Unites States v. Pokerstars, et al

Filing 138

STIPULATION AND ORDER: IT IS HEREBY STIPULATED AND AGREED by and between the United States of America, by its attorney Preet Bharara, United States Attorney for the Southern District of New York, Jason H. Cowley, Assistant United States Attorney, of counsel, and Chad Elie, by his attorney, William R. Cowden, Esq., that: Chad Elie shall have until December 19, 2011, to answer or otherwise respond to the Amended Complaint. Chad Elie answer due 12/19/2011. (Signed by Judge Leonard B. Sand on 12/5/2011) (lmb)

UNITED STATES DISTRICT
SOUTHERN DISTRICT OF

YORK
-x

UNITED STATES OF AMERICA,
STIPULATION AND ORDER

Plaintiff,
v. ­

11 Civ. 2564
POKERSTARS, et

a~,;

(LBS)

@~DSSDNY

Defendants;

DOCUMENT
ELECTRONICALLY FILED
DOC#:

I

ALL RIGHT, TITLE AND INTEREST IN
THE ASSETS OF POKERSTARS, et a~.,

I

Defendants in rem.

- - - - -I I Q) - 5- I

DATE FILED:
-x

WHEREAS,

on or about

complaint, 11 Civ. 2564

(LBS)

i

14, 2011, a verified
aint") was

(the"

fi~ed

under

seal in the United States District Court for the Southern
District of New York seeking the forfeiture of certain properties
(the "Sub ect Property") pursuant to Title 18, United States
Code, Sections 1955 (d),

981 (a) ( ) (A),

seeking civil money laundering

and 981 (a) (1) (C),

and

ties pursuant to Title 18,

United States Code, Section 1956 against PokerStars and others;
WHEREAS, on or about June 15, 2011, claimant Chad Elie
filed a Verified Claim asserting an ownership/possessory interest
in certain of the Subject Property,
1.

including the following:

ac ount numbered 121015408 held at Sunfirst Bank,
St. George, Utah, in the name of Triple Seven LP
d/b/a Netwebfunds.com, and all funds traceable
thereto;

2.

account numbered 121015390 held at Sun rst
St. George, Utah, in the name of Triple Seven LP
d/b/a A WEB DEBIT, and all funds t
thereto;

3.

account numbered 27351910081015 held at Societe
rus LTD, Cyprus, in the name of Golden
Generale
rties Limited, and all funds traceable
Shores
thereto;

4.

account numbered CY1211501001065983USDCACC002 held
at FBME Bank LTD,
rus, in the name of Triple
Seven Inc., and all funds traceable thereto;

5.

account numbered 5510045221 held at Wells Fargo,
N.A., in the name of Triple Seven L.P., and all
funds traceable thereto;

6.

account numbered 7478010312 held at Wells Fargo,
N.A., in the name of Kombi Capital, and all funds
traceable thereto;

7.

account numbered 12900584 held at Sunfirst Bank,
St. George, Utah, formerly in the name of Sunfirst
Bank ITF Powder Mon
/Full Tilt, now in the name
of Sunfirst Bank, and all funds traceable thereto;

8.

account numbered 129000576 on
sit at Sunfirst
Bank, St.
, Utah, formerly in the name of
Sunfirst Bank ITF Mastery Merchant/Psars, now in
the name of Sunfirst Bank, and all funds traceable
thereto;

9.

account numbered 200003291 held at All American

Bank, Des Plaines, Illinois, in the name of 21

Debit LLC, and all funds traceable thereto;

10. account numbered 200003317 held at All American

Bank, Des Plaines, Illinois, in the name of 21

Debit LLC, and all funds traceable thereto;

11. account numbered 200003325 held at All American

Bank, Des Plaines, Illinois, in the name of 21

Debit LLC, and all funds traceable thereto;

12. Account numbered 200003309 held at All American

Bank, Des Plaines, Illinois, in the name of 21

Debit LLC, and all funds traceable thereto;

2

13. account number 201002907 at Barclays Bank, UK
the name of Hotwire Financial LLC, and all funds
traceable thereto;
6BARC20473563472044 at Barcl s
14. account number
Bank, UK, in the name of Hotwire Financial LTD,
and all funds traceable thereto;
15. account number 953500105 at Bank One Utah, in the
name of 4 A Consulting, and all funds traceable
thereto;
16. account numbered 32433 at New City Bank in the
name of 21Debit LLC dba PS Payments, and all funds
traceable thereto;
17. account numbered 32441 at New City Bank in the
name of 21Debit LLC dba FLT Payments, and all
funds traceable thereto;
18. account number 32506 at New City Bank in the name
of 21Debit LLC, and all funds traceable thereto;
19. $410,449.93 formerly on
sit at Bank of America
Account numbered 229006067857 held in the name of
Viable Marketing Corp. and all property traceable
thereto;
20. $8,168,168.89 formerly on
sit at Fifth Third
Bank in Account numbered 7431859508, held in the
name of Viable Market
. and all property
traceable thereto;
21. $40,960.86 formerly on
sit at Fifth Third Bank
in Account numbered 7432618069, held in the name
of Viable Marketing
. and al property
traceable thereto; and
22. $33,743.75 formerly on
sit at Bank of America
Account numbered 003678667131 held in the name of
EZO, LLC and all prope y traceable thereto;
WHEREAS, on or about September 21, 2011, a verified
amended complaint in this action (the "Amended

laint") was

filed seeking the forfeiture of the Subject Property and seeking

3

civil money laundering penalties pursuant to Title

~8,

United

States Code, Section 1956 against PokerStars and others;
WHEREAS, by previous Stipulation and Order, Ch

Elie

s

until November 30, 2011 to answer or otherwise respond to the
Amended Complaint;
WHEREAS, Chad E1ie has requested additional time to answer
the Amended Complaint;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by
and between the United States of America,

its attorney Preet

Bharara, United States Attorney for the Southern District of New
York, Jason H. Cowley, Assistant United States Attorney, of
counsel, and Chad Elie, by his attorney, William R. Cowden, Esq.,
that:
1.

Chad Elie shall have until December 19, 2011, to

answer or otherwise re

to the Amended Complaint.

4

2.
may be
be deemed an or

The signature pages of this Stipulation

Order

s, each of which will

in one or more

nal but all of which together will constitute

one and the same instrument.

ture pages may be by fax and

S

such signatures shall be deemed

s valid originals.

AGREED AND CONSENTED TO:

York
By:
Uni~ed States Attorney

St. Andrew's Plaza

New York, New York 10007

[phone]

CHAD ELIE

II
am
Wi. 1 iam Cowden
2002 Massachusetts Ave., N.W., Ste 100
Washington, DC 20036
Counse: for Chad E_ie

B. SAND
UNITED STATES DISTRICT JUDGE

DATE

5

7 JIll.i
t.",//U