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Declaration of Publication — United States v. The Contents of the Following Accounts (D.N.J., Dkt. 6)

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A Declaration of Publication filed July 23, 2024 as Document 6 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. Assistant United States Attorney Peter A. Laserna declares under 28 U.S.C. § 1746 that attached are a Notice of Forfeiture Action (Attachment 1) and an Advertisement Certification Report (Attachment 2) indicating the notice was posted on an official government internet site for at least thirty (30) consecutive days, beginning on May 25, 2024 and ending on June 23, 2024,. The notice tells any person claiming an interest to file a verified Claim within 60 days from first publication and an Answer within 21 days thereafter. It is signed s/Peter A. Laserna and dated July 23, 2024.

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“Declaration of Publication — United States v. The Contents of the Following Accounts (D.N.J., Dkt. 6).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-n-j-no-2-24-cv-05863-dkt-6-d-n-j-b7d25383f7/, SHA-256 3164af3516159df4ef4e0903eb7b71053675283ab0044f7535ced04d3fcfa0e8.

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Case 2:24-cv-05863-MEF-MAH Document 6 Filed 07/23/24 Page 1 of 7 PageID: 57




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

                  v.                   :      Civil Action No. 24-5863

THE CONTENTS OF THE                    :      DECLARATION OF PUBLICATION
FOLLOWING ACCOUNTS:
                                       :
JP MORGAN CHASE ACCOUNT
ENDING IN 9483 IN THE NAME OF          :
JAE CHOI ATTORNEY TRUST
ACCOUNT, et al.                        :

            Defendants in rem.

      I, PETER A. LASERNA, pursuant to Title 28, United States Code, Section

1746, hereby declare under the penalty of perjury:

      That I am an Assistant United States Attorney in the Office of the United

States Attorney for the District of New Jersey, and

      That attached to this Declaration are the following:

      (1)   A true and correct copy of the Notice of Forfeiture Action against

the Defendants in rem (Attachment 1), and

      (2)   An Advertisement Certification Report generated by the

Consolidated Asset Tracking System maintained by the Department of Justice,

which indicates that the aforementioned Notice was posted on an official
Case 2:24-cv-05863-MEF-MAH Document 6 Filed 07/23/24 Page 2 of 7 PageID: 58




government internet site (www.forfeiture.gov) for at least thirty (30) consecutive

days, beginning on May 25, 2024, and ending on June 23, 2024, as required

by Rule G(4)(a)(iv)(C) of the Supplemental Rules for Admiralty or Maritime

Claims and Asset Forfeiture Actions (Attachment 2).

Dated: July 23, 2024
       Newark, New Jersey


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




                                        -2-
Case 2:24-cv-05863-MEF-MAH Document 6 Filed 07/23/24 Page 3 of 7 PageID: 59




                                   ATTACHMENT 1
Case 2:24-cv-05863-MEF-MAH Document 6 Filed 07/23/24 Page 4 of 7 PageID: 60

Attachment 1

                    IN THE UNITED STATES DISTRICT COURT
                       FOR THE DISTRICT OF NEW JERSEY
         COURT CASE NUMBER: 24-CV-5863; NOTICE OF FORFEITURE ACTION

      Pursuant to 18 U.S.C. § 981, the United States filed a verified Complaint for Forfeiture
against the following property:

      The contents of an account at Bank of America ending in 6043 ($530,014.20) in the
      name of Hee Ah Nam (20-IRS-000300), which was seized from Hee Ah Nam on
      September 3, 2020

      The contents of an account at Bank of America ending in 6030 ($16,980.18) in the
      name of Hee Ah Nam (20-IRS-000301), which was seized from Hee Ah Nam on
      September 3, 2020

      The contents of an account at Bank of America ending in 4685 ($32.06) in the name
      of Smart Learning, Inc. (20-IRS-000302), which was seized from Smart Learning
      Inc. DBA Homeschool Buyers on September 3, 2020

      The contents of an account at JP Morgan Chase ending in 9483 ($1,369,748.16) in
      the name of Jae Choi Attorney Trust Account (20-IRS-000303), which was seized
      from Jae Choi on September 3, 2020

      The contents of an account at JP Morgan Chase ending in 4827 ($300,036.39) in
      the name of Virtua Education, Inc. (20-IRS-000304), which was seized from Virtua
      Education, Inc. on September 3, 2020

      The contents of an account at JP Morgan Chase ending in 0353 ($157,917.19) in
      the name of Virtua Education, Inc. (20-IRS-000305), which was seized from Virtua
      Education, Inc. on September 3, 2020

      The contents of an account at JP Morgan Chase ending in 0711 ($201,870.82) in
      the name of Hee Ah Nam (20-IRS-000306), which was seized from Hee Ah Nam on
      September 3, 2020

      The contents of an account at JP Morgan Chase ending in 9900 ($6,491.84) in the
      name of Hudson Asset Holding Corp (20-IRS-000307), which was seized from
      Hudson Asset Holding Corp. on September 3, 2020

      The contents of an account at JP Morgan Chase ending in 4413 ($980,052.09) in
      the name of Hudson Asset Holding Corp (20-IRS-000308), which was seized from
      Hudson Asset Holding Corp. on September 3, 2020

      The contents of an account at TD Ameritrade ending in 2857 in the name of Hee Ah
      Nam (20-IRS-000309)
Case 2:24-cv-05863-MEF-MAH Document 6 Filed 07/23/24 Page 5 of 7 PageID: 61

       The contents of an account at TD Bank ending in 2483 ($662.44) in the name of
       Hee Ah Nam (20-IRS-000310), which was seized from Hee Ah Nam on September
       3, 2020

       The contents of an account at TD Bank ending in 1237 ($210,517.24) in the name
       of Hee Ah Nam (20-IRS-000311), which was seized from Hee Ah Nam on
       September 3, 2020

       The Real property located at 125 13th Street, Cresskill, New Jersey
       (24-IRS-000296)

Any person claiming a legal interest in the Defendant Property must file a verified Claim
with the court within 60 days from the first day of publication (May 25, 2024) of this Notice
on this official government internet web site and an Answer to the complaint or motion
under Rule 12 of the Federal Rules of Civil Procedure within 21 days thereafter. 18
U.S.C. § 983(h)(1) permits a court to impose a civil fine on anyone asserting an interest in
property which the court determines was frivolous.

The verified Claim and Answer must be filed with the Clerk of the Court, Martin Luther
King Federal Building & U.S. Courthouse, 50 Walnut Street, Room 4105, Newark, NJ
07101-0419, and copies of each served upon Assistant United States Attorney Peter
Laserna, 970 Broad Street,, Suite 700, Newark, NJ 07102, or default and forfeiture will be
ordered. See, 18 U.S.C. § 983(a)(4)(A) and Rule G(5) of the Supplemental Rules for
Admiralty or Maritime Claims and Asset Forfeiture Actions.

The government may also consider granting petitions for remission or mitigation, which
pardon all or part of the property from the forfeiture. A petition must include a description
of your interest in the property supported by documentation; include any facts you believe
justify the return of the property; and be signed under oath, subject to the penalty of
perjury, or meet the requirements of an unsworn statement under penalty of perjury. See
28 U.S.C. Section 1746. For the regulations pertaining to remission or mitigation of the
forfeiture, see 28 C.F.R. Sections 9.1 - 9.9. The criteria for remission of the forfeiture are
found at 28 C.F.R. Section 9.5(a). The criteria for mitigation of the forfeiture are found at
28 C.F.R. Section 9.5(b). The petition need not be made in any particular form and may
be filed online or in writing. You should file a petition not later than 11:59 PM EST 30 days
after the date of final publication of this notice. See 28 C.F.R. Section 9.3(a). The
https://www.forfeiture.gov/FilingPetition.htm website provides access to a standard petition
form that may be mailed and the link to file a petition online. If you cannot find the desired
assets online, you must file your petition in writing by sending it to Assistant United States
Attorney Peter Laserna, 970 Broad Street,, Suite 700, Newark, NJ 07102. This website
provides answers to frequently asked questions (FAQs) about filing a petition. You may
file both a verified claim with the court and a petition for remission or mitigation.
Case 2:24-cv-05863-MEF-MAH Document 6 Filed 07/23/24 Page 6 of 7 PageID: 62




                                   ATTACHMENT 2
Case 2:24-cv-05863-MEF-MAH Document 6 Filed 07/23/24 Page 7 of 7 PageID: 63


                                 Advertisement Certification Report


The Notice of Publication was available on the www.forfeiture.gov web site for at least 18 hours per day
between May 25, 2024 and June 23, 2024. Below is a summary report that identifies the uptime for each
day within the publication period and reports the results of the web monitoring system’s daily check that
verifies that the advertisement was available each day.

U.S. v. Contents of Account at Bank of America Ending 6043

Court Case No:              24-CV-5863
For Asset ID(s):            See Attached Advertisement Copy

   Consecutive          Date Advertisement         Total Hours Web Site             Verification that
   Calendar Day          Appeared on the           was Available during              Advertisement
       Count                 Web Site                  Calendar Day                existed on Web Site
         1                   05/25/2024                      23.9                          Verified
         2                   05/26/2024                      24.0                          Verified
         3                   05/27/2024                      24.0                          Verified
         4                   05/28/2024                      23.9                          Verified
         5                   05/29/2024                      24.0                          Verified
         6                   05/30/2024                      23.9                          Verified
         7                   05/31/2024                      24.0                          Verified
         8                   06/01/2024                      24.0                          Verified
         9                   06/02/2024                      23.9                          Verified
        10                   06/03/2024                      23.9                          Verified
        11                   06/04/2024                      24.0                          Verified
        12                   06/05/2024                      24.0                          Verified
        13                   06/06/2024                      23.9                          Verified
        14                   06/07/2024                      24.0                          Verified
        15                   06/08/2024                      23.9                          Verified
        16                   06/09/2024                      23.9                          Verified
        17                   06/10/2024                      23.9                          Verified
        18                   06/11/2024                      23.8                          Verified
        19                   06/12/2024                      24.0                          Verified
        20                   06/13/2024                      23.9                          Verified
        21                   06/14/2024                      23.9                          Verified
        22                   06/15/2024                      23.9                          Verified
        23                   06/16/2024                      23.9                          Verified
        24                   06/17/2024                      23.9                          Verified
        25                   06/18/2024                      23.9                          Verified
        26                   06/19/2024                      23.9                          Verified
        27                   06/20/2024                      23.9                          Verified
        28                   06/21/2024                      23.9                          Verified
        29                   06/22/2024                      23.9                          Verified
        30                   06/23/2024                      23.9                          Verified
Additional log information is available and kept in the archives for 15 years after the asset has been disposed.


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