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Letter to Judge Farbiarz, Request to Adjourn the Motion for One Additional Cycle (D.N.J., Dkt. 19)

Summary

A letter dated October 17, 2024 from Joseph R. Donahue to Hon. Michael E. Farbiarz, filed October 18, 2024 as Document 19 in Case 2:24-cv-05863-MEF-MAH, a civil forfeiture action in the U.S. District Court for the District of New Jersey. Writing for Hee Ah Nam, the Claimant and Petitioner, the letter asks to adjourn the Government's Motion to Dismiss, returnable November 4, 2024, for one additional cycle and to extend the opposition deadline of October 21, 2024. It states that the Assistant United States Attorney has no objection, that the parties are engaged in productive settlement discussions expected to finish within the next 30 days, and that Judge Hammer granted a joint request to postpone discovery deadlines for 30 days.

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“Letter to Judge Farbiarz, Request to Adjourn the Motion for One Additional Cycle (D.N.J., Dkt. 19).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-n-j-no-2-24-cv-05863-dkt-19-d-n-j-821ad00961/, SHA-256 fc50684ee3b16b3349e0de1f09523b8c65fb8c320d358aebe744805845df0783.

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Case 2:24-cv-05863-MEF-MAH Document19_ Filed 10/18/24 Page 1 of 1 PagelD: 167

JOSEPH R. DONAHUE, LLC

ATTORNEYS

JOSEPH R. DONAHUE*
JDONAHUE@DONAHUENJLAW.COM
MOBILE: (201) 602-4692

135 PROSPECT STREET
RIDGEWOOD, NEW JERSEY 07450
TELEPHONE: (201) 488-7707
OF COUNSEL FACSIMILE: (201) 488-9559
SANDRA COIRA WWW.DONAHUENJLAW.COM

LuciA V. DONAHUE

* CERTIFIED CRIMINAL TRIAL LAWYER — NJ

October 17, 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-referenced
matter. The Government has filed a Motion to Dismiss returnable November 4, 2024 before
Your Honor. My opposition papers are due on October 21, 2024. Please accept this letter as a
request to adjourn the motion for one additional cycle and to extend the deadline for the filing of
our opposition. AUSA Laserna has no objection to this request. I have asked for one previous
adjournment.

The parties are engaged in productive settlement discussions to fully resolve this civil
forfeiture action and anticipate that the settlement discussions can be completed within the next
30 days. For this reason, earlier this week the parties put in a joint request to postpone the
current discovery deadlines for 30 days that was granted by Judge Hammer. It is submitted that
postponing the Government’s pending motion for one additional cycle will conserve judicial
resources, in the event that this matter can be resolved by settlement.

Respectfully submitted,
Joseph R. Donahue
Joseph R. Donahue

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

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