CONSENT JUDGMENT OF NATURALIZATION REVOCATION

JOHN F. WALTER, District Judge.

Plaintiff United States of America and Defendant Grace Mao, a/k/a Guoqing Mao (collectively "the Parties") accept as true the allegations contained in the Complaint to Revoke Naturalization. See Dkt 1. The Parties accordingly have entered into a Settlement Agreement ("Agreement") that resolves this matter.1 See Ex. A — Settlement Agreement.

Based on this Agreement, the Court finds that the facts as alleged in the Complaint have been proven. The Parties consent to an Order Entering Judgment of Naturalization Revocation ("Order") that:

(i) accepts as true the allegations in the Complaint;

(ii) revokes Defendant's United States citizenship;

(iii) cancels Certificate of Naturalization No. 28187772 issued in the name of Grace Mao;

(iv) forever restrains and enjoins Defendant from claiming any rights, privileges, or advantages under any document which evidences United States citizenship obtained as a result of her naturalization;

(v) voluntarily rescinds any claim to any lawful immigration status in the United States that Defendant may claim she possesses as a result of evidence of lawful permanent residence that she unlawfully obtained through Robert Schofield or obtained otherwise;

(vi) requires Defendant to surrender and deliver (to undersigned Plaintiff's counsel by hand or overnight commercial courier to the below-indicated Washington, D.C. address for Plaintiff's counsel within seven (7) days of entry of the order resulting from the above-described Consent Judgment) her Certificate of Naturalization No. 28187772 issued in the name of Grace Mao; any and all United States passports in Defendant's possession issued to Defendant under the name Grace Mao or any other name she has used, whether valid or expired; and any other indicia of United States citizenship or lawful permanent residence status (and to make good faith efforts to recover and then surrender to undersigned Plaintiff's counsel any copies thereof that she knows are in the possession of others); and

(vii) allows the United States to issue a Notice to Appear for Defendant, thereby initiating removal proceedings against her, if she fails to comply with the terms of the Agreement, including those addressing rescission of her lawful permanent residence status; fails to timely act as required by the Agreement to secure any and all documents needed to effectuate her departure from the United States; fails to depart the United States within one hundred and twenty (120) days of the execution of rescission of any lawful permanent resident status she may claim; or if she becomes removable for any other reason prior to departure.

Defendant is represented by legal counsel in this case, who has explained to her her rights and responsibilities pursuant to this Consent Judgment. Defendant agrees to the terms of this Consent Judgment freely, knowingly, voluntarily, without duress or compulsion of any kind from the United States or from any other individual or entity, and with full knowledge of the consequences.

The Parties waive all rights to seek judicial review or otherwise contest the validity of the Order, and Defendant waives any right that may arise under the Equal Access to Justice Act, 28 U.S.C. § 2412. Each party will bear its own costs and fees incurred in this action.

The Parties agree that the Court shall retain jurisdiction of this matter for purposes of construction, modification, and enforcement of the Order.

SO ORDERED.