Unites States v. Pokerstars, et al

Filing 193

MOTION to Dismiss. Document filed by Telamonian Ajax Trust. Responses due by 7/30/2012(Souede, Benjamin)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,

Case No. 1:11 Civ. 02564 (LBS)
Plaintiff,

v.

ECF CASE

POKERSTARS, et al.,

Filed Electronically
Defendants.

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

Defendants-In-Rem.

NOTICE OF MOTION TO DISMISS CLAIMS ONE AND FOUR OF THE VERIFIED
FIRST AMENDED COMPLAINT AS THEY RELATE TO CLAIMANT
TELAMONIAN AJAX TRUST
PLEASE TAKE NOTICE that upon the accompanying Memorandum of Points
and Authorities and all prior pleadings and proceedings herein, and any additional oral or written
evidence or argument later presented to the Court, Claimant Telamonian Ajax Trust
(“Telamonian”) will respectfully move this Court, before the Honorable Judge Leonard B. Sand,
at a date and time convenient for the Court, in Courtroom 15A at the United States Courthouse,
500 Pearl Street, New York, New York, for an order to dismiss Counts One and Four of the
Verified First Complaint asserted by Plaintiff, United States of America, pursuant to Rules
12(b)(6) and 9(b)of the Federal Rules of Civil Procedure.
PLEASE TAKE FURTHER NOTICE that, pursuant this Court’s June 29, 2012, Order,
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1
677182.01

Plaintiff shall file its Response by July 30, 2012, and Telamonian shall file its reply by August
13, 2012.
DATED: July 9, 2012
Respectfully submitted,

s/ Benjamin N. Souede
BENJAMIN SOUEDE
DAVID ANGELI (admitted pro hac vice)
ANGELI LAW GROUP, LLC
121 SW Morrison St., Suite 400
Portland, OR 97232
[phone]
[phone] (facsimile)
Attorneys for Claimant Telamonian Ajax Trust
To:
Jason H. Cowley
Michael D. Lockard
United States Attorney’s Office
One Saint Andrew’s Plaza
New York, NY 10007
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]