Pandemic Darlings The pandemic economy, in original documents
Home Source documents Unopposed Motion for Relief from Certain Conditions of Pretrial Release — United States v. Ford (Document 16)

Unopposed Motion for Relief from Certain Conditions of Pretrial Release — United States v. Ford (Document 16)

Summary

An Unopposed Motion for Relief from Certain Conditions of Pretrial Release, filed September 23, 2022 as Document 16 in United States of America v. Jill Nicole Ford, Case No. CR-22-009-JD, in the U.S. District Court for the Western District of Oklahoma. Counsel J. Patrick Quillian asks for an order requiring U.S. Probation to temporarily return Mrs. Ford's passport, allowing renewal of the passport, and permitting travel to Cancun, Mexico in November 2022 to attend a conference for work purposes. The motion states that Mrs. Ford entered a guilty plea on January 20, 2022 and surrendered the passport to U.S. Probation that day as a condition of release. It states that Assistant United States Attorney Jessica Perry has no objection and that probation officer Robert Honstein has indicated no objection.

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

Cite this document

“Unopposed Motion for Relief from Certain Conditions of Pretrial Release — United States v. Ford (Document 16).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-w-d-okla-no-5-22-cr-00009-dkt-16-e7fee164ec/, SHA-256 eba0b5f1b924b68bb133a7ac3ffe0f8596bc54f02587f8dea4c116350417fa82.

Full text

          Case 5:22-cr-00009-JD Document 16 Filed 09/23/22 Page 1 of 4




             IN THE UNITED STATES DISTRICT COURT FOR THE
                    WESTERN DISTRICT OF OKLAHOMA

UNITED STATES OF AMERICA,                        )
                                                 )
                     Plaintiff,                  )
                                                 )
v.                                               )      Case No. CR-22-009-JD
                                                 )
JILL NICOLE FORD,                                )
                                                 )
                     Defendant.                  )

     UNOPPOSED MOTION FOR RELIEF FROM CERTAIN CONDITIONS OF
                       PRETRIAL RELEASE

       COMES NOW, Jill Nicole Ford, Defendant in the above styled and numbered

cause, by and through her counsel of record, J. Patrick Quillian, Esq. (“Counsel”), hereby

moves the Court for an order requiring U.S. Probation to temporarily return Mrs. Ford’s

passport to her, allowing Mrs. Ford to renew said passport, and permitting her to travel to

Cancun, Mexico in November 2022 so that she may attend a conference for work purposes.

Mrs. Ford submits the following in support of the motion:


       1. Mrs. Ford entered a guilty plea on January 20, 2022, and was permitted to remain

          on release pending sentencing.      Doc. No. 5.     That same day Mrs. Ford

          surrendered her now-expired passport to U.S. Probation as a condition of her

          release. Doc. No. 12. The conditions of release also prohibit Mrs. Ford from

          traveling outside the Western District of Oklahoma without U.S. Probation’s
   Case 5:22-cr-00009-JD Document 16 Filed 09/23/22 Page 2 of 4




   permission and prohibit her from obtaining another passport or other

   international travel document. Id.

2. Mrs. Ford currently resides in Arlington, Texas with her husband and three (3)

   young children and is being supervised by the U.S. Probation Office of the

   Northern District of Texas. To date, Mrs. Ford has been fully compliant with

   her conditions of release.

3. As of the date of this motion, the initial presentence report has not been prepared

   and no sentencing date has been set.

4. Mrs. Ford has agreed to a restitution amount that exceeds $250,000 as part of

   her plea agreement with the government. Doc. No. 8, p. 4. Since beginning

   pre-indictment talks with the government for resolving this matter, Mrs. Ford

   has worked to support her family as well as pay off the restitution that will

   ultimately be ordered by the Court. Mrs. Ford currently works in the Bitcoin

   mining industry for Monbanc Corporation as a salaried employee who also

   makes significant commissions by traveling to conferences and soliciting clients

   for the company. These conferences have historically been lucrative for Mrs.

   Ford, and those commissions have become even more important for the Ford

   family since Mrs. Ford’s husband has recently become unable to work due to

   health reasons.

5. Mrs. Ford’s employer recently indicated that they wish for her to attend the

   World Digital Mining Conference in Cancun, Mexico (The “WDMC”) in
          Case 5:22-cr-00009-JD Document 16 Filed 09/23/22 Page 3 of 4




          November 2022 (the exact date will not be announced until October), which

          presents an opportunity for Mrs. Ford to make a significant commission.

       6. Mrs. Ford therefore requests that the Court grant her relief from the conditions

          of pretrial release (Doc. No. 12) to the extent she be allowed to retrieve her

          passport, renew it, and travel internationally solely for the purpose of attending

          the WDMC. She would promptly return said passport to U.S. Probation after

          returning from this trip. In the event the Court or the government had concerns

          regarding this being an opportunity for Mrs. Ford to flee prior to sentencing,

          counsel notes that Mrs. Ford would not be attending the event with her husband

          and/or her three (3) children.

       7. Counsel for Mrs. Ford has consulted with the Government on this matter and

          Assistant United States Attorney Jessica Perry has no objection to the relief

          sought herein. Mrs. Ford’s probation officer Robert Honstein has indicated he

          too does not object to her going on this work trip.


       WHEREFORE, based on the above and foregoing, Mrs. Ford respectfully requests

this Honorable Court enter an order requiring U.S. Probation to temporarily return Mrs.

Ford’s passport to her, allowing Mrs. Ford to renew said passport, permitting Mrs. Ford to

travel to the WDMC in November 2022, and requiring Mrs. Ford to promptly return said

passport to U.S. Probation after the conference.


                                                   Respectfully submitted,

                                                   /s/J. Patrick Quillian
         Case 5:22-cr-00009-JD Document 16 Filed 09/23/22 Page 4 of 4




                                               J. Patrick Quillian, OBA#20811
                                               Phillips, Coventon, Quillian &
                                               Banner, PLLC
                                               1900 Northwest Expressway, Suite 601
                                               Oklahoma City, Oklahoma 73118
                                               Telephone: (405) 418-8888
                                               Facsimile: (405) 260-9573
                                                jpatrickquillianpc@gmail.com
                                               Counsel for Defendant Jill Ford

                            CERTIFICATE OF SERVICE

  X     I hereby certify that on or before the 23rd day of September, 2022, a copy of the
attached document was electronically transmitted to all ECF registrants in the above-
referenced matter, namely:

Jessica Perry, Esq., Assistant United States Attorney

File and source

File
16.pdf
Size
88,922 bytes
SHA-256
eba0b5f1b924b68bb133a7ac3ffe0f8596bc54f02587f8dea4c116350417fa82
Our copy
16.pdf
Original
archive.org
Back to top