Application to File Sentencing Memorandum Under Seal — United States v. Ford (W.D. Okla., Document 26)

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Application to File Sentencing Memorandum Under Seal, filed May 11, 2023 as Document 26 in United States v. Jill Nichole Ford, Case 5:22-cr-00009-JD, in the U.S. District Court for the Western District of Oklahoma. Counsel for the Defendant, Jill Ford, asks under WD OK LCr.R. 12.2 to file the sentencing memorandum and an attachment under seal. The application states that counsel believes the memorandum contains sensitive, personal, and confidential information and asks the Court to consider these matters without them becoming a public record. It is signed /s/ J. Patrick Quillian and carries a certificate of service dated May 11, 2023.

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           Case 5:22-cr-00009-JD Document 26 Filed 05/11/23 Page 1 of 2




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

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

       APPLICATION TO FILE SENTENCING MEMORANDUM UNDER SEAL

       Counsel for the Defendant, Jill Ford, submits this application to file her sentencing

memorandum and attachment under seal pursuant to WD OK LCr.R. 12.2. In support of this

request, counsel states:

       Counsel believes it necessary, in order to represent Mrs. Ford effectively in this

proceeding, that she file Defendant’s Sentencing Memorandum with the Court that contains

sensitive, personal, and confidential information. Counsel for Mrs. Ford requests that the Court

consider these matters without them becoming a public record in the case.

       Counsel for the Defendant therefore requests that the Court approve this Application and

enter an Order allowing the filing of the Defendant’s Sentencing Memorandum under seal.

                                                   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
                                                   Phone: 405-418-888
                                                   Fax: 405-260-9573
                                                   jpatrickquillianpc@gmail.com
           Case 5:22-cr-00009-JD Document 26 Filed 05/11/23 Page 2 of 2




                                CERTIFICATE OF SERVICE

        I hereby certify that on May 11, 2023, I electronically transmitted the attached document
to the Clerk of the Court using the ECF system for filing and transmittal of a Notice of Electronic
Filing to all ECF registrants who have entered their appearance in the above-referenced matter,
including Assistant United States Attorney Jessica Perry.


                                                                    s/J. Patrick Quillian
                                                                    J. Patrick Quillian




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