Unites States v. Pokerstars, et al

Filing 270

DECLARATION of AUSA Jason H. Cowley in Support re: 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. 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. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Cowley, Jason)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X

UNITED STATES OF AMERICA,
Plaintiff,

- v. 11 Civ. 2564

(LBS)

POKERSTARS, et al.
Defendants;
ALL RIGHT, TITLE AND INTEREST IN
THE ASSETS OF POKERSTARS, et al.;
Defendants-in-rem.

-----------------X
DECLARATION OF JASON H. COWLEY

JASON H. COWLEY, pursuant to the provisions of 28
U.S.C.

§

1746, declares as follows:
1.

I am an Assistant United States Attorney in the

·office of Preet Bharara, United States Attorney for the Southern
District of New York.

I am one of the Assistant United States

Attorneys responsible for representing the Government in the
above-referenced case.

I respectfully submit this declaration in

support of the Government's motion for (1) for the entry of
proposed stipulated order of settlement between the Government
and certain Absolute Poker-affiliated 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 these 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.
2.

Attached hereto as Exhibit A is a true and correct

copy of a declaration executed by Jerry D. Bernstein, a partner
with Blank Rome LLP.
3.

Attached hereto as Exhibit B is a true and correct

copy of a declaration executed by Young Jae Lee, the Chief
Executive Officer of Quad Dimensions, Ltd.

(with facsimile

information redacted) .
4.

Attached hereto as Exhibit C is a true and correct

copy of the declaration (excluding exhibits) of Thomas Steen
Brandi, downloaded from the electronic court docket of the
matter:
In re: Application of Madeira Fjord AS, its bankruptcy
estate, for an Order to Conduct Discovery for Use in a
Foreign Legal Proceeding, Pursuant to 28 U.S.C. § 1782, ·12
Civ. 1465 (N.D. Ill. 2012).
5.

I have spoken with a Deputy U.S. Marshal in the

Southern District of New York, who has informed me that he has
received the disc sent by Mr. Young Jae Lee of Quad Dimensions,
Ltd.
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6.

I have spoken with Maggie Doherty of the U.S.

Marshal Service, Complex Asset Unit.

She has relayed that the

Complex Asset Unit will oversee the liquidation of the assets in
question if the motion for interlocutory sale is granted.

Ms.

Doherty has further relayed that the United States Marshal
Service has the ability to retain a third-party business broker
with industry expertise to market and sell the assets of the
Absolute Poker Settlement Group.
I declare under penalty of perjury that the foregoing
is true and correct.
Dated:

New York, New York
September 21, 2012

Assistant Uni ed States Attorney
therrt District of New York

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