UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE OF IMMIGRATION REVIEW
IN THE MATTER OF:
FILE NO: Axxxxxxxxx
Respondent. IN REMOVAL PROCEEDINGS
MOTION FOR BOND REDETERMINATION
COMES NOW the Respondent by and through his undersigned attorney and moves this court to set bond in this matter and in support thereof, states:
PERSONAL AND PROCEDURAL FACTS OF THE CASE
Respondent is a native of * and a citizen of *.
He entered the U. S. on * as a tourist, married a U.S. citizen and became lawful permanent resident.
Respondent has 4 USC children; *
Respondent is married to * who is a U.S. citizen. They have one child, * who live in Florida.
Respondent has filed a Federal Income Tax Return. Attached are his tax returns for 20*, 20* and 20*.
On * Respondent was arrested and charged with *.
Respondent has no criminal record other than the foregoing and *.
Respondent received bond from the criminal court.
The criminal court waived the appearance of Respondent at the initial hearings.
Respondent appeared at the sentencing hearing.
Respondent is currently detained at *.
If released on bond Respondent will return to work at * in *.
Respondent’s brother lives in the * area.
Respondent has strong family ties.
He has employment.
Respondent has shown that he is not a flight risk.
Respondent is not a danger to the community.
Respondent’s below signed attorney has ordered the transcript of the criminal proceedings to determine if
Respondent has any post-conviction relief eligibility. Other possible defenses may relate to whether the
Respondent was wrongfully denied Naturalization and Cancellation of Removal and cooperation in
investigating major criminal activity.
See Second Article on Immigration Bond