Stipulation, JP Morgan Chase Account Ending in 9483, Bank of America Ending in 4685 (D.N.J., Dkt. 30-2)
Summary
A Stipulation between the United States and claimant Hee Ah Nam, filed January 10, 2025 as Document 30-2 in Civil Action No. 24-5863 (Case 2:24-cv-05863-MEF-MAH), in the U.S. District Court for the District of New Jersey. It recites that the United States filed a Verified Complaint for Forfeiture In Rem on May 6, 2024, and that the Claimant filed a Claim and Petition (ECF Nos. 7 and 8) and an Answer (ECF Nos. 9 and 10). Of approximately $210,517.24 seized from a TD Bank account, $110,000.00 is to be returned to the Claimant and $100,517.24 treated as a substitute res and forfeited to the United States. The Claimant withdraws the claim and answer as to the Cresskill real property and the other listed accounts, waives defenses including "innocent owner", and agrees not to contest the forfeiture.
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“Stipulation, JP Morgan Chase Account Ending in 9483, Bank of America Ending in 4685 (D.N.J., Dkt. 30-2).”
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Case 2:24-cv-05863-MEF-MAH Document 30-2 Filed 01/10/25 Page 1 of 10 PageID:
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UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA
Hon. Michael E. Farbiarz
v.
Civil Action No. 24-5863
THE CONTENTS OF THE
FOLLOWING ACCOUNTS: STIPULATION
JP MORGAN CHASE ACCOUNT
ENDING IN 9483 IN THE NAME
OF JAE CHOI ATTORNEY TRUST
ACCOUNT;
BANK OF AMERICA ACCOUNT
ENDING IN 4685 IN THE NAME
OF SMART LEARNING, INC.;
JP MORGAN CHASE ACCOUNT
ENDING IN 0711 IN THE NAME
OF HEE AH NAM;
TD BANK ACCOUNT ENDING IN
2483 IN THE NAME OF HEE AH
NAM;
TD BANK ACCOUNT ENDING IN
1237 IN THE NAME OF HEE AH
NAM;
BANK OF AMERICA ACCOUNT
ENDING IN 6030 IN THE NAME
OF HEE AH NAM;
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BANK OF AMERICA ACCOUNT
ENDING IN 6043 IN THE NAME
OF HEE AH NAM;
JP MORGAN CHASE ACCOUNT
ENDING IN 9900 IN THE NAME
OF HUDSON ASSET HOLDING
CORP;
JP MORGAN CHASE ACCOUNT
ENDING IN 4413 IN THE NAME
OF HUDSON ASSET HOLDING
CORP;
JP MORGAN CHASE ACCOUNT
ENDING IN 0353 IN THE NAME
OF VIRTUA EDUCATION, INC.;
JP MORGAN CHASE ACCOUNT
ENDING IN 4827 IN THE NAME
OF VIRTUA EDUCATION, INC.;
AND
TD AMERITRADE ACCOUNT
ENDING IN 2857 IN THE NAME
OF HEE AH NAM; AND
THE REAL PROPERTY LOCATED
AT 125 13TH STREET,
CRESSKILL, NEW JERSEY,
Defendants in rem.
- - - - - - - - - - - - - - - - - - - - - - -x
Plaintiff, the United States of America (the “United States”), by and through
its undersigned attorney, Vikas Khanna, Acting United States Attorney for the
District of New Jersey (Assistant United States Attorney Peter A. Laserna,
appearing), and claimant Hee Ah Nam (the “Claimant”), individually and through
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her undersigned attorney (the United States and Claimant collectively referred
to as the “Parties”), hereby stipulate and agree as follows:
1. The Parties agree that the Court has jurisdiction over the Parties,
the defendants in rem, and the subject matter of this Stipulation.
2. On May 6, 2024, the United States filed a Verified Complaint for
Forfeiture In Rem (the “Complaint”), seeking civil forfeiture of the above-
captioned 13 defendants in rem (collectively, the “Defendant Properties”). See
Complaint, ECF No. 1.
3. On or about July 24, 2024, and on or about July 25, 2024, Claimant
filed a Claim and Petition of Hee Ah Nam, in accordance with Rule G of Rule
G(5)(a) of the Supplemental Rules for Admiralty or Maritime Claims and Asset
Forfeiture Actions. See ECF Nos. 7 and 8; see also 07/25/2024 Clerk’s Quality
Control Message (rejecting Claimant’s July 24 filing because Claimant
improperly signed the pleading electronically). The July 24 and July 25 filings
are hereinafter collectively referred to as the “Verified Claim.”
4. In the Verified Claim, Claimant asserted an interest in the following
Defendant Properties:
a. The Real Property Located at 125 13th Street, Cresskill, New
Jersey (the “Cresskill Property”);
b. The contents of an account at TD Bank ending in 2483 in the
name of Hee Ah Nam;
c. The contents of an account at TD Bank ending in 1237 in the
name of Hee Ah Nam (“Hee Ah Nam TD Acct 1237”);
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d. The contents of an account at Bank of America ending in 6030
in the name of Hee Ah Nam;
e. The contents of an account at Bank of America ending in 6043
in the name of Hee Ah Nam;
f. The contents of an account at JP Morgan Chase ending in 9900
in the name of Hudson Asset Holding Corp;
g. The contents of an account at JP Morgan Chase ending in 4413
in the name of Hudson Asset Holding Corp; and
h. The contents of an account at TD Ameritrade ending in 2857 in
the name of Hee Ah Nam.
5. On or about August 14, 2024, and August 15, 2024, Claimant filed
an Answer and Defenses of Claimant Hee Ah Nam, in accordance with Rule G of
Rule G(5)(b) of the Supplemental Rules for Admiralty or Maritime Claims and
Asset Forfeiture Actions. See ECF Nos. 9 and 10; see also 08/15/2024 Clerk’s
Quality Control Message (rejecting Claimant’s August 14 filing because Claimant
improperly signed the pleading electronically). The August 14 and August 15
filings are hereinafter collectively referred to as the “Answer.”
6. Claimant has not filed any other claims or responsive pleadings in
the above-captioned civil forfeiture action, either in her individual capacity or in
a representative capacity for another individual or entity.
7. The Parties are not aware of any other potential claimants in the
above-captioned civil forfeiture action, and the statutory time period for a
potential claimant to file a claim has expired.
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8. The Parties agree to resolve the above-captioned civil judicial
forfeiture action consistent with the sound policy favoring settlement of legal
disputes without resort to unnecessary litigation.
9. In her Verified Claim, Claimant purported to be an owner of Hudson
Asset Holding Corp. and, in her capacity of owner of Hudson Asset Holding Corp.,
Claimant asserted an interest in the Hudson JPMC Acct 9900, Hudson JPMC
Acct 4413, and the Cresskill Property.
10. The Parties agree that Claimant is the only living potential owner,
corporate officer or shareholder of Hudson Asset Holding Corp.
11. Claimant agrees to sign this stipulation in her individual capacity
and in her capacity as president and sole living shareholder of Hudson Asset
Holding Corp.
12. As set forth in the Complaint, approximately $210,517.24 was seized
from Hee Ah Nam TD Acct 1237. See Complaint, ¶ 75 and p. 38, Table III.
13. The Parties agree that $110,000.00 (one hundred and ten thousand
dollars and no cents) of the funds seized from defendant in rem Hee Ah Nam TD
Acct 1237 shall be returned to Claimant as soon as practical and the remaining
$100,517.24 of the funds seized from defendant in rem Hee Ah Nam TD Acct
1237 shall be treated as a substitute res in this civil forfeiture action and forfeited
to the United States.
14. Claimant understands that the Debt Collection Improvement Act of
1996, 31 U.S.C. § 3716, requires the United States Department of the Treasury
and other disbursing officials to offset Federal payments to collect delinquent
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non-tax debts owed to the United States, or delinquent debts owed to states,
including past-due child support enforced by states. The release of funds set
forth in this Stipulation is expressly conditioned on the Claimant’s provision of
her Social Security Number, Taxpayer Identification Number, and any other
information required to determine if an offset is necessary. (If the Claimant
believes that the funds released under this Stipulation may be subject to an
offset, Claimant may contact the Department of the Treasury at 1-800-304-
3107). If an offset is made, the Claimant will receive a notification from the
Department of the Treasury at the last address provided by the debtor to the
creditor.
15. Claimant hereby withdraws her Verified Claim (ECF Nos. 7 and 8)
and Answer (ECF Nos. 9 and 10) as to the following Defendant Properties:
a. The Cresskill Property (the full legal description for which real
property is set forth in Exhibit 1 to this Stipulation);
b. The contents of an account at TD Bank ending in 2483 in the
name of Hee Ah Nam;
c. Approximately $100,517.24 seized from an account at TD Bank
ending in 1237 in the name of Hee Ah Nam;
d. The contents of an account at Bank of America ending in 6030
in the name of Hee Ah Nam;
e. The contents of an account at Bank of America ending in 6043
in the name of Hee Ah Nam;
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f. The contents of an account at JP Morgan Chase ending in 9900
in the name of Hudson Asset Holding Corp.;
g. The contents of an account at JP Morgan Chase ending in 4413
in the name of Hudson Asset Holding Corp; and
h. The contents of an account at TD Ameritrade ending in 2857 in
the name of Hee Ah Nam.
(hereinafter collectively referred to as the “Released Properties”).
16. Other than to enforce her rights under this Stipulation, the Claimant
waives any legal or equitable claim she may have to any of the Released
Properties, and will not assert any claim in the proceedings to forfeit these assets
or take any legal or other action to attempt to assert any interest in the Released
Properties, or otherwise prevent the transfer of title of the Released Properties to
the United States Government.
17. Other than to enforce her rights under this Stipulation, Claimant
waives notice of all forfeiture proceedings with respect to the Released
Properties and waives any and all defenses to such proceedings that may be
asserted, including, but not limited to, “innocent owner” and constitutional
defenses, and agree that judgment may immediately be entered against the
Released Properties.
18. Claimant agrees that she will not object to the entry of the Final
Order of Forfeiture or file a petition in an ancillary proceeding as to the
Released Properties; file a claim, statement of interest or petition (including but
not limited to a petition for remission or mitigation); or otherwise contest the
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administrative or judicial forfeiture of the Released Properties in any
proceeding under the U.S. asset forfeiture laws, nor will she assist a third party
in doing so, including any relatives (by blood or marriage and of any degree) of
her deceased husband Jae Choi.
19. Claimant agrees to take all requested steps within Claimant’s ability
and control to surrender Claimant’s interest in the Released Properties to the
United States, including, but not limited to, surrendering title, signing a consent
decree of forfeiture, signing any other documents necessary to effectuate such
transfers, and consenting to any criminal forfeiture action that may be brought
against these assets pursuant to any civil forfeiture statute.
20. Claimant hereby waives any claim against the United States or its
agents and employees in connection with the United States’ seizure or restraint
of any of the Defendant Properties (including, but not limited to, the Released
Properties), including, but not limited to, any claim that the United States did
not have probable cause to restrain the Defendant Properties.
21. Claimant agrees to hold harmless the United States and any and all
of the United States’ agents and employees from any and all third-party claims
against the Defendant Properties in connection with this action, including but
not limited to any claim of ownership of those assets.
22. Claimant enters into this Stipulation upon her own free will and
agrees that she has not been coerced in any way into signing this Stipulation.
23. Claimant acknowledges that she has had a full and fair
opportunity to discuss this Stipulation with her counsel of record in this civil
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01/10/2025
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