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In the United States District Court

For the Western District of Texas

Austin Division

Natacha Ingonga Bolumbu, 

 Petitioner,

v. 

William Barr, U.S. Attorney General;

Chad F. Wolf, Acting Secretary of the 

Department of Homeland Security; 

Matthew T. Albence, Deputy Director and 

Senior Official performing the duties of the 

Director, United States Immigration and 

Customs Enforcement; Henry Lucero 

Executive Associate Director, Enforcement 

and Removal Operations, United States 

Immigration and Customs Enforcement; 

United States Department of Homeland 

Security; United States Department of 

Immigration and Customs Enforcement, 

 Respondents. 

 No. 1:20-cv-00392-RP

STIPULATION FOR COMPROMISE AGREEMENT

It is hereby stipulated by and between the undersigned counsel for Petitioner, Natacha 

Ingonga Bolumbu (“Petitioner”), and Respondents William Barr, U.S. Attorney General; Chad 

F. Wolf, Acting Secretary of the Department of Homeland Security; Matthew T. Albence, Deputy

Director and Senior Official performing the duties of the Director, United States Immigration and 

Customs Enforcement; Henry Lucero Executive Associate Director, Enforcement and Removal 

Operations, United States Immigration and Customs Enforcement; United States Department of 

Homeland Security; United States Department of Immigration and Customs Enforcement 

(“Respondents”) (collectively, “the Parties”), by and through their respective attorneys as follows:

1. Respondents contend they have not been served with process in accordance with

Federal Rule of Civil Procedure 4. Without waiver of their right to proper service of process and 
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without waiver of the defense of lack of personal jurisdiction, Respondents have moved for 

dismissal of Petitioner’s Petition for Writ of Habeas Corpus on the basis that the Court lacks 

subject matter jurisdiction. See Dkt. 10. Respondents’ Motion to Dismiss for Lack of Subject 

Matter Jurisdiction remains pending, and the Court has not determined that it may exercise 

jurisdiction in this case. 

2. Subject to and without waiver of their jurisdictional defenses, Respondents assert a

general denial to the allegations in Petitioner’s Petition for Writ of Habeas Corpus and deny that 

they have violated Petitioner’s constitutional rights or that they have violated any law or regulation 

with respect to the alleged action. 

3. While Respondents’ Motion to Dismiss was pending, Respondents invited

Petitioner to submit supplemental documentation and information to support a finding of eligibility 

for parole. Specifically, Respondents asked Petitioner to supply additional documentation and 

information regarding Petitioner’s identity and sponsor to refute the issues identified by 

Respondents. See Supplemental Fowler Decl. Dkt. 14-1 (Motion to Seal Pending). 

4. On May 12, 2020 and May 13, 2020, Petitioner supplied the requested supplemental

documentation and information in the form of a Request for Reconsideration of Denial of Parole. 

Having considered the Request for Reconsideration of Denial of Parole and the supporting 

documentation, United States Immigration and Customs Enforcement has determined that 

Petitioner is eligible for parole, subject to certain conditions precedent as described in greater detail 

herein. 

5. Accordingly, 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 any alleged acts 

or omissions by Respondents or its agencies, current or former officers, agents, servants, or 
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employees, either in their official or individual capacities, that gave rise to the above-captioned 

action, under the terms and conditions set forth in this Stipulation For Compromise Agreement. 

6. In consideration of the mutual acts, covenants and promises stated herein, it is

agreed that Respondents will release Petitioner as follows: 

a. Within 12 hours of the execution of this agreement, Petitioner’s counsel, acting

on behalf of Petitioner, will 

i. arrange for the surrender of Petitioner’s passport to Patrick Mullen, SDDO,

ICE ERO Portland, ME Sub-Office, 176 Gannett Drive, South Portland, ME 04106; and 

ii. provide in writing to Respondents’ counsel the names, addresses, and

telephone numbers of Petitioner’s sponsor; and 

iii. provide in writing to Respondents’ counsel either the name, address, and

telephone number of a temporary local shelter to which ICE will transport Petitioner upon 

release (unless she is released directly to her attorney) or present a boarding pass departing 

from Austin-Bergstrom International Airport or bus ticket for transportation to Petitioner’s 

sponsor; and 

iv. execute the Stipulation of Dismissal With Prejudice attached hereto as

Exhibit A. 

b. Within 24 hours of satisfaction of all conditions stated in Paragraph 6(a)

above, ICE shall release Petitioner from the T. Don Hutto Detention Center. ICE will provide twohour advance notice to Petitioner’s counsel to coordinate the release of Petitioner, who will be 

either released to her attorney or transported by ICE to the temporary local shelter described in 

Paragraph 6(a)(iii) above. 
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c. Upon release, Petitioner shall be subject to the terms of the ICE Enforcement and

Removal Operations (ERO) Alternatives to Detention Program, which may include GPS 

monitoring. 

d. Upon release, Petitioner shall be subject to 60-day ICE check-ins, subject to the

discretion of ERO to permit less frequent check-ins.

e. Petitioner will not be re-detained by ICE for civil immigration purposes until the

conclusion of Petitioner’s immigration proceedings, for the execution of a final removal order, or 

after the commission of a felony or non-traffic misdemeanor. If Petitioner misses a scheduled 

report date with ICE (see paragraph 6.f., above), she will also be subject to being re-detained. 

Petitioner shall remain at all times subject to the terms of the Alternative to Detention Program. 

7. This Stipulation For Compromise Agreement is not, is in no way intended to be,

and should not be construed as an admission of wrongdoing, or a violation of Petitioner’s rights in 

any respect, or admission of liability on the part of the United States of America, its agencies, 

current or former officers, agents, servants, or employees, either in their official or individual 

capacities, including any federal defendant in the referenced civil action, and it is specifically 

denied that they are liable to Petitioner. This settlement is entered into by all Parties for the purpose 

of compromising disputed claims and avoiding the expenses and risks of further litigation. 

8. The persons signing this Stipulation For Compromise Agreement warrant and

represent that they possess full authority to bind the persons on whose behalf they are signing to 

the terms and conditions of the settlement and further warrant and represent that they have 

completely read and fully understand the terms of this agreement and voluntarily accept those 

terms of their own free will. 
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9. It is also agreed, by and among Petitioner and Respondents, that the respective parties

will each bear their own costs, fees, and expenses 

10. The Parties agree that this agreement may be signed by counterparts.

11. There are no other terms to this agreement other than those expressly written here.

This agreement may not be modified except by a writing signed by each party or that party's agent. 

Executed this 13th day of May, 2020. 

Date: 

Joseph Krebs Muller

Bar: MO #65066, TX #24117397 

Law Office of Joseph Muller 

9600 Great Hills Trl. Ste. 150W 

Austin, TX 78759 

Email: joseph@jkmlaw.cc

Phone: (512) 593-8258 

Fax: (512) 361-4938

ATTORNEY FOR PETITIONER

05/13/2020 /s/ Joseph Krebs Muller
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JOHN F. BASH

UNITED STATES ATTORNEY 

/s/ Liane Noble .

LIANE NOBLE 

Assistant United States Attorney 

Texas Bar No. 24079059 

903 San Jacinto Blvd., Suite 334 

Austin, Texas 78701 

(512) 370-1252 (phone)

(512) 916-5854 (fax)

Liane.Noble@usdoj.gov

LACY L. McANDREW 

Assistant United States Attorney 

Florida Bar No. 45507 

601 N.W. Loop 410, Suite 600 

San Antonio, Texas 78216 

(210) 384-7340 (phone)

(210) 384-7312 (fax)

Lacy.McAndrew@usdoj.gov

ATTORNEYS FOR RESPONDENTS 
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Date: _____________ 

Nicholas D. Fowler 

Assistant Field Office Director 

T. Don Hutto Detention Center 

U.S. Department of Homeland Security

Immigration and Customs Enforcement 

Enforcement and Removal Operations 

May 13, 2020

NICHOLAS D 

FOWLER

Digitally signed by NICHOLAS D 

FOWLER 

Date: 2020.05.13 17:14:07 -05'00'