Unites States v. Pokerstars, et al
Filing
77
CLAIM FOR ADMIRALTY OR MARITIME AND ASSET FORFEITURE ACTIONS. Document filed by Steve Segal. (Attachments: # 1 Certificate of Service)(Burt, Thomas)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
- - -x
UNITED STATES OF AMERICA,
Plaintiff,
v.
POKERSTARS; FULL TILT POKER;
ABSOLUTE POKER; ULTIMATE BET;
OLDFORD GROUP LTD.; RATIONAL
ENTERTAINMENT ENTERPRISES LTD.;
PYR SOFTWARE LTD.; STELEKRAM LTD.;
SPHENE INTERNATIONAL LTD.;
TILTWARE LLC; KOLYMA CORPORATION
A.V.V.; POCKET KINGS LTD.; POCKET
KINGS CONSULTING LTD.; FILCO LTD.;
VANTAGE LTD.; RANSTON LTD.; MAIL
MEDIA LTD.; FULL TILT POKER LTD.;
SGS SYSTEMS INC.; TRUST SERVICES
LTD; FIDUCIA EXCHANGE LTD.; BLUE
WATER SERVICES LTD.; ABSOLUTE
ENTERTAINMENT, S.A.; and BLANCA
GAMES, INC. OF ANTIGUA; RAYMOND
BITAR; HOWARD LEDERER; CHRISTOPHER
FERGUSON, a/k/a "JESUS;" and
RAFAEL FURST,
Defendants;
and
ALL RIGHT, TITLE AND INTEREST IN
THE ASSETS OF POKERSTARS; FULL
TILT POKER; ABSOLUTE POKER;
ULTIMATE BET; OLDFORD GROUP LTD.;
RATIONAL ENTERTAINMENT ENTERPRISES
LTD.; PYR SOFTWARE LTD.; STELEKRAM
LTD.; SPHENE INTERNATIONAL LTD.;
TILTWARE LLC; KOLYMA CORPORATION
A.V.V.; POCKET KINGS LTD.; POCKET
KINGS CONSULTING LTD.; FILCO LTD.;
VANTAGE LTD.; RANSTON LTD.; MAIL
MEDIA LTD.; FULL TILT POKER LTD.;
SGS SYSTEMS INC.; TRUST SERVICES
LTD; FIDUCIA EXCHANGE LTD.; BLUE
WATER SERVICES LTD.; ABSOLUTE
ENTERTAINMENT, S.A.; and BLANCA
GAMES, INC. OF ANTIGUA; INCLUDING
Case No.: ll-Civ-2564 (LBS)
BUT NOT LIMITED TO THE PROPERTIES
LISTED IN SCHEDULE A, SUCH AS BUT
NOT LIMITED TO THE DOMAIN NAMES
POKERSTARS.COM; FULLTILTPOKER.COM;
ABSOLUTEPOKER.COM;
ULTIMATEBET.COM; and UB.COM;
ALL RIGHT, TITLE, AND INTEREST IN
THE PROPERTIES LISTED IN SCHEDULE
B; and ALL RIGHT, TITLE, AND
INTEREST IN THE PROPERTIES LISTED
IN SCHEDULE C,
Defendants-in-rem.
- - - - - - - - - - - - -x
CLAIM IN FORFEITURE PROCEEDING PURSUANT TO
SUPPLEMENTAL RULE G(S) FOR ADMIRALTY OR MARITIME AND
ASSET FORFEITURE ACTIONS
Dated: October 19,2011
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
Lawrence P. Kolker
Thomas H. Burt
Beth A. Landes
270 Madison Avenue
New York, New York 10016
Telephone: 212-545-4600
Facsimile: 212-545-4653
Steve Segal, hereinafter referred to as "Claimant", states:
1.
I am one of the named plaintiffs in the civil class action Segal v. Bitar, No. 11-
Civ-4521 (LBS) (S.D.N.Y. June 30, 2011) and represent a putative class of U.S. residents, who
held balances in the Full Tilt Player Accounts ("Player Accounts") on April 15 th , 2011, (the
"Class" or "Claimants") the day that access to the Player Accounts was first denied. In that
action, the Class seeks the return of the $150 million contained in the Player Accounts from
certain individuals who are named in this action.
2.
Pursuant to 18
u.s.c. ยง983(a)(4) and Rule G(5) of the Supplemental Rules for
Admiralty or Maritime Claims and Asset Forfeiture Actions, I, on the behalf of the Class, assert
their right, title and interest in the property listed at Schedule C of the Government's First
Verified Amended Complaint' ("Amended Compl.") and contest the forfeiture of that property,
which contains, as the Government has alleged, the Class Members' funds. 2
3.
The Class hereby lays claim to the U.S. Player Account balances held in the
properly identified five bank accounts listed in Schedule C to the Amended Complaint, or the
funds traceable to the accounts, listed here:
FTP INSIDER ACCOUNTS
(As Alleged in Schedule C to Government's FAC of September 20, 201l)
1. Account numbered GB81 RBOS 609542340877 66 held at NatWest, in the name of
Raymond Bitar, and all funds traceable thereto;
2. Account numbered 7655741861 held at Wells Fargo Bank, N.A., in the name ofHH
Lederer Consulting LLC, and all funds traceable thereto;
3. Account numbered GB56LOYD301663 14010402 held at Lloyds TSB International,
Isle of Mann, in the name of Howard Lederer, and all funds traceable thereto;
4. Account numbered 40039049628 held at Citibank, N.A., in the name of Chris
Ferguson, and all funds traceable thereto; and
5. Account numbered CH87 0875 5057 06840010 0 held at Pictet & Co Bankers,
Switzerland, in the name of Telamonian Ajax Trust, and all funds traceable thereto.
4.
The Claimants' interest in the property is equitable. Class Members have a
rightful and superior interest in the amount of up to $150 million held or traceable to those
accounts. As provided in the Government's First Verified Amended Complaint and as alleged in
, See U.S. v. Pokerstars, et. ai, No. 11-Civ-2564 (LBS) (S.D.N.Y. 2011) ECF No. 53.
2
See /d. at
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?