Letter to Honorable Jessica S. Allen — United States v. Daniel Dadoun, Mag. No. 23-8137 (February 9, 2024)

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Letter dated February 9, 2024, to Honorable Jessica S. Allen, United States Magistrate Judge, in United States v. Daniel Dadoun, Mag. No. 23-8137 (JSA), District of New Jersey, from Zach Intrater, Esq. on behalf of Mr. Dadoun. The letter requests that the Court issue an Order instructing the Essex County Correctional Facility to grant Mr. Dadoun library privileges to the greatest extent possible. It states that Mr. Dadoun has been detained there since November 13, 2023, and that library privileges are granted on Saturdays, which conflicts with his religious observance. It states that the government has no objection to the request.

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 Case 2:23-mj-08137-JSA         Document 11       Filed 02/09/24     Page 1 of 2 PageID: 27




                                                           February 9, 2024

VIA ECF
Honorable Jessica S. Allen
United States Magistrate Judge
District of New Jersey
Martin Luther King, Jr. Federal Courthouse
50 Walnut Street
Newark, NJ 07102

       Re:    United States v. Daniel Dadoun, Mag. No. 23-8137 (JSA)

Dear Judge Allen:

        We represent Mr. Daniel Dadoun in the above-captioned matter. Mr. Dadoun has been
detained at the Essex County Correctional Facility (“ECCF”) since November 13, 2023. We
write to respectfully request the Court issue an Order instructing ECCF to grant Mr. Dadoun
library privileges to the greatest extent possible. ECCF has granted Mr. Dadoun library
privileges on Saturdays, but Mr. Dadoun is an observant Jew, and this observance includes not
working (or using computers) on the Jewish Sabbath. The Jewish Sabbath starts at sundown
Friday and lasts until sundown Saturday. Therefore, his religious observance does not allow him
to perform the tasks in the library that he needs to accomplish.

        Counsel has repeatedly requested that ECCF provide Mr. Dadoun expanded access to the
library four days a week, aside from Saturdays. Those requests resulted in one change to the
library hours, to add access on Wednesdays, but officials at the ECCF have advised that if they
have an Order from this Court, then Mr. Dadoun will have additional access, in line with other
inmates who have document-intensive cases who are awaiting trial at ECCF. Counsel has also
 Case 2:23-mj-08137-JSA         Document 11       Filed 02/09/24     Page 2 of 2 PageID: 28




raised this with the AUSA assigned to the case and advised of the issue, though counsel
understands that the AUSA does not have any authority over ECCF.

        Because the administrators at ECCF are specifically seeking an Order from this Court, we
respectfully request that the Court intervene. Specifically, we ask that this Court sign the
enclosed order directing ECCF to afford Mr. Dadoun the maximum amount of library access,
excluding Saturdays. The government has no objection to this request.

                                                           Respectfully submitted,



                                                           Zach Intrater, Esq.

cc:    AUSA Katherine Romano (via ECF)


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