Marina N. Alexandrovich's Legal Guides (14)

Non-Pereira argument for termination of a removal case with an incomplete NTA

May 20, 2020

There are laws ... and there are laws that are being followed. The statute 8 USC §1229(a)(1) is not being followed ... because DHS gets away with commencing proceedings before Its solely on regulation...

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Seeking reconsideration of denied "Pereira" MTT under Lorenzo Lopez precedent.

Jul 20, 2019

New precedent Lorenzo Lopez v. Barr, No. 15-72406 May 22, 2019 (9th Cir. 2019) allows to move the BIA to reconsider denial of "Pereira" motion to terminate for lack of subject-matter jurisdiction. Thi...

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Surviving Bermudez-Cota

Sep 03, 2018

Bermudez-Cota is contrary to the Supreme Court's precedent, hence, legally inconsequential. Bermudez-Cota construes INA *239(a) contrary to the Superior Court's construction given in Pereira The Supre...

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Durable Pereira Motion to Terminate: argue all reasons for termination

Aug 24, 2018

Half IJs deny Pereita MTTs. The BIA started turning out unpublished denials of Pereira MTTs. At the same time the IJs more and more terminate sua sponte (yes, without ay party moving to terminate) the...

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