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Home Source documents Government’s Motion Pursuant to U.S.S.G. § 3E1.1(b) to Award Defendant Jon Hallford a Decrease in Offense Level by One Additional Level for Acceptance of Responsibility — United States v. Jon M. Hallford, No. 24-cr-00113-NYW (Dkt. 78, D. Colo.)

Government’s Motion Pursuant to U.S.S.G. § 3E1.1(b) to Award Defendant Jon Hallford a Decrease in Offense Level by One Additional Level for Acceptance of Responsibility — United States v. Jon M. Hallford, No. 24-cr-00113-NYW (Dkt. 78, D. Colo.)

Summary

In this District of Colorado motion, submitted on the 24th day of February, 2025, the United States asks the court to give defendant Jon M. Hallford a decrease in offense level by one additional level for acceptance of responsibility under U.S.S.G. § 3E1.1(b). The government says the defendant assisted authorities by timely notifying them of the intention to plead guilty, which let the government avoid preparing for trial and allocate its resources efficiently. The motion is signed by Assistant U.S. Attorneys Tim Neff and Craig G. Fansler for Acting U.S. Attorney J. Bishop Grewell in Criminal Case No. 24-cr-00113-NYW.

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Full text

                      IN THE UNITED STATES DISTRICT COURT
                          FOR THE DISTRICT OF COLORADO


Criminal Case No. 24-cr-00113-NYW

UNITED STATES OF AMERICA,

       Plaintiff,

v.

1. JON M. HALLFORD,

       Defendant.


     GOVERNMENT'S MOTION PURSUANT TO U.S.S.G. § 3E1.1(b) TO AWARD
      DEFENDANT JON HALLFORD A DECREASE IN OFFENSE LEVEL BY
       ONE ADDITIONAL LEVEL FOR ACCEPTANCE OF RESPONSIBILITY



       The United States of America respectfully moves this Court to enter an Order

awarding defendant Jon Hallford a decrease in offense level by one additional level for

acceptance of responsibility. The Government files this Motion pursuant to U.S.S.G.

§3E1.1(b).

       As grounds, the Government states that the Defendant has assisted authorities

in the investigation and prosecution of his own misconduct by timely notifying authorities

of his intention to enter a plea of guilty, thereby permitting the Government to avoid

preparing for trial and permitting the Government to allocate its resources efficiently.

       WHEREFORE, the Government moves the Court to grant this Motion and award

//

//


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the Defendant a decrease in offense level by one additional level based on his

acceptance of responsibility.

      Respectfully submitted this 24th day of February, 2025.



                                               J. Bishop Grewell
                                               Acting 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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                               CERTIFICATE OF SERVICE

       I certify that on this 24th day of February, 2025, I electronically filed the foregoing
GOVERNMENT'S MOTION PURSUANT TO U.S.S.G. § 3E1.1(b) TO AWARD
DEFENDANT JON HALLFORD A DECREASE IN OFFENSE LEVEL BY ONE
ADDITIONAL LEVEL FOR ACCEPTANCE OF RESPONSIBILITY with the Clerk of the
Court using the CM/ECF system which will send notification of such filing to counsel of
record in this case.

                                    By: s/Ilmira Allazova
                                       Legal Administrative Specialist
                                       United States Attorney’s Office




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