Letter Motion for Turnover Order — United States v. Daniel Dadoun

Record facts

U.S. District Court, District of New Jersey · No. 3:25-cr-00215-RK · Doc. 50 · 2026-02-27 · Docket on CourtListener

Full text

U.S. Department of Justice 
 
 
 
United States Attorney 
 
 
District of New Jersey 
 
_____________________________________________________________________________________________________________________ 
 
 
February 27, 2026 
 
VIA ECF 
The Honorable Robert Kirsch 
United States District Judge 
Clarkson S. Fisher Building & U.S. Courthouse 
402 East State Street 
Trenton, New Jersey 08608 
 
 
     
 
 
 Re:  United States v. Daniel Dadoun,  
 
 
 
 
         Criminal Number: 25-CR-215 (RK) 
 
Dear Judge Kirsch: 
 
 
I am an Assistant United States Attorney assigned to the Bank Integrity, 
Money Laundering and Recovery Unit. I am responsible for the enforcement and 
collection of the Special Assessment and Restitution that was ordered in the above-
referenced case. The United States respectfully submits this Letter Motion and 
proposed Turnover Order allowing for approximately $1,706.85, that is currently held 
in Defendant’s Bureau of Prisons (BOP) Inmate Trust Account, to be turned over to 
the Clerk of Court and applied against the Special Assessment and Restitution due 
in this matter. 
 
 
By way of background, pursuant to Defendant Daniel Dadoun’s (Defendant) 
Judgment, dated: September 22, 2025, the Defendant was ordered to pay a Special 
Assessment in the amount of $200.00 and to pay Restitution in the amount of 
$3,239.773.43 (interest waived) (ECF# 49). The combined Special Assessment debit 
and the Restitution debt resulted in a total debt of $3,239,973.43. As of February 13, 
2026, the Defendant’s outstanding Special Assessment and Restitution debt balance 
was approximately $3,239,973.43. The Court ordered that the Special Assessment 
and the Restitution were “due immediately” (ECF# 49 at 1 and 7). 
 
 
The United States submits that the requested relief is reasonable and 
appropriate in this instance where the Defendant has accumulated significant funds 
in his BOP Inmate Trust Account (also known as: Inmate Commissary Account). Also, 
TODD BLANCHE 
 
U.S. DEPUTY ATTORNEY GENERAL 
                                                                                                                                                      
PHILIP LAMPARELLO 
SENIOR COUNSEL 
 
Jordan M. Anger  
Assistant United States Attorney 
 970 Broad Street, Suite 700 
 Newark, New Jersey 07102 
 jordan.anger@usdoj.gov                             
main:  (973) 645-2700    
direct: (973) 645-2829 
fax:     (973) 645-3210 
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without this relief, the BOP will be required to allow the Defendant access to those 
funds. That would allow the Defendant the opportunity to possibly dissipate, conceal 
or transfer the fund, without first paying his court ordered Special Assessment and 
Restitution. 
 
The Defendant remains in the custody of the BOP and is assigned to the 
Federal Correctional Institution-Fort Dix at Joint Base Middle, New Jersey. The 
Defendant has BOP Register Number: 86374-510. The Defendant is scheduled to 
remain in the custody of the BOP until May 21, 2027. The Defendant’s BOP Inmate 
Trust Account balance was approximately $1,706.85 as of February 10, 2026. 
 
 The United States will apply the $1,706.85 (or whatever lesser amount is 
deemed appropriate by the Court) from the Defendant’s BOP Inmate Trust Account 
at the time of turnover to the outstanding Special Assessment and Restitution debts 
owed by this Defendant. 
 
The United States has served the Defendant with a copy of this Letter Motion 
and the attached proposed Turnover Order. The Defendant may object to the United 
States’ intended use of his property. The United States is not aware of any other 
party, who may claim an interest in the property. 
 
The United States submits the enclosed proposed Turnover Order seeking:  
 
1. 
The BOP remit $1,706.85 (or whatever lesser amount is deemed 
appropriate by the Court) currently contained in the Defendant’s BOP 
Inmate Trust Account to the Clerk of Court to be applied against the 
Defendant’s outstanding Special Assessment and Restitution debt; and  
 
2. 
That the Defendant’s Special Assessment and Restitution debts be credited 
with the foregoing payments. 
 
 
Pursuant to 18 U.S.C. § 3613: 
 
The United States may enforce a judgment imposing a fine 
[or restitution] in accordance with the practices and 
procedures for the enforcement of a civil judgment under 
Federal law or State law. Notwithstanding any other 
Federal law . . . a judgment imposing a fine may be enforced 
against all property or rights to property of the person fined 
. . . . 
 
18 U.S.C. § 3613(a). 
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Enforcement of restitution may begin immediately after an entry of judgment 
arises on a defendant’s property.  See id. § 3613(c).  Pursuant to Section 3613(c), an 
order of restitution creates “a lien in favor of the United States on all property and 
rights to property of the person fined as if the liability . . . were a liability for a tax 
assessed” by the IRS.  Id. (emphasis added).  The only property not subject to 
enforcement is that which is exempt under § 6334(a)(1)-(8), (10) and (12) of the 
Internal Revenue Code of 1885.  See id. § 3613(a)(1).  In other words, not only may a 
judgment be recorded for the full amount of the order, see id. § 3664(m)(1), but the 
judgment may be immediately enforced against all property of the defendant with 
limited exceptions.  Id. § 3613(a) and (f). 
 
 
Since the enactment of the Victim and Witness Protection Act of 1982 
(“VWPA”), federal courts have been vested with general authority to order victim 
restitution as part of the sentence for criminal convictions under Title 18.  See VWPA, 
Pub. L. No. 97-291, § 5, 96 Stat. 1248, 1253-55 (1982) (enacting predecessor to 18 
U.S.C. § 3663).  In reporting this legislation to the full Senate, the Committee on the 
Judiciary noted: 
 
The principle of restitution is an integral part of virtually 
every formal system of criminal justice, of every culture 
and every time. It holds that, whatever else the sanctioning 
power of society does to punish its wrongdoers, it should 
also ensure that the wrongdoer is required to the degree 
possible to restore the victim to his or her prior state of 
well-being. 
 
S. Rep. 97-532 at 30 (1982), reprinted in 1982 U.S.C.C.A.N. 2515, 2536.  The 
VWPA was part of a movement towards a more victim-centered justice system and 
for the first time provided federal courts with authority to order payment of 
restitution independently of probation.  See id. 
 
Congress strengthened the role of restitution in the sentencing process in 1996 
by enacting the Mandatory Victims Restitution Act (“MVRA”), Pub. L. No. 104-132, 
§§ 201-211, 110 Stat. 1214 (1996).  The MVRA made victim restitution mandatory for 
most federal crimes, consolidated procedures for issuing restitution orders, and 
provided for enhanced post-conviction enforcement of such orders by the United 
States.  The restitution provisions of the MVRA and the VWPA are now codified 
principally at 18 U.S.C. §§ 3663, 3663A, and 3664.  The legislative history of the 
MVRA in the United States Senate indicates that it was intended: 
 
[F]irst, to require that full restitution be ordered to the 
victims of all covered offenses in which there is an 
identifiable victim, second, to establish one set of 
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procedures for the issuance of restitution orders in Federal 
criminal cases, and third, to consolidate the procedures for 
the collection of unpaid restitution with existing 
procedures for the collection of unpaid fines, while at the 
same time strengthening those procedures.  
 
S. Rep. 104-179, at 13-14 (1995), reprinted in 1996 U.S.C.C.A.N. 924, 926-27; 
see also United States v. Phillips, 303 F.3d 548, 551 (5th Cir. 2002).  The legislative 
history of the MVRA in the United States House of Representatives also states: 
 
[T]he [MVRA] is an important step forward in ensuring 
justice for the victims of crime and accountability for 
convicted criminals.  By requiring full financial restitution, 
the Act requires the offender to face the harm suffered by 
his victims and, to others harmed by his unlawful actions.  
Further, it strives to provide those who suffer the 
consequences of crime with some means of recouping the 
personal and financial losses resulting from crime. 
 
H.R. Rep. 104-16, at 4-5 (1995).    
 
The MVRA requires courts to order the defendant to make restitution to all 
victims in the full amount of each victim's losses “without consideration of the 
economic circumstances of the defendant.” 18 U.S.C. § 3664(f)(1)(A). Pursuant to 18 
U.S.C. § 3572, there is a preference for a defendant to “make such payment 
immediately.” Id. § 3572(d)(1) (emphasis added). Should the Court allow for other 
than immediate payment, it “shall be the shortest time in which full payment 
can reasonably be made.” Id. § 3572(d)(2). Moreover, under the Justice for All Act, a 
victim is entitled to “full and timely restitution as provided in law.” Id. § 3771 (a)(6) 
(emphasis added).  
 
 
Under 18 U.S.C. § 3664(n): “[i]f a person obligated to provide restitution, or 
pay a fine, receives substantial resources from any source, including inheritance, 
settlement, or other judgment, during a period of incarceration, such person shall be 
required to apply the value of such resources to any restitution or fine still owed.” 
 
Under 18 U.S.C.§ 3612(c), Congress directed the Attorney General to 
aggressively enforce restitution orders with the intent that the Department of Justice 
would commit resources necessary to ensure that the rights of victims are enforced.  
See id. § 3612(c); Phillips, 303 F.3d at 551. The Attorney General was instructed to 
promulgate guidelines that would ensure such enforcement of restitution orders is 
pursued “to the fullest extent of the law.”  See Pub. L. No. 104-132, § 209(2), 110 Stat. 
1214 (codified as a note under 18 U.S.C. § 3551).   
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The Attorney General's guidelines comply with this mandate, both directing 
that orders of restitution be enforced as a key element of the criminal judgment and 
requiring the United States Attorney's Offices to take all steps possible to ensure that 
restitution is collected and that victims of crime are fully compensated for their losses. 
The MVRA provides the Government authority to enforce victim restitution orders in 
the same manner that it recovers fines and by all other available means and, under 
18 U.S.C. § 3613(a), it may collect restitution in accordance with the practices and 
procedures for the enforcement of a civil judgment under Federal law or State law, 
including the Federal Debt Collection Procedures Act of 1990.  
 
In this case, the Defendant is scheduled to be incarcerated until May 21, 2027. 
His current (as of February 10, 2026) BOP Inmate Trust Account balance of $1,706.85  
is likely to be the most substantial sum of money that the Defendant will have to 
apply to his outstanding special assessment and restitution debts for many years.  
Accordingly, in compliance with the mandate to enforce restitution orders in the 
shortest period of time possible, the United States respectfully requests that the 
Court grant the turnover order. 
 
 
Based on the foregoing, the United States respectfully requests that the Court 
enter the proposed Turnover Order, so that money contained in the Defendant’s BOP 
Inmate Trust Account can be applied against the Defendant’s Special Assessment 
and Restitution obligations previously imposed by the Court. 
 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
TODD BLANCHE 
 
 
 
U.S. DEPUTY ATTORNEY GENERAL 
 
 
 
PHILIP LAMPARELLO 
 
 
 
SENIOR COUNSEL 
 
 
                                         By:    s/ Jordan M. Anger           
  
  
  
  
  
                      Jordan M. Anger  
 
  
  
  
  
  
           Assistant United States Attorney 
 
 
Enclosure 
 
 
 
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CERTIFICATE OF MAILING 
 
I hereby certify that on February 27, 2026, I electronically filed the foregoing with 
the Clerk of the Court using the ECF system, which will send notification of such 
filing to all counsel of record.  
 
In addition, I hereby certify that these documents were mailed, via Certified Mail, to 
the following non CM/ECF participant:  
 
Defendant: 
Daniel Dodoun 
Register Number: 86374-510 
Federal Correctional Institution-Fort Dix 
P.O, Box 2000 
Joint Base Middle, New Jersey 08640 
 
 
 
 
By: 
  s/ Jordan M. Anger 
  
 
 
 
 
 
 
 
JORDAN M. ANGER 
 
 
 
 
 
 
      
Assistant United States Attorney 
 
Case 3:25-cr-00215-RK     Document 50     Filed 02/27/26     Page 6 of 6 PageID: 403

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