Unites States v. Pokerstars, et al

Filing 25

MOTION for Jeremy D. Frey to Appear Pro Hac Vice. Document filed by MAS, Inc., Ultra Safe Pay, LLC.(pgu)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA

11-Civ. 2564 (LBS)

Plaintiff,
v.

NOTICE OF MOTION TO ADMIT
COUNSEL PRO HAC VICE

POKERSTARS, ET AL.
Defendants.
PLEASE TAKE NOTICE that, upon the Affidavit of Adam B. Miohaels, sworn to
(,:·.::.,..,1
June 27,2011, and the Certificates of Good Standing annexed thereto, Claimants MASJ·Inc.~'and

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Ultra Safe Pay, LLC will move this Court before the Honorable Leonard B. Sand, at the::Uni.t€d
-,·
States Courthouse, 500 Pearl Street, New York, New York 10007, for an Order pursu~o

~le

1.3(c) of the Local Rules of the United States District Courts for the Southern an~ Eastern

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Districts of New York, allowing the admission pro hac vice of Jeremy D. Frey,

an attorney with

the law firm of Pepper Hamilton LLP and a member in good standing of the Bars of the State of
New Jersey and the Commonwealth of Pennsylvania. There are no pending disciplinary
proceedings against Mr. Frey in any state or federal court.
Dated: New York, New York
June 27, 2011

Respectfully submitted,

Adam B. Michaels. (AM 9120)
PEPPER HAMIL TON LLP
Attorneys for Defendant
The New York Times Building
620 Eighth Avenue
New York, New York 10018-1405
[phone]
Counsel for Claimants MAS, Inc. and Ultra
Safe Pay, LLC

#14415793 vi

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA

11-Civ. 2564 (LBS)

Plaintiff,
v.

AFFIDAVIT

POKERSTARS, ET AL.
Defendants.
STATEOFNEWYORK

)
) ss:
COUNTY OF NEW YORK )
ADAM B. MICHAELS, being duly sworn, deposes and says:
1.

I am a member in good standing of the bar of the State of New York and

was admitted to practice in 2003. I was also admitted to the bar of the United States District
Court for the Southern District ofNew York on July 8, 2003, and am in good standing with this
Court.
2.

I am of counsel with the law firm of Pepper Hamilton LLP, counsel for

Claimants MAS, Inc. and Ultra Safe Pay, LLC in the above-captioned action, and make this
Affidavit in support of the motion for the admission of Jeremy D. Frey to practice pro hac vice in
the above-captioned action.
3.

Mr. Frey is an attorney with the law firm of Pepper Hamilton LLP. His

telephone number is 215-981-4445. His e-mail address is [e-mail]. As shown in
the Certificates of Good Standing annexed to this Affidavit, he is a member in good standing of
the Bars ofthe State ofNew Jersey and the Commonwealth of Pennsylvania, admitted in 1991
and 1979, respectively.

4.

There are no pending disciplinary proceedings against Mr. Frey in any

state or federal Court.
5.

Mr. Frey is a skilled attorney and a person of integrity. He is experienced

in federal practice and with the Federal Rules of Civil Procedure.
6.

Accordingly, I am pleased to move the admission of Mr. Frey pro hac

7.

It is respectfully requested that the Court grant the motion for an order

vice.

permitting Jeremy D. Frey to appear in this action as counsel for Claimants MAS, Inc. and Ultra
Safe Pay, LLC for all purposes pro hac vice. A proposed order for Mr. Frey's admission pro hac
vice is annexed hereto.

ADAM B. MICHAELS

Sworn to before me this
27th day of June, 2011.

-2-

~upreme ~ourt

~ertificate

of ..fleW j ersep

of ®oob ~tanbing

'I!iis is to certify that JEREMY D FREY
(9\[p.
045101991
) was constitutea ana appointee{ anYLttorney at Law of:A&w
Jersey on
December 19, 1991
aru[, as sucli,
lias 6een aamittea to practice 6efore tlie Supreme Court ana a[{ otlier courts of tliis State
as an Ylttorney at Law, acconfing to its Caws, rufes, ana customs.
I furtlier certify tliat as of tliis aate, tlie a6ove-namea is an Ylttorney at Law in
(jooa Stanaing. :For tlie purpose of tliis Certificate, an attorney is in (((jooa Stanaing" if
tlie Courts recortfs refCect that tlie attorney: 1) is current witli a[{assessments imposeaas a
part oftlie ji{ing oftlie annuafYLttorney !RJ;gistrationStatement, inc{tufing, 6ut not fimitea
to, a[{ o6{igations to tlie ~w Jersey Lawyers' :Juna for C{ient Protection; 2) is not
suspenrfea or ais6arreafrom tlie practice of Caw; 3) lias not resignee{from tlie 'Bar of tliis
State; ana4) lias not 6een transferrea to 1Jisa6ifity Inactive status pursuant to 2(ufe 1:2012.
Pfease note that tliis Certificate aoes not constitute confinnation of an attorneys
satisfaction of tlie aaministrative requirements of2(u{e 1:21-1 (a)for e{igi6ifity to practice
Caw in tliis State.
In testimony w/Ureofi I have
/Ureunto set my hana ana
affi~ea t/U Sea! of t!U
Supreme Court, at Trenton, tfiis
2151 iay of June
, 20 11

Cferk._of t/U Supreme Court
-453a-

~upreme

<!Court of f)enngplbania

CERTIFICATE OF GOOD STANDING

Jeremy Daniel Frey, Esq.
DATE OF ADMISSION

November 15, 1979

The above named attorney was duly admitted to the bar of the Commonwealth of
Pennsylvania, and is now a qualified member in good standing.

.. Witness my hand and official seal
Dated: June 16, 2011

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA

11-Civ. 2564 (LBS)

Plaintiff,
v.

ORDER FOR ADMISSION
PRO HAC VICE

POKERSTARS, ET AL.
Defendants.

Upon the motion of Adam B. Michaels, attorney for Claimants MAS, Inc. and
Ultra Safe Pay, LLC and said sponsor attorney's affidavit in support,
IT IS HEREBY ORDERED that Jeremy D. Frey is admitted to practice pro hac
vice as counsel for Claimants MAS, Inc. and Ultra Safe Pay, LLC in the above captioned case.

All attorneys appearing before this Court are subject to the Local Rules of this Court, including
the Rule governing discipline of attorneys. Counsel shall immediately apply for an Electronic
Case Filing (ECF) password at nysd.uscourts.gov. Counsel shall forward the pro hac vice fee to
the Clerk of Court.

Dated:- - - - - - - - - - - - - - - U.S. D. J.

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

11 Civ. 2564 (LBS)

Plaintiff,

v.

CERTIFICATE OF SERVICE

PO KERSTARS, ET AL.
Defendants.
I hereby certify that on June 29,2011, I caused a true and correct copy of
Claimants MAS, Inc. and Ultra Safe Pay, LLC's Notice ofMotion to Admit Counsel Pro Hac
Vice, Affidavit of Adam B. Michaels, and exhibits annexed thereto to be served via First Class
Mail.Service was made on following counsel:
Michael Fred Bachner
Bachner & Associates, P.C.
26 Broadway , Suite 2310
New York, NY 10004

Jason Harris Cowley
U.S. Attorney's Office, SDNY
One St. Andrew's Plaza
New York, NY 10007

Attorneys for Defendant LST Financial,
Inc.

Attorneys for Plaintiff United States of
America

Elizabeth Nicole Warin
Cozen O'Connor
45 Broadway
New York, NY 10006
(212)-883-4969

Michael Dennis Lockard
United States Attorney Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007

Attorneys for Defendant Tiltware LLC

Attorneys for Plaintiff United States of
America

~--~

iclalllB. Michaels