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CRM 1500-1999

1938. Appendix H -- Factual Allegations In Support Of Request For Judicial Order Of Deportation (Multiple CIMT)

Outdated—pending revision.


Factual Allegations in Support of Request for Judicial Order of Deportation (Multiple Crimes Involving Moral Turpitude)

(8 U.S.C. § 1252a(d))

The United States Attorney Charges:

  1. The defendant, ____________, is not a citizen or national of the United States.
  2. Defendant is a native of____________, and a citizen of______________.
  3. Defendant entered the United States at/near ____________ on or about ____________, 19__.
  4. At that time, Defendant entered as a ______________.
  5. At the time of sentencing in this criminal proceeding, Defendant will be convicted in this court for the offenses of ___________, committed on or about __________, 19__, in violation of _________; and ____________, committed on or about____________, 19__, in violation of _______________.

Wherefore, at his sentencing, Defendant will be subject to deportation under Section 241(a)(2)(A)(ii) of the Immigration and Nationality Act, as amended (Act), (8 U.S.C. § 1251(a)(2)(A)(ii)), in that he will have been convicted of two or more crimes involving moral turpitude at any time after entry, not arising out of a single scheme of criminal misconduct, regardless of whether confined therefor and regardless of whether the convictions were in a single trial.

Accordingly, pursuant to Section 242A(d) of the Act, 8 U.S.C. § 1252a(d), the Government requests that this Court, after imposing sentence, order that the defendant be deported from the United States so that promptly upon his release from confinement herein, the Immigration and Naturalization Service may execute said deportation order according to applicable laws and regulations.


United States Attorney


Based upon the factual allegations stated above, on behalf of the Commissioner of the Immigration and Naturalization Service, I concur in the request by the Government herein that a judicial order of deportation be issued.



NOTE: The INS concurrence may also be in the form of an appended letter from the authorized official.

[cited in Criminal Resource Manual 1926; JM 9-73.500]