UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

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

UNITED STATES OF AMERICA,

Plaintiff,

vs.

REAL PROPERTY LOCATED AT

900 BISCAYNE BLVD UNIT #6107,

MIAMI, FLORIDA 33132,

Defendant In Rem.

/

AGREED MOTION TO APPROVE SETTLEMENT AGREEMENT

The United States of America submits this Agreed Motion to Approve Settlement 

Agreement between the United States and Nathalie Bumba-Pembe (“Claimant”) (collectively, the 

“Parties”). In support of its motion, the United States submits as follows:

1. On June 12, 2020, the United States filed a Verified Complaint for Forfeiture in 

Rem (the “Complaint”) against Real Property Located at 900 Biscayne Blvd Unit #6107, Miami, 

Florida 33132 (“Defendant Property”). See Compl., ECF No. 1. On June 23, 2020, the Complaint 

was duly posted on the door of the Defendant Property. ECF No. 4. Notice of Civil Forfeiture 

was posted on an official government internet site (www.forfeiture.gov) for at least 30 consecutive 

days as required by Rule G(4)(a)(iv)(C) of the Supplemental Rules for Admiralty or Maritime 

Claims and Asset Forfeiture Actions. ECF No. 27.

2. On August 28, 2020, Claimant filed a Verified Claim and Statement of Interest as 

the sole titleholder of the Defendant Property, ECF No. 9, and on September 18, 2020, filed an 

Answer and Affirmative Defenses, ECF No. 12.

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3. On October 22, 2020, the Parties filed an Agreed Motion to Authorize Interlocutory

Sale of the Defendant Property, ECF No. 13, in which the Parties agreed that the net proceeds of 

the sale of the Defendant Property (“Net Proceeds”), to include any refund of taxes paid in 

connection with the sale, would be substituted as the res in this civil forfeiture action. The Court 

entered an order granting the motion on the same day, ECF No. 14. 

4. Per the Court’s order, the Defendant Property was sold, and, on November 2, 2020,

the Net Proceeds were transferred to HSI and the IRS.1

5. The time for filing other claims has expired and no other claims have been filed.

6. Consistent with the sound policy favoring settlement of legal disputes without

resort to unnecessary litigation, the United States and Claimant have entered into a Stipulation and 

Agreement (“Agreement,” ECF No. 28-1), which does not constitute an admission of guilt, 

fault, liability, and/or any form of wrongdoing on the part of the Claimant. Moreover, as part 

of the Agreement, the United States and Claimant agreed to return approximately $250,000 of 

the Net Proceeds to the Claimant, with the remainder of the Net Proceeds forfeited in their 

entirety to the United States. 

7. After Court approval of the subject Agreement, the United States will move for

entry of final judgment of forfeiture and any other appropriate order to effectuate the Agreement. 

WHEREFORE, the United States requests that this Court grant this Motion, and for such 

other and further relief as the Court deems just and proper. 

1

 The funds transferred to the IRS represent “those withheld under the Foreign Investment 

in Real Property Tax Act (‘FIRPTA’),” which Claimant agreed, if they were “later released or 

refunded . . . shall be remitted to the United States and shall become a part of the net proceeds and 

the substitute res.” Aff. of Nathalie Bumba-Pembe, ECF No. 13-1. 

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Respectfully submitted,

Dated: August 2, 2021 JUAN ANTONIO GONZALEZ

ACTING UNITED STATES ATTORNEY

SOUTHERN DISTRICT OF FLORIDA

BY: /s Adrienne E. Rosen

 Adrienne E. Rosen 

 Assistant United States Attorney

DEBORAH CONNOR

CHIEF

MONEY LAUNDERING & 

ASSET RECOVERY SECTION

BY: /s Shai D. Bronshtein

 Shai D. Bronshtein 

 Trial Attorney

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