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Correspondence · Jan. 5, 2022

Defense letter to the judge seeking release of surrendered firearm, Jan. 2022

Defense counsel writes the presiding judge asking for a court order directing NYPD to return the defendant's surrendered firearm after charges were dropped via nolle prosequi.Machine-written summary

Document EFTA 02845979

MI .0 --- FOY & SEPLOW I TZE a t t o r n ey s a t l a w

105 MAIN STREET HACKENSACK. NJ 07601 TEL: 201-457-0071 FAX: 201-457-0072 WWW.FOYSEPLOWITZ.COM

January 5, 2022

Honorable Analisa United States District Court Judge Southern District of New York 500 Pearl Street New York, NY 10007

Re: US v. Tova Noel, et al Docket # 19 cr. 830 (AT) Order to Release Firearm and any other Property

Dear Judge

30 WALL STREET 8TH FLOOR NEW YORK. NY 10005 TEL 212-709-8230

On January 3, 2022, the Court filed the fully executed Nolle Prosequi Order formally terminating the prosecution and dismissing all criminal charges in the above referenced criminal action. In November of 2019, Ms. Tova Noel was released with conditions. One of the conditions required the surrender of her firearm to the New York City Police Department (NYPD). As required, Ms. Noel promptly surrendered her firearm to the 44th Precinct of the NYPD in the Bronx.

On January 4, 2022, Ms. Noel went to the 44th Precinct to retrieve her firearm with a copy of the Nolle Prosequi Order. She was referred to the NYPD property clerk’s office located in the basement of the Bronx Criminal Court. The NYPD property clerk was presented with the Nolle Prosequi Order, however, the property clerk refused to release the firearm. The NYPD property clerk indicated that they would only release the firearm pursuant to a court order.

Attached is a proposed order mandating the release of Ms. Noel’s firearm and any other property that was surrendered as a condition of release. I have spoken with the Government regarding this application, and they have no objection. Thank you for your thoughtful consideration.

Sincerely,

FOY & SEPLOWITZ LLC

“awl e gy

JASON E. FOY ifovflovsealowitz.com

Defense letter to the judge seeking release of surrendered firearm, Jan. 2022

Emails and letters

Defense counsel writes the presiding judge asking for a court order directing NYPD to return the defendant's surrendered firearm after charges were dropped via nolle prosequi.

Court Records: S.D.N.Y. No. 1:19-cr-00830 · Jan. 5, 2022

Document EFTA 02845979 MI .0 --- FOY & SEPLOW I TZE a t t o r n ey s a t l a w 105 MAIN STREET HACKENSACK. NJ 07601 TEL: 201-457-0071 FAX: 201-457-0072 WWW.FOYSEPLOWITZ.COM January 5, 2022 Honorable Analisa United States District Court Judge Southern District of New York 500 Pearl Street New York, NY 10007 Re: US v. Tova Noel, et al Docket 19 cr. 830 (AT) Order to Release Firearm and any other Property Dear Judge 30 WALL STREET 8TH FLOOR NEW YORK. NY 10005 TEL 212-709-8230 On January 3, 2022, the Court filed the fully executed Nolle Prosequi Order formally terminating the prosecution and dismi…