Motion to Modify Release Conditions — United States v. Daniel Dadoun (D.N.J.)

Record facts

U.S. District Court, District of New Jersey · No. 3:25-cr-00215-RK · Doc. 25 · 2025-01-21 · Docket on CourtListener

Full text

ANTHONY POPE LAW, P.C.
ATTORNEYS AT LAW
NEW JERSEY OFFICE
NEW YORK OFFICE
60 PARK PLACE
275 MADISON AVE.
SUITE 1101
35TH FLOOR
NEWARK, NJ 07102
NEW YORK, NY 10016
TEL: (973) 344-4406
TEL: (212) 905-4900
FAX: (973) 344-320!
FAX: (973) 344-320!
wwvanthonvpopclawtirni cciii
ANTHONY POPE, ESQ.*
apope. ayopelirin.coni
*Certfied by the Supreme Court of
PLEASE REPLY TO:
New Jersey as a Civil & Criminal Trial Attorney
New Jersey Office
January 21, 2025
VIA ECF
The Honorable Michael A. Hammer
United States Magistrate Judge
Martin Luther King Building & U.S. Courthouse
50 Walnut Street
Newark, NJ 07101
RE:
United States v. Daniel Dadoun
Docket No. 23-8137
Dear Judge Hammer,
This office represents the interests of Defendant, Daniel Dadoun (hereinafier, “Mr.
Dadoun” or “Dadoun”), relative to the above-captioned matter. On September 19, 2024, Your
Honor entered an Order releasing Mr. Dadoun from custody on home incarceration, secured by
Dadoun’s residential properties and an appearance bond with a co-signor (ECF 20). Please
accept this correspondence in lieu of a more formal submission in support of Dadoun’s request
for modification of his release conditions to allow him to attend synagogue for daily religious
services and to attend in-person visits with his civil attorneys twice per week.
Since his release from custody in September 2024, Dadoun has remained compliant with
all conditions of his release. Because he was released on home incarceration, he is restricted to
his residence under a 24-hour lockdown (ECF 20). As a result, he is unable to attend religious
services or meet with his civil attorneys on a regular basis in order to to discuss the many civil
cases his company is actively litigating. For these reasons, he makes the within application for
modification of his release conditions to allow him to attend religious services or meaningfully
participate in the many of civil cases in litigation.
Case 3:25-cr-00215-RK     Document 25     Filed 01/21/25     Page 1 of 3 PageID: 111

Dadoun is a devout member of the Orthodox Jewish faith. Those who follow Orthodox
Judaism customarily attend synagogue for prayer services three times per day in the morning,
afternoon, and at sundown’. Orthodox Jewish individuals also attend prayer services on the
Sabbath (on Friday evenings and Saturday mornings), in addition to attending synagogue on
Jewish holidays such as Rosh Hashanah, Yom Kippur, and Passover. Dadoun’s religion is of
utmost importance to him. To illustrate, while incarcerated for over 10 months at the Essex
County Correctional Facility, Dadoun refused to take off his yarmulke, despite daily antisemitic
threats, harassment and assaults from his fellow inmates.
Because of his current release conditions, Dadoun was not permitted to attend religious
services on the Jewish holidays of Rosh Hashanah, Yom Kippur, or Succot, and cannot attend for
daily or Shabbat prayer services. This has been especially hard for Dadoun, whose faith has only
strengthened since his arrest and incarceration, and who wishes to pray not only for himself, but
also for his wife and children, all of whom remain in Israel. He respectfully requests the
opportunity to attend religious services at his local synagogue, “Yeshiva Ateret Torah,” located
at 901 Quentin Road in Brooklyn, NY, 11223. If permitted, he would attend for morning,
afternoon, and night prayer on weekdays, as well as Sabbath Prayers on Friday nights and
Saturday mornings.
Additionally, Dadoun requests the opportunity to visit his civil attorney’s office, located
in Hackensack, New Jersey, twice per week on Tuesdays and Thursdays. The state of affairs of
Dadoun’s businesses has resulted in many lawsuits filed against them. Dadoun hired Richard D.
Wolloch, Esq., of the law firm of Winnie Banta Basralian & Kahn, to represent him in these
lawsuits. Mr. Wolloch provided a letter in support of this request, in which he included the
names of the cases in suit and their corresponding docket numbers (see attached “Exhibit A” for
a copy of Mr. Wolloch’s letter). Due to the amount of cases and the extent to which the firm
requires Dadoun’s assistance, his attorneys would be better served by having increased face-to-
face interaction with Dadoun, as opposed to phone calls and sending documents back and forth.
The Government has communicated its position that it cannot provide consent for any of
the within requests for modification of Dadoun’s release. However, Dadoun has not engaged in
any conduct during the pendency of his release that would lead the Court to believe that if
granted, Dadoun would not be similarly compliant with the modifications. Further, the instant
case represents Dadoun’s only interaction with law enforcement, as he has no prior criminal
history. Dadoun has surrendered his passport, and his release was secured by a custodian, a co
signor, and his property. Therefore, there are appropriate safeguards to prevent Dadoun from
fleeing the Country, despite there being no desire for him to do so.
For the foregoing reasons, Mr. Dadoun respectfully requests that the Court modif5’ his
current release conditions to allow him to attend religious services at his synagogue and for
weekly visits to his civil attorneys’ office.
Respectfully submitted,
Dadoun’s synagogue holds moming prayers at 7AM; afternoon prayers at 12:30 PM, and night prayers at
sundown.
Case 3:25-cr-00215-RK     Document 25     Filed 01/21/25     Page 2 of 3 PageID: 112

cc: AUSA Katherine Romano
ANTHONY POPE LAW, P.C.
,ESQ.
Case 3:25-cr-00215-RK     Document 25     Filed 01/21/25     Page 3 of 3 PageID: 113

File and source

File

gov.uscourts.njd.565817.25.0.pdf

Size

122,230 bytes

SHA-256

569d219b6a4af6bd9babd25e86618451ef3cadd0339fe64400c30fe05269dab5

Our copy

gov.uscourts.njd.565817.25.0.pdf

Original

PACER (login required)