Unites States v. Pokerstars, et al
Filing
170
STIPULATION AND ORDER: Chad Elie shall have until 5/14/2012 to answer or otherwise respond to the Amended Complaint. (Signed by Judge Leonard B. Sand on 3/20/2012) (ab)
II DOCUMENT
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ELECTRONICALLY FILED
,/'DOC#:
rI DATE F-IL-E-D-: ---(;)-0---\-~3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-x
UNITED STATES OF AMERICA,
STIPULATION AND ORDER
Plaintiff,
- v.
11 Civ. 2564 {LBS)
POKERSTARS , et al,i
Defendants;
ALL RIGHT, TITLE AND INTEREST IN
THE ASSETS OF POKERSTARS, et al.,
Defendants-in-rem.
-x
WHEREAS, on or about April 14, 2011, a verified
complaint, 11 Civ. 2564
(LBS)
(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
Property") pursuant to Title 18, United States
Code, Sections 1955 (d),
981 (a) (1) (A), and 981 (a) (1) (C), and
seeking civil money laundering penalties 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
1.
Subject Property, including the following:
account 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 Sunfirst Bank,
St. George, Utah, in the name of Triple Seven LP
d/b/a A WEB DEBIT, and all funds traceable
thereto;
3.
account numbered 27351910081015 ::1eld at Societe
Generale Cyprus LTD, Cyprus, in the name of Golden
Shores Properties Limited, and all funds traceable
thereto;
4.
account numbered CY1211501001065983USDCACC002 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 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 Monkeys/Full Tilt, 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 rTF 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 in
the name of Hotwire Financial LLC, and all funds
traceable thereto;
14. account number GB26BARC20473563472044 at Barclays
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 deposit 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 deposit at Fifth Third
Bank in Account numbered 7431859508, held in the
name of Viable Marketing Corp. and all property
traceable thereto;
21. $40,960.86 formerly on deposit at Fifth Third Bank
in Account numbered 7432618069, held in the name
of Viable Marketing Corp. and all property
traceable thereto; and
22. $33,743.75 formerly on deposit 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 Property and seeking
3
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 March 19, 2012, to answer or otherwise respond to the
Amended Complaint;
WHEREAS, counsel for Chad Elie 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, 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 attorneys, Barry H. Berke, Esq.,
and Dani R. James, Esq., that:
1.
Chad Elie shall have until May 14, 2012, to answer
or otherwise respond to the Amended Complaint.
4
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 may be by fax and
such signatures shall be deemed as valid originals.
AGREED AND CONSENTED TO:
PREET BHARARA
United States Attorney
Southern D stri
York
By:
DATE I
ant
tates Attorney
One
. Andrew's Plaza
New York, New York 10007
(212) 637-2479
CHAD ELIE
By:
ill~
BarrYH~
3 . I~. ,;(
DJI.TE
Dani R. James, Esq.
Kramer Levin Naftalis & Frankel LLP
1177 Avenue of the Americas
New York, Ny 10036
Counsel for Chad Elie
SO ORDERED:
/~_1
~/~)~~./ ~
HONORABLE LEONARD B. SAND
UNITED STATES DISTRICT JUDGE
DATE
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