Unites States v. Pokerstars, et al
Filing
94
STIPULATION AND ORDER, Chad Elie answer to complaint due 11/30/2011. (Signed by Judge Leonard B. Sand on 11/1/2011) (cd)
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,;
USI";Y
s;
De
. DOC:,
ALL RIGHT, TITLE AND INTEREST IN
THE ASSETS OF POKERSTARS, et al.,
i
ELEC;
, ''IT
, J
N'ICALLY FILED
DOC;:
DATI I ! LED: \ \ - i - \ l
Defendants-in-rem.
-x
April 14, 2011, a verified
WHEREAS, on or
int, 11 Ci v. 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
(the \\
ect Propert
) pursuant to Title 18,
t
rt
States
Code, Sections 1955(d), 981(a) (1) (A), and 981(a) (1) (C), and
seeking civil money laundering
nalties
to Tit
18,
United States Code, Section 1956 against PokerStars and others;
WHEREAS, on or about June 15, 2011, claimant Chad Elie
fi
owne
a Veri
Claim to De
/possess
s In Rem asserting an
interest in certain Subject Properties,
including the following:
1.
account numbered 121015408 held at Sunfirst Bank,
St. George, Utah, in the name of Triple Seven LP
d/b/a Netwebfunds.com, and all funds traceable
thereto;
2.
account numbered 121015390 held at Sunfirst Bank,
s
St. George, Utah, in the name of Tr
d/b
A WEB DEBIT,
all
thereto;
LP
e
3.
account numbered 27351910081015 held at
ete
Generale
s LTD, Cyprus,
the name of Golden
Shores Properties L
ted,
all
traceable
thereto;
4.
account numbe
CY1211501001065983USDCACC002 held
at FBME Bank LTD, Cyprus,
n the name of Tr le
Seven Inc., and all funds traceable
reto;
5.
account numbered 5510045221 held at Wells Fargo,
N.A.,
the name of T
e Seven L.P., and all
funds traceable thereto;
6.
account numbered 7478010312 held at Wells Fargo,
N.A., in the name of Kombi C
tal, and all funds
traceable thereto;
7.
account numbered 12900584 held at Sunfirst Bank,
St. Geo
, Utah, formerly in the name of Sunfirst
Bank ITF Powder Monkeys/Full Tilt, now in the name
of Sunfirst Bank, and all
s traceable thereto;
8.
account numbered 129000576 on deposit at Sunfirst
Bank, St. George, Utah, formerly in the name of
Sunfirst Bank ITF Mastery Merchant/Psars, now in
the name of Sunfirst Bank, and all funds traceable
t
reto;
9.
account numbered 200003291 held at All American
Bank, Des Plaines, III
is, in the name of 21
Debit LLC, and all funds traceable thereto;
10. account numbered 200003317 held at All American
Bank, Des Plaines, Illinois, in the name of 21
Debit LLC, and all funds traceable thereto;
11. account numbered 200003325 held at All
can
Bank, Des Pines, Illinois, in the name of 21
t LLC,
all funds traceable thereto;
12. Account numbered 200003309 held at All American
Bank, Des Plaines, III
s, in the name of 21
Debit LLC, and all funds traceable thereto;
2
13. account number 201002907 at Barcl
the name of Hotwire
nancial LLC,
traceable thereto;
Bank, UK in
all funds
14. account number GB26BARC20473563472044 at Barclays
Bank, UK, in the name of
re
ial LTD,
and all funds traceable t
15. account number 953500105 at Bank One Utah, in the
name of 4 A Consulting, and all funds traceable
thereto;
16. account
32433 at New City Bank in the
name of 21Debit LLC dba PS Payments, and all funds
traceable t
0;
17. account numbered 32441 at New City Bank in the
name of
t LLC dba FLT Payments, and all
funds
e thereto;
18. account number 32506 at New City Bank in the name
of 21
it LLC,
all funds traceable thereto;
19. $410,449.93 formerly on deposit at Bank of America
Account
229006067857 held in the name of
Vi
. and all property traceable
reto;
20. $8,168,168.89 formerly on deposit at Fifth Third
Bank in Account numbe
7431859508, held in the
name of
able Marketing Corp. and all property
traceable thereto;
21. $40,960.86 formerly on deposit at Fifth Third Bank
in Account numbered 7432618069, held in the name
of
Ie Marketing Corp. and all property
traceable thereto; and
22. $33,743.75 formerly on deposit at Bank of America
Account numbered 003678667131 held in the name of
EZO, LLC and all property traceable thereto;
WHEREAS, on or about September 21, 2011, a verified
amended
see
aint in this action (the "Amended Complaint") was
the forfeiture of the Subject
3
rty and see
viI money laundering penalt
s pursuant to Title 18, United
States Code, Section 1956 against PokerStars and others;
WHEREAS, on or about October 4, 2011, a Stipulation and
Order was entered extending Chad Elie's t
to answer the
Complaint until October 31, 2011;
WHEREAS, Chad Elie has requested additional t
to answer
the Complaint;
NOW, THEREFORE,
IT IS HEREBY STIPULATED AND AGREED by
and between the United States of America, by its at
Bharara, United States Att
for the Southern
Preet
strict of New
York, Jason H. Cowley, Assistant United States Attorney, of
counsel, and Chad Elie, by his attorney, Wil iam R. Cowden, Esq.
of Mallon & McCool, LLC, that:
1.
Chad Elie shall have unti
file an answer to the Complaint.
4
November 30, 2011, to
2.
The signature pages of this St
ion 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.
such s
Signature pages may be by fax and
ures shall be deemed as valid originals.
AGREED AND CONSENTED TO:
PREET BHARARA
United States Attorney
Southern District of New York
By:
~~
Ja~C~.
Assistant United States Attorney
One St. Andrew's Plaza
10007
By:
William R. Cowden, Esq.
Mallon & McCool, LLC
1776 K Street, N.W., Suite 200
Washington, DC 20006
(202) 642-0209
Counsel for Chad Elie
SO ORDERED'
HqN RABLE LEONARD B. SAND
U TED STATES DISTRICT JUDGE
5
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