Unites States v. Pokerstars, et al

Filing 237

MOTION For (1) the Entry of a Proposed Stipulated Order of Settlement Between the United States and Certain Absolute Poker-Affiliated Entities and (2) the Interlocutory Sale of All Assets of Those Entities. Document filed by United States Of America.(Cowley, Jason)

- - - - - - - - - - - - - - - - - -x
:
UNITED STATES OF AMERICA,
Plaintiff,
:
- v -

:

POKERSTARS, et al.

:

Defendants;

11 Civ. 2564 (LBS)

:
:

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

:

Defendants-in-rem.

:

- - - - - - - - - - - - - - - - - -x
NOTICE OF MOTION
PLEASE TAKE NOTICE that, upon the Affidavit of Jason H.
Cowley in Support of Government’s Motion, together with the
exhibits thereto, the Government’s Memorandum of Law in Support
of Motion, together with the exhibit thereto, and upon all papers
and prior proceedings herein, the United States of America will
move before the Honorable Leonard B. Sand, United States District
Judge for the Southern District of New York, at such time as the
Court shall direct, (1) for the entry of proposed stipulated
order of settlement between the Government and Absolute Pokeraffiliated parties; and (2) for an order, pursuant to Rule G(7)
of the Supplemental Rules for Admiralty or Maritime Claims and
Asset Forfeiture Actions, permitting the United States Marshals
Service to seize and conduct an interlocutory sale of all of the
right, title, and interest in the assets of certain Absolute
Poker corporate entities, with the net proceeds generated by such

sale to be held by the Government as substitute res for the
ongoing litigation with other claimants who have asserted an
interest in those assets, or such other relief as the Court may
determine to be just and proper.

Dated:

New York, New York
July 31, 2012
Respectfully submitted,
PREET BHARARA
United States Attorney for the
Southern District of New York
Attorney for the Plaintiff
United States of America

By:

/s/
SHARON COHEN LEVIN
MICHAEL D. LOCKARD
JASON H. COWLEY
One St. Andrew’s Plaza
New York, New York 10007
[phone]/2193/2479

2