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If ineligible, the Plaintiff agrees to dismiss the 8 U.S.C. §1503 claim within 7 days of being informed in 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Case No.:0:19-cv-01236-PJS-BRT  \nPatrick J.SchiltzUnited States District Judge  \n# SETTLEMENT AND RELEASE OF ALL CLAIMS\n\nIt is hereby stipulated by and between the undersigned Plaintiff,Mark Gilbert Esqueda,and Defendant,Michael R.Pompeo,U.S.Secretary of State,by and through their respectiveattorneys,as follows:  \n1.The parties do hereby agree to settle and compromise each and every claim of any kind,whether known or unknown,arising directly or indirectly from the acts or omissions thatgave rise to the above-captioned action under the terms and conditions set forth in thisStipulation for Compromise Settlement and Release ofall Claims (Settlement Agreement).  \n2.As part of the resolution,based on recently uncovered evidence,the Department of State(DOS or the Department)acknowledges that Plaintiff is now able to meet his burden ofestablishing by the preponderance of the evidence that Mark Gilbert Esqueda was born inTexas,and that Mark Gilbert Esqueda is a U.S.citizen.  \na.Plaintiff agrees to dismiss all claims against Defendant with prejudice,with eachparty bearing its own costs and fees.Within 60 days of the date of execution ofthis agreement,Plaintiff will submit to DOS a new passport application(Form DS-  \n11)that is unexecuted,but signed by Plaintiff;a new passport photo of Plaintiff;and a copy of the front and back of a valid government identification card.  \nb.The Department acknowledges that Mark Gilbert Esqueda has now met his burdenof proving U.S.citizenship under 22 C.F.R.§51.40 and identity under 22 C.F.R.§  \n51.23.If Mark Gilbert Esqueda is eligible to receive a U.S.passport pursuant to 22  \nC.F.R.§§51.60-61 and 22 U.S.C.§212a,DOS will issue Mark Gilbert Esqueda aU.S.passport book within 60 days of receipt of Plaintiffs passport application andsupporting documentation (described above in section 2(a)).In the event thatPlaintiff is ineligible to receive a U.S.passport under 22 C.F.R.§§51.60-61 and 22  \nU.S.C.§212a,Plaintiff agrees to dismiss his 8 U.S.C.§1503 claim against theDepartment within 7 days of being informed of his ineligibility in writing.  \n3.This Settlement Agreement is not,and is in no way intended to be,and shall not beconstrued as,an admission of liability or fault on the part of Defendant,its agents,servants,or employees,and it is specifically denied that it is liable to Plaintiff.All parties enter intothis Settlement Agreement for the purpose of settling his claim under 8 U.S.C.§1503 andavoiding the expenses and risks of further litigation.  \n4.Plaintiff acknowledges the restrictions on the use of this Settlement Agreement imposedby Federal Rule of Evidence 408.  \n5.Except as provided for in section 2(b),Plaintiff agrees to dismiss this case in its entiretywith prejudice,including all claims against all named defendants,within 7 days of receiptof the passport book.  \n6.The parties agree to bear their own costs and attorney fees,and to forego any request forsuch costs or fees under the Equal Access to Justice Act,28 U.S.C.§2412,or any otherstatute,rule,or legal doctrine.Plaintiff also agrees he willnot initiate any litigation withrespect to claims under the Equal Access to Justice Act,28 U.S.C.§2412,stemming fromthe instant litigation.Plaintiff understands that he is waiving all claims,known orunknown,which may arise with respect to seeking any fees or costs from any defendant inthe above-captioned matter.  \n7.This Settlement Agreement contains the entire agreement between the parties hereto.Plaintiff acknowledges and agrees that no promise or representation not contained in thisSettlement Agreement has been made to him,and acknowledges and represents that thisSettlement Agreement contains the entire understanding between the parties to thisSettlement Agreement and contains allterms and conditions pertaining to the compromiseand settlemen","cbCaieoknD5Q007n","https://ap.wps.com/l/cbCaieoknD5Q007n","pdf",66657,"English","# Settlement and Release of All Claims\n## Parties and Case Information\n## Agreement to Settle and Dismiss Claims\n## Citizenship, Identity, and Passport Process\n## No Admission of Liability and Evidentiary Restrictions\n## Entire Agreement, Modification, and Signing","[{\"question\":\"What is the purpose of the Settlement and Release of All Claims agreement?\",\"answer\":\"The agreement settles the Plaintiff’s claim under 8 U.S.C. §1503 and avoids the expenses and risks of further litigation.\"},{\"question\":\"What must the Plaintiff do as part of the resolution?\",\"answer\":\"The Plaintiff must dismiss claims with prejudice and, within 60 days of execution, submit a new passport application (Form DS-11), a new passport photo, and copies of identification documents.\"},{\"question\":\"How does the agreement handle passport eligibility and dismissal timelines?\",\"answer\":\"If eligible, the Department will issue a U.S. passport book within 60 days of receiving the application and documentation. If ineligible, the Plaintiff agrees to dismiss the 8 U.S.C. §1503 claim within 7 days of being informed in writing.\"}]","Settlement and Release of All Claims | PDF",1789823690]