Unites States v. Pokerstars, et al

Filing 63

STIPULATION AND ORDER: MAS, Inc. and Ultra Safe pay, LLC each shall have until October 31, 2011, to answer or otherwise respond to the Amended Complaint. (Signed by Judge Leonard B. Sand on 10/3/2011) (rdz)

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DOCUMENT
ELECTRONICALLY FILED
DOC#: _____________
DATE FILED: ) Q - 3·- j \

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-x

uNITED STATES OF AMERICA,
STIPULATION AND ORDER

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

WHEREAS, on or about April 14, 2011, a verified
complaint, 11 civ. 2564 (LBS)

(the "Complaint") was filed under

seal in the United states District Court for the Southern
District of New York seeking the forfeiture of certain properties
pursuant to Title 18, United States Code, Sections 1955(d),
981 (a) (1) (A), and 981 (a) (1)

(C),

including, but not limited to,

All Funds Formerly On Deposit at Hawaii National Bank, Honolulu,
Hawaii, in Account Number 12008656, held in the Name of MAS, Inc.
(the "MAS Subject Property") and All Funds Formerly On Deposit at
UMPQUA Bank, Roseburg, Oregon, in Account Number 972402309, held
in the Name of Ultra Safe Pay (the "Ultra Safe Pay Subject
property"), and seeking civil money laundering penalties pursuant
to Title 18, united States code, Section 1956 against PokerStars
and others;
WHEREAS, on or about June 21, 2011

1

claimant MAS, Inc.,

filed a Verified Claim asserting an ownership interest in the MAS
Subject Property;
WHEREAS, on or about June 21, 2011, claimant Ultra Safe
Pay, LLC filed a Verified Claim asserting an ownership interest
in the Ultra Safe Pay Subject property;
WHEREAS, on or about September 21, 2011, a verified
amended complaint in this action (the "Amended Complaint") was
filed seeking the forfeiture of, among others, the MAS Subject
property and the Ultra Safe pay Subject Property, and seeking
civil money laundering penalties pursuant to Title 18, United
States Code, Section 1956 against against PokerStars and others;
WHEREAS, MAS, Inc. and Ultra Safe pay LLC have
requested additional time to answer or otherwise respond to the
Amended Complaint;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by
and between the United States of America, by its attorney Preet
Bharara, United States Attorney for the Southern District of New
York, Jason H. Cowley, Assistant United States Attorney, of
counsel, and MAS,

Inc. and Ultra Safe Pay, LLC, by their

attorneys, Adam B. Michaels, Esq. and Jeremy D. Frey, Esq., of
Pepper Hamilton LLP, that:
1.

MAS, Inc. and Ultra Safe pay, LLC each shall have

until October 31, 2011, to answer or otherwise respond to the
Amended Complaint.

2

2.

The signature pages of this Stipulation and Order

may be executed in one or more counterparts, each of which will
be deemed an original but all of which together will constitute
one and the same instrument.

Signature pages may be by fax and

such signatures shall be deemed as valid originals.
AGREED AND CONSENTED TO:
PREET BHARARA

United States Attorney

Southern District of New York

By:
Attorney

One St. Andrew's

New York, New York

[phone]
MAS INC. and ULTRA SAFE PAY, LLC

By:

A~M~~;

DATE

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Pepper Hamilton LLC

The New York Times Building

620 Eighth Avenue

New york, New York 10018-1405

[phone]
Jeremy D. Frey, Esq. (pro hac vice pending)

Pepper Hamilton LLP

3000 Two Logan Square

18th and Arch Streets

Philadelphia, Pennsylvania 19103

[phone]
Counsel for MAS Inc. and Ultra Safe Pay, LLC
SO

OR~ED:

.

Ad.
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HONORABLE LEONARD B. SAND
UNITED STATES DISTRICT JUDGE

DATE

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3

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