Unites States v. Pokerstars, et al

Filing 208

ENDORSED LETTER addressed to Judge Leonard B. Sand from David M. Zornow dated 7/9/2012 re: The PokerStars Companies intend to file herewith a motion to dismiss the Verified First Amended Complaint (the "Complaint"), and respectfully request that the Court permit the filing of a memorandum of law of up to 51 pages. ENDORSEMENT: SO ORDERED. (Signed by Judge Leonard B. Sand on 7/9/2012) (djc)

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July 9, 2012

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Hon. Leonard B. Sand
Cnited States District Judge
Cnited States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007-1312

RE:

: ' DOCU.lI.ffiNT
I
ELECTRONICALLY FILED
DOC#: ______________

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1DATE FILED::,- \ G - \.::t. I~

United States v. PokerStars, et. aI., ll-CV-2564 (LBS)

Dear Judge Sand:
We write as counsel for PokerS tars, Oldford Group Ltd., Rational
Entertainment Enterprises Ltd., Pyr Software Ltd., Stelekram Ltd., and Sphene
International Ltd. (defined as the "PokerStars Companies") in the above-referenced
action.
The PokerStars Companies intend to file herewith a motion to dismiss
the Verified First Amended Complaint (the "Complaint"), and respectfully request
that the Court permit the filing of a memorandum of law of up to 51 pages. A
memorandum of this length is needed in order to address the numerous issues raised
in the 89 pages and 161 numbered paragraphs of the Complaint. The additional
length is also warranted due to the fact that the Complaint raises novel issues of law,
and asserts both in rem claims and a demand for at least $1.5 billion in civil penalties.
Finally, the PokerStars Companies are filing one consolidated motion to dismiss,
rather than separate motions, thus providing an additional basis for the request.

We have conferred with the United States Attorney's Office for the
Southern District of New York, and they do not object to this request.

Respectfully submitted,

olf~ ~/f'\M'I
David M. Zornow

New York, NY
July 9,2012

SO ORDERED:

(}~,A ~
onor Ie Leonard B. Sand
United States District Judge

cc:

Counsel of Record