Claim and Petition of Hee Ah Nam — United States v. The Contents of the Following Accounts (D.N.J., Dkt. 8)

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Document 8 in Civil Action No. 24-5863 (Case 2:24-cv-05863-MEF-MAH), United States of America v. The Contents of the Following Accounts, in the U.S. District Court for the District of New Jersey, filed July 25, 2024. It is a Claim and Petition of Hee Ah Nam, presented by the Law Offices of Joseph R. Donahue as attorneys for Hee Ah Nam. The petition claims a lot of land with its buildings in Cresskill, New Jersey, together with accounts at TD Bank, Bank of America, JP Morgan Chase and TD Ameritrade in the name of Hee Ah Nam or Hudson Asset Holding Corp. It states that Hee Ah Nam is an owner of Hudson Asset Holding Company, the record title owner of that property, and seeks a declaration concerning the criminal conviction of Jae H. Choi. The page carries the date July 22, 2024.

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Case 2:24-cv-05863-MEF-MAH Document 8 Filed 07/25/24 Page 1 of 2 PagelD: 66

Joseph R. Donahue, Esq.

Law Offices of Joseph R. Donahue
135 Prospect Street

Ridgewood, New Jersey 07450
(201) 488-7707

Attorneys for Hee Ah Nam

UNITED STATES OF AMERICA, : UNITED STATES DISTRICT COURT
: DISTRICT OF NEW JERSEY

THE CONTENTS OF THE FOLLOWING Civil Action No.: 24-5863

ACCOUNTS:

JP MORGAN CHASE ACCOUNT :’ CLAIM AND PETITION OF

ENDING IN 9483 IN THE NAME OF JAE HEE AH NAM

CHOI ATTORNEY TRUST ACCOUNT, ET :

AL.

Defendants in rem.

Hee Ah Nam, of 125 13" Street, Cresskill, New Jersey 07626, hereby files a
petition/claim pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure, Rule G
of the Federal Rules of Civil Procedure and Title 21 U.S.C. Section 853(n) for the
property listed below.

Ms. Nam asserts her interest in the following real property and bank accounts:

1. All that lot or parcel of land, together with its buildings, appurtenances,

improvements, fixtures, attachments and easements, located at 125 13"
Street, Cresskill, New Jersey 07626.

2. TD Bank Account ending in 2483 in the name of Hee Ah Nam;

3. TD Bank Account ending in 1237 in the name of Hee Ah Nam;

4. Bank of America Account ending in 6030 in the name of Hee Ah Nam;

5. Bank of America Account ending in 6043 in the name of Hee Ah Nam;
Case 2:24-cv-05863-MEF-MAH Document 8 Filed 07/25/24 Page 2 of 2 PagelD: 67

6. JP Morgan Chase Account ending in 9900 in the name of Hudson Asset
Holding Corp.;

7. JP Morgan Chase Account ending in 4413 in the name of Hudson Asset
Holding Corp.;

8. TD Ameritrade Account ending in 2857 in the name of Hee Ah Nam.

Ms. Nam asserts that she is an innocent owner and innocent spouse in connection
with this matter and the claims to the above listed real property and bank accounts.

Ms. Nam currently resides at 206 Grant Avenue, Cliffside Park, NJ. Ms. Nam is
an owner of Hudson Asset Holding Company which is the record title owner of the
property located at 125 13" Street, Cresskill, New Jersey 07626.

Ms. Nam asserts a claim as to all bank accounts under her name and Hudson
Asset Holding Company. The relief claimed by Petitioner is an order of this Court
declaring that the Government’s forfeiture rights pursuant to the criminal conviction of
Jae H. Choi does not affect Ms. Nam’s interest in the property and above listed bank
accounts. Ms. Nam also seeks an order declaring that Ms. Nam’s interest in the Cresskill
property and the bank accounts listed above be turned over to Ms. Nam promptly.

I hereby state under penalty of perjury that the above is true and correct to the best

of my knowledge.

Dated: July 22, 2024


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