Docusign Envelope ID: 00782DF1-527D-4551-A87A-38E581F7867C 

IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

WESTERN DIVISION 

UNITED STATES OF AMERICA Case No. 1:18-CR-109-1 

v. Judge Douglas R. Cole 

ANDREY SHUKLIN, 

Defendant. 

SETTLEMENT AGREEMENT 

WHEREAS, on May 12, 2022, the Couit entered a Preliminary Order of Forfeiture (Doc. 

240) finding that all right, title, and interest in the following property ("Real Prope1ty") had been 

forfeited to the United States pursuant to 18 U.S.C. § 1963(m): 

Real property known and numbered as 3370 Hidden Bay Drive #814, 

Aventura, Florida 33180 with all appurtenances, attachments, and 

improvements attached thereon, which is legally described as: 

Condominium Unit No. 814, of 100 Hidden Bay Condominium, a 

Condominium according to the Declaration thereof, as recorded in Official 

Records Book 19034, at Page 4250, as amended, of the Public Records of 

Miami-Dade County, Florida. 

Record Owner: Tatiana Rakhmaninova 

Parcel Id: 2822030573180; 

WHEREAS, the United States published notice of this forfeiture action and of its intent to 

dispose of the Real Prope1ty in accordance with the law on an official government forfeiture 

internet site (www.forfeiture.gov) for at least 30 consecutive days, beginning on June 17, 2022 

(Doc. 307); 

WHEREAS, the United States sent direct written notice of the Preliminary Order of 

Forfeiture to all persons who reasonably appeared to be a potential claimant with standing to 

contest the forfeiture of the Real Property in the ancillary proceeding, including Independent Van 

Case: 1:18-cr-00109-DRC Doc #: 311 Filed: 10/03/24 Page: 1 of 4 PAGEID #: 2205
Docusign Envelope ID: 00782DF1-527D-4551-A87A-38E581F7867C 

Lines, LLC and Tatiana Rakhmaninova (Doc. 306); 

WHEREAS, on June 10, 2022, Tatiana Rakhmaninova and Independent Van Lines, LLC 

("Petitioners") filed a verified petition and claim asse1ting an interest in the Real Prope1ty (Doc. 

249); 

AND WHEREAS, no other person or entity has filed a petition with the Comt asserting 

any interest in the Real Property or objecting to its proposed forfeiture, and the time to do so has 

expired. Therefore, the only paities who could have an interest in the Real Prope1ty at the 

conclusion of the ancillary proceeding are before the Comt. 

NOW THEREFORE, in the interest of fully resolving their respective interests in the Real 

Prope1ty in all aspects and to avoid the expenses and risks of further litigation, the United States 

and Petitioners (together "the Patties") HEREBY STIPULATE AND AGREE that: 

1. On or before December 1, 2024, Petitioners shall pay to the United States a total of 

Thi1ty-Six Thousand, Four Hundred Eighty-One and 58/100 Dollars ($36,481.58) in the form of a 

check made payable to the "United States Marshals Service" and delivered to the United States 

Attorney's Office, Attn: Matthew C. Singer, Assistant U.S. Attorney, 221 East Fourth Street, Suite 

400, Cincinnati, Ohio 45202. 

2. The payment of the $36,481.58 to the United States shall be in full settlement and 

satisfaction of any and all claims, demands, rights, and causes of action relating to the Real 

Prope1ty in this case. 

3. The $36,481.58 will be substituted for the Real Property named in the Preliminary 

Order of Forfeiture (Doc. 240) and held by the United States Marshals Service for forfeiture in 

lieu of the Real Prope1ty pending fmther order of the Court. 

4. By signing this Settlement Agreement, Petitioners agree to the entry of a Final 

Order of Forfeiture against the $36,481.58, which will forfeit all their right, title, and interest in 

2 

Case: 1:18-cr-00109-DRC Doc #: 311 Filed: 10/03/24 Page: 2 of 4 PAGEID #: 2206
Docusign Envelope ID: 00782DF1-527D-4551-A87 A-38E581F7867C 

the funds to the United States in accordance with 18 U.S.C. § l 963(m). 

5. Petitioners agree to release and hold harmless the United States, and any agents, 

servants, and employees of the United States (or any state or local law enforcement agency) acting 

in their individual or official capacities, from any and all claims, demands, rights, and causes of 

action of whatsoever kind and nature, whether known or unknown, which they may have or later 

acquire against the United States and its agents, servants, and employees on account of the same 

subject matter that gave rise to the above-captioned action, including any future claim or lawsuit 

of any kind or type whatsoever, whether for compensatory or exemplary damages, all with respect 

to the Real Property. 

6. The Parties agree that each patty shall bear its own costs and attorneys' fees. 

Petitioners further agree to waive any and all rights they may have to recover attorneys' fees under 

the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412, the Civil Asset Forfeiture Reform Act 

(CAFRA), 28 U.S.C. § 2465, or any other legal or statutory basis, with regard to the Real Property. 

7. For the purpose of construction, this Settlement Agreement shall be deemed to have 

been drafted by the Parties and shall not, therefore, be construed against any patty in any 

subsequent dispute including, but not limited to, any proceedings to enforce the terms of this 

Settlement Agreement. 

8. This Settlement Agreement contains the entire agreement between Petitioners and 

the United States. 

9. This Settlement Agreement may be executed in several counterpatts, with a 

separate signature page for each party. All such counterparts and signature pages, together, shall 

be considered one document. 

10. Unless specifically directed by an order of the Comt, Petitioners shall be excused 

and relieved from fmther patticipation in this case. 

3 

Case: 1:18-cr-00109-DRC Doc #: 311 Filed: 10/03/24 Page: 3 of 4 PAGEID #: 2207
Docusign Envelope ID: 00782DF1-527O-4551-A87A-38E581F7867C 

11 . The Patties agree that the United States District Com1 for the Southern District of 

Ohio, Western Division shall retain jurisdiction of this action to enforce this Settlement 

Agreement. 

Date: 

10/1/2024 

Date: 

110/1/2024 

Date: 

4 

KENNETH L. PARKER 

United States Attorney 

WC. SINGER( 

Assistant United States Attorney 

Attorneys for Plaintiff 

221 East Fomth Street, Suite 400 

Cincinnati, Ohio 45202 

(513) 684-3711 

Matthew.S inger@usdoj .gov 

Q

DocuSigned by: 

r ea-Uff1,,&<, 7('~~.,e,, 

5399815E4675440 ... 

TATIANA RAKHMANINOVA 

Individually and as Owner and Manager of 

INDEPENDENT VAN LINES, LLC 

Petitioners 

Christopher Cavallo (Fla. Bar 0092305) 

Nelson Mullins Riley & Scarborough LLP 

2 S. Biscayne Blvd., Suite 2100 

Miami, Florida 33131 

305.373.9400 

chris.cavallo@nelsonmullins.com 

Attorney for Petitioners Tatiana Rakhmaninova 

and Independent Van Lines, LLC 

Admitted Pro Hae Vice 

Case: 1:18-cr-00109-DRC Doc #: 311 Filed: 10/03/24 Page: 4 of 4 PAGEID #: 2208