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)

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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,; 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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