Motion to Modify Conditions of Release as to Erin Jare Brown — USA v. Adiana Pierre, et al. (Brown) (Dkt. 22, D. Mass.)

Record facts

U.S. District Court for the District of Massachusetts · No. 1:23-mj-05013-JGD · Doc. 22 · 2023-04-14 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
____________________________________
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UNITED STATES OF AMERICA
 )
 )
Plaintiff,
 ) 
 )
v.
 )
Case No. 23-mj-5013-JGD-2
 )
ERIN BROWN FORD,
 )
 )
Defendant.
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____________________________________)
DEFENDANT ERIN BROWN FORD'S 
UNOPPOSED M
 
 OTION TO MODIFY CONDITIONS OF RELEASE
Defendant Erin Brown Ford respectfully requests that the Court modify a condition of her
pretrial release and allow her to obtain an increase in her credit card limit and to apply for a new 
cell phone plan which will require a credit check.
In support of this motion, Mrs. Ford states as follows:
1. Mrs. Ford and her husband Wallace Ford were both arrested and charged in this matter. 
Mrs. Ford was subsequently released on conditions, including a condition requiring that 
Mrs. Ford “not submit any loan applications absent prior approval from the probation 
officer.”
2. Pursuant to the relevant release condition, undersigned counsel asked probation to 
approve Mrs. Ford’s increase in her credit card limit and application for a new cell phone 
plan, but probation has demurred and directed that Mrs. Ford seek Court approval.
3. Since her release, Mrs. Ford has been a model supervisee and has complied with all 
release conditions. The increase in her credit card limit and new cell phone plan are 
Case 1:23-mj-05013-JGD     Document 22     Filed 04/14/23     Page 1 of 2

needed to allow the Fords to meet their everyday expenses in the most cost effective way 
possible.
4. Undersigned counsel has conferred with counsel for the government in this matter, and he
does not oppose this motion.
WHEREFORE, Mrs. Ford respectfully requests that this Court ALLOW this motion and
modify the conditions of her release to allow her to obtain an increase in her credit card limit and
to apply for a new cell phone plan which will require a credit check.
Respectfully Submitted,
ERIN BROWN FORD
By her attorney,
      /s/ Joan M. Griffin        
Joan M. Griffin (BBO# 549522)
PO Box 133
Dublin, NH 03444 
Griffin@LawJMG.com, (617) 283-0954
April 14, 2023
CERTIFICATE OF SERVICE
 I hereby certify that the above document was served on all parties of record by ECF 
filing on April 14, 2023.
/s/ Joan M. Griffin
Joan M. Griffin
2
Case 1:23-mj-05013-JGD     Document 22     Filed 04/14/23     Page 2 of 2

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