UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
In order to move the large pleading calendar quickly
and more efficiently, it is required that counsels/representatives
follow this format and be prepared to make the following oral representations:
Upon commencement of the proceedings, the Court will
recognize counsel or accredited representatives of record for the
respondent. Notice of Entry of Appearance must be submitted to the
Court prior to the hearing.
COUNSEL TO THE COURT:
I, (attorney/accredited representative), (state your
name), on behalf of (state the name of your client), do concede proper
service of a Notice to Appear dated (state date of the NTA), and (waive
a formal reading thereof) or (wish to have the charging document read
into the record).
I represent to the Court that I have discussed with
my client the nature and purpose of these proceedings, discussed specifically
the allegations of facts and the charge(s) of removability, and further
advised my client of his legal rights in removal proceedings.
I further represent to the court that I have fully
explained to my client the consequences of failing to appear for a
removal hearing or a scheduled date of departure and the consequences
of knowingly filing any frivolous applications. My client knowingly
and voluntarily waives the oral notice required by INA § 240(b)(7).
As to each of these points, I am satisfied my client
understands fully. On behalf of my client, he/she enters the following
plea before this Court:
1. Admits allegation(s) #_______________ to _______________
Denies allegation(s) # _______________ to _______________.
2. Admits the charge(s) of removability or denies
the charge(s) of removability.
3. Seeks the following applications for relief from
removal: (state applications to include
termination of proceedings).
4. Requests until (state date to be filed) to submit
such applications to the Court with proper certification to the Office
of the Chief Counsel, Department of Homeland Security.
5. Represents to the Court that my client is prima
facie eligible for the relief stated herein.
6. Requests (time/hours) to present my client’s
case in chief.
7. Lastly, my client designates (state name of country)
as his/her country of choice for removal if removal becomes necessary.
BY AUTHORITY OF: