Emergency Rapid Response Materials (Last updated: 5/4/2017) These materials have been prepared by Avantika Shastri and Valerie Anne Zukin on behalf of the Justice & Diversity Center of The Bar Association of San Francisco. These are intended to be rapid response materials for the use of volunteer immigration attorneys in the case of enforcement actions by the Department of Homeland Security. The primary goal of these materials is to: (1) avoid the immediate removal of a detained individual without adequate due process protections; and (2) obtain the release of the detained individual, or to at least keep the detained individual housed in Northern California, while any legal proceedings take place. The information in these materials is intended for immigration practitioners familiar with removal defense. The information in these materials is not intended to be a comprehensive or exhaustive summary of immigration law or remedies. It is also not a substitute for individualized assessment and legal advice. Thank you to Ilyce Shugall for her comments on the legal analysis in these materials. Thank you to Van Der Hout, Brigagliano & Nightingale, LLP, for sharing their EOIR Request for Bond Hearing template. These materials are a work in progress. If you have any corrections or suggestions, please contact Avantika at ashastri@sfbar.org.
Emergency Response Procedures at an ICE Office Go to the ICE Office. Take the recommended rapid response materials with you. Ask to meet with the detainee, if any decisions have been made on the detainee s case, and to see any documents signed by/issued to the detainee. If questioned, explain that the detainee s family member requested your assistance. If informed that the detainee is being processed by ICE, ask to speak to him/her right away so that you can advise him/her of rights and legal options, and advise ICE of any relevant information about his/her case, before any statements are taken or decisions are made in the case. When meeting with the detainee, conduct intake and determine next steps as quickly as possible: Ask basic intake questions from Intake Form. Ask if they have signed any documents so far, if they have been given any documents, and what has happened since they were arrested. Provide information re their rights and immediate legal options Get their signatures on necessary forms if possible. You do not need the detainee s signature on the G-28 if you have verbal consent to representation. You should file a Form G-28 ASAP with ICE. Ask if any decisions have been made on the detainee s case, or whether a NTA has been or will be issued If detainee has signed any documents, ask for a copy of those documents immediately. In case of reinstatement and administrative removals, ask for copy of any documents supporting the removal procedures. File appropriate forms as soon as possible and advocate on detainee s behalf. ICE Decision If ICE notifies you that detainee is eligible to be released on bond, contact family members right away and advise them to pay bond before 3pm today if possible. If ICE notifies you that Respondent will not be released on bond or does not make a decision on the bond, file a request for a bond hearing with the Immigration Court on the same day before the Court closes. Inform ERO immediately regarding the filing of the bond hearing request, and serve OCC. For other decisions, notify detainee and family members, file additional documentation if necessary, and provide information regarding next steps or options. **At any point, ask to speak to an ICE Supervisor if ICE is not giving you access to a detainee or information about his/her case within a reasonable period of time. ** 1
Emergency legal analysis In the course of your advocacy with ICE and when advising the detainee, seek to avoid any concessions of alienage to the government. If the detainee is a minor or shows indicia of mental health issues, argue the need for special protections. If time permits, ask the detainee facts about his/her arrest in case there is a basis for a motion to suppress. I. If detainee has never been in proceedings and/or ICE wants to issue NTA: A. If time and information permits, present arguments that your client is not subject to grounds of removability and therefore, no NTA should be issued. B. Ask for release on own recognizance/reasonable bond, or alternatively to house locally. C. If no decision made on bond (or bond denied), file request for bond redetermination or custody hearing with IJ (unless arriving alien). II. If person has prior removal order: A. If DHS seeks to reinstate prior removal order: 1. If detainee has signed any documents and waived any rights, request to withdraw his or her signature immediately. 2. Ask to see documentation in support of reinstatement: prior order of removal, fingerprints used to verify identity, evidence of subsequent unlawful re-entry, notice of intent to reinstate (Form I-871). 8 C.F.R 241.8(a)-(b). 3. Request opportunity to make written or oral statement contesting reinstatement determination, and time to review evidence with client. 8 C.F.R. 241.8(b). 4. If applicable, argue that reinstatement provisions do not apply because ICE does not have the necessary evidence to support reinstatement or the charges are incorrect. For example: (a) Client s identity has not been properly verified (b) Client does not have a prior deportation order. (c) Client never departed the US under that prior order. (d) Client did not enter unlawfully following that prior order. (e) Other legislative, regulatory and judicial exemptions to reinstatement 5. If fear of return, ask for reasonable fear interview (RFI). 8 C.F.R. 208.31, 241.8(e). 6. If no fear of return and possible basis to argue that reinstatement is invalid, file 2
petition for review at the Ninth Circuit with request for stay and 14 days to supplement the stay request. Send copy of PFR and stay to ERO. 7. Other discretionary remedies to reinstatement: (a) Request reinstatement proceedings be terminated and detainee placed in removal proceedings under INA 240. Perez-Guzman v. Lynch, 835 F.3d 1066, 1081 (9th Cir. 2016); Villa-Anguiano v. Holder, 727 F.3d 873, 878 (9th Cir. 2013). (b) File motion to reopen/reconsider reinstatement order to ICE. 8 C.F.R. 103.5. B. If person has never left US but has outstanding unexecuted removal order: 1. If in absentia order: File skeletal motion to reopen with notice of automatic stay to IJ, if client is eligible based on exceptional circumstances (within 180 days or equitable tolling arguments), lack of notice or because in custody (at any time). INA 240(b)(5)(C). Request additional time to supplement motion with arguments and evidence. Send copy of MTR and automatic stay to ERO immediately, and serve OCC. 2. If eligible for VAWA protections: File skeletal motion to reopen with notice of automatic stay to IJ/BIA (within 1 year or with waiver request). INA 240(c)(7)(c)(iv). Request additional time to supplement motion. Send copy of MTR and automatic stay to ERO immediately, and serve OCC. 3. Other discretionary remedies to prevent deportation: (a) Request discretionary stay of removal from ICE (Form I-246). (b) Skeletal motions to reopen on other bases with discretionary stay requests to IJ/BIA. If possible, include arguments for equitable tolling of numerical and time limits. (c) File petition for writ of habeas corpus and TRO in district court? III. If DHS wants to issue summary removal order: A. If DHS wants to issue expedited removal (ER) order: 1. If detainee has signed any documents and waived any rights, request to withdraw his or her signature immediately. 2. Argue that detainee not subject to ER. INA 235(b)(1)(A)(i), 8 CFR 235.3(b): (a) Was admitted with valid visa (without fraud or misrepresentation), no false claim to USC, or was paroled in. (b) Has been continuously present in the United States for over 14 days (or two years if DHS Secretary expands ER authority). (c) Was not arrested within 100 miles of international land border (unless DHS Secretary expands ER authority). (d) Has a valid claim to lawful permanent resident status, has been granted refugee or asylee status, or a claim to citizenship. 8 CFR 235.3(b)(5). 3
(e) Other sub-rules 3. If has fear of return, ask for credible fear interview (CFI). INA 235(b)(1)(A)(ii), 8 CFR 235.3(b)(5). 4. Other discretionary remedies: (a) Request expedited removal proceedings be terminated and detainee placed in removal proceedings under INA 240. (b) File motion to reopen/reconsider expedited removal order to DHS office that issued expedited removal order. 8 C.F.R. 103.5. (c) Can file habeas action in district court to contest limited issues related to expedited removal procedures? INA 242(e)(2)(A)-(C). B. If DHS wants to issue administrative removal order under INA 238(b): 1. If detainee has signed any documents and waived any rights, request to withdraw signature immediately. 2. Ask to inspect DHS s evidence of removability related to alienage and charged criminal conviction, and 10 day rebuttal period. INA 238(b)(4)(C); 8 C.F.R 238.1(c)(2)(ii). Detainee may also seek an additional extension of time if required. 8 C.F.R 238.1(c)(1). 3. Argue that administrative removal process cannot be applied and/or request RFI. 8 CFR 238.1(f)(3). For example: (a) Detainee is not the person named (b) Detainee is a citizen or LPR (c) Detainee was not convicted of the charged crime (d) The charged crime is not an aggravated felony 4. If administrative removal order is final, no fear of return and possible basis to argue that order is invalid, file petition for review at the Ninth Circuit with request for stay and 14 days to supplement the stay request (within 30 days of issuance of final order). INA 238(b)(3), 242(a)(1), (b)(1). Send copy of PFR and stay to ERO. 5. Other discretionary remedies: (a) Request administrative removal proceedings be terminated and detainee placed in removal proceedings under INA 240. (b) File motion to reopen/reconsider administrative removal order to ICE. 8 C.F.R. 103.5. C. If DHS seeks to use stipulated removal procedures: 1. File motion to reopen to Immigration Court to withdraw signature and request master calendar hearing because detainee did not voluntarily, knowingly, or intelligently waive right to a hearing. INA 240(d); 8 C.F.R. 1003.25(b). 4
Recommended Emergency Response Materials Valid government-issued ID and valid bar card Blank Intake Forms (see suggested Intake Form) Blank (or pre-filled with attorney s information) Forms G-28 and E-28 Blank Templates (see attached samples) Blank Forms I-246 (ICE stays of removal) Government contact information EOIR Automated hotline number: 1-800-898-7180 ICE detainee locator web address - https://locator.ice.gov/ Local ICE contact information/organizational charts Local Immigration Court contact information Local OCC contact information Information on how to pay bond and list of immigration bond companies Information on how to pay filing fees for stay requests Reference materials (see suggested list at end of packet) Water and snacks Cell phone and charger Notepad/blank paper Your business cards for quick identification and contact information, or one-page document briefly explaining your identity, purpose and contact information 5
Templates ICE Release request ICE Notice of withdrawal of signature ICE Challenging Summary Removal Procedures and Request for CFI/RFI EOIR Request for bond hearing, proposed order, proof of service Request for stay Ninth Circuit Petition for review of order of reinstatement Ninth Circuit Motion for Leave to Proceed In Forma Pauperis Form 4 Affidavit Accompanying Motion for Permission to Appeal in Forma Pauperis Print from Ninth Circuit website Ninth Circuit Motion for Appointment of Counsel Ninth Circuit Motion for Stay of Removal Ninth Circuit Certificate of Service The following two excellent templates are available as part of the National Immigration Project of the National Lawyers Guild (NLG-NIP) Practice Advisory, Administrative Removal under 238(b): Questions and Answers (February 16, 2017), available at https://www.nationalimmigrationproject.org: Response to Department of Homeland Security to Notice of Intent to Issue a Final Administrative Order under 8 U.S.C. 1228(b); INA 238(b) Ninth Circuit Petition for Review of Decision Issued by the DHS The following template is also available as part of the NLG-NIP, American Immigration Council Practice Advisory Reinstatement of Removal (April 29, 2013), available at https://www.nationalimmigrationproject.org/: Sample Letter to DHS Requesting Copy of Reinstatement Letter and Accompanying Documentation 6
Field Office Director U.S. Immigration and Customs Enforcement Enforcement and Removal Office 630 Sansome Street, Room 590 San Francisco, CA 94111 VIA PERSONAL DELIVERY, 2017 Re: Request for release on own recognizance/bond, and Request to house in Northern California A Dear Sir/Madam: As shown by my attached Notice of Appearance (Form G-28), I represent the above named individual before your office. We respectfully request that you release my client on his/her own recognizance. My client is not a danger to the community and will appear for all appearances when notified and required: Alternatively, we request that you release my client on a reasonable bond. My client and his/her family are hardworking but have limited means. A bond of would be a significant sum for his/her family. His/her family is prepared to pay a bond right away. If you believe that continued custody is warranted, we respectfully request that you house my client in a facility in Northern California, given that he/she has retained my legal services and I am based in San Francisco. In addition, my client and his/her family reside in, and thus all of the evidence in support of his/her case is based in the jurisdiction of the San Francisco Immigration Court. If you have any questions about this case, please do not hesitate to contact me at. Thank you for your attention to this matter. Sincerely, 7
Field Office Director U.S. Immigration and Customs Enforcement Enforcement and Removal Office 630 Sansome Street, Room 590 San Francisco, CA 94111 VIA PERSONAL DELIVERY, 2017 Re: Notice of Withdrawal of Prior Signature A Dear Sir/Madam: As shown by my attached Notice of Appearance (Form G-28), I represent the above named individual before your office. My client now withdraws his/her signature(s) on the following forms: At the time of signing the forms, my client did not fully understand the legal implications and meaning of those forms. Having retained counsel, he/she now withdraws his/her signature(s) at the earliest time possible. If you have any questions about this case, please do not hesitate to contact me at. Thank you for your attention to this matter. Sincerely, 8
Field Office Director U.S. Immigration and Customs Enforcement Enforcement and Removal Office 630 Sansome Street, Room 590 San Francisco, CA 94111 VIA PERSONAL DELIVERY, 2017 Re: Contestation of Removal Procedures, and/or Request for Credible/Reasonable Fear Interview A Dear Sir/Madam: As shown by my attached Notice of Appearance (Form G-28), I represent the above named individual before your office. I have been informed that your office intends to apply the following removal procedures to my client: I hereby request a copy of all evidence used and notices/orders issued by your office in support of this removal procedure, and any documentation signed by my client. I hereby request at least 10 days to review and respond to this evidence. I have just been retained that thus require this amount of time to speak to my client and his/her family, collect necessary documents, and investigate his case. As explained below, my client should not be subject to these removal provisions. Documentary evidence is attached to this request, or can be submitted shortly: We hereby request a Credible Fear/Reasonable Fear Interview. My client is afraid of being removed from the United States because he/she has experienced past acts of persecution and/or has a well-founded fear of future persecution or torture. Thus, we hereby request that you reconsider this action. If you have any questions, please do not hesitate to contact me at. Thank you for your attention to this matter. Sincerely, 9
Clerk of the Court Office of the Immigration Judge Executive Office for Immigration Review 630 Sansome Street, Fourth Floor San Francisco, CA 94111 VIA PERSONAL DELIVERY, 2017 RE: Request to Set Bond Redetermination/Custody Hearing A Dear Sir/Madam: By this letter I request a review by an Immigration Judge ( IJ ), of the custody and bond determination made by the Immigration and Customs Enforcement with regard to the above named individual. 8 C.F.R. 1003.19. Enclosed please find my Form EOIR-28, as well as a Proposed Order and Proof of Service on the opposing counsel. The regulations clearly provide that after an initial custody determination by DHS, the respondent may request amelioration of the conditions under which he or she may be released. The IJ has the authority to detain the alien in custody, release the alien, and determine the amount of bond, if any, under which respondent may be released. 8 C.F.R. 1236.1; 8 C.F.R. 1003.19. Under 8 C.F.R. 1003.19(c), applications of the exercise of authority to review bond determinations are to be made first, if the respondent is detained, to the Immigration Court having jurisdiction over the place of detention. Under 8 C.F.R. 1003.14, "no charging document is required to be filed with the Immigration Court to commence bond proceedings pursuant to 1003.19, 236.1(d) and 1240.2(b)." (emphasis added). Thus, this Court may have jurisdiction over the custody determination before a NTA is filed with the Immigration Court. Respondent was taken into custody today by ICE, and continues to be detained by the San Francisco District Office. To the best of my knowledge, a NTA has / has not yet been issued in this case. A request for release on bond was filed with ICE, and ICE denied/has not yet made a timely decision on that request. Counsel requests that a Bond Redetermination Hearing be calendared immediately so that the Court can review the determination by the DHS that Respondent is to be held without bond. Thank you for your prompt attention to this matter. Sincerely, Att: Form E-28, Proposed Order, Proof of Service 10
U.S. DEPARTMENT OF JUSTICE EXECUTIVE OFFICE FOR IMMIGRATION REVIEW IMMIGRATION COURT SAN FRANCISCO, CA In the Matter of: Respondent, File No. A Next Hearing: Hon. Immigration Judge In Bond Proceedings ORDER OF THE IMMIGRATION JUDGE Upon consideration of the Respondent s Request for Bond Redetermination/Custody Hearing, it is HEREBY ORDERED that the motion be GRANTED DENIED because: DHS does not oppose the motion. A response to the motion has not been filed with the court. Good cause has been established for the motion. The court agrees with the reasons stated in the opposition to the motion. The motion is untimely per. Other: Date Immigration Judge Certificate of Service This document was served by: [ ] Mail [ ] Personal Service To: [ ] Alien [ ] Alien c/o Custodial Officer [ ] Alien s Atty/Rep [ ] DHS Date: By: Court Staff 11
In the Matter of A - - CERTIFICATE OF SERVICE On / / 20, I, caused to be served the attached: On the opposing counsel, via: To the following party: At the following address: Hand delivery First Class Mail (use below P.O. Box) Courier Service Electronic Mail Department of Homeland Security U.S. Immigration and Customs Enforcement Office of the Chief Counsel 100 Montgomery Street, Suite 200, San Francisco, CA 94104 630 Sansome Street, Room 1155, San Francisco, CA 94111 P.O. Box 26449, San Francisco, CA 94126 (mailing address) Date: Signed: 12
Field Office Director U.S. Immigration and Customs Enforcement Enforcement and Removal Office 630 Sansome Street, Room 590 San Francisco, CA 94111 VIA PERSONAL DELIVERY, 2017 Re: Request for Stay of Removal (Form I-246) A Dear Sir/Madam: As shown by my attached Notice of Appearance (Form G-28), I represent the above named individual before your office. I am also attaching a Form I-246 and filing fee to this request. We respectfully request that you grant a stay of removal for my client for the following reasons: I have attached some evidence in support of this request to this letter, and can provide more information shortly. If you have any questions about this case, please do not hesitate to contact me at. Thank you for your attention to this matter. Sincerely, 13
Name: A: - - ICE Detention Facility: Pro Se Petitioner DETAINED IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT, Petitioner, Case No. File No. v. JEFF SESSIONS, Attorney General of the United States; JOHN KELLY, U.S. Department, Homeland Security, Secretary of Homeland Security 1, PETITION FOR REVIEW OF ORDER OF REINSTATEMENT Respondent. 1 Pursuant to 8 U.S.C. 1252(b)(3)(A), Petitioner lists the Attorney General as a respondent. However, as the Department of Homeland Security ( DHS ) issued the agency decision for which Petitioner seeks review, Petitioner also has listed the Secretary of Homeland Security. 14
Petitioner,, hereby seeks review by this Court, of the reinstatement order issued by Immigration and Customs Enforcement ( ICE ). Petitioner hereby attaches a copy of the order, or will submit a copy of the order in the future if possible. 1. Jurisdiction to review ICE s decision is asserted pursuant to section 242(a)(1) of the Immigration and Nationality Act ( the Act or INA ); 8 U.S.C. 1252(a)(1); See Morales de Soto v. Lynch, 824 F.3d 822, 825 (9th Cir. 2016) (as amended); Ortiz-Alfaro v. Holder, 694 F.3d 955, 958 (9th Cir. 2012); Andrade Garcia v. Lynch, 828 F.3d 829, 833 (9th Cir. 2016). 2. Venue is asserted pursuant to section 242(b)(2) of the Act; 8 U.S.C. 1252(b)(2), because the reinstated order became final in this jurisdiction or because warranted by the interests of justice. Bibiano v. Lynch, 834 F.3d 966, 974-75 (9th Cir. 2016). 3. This petition is timely filed pursuant to section 242(b)(1) of the Act; 8 U.S.C. 1252(b)(1), as it is filed within 30 days of the date the reinstatement order became final. See Morales de Soto, 824 F.3d at 825; Ortiz-Alfaro, 694 F.3d at 958. / / / 15
4. This petition for review asserts that reinstatement is improper for the following reason(s): 5. Pursuant to Circuit Rule 15-4, Petitioner advises the Court that s/he is currently detained in the custody of the Department of Homeland Security at, in, California. To date, no court has upheld the validity of the reinstatement order. No other motion to reopen or reconsider is currently pending before the Executive Office for Immigration Review. Date: Respectfully submitted, [Signature] [Print Name] A - - Pro Se Petitioner 16
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Name: A: - - ICE Detention Facility: Pro Se Petitioner DETAINED UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT Petitioner, Case No. File No. A v. JEFF SESSIONS, Attorney General of the United States; JOHN KELLY, U.S. Department, Homeland Security, Secretary of Homeland Security, Motion for Leave to Proceed in Forma Pauperis Respondent. 18
Petitioner, proceeding pro se, hereby moves for leave to proceed in forma pauperis. Pursuant to FRAP 24(b), the affidavit prescribed by Rule 24(a)(1) is attached. Petitioner is currently detained in the custody of Immigration and Customs Enforcement and is unable to earn an income. For this and other reasons, s/he respectfully moves to proceed in forma pauperis. Date: Respectfully Submitted, [Signature] [Print Name] A - - Pro Se Petitioner 19
Name: A: - - ICE Detention Facility: Pro Se Petitioner DETAINED UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT, Petitioner, Case No. File No. A v. JEFF SESSIONS, Attorney General of the United States; JOHN KELLY, U.S. Department, Homeland Security, Secretary of Homeland Security, Motion for Appointment of Counsel Respondent. Comes now the above named petitioner and moves this Court for the appointment of counsel to represent petitioner in this proceeding. This motion is based on the petitioner s Motion for Leave to Proceed in Forma Pauperis, and the attached declaration, which indicates why petitioner believes it would be difficult to proceed pro se. Respectfully submitted: (date) By: (signature) 20
Print Name: Name: A: - - ICE Detention Facility: Pro Se Petitioner DETAINED UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT Petitioner, Case No. File No. A v. JEFF SESSIONS, Attorney General of the United States; JOHN KELLY, U.S. Department, Homeland Security, Secretary of Homeland Security, Declaration in Support of Motion for Appointment of Counsel Respondent. 21
I,, hereby declare under penalty of perjury that the following is true and correct: Respectfully submitted on: (date) By: (signature) Print Name: 22
Name: A: - - Pro Se Petitioner UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT Petitioner, Case No. File No. A v. JEFF SESSIONS, Attorney General of the United States; JOHN KELLY, U.S. Department, Homeland Security, Secretary of Homeland Security, Motion for Stay of Removal Respondent. Petitioner, pro se, hereby moves that this Court issue a stay of removal pending the adjudication of the instant petition for review. Pursuant to Ninth Circuit General Order 6.4(c), Petitioner respectfully notes that a temporary stay of removal is in effect pending further order of the Court. See also Desta v. Ashcroft, 365 F.3d 741 (9th Cir. 2004). In addition, pursuant to Circuit Rule 27-8.2, Petitioner advises that he is detained in the custody of the Department of Homeland Security 23
. Argument on Petition for Review I am eligible for the following relief: I am petitioning for review of the decision of the Board of Immigration Appeals / Immigration Judge / Department of Homeland Security because: Standard for Stay of Removal In Nken v. Holder, 129 S. Ct. 1749, 1761 (2009), the Supreme Court 24
identified four standard factors that should be considered in adjudicating a motion for stay of removal: (1) whether the stay applicant has made a strong showing that he is likely to succeed on the merits; (2) whether the applicant will be irreparably injured absent a stay; (3) whether issuance of the stay will substantially injure the other parties interested in the proceeding; and (4) where the public interest lies. Because the Government is the opposing party here, the last two factors merge. Nken, 129 S.Ct. at 1762. The Petitioner is able to satisfy the standard for a stay as articulated by both the Nken decision and as well as was previously articulated by this Court in Andreiu v. Ashcroft, 253 F.3d 477, 483 (9th Cir. 2001). I merit a stay of removal because I raise the following serious legal questions: injury: I also merit a stay of removal because removal will cause me irreparable 25
A stay is in the public interest because: of removal. For these reasons, Petitioner moves that the Court grant this motion for stay Date: Respectfully Submitted, [Signature] [Print Name] A - - Pro Se Petitioner 26
CERTIFICATE OF SERVICE I hereby certify that on, true and correct copies of the foregoing: Petition for Review Administrative Order Motion for Leave to Proceed In Forma Pauperis, and Form 4 Motion for Appointment of Counsel, and Supporting Declaration Motion for Stay of Removal were mailed by first-class mail, postage pre-paid, upon: U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, D.C. 20530-0001 Office of Immigration Litigation PO Box 878, Ben Franklin Station Washington, DC 20044 Office of Chief Counsel, ICE 100 Montgomery Street, Suite 200 San Francisco, CA 94104 Dated this. [Signature] [Print Name] 27
Reference Materials Challenging a Notice to Appear American Immigration Council (AIC), Penn State Dickinson School of Law, ABA Commission on Immigration Practice Advisory: Notices to Appear: Legal Challenges and Strategies (June 2014), available at https://www.americanimmigrationcouncil.org Criminal Analysis (for quick reference, not sufficient for a complete analysis) Immigrant Legal Resource Center (ILRC), California Crimes Chart, available at https://www.ilrc.org/chart Eligibility for Relief (for quick reference, not sufficient for a complete analysis) ILRC, Screening for Immigration Relief: Client Intake Form and Notes (July 14, 2017), available at https://www.ilrc.org/sites/default/files/resources/client_intake_form_and_notes.pdf ILRC, Immigration Relief Toolkit for Criminal Defenders (January 2016), available at https://www.ilrc.org/immigration-relief-toolkit-criminal-defenders Reinstatement of removal National Immigration Project of the National Lawyers Guild (NIP), AIC, Practice Advisory Reinstatement of Removal (April 29, 2013), available at https://www.nationalimmigrationproject.org/ Expedited Removal NIP, AIC, American Civil Liberties Union, Practice Advisory, Expedited Removal: What has Changed since Executive Order no. 13767, Border Security and Immigration Enforcement Improvements (Issued on January 25, 2017) (Feb. 20, 2017), available at https://www.nationalimmigrationproject.org/ Administrative Removals under INA 238(b) NIP, Practice Advisory, Administrative Removal under 238(b): Questions and Answers (February 16, 2017), available at https://www.nationalimmigrationproject.org Bond Hearings Practicing Law Institute webinar, Bond Hearing Basics and Strategies for Representing Clients Subject to Prolonged Detention (April 19, 2017), available at www.pli.edu Motion to reopen in absentia orders AIC, Rescinding an In Absentia Removal Order (Mar. 31, 2010), available at https://www.americanimmigrationcouncil.org VAWA ILRC recorded webinar, VAWA Issues and Updates (April 11, 2013), available at www.ilrc.org 28
ILRC recorded webinar, VAWA Fundamentals and Emerging Issues (April 20, 2017), available at www.ilrc.org Know Your Rights Materials American Immigration Lawyers Association, www.aila.org Immigrant Legal Resource Center, www.ilrc.org Immigrant Defense Project, https://www.immigrantdefenseproject.org/ National Immigration Law Center, www.nilc.org Remedies to Enforcement at Sensitive Locations NIP, Practice Advisory, Remedies to DHS Enforcement at Courthouses and Other Protected Locations (April 12, 2017), available at https://www.nationalimmigrationproject.org 29