Unites States v. Pokerstars, et al

Filing 299

DECLARATION of AUSA Jason H. Cowley in Support re: 203 MOTION to Strike Document No. 62 (Claim of Cardroom International).. Document filed by United States Of America. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Cowley, Jason)

Exhibit C

U.S. Department of Justice
United States Attorney
Southern District ofNew York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007

December 14,2012
BY HAND
Honorable Kimba M. Wood
United States District Judge
United States Courthouse
500 Pearl Street, Room 1910
New York, NY 10007

Re:

United States v. Pokerstars, et al.,
11 Civ. 2564 (KMW)

Dear Judge Wood:
Please find enclosed proposed stipulated orders of settlement (the "Settlements") regarding
the following parties:
1.

Claimant/Defendant Howard Lederer;

2.

Claimant Ultra Safe Pay, LLC; and

3.

Claimant MAS, Inc.

Pursuant to the Settlements, these three parties have agreed to forfeit certain property to the
United States (collectively, the "Forfeited Property"). Claimant/Defendant Lederer also agrees to
the payment of certain funds relating to the in personam civil money laundering penalty claim
alleged against him in the second amended complaint.

Because at least one other claimant, Cardroom International, has arguably asserted a claim
to the Forfeited Property, the Government shall maintain the Forfeited Property, or any funds
resulting from the liquidation of the Forfeited Property, in a seized asset account until such claims
are resolved.

Respectfully submitted,
PREET BHARARA
United States Attorney for the
Sou hem District ofNew York

By:

s nH. Cowley
Assistant United States Attorney
[phone]/2193/2479

cc (cover letter only):
Zachary Kozak, counsel for Cardroom International
Elliot Peters, counsel for Howard Lederer
Jeremy Frey, counsel for Ultra Safe Pay, LLC and MAS, Inc.

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U.S. Department of Justice
United States Attorney
Southern District ofNew York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007

November 16, 2012
BY HAND
Honorable Leonard B. Sand
United States District Judge
United States Courthouse
500 Pearl Street, Room 1650
New York, NY 10007

Re:

United States v, Pokerstars, et al.,
11 Civ. 2564 (LBS)

Dear Judge Sand:
Please find enclosed a proposed stipulated order of settlement (the "Settlement") regarding
claimant/defendant Rafael Furst and related claimant Telamonian Ajax Trust (the "Trust"). As part
of the settlement, Furst and the Trust agree to forfeit all funds held in a particular account in
Switzerland (the "Trust Account Funds").

Because at least one other claimant, Cardroom International, has asserted a claim to the Trust
Account Funds, the Government shall maintain the Trust Account Funds in a seized asset account
until such claims are resolved.

Respectfully submitted,
PREET BHARARA

By:

cc (cover letter only):
Zachary Kozak, counsel for Cardroom International
David Angeli, counsel for Rafael Furst and Telamonian Ajax Trust

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