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Respondent’s Evidence Submission
Respondent’s evidence submission to Immigration Court with Exhibit list, witness list and Certificate of Service
BIA Brief Regarding Lawful Admission
Brief to the Board of Immigration Appeals arguing that a a waive-through at a port of entry constitutes a lawful admission tot he US for purposes of adjustment of status.
Motion to Terminate under Pereira
Motion to Immigration Court moving for termination of proceedings based upon the US Supreme Court decision in Pereira v. Sessions.
Motion to Reconsider and Reopen Record
Motion to Reopen Immigration Court testimony based upon Respondent’s incompetency. Respondent became confused during testimony due to a traumatic brain injury which caused serious cognitive defects and memory and confusion issues. Motion requested that Court reopen the record and take additional testimony of Respondent’s lack of competence.