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United States v. Rendon

United States District Court, N.D. Illinois, Eastern Division

December 9, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
MARIA VICTORIA RENDON, a/k/a Genoveva Restiepo-Rendon, a/k/a Maria Genoveva Rendon-Restrepo, a/k/a Maria-Genoveva Rendon, a/k/a Genoveva Rendon-Restiepo, a/k/a Genoveva Rendon, a/k/a Maria Rendon, Defendant.

          JOHN R. LAUSCH, Jr. United States Attorney

          CRAIG A. OSWALD Assistant United States Attorney

          JOSEPH H. HUNT Assistant Attorney General Civil Division

          JOHN J. W. INKELES Counsel for National Security U.S. Department of Justice, Civil Division Office of Immigration Litigation

          MATTHEW S. KRIEZELMAN, Esq. Kriezelman Burton & Associates, LLC. Counsel for Defendant

          PLAINTIFF'S NOTICE OF MOTION

         To: MATTHEW KRIEZELMAN, Esq.

         Kriezelman Burton & Associates, LLC.

         200 W Adams Street, Suite 2211

         Chicago, IL 60606

         PLEASE TAKE NOTICE that, on Wednesday, December 18, 2018, at 9:30 a.m., or as soon thereafter as counsel may be heard, Plaintiff, by and through its attorney, JOHN J. W. INKELES, shall appear before Judge Joan H. Lefkow in the courtroom usually occupied by her in the Everett McKinley Dirksen U.S. Courthouse, 219 South Dearborn Street, Chicago, Illinois, or before such other judge who may be sitting in her place and stead, and then and there present the parties' JOINT MOTION FOR ENTRY OF CONSENT JUDGMENT in the above-captioned case, at which time and place you may appear if you see fit.

         Civil Action No. 1:19-cv-7797 (JHL)

         JOINT MOTION FOR ENTRY OF CONSENT JUDGMENT

         Plaintiff the United States of America (“United States”) and Defendant Maria Victoria Rendon, a/k/a Genoveva Restiepo-Rendon, a/k/a Maria Genoveva Rendon-Restrepo, a/k/a Maria Genoveva Rendon, a/k/a Genoveva Rendon-Restiepo, a/k/a Genoveva Rendon, a/k/a Maria Rendon (“Defendant”), jointly move this Court to enter the attached proposed Consent Judgment Revoking Naturalization. This motion is supported by Defendant's admission to, and acknowledgment of the truth of, the specific facts identified below.

         FACTUAL ...


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