Unites States v. Pokerstars, et al

Filing 48

MOTION for Leave to File Amended Complaint. Document filed by United States Of America.(Cowley, Jason)

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PREET BHARARA United States Attorney for the Southern District of New York By: SHARON COHEN LEVIN MICHAEL D. LOCKARD JASON H. COWLEY Assistant United States Attorneys One St. Andrew’s Plaza New York, New York 10007 Telephone: (212) 637-1060/2193/2479 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - -x UNITED STATES OF AMERICA, : Plaintiff, : 11 Civ. 2564 (LBS) - v. - : POKERSTARS, FULL TILT POKER, ABSOLUTE POKER, ULTIMATE BET, et al., Defendants; ALL RIGHT, TITLE AND INTEREST IN THE ASSETS OF POKERSTARS, FULL TILT POKER, ABSOLUTE POKER, ULTIMATE BET, et al., : : : : : : Defendants-in-rem. : - - - - - - - - - - - - - - - - - -x NOTICE OF MOTION PLEASE TAKE NOTICE that, upon the Declaration of Michael D. Lockard in Support of Government’s Motion For Leave To File An Amended Complaint, together with the exhibits thereto, the Government’s Memorandum of Law in Support of its Motion For Leave To File An Amended Complaint, and upon all papers and prior proceedings herein, the United States of America will move before the Honorable Leonard B. Sand, United States District Judge for the Southern District of New York, at such time as the Court shall direct, for an order, pursuant to Rule 15 of the Federal Rules of Civil Procedure, granting leave to file the Amended Complaint, attached as Exhibit A to the Declaration of Michael D. Lockard, and such other relief as the Court may determine to be just and proper. Dated: New York, New York September 19, 2011 Respectfully submitted, PREET BHARARA United States Attorney for the Southern District of New York Attorney for the Plaintiff United States of America By: To: /s/ Sharon Cohen Levin Michael D. Lockard Jason H. Cowley Assistant United States Attorneys Telephone: (212) 637-1060/2193/2479 All counsel 2

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