Appendix: Sample Statutory Motion to Reconsider and Terminate Removal Proceedings, or, in the Alternative, Sua Sponte Motion to Reconsider and Terminate, in Light of the Supreme Court’s Decision in Borden v. United States

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Immigrant Defense Project Template motion Direct DOCX available

Why it matters

Useful as a drafting starting point for Crimes work in Immigration Judge; adapt the facts, authority, and venue-specific requirements before use.

Crimes and categorical approach Removal defense

Immigration court deadline Motions, stays, and pretermission BIA, PFR, and federal court Crim-imm screening Sample filings and templates

Immigration court BIA Court of appeals

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