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Case 1:19-cr-00830-AT Document 66 Filed 01/05/22 Page 1 of 1
105 Main Street 30 Wall Street
Hackensack, NJ 07601 8th Floor
Tel: 201-457-0071 New York, NY 10005
Fax: 201-457-0072 www.foyseplowitz.com 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 conditio
[…]