Unites States v. Pokerstars, et al

Filing 95

STIPULATION AND ORDER: MAS, Inc. answer to the Amended Complaint due 11/30/2011; Ultra Safe Pay, LLC answer to the Amended Complaint due 11/30/2011. (Signed by Judge Leonard B. Sand on 11/1/2011) (cd)

-_

..

USDSSDNY
DOCUMENT
ELECTRONICALLY FILED
DOC#: __________--­
DATE FILED: \ , .- \ - \ l

UNITED STATES
ISTR CT COURT
SOUTHERN DISTRICT OF NEW YORK

-x
UNITED STATES OF AtvlERICA,
Plaintiff,

- v. ­
11 Civ. 2564

(L8S)

POKERSTARS, et al,;
Defendants;
ALL RIGHT, TITLE AND ~NTEREST IN
THE ASSETS OF POKERSTARS, et al.,
Defendants-in rem.

x
il 14, 2011,

WHEREAS, cn or about
complaint,

11 Cjv. 2564

(L88)

1 in the United State
Dis~r

laint U

(the

a verif ed
)

wa

Dis riet Court for the So

filed under
hero

ct of New Ycrk seeking the forfeiture of certain properties

(the "Subject Proper

) pursuant to Title 18, United States

Code, Sections 1955(d),
seeking

981(a) (1) (A),

and 981(a) (ll (Cl, and

ivil money laundering penalties pursuant to Title 18,

United States Code,
WHEREAS,

Section 1956 against PokerStars and others;
on

r about June 21, 2011, claimant MAS, In .,

filed aVer f ed Claim asserting an ownership interest in All
Funds Formerly 8n

Hawaii,

it at Hawa i

In Account Number 1200865

f

NatIon]

BanJ.r.,

Honolu i u,

Held in the Name of MAS,

DC. ;

WHEREAS,
Pay,

LLC f

o~

about June 21,

led a Verif ed Claim as ert

2011,

claimant U tra Safe

an ownership

ntere

I

I

I

n A1l Funds formerly On Deposit at UMPQUA Bank, Ro eburq,
Oregon,

in Account Number 972402309,

Held in the Name

[Ultra

Safe Pay;
on or about SepterEber 21,

'fJHEREAS,

amended complaint in this action

01, a verified

(the "Amended

filed seeking the forfeiture of the Subject

amp aint")

rty and seeking

civi2 money laundering penalties pursuant to Title 18,
States Code,

Sect on 1956 against MAS,

was

United

Inc and Ultra Safe Pay

LLC;
WHERElI.S, NAS,

LLC each has

Inc. and Ultra Safe

requested addit anal time to answer or otherwise respond to the
Complaint;
NOW,

THEREFORE,

IT IS HEREBY ST PULATED AND AGREED

and betl.;een the United States of America,
Bharara,

by its attorney Preet

United States Attorney for the Southern District of New

Jason H. Cowley, Assistant United States Attorney,

York,

counse ,

and NAS,

Inc. and Ultra Safe

attorney, Adam B. Michaels,
r

Ham lton LLP,
M.n.S,

until Ncvember

and Jeremy D.

by their
Frey,

Amended Complaint.

Esq.,

of

that:
Inc. and Ultra Safe Pay,

LLC each

v, 201l, to answer or otherwise re

')(1

.~

, LLC,

of

1 have
t

t

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 istrict of New York

_.JGil LIII(

By:

DATE

New York, New York
[phone]

MAS INC. and ULTRA SAFE PAY,

LLC

BY'~.~~

(~/~/ /r/
DATE

Pepppr Ham i 1. ton 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, Pe~nsylvania 19103

(215)

981-4DDO

Counsel for

~'lAS

SO~

Inc. and Ultra Safe Pay,

&­

HONORABLE LEONARD B. SAND
UNITED STATES DISTRICT JUDGE
3

LLC