IMMIGRATION BOND MOTION PACKET

MOTION FOR CUSTODY REDETERMINATION AND BOND

Filing Overview

• Respondent: [NAME], A#: [A-NUMBER]
• Detained at: [FACILITY]; Custody status: [NO BOND/BOND $___]
• Hearing info: IJ court/location; Date/time requested/assigned: [DETAILS]
• Convictions/charges: [LIST]; Removability charges: [INA SECTIONS]
• Relief pursued: [ASYLUM/WITHHOLDING/CAT/OTHERS]

Packet Order (suggested)

1) Cover letter to EOIR with motion and proposed order.
2) Notice of Appearance (E-28) if not already filed.
3) Motion for custody redetermination (with legal standard and bond factors).
4) Proposed order.
5) Evidence of eligibility and equities:
- Identity/A#: passport/ID/biographic documents.
- Family ties: marriage/birth certificates; proof of USC/LPR relatives.
- Community support: letters from employers, faith/community leaders; volunteer records.
- Residence stability: lease/deed, utilities, affidavits from household members.
- Employment/financial support: pay stubs, employer letter, tax filings.
- Rehabilitation/criminal mitigation: certified dispositions, program completions, character references.
- Relief likelihood: I-589 receipt/draft, prima facie eligibility summary, country reports (if relevant).
6) Certificate of service on DHS OPLA.
7) Filing/service proof (email/fax/ECAS/hand delivery per local rules).

Cover Letter Body (sample)

text
Date: [DATE]

Immigration Court [CITY/STATE]
Attn: Immigration Judge [NAME]

RE: Motion for Custody Redetermination and Bond - [NAME, A#]

Dear Immigration Judge:

Enclosed is a motion for custody redetermination requesting release on bond in the amount of $[AMOUNT] or, alternatively, on recognizance. The respondent has strong community ties, no danger to the community, and is not a flight risk. Evidence supporting these factors and the likelihood of success on relief is attached.

Respectfully,
[NAME/ATTORNEY]

Bond Motion Outline (IJ)

1) Introduction and relief requested.
2) Procedural posture and detention history.
3) Legal standard (danger and flight risk).
4) Application of factors: family/community ties, employment, residence, rehabilitation, relief merits.
5) Requested bond amount/conditions (check-ins, ankle monitor if applicable).
6) Conclusion and proposed order.

Practice Notes

• Verify custody eligibility; some categories are ineligible or subject to mandatory detention.
• Confirm court-specific filing/service rules and timing for redetermination.
• Prepare respondent and witnesses for bond hearing testimony; include interpreter requests.
• Provide DHS counsel with courtesy copy; negotiate stipulations when possible.
• Keep exhibits organized and paginated for quick IJ reference.