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.
Brief in Support of Particular Social Group for Asylum
Brief arguing that certain gang based and domestic sexual violence based claims still qualify as a particular social group membership for purposes of asylum post Matter of A-B-. Also argues that certain conclusions reached in Matter of A-B- are flawed and contradict current caselaw.
Brief Regarding VAWA cancellation – Extreme Cruelty
Brief to Board of Immigration Appeals arguing eligibility for VAWA cancellation based upon extreme cruelty by USC spouse due to his alcoholism.
RESPONDENT’S WRITTEN PLEADINGS
Respondent’s pleading for immigration proceedings. Also includes notice of request for volunteer departure.
Federal Court Civil Complaint with Request for Injunctive Relief
Federal Civil Complaint based on diversity of citizenship, and including claims for misappropriation of trade secrets and breach of contract; includes request for injunctive relief. US District Court for the District of Minnesota.
BIA Bond Brief
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.
Asylum Process in the USA
Brief to the USCIS Asylum Office in support of an application for asylum based upon political opinion in Venezuela.
The length of the asylum process varies, but it typically takes between 6 months and several years. The length of asylum process may vary depending on whether the asylum seeker filed affirmatively or defensively and on the particular facts of his or her asylum claim.
If you can get a visa to come to the United States, such as a tourist visa, you can apply for asylum when you arrive, by telling the inspections officer that you fear returning to your country and wish to apply for asylum.
Your statement should help the Asylum Officer or the Immigration Judge better understand why you are applying for asylum. Describe specific incidents and dates, and include as much detail as you can remember. Do not simply write general statements. If you cannot remember an exact date, state that you are estimating it.
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.
Brief in Support of Reasonable Fear/Asylum
Brief to Immigration Court in support of reasonable fear determination. Asylum/particular social group argument based upon status as former police officer in Mexico.
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.