Unites States v. Pokerstars, et al
Filing
131
MOTION to Dismiss. Document filed by Ultra Safe Pay, LLC.(Michaels, Adam)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
Plaintiff,
v.
POKERSTARS, et al.,
Defendants;
ALL RIGHT, TITLE AND INTEREST
IN THE ASSETS OF POKERSTARS,
et al.,
Defendants-in-rem.
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11 Civ. 2564 (LBS)
CLAIMANT ULTRA SAFE PAY, LLC NOTICE OF
MOTION TO DISMISS FORFEITURE COMPLAINT AND FOR OTHER RELIEF
PLEASE TAKE NOTICE that Claimant Ultra Safe Pay, LLC (“USP”), by its
attorneys, Pepper Hamilton LLP (by Jeremy D. Frey and Adam B. Michaels), will move this
Court before the Honorable Leonard B. Sand at the U.S. Courthouse for the Southern District of
New York, on a date and time to be designated by the Court, for an Order to return to USP the
funds designated in USP’s filed claim in this matter.
There being no scheduling order in this case, the defendants, persons representing
defendants-in-rem and other claimants have diverse dates on which to answer or otherwise
respond to the First Amended Complaint. Accordingly, USP, being a mere claimant and in the
interest of judicial economy, by this motion prospectively joins in and incorporates the motions,
legal arguments and assertions to be contained in motions and all supporting briefs and
documents that may be filed by defendants, persons representing defendants-in-rem and/or other
claimants to property alleged to be subject to forfeiture, including without limitation any such
#15207545 v2
motions and related matters under Fed. R. Civ. P. 12(b)(1), (b)(3) and (b)(6), as its interests may
appear.
For the foregoing reasons, Claimant Ultra Safe Pay, LLC joins these motions to
be filed and requests that this Court issue an Order returning property of USP in accordance with
USP’s filed claim, and for such other and further relief as this Court may deem proper.
Dated: November 30, 2011
Respectfully submitted,
/s/ Adam B. Michaels
Adam B. Michaels
PEPPER HAMILTON, LLP
620 Eighth Avenue
37th Floor
New York, NY 10018-1405
michaelsa@pepperlaw.com
Tel: (212) 808-2700
Fax: (212) 286-9806
Jeremy D. Frey (Pro hac vice)
PEPPER HAMILTON, LLP
3000 Two Logan Square
Eighteenth and Arch Streets
Philadelphia, PA 19103-2799
freyj@pepperlaw.com
Tel: (215) 981.4445
Fax: (866) 422.3552
Attorneys for Ultra Safe Pay, LLC
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CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of November, 2011, I electronically filed the
forgoing Notice of Motion with the Clerk of the Court by using the CM/ECF system, which will
send a notice of electronic filing to the parties of record.
/s/ Adam B. Michaels
Adam B. Michaels
PEPPER HAMILTON, LLP
620 Eighth Avenue
37th Floor
New York, NY 10018-1405
michaelsa@pepperlaw.com
Tel: (212) 808-2700
Fax: (212) 286-9806
Attorneys for Ultra Safe Pay, LLC
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