[PROPOSED] CONSENT JUDGMENT

CHRISTINA A. SNYDER, District Judge.

The Court, having reviewed the Stipulation for Entry of Consent Judgment, and good cause appearing therefor,

IT IS HEREBY ADJUDICATED AND DECREED:

1. This Court has subject matter jurisdiction over this civil action, and personal jurisdiction over Defendant Kouam.

2. Defendant Kouam admits to all factual allegations set forth in the Complaint.

3. Defendant Kouam shall pay to the United States $323,510.54. This amount includes $241.388.63 in principal and $82,121.91 in fees.

4. Payment Provision: From March 1, 2018, to March 1, 2020, Defendant Kouam shall make a payment of $1,000.00 toward the balance of $323,510.54 payable every month.

5. On March 1, 2020, the entire debt will be due and payable in full.

6. If any part of the debt remains due after March 1, 2020, the United States will send Defendant Kouam a Financial Disclosure Statement. Defendant Kouam shall complete the Financial Disclosure Statement within thirty (30) days of receipt, and will return the completed statement to the United States Attorney's Office, Financial Litigation Section, together with his tax returns for the past two years.

7. After reviewing the Financial Disclosure Statement, the United States will contact Defendant Kouam regarding the amount of acceptable monthly payments to be made in the following year.

8. Until the parties agree on the amount of acceptable monthly payments set forth in paragraph 7, Defendant Kouam shall continue to make monthly payments of $1,000.00 until advised, in writing by the United States Attorney's Office, of an alternative payment schedule.

9. Defendant Kouam shall make payments at https://www.pay.gov to the U.S. Department of Justice account, in accordance with instructions provided to Defendant by the Financial Litigation Section of the United States Attorney's Office for the Central District of California. Defendant Kouam shall make payments on the first day of every month. A payment is considered delinquent if it is more than fifteen (15) days late.

10. Default Provision: If Defendant Kouam's monthly payments are delinquent on three or more months in any consecutive, twelve-month period, the United States may, in its sole discretion and without the obligation to seek authorization from the Court, initiate enforcement action(s) against Defendant Kouam to collect payments on this judgment.

11. Defendant Kouam waives any judicial challenge to the United States' decision to act under the Default Provisions except Defendant Kouam will retain the right to make a judicial challenge based solely upon evidence that Defendant Kouam was not delinquent on three or more months in any consecutive twelve-month period. Defendant Kouam will provide written notice, with documentary evidence and a declaration, evidencing the fact that Defendant Kouam was not delinquent on three or more months in any consecutive twelve-month period to the United States at least five (5) court days prior to filing any judicial challenge.

12. The United States will record this judgment pursuant to 28 U.S.C. § 3201, against Defendant Kouam. The United States shall take no additional action to enforce this judgment against any of the defendants in this action unless Defendant Kouam is delinquent on three or more months in any twelve-month period.

13. Defendant Mobile XL, LLC, a business entity, is hereby dismissed from this action with prejudice.

14. Defendant Kouam will not be subject to any prepayment penalties. Defendant Kouam shall retain the ability, at any time after the entry of this Consent Judgment, to offer lump sum discounted amount to settle the remaining obligation in full.

15. Defendant Kouam shall provide the United States with written notification of any material change to his financial condition, employment, residence, or telephone number within ten (10) days of such change.

16. If Defendant Kouam commences any case, proceeding, or other action under any law relating to bankruptcy or for relief from debts, Defendant Kouam will not argue, contend or otherwise take the position that Defendant Kouam's obligations under the stipulated consent judgment may or should be avoided. Additionally, Defendant Kouam will not challenge, in such proceeding, the United States' right to file a proof of claim setting forth the balance due and owing at the time of the filing of such case, proceeding or other action, inclusive of any post-judgment accruals of interest, fees and penalties.

17. Each party will bear his or its own legal and other costs incurred in connection with this matter.

IT IS SO ORDERED.