UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

UNITED STATES OF AMERICA,

Plaintiff,

vs.

REAL PROPERTY LOCATED AT 

900 BISCAYNE BLVD UNIT #6107,

MIAMI, FLORIDA 33132,

Defendant In Rem.

_______________________________________/

NOTICE OF VERIFIED COMPLAINT FOR FORFEITURE IN REM 

AGAINST REAL PROPERTY

To: NATHALIE BOUMBA PEMBE, AND ALL OTHER PERSONS WHO MAY CLAIM 

INTEREST IN THE DEFENDANT PROPERTY

1. DATE OF NOTICE: June 12, 2020

2. FORFEITURE COMPLAINT: On June 12, 2020, the United States of America 

filed a Verified Complaint for Forfeiture In Rem seeking forfeiture, pursuant to 18 U.S.C. § 981, 

in the United States District Court for the Southern District of Florida against the defendant 

property commonly known as 900 Biscayne Blvd Unit #6107, Miami, Florida 33132, legally 

described as follows:

Condominium Parcel No. 6107 in 900 BISCAYNE BAY, a 

Condominium, according to the Declaration thereof recorded 

April 23, 2008 in Official Record Book 26340, Page 0882, of 

the Public Records of Miami-Dade County, Florida, as 

amended and/or supplemented from time to time, together with 

an undivided interest in the common elements appurtenant

thereto.

a/k/a 900 Biscayne Boulevard #6107, Miami, FL 33132-1729

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PARCEL IDENTIFICATION NO.: 01-3231-069-3350

3. FILING OF A VERIFIED CLAIM: Pursuant to Rule G(5)(a)(ii) of the 

Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, in order to 

avoid forfeiture of the defendant property, any person who asserts an interest in the defendant 

property must file a verified claim within 35 days after the date of this notice or the date of 

delivery, if personally served.

4. CONTENTS OF VERIFIED CLAIM: Pursuant to Rule G(5)(a), the claim must 

(A) identify the specific property claimed; (B) identify the claimant and state the claimant’s interest 

in the property; and (C) be signed by the claimant under penalty of perjury (see 28 U.S.C. § 1746).

5. FILING OF AN ANSWER: If you file a verified claim, you must then file an 

answer to the complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure within 

20 days after filing the verified claim.

6. FILING WITH COURT AND SERVICE ON UNITED STATES: The verified

claim and answer must be filed with the Office of the Clerk, United States District Court for the 

Southern District of Florida, Wilkie D. Ferguson Jr., U.S. Courthouse, 400 North Miami Avenue, 

Room 8N09Miami, FL 33128, and a copy of the claim and answer or motion must be sent to 

Adrienne Rosen, Assistant United States Attorney, 99 NE 4th Street, 7th Floor, Miami, Florida 

33132.

7. In accordance with 18 U.S.C. § 985(c)(1)(B), this Notice shall be posted on the 

defendant property and served on the property owner, along with a copy of the Verified Complaint 

for Forfeiture In Rem.

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Failure to follow the requirements set forth above may result in judgment by default 

taken against you for the relief demanded in the Complaint. You may wish to seek legal 

advice to protect your interests.

DATED: June 12, 2020 DEBORAH CONNOR, CHIEF

MONEY LAUNDERING & ASSET RECOVERY 

SECTION

Woo S. Lee, Deputy Chief

Shai D. Bronshtein, Trial Attorney

Teresa C. Turner-Jones, Senior Trial Attorney

Criminal Division

United States Department of Justice 

1400 New York Avenue NW

Washington, DC 20005

Telephone: (202) 616-5950

Shai.Bronstein@usdoj.gov

ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

BY: /s/ Adrienne E. Rosen

Adrienne E. Rosen

Assistant United States Attorney

Court ID No. A5502297

U.S. Attorney’s Office 

99 NE 4th Street, 7th Floor

Miami, Florida 33132

Telephone: (305) 961-9338

Facsimile: (305) 536-4089

Adrienne.Rosen@usdoj.gov

Attorneys for Plaintiff

UNITED STATES OF AMERICA

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