Unites States v. Pokerstars, et al

Filing 32

MOTION for L. Barrett Boss to Appear Pro Hac Vice. Document filed by Filco Ltd., Kolyma Corporation A.V.V., Mail Media Ltd., Pocket Kings Consulting Ltd., Pocket Kings Ltd., Ranston Ltd., Tiltware LLC, Vantage Ltd.(pgu)

UNITED STATES DISTRICT
SOUTHERN DISTRICT OF NEW YORK
United States of America,
Plaintiff,
-against-

0

11 Civ. 2564 (LBS)
MOTION
TO ADMIT COUNSEL
PRO HAC VICE

PokerStars, et al.,
Defendants.

N

PURSUANT TO RULE 1.3(c) of the Local Rules of the United States District
Courts for the Southern and Eastern Districts ofNew York, I, Elizabeth Nicole Warin, a
member in good standing of the bar of this Court, hereby move for an Order allowing the
admission pro hac vice of the following applicant, in order to represent the defendants
Tiltware LLC, Kolyma Corporation A.V.V., Pocket Kings Ltd., Pocket Kings Consulting
Ltd., Filco Ltd., Vantage Ltd., Ranston Ltd., and Mail Media Ltd.:

(
r--:.

=
0 '

L. Barrett Boss
Cozen 0' Connor
1627 I Street, NW, Suite 1100
Washington, D.C. 20006
Ph: [phone]
Fax: [phone]
[e-mail]

C:'

.

_,,
C'

z
.

;-<

As set forth in the annexed affidavit, Mr. Boss is a member in good standing of
the Bars ofthe District of Columbia and State ofMaryland, and there are no pending
disciplinary proceeding against him in any State or Federal court. Further, he has been
retained to represent Defendants Tiltware LLC, Kolyma Corporation A.V.V., Pocket
Kings Ltd., Pocket Kings Consulting Ltd., Filco Ltd., Vantage Ltd., Ranston Ltd., and
Mail Media Ltd. in this proceeding.

L.

c:

v·--

-o

-''i'i..
·~..t. ...

..

(_,;)

w

U1

.
,..

::)

l

:

~~·":;;

'\

~:-.:

1

Dated: July 8, 2011
New York, New York

Eliz eth N. W arin
ENW2269
Cozen 0' Connor
45 Broadway, 161h Floor
New York, NY 10006
Phone [phone]
Fax [phone]
[e-mail]

UNITED STATES DISTRICT
SOUTHERN DISTRICT OF NEW YORK
11 Civ. 2564 (LBS)
United States of America,
Plaintiff,
-againstPokerStars, et al.,

AFFIDAVIT OF
ELIZABETH NICOLE W ARIN
IN SUPPORT OF MOTION
TO ADMIT COUNSEL
PRO HAC VICE

Defendants.

State of New York

)
) SS:
County ofNew York )
Elizabeth Nicole Warin, being duly sworn, hereby deposes and says as follows:
1.
I am of counsel at Cozen O'Connor, counsel for Defendants Tiltware LLC,
Kolyma Corporation A.V.V., Pocket Kings Ltd., Pocket Kings Consulting Ltd., Filco
Ltd., Vantage, Ltd., Ranston Ltd., and Mail Media Ltd., [hereafter "Tiltware et al."] in the
above captioned action. I am familiar with the proceedings in this case. I make this
statement based on my personal knowledge of the facts set forth herein and in support of
Tiltware et al. 's motion to admit Mr. L. Barrett Boss as counsel pro hac vice to represent
Tiltware et al., in this matter.

2.
I am a member in good standing of the bar ofthe State ofNew York and was
admitted to practice law in 1998. I am also admitted to the bar ofthe United States
District Court for the Southern District of New York, and am in good standing with this
Court.
3.
I have known Mr. Boss since 2010. Mr. Boss is a member of Cozen O'Connor,
in Washington D.C .. , and a member in good standing of the Bar of the District of
Columbia, and the State of Maryland, as evidence by the attached certificates, annexed
hereto as Exhibit A.
4.
I have found Mr. Boss to be a skilled attorney and a person of integrity. He is
experienced in Federal practice and is familiar with the Federal Rules of Procedure.
5.

Accordingly, I am pleased to move the admission of L. Barrett Boss pro hac vice.

6.
I respectfully submit a proposed order granting the admission of L. Barrett Boss
pro hac vice, which is annexed hereto as Exhibit B.

WHEREFORE it is respectfully requested that the motion to admit L. Barrett
Boss pro hac vice, to represent Defendants Tiltware et al., in the above captioned matter,
be granted.
Dated: July 8, 2011
New York, New York
Respectfully submitted,

Eli~l·W/M'
ENW2269
Cozen 0' Connor
45 Broadway, 16th Floor
New York, NY 10006
Phone[phone]
Fax [phone]
[e-mail]

Subscribed and sworn to before me this
State of New York
County ofNew York

f)::_ day oft y, · 1:
2
"'-

)
)
)

(

ota~y

Public

CHRISTOPHER B. KENDE
Notary Public, State of New York
No.02KE5043833
Qualified In New York County
Commiasion Expires .IUIJ241 2b11

~ istrid of Qlolumhht Qlood of J\pptetls
C1Iommit±tt on J\omiszious

if ~trcct, ~••. .as4mgtou, :!§. QI.

43D

~om 123

2DDD1

202 I 879-2710

I, J'ULIO .Jt. CYSTIL.£0, C[erk of tfie 'District of Co[umGia Court of
.Jtyyeafs, ao fiereGy certify tfiat
L. 'B.Jt'R'R'ETT (13.JtRRY)

was on tfie

llnr

aay of

APRIL,

13055

1986

------------------------------------

c[u[y qua[ifieaanaaamitteaas an attorney anacounse[or anaentit[eato yractice
Gefore tfiis Court ana is, on tfie aate incficatea Ge[ow, an active memGer in gooa
standing of tfiis 'Bar.

In Testimony Wfiereof, I fiave
fiereunto suGscriGeamy name ana
affixea tfie sea[of tfiis Court at tfie
City ofWasfiington, 'D.C., onJune
30, 2011.

J'ULIO A . C'.J\.S'Ji£.£.0
C[erk cf tfie Court

~·-aK;;

'By:

~'-----

Ql:ourt of ~peal~
of ;f!lat!'lanb
~nnapoli~, J~rm

CERTIFICATE OF GOOD STANDING
STATE OF MARYLAND, ss:
I, Bessie M. Decker, Clerk of the Court ofAppeals ofMaryland,

do hereby certify that on the thirteenth day ofJune, 1995,

having first taken and subscribed the oath prescribed by the Constitution and
Laws of this State, was admitted as an attorney ofsaid Court, is now in good
standing, and as such is entitled to practice law in any of the Courts of said
State, subject to the Rules of Court.

lfn

'Utt~timonp

Wbtrtof,

I have hereunto
set my hand as Clerk, and affixed the Seal
of the Court ofAppeals ofMaryland, this
thirtieth day ofJune, 2011.

Clerk of the Court ofAppeals ofMaryland

UNITED STATES DISTRICT
SOUTHERN DISTRICT OF NEW YORK
11 Civ. 2564 (LBS)
United States of America,
Plaintiff,

ORDER FOR ADMISSION PRO
HAC VICE ON WRITTEN
MOTION

-againstPokerStars, et al.,
Defendants.

Upon the motion of Elizabeth Nicole Warin, attorney for Defendants Tiltware
LLC, Kolyma Corporation A.V.V., Pocket Kings Ltd., Pocket Kings Consulting Ltd.,
Filco Ltd., Vantage, Ltd., Ranston Ltd., and Mail Media Ltd., and said sponsor attorney's
affidavit in support;

IT IS HEREBY ORDERED that
L. Barrett Boss
Cozen 0' Connor
1627 I Street, NW
Suite 1100
Washington, D.C. 20006
Ph: [phone]
Fax: [phone]
[e-mail]

is admitted to practice pro hac vice as counsel for in the above captioned 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, counsel 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 ofNew York

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

CERTIFICATE OF SERVICE

I hereby certify that on this 8th day of July 2011, I caused this (1) Motion to
Admit L. Barrett Boss, Pro Hac Vice, (2) the Affidavit in support thereof, and (3) a
proposed Order to be served on the following counsel, by forwarding the same to them,
by First Class U.S. Mail, addressed as follows:

Attorneys for the Plaintiff United States ofAmerica
AUSA Jason Harris Cowley
AUSA Michael Dennis Lockard
Office of the United States Attorney, S.D.N.Y.
One St. Andrew's Plaza
New York, NY 10007
Attorneys for Defendant LST Financial, Inc.
Michael Fred Bachner
Bachner & Associates, P.C.
26 Broadway, Suite 2310
New York, NY 10004
Attorneys for Chad Elie
William Rakestraw Cowden
Steven J. McCool
Mallon & McCool, LLC
1776 K Street, N.W., Suite 200
Washington, D.C. 20006
Attorneys for Ultra Safe Pay, LLC and MAS, Inc.
Adam Benjamin Michaels
Jeremy D. Frey
Pepper Hamilton, L.L.P.
1180 Avenue ofthe Americas, 14th floor
New York, NY 10036