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Letter to Judge Farbiarz, Response to Text Order (D.N.J., Dkt. 30, January 10, 2025)

Summary

A letter dated January 10, 2025 from the Government in United States of America v. The Contents of the Following Accounts, Civil Action No. 24-CV-5863 (MEF)(MAH), filed as Document 30 in the District of New Jersey. It responds to the Court's Text Order dated January 2, 2025 (ECF No. 29) and explains that settlement stipulations generally provide for being "so ordered". The parties, including counsel for Claimant Hee Ah Nam and for the Borough of Cresskill, agree the stipulations are enforceable without that step, and new stipulations are enclosed. The Government withdraws its request for endorsement of the previously filed stipulations (ECF Nos. 27 and 28) and says it will separately submit a proposed default judgment and final order of forfeiture. It is signed /s/ Peter A. Laserna, Assistant U.S. Attorney.

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“Letter to Judge Farbiarz, Response to Text Order (D.N.J., Dkt. 30, January 10, 2025).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-n-j-no-2-24-cv-05863-dkt-30-d-n-j-4a2cfe2a68/, SHA-256 fab94e561229a023382d4bba825f4d050b42695ada64cde10ecd0b162d089da5.

Full text

Case 2:24-cv-05863-MEF-MAH                  Document 30           Filed 01/10/25          Page 1 of 2 PageID: 195

                                                                U.S. Department of Justice

                                                                United States Attorney
                                                                District of New Jersey
  _____________________________________________________________________________________________________________________________

                                                                970 Broad Street, 7th floor                       973-645-2700
                                                                Newark, New Jersey 07102


                                                                January 10, 2025

  Hon. Michael E. Farbiarz
  United States District Judge
  District of New Jersey
  Frank R. Lautenberg Post Office & U.S. Courthouse
  2 Federal Square
  Newark, NJ 07101

          Re:      United States of America v. The Contents of the Following Accounts:
                   JP Morgan Chase Account Ending in 9483 in the Name of Jae Choi
                   Attorney Trust Account, et al.,
                   Civil Action No. 24-CV-5863 (MEF)(MAH)

  Dear Judge Farbiarz:

          The Government writes in response to Your Honor’s January 2, 2025, Text
  Order (ECF No. 29). When the Government reaches a settlement stipulation in a
  civil forfeiture action filed in this District, the settlement stipulation generally
  includes provisions that the settlement stipulation will be “so ordered” by the
  Court. 1 The intended purpose of such provisions is to clarify that the parties’
  recourse for an alleged breach of the settlement stipulation is to seek to have the
  Court enforce the terms stipulation, rather than to initiate a separate lawsuit for
  breach of contract.

         However, the undersigned Assistant U.S. Attorney has conferred with
  counsel for Claimant Hee Ah Nam and counsel for the Borough of Cresskill
  regarding the respective stipulations. The parties agree that the respective
  stipulations are enforceable even if they are not “so ordered” by the Court. In that
  regard, the parties’ have executed new stipulations, which are enclosed with this



  1 See, e.g., United States v. 0.346 Cubic Meters of Brazilian Rosewood (Dalbergia

  nigra), 22-CV-6997 (MEF), ECF No. 38, Stipulation and Order of Settlement,
  entered July 25, 2023; United States v. $142,250 in United States Currency, et al.,
  19-CV-09725 (JXN), ECF No. 23, Stipulation and Order of Settlement, entered
  September 13, 2022; United States Of America V. Two African Elephant (Loxodanta
  Africana) Ivory Tusks, 20-CV-14645 (CCC), ECF No. 27, Stipulation and Order of
  Settlement, entered April 4, 2022.
Case 2:24-cv-05863-MEF-MAH       Document 30      Filed 01/10/25   Page 2 of 2 PageID: 196




  letter. The stipulations do not contain any reference to being “so ordered” by the
  Court.

        The Government respectfully withdraws its request for the Court to endorse
  the previously-filed stipulations (see ECF Nos. 27 and 28). The Government will
  separately submit a proposed default judgment and final order of forfeiture for the
  Court’s review and endorsement. We thank the Court for its consideration of this
  matter.

                                                 Respectfully submitted,

                                                 VIKAS KHANNA
                                                 ACTING United States Attorney

                                                 /s/ Peter A. Laserna
                                         By:     Peter A. Laserna
                                                 Assistant U.S. Attorney

  Enclosures




                                           -2-

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