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)
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.
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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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