Letter on Release Conditions — United States v. Daniel Dadoun (Document 25)

Summary

In this letter to Magistrate Judge Michael A. Hammer, filed January 21, 2025, the office of Anthony Pope Law, P.C. writes for defendant Daniel Dadoun to request a modification of release conditions. The letter states that a September 19, 2024 order released Dadoun on home incarceration under a 24-hour lockdown. It asks that Dadoun be allowed to attend religious services at a synagogue and to visit his civil attorneys' office in Hackensack, New Jersey on Tuesdays and Thursdays. It states that the Government cannot consent to the requests and that Dadoun has surrendered his passport.

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 Case 2:23-mj-08137-JSA              Document 25           Filed 01/21/25   Page 1 of 3 PageID: 111




                               ANTHONY POPE LAW, P.C.
                                              ATTORNEYS AT LAW

NEW JERSEY OFFICE                                                                    NEW YORK OFFICE
60 PARK PLACE                                                                        275 MADISON AVE.
                                                                                           35TH
SUITE 1101                                                                                      FLOOR
NEWARK, NJ 07102                                                                   NEW YORK, NY 10016


TEL: (973) 344-4406                                                                  TEL: (212) 905-4900
FAX: (973) 344-320!                                                                  FAX: (973) 344-320!
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ANTHONY POPE, ESQ.*
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*Certfied by the Supreme Court of                                                   PLEASE REPLY TO:
New Jersey as a Civil & Criminal Trial Attorney                                        New Jersey Office


                                                  January 21, 2025

VIA ECF
The Honorable Michael A. Hammer
United States Magistrate Judge
Martin Luther King Building & U.S. Courthouse
50 Walnut Street
Newark, NJ 07101

         RE:               United States v. Daniel Dadoun
                           Docket No. 23-8137


Dear Judge Hammer,

        This office represents the interests of Defendant, Daniel Dadoun (hereinafier, “Mr.
Dadoun” or “Dadoun”), relative to the above-captioned matter. On September 19, 2024, Your
Honor entered an Order releasing Mr. Dadoun from custody on home incarceration, secured by
Dadoun’s residential properties and an appearance bond with a co-signor (ECF 20). Please
accept this correspondence in lieu of a more formal submission in support of Dadoun’s request
for modification of his release conditions to allow him to attend synagogue for daily religious
services and to attend in-person visits with his civil attorneys twice per week.

        Since his release from custody in September 2024, Dadoun has remained compliant with
all conditions of his release. Because he was released on home incarceration, he is restricted to
his residence under a 24-hour lockdown (ECF 20). As a result, he is unable to attend religious
services or meet with his civil attorneys on a regular basis in order to to discuss the many civil
cases his company is actively litigating. For these reasons, he makes the within application for
modification of his release conditions to allow him to attend religious services or meaningfully
participate in the many of civil cases in litigation.
Case 2:23-mj-08137-JSA             Document 25          Filed 01/21/25       Page 2 of 3 PageID: 112




         Dadoun is a devout member of the Orthodox Jewish faith. Those who follow Orthodox
Judaism customarily attend synagogue for prayer services three times per day in the morning,
afternoon, and at sundown’. Orthodox Jewish individuals also attend prayer services on the
Sabbath (on Friday evenings and Saturday mornings), in addition to attending synagogue on
Jewish holidays such as Rosh Hashanah, Yom Kippur, and Passover. Dadoun’s religion is of
utmost importance to him. To illustrate, while incarcerated for over 10 months at the Essex
County Correctional Facility, Dadoun refused to take off his yarmulke, despite daily antisemitic
threats, harassment and assaults from his fellow inmates.

        Because of his current release conditions, Dadoun was not permitted to attend religious
services on the Jewish holidays of Rosh Hashanah, Yom Kippur, or Succot, and cannot attend for
daily or Shabbat prayer services. This has been especially hard for Dadoun, whose faith has only
strengthened since his arrest and incarceration, and who wishes to pray not only for himself, but
also for his wife and children, all of whom remain in Israel. He respectfully requests the
opportunity to attend religious services at his local synagogue, “Yeshiva Ateret Torah,” located
at 901 Quentin Road in Brooklyn, NY, 11223. If permitted, he would attend for morning,
afternoon, and night prayer on weekdays, as well as Sabbath Prayers on Friday nights and
Saturday mornings.

        Additionally, Dadoun requests the opportunity to visit his civil attorney’s office, located
in Hackensack, New Jersey, twice per week on Tuesdays and Thursdays. The state of affairs of
Dadoun’s businesses has resulted in many lawsuits filed against them. Dadoun hired Richard D.
Wolloch, Esq., of the law firm of Winnie Banta Basralian & Kahn, to represent him in these
lawsuits. Mr. Wolloch provided a letter in support of this request, in which he included the
names of the cases in suit and their corresponding docket numbers (see attached “Exhibit A” for
a copy of Mr. Wolloch’s letter). Due to the amount of cases and the extent to which the firm
requires Dadoun’s assistance, his attorneys would be better served by having increased face-to-
face interaction with Dadoun, as opposed to phone calls and sending documents back and forth.

        The Government has communicated its position that it cannot provide consent for any of
the within requests for modification of Dadoun’s release. However, Dadoun has not engaged in
any conduct during the pendency of his release that would lead the Court to believe that if
granted, Dadoun would not be similarly compliant with the modifications. Further, the instant
case represents Dadoun’s only interaction with law enforcement, as he has no prior criminal
history. Dadoun has surrendered his passport, and his release was secured by a custodian, a co
signor, and his property. Therefore, there are appropriate safeguards to prevent Dadoun from
fleeing the Country, despite there being no desire for him to do so.

        For the foregoing reasons, Mr. Dadoun respectfully requests that the Court modif5’ his
current release conditions to allow him to attend religious services at his synagogue and for
weekly visits to his civil attorneys’ office.


                                                                   Respectfully submitted,

 Dadoun’s synagogue holds moming prayers at 7AM; afternoon prayers at 12:30 PM, and night prayers at
sundown.
Case 2:23-mj-08137-JSA      Document 25   Filed 01/21/25   Page 3 of 3 PageID: 113




                                                   ANTHONY POPE LAW, P.C.



                                                   ,ESQ.


cc: AUSA Katherine Romano


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