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Letter to Judge Farbiarz, Request to Adjourn the Motion for One Cycle (D.N.J., Dkt. 14)

Summary

A letter dated October 7, 2024, filed the same day as Document 14 in the civil forfeiture action United States v. contents of listed accounts, Case 2:24-cv-05863-MEF-MAH, in the U.S. District Court for the District of New Jersey. Attorney Joseph R. Donahue writes to Judge Farbiarz on behalf of Hee Ah Nam, the Claimant and Petitioner, and asks to adjourn the Government's Motion to Dismiss, returnable October 21, 2024, for one cycle and to extend the deadline for filing opposition papers, which the letter says are due that day. The letter states that this is the first time the motion has been listed and that counsel understands the Assistant United States Attorney has no objection. It adds that counsel would like to discuss a resolution of the matter. It is signed /s/ Joseph R. Donahue.

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“Letter to Judge Farbiarz, Request to Adjourn the Motion for One Cycle (D.N.J., Dkt. 14).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-n-j-no-2-24-cv-05863-dkt-14-d-n-j-e35bd1a7fc/, SHA-256 557c512e87a40f300a6c178985cc6ac4526cdd056709ef008c58149daa63e8b9.

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Case 2:24-cv-05863-MEF-MAH Document14_ Filed 10/07/24 Page1of1PagelD: 157

JOSEPH R. DONAHUE, LLC

ATTORNEYS
JOSEPH R. DONAHUE* 135 PROSPECT STREET
JDONAHUE@DONAHUENJLAW.COM RIDGEWOOD, NEW JERSEY 07450
MOBILE: (201) 602-4692 TELEPHONE: (201) 488-7707

FACSIMILE: (201) 488-9559

OF COUNSEL
WWW.DONAHUENJLAW.COM

SANDRA COIRA
LUCIA V. DONAHUE

“CERTIFIED CRIMINAL TRIAL LAWYER — NJ

October 7, 2024

Via ECF Filing

Hon. Michael E. Farbiarz, USDJ

M.L.K Federal Bldg. & U.S. Courthouse
50 Walnut Street

Newark, New Jersey 07101

Re: US v. Contents of JP Morgan Chase Acct. Ending in 9483, et al.
Civil Action No. 2:24-5863-MEH-MAH

Dear Judge Farbiarz:

I represent Hee Ah Nam, the Claimant and Petitioner relevant to the
above-referend matter. The Government has filed a Motion to Dismiss
returnable October 21, 2024 before Your Honor. My opposition papers are due
today. Please accept this letter as a request to adjourn the motion for one cycle
and to extend the deadline for the filing of our opposition. This is the first time
this motion has been listed. I have had several conversations with AUSA
Laserna regarding this matter and it is my understanding that he has no
objection to my request. I would like to take the opportunity to further discuss a
resolution of this matter and believe that additional time would be helpful.

Respectfully submitted,
/s/ Joseph R. Donahue

Joseph R. Donahue

cc: Peter A. Laserna, AUSA (via ECF filing)


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