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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.
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.
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.
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.
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.
Motion for Judgment not withstanding the verdict or Motion for New Trial
Judgment was entered against my client. We filed a motion based on the evidence for a new trial or in the alternative a Motion Not Withstanding the Verdict. My client was held liability for Outrageous Conduct and emotion distress
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 Jury Instruction
Civil case Jury instruction with Mitigation of damages Defense
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOSÂ
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Plaintiff’s response in opposition to defendant’s third motion in limine regarding rights versus duties.Â
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SIXTH MOTION IN LIMINE REGARDING
Plaintiff’s response to defendant’s sixth motion in limine regarding expert.Â