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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 STATUS REPORT

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

(“Plaintiff”) (collectively, the “Parties”) hereby file this Joint Status Report and, together, move 

the Court for a stay of 30 additional days from the date of this report – or until June 1, 2021 – of 

all deadlines in this case while the Parties continue to negotiate an agreement in principle to resolve 

this matter. In support of this request, the Parties state as follows: 

1. On March 30, 2021, the Parties filed a Joint Motion to Stay Proceedings in order to 

facilitate continued negotiations towards an agreement in principle to resolve this matter. The 

Parties requested a stay of all deadlines until June 1, 2021.

2. On April 6, 2021, this Court entered an order granting in part and denying in part 

the Joint Motion to Stay Proceedings. This order stayed the proceedings until May 1, 2021, and 

directed that the Parties file by that date a joint status report detailing the Parties’ negotiation 

efforts, including whether the Parties will require an additional stay of proceedings in 

contemplation of said efforts.

3. With respect to the Parties negotiation efforts, the Parties have been diligently 

engaged in good faith negotiations and are progressing towards a settlement. However, the Parties 

note that additional time is necessary in order to reach an agreement.

Case 1:20-cv-22427-MGC Document 21 Entered on FLSD Docket 04/30/2021 Page 1 of 4
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4. Therefore, 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.

5. 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 

Parties will promptly inform the Court and file a Joint Scheduling Report and Joint Proposed 

Scheduling Order no later than June 15, 2021.

6. This request of the Court 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: April 30, 2021 Respectfully submitted, 

/s/ Evelyn Baltodano-Sheehan_____ 

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

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

/s/ Shai Bronshtein ___ 

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 21 Entered on FLSD Docket 04/30/2021 Page 2 of 4
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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

Attorneys for Claimant Nathalie BumbaPembe

Case 1:20-cv-22427-MGC Document 21 Entered on FLSD Docket 04/30/2021 Page 3 of 4
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CERTIFICATE OF SERVICE

I hereby certify that, on April 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/ Evelyn Baltodano-Sheehan 

 Evelyn Baltodano-Sheehan

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

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