Immigration
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Motion to Administratively Close Proceedings
Motion to Immigration Court requesting administrative closure under Matter of Avetisyan based upon humanitarian grounds and low priority for removal.
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.
BIA Motion to Reconsider I-130 Revocation
Motion to the Board of Immigration Appeals to reconsider the USCIS revocation of a marriage based Form I-130 Petition for Alien Relative. Legal Argument: Impermissible revocation, proper legal standard for good faith marriage, petitioner’s burden to show bona fide marriage, proper evidentiary standard.
Defendant’s Motion In Limine Re: Statements Within Immigration
Immigration Defendant seeking to exclude statements made to ICE and other government agents in prior contacts with ICE and other law enforcement regarding his immigration status (Defendant exercised the 5th in this case). US District Court for the District of Arizona.
Defendant’s Motion In Limine Re: Initial Contact
Defendant in an Immigration case seeking to exclude the reasons for, and facts that, he was in jail when ICE agents made contact with him.
Motion for Suppression of Evidence – Immigration
Motion for Suppression of Evidence – Immigration
Request for Stay of Removal – Immigration Law
Request for Stay of Removal – Immigration Law
Support Brief of Application for Waiver of Grounds of Inadmissability
Support Brief of Application for Waiver of Grounds of Inadmissability
Brief in Support of Appeal Motion to Remand in the Alternative
Brief in Support of Appeal Motion to Remand in the Alternative