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Government’s Sentencing Statement for Defendant Carie L. Hallford — United States v. Hallford (Dkt. 145, D. Colo.)

Summary

The Government's Sentencing Statement for Defendant Carie L. Hallford in United States of America v. Carie L. Hallford, Criminal Case No. 24-cr-00113-NYW-02, in the U.S. District Court for the District of Colorado, filed February 23, 2026. The United States asks the Court to impose a 180 month (15 year) term of imprisonment, the maximum it may request under the plea agreement, and states that the Presentence Report also recommends that term. It states that the defendant affirmed on August 4, 2025 her plea of guilty to Count 11 under Rule 11(c)(1)(B), and that the advisory guideline range is 78 to 97 months, so an upward variance would be needed. The statement alleges misuse of loan proceeds, including for a $92,000 vehicle, and describes the distress it says the conduct caused to grieving families.

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 February 23, 2026 in Carie L. Hallford; one of 24 filings from this case.

Record facts

CourtU.S. District Court for the District of Colorado
Filed2026-02-23

Cite this document

“Government’s Sentencing Statement for Defendant Carie L. Hallford — United States v. Hallford (Dkt. 145, D. Colo.).” U.S. District Court for the District of Colorado, No. 1:24-cr-00113, Doc. 145, filed 2026-02-23. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-carie-l-hallford-cod-233033/2026-02-23-gov-uscourts-cod-233033-145-0-doc-145/, SHA-256 7cca9ccbe4f2090b050db821886e207ce3d9d269795a83f6f927a8f3b75dd21b.

Full text

Case No. 1:24-cr-00113-NYW       Document 145      filed 02/23/26   USDC Colorado       pg 1
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                      IN THE UNITED STATES DISTRICT COURT
                          FOR THE DISTRICT OF COLORADO


 Criminal Case No. 24-cr-00113-NYW-02

 UNITED STATES OF AMERICA,

       Plaintiff,

 v.

 2. CARIE L. HALLFORD,

       Defendant.


                    GOVERNMENT'S SENTENCING STATEMENT FOR
                         DEFENDANT CARIE L. HALLFORD


       The United States of America respectfully files this Sentencing Statement for

 defendant Carie L. Hallford.

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

 (15 year) term of imprisonment. This is the maximum amount of prison time which the

 Government may request under the terms of the parties’ plea agreement 1. Carie

 Hallford Plea Agreement, at 3 [#136]. The Government’s recommendation is consistent



 1  On February 24, 2025, the Court issued a Minute Order [#79] finding that the terms
 of the parties’ original Plea Agreement “is not in the public interest.” Order at 1.
 Pursuant to the Order, the Court provided the Defendant the option to withdraw her plea
 of guilty or proceed forward with her plea of guilty pursuant to Rule 11(c)(1)(B), meaning
 the Court would no longer be bound by any sentencing recommendation of the parties.
 On August 4, 2025, the Defendant affirmed her desire to persist in her plea of guilty to
 Count 11 of the Indictment pursuant to Rule 11(c)(1)(B). [#136]. Because the
 Government agreed as part of the original plea deal not to seek a sentence higher than
 15 years, the Government remains committed to recommending a 15 year sentence
 imprisonment sentence.
                                             1

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 with the recommendation contained within the Presentence Report (“PSR”), Exhibit A,

 R-1 [#71-1], which also recommends a 180 month (15 year) sentence to imprisonment.

        Here, the PSR states that the advisory guideline range is 78 to 97 months

 imprisonment (offense level 28 and criminal history category I). Id. However, the matter

 before the Court is not an ordinary case and there are various aggravating factors

 warranting a significantly higher sentence than recommended by the guidelines. By

 separate pleading, the Government sets forth the basis upon which it seeks a sentence

 above the applicable guidelines. In order to impose a 180 month sentence, the Court

 would need to find that an upward variance from the guidelines is appropriate.

                                Restitution and Loss Amount

        As a threshold issue, the Government requests that the Court find that the total

 loss amount and restitution amount imposed in Carie Hallford’s case be identical to the

 amounts imposed by the Court at the sentencing for co-defendant Jon Hallford on June

 27, 2025. It is the Government’s understanding that the Defendant does not contest

 the below loss and restitution figures.

        Specifically, the total loss amount and restitution amount should be

 $1,070,413.74 which is comprised of the following:

        •   $193,966.18 owed to the victims 2 in the funeral home case

        •   $876,447.56 owed to the U.S. Small Business Administration


 2  As it relates to the victims in the funeral home case, the Government has provided
 the Probation Department and defense counsel a detailed list of the impacted
 decedents, the amounts of funds which are owed per decedent, and the names of the
 payees. The itemized list of funeral home victims/payees in this case is identical to the
 restitution victims/payees listed in the Judgment for Jon Hallford. [#121-1, Judgment
 Attachment A].
                                             2

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        Further, pursuant to 18 U.S.C. § 3664(i), because all nonfederal victims must be

 paid before the United States is paid, the Government requests (like in Jon Hallford’s

 case) that the victims in the funeral home be made “first priority” in connection with any

 restitution payments. The Government also requests that any restitution for Carie

 Hallford be ordered to be paid jointly and severally with the restitution owed by co-

 defendant Jon Hallford.

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

                           (1) Nature and Circumstances of Offense

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

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

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

 role and participation in the underlying offense and thus, the Government does not

 repeat all of the facts here 3. PSR ¶¶ 11-71. It is important to note that the Defendant

 has stipulated that the underlying facts are true and correct as set forth in her Plea

 Agreement and incorporated within the PSR as part of relevant conduct. PSR ¶ 10.

 Further, the Defendant has agreed as part of the sentencing guidelines calculations that

 various sentencing enhancements apply including: a loss amount greater than

 $500,000 but less than $1,500,000, ten or more victims, sophisticated means,




        3 The Government has contemporaneously filed a Motion Seeking an Upward
 Variance Pursuant to 18 U.S.C. § 3553(a). Within such Motion, the Government
 discusses numerous facts and information relevant to the offense conduct. Here, the
 Government incorporates by reference such pleading and any pertinent facts set forth
 therein.

                                              3

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 conscious or reckless risk of death or serious bodily injury, vulnerable victim, and abuse

 of trust. PSR ¶¶ 86-88, 90-91.

        When evaluating the nature of the offense conduct, it is important to keep in mind

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

        First, the scheme defrauded numerous victims of monetary funds. Put simply,

 the Defendant knowingly failed to provide proper cremations or burial services for 190

 bodies despite contractually promising the families otherwise. PSR ¶ 23. Instead, the

 victims paid approximately $193,966.18 in aggregate for funeral services which the

 Defendants failed to ever provide. PSR ¶ 151. The Defendant and her husband often

 lied to the victims and next of kin by providing concrete mix instead of cremains. PSR ¶

 27.   In this respect, the crime was a classic “bait and switch swindle”. As a result, the

 Defendants’ business, Return to Nature, reaped an unjust financial windfall for services

 which it never rendered -- all to the economic detriment of the victims.

        Second, the Hallfords deceived the U.S. Small Business Administration (“SBA”)

 out of approximately $882,300 in covid relief funds through fraudulent loan statements

 and certifications. The Hallfords then misused the loan proceeds to purchase a $92,000

 vehicle along with spending it on frivolous personal expenditures such as vacations,

 entertainment, dining, cosmetic procedures and jewelry. PSR ¶ 43.          Ultimately, the

 Government (i.e. – taxpayer) was deprived of these funds and it will likely never recoup

 such losses given the Defendant’s indigency and imminent prison sentence.

        Third, the Hallfords crime resulted in numerous false death certificates being filed

 with the State of Colorado which subsequently had to be amended. PSR ¶ 25. Such a

 process resulted an unneeded angst and anxiety for victims who were already grieving.

                                             4

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 Similarly, third party businesses who provided cremation services for Return to Nature

 sometimes misidentified bodies within their own records exposing them to unnecessary

 liability. PSR ¶ 26. On at least two occasions, the wrong remains of bodies were buried

 by the Hallfords. This conduct resulted in two subsequent exhumations and forced

 families to go through the relived trauma of reburying a loved one. PSR ¶ 27.

        Fourth, the Hallford’s crime impacted others in the community by eroding the

 public’s trust and confidence in the funeral home industry. Although it’s impossible to

 measure the full extent of such harm, individuals who learned of the case within the

 Colorado Springs area were understandably dubious of the legitimacy of funeral home

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

 other reputable businesses who honestly provide essential services in this sensitive but

 essential area of commerce.

        Finally, in the course of swindling the victims out of their money, the Defendant

 also inflicted untold trauma on the families who trusted her. In this respect, this case is

 far worse than a routine fraud case. To the horror of some of the victims, they later

 learned from law enforcement that their loved ones’ bodies had been left to decay and

 decompose in unimaginable circumstances at the Penrose location. The Defendants’

 actions resulted in extreme emotional distress for numerous victims at a time when

 many were still grieving the loss of a loved one. The Government cannot adequately

 capture in words the extent of the victims’ pain as it is incalculable in depth and scope.

 Rather, the multiple victim impact statements submitted to the Court provide the best

 description of the damage caused by the crime along with the range of emotions felt by

 the victims which includes, despair, disbelief, betrayal, anger, vengeance, sadness,

                                              5

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 frustration, and grief, etc. Regrettably for many of the victims, the wounds caused by

 the indignities of the offense have been so great that it has been difficult for them to

 move on in their lives. Some victims have described suffering physical and medical

 infirmities due to the offense. In addition, a number of the victims have actually

 received counseling and therapy in the aftermath.

         In sum, the harmful toll caused by Carie Hallford’s conduct has been enormous

 and immeasurable. The negative financial, emotional, and health consequences for the

 victims from the offense and others collaterally impacted must be taken into account at

 sentencing in order for there to be any justice in this case.

                        (2) History and Characteristics of the Defendant

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

 criminal record. The present case represents her first felony conviction. PSR, ¶¶ 98-

 101. (Based on the underlying conduct, the Defendant is also awaiting sentencing in

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

 101).

         However, the Defendant’s formal criminal record only tells so much. It paints an

 incomplete picture related to her history and characteristics.

         Here, it’s important to keep in mind that the Defendant’s fraudulent conduct

 spanned four years (September 15, 2019, to October 5, 2023), and impacted the

 families and next of kin of 190 individuals. In the course of operating her business and

 carrying out the fraud scheme, the Defendant regularly interacted with the victims on

 multiple occasions over an extended period. To keep the horrific fraud scheme hidden,

 the Defendant and her husband told countless lies to the families and engaged in daily,

                                              6

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 deliberate falsehoods. The lies started with Return to Nature’s contractual promises

 that the remains of the deceased would be well-cared for and properly handled in a

 dignified manner, and concluded with the Hallfords providing grief-stricken family

 members with urns full of concrete mix. All the while, the Defendant was falsely

 reassuring the victims that she truly cared for their deceased loved ones. In the midst

 of this conduct, the Defendant was aware of the macabre nature of the Penrose building

 yet she did nothing about it. She was aware (as evidenced by text communications)

 that bodies were collecting, decomposition fluid was pooling on the floor, and the awful

 stench from rotting corpses permeated the air. PSR ¶ 65. To conceal the conduct, the

 Defendant helped her husband cover up the windows and doors of the Penrose building

 and caused false death certificates to be filed with the state.

        The following texts communications demonstrate the Defendant’s knowledge of

 the horrendous crime she and her husband were committing as early as June of 2020.

 Yet as decomposing bodies were accumulating at the Penrose location, the Defendant

 continued to carry out the scheme and helped conceal the crimes from others.

        For example, the Defendant had the following text exchange with her husband on

 June 4, 2020:

               Jon Hallford texted:

               You’re frustrated ! I’m sorry, I assure you it’s not for any other reason
               than trial and error, R and D, it’s learning as I go. I’m trying, and I’m
               beyond freaked out. We’re getting everything we want right now and
               that fucking Penrose could screw everything ! No one wants those
               bodies gone more than I do! I’m sorry

               Carrie Hallford replied:



                                               7

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              Yes we are ok…I have a lot going on in my brain and I’m sorry I can’t
              just shut it off. I’m thinking about the house, the loan, what do we still
              need to get taken care of to process the loan, cremation dates, am I
              upsetting families because we’re running so far behind, and yes
              Penrose….[rest of text intentionally omitted].

 (Gov’t. Exhibit 1, p.1, text #1). Approximately one year into the fraud scheme, the

 Defendant received a text (which was marked as “read”) from Jon Hallford on October

 6, 2020, which stated:

              By December 6th we need to begin cleaning and restoring the building in

              Penrose to be out by Dec. 31st.

              Options

              A – Build a new machine ASAP

              B. Dig a hole and use lye Where ?

              C. Dig a small hole and build a large fire Where ?

              D. I go to prison, which is probably what’s going to happen.

 (Gov’t. Exhibit 1, p.2, text #2). Several months before the fraud was discovered by

 authorities in October of 2023, the Defendant communicated with her husband on

 August 13, 2023, as follows:

              Jon Hallford texted:

              If Penrose were to get exposed, we both lose everything anyway. We
              can’t allow that to happen. We can’t allow our family to be destroyed. I
              don’t know that’s happening with the kids but I know that I’m willing to
              do whatever it takes to fix it.

              Carie Hallford replied:

              There’s nothing you or I can do to fix it. We cannot be together. We
              have a business to deal with and I want to help deal with it. The kids
              are done.


                                                8

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 (Gov’t. Exhibit 1, p.3, text #3).

        When the Hallfords were about to receive a $350,000 covid loan payment from

 the SBA in April of 2021, both the Defendant and her husband were keenly aware that

 such funds would be useful in addressing their disaster at the Penrose facility where

 bodies were rotting. The couple’s text exchange on April 7, 2021, was as follows:

                Jon Hallford texted:

                Do you understand IF we get the $350,000 it will completely get us out
                of debt and handle Penrose

                Carie Hallford replied:

                I know !!! Penrose !

 (Gov’t. Exhibit 1, p.4, text # 4). Despite ultimately receiving a large $350,000 loan

 payment from the SBA on May 24, 2021, neither of the Hallfords used the funds to

 properly cremate and bury the bodies at Penrose as they had promised. Instead, they

 spent the funds on personal expenses, ignoring the victims’ loved ones who were left to

 decay at their business.

        In short, the Defendant’s callous behavior during the four year period of the fraud

 scheme along with her active roll in covering it up provides the Court with ample insight

 into her character.

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

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

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

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

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


                                               9

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her husband took advantage of numerous victims who were at their lowest point given

the recent loss of a loved one. The fragile emotional state of many of the victims during

their bereavement cannot be overstated. While many victims were emotionally vulnerable

due to their gut-wrenching grief, the Defendant played a central role in carrying out the

underlying fraud.

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

manner - as was her contractual and moral obligation – the Defendant abused multiple

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

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

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

victims that Return to Nature would guide the families through the bereavement process

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

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

victims forever. By sentencing the Defendant to a lengthy prison sentence, the Court can

provide some semblance of justice albeit imperfect. A lengthy prison sentence will signal

to others that the law must be respected and that individuals like the Defendant who

decide to violate society’s basic norms of decency and respect for the deceased will

ultimately be accountable for their actions.

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

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

individuals who suffered from adverse business consequences during the pandemic.

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

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

                                               10

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

Defendant and her husband lied on the initial loan application to obtain the funds and then

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

cosmetic medical procedures, cryptocurrency, entertainment and vacations.               The

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

substantial prison term.

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

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

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

trauma. Instead of using the victims’ hard-earned money for promised cremations or

burials, the Defendant and Jon Hallford pocketed funds for their personal benefit while

failing to provide funeral services. The Defendants knowingly and repeatedly allowed

deceased bodies to languish, unattended in deplorable conditions. The Defendants also

abused the Government’s covid relief program resulting in significant losses for the SBA.

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

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

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

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

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

of wire fraud but in doing so, she gravely overstepped societal standards related to the

treatment of human remains. Others inclined to engage in this criminal conduct should

be put on notice that substantial imprisonment will inevitably result should they follow in

the same misguided path.

                                             11

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      There is also a need for specific deterrence as it relates to Carie Hallford as she is

48 years old and maintains the ability to gain employment in the future. To ensure that

innocent members of the public are protected and the Defendant is prevented from

returning to her deceitful business practices, the Court should impose a substantial

imprisonment sentence.

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

      The PSR does not indicate that the Defendant has any particularized needs in

connection with her sentence. She appears to be in good health and physical condition;

she has no apparent substance abuse issues, PSR ¶¶115, 119-120. The Defendant

has a high school degree and a bachelor of science degree from the University of

Central Oklahoma. PSR ¶ 121. She also received a certificate of medical technology

post-graduate. PSR ¶ 122. The Defendant’s employment history since 2013 includes

working in a lab at a hospital and working at other retail establishments. The bulk of her

employment history from 2017 to 2023 was spent working in the funeral home industry

with her husband for Hallford Homes, LLC. PSR ¶¶ 124-129. Finally, it does not

appear that the Defendant suffers from any mental health illness. PSR ¶ 116.

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

educational, vocational, medical or physical conditions that require special consideration

as part of her sentence.

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

      Conducting a meaningful disparity analysis between the Defendant and other

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

                                            12

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defendants engaging in similar conduct. Here, the co-defendant received a 20 year

imprisonment sentence. The Government also conducted a canvas of the federal

reporter looking for similar cases but was unable to find any congruent ones save one.

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

1011(2024) (District of Colorado), involved conduct implicating some of the same

factual issues involved in the present matter. In Hess, the defendants were a mother

and daughter team who each pled guilty to the offense of mail fraud in connection with

the operation of their family funeral home and body broker business. Id. at 1020-21.

Among other things, Hess and Koch worked together to defraud hundreds of customers

by falsely representing that they would provide a cremation or burial services for the

victims’ next of kin. Id. at 1020. Instead, the duo “frequently … exceeded the authority

which they obtained” as it related to decedents’ remains. Id. at 1019. In numerous

cases, “body parts beyond those which were authorized, if not entire bodies, would be

sold [by Hess and Koch] typically for purposes not even contemplated or agreed to by

the victims.” Id. Like here 4, “families were given cremains ‘that were represented as

that of their loved ones when that was not true.’ Instead, those cremains were either

replaced or mixed with the remains of others.” Id.

      At sentencing, Senior Judge Christine M. Arguello imposed an upward variant

sentence as to each. Hess received the statutory maximum of 240 months

imprisonment while Koch received 180 months. Id. 1022. The Tenth Circuit remanded


4   “The Hallfords – in a number of instances – provided the decedent’s family members,
friends, or designated next-of-kin with an urn filled with dry concrete mix instead of the
actual cremains of the deceased.” PSR ¶ 27.

                                           13

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the matter for resentencing as to both defendants based on various guideline issues. At

the resentencing hearing for both defendants held on April 21, 2025, the District Court

reimposed the same sentence of 20 years imprisonment as to each defendant. See

U.S. v. Megan Hess and Shirley Koch, Case No. 20-cr-00098-CMA (docket entries #s

428 and 431, judgments).

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

conducting its disparity analysis and considering whether an upward variance is

appropriate. Like in Hess, the present case involves more than simply a garden-variety

fraud scheme. Instead, the Defendants’ conduct breeched all bounds of societal norms

and decency when the Hallfords chose to continuously allow 190 bodies to rot and

decay in their funeral home, contrary to the wishes of the families and terms of the

victims’ funeral contracts. Like in Hess, the Defendants betrayed all trust which

families placed in them to properly handle the remains of loved ones in a dignified

manner. Instead, Carie Hallford and her husband defiled and disrespected the remains

of the loved ones, deceived the families by providing concrete mix rather than actual

cremains, and carried out their cruel conduct for a four year period.

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

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

advisory guidelines. However, other than Hess, there appears to be a dearth of cases

with a similar fact pattern as the present one. The macabre nature of the underlying

offense along with the Defendants’ calculating and callous manner in which they carried

it out makes it a unique outlier, with few other cases for comparison. Consequently, the

Government’s recommended sentence would not result in a disparate outcome as there

                                            14

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is a lack of similarly situated defendants from which to make a meaningful comparison.

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

need to consider the various aggravating factors which make the criminal conduct so

unique.

                          (7) Need to Provide Restitution to Victims

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

sentence in this case. As noted in the PSR, there are two victims in this case: (1) the

victims from the funeral home fraud scheme, and (2) the U.S. Small Business

Administration. Exhibit A, R-1. Under federal law 18 U.S.C. § 3664(i), the individual

victims harmed by the Hallfords are entitled to priority while the SBA’s right to restitution

is secondary.

       As noted in the numerous victim impact statements, the families of the deceased

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

receiving any restitution payments as soon as possible would certainly be of a benefit to

such victims. Nonetheless, the need for the victims to be recompensed must be

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

punishment and the protection of the public. Unfortunately, it does not appear from the

Defendant’s financial condition that she will be in a position to make any meaningful

restitution payments in the near future given that she is indigent and has virtually no

assets. PSR, ¶¶ 131-136.

       WHEREFORE, the Government requests that the Court impose an imprisonment

sentence to 180 months imprisonment.

       Respectfully submitted this 23rd day of February, 2026.

                                             15

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                                          PETER MCNEILLY
                                          United States Attorney

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

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




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