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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.

/

JOINT MOTION TO STAY PROCEEDINGS

Claimant Nathalie Bumba-Pembe (“Claimant”) and Plaintiff United States of America 

(“Plaintiff”) (collectively, the “Parties”) hereby jointly move the Court for a stay of 60 days from 

the date of this joint motion – or until June 1, 2021 – of all deadlines in this case while the Parties 

negotiate an agreement in principle to resolve this matter. In support of this joint motion, the 

Parties state as follows:

1. On February 24, 2021, the Court entered an Order of Referral which provided, in 

part, that counsel for the Parties were to participate in a Scheduling Conference on or before March 

22, 2021, as well as file a Joint Scheduling Report and Joint Proposed Scheduling Order on or 

before April 12, 2021.

2. The Parties are diligently working to negotiate and reach an agreement in principle 

to resolve this matter, including conducting ongoing and extensive settlement discussions. The 

Parties anticipate that they will be able to successfully reach an agreement.

3. The Parties respectfully submit that, in the interest of justice, the preservation of 

judicial and financial economy, and to allow time for the undertaking of negotiating to resolve this 

matter, a stay of all deadlines until 11:59 p.m. on Tuesday, June 1, 2021 is warranted.

4. The Parties further respectfully submit that if, at the end of the requested stay 

period, they have been unable to reach an agreement in principle to resolve this matter, then the

Case 1:20-cv-22427-MGC Document 19 Entered on FLSD Docket 03/30/2021 Page 1 of 4
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Parties will promptly inform the Court and file a Joint Scheduling Report and Joint Proposed 

Scheduling Order no later than June 15, 2021. 

5. This joint motion is made in good faith and not for purposes of delay, and the 

granting of the relief requested herein is supported by good cause and will not prejudice the Court 

or any of the parties to this action.

WHEREFORE, the Parties respectfully request that the Court issue an order staying all 

deadlines in this matter until 11:59 p.m. on Tuesday, June 1, 2021. 

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1(a)(3)

I hereby certify that, in accordance with Local Rule 7.1(a)(3), the undersigned have 

conferred with all counsel regarding the issues raised herein, and all counsel join in this motion. 

Date: March 30, 2021 Respectfully submitted,

/s/ Adriana Riviere-Badell

Adriana Riviere-Badell

adriana.riviere-badell@kobrekim.com

201 South Biscayne Blvd. 

Suite 1900 

Miami, FL 33131 

Tel: +1 305 967 6117 

Fax: +1 305 967 6120 

Robin Rathmell

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

/s/

Shai Bronshtein, Trial Attorney

shai.bronshtein@usdoj.gov

United States Department of Justice 

1400 New York Avenue NW 

Washington, DC 20005 

Tel: +1 202 616 5950 

Adrienne Rosen

adrienne.rosen@usdoj.gov

Assistant United States Attorney 

Court ID No. A5502297

99 Northeast Fourth Street, 7th Floor 

Miami, Florida 33132 

Tel: +1 305 961 9338 

Attorneys for Plaintiff United States of 

America

Case 1:20-cv-22427-MGC Document 19 Entered on FLSD Docket 03/30/2021 Page 2 of 4
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Evelyn Baltodano-Sheehan 

evelyn.sheehan@kobrekim.com

201 South Biscayne Blvd.

Suite 1900

Miami, FL 33131

Tel. +1 305 967 6112

Fax. +1 305 967 6120

Attorneys for Claimant Nathalie BumbaPembe

Case 1:20-cv-22427-MGC Document 19 Entered on FLSD Docket 03/30/2021 Page 3 of 4
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CERTIFICATE OF SERVICE

I hereby certify that, on March 30, 2021, I electronically filed the foregoing document with 

the Clerk of the Court using the CM/ECF system. I further certify that the foregoing document is 

being served on all counsel of record via transmission of Notices of Electronic Filing generated by 

CM/ECF.

/s/ Adriana Riviere-Badell

Adriana Riviere-Badell

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

Adriana Riviere-Badell 

adriana.riviere-badell@kobrekim.com

Evelyn Sheehan 

evelyn.sheehan@kobrekim.com

Robin Rathmell 

robin.rathmell@kobrekim.com

Jason Michael Short 

jason.short@kobrekim.com

Case 1:20-cv-22427-MGC Document 19 Entered on FLSD Docket 03/30/2021 Page 4 of 4