Government Opposition to Motion for Modification of Bail 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. 26 · 2025-01-22 · Docket on CourtListener

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U.S. Department of Justice 
 
 
United States Attorney 
 
District of New Jersey 
 
 
 ___________________________________________________________________________________________________________________________ 
 
 
970 Broad Street, 7th floor 
973-645-2700 
 
Newark, New Jersey 07102 
 
 
  
 
January 22, 2025 
Via ECF and Email 
 
The Honorable Michael A. Hammer 
United States Magistrate Judge 
MLK Jr. Bldg. & U.S. Courthouse 
50 Walnut Street 
Newark, NJ 07102 
 
 
 
 
Re: 
United States v. Daniel Dadoun, Mag. No. 23-8137 – 
Government Opposition to Motion for Modification of Bail 
Conditions  
 
Dear Judge Hammer: 
 
Please accept this letter in lieu of a more formal response in opposition to 
Defendant’s motion for modification of his bail conditions (ECF No. 25).  The Court 
should deny Defendant’s request.   
Background 
 
Defendant has been charged by criminal complaint with four counts of bank 
fraud and two counts of transacting in criminal proceeds associated with a scheme 
to defraud the U.S. Paycheck Protection Program of over $3.2 million in federal 
COVID-19 emergency relief funds, based on false and fraudulent loan and 
forgiveness applications. (ECF No. 1.)  Defendant, who is not a U.S. citizen and 
holds passports from Israel, Canada, and France, was arrested at JFK Airport on 
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November 12, 2023 upon arrival to the United States from China.  Defendant was 
thereafter detained. (ECF No. 6.) 
 
On September 19, 2024, Defendant was released on bail, over the 
Government’s objection, and the Court imposed strict conditions of home 
incarceration.  (See ECF Nos. 19, 20.)  The Government opposed Defendant’s 
request for release given the significant risk of flight.  Dadoun is a non-U.S. citizen 
with connections to several foreign countries and he has been charged with serious 
offenses.  He has access to significant funds including funds held both U.S. and 
foreign bank accounts, and he lacks ties to the community; his entire family resides 
in Israel.  
A. Defendant Has Not Been Compliant With Conditions of Home 
Incarceration, and Does Have a Criminal History 
 
 
Defendant has not remained compliant with the terms of his home 
incarceration.  For example, according to Pretrial Services, when asked to provide 
proof of his attendance at a recent medical appointment on January 16, 2025, 
Defendant was unable to do so, and said that the appointment had been cancelled. 
Location monitoring indicated that Defendant left his residence that day to go 
shopping.  When questioned about his whereabouts on January 19, 2025, another 
day on which Defendant purportedly had a medical appointment, Defendant 
reported to Pretrial Services that his appointment was rescheduled from 9:30 a.m., 
to 11 a.m., to 1:00 p.m., and that he traveled around Manhattan during that time.  
Pretrial Services is awaiting confirmation of Defendant’s attendance at a medical 
appointment on that date.  
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Defendant’s motion seeking modification of his bail conditions is also not 
accurate to the extent he claims that this is his first interaction with law 
enforcement and that he has no criminal history.  In fact, in 2014 Defendant was 
charged by state authorities in New Jersey with making false statements to law 
enforcement in connection with an incident at a business he operated, where a 
worker was electrocuted.  He received a conditional discharge, which is part of his 
criminal history.  
B. The Government Opposes Defendant’s Extensive Requests for 
Modification 
 
At the bail hearing on September 19, 2024, Defendant specifically asked that 
he be permitted to leave his residence for religious services, and the Court denied 
that request. (ECF No. 19.1) Nothing has changed that would warrant the Court 
revisiting that ruling, particularly given Defendant’s recent noncompliance with his 
current conditions of release.  Defendant continues to present a significant flight 
risk, and modification of his conditions to permit in-person attendance at religious 
services three times per day during weekdays, and twice on weekends, would 
permit him extensive freedom to leave his residence that would make it more 
difficult for Pretrial Services to monitor his location and ensure his compliance with 
conditions and his attendance for required court proceedings.  
Defendant’s current conditions of release already provide an accommodation 
for attorney visits.  However, the Government opposes Defendant’s request that he 
 
1 A copy of this transcript has been ordered, but not yet received.  
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be granted blanket permission to cross state lines to meet with his civil attorneys 
for five hours per day, twice a week, for a duration of six months.  Neither 
Defendant nor his attorneys have presented any justification as to why this 
modification of bail conditions is necessary or would be appropriate under the 
circumstances.  Defendant is represented by counsel as to these civil cases, none of 
which appear to name him personally as a litigant, and the cases appear to be 
straightforward contract, landlord-tenant, and zoning matters.  The Government is 
concerned that given the Defendant’s recent use of purportedly scheduled “medical 
appointments” to leave his residence for unauthorized purposes, modifying his 
conditions to permit this extensive, regular, out-of-state travel for purported 
attorney visits would present a significant risk of flight and could impede Pretrial 
Services’ ability to monitor his location. 
Conclusion 
For the reasons explained above and on the record at the bail hearing on 
September 19, 2024, the Court should deny Defendant’s request for modification of 
bail conditions.  (ECF No. 25.)  
Respectfully submitted, 
VIKAS KHANNA 
ACTING UNITED STATES ATTORNEY 
_______________________________ 
 By:  
Katherine M. Romano 
Assistant U.S. Attorney 
cc: Counsel of Record (via ECF) 
/s/ Katherine M. Romano
Case 3:25-cr-00215-RK     Document 26     Filed 01/22/25     Page 4 of 4 PageID: 120

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