Practitioner’s Notes for Template Prosecutorial Discretion Request: Joint Motion to Reopen an in Absentia Removal Order and Dismiss or, in the alternative, a Joint Motion to Reopen

This template is intended for practitioners who represent a client who has been ordered removed in absentia and is requesting prosecutorial discretion following the vacatur of DHS’s immigration enforcement priorities set out in the Mayorkas and Doyle Memoranda.

National Immigration Project Template motion Sep 1, 2022 Direct PDF available

Why it matters

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

Topics

Removal defense Motions to reopen / reconsider

Workflows

Immigration court deadline Motions, stays, and pretermission BIA, PFR, and federal court Sample filings and templates

Forums

Immigration court BIA

Jurisdictions

National