An Immigration Court brief that argues that certain crimes do not involve moral turpitude including:

1) Whether Mr. X’s conviction for harassment does not constitute a crime involving moral turpitude for immigration inadmissibility purposes 2) If the Court finds that Mr. X’s conviction for harassment is a crime involving moral turpitude, it qualifies under the petty offense exception.

Motion to Dismiss/Sanctions for Rule 16 violation: Motion related to prosecution's failure to disclose or provide copies of video taken of the defendant while in a DUI holding cell after defendant's arrest. Court agreed the video was exculpatory as to the DUI charge, and dismissed the DUI charge accordingly (Court ruled it was not relevant to a second count of Driving Under Restraint).

Brief to the Board of Immigration Appeals appealing the Immigration Court's denial of bond.  Respondent argued that the Immigration Judge failed to weigh all positive and negative factors in determining bond.  Additionally new circumstances arose following the hearing in which the Respondent received substandard medical care in detention, which justified remand to the court to reconsider its bond ruling.