Unites States v. Pokerstars, et al

Filing 4

ENDORSED LETTER addressed to Judge Robert W. Sweet from Michael D. Lockard dated 04/15/2011 re: As soon as practicable thereafter, the Government will present this letter, if endorsed by the Court, to the appropriate Court personnel so that the Sealed Materials maintained in official Court files can be unsealed. ENDORSEMENT: SO ORDERED. (Signed by Judge Robert W. Sweet on 04/15/2011) (mps)

U.S. Department of Justice
United Stales Attorney
Sourhern District olNew York
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Honorable Robert W. Sweet
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
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April IS, 2011

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UNDER SEAL

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

Dear Judge Sweet,
On April 14, 2011, the Government initiated the above­
captioned in rem forfeiture and money laundering penalty action
by filing a verified complaint (the "Complaint" or "Compl.")
under seal against certain corporate entities as defendants and
certain assets and properties as defendants in rem.
The above
captioned action relates factually to a sealed Indictment, United
States v. Scheinberg, et. al., S3 10 Cr. 336 (LAK)
(the
"Indictment") .
Today, April 15, 2011, the Government anticipates the arrest
of two defendants charged in the Indictment, and once today's
arrests are executed, the Government will no longer need the
Complaint or the identities of the parties in the above-captioned
case to remain under seal.
This is also true of the affidavits
attached to the Complaint as exhibits and incorporated therein
that had been previously placed under seal.
These affidavits
were submitted in connection with the following seizure warrants:
(a) United States v. All funds on deposit at City National
Bank in account number 370117950, held in the name of G.I.
Holdings, and all property traceable thereto, et al., 09
Mag. 1932;

(b) United States v. All funds on deposit, up to and
including $231,000, at First Republic Bank in account number
80000373283, held in the name of G.I. Holdings, and all
funds traceable thereto, 09 Mag. 1974;

Honorable Judge Sweet
April 15, 2011
Page 2

(c) United States v. All funds on deposit at Fifth Third
Bank in account number 7431859508, held in the name of
Viable Marketing Corp., and all property traceable
thereto,
et al., 09 Mag. 2382;
(d) United States v. All funds on deposit at National Bank
of California in account number 2547716 held in the name of
Viable Processing Solutions, and all property traceable
thereto, et al., 10 Mag. 354;
(e) United States v. All funds on deposit at Four Oaks Bank
and Trust Company, Four Oaks North Carolina,
account
number 520055501, held in the name of LST Financial, and all
property traceable thereto, et al., 10 Mag. 1562; and
(f) United States v. $6,152,285.88 in United States currency
on deposit at First Bank of Delaware, Philadelphia,
Pennsylvania, in account numbered 9016139, et al., 10 Mag.
2701.
We refer to these affidavits, along with the Complaint in the
above-captioned matter (including the identity of the parties)
collectively as the "Sealed Materials. n
Accordingly, the Government respectfully requests permission
to disclose and make public the Sealed Mate als immediately
following the execution of one or more arrest warrants in the
Scheinberg matter without further order from the Court. As soon
as practicable thereafter, the Government will present this
letter, if endorsed by the Court, to the appropriate Court
personnel so that the Sealed Materials maintained in offic
Court files can be unsealed.

Honorable Judge Sweet
April 15, 2011
Page 3

Respectfully submitted,
PREET BHARARA
United States Attorney for the
SOUtlh~t of New York
By:
hael D. Lo
ason H. Cowley
ssistant United States Attorneys
,el. [phone]/ 2479
F~ [phone]

Hon.
United States District Judge
Souther District of new York
Part I
Dated:

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