Unites States v. Pokerstars, et al

Filing 24

MOTION for William R. Cowden to Appear Pro Hac Vice. Document filed by Chad Elie.(pgu)

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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 U; C' c r~ . .) U:) -r-; i . ~·· PURSUANT TO RULE 1.3(c) of the Local Rules of the United States District Courti4ibr t~ . Southern and Eastern Districts of New York, I, Michael Cornacchia, a member in good standing 0 of\.li~Ie •:., 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: William R. Cowden Mallon & McCool, LLC 1776 K Street, N.W., Suite 200 Washington, DC 20006 T: 202.393.7088 F: 202.293.3499 wcowden@mallonandmcool.com Mr. Cowden 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 '~ ·~';Jl .... ' claimant Chad Elie who filed a verified claim in this case on June 15, 2011. There are no pending disciplinary proceedings against Mr. Cowden in any State or Federal court. Dated: June 28, 2011 New York, New York Michael T. Cornacchia Attorney at Law MC2444 260 Madison A venue 22nd Floor New York, NY 10016 T: 646-278-4297 F: 646-839-2538 mcornacchia@mtclegal.com 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, Plaintiff v. POKERSTARS, ET AL., Defendants 11-CV-02564 (LBS) AFFIDAVIT OF MICHAEL T. CORNACCHIA IN SUPPORT OF MOTION TO ADMIT COUNSEL PRO HAC VICE 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 William R. Cowden as counsel, pro hac vice, to represent claimant Chad Elie in the abovecaptioned in rem civil forfeiture case in which he filed a verified claim on June 15, 2011 [Dkt. 13]. 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 in good standing with this Court. 3. I have known Mr. Cowden since 2010 and his law partner, Steven J. McCool, since 2005. 4. Mr. Cowden is a partner at Mallon & McCool, LLC, in Washington, DC, former Assistant United States Attorney for the District of Columbia, former Senior Trial Attorney with the Department of Justice, and 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. Cowden's reputation to be that of a skilled attorney and person of integrity. He is experienced in Federal practice, including criminal and asset forfeiture matters, and familiar with the Federal Rules of Procedure. Mr. Cowden has been admitted by this Court to represent Chad Elie in the related criminal matter, United States v. Tzvetkoff, et al., 10-cr-0336 (LAK). 6. Accordingly, I am pleased to move the admission of William R. Cowden, pro hac vice. 7. I respectfully submit a proposed order granting the admission of William R. Cowden, pro hac vice, which is marked as Exhibit B. WHEREFORE it is respectfully requested that the motion to admit William R. Cowden, pro hac vice, to represent Claimant Chad Elie in the above-captioned case, be granted. Respectfully submitted, ~g;a MC 2444 260 Madison A venue 22nd Floor New York, NY 10016 T: 646-278-4297 F: 646-839-2538 mcornacchia@mtclegal.com Subscribed and sworn to before me State of New York County of New York ) ) ) this;z.~~ay of June 2011: ss: JOANN M. DIMARCO Notary Public, State of New York No. 31-01015007831 Qualified in New York County 0 Commission Expires February 8, 20~ 2 _.. ~ iz±rid nf Qlniumhia Qlnud nf J\pp~aiz illnmmiftcc nn J\omissinns tll ~fred, ~~~ ~ - ~nm 123 ~asqingtmt, ~EL ill~ 20001 202 I 879-2710 430 I, JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals, do hereby certify that WILLIAM R. COWDEN 28TH was on the duly qualified entitled to and day of admitted practice DECEMBER, 1990 ------------------------------------------- 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. JULIO A. CASTILLO Clerk of ~he Court have name this of June 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 William R. Cowden Mallon & McCool, LLC 1776 K Street, N.W., Suite 200 Washington, DC 20006 T: 202.393.7088 F: 202.293.3499 wcowden@mallonandmcool.com 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 William R. Cowden, Pro Hac Vice, (2) the Affidavit 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

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