Declaration of Jaclyn N. Wyrwas Regarding Direct Notice (D.N.J., Dkt. 11)

Summary

Declaration of Jaclyn N. Wyrwas, filed August 19, 2024 as Document 11, Case 2:24-cv-05863-MEF-MAH, United States of America v. The Contents of the Following Accounts, et al., District of New Jersey. Wyrwas states being a senior law clerk in the Asset Recovery and Money Laundering Unit of the Office of the United States Attorney, and details efforts to send notice of the civil forfeiture action to potential claimants. It states that the Verified Complaint was filed May 6, 2024 (ECF Doc. 1). It states that on or about May 29, 2024, copies were sent by Federal Express to Virtua Education, Inc., Smart Learning Inc., and Hudson Asset Holding Corp., with a claim deadline of July 3, 2024, and on or about June 20, 2024, to Hee Ah Nam through counsel, with a deadline of July 25, 2024.

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“Declaration of Jaclyn N. Wyrwas Regarding Direct Notice (D.N.J., Dkt. 11).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-n-j-no-2-24-cv-05863-dkt-11-d-n-j-8aeda715a8/, SHA-256 44facdaf4a7abe4f3c3830c80cad68b98f05ef7468fc7789341955b1eda77806.

Full text

Case 2:24-cv-05863-MEF-MAH Document 11 Filed 08/19/24 Page 1 of 4 PageID: 106

2024V00579/PAL/jw

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA : Hon. Michael E. Farbiarz

Plaintiff, : Civil Case No. 24-5863

v. : DECLARATION OF JACLYN N.
WYRWAS REGARDING
THE CONTENTS OF THE : DIRECT NOTICE
FOLLOWING ACCOUNTS:
:
JP MORGAN CHASE ACCOUNT
ENDING IN 9483 IN THE NAME OF :
JAE CHOI ATTORNEY TRUST
ACCOUNT, et al. :

Defendants in rem. :

Jaclyn N. Wyrwas, pursuant to 28 U.S.C. § 1746, declares under penalty

of perjury as follows:

1. I am a senior law clerk in the Asset Recovery and Money

Laundering Unit, a contract employee, in the Office of the United States

Attorney for the District of New Jersey.

2. I make this Declaration in order to detail the United States of

America’s efforts to send notice of the above-captioned civil forfeiture action to

potential claimants, in accordance with Rule G(4)(b) of the Supplemental Rules

for Admiralty or Maritime Claims and Asset Forfeiture Actions.

3. On or about May 6, 2024, the United States of America filed a

Verified Complaint for Forfeiture in Rem (ECF Doc. 1, hereinafter referred to as

the “Verified Complaint”) seeking forfeiture, pursuant to 18 U.S.C. §§
Case 2:24-cv-05863-MEF-MAH Document 11 Filed 08/19/24 Page 2 of 4 PageID: 107

981(a)(1)(C) and 981(a)(1)(A), in the United States District Court for the District

of New Jersey, against the following property:

a. The contents of an account at JP Morgan Chase ending in
9483 in the name of Jae Choi Attorney Trust Account;

b. The contents of an account at Bank of America ending in
4685 in the name of Smart Learning, Inc.;

c. The contents of an account at JP Morgan Chase ending in
0711 in the name of Hee Ah Nam;

d. The contents of an account at TD Bank ending in 2483 in
the name of Hee Ah Nam;

e. The contents of an account at TD Bank ending in 1237 in
the name of Hee Ah Nam;

f. The contents of an account at Bank of America ending in
6030 in the name of Hee Ah Nam;

g. The contents of an account at Bank of America ending in
6043 in the name of Hee Ah Nam;

h. The contents of an account at JP Morgan Chase ending in
9900 in the name of Hudson Asset Holding Corp;

i. The contents of an account at JP Morgan Chase ending in
4413 in the name of Hudson Asset Holding Corp;

j. The contents of an account at JP Morgan Chase ending in 0353 in
the name of Virtua Education, Inc.;

k. The contents of an account at JP Morgan Chase ending in
4827 in the name of Virtua Education, Inc.;

l. The contents of an account at TD Ameritrade ending in
2857 in the name of Hee Ah Nam; and

m. The real property located at 125 13th Street, Cresskill,
New Jersey

(collectively, the “defendant property”).

-2-
Case 2:24-cv-05863-MEF-MAH Document 11 Filed 08/19/24 Page 3 of 4 PageID: 108

4. On May 8, 2024, the United States filed a Notice of Complaint for

Forfeiture with regard to the defendant property. (ECF Doc. 4). The Notice of

Complaint for Forfeiture explained the procedures for filing a claim to assert an

interest in the defendant property.

5. According to the records and files of the United States Attorney’s

Office, on or about May 29, 2024, copies of the Notice of Complaint for

Forfeiture and the Verified Complaint were sent by Federal Express to Virtua

Education, Inc., c/o Legalinc Corporate Services Inc., 131 Continental Drive,

Suite 305, Newark, Delaware 19713. The cover letter, dated May 29, 2024,

stated that a claim asserting an interest in the defendant property had to be

filed no later than July 3, 2024, i.e., 35 days after the date of the cover letter.

Copies of the notice letter and proof of delivery are attached hereto as Exhibit

6. According to the records and files of the United States Attorney’s

Office, on or about May 29, 2024, copies of the Notice of Complaint for

Forfeiture and the Verified Complaint were sent by Federal Express to Smart

Learning Inc., c/o Legalinc Corporate Services Inc., 131 Continental Drive,

Suite 305, Newark, Delaware 19713. The cover letter, dated May 29, 2024,

stated that a claim asserting an interest in the defendant property had to be

filed no later than July 3, 2024, i.e., 35 days after the date of the cover letter.

Copies of the notice letter and proof of delivery are attached hereto as Exhibit

-3-
Case 2:24-cv-05863-MEF-MAH Document 11 Filed 08/19/24 Page 4 of 4 PageID: 109

7. According to the records and files of the United States Attorney’s

Office, on or about May 29, 2024, copies of the Notice of Complaint for

Forfeiture and the Verified Complaint were sent by Federal Express to Hudson

Asset Holding Corp., c/o Legalinc Corporate Services Inc., 301 Route 17 North,

Suite 800, #12-40, Rutherford, New Jersey 07070. The cover letter, dated May

29, 2024, stated that a claim asserting an interest in the defendant property

had to be filed no later than July 3, 2024, i.e., 35 days after the date of the

cover letter. Copies of the notice letter and proof of delivery are attached hereto

as Exhibit C.

8. According to the records and files of the United States Attorney’s

Office, on or about June 20, 2024, copies of the Notice of Complaint for

Forfeiture and the Verified Complaint were sent by Federal Express and

electronic mail to Hee Ah Nam a/k/a Iris Choi, c/o Joseph R. Donahue, Esq.,

Joseph R. Donahue, LLC, 135 Prospect Street, Ridgewood, New Jersey 07450,

jdonahue@donahuenjlaw.com. The cover letter stated that a claim asserting an

interest in the defendant property had to be filed no later than 35 days of the

date of the cover letter (i.e., July 25, 2024). Copies of the notice letter, the

email to counsel and proof of Federal Express delivery are attached hereto as

Exhibit D.

I declare under penalty of perjury that the foregoing is true and correct.

Dated: August 19, 2024

Jaclyn N. Wyrwas

-4-

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