Notice of Complaint for Forfeiture — United States v. Contents of Accounts (D.N.J., Dkt. 4)

Summary

Notice of Complaint for Forfeiture, filed May 8, 2024 as Document 4, Case 2:24-cv-05863-MEF-MAH, United States of America v. The Contents of the Following Accounts, District of New Jersey. The notice states that on May 6, 2024, the United States filed a civil complaint seeking forfeiture of the listed bank accounts and real property. It states that a verified claim must be filed no later than 35 days from the date of mailing of direct notice, or within 60 days from the first day of publication of notice if direct notice is not provided, and that an answer or a motion must follow within 21 days after filing the verified claim. It states that failure to follow the requirements may result in judgment by default. The signature block shows s/Peter A. Laserna, Assistant United States Attorney.

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Case 2:24-cv-05863-MEF-MAH Document 4 Filed 05/08/24 Page 1 of 4 PageID: 52




PHILIP R. SELLINGER
United States Attorney
By: PETER A. LASERNA
Assistant United States Attorney
970 Broad Street, Suite 700
Newark, New Jersey 07102
Tel: (973) 645-2700
Peter.Laserna@usdoj.gov

                      UNITED STATES DISTRICT COURT
                         DISTRICT OF NEW JERSEY


UNITED STATES OF AMERICA,               Hon. Michael E. Farbiarz, U.S.D.J.

                Plaintiff,              Civil Action No. 24-5863

           v.
                                        NOTICE OF COMPLAINT
THE CONTENTS OF THE                     FOR FORFEITURE
FOLLOWING ACCOUNTS:
                                        Electronically Filed
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;
Case 2:24-cv-05863-MEF-MAH Document 4 Filed 05/08/24 Page 2 of 4 PageID: 53




 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.



TO:   ALL PERSONS WITH A POTENTIAL INTEREST IN THE ABOVE-
      CAPTIONED PROPERTY

      1.    FORFEITURE COMPLAINT: On May 6, 2024, the United States of

America filed a civil complaint seeking forfeiture, pursuant to 18 U.S.C. §§

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




                                        -2-
Case 2:24-cv-05863-MEF-MAH Document 4 Filed 05/08/24 Page 3 of 4 PageID: 54




of New Jersey, against the above-captioned property (collectively, the

“defendant property”).

      2.    FILING OF A VERIFIED CLAIM: Pursuant to Rule G(5)(a)(ii) of the

Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture

Actions of the Federal Rules of Civil Procedure, in order to avoid forfeiture of

the defendant property, any person who asserts an interest in the defendant

property must file a verified claim:

            •      If notice was mailed: No later than 35 days from the
                   date of mailing of direct notice.

            •      If notice was personally served: No later than 35 days
                   from the date of delivery.

            •      Within the time period that the Court allows, provided
                   that any request for an extension of time from the
                   Court is made prior to the expiration of the time within
                   which the person is required to file such verified claim.

            •      If direct notice is not provided: Within 60 days from
                   the first day of publication of notice on the government
                   internet site www.forfeiture.gov.

      3.    CONTENTS OF VERIFIED CLAIM: Pursuant to Supplemental Rule

G(5)(a), the claim must (A) identify the specific property claimed; (B) identify the

claimant and state the claimant’s interest in the property; (C) be signed by the

claimant under penalty of perjury (see 28 U.S.C. § 1746); and (D) be served on

the government attorney designated below.

      4.    FILING OF AN ANSWER: If you filed a verified claim, you must

then file an answer to the complaint or a motion under Rule 12 of the Federal

Rules of Civil Procedure within 21 days after filing the verified claim.


                                        -3-
Case 2:24-cv-05863-MEF-MAH Document 4 Filed 05/08/24 Page 4 of 4 PageID: 55




      5.    FILING WITH THE COURT AND SERVICE ON THE UNITED

STATES: The verified claim and answer must be filed:

            •     On the District of New Jersey’s Case Management
                  Electronic Filing System (CM/ECF), or

            •     With the Office of the Clerk, United States District
                  Court for the District of New Jersey, Martin Luther
                  King Building and U.S. Courthouse, 50 Walnut Street,
                  Room 4015, Newark, New Jersey 07102.

      In addition, a copy of the claim and answer or motion must be sent to

Assistant United States Attorney Peter A. Laserna, United States Attorney’s

Office, District of New Jersey, 970 Broad Street, 7th Floor, Newark, New Jersey

07102.

      Failure to follow the requirements set forth above may result in

judgment by default taken against you, the forfeiture of the defendant

property to the United States of America, and other relief demanded in

the Complaint.

      DATED this 8th day of May, 2024.

                                            PHILIP R. SELLINGER
                                            United States Attorney

                                            s/Peter A. Laserna
                                            By: PETER A. LASERNA
                                            Assistant United States Attorney




                                      -4-


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