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.
Spanish version of Letter to Client regarding Voluntary Departure
A sample letter used to send to client regarding their agreement or stipulation to voluntary depart the country.
Letter to client Regarding Voluntary Departure
A sample letter used to send to client regarding their agreement or stipulation to voluntary depart the country.
JOINT REPORT OF STIPULATED JURY INSTRUCTIONS
JOINT REPORT OF STIPULATED JURY INSTRUCTIONS
PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT PURSUANT TO Fed.R.Civ.P. 56 and D.C.COLO.LCivR 56.1 AND INCORPORATED MEMORANDUM OF LAW
PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT PURSUANT TO Fed.R.Civ.P. 56 and D.C.COLO.LCivR 56.1 AND INCORPORATED MEMORANDUM OF LAW
PLAINTIFF’S REQUESTED QUESTIONS FOR THE JURY VENIRE AT VOIR DIRE
PLAINTIFF’S REQUESTED QUESTIONS FOR THE JURY VENIRE AT VOIR DIRE
PLAINTIFF’S UNOPPOSED MOTION TO CONTINUE JURY TRIAL
PLAINTIFF’S UNOPPOSED MOTION TO CONTINUE JURY TRIAL
PLAINTIFF’S MOTION TO COMPEL DISCOVERY RESPONSES AND TO COMPEL THE DEPOSITIONS OF /FROM AN ANALYSIS GROUP AND INCORPORATED MEMORANDUM OF LAW
PLAINTIFF’S MOTION TO COMPEL DISCOVERY RESPONSES AND TO COMPEL THE DEPOSITIONS OF /FROM AN ANALYSIS GROUP AND INCORPORATED MEMORANDUM OF LAW
UNITED STATES UNOPPOSED MOTION TO RESET HEARING ON MOTION FOR PROTECTIVE ORDER
UNITED STATES UNOPPOSED MOTION TO RESET HEARING ON MOTION FOR PROTECTIVE ORDER
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.
Defendant’s Motion In Limine to Preclude Evidence of Uncharged Tax Years
Motion by a criminal defendant in the US District Court for the Western District of California to preclude the inclusion of specific evidence. In this case, to exclude evidence of tax filings for ax years not included in the Government’s charges.