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Shared Practice Manual Appendices

Appendix L - Ex. Oral Pleading

Prior to entering a pleading, parties are expected to have reviewed the pertinent regulations, as well as ICPM, Chapter 4 (Hearings Before Immigration Judges).

I, [state your name], on behalf of [state the name of your client], do concede proper service of the Notice to Appear dated [state date of the NTA], and waive a formal reading thereof.

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 their 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 as well as the consequences under section 208(d)(6) of the Act of knowingly filing or making a frivolous asylum application.  My client knowingly and voluntarily waives the oral notice required by section 240(b)(7) of the Act.

As to each of these points, I am satisfied my client understands fully. On behalf of my client, I enter the following plea before this court:

One, my client admits allegation(s) # [charge number(s) from NTA] to [charge number(s) from NTA].


my client denies allegation(s) # [charge number(s) from NTA] to [charge number(s) from NTA].

Two, my client concedes the charge(s) of removability.


my client denies the charge(s) of removability.

Three, my client seeks the following applications for relief from removal: [state all applications, including termination of proceedings, if applicable].

My client acknowledges that if any applications are not timely filed, the applications will be deemed waived and abandoned under 8 C.F.R. § 1003.31(c). My client acknowledges receipt of the DHS biometrics instructions, and understands that, under 8 C.F.R. § 1003.47(d), failure to timely comply with the biometrics instructions will constitute abandonment of the applications.

I request until [state date to be filed] to submit such applications to the court with proper service on DHS.

I represent to the court that my client is prima facie eligible for the relief stated herein.

I request [time/hours] to present my client’s case in chief.

I request an interpreter proficient in the [state name of language] language, [state name of any applicable dialect] dialect.


I represent that my client is proficient in English and will not require the services of an interpreter. If any witnesses require an interpreter, I will notify the court no later than fifteen days prior to the individual calendar hearing.

My client designates [state name of country] as the country of choice for removal if removal becomes necessary.


My client declines to designate a country of removal.