Unites States v. Pokerstars, et al

Filing 220

MOTION to Stay In Rem Claims As To Domain Defendants. Document filed by Commonwealth of Kentucky, ex. rel. J. Michael Brown, Secretary, Justice and Public Safety Cabinet.(Lycan, David)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, Plaintiff, v. POKERSTARS, ET AL., Defendants, ALL RIGHTS, TITLE & INTEREST IN THE ASSETS OF POKERSTARS, ETC., Defendants-In-Rem. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 1:11-cv-02564-LBS NOTICE OF MOTION TO STAY IN REM CLAIMS AS TO DOMAIN DEFENDANTS PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law and all prior pleadings and proceedings herein, and any additional oral or written evidence or argument later presented to the Court, the Commonwealth of Kentucky, ex rel., J. Michael Brown, Secretary Justice and Public Safety Cabinet (the “Commonwealth”), by and through counsel, will respectfully move this Court, at a date and time convenient for the Court, for an order to stay this action in regard to the in rem defendant domain names pokerstars.com, fulltiltpoker.com, absolutepoker.com and ultimatebet.com in favor of the prior exclusive jurisdiction of the Franklin Circuit Court in Frankfort, Kentucky. i PLEASE TAKE FURTHER NOTICE that, pursuant this Court’s July 11, 2012, Order, Plaintiff shall file its Response by August 6, 2012, and the Commonwealth shall file its Reply by August 13, 2012. DATED: July 16, 2012 Respectfully submitted, /s/ D. Eric Lycan (pro hac vice) STEPTOE & JOHNSON, PLLC 1010 Monarch Street, Suite 250 P.O. Box 910810 Lexington, Kentucky 40513 Telephone: (859) 255-7080 Facsimile: (859) 255-6903 eric.lycan@steptoe-johnson.com Attorney for Commonwealth of Kentucky ex rel., J. Michael Brown, Secretary Justice and Public Safety Cabinet To: Jason H. Cowley Michael D. Lockard United States Attorney’s Office One Saint Andrew’s Plaza New York, NY 10007 Tel: (212) 637-1060 Fax: (212) 637-0421 Jason.Cowley@usdoj.gov Michael.Lockard@usdoj.gov

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