Chris Ferguson Responds to Full Tilt Poker Complaint



On Tuesday, Nov. 14, Chris Ferguson, through his attorney Jonathan Harris, filed numerous motions with the United States District Court Southern District of New York, including one to bring Ian J. Imrich on board pro hac vice to his defense counsel.

For those unfamiliar with legalese, pro hac vice is Latin for "for this one particular occasion." According to Nolo’s Plain-English Law Dictionary: “The phrase usually refers to an out-of-state lawyer who has been granted special permission to participate in a particular case, even though the lawyer is not licensed to practice in the state where the case is being tried.”

Imrich is a part of the Law Office of Ian J. Imrich, Esq. based out of Los Angeles. As Harris states in the order: “I have found Mr. Imrich to be a skilled attorney and a person of integrity. He is experienced in federal practice and familiar with the Federal Rules of Procedure . . . Accordingly, I am pleased to move the admission of Ian J. Imrich, pro hac vice.”

In addition, Ferguson signed four documents that were submitted to the U.S. Court of Southern District of New York:

One document sites the Supplemental Rules for Admiralty or Maritime Claims and Assets Forfeiture Actions, the same set of laws invoked by Ray Bitar at the end of September, that claims the defendant, in this case Filco Ltd., “has right, title, or interest to all funds in the following accounts.” The document then goes on to list two bank accounts and concludes with “As an authorized agent of claimant Filco Ltd., I, CHRIS FERGUSON, hereby verify that the foregoing facts are true and correct and made under penalty of perjury,” followed by Ferguson’s signature.

The second asserts the same claims as the first, but this time for Vantage LTD. and Kolyma Corporation A.V.V. Also signed by Ferguson, that document went on to state that the aforementioned companies are entitled to the money seized by the Department of Justice, listing several bank accounts totaling $98,276,540.

Like the first two, the remaining documents do the same except for Tiltware LLC. and Pocket Kings Ltd. In the former, Fergsuon, through Tiltware, lays claims to several bank accounts totaling $196,553,080; while in the latter, 11 more bank accounts are named, primarily in Ireland, though amounts are not listed.

What this means is that these various companies, which comprise Full Tilt Poker, claim the funds in the seized banks accounts legally belong to them and that said accounts “contain funds deposited by Full Tilt Poker players to be transferred to Vantage and/or Kolyma or funds deposited by Vantage and/or Kolyma that were in the process of being returned to Full Tilt Poker players.”

The latest filings come on the heels of the Nov. 11, 2011, "waiver of service" by Ferguson, Bitar, Howard Lederer, and Rafe Furst, which meant that they will not need to appear in person to answer the civil complaint. has all of the documents from the Black Friday indictments.

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