Unites States v. Pokerstars, et al

Filing 23

MOTION for Steven J. McCool to Appear Pro Hac Vice. Document filed by Chad Elie.(pgu)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
11 CV 02564 (LBS)
UNITED STATES OF AMERICA
Plaintiff

MOTION TO ADMIT COUNSEL
PRO HAC VICE
,

v.
POKERSTARS, ET AL.,
Defendants

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c
PURSUANT TO RULE 1.3(c) of the Local Rules of the United States District

Court~or ~

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Southern and Eastern Districts of New York, I, Michael Cornacchia, a member in good standing of!pe
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bar of this Court, hereby moves for an Order allowing the admission, pro hac vice, of _the following
applicant, in order to represent the claimant CHAD ELIE, in the above-captioned case, said applicant
being:

Steven J. McCool
Mallon & McCool, LLC
1776 K Street, N.W., Suite 200
Washington, DC 20006
T: 202.393.7088
F: 202.293.3499
[e-mail]

Mr. McCool is a member in good standing of the Bar of the District of Columbia, a certification to
this effect being annexed to my affidavit in support of this motion, and has been retained to represent the

claimant Chad Elie who filed a verified claim in this case on June 15, 2011. There are no pending
disciplinary proceedings against Mr. McCool in any State or Federal court.

Dated: June 28, 2011
New York, New York

Q)#mitted,
Michael T. Cornacchia
Attorney at Law
MC 2444
260 Madison Avenue
22nd Floor
New York, NY 10016
T: 646-278-4297
F: 646-839-2538
[e-mail]

2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,
Plaintiff

v.
POKERSTARS, ET AL.,

11 CV 02564 (LBS)

AFFIDAVIT OF
MICHAEL T. CORNACCHIA
IN SUPPORT OF MOTION
TO ADMIT COUNSEL
PRO HAC VICE

Defendants

State of New York
County of New York
Michael T. Cornacchia, being duly sworn, hereby deposes and says as follows:
1. I am familiar with the proceedings in the above-captioned case, and make this affidavit based

on my personal knowledge of the facts set forth herein, and in support of my motion to admit
Steven J. McCool as counsel, pro hac vice, to represent Claimant Chad Elie, who filed, on June
15, 2011, a verified claim, in this Court, in the above-captioned in rem civil forfeiture case [Dkt.
13]. My previous motion to move Mr. McCool's admittance, pro hac vice, before this Court, to
represent Mr. Elie, as a defendant in the related criminal case, United States v. Tzvetkoff, et al.,
10 CR 336 S-3 (LAK), was granted by the Honorable Lewis A. Kaplan.
2. I am a member in good standing of the Bar of the State of New York, and was admitted to
practice law in 1977. I am also admitted to the Bar of the United States District Court for the
Southern District of New York, and am in good standing with this Court.
3. I have known Mr. McCool since 2005.
4. Mr. McCool is a partner at Mallon & McCool, LLC, in Washington, DC, a former Assistant
United States Attorney for the District of Columbia and a member in good standing of the Bar of
the District of Columbia, as evidenced by the attached Certificate, marked as Exhibit A.
5. I know Mr. McCool to be a skilled attorney and a person of integrity. He is experienced in
federal practice and familiar with the Federal Rules of Procedure.
6. Accordingly, I am pleased to move the admission of Steven J. McCool, pro hac vice.
7. I respectfully submit a proposed order granting the admission of Steven J. McCool, pro hac
vice, which is attached hereto as Exhibit B.

WHEREFORE it is respectfully requested that the motion to admit Steven J. McCool,
pro hac vice, to represent Claimant Chad Elie in the above-captioned case, be granted.

Michael T. Cornacchia
MC 2444
260 Madison Avenue
22nd Floor
New York, NY 10016
T: 646-278-4297
F: 646-839-2538
[e-mail]

Subscribed and sworn to before me this Kef-day of June 2011:
State of New York
County of New York

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JOANN M. DIMARCO
Notary Public, State of New York
No. 31-01015007831
Ouali!ied in New York County
Comm1ss1on Expires February 8, 20

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202 J879-2710

I, JULIO A. CASTILLO, Clerk of the District of Columbia
Court of Appeals, do hereby certify that
STEVEN J. McCOOL
26TH

was on the
duly

qualified

entitled

to

and

day of

admitted

practice

JULY, 1991

-----------------------------------------

before

as

an

this

attorney
Court

and

and
is,

counselor
on

the

and
date

indicated below, an active member in good standing of this Bar.

In Testimony Whereof, I
hereunto subscribed my
and affixed the seal of
Court
at
the
City
Washington,
D.C., on
20, 2011.

have
name
this
of
June

JULIO A. CASTILLO
Clerk of tLe Court

By,~~~
Deputy Clerk

UNITED STATES DISTRICT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,
Plaintiff

v.

11 CV 02564 (LBS)
ORDER FOR ADMISSION
PROHACVICE
ON WRITTEN MOTION

POKERSTARS, ET AL.,
Defendants.

Upon the motion of Michael T. Cornacchia, an attorney admitted to the Bar of this Court,
and his affidavit in support;
IT IS HEREBY ORDERED that
Steven J. McCool
Mallon & McCool, LLC
1776 K Street, N.W., Suite 200
Washington, DC 20006
T: 202.393.7088
F: 202.293.3499
[e-mail]
is admitted to practice, pro hac vice, as counsel for CHAD ELIE, a claimant in the abovecaptioned case in the United States District Court for the Southern District of New York. All
attorneys appearing before this Court are subject to the Local Rules of this Court, including the
Rules governing discipline of attorneys. If this action is assigned to the Electronic Case Filing
(ECF) system, Mr. McCool shall immediately apply for an ECF password at nysd.uscourts.gov.
Counsel shall forward the pro hac vice fee to the Clerk of Court.

Dated:------The Honorable Leonard B. Sand
United States District Judge
Southern District of New York

UNITED STATES DISTRICT COURT
THE SOUTHERN DISTRICT OF NEW YORK

CERTIFICATE OF SERVICE
I hereby certify that on this 28th day of June 2011, I caused (1) this Motion to Admit
Steven J. McCool, Pro Hac Vice, (2) the Mfidavit in support thereof, and (3) a proposed Order
to be served on the following counsel for the Plaintiff United States of America, by forwarding
the same to them, by First Class U.S. Mail, addressed as follows:
Assistant United States Attorney Jason Harris Cowley
Assistant United States Attorney Michael Dennis Lockard
Office of the United States Attorney, S.D.N.Y.
One St. Andrew's Plaza
New York, NY 10007