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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,

Plaintiff,

v.

ONE GULFSTREAM G-V JET AIRCRAFT
DISPLAYING TAIL NUMBER VPCES, ITS
TOOLS AND APPURTENANCES,

Defendant.
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Civil Action No.: 1:11-cv-01874-RC


JOINT STATUS REPORT REGARDING LIMITED EXPEDITED DISCOVERY

On March 4, 2014, this Court entered an order granting in part and denying in part the
United States Motion to Compel, for Limited Expedited Discovery, and to Stay Consideration
of Claimants Motion to Dismiss (the Order). See ECF 41. In the Order, the Court denied the
United States motion to compel Claimants Teodoro Nguema Obiang Mangue (Vice President
Nguema) and Ebony Shine International, Ltd. (Ebony Shine and with Nguema, the
Claimants) to Supplement their Responses to the United States Special Interrogatories and
denied its Motion to Stay. However, the Court granted the Governments request for limited
expedited discovery to ascertain Nguemas purported interest in the Aircraft, which would
determine whether he has standing to contest the Governments forfeiture action. ECF No. 46.
In so doing, the Court gave the United States leave to take up to two depositions and to serve
document requests. The Court directed that this discovery be completed by May 5, 2014.
I. The Deposition of Claimant Vice President Nguema
On May 12, 2014, the parties filed a joint status report concerning the expedited
discovery. ECF No. 47. In that joint status report, the parties notified the Court that in light of
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its May 9, 2014 Order granting Vice President Nguemas Motion for a Protective Order
regarding the notice of his deposition (ECF No. 45), the United States would take Vice President
Nguemas deposition via videoconference to ascertain his purported interest in the Gulfstream
Jet. Thereafter, the parties agreed that the videoconference deposition would take place on June
9, 2014. On June 4, the United States formally noticed the Videoconference Deposition of
Teodoro Nguema Obiang Mangue.
During this same time period, the parties began engaging in serious and meaningful
settlement discussions. As a result, counsel for Claimants requested, and the United States
agreed, to postpone Vice President Nguemas deposition. On June 6, the United States withdrew
the June 4 Notice of Videoconference Deposition of Teodoro Nguema Obiang Mangue, making
clear that it would issue an amended deposition notice if necessary.
As of the date of this filing, the parties continue to engage in productive settlement
negotiations. If a settlement cannot be reached, however, the parties have agreed that the
videoconference deposition of Vice President Nguema will take place no later than July 11,
2014.
II. Claimants Supplemental Production of Documents
On March 7, 2014, the United States served its First Sets of Requests for Production of
Documents in accordance with the expedited discovery Order on Claimants Nguema and Ebony
Shine. Each claimant served Objections and Responses to those Requests on the United States
on April 10, 2014, and made an initial production on that date. Claimants then supplemented
their production on April 15.
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The United States served its Second Sets of Requests for Production of Documents on
Vice President Nguema and on Ebony Shine on April 23. Claimants served their Objections and
Responses to those Requests on the United States on May 1.
On May 9, counsel for Claimants and for the United States participated in a telephonic
meet and confer to discuss certain of Claimants Responses to the United States Requests for the
Production of Documents relating to Claimants standing. At the conclusion of the telephonic
meet and confer, Claimants agreed to search for additional documents responsive to certain of
the United States requests and to supplement their production if any such documents exist.
Claimants will make any supplemental production prior to Claimant Nguemas deposition.

Respectfully submitted,

DATED: June 13, 2014 JAIKUMAR RAMASWAMY
CHIEF, ASSET FORFEITURE AND
MONEY LAUNDERING SECTION

/s/ Stephen A. Gibbons_____________________
DANIEL H. CLAMAN, Assistant Deputy Chief
WOO S. LEE, Trial Attorney (D.C. Bar No. 486004)
STEPHEN A. GIBBONS (D.C. Bar No. 493719)
Trial Attorney
ASSET FORFEITURE AND MONEY
LAUNDERING SECTION
CRIMINAL DIVISION
UNITED STATES DEPARTMENT OF JUSTICE

Attorneys for Plaintiff
United States of America

DATED: June 13, 2014 QUINN EMANUEL URQUHART & SULLIVAN, LLP


By /s/ Duane R. Lyons______________
Duane R. Lyons
Brian M. Wheeler
Attorneys for Claimants Vice President Teodoro Nguema
Obiang Mangue and Ebony Shine International, Ltd.
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