DOJ-OGR-00022150.pdf

--- Page 1 --- **Case 1:19-cr-00830-AT** **Document 66** **Filed 01/05/22** **Page 1 of 1** **FOY & SEPLOWITZ** **attorneys at law** **105 MAIN STREET** **HACKENSACK, NJ 07601** **TEL: 201-457-0071** **FAX: 201-457-0072** **WWW.FOYSEPLOWITZ.COM** **30 WALL STREET** **8TH FLOOR** **NEW YORK, NY 10005** **TEL: 212-709-8230** **January 5, 2022** **Honorable Analisa Torres** **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 Torres:** 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** **Jason E. Foy** **JASON E. FOY** **jfoy@foyseplowitz.com** **DOJ-OGR-00022150**