UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

UNITED STATES OF AMERICA,

Plaintiff,

v. 1:20-cv-23278-MGC

REAL PROPERTY LOCATED AT 7505 AND 7171 

FOREST LANE, DALLAS, TEXAS 75230 et al.,

Defendant.

________________________________________________/ 

UNITED STATES OF AMERICA,

Plaintiff,

v. 1:20-cv-23279-MGC

ALL RIGHT TO AND INTEREST IN PNC CORPORATE 

PLAZA HOLDINGS LLC HELD, CONTROLLED, OR

ACQUIRED, DIRECTLY OR INDIRECTLY, BY OPTIMA 

CBD INVESTMENTS LLC AND/OR CBD 500 LLC, et al.,

Defendant.

________________________________________________/ 

UNITED STATES OF AMERICA,

Plaintiff,

v. 1:20-cv-25313-MGC

REAL PROPERTY LOCATED AT 55 PUBLIC SQUARE,

CLEVELAND, OHIO, et al.

Defendant.

________________________________________________/ 

MOTION FOR CLARIFICATION

The United States hereby requests that the Court clarify its Order Consolidating Cases, 

20-23278 ECF 48 (the “Consolidation Order”). Specifically, the Consolidation Order states

Case 1:20-cv-23278-MGC Document 65 Entered on FLSD Docket 03/19/2021 Page 1 of 3
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that “all previous orders” in case numbers 1:20-cv-23279 and 1:20-cv-25313, other than the 

restraining order entered in 1:20-cv-23279, are “vacated.”

This Court had previously entered an order in case number 1:20-cv-25313, ECF 24, 

allowing the sale of the Defendant Asset, 55 Public Square, Cleveland, Ohio, pursuant to a 

private contract executed before the commencement of the civil forfeiture action (the “Sale 

Order”). The Sale Order also provided that the net proceeds of the sale would be held by the 

United States in escrow pending the outcome of the action, and would constitute the 

substitute res. Per that order, the sale was consummated on February 11, 2021, and the net 

proceeds were deposited with the US Marshals Service. 

To dispel any uncertainty, the United States respectfully requests that the Court clarify 

the Consolidation Order to indicate that the Sale Order remains in force and is not vacated, 

and that the net proceeds constitute the substitute res of this action. 

Pursuant to Local Rule 7.1(a)(3), the government has conferred with counsel for the 

various claimants. Claimants Mordechai Korf, Uriel Laber, Optima 7171 LLC, Optima 

Ventures LLC, Vadim Shulman, Hornbeam Corporation, and Bracha Foundation do not 

oppose the relief sought by this motion. However, claimant Law Offices of Cleveland, Inc. 

opposes the clarification the government seeks.

Respectfully submitted,

Dated: March 19, 2021 DEBORAH CONNOR, CHIEF

MONEY LAUNDERING & ASSET 

RECOVERY SECTION

By: /s/ Shai D. Bronshtein

Shai D. Bronshtein (ID No. A5502665)

Rachel E. Goldstein

Trial Attorneys

Criminal Division

United States Department of Justice 

1400 New York Avenue NW

Washington, DC 20005

Telephone: (202) 616-5950 

Shai.Bronshtein@usdoj.gov

Case 1:20-cv-23278-MGC Document 65 Entered on FLSD Docket 03/19/2021 Page 2 of 3
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ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

/s/ Adrienne E. Rosen

Adrienne E. Rosen (ID No. A5502297)

Marx P. Calderón 

Assistant United States Attorney

US Attorney’s Office

99 Northeast Fourth Street, 7th Floor

Miami, Florida 33132

Telephone: (305) 961-9338

Adrienne.Rosen@usdoj.gov

Case 1:20-cv-23278-MGC Document 65 Entered on FLSD Docket 03/19/2021 Page 3 of 3