the foregoing Joint Motion to Continue
Motions Deadline with the Clerk of Court using the CM/ECF system, which will send notification
of such filing to the following email addresses:

        Craig Fansler, Assistant United States Attorney
        Email: craig.fansler2@usdoj.gov

        Tim Neff, Assistant United States Attorney
        Email: tim.neff@usdoj.gov

        Robert C. Melihercik
        Email: chaz@meliherciklaw.com
        Attorney for Carie Hallford

        I hereby certify that I have mailed or served the document or paper to the following participant
in the manner (mail, hand-delivery, etc.) indicated next to the participant’s name:

        Jon M. Hallford (via U.S. Mail)

                                                   s/ Laura H. Suelau
                                                   LAURA H. SUELAU
                                                   Assistant Federal Public Defender
                                                   633 17th Street, Suite 1000
                                                   Denver, CO 80202
                                                   Telephone: (303) 294-7002
                                                   FAX: (303) 294-1192
                                                   laura_suelau@fd.org
                                                   Attorney for Defendant Jon Hallford




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