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4857-9016-4712 v.1 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF OHIO 

WESTERN DIVISION 

UNITED STATES OF AMERICA, 

 Plaintiff, 

v. 

ANDREY SHUKLIN, 

 Defendant. 

Case No. 1:18-cr-109-1 

JUDGE DOUGLAS R. COLE 

_____________________________________ 

VERIFIED PETITION AND CLAIM OF THIRD PARTIES 

TATIANA RAKHMANINOVA AND INDEPENDENT VAN LINES, LLC1

Pursuant to 21 U.S.C. § 853(n)(3), petitioner third-parties, Tatiana Rakhmaninova 

(“Tatiana”) and Independent Van Lines, LLC (“Ind. Van Lines”) (together, “Petitioners”), 

respectfully submit this Verified Petition and Claim (“Verified Petition”) Concerning Preliminary 

Order of Forfeiture [D.E. 240] (“Preliminary Order”), to assert a legal interest in property 

described in the Preliminary Order as “Real property known and numbered as 3370 Hidden Bay 

Drive #814, Aventura, Florida 33180 with all appurtenances, attachments, and improvements 

attached thereon . . .” (“Home”). In support of this Verified Petition, Petitioners state as follows: 

1. This petition is submitted primarily on behalf of Tatiana. 

2. Tatiana is the spouse of Defendant Andrey Shuklin. 

3. Tatiana, in her individual capacity, is the sole owner of the Home. 

4. Tatiana presently lives at the Home with her daughter, and has lived there 

continuously since the Home was purchased in or about April 2015. 

1

 This identical Verified Claim was previously filed in June 2022 at [D.E. 249], which preserved 

Petitioners’ rights. Petitioners refile this Verified Claim only in an abundance of caution, with 

reference to the recently filed Certificate of Service on Motion for Forfeiture at [D.E. 306]. 

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5. Tatiana’s daughter has never lived anywhere else. 

6. The Home is Tatiana’s primary residence and her homestead. 

7. The government is not entitled to forfeiture of the Home as a substitute asset 

because Tatiana became the sole owner of the Home before entry of the Preliminary Order. Tatiana 

also has other legitimate legal interests in the Home and has put substantial personal funds into the 

Home. 

8. The following are additional pertinent facts regarding the nature, extent, time, and 

circumstances of Tatiana’s right, title, and interest in the Home, as required by 18 U.S.C. § 

853(n)(3) and the Court’s Preliminary Order: 

a. On or about March 20, 2015, Tatiana’s father sent her approximately $278,100 as 

a gift for her to use towards a down payment to purchase the Home (“Down 

Payment Funds”). 

b. Tatiana’s father sent the Down Payment Funds to Tatiana at her TD Bank account. 

c. On or about May 5, 2015, Ind. Van Lines, a company owned by Tatiana and 

Defendant Shuklin, obtained a mortgage (“Mortgage”) for $245,000.00 for the 

purchase of the Home. Tatiana is also a manager of Ind. Van Lines. 

d. At or around the same time, Tatiana personally used the Down Payment Funds in 

her TD Bank account to make an approximately $265,000 down payment on the 

Home. 

e. On or about February 1, 2020, Tatiana’s father sent Tatiana a second wire in the 

amount of approximately $270,000.00 as a gift for her to use to make payments on 

the Mortgage and cover her other personal expenses (“Second Wire”). 

f. Tatiana’s father sent the Second Wire to Tatiana at her JPMorgan Chase account. 

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g. On or about December 17, 2020, Ind. Van Lines, of which Tatiana is an owner, 

executed a quit-claim deed in favor of Tatiana, assigning Tatiana alone, in her 

individual capacity, all right, title, and interest to the Home. The quit-claim deed 

was executed with the understanding that Tatiana would pay off the Mortgage in 

full, as soon as possible, as consideration. 

h. On or about December 8, 2021, Tatiana’s father sent Tatiana a third wire in the 

amount of approximately $30,000 as a gift for Tatiana to pay off the Mortgage on 

the Home (“Third Wire”). 

i. Tatiana’s father sent the Third Wire to her JPMorgan Chase account. 

j. On December 16, 2021, Tatiana wired $230,292.95 to the entity that took her 

Mortgage payments, paying off the Mortgage in full. Tatiana used gift funds from 

the Second Wire and Third Wire from her father to pay off the Mortgage. 

k. On May 9, 2022, the government moved for forfeiture of property, including the 

Home. [D.E. 234]. 

l. On May 12, 2022, the Court entered the Preliminary Order. [D.E. 240]. 

m. Tatiana has acted in good faith with respect to the Home, has not attempted to sell 

the Home, and has put nearly $600,000 of her personal funds, much of which was 

gifted from her father, towards paying for the Home. 

9. Based on the foregoing, Tatiana became the sole owner of the Home and obtained 

all right, title, and interest in the Home, in her personal capacity, before entry of the Preliminary 

Order. Tatiana also has other legitimate legal interests in the Home. 

10. In addition, Tatiana asserts her interest in the Home through her interest in Ind. Van 

Lines, insofar as Ind. Van Lines is deemed to have any interest in the Home. 

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WHEREFORE, Petitioners respectfully request that the Court enter an order finding that 

Tatiana, in her individual capacity, is the sole owner of the Home and has all right, title, and interest 

in the Home, and amending the Preliminary Order accordingly. In the alternative, Petitioners 

respectfully request that the Court enter an order finding that Tatiana, in her individual capacity or 

through her interest in Ind. Van Lines, has other bona fide and legitimate interests in the Home, 

amending the Preliminary Order accordingly. 

Dated: September 23, 2024. 

Respectfully submitted, 

NELSON MULLINS 

/s/ Dustin B. Rawlin 

Dustin B. Rawlin, Esq. 

1100 Superior Avenue, Suite 2000 

Cleveland, OH 44114 

Tel.: (216) 304-6153 

dustin.rawlin@nelsonmullins.com 

Christopher Cavallo, Esq. 

2 South Biscayne Blvd., 21st Floor 

Miami, FL 33131 

Tel.: (305) 373-9465 

Fla. Bar No. 0092305 

chris.cavallo@nelsonmullins.com 

Admitted Pro Hac Vice 

Attorneys for Third-Party Petitioners 

Tatiana Rakhmaninova and Independent Van 

Lines, LLC 

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CERTIFICATE OF SERVICE 

The foregoing submission was filed via ECF and will be forwarded by the Court’s 

Electronic Filing System to all counsel of record registered for e-filing. 

/s/ Dustin B. Rawlin 

Dustin B. Rawlin 

Attorneys for Third-Party Petitioners 

Tatiana Rakhmaninova and 

Independent Van Lines, LLC 

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