Attorney

UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
IMMIGRATION COURT
[COURT CITY, COURT STATE]

In the Matter of
[ALIEN NAME] File No.: [ALIEN NUMBER]

RespondentIn Removal Proceedings

RESPONDENT’S MOTION TO REOPEN

Respondent, [ALIEN NAME], through his attorney, Atty. [LAWYER NAME], hereby asks that this Court reopen his case for the reasons statedbelow, to allow him to apply for political asylum in the United States:

1. Respondent, Mr. [ALIEN LAST NAME], is a native and citizen of the [ALIEN’S COUNTRY].
2. Mr. [ALIEN LAST NAME] enteredthe United States on [DATE] at Los Angeles, California.
3. Mr. [ALIEN LAST NAME], his girlfriend, [COMPLETE NAME], and her daughter XXXXXXX, entered the United States together in Los Angeles,California.
4. Mr. [ALIEN LAST NAME] and Ms. [LAST NAME] have lived together for five (5) years.
5. On MMMM/DD/YYYY, Mr. [ALIEN LAST NAME] and Ms. [LAST NAME], were having an argument in their duplex. Mr.[ALIEN LAST NAME]‘s neighbor, Ms. [LAST NAME], called the police.
6. The police arrived at their home on [HOME ADDRESS], and Mr. [ALIEN LAST NAME] was arrested. He appeared before a judge and was givena $1000 bond. (See Exhibit A)
7. Mr. [ALIEN LAST NAME] and Ms. [LAST NAME] were not able to pay the bond until [DATE].
8. Mr. [ALIEN LAST NAME] was scheduled for a master calendar hearing beforethe Immigration Court on [DATE] in [CITY, STATE].
9. On [DATE], Mr. Mr. [ALIEN LAST NAME]’s girlfriend, Ms. [LAST NAME] called to inform the Immigration Court that her boyfriend was detained and couldnot attend. Ms. [LAST NAME]was told by the clerk that when he got out they should bring the papers to the Judge.
10. Mr. [ALIEN LAST NAME] was in state custody and therefore unable to attend hishearing.
11. On [DATE], as a result of his absence, Mr. [ALIEN LAST NAME] was ordered removed in absentia from the United States by the Immigration Judge.
12. On [DATE], Mr. [ALIEN LAST NAME] was...