Government’s Unopposed Motion for Reconsideration of Court Order Cotinuing Sentencing Date for Jon M. Hallford — No. 1:24-cr-00113 (Dkt. 95, D. Colo.)

Summary

The government's unopposed motion for reconsideration of the court order continuing the sentencing date for defendant Jon M. Hallford, filed March 10, 2025 as Document 95 in United States v. Hallford, Criminal Case No. 24-cr-00113-NYW, in the U.S. District Court for the District of Colorado. The motion states that the court changed the sentencing date from March 20, 2025 to June 27, 2025 (ECF #93) on March 6, 2025. It notes that co-defendant Carie Hallford's trial is set for April 14, 2025 and that she has an unopposed motion for a continuance of about 180 days pending, and that Jon Hallford is to be sentenced in state court on April 18, 2025. The government asks to keep the March 20 sentencing, stating that approximately ten victims intend to speak.

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“Government’s Unopposed Motion for Reconsideration of Court Order Cotinuing Sentencing Date for Jon M. Hallford — No. 1:24-cr-00113 (Dkt. 95, D. Colo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/government-s-unopposed-motion-for-reconsideration-of-court-order-cotin-77e9b9c225/, SHA-256 c5b05b31db7ef76632bc5356faef30ed229b8df8c3e074b7ff9b470eb723dcb4.

Full text

Case No. 1:24-cr-00113-NYW Document 95 filed 03/10/25 USDC Colorado pg 1
of 6

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO

Criminal Case No. 24-cr-00113-NYW

UNITED STATES OF AMERICA,

Plaintiff,

1. JON M. HALLFORD,

Defendant.

GOVERNMENT’S UNOPPOSED MOTION FOR RECONSIDERATION OF COURT
ORDER COTINUING SENTENCING DATE FOR JON M. HALLFORD

The Government respectfully moves this Court to reconsider its recently entered

Order continuing the Sentencing Hearing for defendant Jon Hallford. This Motion is

unopposed.

1. On March 6, 2025, the Court sua sponte changed the sentencing date for the

Defendant from March 20, 2025, until June 27, 2025. [ECF #93, Minute Order]. The

Court understandably issued its ruling in an effort to ensure “efficiency of the

proceedings, including but not limited to minimizing the impact upon repeated testimony

of potential victim witnesses at trial.” Id. Neither party questions the Court’s rationale

for moving the sentencing date. However, the following reasons are offered as

countervailing factors for the Court’s evaluation in this Motion for Reconsideration.

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Case No. 1:24-cr-00113-NYW Document 95 filed 03/10/25 USDC Colorado pg 2
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2. Co-defendant Carie Hallford’s case is currently set for trial on April 14,

2025. Pending before the Court is an Unopposed Motion for an Ends of Justice

Continuance [#94] filed by co-defendant Carie Hallford, which if granted, would delay

the start of the trial in her case for approximately 180 days. The Government did not

oppose Carie Hallford’s Motion for such a delay for her trial date because the request

appeared to be a reasonable in light of the time period necessary for the parties to

litigate any pretrial motions and to provide for adequate time to effectively prepare for

trial.

3. In the event the Court grants such a delay in Carie Hallford’s case, the

present sentencing date of June 27th for Jon Hallford would not achieve the goal of

minimizing the impact of victims potentially testifying twice. Because the two co-

defendants are on no longer on a parallel track, the likelihood of a small number of

victims testifying more than once is an unfortunate but unavoidable circumstance.

4. Here, Jon Hallford is set to be sentenced in state court on related charges on

April 18, 2025. Accordingly, some victims may necessarily need to speak more than

once given that there is a separate but interconnected state case.

5. From the Government’s perspective, the benefits of proceeding to the

sentencing hearing on March 20th as previously scheduled outweigh the burden that

might be placed on a small number of victims who may need to testify twice. Here,

approximately ten victims are presently intending to speak at the sentencing on March

20th. The Government does not anticipate calling all of these specific victims at the

2
Case No. 1:24-cr-00113-NYW Document 95 filed 03/10/25 USDC Colorado pg 3
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trial for Carie Hallford; therefore, the number of victims who potentially need to be called

twice as victims in the federal case is anticipated to be minimal. In addition, the vast

majority of the victims in this case have expressed a desire to government counsel over

the last several months for the sentencing date to remain fixed on March 20th.

Government counsel has explained to the victims that lengthy delays are sometimes

necessary in cases of this nature. Nonetheless, the impacted victims are desirous of

having the matter proceed to sentencing as expeditiously as possible – even if the

sentencing is as to only one of the defendants. Victims have expressed that delays in

a case of this nature are frustrating and demoralizing.

6. In addition, the parties agreed to a reciprocal term within the plea agreement1

requiring both parties to attempt to have the Defendant sentenced first on the federal

case before the related state case. As indicated, Jon Hallford is set to be sentenced in

state court on April 18, 2025. The respective parties in state court scheduled the April

1
The Defendant agreed in term no. 8 of the Plea Agreement [#52, p. 2] to the following:

Agree to request and/or not oppose efforts by the Government to have the
sentencing hearing occur first within the present federal case before proceeding
to any future sentencing hearing in the related state court case pending in U.S. v.
Jon Hallford, Case No. 2023CR4849, El Paso County District Court, Colorado.

Similarly, the Government agreed to the following term no. 5 in the Plea Agreement [#52, p. 3]
the following:

Agree to request and/or not oppose efforts by the Defendant to have the
sentencing hearing occur first within the present federal case before proceeding
to any future sentencing hearing in the related state court case pending in U.S. v.
Jon Hallford, Case No. 2023CR4849, El Paso County District Court, Colorado;
and

3
Case No. 1:24-cr-00113-NYW Document 95 filed 03/10/25 USDC Colorado pg 4
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18th sentencing date on the assumption that a federal sentence would have already

been imposed by such date. As a result, delaying sentencing on the federal case until

June may have the collateral consequence of delaying the state sentencing date which

is not desired by the state litigants. While this Court is certainly not bound by the

parties’ plea term seeking to have the Defendant sentenced first on federal charges

before state ones, both parties are seeking such an occurrence here.

7. The parties have conferred on this issue and both sides are concerned that

the order in which sentences are imposed between the respective federal and state

courts may likely impact which sovereign has primary jurisdiction when it comes to the

Defendant serving any prison time.

8. Government counsel has also conferred with defense counsel (Ms. Laura

Suelau) regarding the present Motion and she does not oppose the request. Both

parties remain ready to proceed to sentencing on the previously scheduled date of

4
Case No. 1:24-cr-00113-NYW Document 95 filed 03/10/25 USDC Colorado pg 5
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March 20th should the Court grant the herein Motion for Reconsideration.

Respectfully submitted this 10th day of March, 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

5
Case No. 1:24-cr-00113-NYW Document 95 filed 03/10/25 USDC Colorado pg 6
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CERTIFICATE OF SERVICE

I certify that on this 10th day of March, 2025, I electronically filed the foregoing
GOVERNMENT’S UNOPPOSED MOTION FOR RECONSIDERATION OF COURT
ORDER COTINUING SENTENCING DATE FOR JON M. HALLFORD 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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