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UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, Case No. 15-cv-11887 

 Hon. Matthew F. Leitman 

v. 

HASSAN JAWAD and 

MONROE MOBIL, INC., 

Defendants. 

__________________________________________________________________/ 

CONSENT JUDGMENT

This Consent Judgment is entered into by and between the United States of 

America, Plaintiff, and Defendants, Hassan Jawad and Monroe Mobil, Inc., the 

parties to the Consent Judgment, by and through their respective, undersigned 

counsel. 

WHEREAS, on May 28, 2015, the United States filed its Amended 

Complaint (Docket No. 4) in this case against Hassan Jawad, individually, and 

Monroe Mobil, Inc. (“Defendants”), to obtain a judgment against the Defendants in 

connection with a defaulted loan made by Charter One Bank NA to Monroe Mobil, 

Inc., personally guaranteed by Hassan Jawad, and guaranteed by the U.S. Small 

Business Administration, all as set forth in the Amended Complaint and the 

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Exhibits as initially filed (Docket Nos.1-2 through 1-7), incorporated by reference 

herein; 

WHEREAS, an Answer was filed, a Joint Discovery Plan and Report 

submitted and a Case Management and Scheduling Order issued; and 

WHEREAS, the deposition of Hassan Jawad was taken, discovery concluded 

and settlement negotiations conducted on December 21, 2015; and 

WHEREAS, the parties have consented to the terms and conditions of this 

Consent Judgment as set forth below, and to its entry as evidenced by the approval 

of their undersigned attorneys, and the Court having reviewed this Consent 

Judgment and being otherwise fully advised in the premises, now, therefore; 

IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows: 

1. The Court has jurisdiction under 28 U.S.C. § 1345 because the United 

States is the Plaintiff. 

2. Venue is also proper under 28 U.S.C. § 1391(b)(1) because 

Defendant, Hassan Jawad, resides in the Eastern District of Michigan, and under 

28 U.S.C. §§ 1391(c)(2) and 1391(d) because Defendant, Monroe Mobil, Inc., is 

incorporated under the laws of the State of Michigan, has its principal place of 

business in this district, and its resident agent resides in this district. 

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3. The allegations of the Amended Complaint were well taken, the 

United States had reasonable cause to bring the action, and the position of the 

United States was and is substantially justified as set forth in 28 U.S.C. § 2412. 

4. The parties to this Consent Judgment will not seek attorney fees or 

costs from the United States in connection this case under the Equal Access to 

Justice Act or any other statute, rule or regulation, or otherwise. 

5. The Defendants shall be jointly and severalty liable for, and shall pay 

$77,029.25, without interest (“the Settlement Sum”), to the United States as 

follows: $3,000.00 to be paid within 7 days of the entry of this Consent Judgment, 

and $1,000.00 on the first day of February, 2016 and on the first day of every 

month thereafter until the Settlement Amount is paid in full. Checks should be 

made payable to the U.S. Department of Justice and mailed or delivered to the 

United States Attorney’s Office, Financial Litigation Unit, 211 W. Fort St., Suite 

2001, Detroit, Michigan 48226. The names of the Defendants and Case No. 15-cv11887 should be designated on the face of the checks. 

6. If the Defendants fail to make a required $1,000.00 payment in the 

full amount on or before the first day of the month when due (“the due date”), i.e., 

default, and do not cure the default within five (5) days of the due date, then 

nothing herein shall prevent the United States by and through the Asset Forfeiture 

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Financial Litigation Unit (AFFLU) of the U.S. Attorney’s Office from proceeding 

with any available administrative or judicial remedy to enforce collection of any 

remaining, accelerated balance due on Defendants’ total debt to the United States 

of $103,235.08, as certified by Treasury Fiscal Services on May 13, 2015 (Docket 

No. 1-6). The provisions of this paragraph shall also apply if the Defendants fail to 

make the initial payment of $3,000 in full when due. 

7. If the Defendants are not in default, upon the Defendants’ request and 

at the discretion of the AFFLU, a re-evaluation of the Settlement Sum and the 

Defendants’ ability to pay may be conducted. 

8. If the Defendants are current in their payments toward the Settlement 

Sum, the United States will forebear from any other enforcement or collection 

actions to collect the debt hereunder. 

9. Until the debt is paid in full, whether the Settlement Sum or the total 

debt remaining upon default, the Defendants shall remain in the Treasury Offset 

Program (TOP), and eligible administrative offsets, including Federal tax refunds, 

shall be applied to toward the remaining balance until paid in full. 

10. The Defendants who are signatories to this Consent Judgment release, 

remise and discharge plaintiff, the United States of America, and any of its 

agencies involved in this action and the underlying financial investigation, 

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including the United States Attorney’s Office, the U.S. Department of Treasury, 

Fiscal Management Services, and the U.S. Small Business Administration, their 

agents, officers and employees, past and present, from any claims or causes of 

action which such Defendants, their agents, officers, employees, assignees and/or 

successors in interest have, may have or may have had, in connection with this 

enforcement action or any aspect of the underlying investigation. 

11. The parties to this Consent Judgment have discussed this settlement 

with their counsel, fully understand its terms and conditions, and the consequences 

of entering into it. The parties agree that they shall bear their own costs in this 

matter. 

12. Upon entry of this Consent Judgment, this case shall be 

administratively closed. 

13. Upon motion of the United States, this case may be reopened to 

enforce the terms of the Consent Judgment, or to conclude the case upon payment 

of the Settlement Sum or the remaining total indebtedness, whichever applies, by 

entry of a satisfaction of judgment, or an order of dismissal, or both. 

 

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14. If and to the extent permissible by law, the Court shall retain 

jurisdiction to enforce the terms of the Consent Judgment or to conclude the case. 

 /s/Matthew F. Leitman 

 MATTHEW F. LEITMAN 

 UNITED STATES DISTRICT JUDGE 

Dated: December 30, 2015 

We approve the terms of the above Consent Judgment and stipulate to its entry:

s/T.N. ZIEDAS s/MICHAEL L. KALIS (w/consent) 

T.N. Ziedas (P35653) Michael L. Kalis (P23132) 

United States Attorney’s Office Michael L. Kalis & Assoc. PLLC 

211 W. Fort Street, Ste. 2001 3203 S. Telegraph Rd. 

Detroit, MI 48226 Dearborn, MI 48124 

313.226.9100 313.277.0310 

peter.ziedas@usdoj.gov kalislaw@yahoo.com

Counsel for the United States Counsel for Monroe Mobil, Inc. and 

 Hassan Jawad 

Dated: 12-28-2015 Dated: 12-28-2015 

 s/ HASSAN JAWAD (see attached pg) 

 Hassan Jawad, individually, and 

 on behalf of Monroe Mobil, Inc. 

 Dated: 12-28-2015 

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