1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:20-cv-22427-MGC

UNITED STATES OF AMERICA,

Plaintiff,

v.

REAL PROPERTY LOCATED AT 900 

BISCAYNE BLVD UNIT #6107, MIAMI, 

FLORIDA 33132,

Defendant In Rem.

/

ANSWER TO VERIFIED COMPLAINT FOR FORFEITURE IN REM ON BEHALF OF 

NATHALIE BUMBA-PEMBE

Claimant Nathalie Bumba-Pembe (“Claimant”), by and through her undersigned counsel, 

hereby answers the Verified Complaint for Forfeiture In Rem (“Complaint”) as follows:1

NATURE OF THE ACTION

1. The allegations in this Paragraph set forth Plaintiff’s legal allegations and its 

characterization of its action, to which no response is required. To the extent a response is required, 

Claimant lacks knowledge or information sufficient to form a belief as to the allegations in this 

Paragraph and, on that basis, denies them.

2. The allegations in this Paragraph set forth Plaintiff’s legal allegations and its 

characterization of its action, to which no response is required. To the extent a response is required, 

Claimant lacks knowledge or information sufficient to form a belief as to the allegations in this 

Paragraph and, on that basis, denies them.

 1 For the avoidance of doubt, any allegation not specifically admitted herein is otherwise denied.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 1 of 17
2

3. The allegations in this Paragraph set forth Plaintiff’s legal allegations and its 

characterization of its action, to which no response is required. To the extent a response is required, 

Claimant lacks knowledge or information sufficient to form a belief as to the allegations in this 

Paragraph and, on that basis, denies them.

4. The allegations in this Paragraph set forth Plaintiff’s legal allegations and its 

characterization of its action, to which no response is required. To the extent a response is required, 

Claimant lacks knowledge or information sufficient to form a belief as to the allegations in this 

Paragraph and, on that basis, denies them.

JURISDICTION AND VENUE

5. This Paragraph consists of conclusions of law, to which no response is required.

6. This Paragraph consists of conclusions of law, to which no response is required.

7. This Paragraph consists of conclusions of law, to which no response is required.

PEOPLE AND ENTITIES

8. Claimant admits the allegations in this Paragraph. 

9. Claimant admits the allegations in this Paragraph. 

10. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

11. Claimant admits that Denis Sassou Nguesso is the President of the Republic of 

Congo and that he has held office since 1979. Claimant lacks knowledge or information sufficient 

to form a belief as to the remainder of the allegations in this Paragraph and, on that basis, denies 

each and every remaining allegation in this Paragraph.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 2 of 17
3

12. Claimant admits that Denis-Christel Sassou Nguesso (“Mr. Nguesso”) 2 is a 

Member of Parliament in Congo and that, from 2001-2009, Mr. Nguesso held various positions 

with Société Nationale de Pétroles du Congo (“SNPC”). Claimant lacks knowledge or information 

sufficient to form a belief as to the remainder of the allegations in this Paragraph and, on that basis,

denies each and every remaining allegation in this Paragraph.

13. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

14. Claimant admits the allegations in this Paragraph.

15. Claimant avers that she is the partner of Mr. Nguesso. Claimant further avers that 

she is titleholder to the Defendant Asset, and therefore holds 100% ownership interest in the 

Defendant Asset.

16. The allegations in this Paragraph set forth Plaintiff’s legal allegations and its 

characterization of its action, to which no response is required. To the extent a response is required, 

Claimant lacks knowledge or information sufficient to form a belief as to the allegations in this 

Paragraph and, on that basis, denies them.

FACTUAL ALLEGATIONS

17. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

18. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

 2 Claimant avers that the official title of Denis-Christel Sassou Nguesso is “Congressman” or Member of Parliament 

(“MP”) and not “Minister.” Nonetheless, in following the structure of the Verified Complaint, this Answer restates 

Plaintiff’s use of the term “Minister” in subsequent section headings. Claimant’s restatement of Plaintiff’s section 

headings is in no way an admission of the contents of those section headings.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 3 of 17
4

19. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

I. Minister Nguesso Was The Gatekeeper to Congo’s Oil Wealth

20. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

21. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

22. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

23. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

24. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

25. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

II. Minister Nguesso Abused His Position at SNPC to Misappropriate Public Funds

26. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

A. Minister Nguesso Misappropriated Money from SNPC.

27. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

28. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 4 of 17
5

29. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

30. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

31. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

32. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

33. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

B. Minister Nguesso Took Bribes and Engaged in Self-Dealing.

34. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

35. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

III. Minister Nguesso Spent Significantly More Money Than He Claimed to Earn

36. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

37. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

38. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 5 of 17
6

39. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

40. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

41. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

42. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

43. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

44. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

45. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

46. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

47. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

48. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

IV. Minister Nguesso Purchased The Miami Property With Funds Traceable To Funds 

He Misappropriated From SNPC

49. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 6 of 17
7

50. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

51. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

52. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

53. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

54. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

55. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

56. Claimant admits that the Defendant Asset is a penthouse condo with floor-to-ceiling 

windows and a view of Miami’s Biscayne Bay, the Atlantic Ocean, and the Miami skyline. 

Claimant further admits that the Defendant Asset has over 3,500 square feet including three 

terraces, three bedrooms, and five bathrooms. Claimant lacks knowledge or information sufficient 

to form a belief as to the remaining allegations in this Paragraph and, on that basis, denies them.

57. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

58. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

59. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 7 of 17
8

60. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

61. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

62. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

63. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

64. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

65. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

66. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

67. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them. 

68. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

69. Claimant admits that the Defendant Asset was transferred to her on September 22, 

2016 by Mr. Nguesso, her partner. Claimant lacks knowledge or information sufficient to form a 

belief as to the remaining allegations in this Paragraph and, on that basis, denies them.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 8 of 17
9

70. Claimant denies each and every allegation set forth in this Paragraph. Claimant 

avers that the transfer of ownership of the Defendant Asset was undertaken in consideration for 

the financial security of Claimant and the minor children of Mr. Nguesso and Claimant. 

71. Claimant denies each and every allegation set forth in this Paragraph. Claimant 

incorporates by reference her response in Paragraph 70 to each and every allegation incorporated 

by Plaintiff in this Paragraph as if fully set forth herein.

V. Minister Nguesso Purchased Other Properties Using A Similar System of 

Misdirection and Nominees

72. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

73. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

74. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

75. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

76. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

77. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

78. Claimant lacks knowledge or information sufficient to form a belief as to the 

allegations in this Paragraph and, on that basis, denies them.

FOREIGN LAW BASIS FOR FORFEITURE

79. This Paragraph consists of conclusions of law, to which no response is required.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 9 of 17
10

80. This Paragraph consists of conclusions of law, to which no response is required.

81. This Paragraph consists of conclusions of law, to which no response is required.

FIRST CLAIM FOR RELIEF

(18.U.S.C. § 981(a)(1)(C))

82. Claimant incorporates her responses to each and every allegation incorporated by 

Plaintiff in this Paragraph as if fully set forth herein.

83. This Paragraph consists of conclusions of law, to which no response is required.

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

84. This Paragraph consists of conclusions of law, to which no response is required.

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

SECOND CLAIM FOR RELIEF

(18 U.S.C. § 981(a)(1)(A))

85. Claimant incorporates her responses to each and every allegation incorporated by 

Plaintiff in this Paragraph as if fully set forth herein.

86. This Paragraph consists of conclusions of law, to which no response is required.

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

87. This Paragraph consists of conclusions of law, to which no response is required. 

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

THIRD CLAIM FOR RELIEF

(18 U.S.C. § 981(a)(1)(A))

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 10 of 17
11

88. Claimant incorporates her responses to each and every allegation incorporated by 

Plaintiff in this Paragraph as if fully set forth herein.

89. This Paragraph consists of conclusions of law, to which no response is required.

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

90. This Paragraph consists of conclusions of law, to which no response is required.

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

FOURTH CLAIM FOR RELIEF

(18 U.S.C. § 981(a)(1)(A))

91. Claimant incorporates her responses to each and every allegation incorporated by 

Plaintiff in this Paragraph as if fully set forth herein.

92. This Paragraph consists of conclusions of law, to which no response is required.

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

93. This Paragraph consists of conclusions of law, to which no response is required. 

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

FIFTH CLAIM FOR RELIEF

(18 U.S.C. § 981(a)(1)(A))

94. Claimant incorporates her responses to each and every allegation incorporated by 

Plaintiff in this Paragraph as if fully set forth herein.

95. This Paragraph consists of conclusions of law, to which no response is required.

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 11 of 17
12

96. This Paragraph consists of conclusions of law, to which no response is required.

To the extent a response is required, Claimant lacks knowledge or information sufficient to form 

a belief as to the allegations in this Paragraph and, on that basis, denies them.

ALLEGATIONS COMMON TO ALL AFFIRMATIVE DEFENSES

1. On information and belief, Claimant alleges this action was not commenced within 

five years after the time when Plaintiff knew or should have known of all or part of the conduct 

constituting the alleged offenses giving rise to this forfeiture, or within two years after the time 

when Plaintiff knew or should have known of the involvement of the Defendant Asset in the 

alleged offenses giving rise to the forfeiture.

2. On information and belief, Claimant alleges, to the extent that the Defendant Asset 

is not traceable directly to any of the alleged offenses giving rise to this forfeiture, this action was 

commenced more than one year from the date of the alleged offenses.

3. On information and belief, Claimant alleges that Plaintiff has incorrectly 

interpreted or otherwise mischaracterized Article 177 and Article 178 of the Penal Code of Congo, 

as well as Article 53 and Article 54 of the Constitution of the Republic of Congo, and, as such, has 

failed to state a foreign law basis for forfeiture of the Defendant Asset. Claimant alleges that 

Plaintiff’s failure to so state a foreign law basis for forfeiture is further evidenced by Plaintiff’s 

failure to append as an Attachment to its Verified Complaint the selected provisions of Congolese 

law upon which it relies for forfeiture.

4. On information and belief, Claimant alleges that Plaintiff’s sprawling, conclusory 

Verified Complaint poses significant risk of impeding upon the legitimate sovereignty of the 

Republic of the Congo, while inappropriately denigrating and intruding upon the governmental 

and administrative affairs of that independent nation. To wit, Plaintiff devotes a substantial portion 

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 12 of 17
13

of the Verified Complaint casting aspersions against the business conducted by SNPC, as well as 

Mr. Nguesso’s purportedly “lavish” lifestyle – including raising allegations involving transactions 

wholly unrelated to the Defendant Asset, such as the chartering of private flights or the purchasing 

of luxury vehicles and designer watches.

FIRST AFFIRMATIVE DEFENSE

(Failure to State a Claim)

5. The Complaint fails to state a claim upon which relief can be granted.

SECOND AFFIRMATIVE DEFENSE

(Due Process; Fifth Amendment)

6. The forfeiture of the Defendant Asset would violate the substantive and procedural 

due process rights guaranteed by the Due Process Clause of the Fifth Amendment to the United 

States Constitution.

THIRD AFFIRMATIVE DEFENSE

(Excessive Fine; Eighth Amendment)

7. The forfeiture of the Defendant Assets would be unconstitutionally excessive and 

would violate the Excessive Fines Clause of the Eighth Amendment.

FOURTH AFFIRMATIVE DEFENSE

(Statute of Limitations)

8. Plaintiff’s claims are barred by the applicable statutes of limitation, as provided in 

18 U.S.C. § 981, 18 U.S.C. § 984(b), and 19 U.S.C. § 1621.

FIFTH AFFIRMATIVE DEFENSE

(Equitable Estoppel)

9. Plaintiff’s claims are barred by the equitable doctrine of estoppel.

SIXTH AFFIRMATIVE DEFENSE

(Innocent Ownership)

10. Claimant is an innocent owner of the res the Plaintiff seeks to seize. 

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 13 of 17
14

SEVENTH AFFIRMATIVE DEFENSE

(Act of State Doctrine)

11. Plaintiff’s Complaint should be dismissed under the act of state doctrine.

EIGHTH AFFIRMATIVE DEFENSE

(International Comity) 

12. Plaintiff’s Complaint should be dismissed, and the Court should abstain from 

exercising jurisdiction, under the principles of international comity.

NINTH AFFIRMATIVE DEFENSE

(Tracing)

13. Plaintiff’s claims are barred by its failure to trace the Defendant Asset under 18 

U.S.C. § 981.

TENTH AFFIRMATIVE DEFENSE

(Subsequently Discovered Defenses)

14. Claimant may discover additional affirmative defenses. Claimant reserves the right 

to assert additional defenses if discovery indicates such defenses would be appropriate.

CLAIMANT’S PRAYER FOR RELIEF

WHEREFORE, Claimant prays for judgment as follows:

1. That Plaintiff’s Complaint be dismissed with prejudice;

2. That Plaintiff’s request for forfeiture of the Defendant Asset be denied and the 

Defendant Asset be released to Claimant;

3. That Claimant be awarded her costs incurred in defending this action as permitted 

by applicable law, including reasonable attorneys’ fees; and

4. For such other and further relief as the Court deems just and proper.

DEMAND FOR JURY TRIAL

In accordance with Rule 38 of the Federal Rules of Civil Procedure, Claimant demands a 

trial by jury on all issues so triable.

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 14 of 17
15

Dated: September 18, 2020 Respectfully submitted,

KOBRE & KIM LLP

/s/ Adriana Riviere-Badell 

Adriana Riviere-Badell 

Adriana.Riviere-Badell@kobrekim.com

Florida Bar No. 30572.

201 South Biscayne Blvd.

Suite 1900

Miami, FL 33131

Tel: +1 305 967 6117

Fax: +1 305 967 6120

Robin Rathmell, Esq. 

Robin.Rathmell@kobrekim.com

1919 M Street, NW

Washington, DC 20036

Tel. +1 202 664 1900

Fax. +1 202 664 1920

Jason Short

Jason.Short@kobrekim.com

800 Third Ave.

Floor 6

New York, NY 10022

Tel. +1 212 488 1200

Fax. +1 212 488 1220

Attorneys for Claimant Nathalie BumbaPembe

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 15 of 17
16

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on September 18, 2020 a true and correct copy of the foregoing 

Answer was electronically filed with the Clerk of the Court using the CM/ECF system which will 

send a notice of electronic filing on all counsel or parties of record on the service list. 

/s/ Adriana Riviere-Badell 

Adriana Riviere-Badell 

Adriana.Riviere-Badell@kobrekim.com

Florida Bar No. 30572.

201 South Biscayne Blvd.

Suite 1900

Miami, FL 33131

Tel: +1 305 967 6117

Fax: +1 305 967 6120

Robin Rathmell, Esq. 

Robin.Rathmell@kobrekim.com

1919 M Street, NW

Washington, DC 20036

Tel. +1 202 664 1900

Fax. +1 202 664 1920

Jason Short

Jason.Short@kobrekim.com

800 Third Ave.

Floor 6

New York, NY 10022

Tel. +1 212 488 1200

Fax. +1 212 488 122

SERVICE LIST

Electronic Mail Notice List

The following is the list of parties who are currently on the list to receive email notice/service for 

this case.

Adrienne E. Rosen

Adrienne.rosen@usdoj.gov

Shai Bronshtein

Shai.bronshtein@crm.usdoj.gov

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 16 of 17
17

Adriana Riviere-Badell

adriana.riviere-badell@kobrekim.com

Robin Rathmell

robin.rathmell@kobrekim.com

Jason Michael Short

jason.short@kobrekim.com

Case 1:20-cv-22427-MGC Document 12 Entered on FLSD Docket 09/18/2020 Page 17 of 17