Pauline Antoine El Deeb v. Susan Curda

Filing 17

CONSENT JUDGMENT FOR DENIAL OF NATURALIZATION by Judge Beverly Reid O'Connell that Plaintiff and Defendant accept as true the allegations contained in USCIS 4/20/2016, decision denying El Deeb's Form N-400, Application for Naturalization. The parties accordingly have entered into a Settlement Agreement that resolves this matter. Based on this Agreement, and because there is no genuine issue as to any material fact, the Parties: (SEE ATTACHMENT FOR FURTHER DETAILS). (MD JS-6. Case Terminated.) (jp)

JS-6

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CHAD A. READLER
Acting Assistant Attorney General
Civil Division
WILLIAM C. PEACHEY
Director
GISELA A. WESTWATER
Assistant Director
SHEREASE PRATT (NY Bar No. 2620912)
Trial Attorney
United States Department of Justice
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION

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Pauline Antoine El Deeb,

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Plaintiff,

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v.
Susan Curda, Director of Los
Angeles District Office, U.S.
Citizenship and Immigration
Services,

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Defendant.

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CASE NO. 2:16-cv-08416-BRO-MRW
CONSENT JUDGMENT FOR
DENIAL OF NATURALIZATION

Hon. Beverly Reid O’Connell

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Plaintiff Pauline Antoine El Deeb (“Plaintiff”) and Defendant Susan Curda,
Director, Los Angeles District Office, United States Citizenship and Immigration
Services (“USCIS”) (together, the “Parties”) accept as true the allegations
contained in USCIS’s April 20, 2016, decision (“USCIS’s Decision”) denying El
Deeb’s Form N-400, Application for Naturalization. The parties accordingly have

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entered into a Settlement Agreement (“Agreement”) that resolves this matter. See
Ex. A – Settlement Agreement. Based on this Agreement, and because there is no

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genuine issue as to any material fact, the Parties:
(i)

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consent to an Order (“Order”) that denies El Deeb’s application for
naturalization under 8 U.S.C. § 1427(a)(1) and (a)(3), and 8 U.S.C.

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§ 1429 [Immigration and Nationality Act (“INA”) sections 316(a)(1)

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and (a) (3) and 318], based on lack of lawful admission and lack of

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good moral character;

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(ii)

consent to the issuance of a Notice to Appear for Ms. El Deeb under
8 U.S.C. § 1182(a)(6)(c)(i) [INA section 212(a)(6)(c)(i)], for fraud
and willful misrepresentation, thereby initiating proceedings to
remove Ms. El Deeb from the United States.

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Upon entry of this consent judgment, USCIS will execute a Notice to
Appear to be filed by the Department of Homeland Security (“DHS”) with the

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Executive Office for Immigration Review, by which El Deeb stipulates to the
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charges presented against her in the Notice to Appear: 8 U.S.C. § 1227(a)(1)(A)
[INA § 237(a)(1)(A)] and 8 U.S.C. § 1182(a)(6)(C)(i) [INA 212(a)(6)(C)(i)]; i.e.,
that Ms. El Deeb was inadmissible when she obtained her conditional Lawful
Permanent Resident status and at the time the conditions were removed because
she sought to procure, and/or had procured, a visa or other immigration benefit by

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fraud or by willfully misrepresenting material facts.
El Deeb retains the right to an immigration hearing before an immigration

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judge, and retains any right she might otherwise have to apply for asylum,
withholding of removal, protection under the Convention Against Torture, and/or
any other form of relief from removal, which the immigration judge may grant or

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deny in accordance with the applicable provisions of the Immigration and
Nationality Act. El Deeb agrees to provide notice to the DHS of any change of

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address within five (5) business days and understands that she may be required to
report to the DHS periodically, or may be visited by DHS periodically, during any
period in which she is not detained.
El Deeb is represented by legal counsel in this case who has explained her
rights and responsibilities to her as contained in this consent judgment. El Deeb

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agrees to the denial of her United States citizenship freely, knowingly, voluntarily,
without duress or compulsion of any kind from USCIS or any other individual or

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entity, and with full knowledge of the consequences.
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August 22, 2017

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CERTIFICATE OF SERVICE
I hereby certify that on August 21, 2017, I electronically filed the foregoing
Consent Judgment for Denial of Naturalization with the Clerk of the Court by
using the CM/ECF system, which will provide electronic notice and an electronic
link to the same to the following attorneys of record:

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David M. Sturman Law Offices
16530 Ventura Boulevard Suite 412
Encino, CA 91436
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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/s/ Sherease Pratt
SHEREASE PRATT
Senior Litigation Counsel
United States Department of Justice

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