Second Unopposed Motion for Relief from Certain Conditions — United States v. Ford (W.D. Okla., Document 19)

Summary

A Second Unopposed Motion for Relief from Certain Conditions of Pretrial Release, filed January 5, 2023 as Document 19 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 permitting Mrs. Ford to obtain a passport and travel to Dubai, UAE, in early February 2023 to attend a conference for work purposes. The motion identifies the conference as the Satoshi Roundtable IX, scheduled to take place February 2 to February 7, 2023. It states that Assistant United States Attorney Jessica Perry has no objection and that probation officer Robert Honstein has indicated he does not object. The signature line shows /s/J. Patrick Quillian.

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         Case 5:22-cr-00009-JD Document 19 Filed 01/05/23 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.                   )

       SECOND 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”), and

hereby moves the Court for an order permitting Mrs. Ford to obtain a passport and travel

to Dubai, UAE, in early February 2023 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

          permission and prohibit her from obtaining another passport or other

          international travel document. Id.
             Case 5:22-cr-00009-JD Document 19 Filed 01/05/23 Page 2 of 4




         2. Mrs. Ford currently resides in Arlington, Texas with her 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 save money to pay off the restitution

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

             Bitcoin mining industry for Fort Worth, Texas-based Not Your Basic ASIC 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.

         5. Mrs. Ford recently was invited to attend the Satoshi Roundtable IX, an exclusive,

             invitation-only Bitcoin conference in Dubai, UAE that is scheduled to take place

             February 2 to February 7, 2023 (the “Conference”).1 Mrs. Ford believes that

             attending the Conference could assist her in earning commissions, a majority of

             which she plans to pay towards restitution.



1
    Information on the Conference can be found at https://satoshiroundtable.org/.
          Case 5:22-cr-00009-JD Document 19 Filed 01/05/23 Page 3 of 4




       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 obtain a new

          passport and travel internationally solely for the purpose of attending the

          Conference. 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 also 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 permitting Mrs. Ford to obtain a valid passport and

travel to the Conference in early February 2023, and requiring Mrs. Ford to promptly return

said passport to U.S. Probation after she returns from the Conference.


                                                 Respectfully submitted,

                                                 /s/J. Patrick Quillian
                                                 J. Patrick Quillian, OBA#20811
                                                 Phillips, Coventon, Quillian &
                                                 Banner, PLLC
                                                 1900 Northwest Expressway, Suite 601
                                                 Oklahoma City, Oklahoma 73118
          Case 5:22-cr-00009-JD Document 19 Filed 01/05/23 Page 4 of 4




                                                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 5th day of January, 2023, 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


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