Unites States v. Pokerstars, et al

Filing 147

STIPULATION AND ORDER: Chad Elie shall have until 1/23/2012, to answer or otherwise respond to the Amended Complaint. (Signed by Judge Leonard B. Sand on 12/26/2011) (ft)

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\ FLEC~RONICALLY FILED

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

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DATE FILED: \

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UNITED STATES OF AMERICA,

STIPULATION AND ORDER

PlaintifC
- v.

11 Civ.

2564

(LBS)

POKERSTARS, et al,;
Defendants;
ALL RIGHT, TITLE AND INTEREST IN
THE ASSETS OF POKERSTARS, et al.,
Defendants-in-rem.

- - - -x
WHEREAS,
complaint,

on or about April 14,

11 Civ. 2564

(LBS)

2011,

a verified

(the "Complaint") was filed under

seal in the United States District Court for the Southern
District of New York seeking the forfeiture of certain properties
(the "Subject
Code,

rty") pursuant to Title 18, United States

Sections 1955 (d),

981 (a) (1) (A),

and 981 (al (1) (C), and

seeking civil money laundering penalties pursuant to Title 18,
United States Code, Section 1956

nst PokerStars and others;

WHEREAS, on or about June 15,

2011,

filed a Verified Claim asserting an ownersh
in certain of the Subject Property,
1.

claimant Chad Elie
/possessory interest

including the following:

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

2.

account numbered 121015390 held at Sunfirst Bank,
St. George, Utah, in the name of Triple Seven LP
d/b/a A WEB DEBIT, and a 1 funds traceable
thereto;

3.

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

4.

account numbered CY121150100106S983USDCACC002 held
at FBME Bank LTD, Cyprus, 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
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 Monkeys/Full Ti t, now in the name
of Sunfirst Bank, and all funds traceable thereto;

8.

account numbered 129000576 on deposit at Sunfirst
Bank, St. George, Utah, formerly in the name of
Sunfirst Bank ITF Mastery Merchant/Psars, now in
the name of Sun first Bank, and all funds traceab e
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, 11 inois, 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;
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13. account number 201002907 at Barela
Bank, UK in
the name of Hotwire Financial LLC, and all funds
traceable thereto;
14. account number GB26BARC20473563~72044 at Barclays
Bank, UK, in the name of Hotwire Financial LTD,
and all fun
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 21
t 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 Paynents, 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 deposit at Bank 0 America
Account numbered 229006067857 held in the name of
Viable Marketing Corp. and all property traceable
thereto;
20. $8,168,168.89 formerly on depos~t at Fifth Third
Bank in Account numbered 7431859508, held in the
name of Viable Market
Corp. and all proper
traceable thereto;
21. $40,960.86 formerly on
sit at Fifth Third Bank
in Account numbered 7432618069, held in the name
of Viable Marketing Corp. and a_I 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 property traceable thereto;
WHEREAS, on or about September 21, 2011, a verified
amended complaint in this action (the "Amended Complaint") was
filed seeking the forfeiture of the Subject

rty and seeking

3

rrr.

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'IIZiililtlllmiiIM'
'1,.~:.it'iiI"_t _ _ _ _ _

civil money laundering penalties pursuant to Title 18, United
States Code, Section 1956 against PokerStars and others;
WHEREAS, by previous Stipulation and Order, Chad Elie has
until December 19, 2011 to answer or otherwise respond to the
Amended Complaint;
WHEREAS, Chad Elie has requested additional time to answer
the Amended Complaint;
NOW, THEREFORE, IT IS HEREBY

STIPULA~ED

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:
1.

Chad Elie shall have until January 23, 2012, to

answer or otherwise respond to the Amended Complaint.

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2.

The signature pages of this Stipulation and Order

may be executed in one or more counterparts, each of which will
be deemed an original but all of which together will constitute
one and the same instrument.

Signature pages .J1ay be by fax and

such signatures shall be deemed as valid originals.
AGREED AND CONSENTED TO:
PREET BHARARA
United States Attorney
Southern istr' t of New York
By:
States Attorney
t. Andrew's Plaza
New York, New York 10007
[phone]

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By:

william R. Cowden,
D1HE

William Cowden LLC

2002 Massachusetts Ave., N.W., Ste 100

Washington, DC 20036

Counsel for Chad Elie

SO

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Dl'1TE

LE LEONARD B. SAND
STATES DISTRICT JUDGE

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