MOTION TO TERMINATE REMOVAL PROCEEDINGS

Comprehensive Filing Packet with Supporting Brief, Evidence Checklist, and Proposed Order

IMPORTANT NOTICE TO PRACTITIONERS

This template provides a comprehensive framework for filing a Motion to Terminate Removal Proceedings before the Executive Office for Immigration Review (EOIR). It covers the most commonly invoked grounds for termination, including defective Notice to Appear (NTA), failure of DHS to sustain its burden of proof, pending immigration benefit applications, prosecutorial discretion, and other equitable grounds. Practitioners must tailor this motion to the specific facts and controlling circuit law of the case. Always consult the EOIR Immigration Court Practice Manual and any local court standing orders before filing.

TABLE OF CONTENTS

1. Caption and Document Header
2. Preliminary Statement
3. Procedural History and Statement of Facts
4. Legal Standards
5. Argument
   - 5.1 Defective Notice to Appear
   - 5.2 DHS Failure to Sustain Burden of Proof
   - 5.3 Pending Immigration Benefit Before USCIS
   - 5.4 Prosecutorial Discretion / Administrative Closure
   - 5.5 Termination in the Interest of Justice
   - 5.6 Constitutional and Due Process Grounds
6. Prayer for Relief
7. Stay of Removal Request
8. Evidence and Exhibit Checklist
9. Signature Block
10. Certificate of Service
11. Proposed Order
12. Practitioner Notes and Common Pitfalls
13. Sources and References

1. CAPTION AND DOCUMENT HEADER

UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
IMMIGRATION COURT — [________________________________]
[City, State]

──────────────────────────────────────────────────────────
In the Matter of: )
)
[________________________________], ) File No.: A-[________________________________]
)
Respondent. ) MOTION TO TERMINATE
) REMOVAL PROCEEDINGS
In Removal Proceedings )
) [☐ AND REQUEST FOR STAY OF REMOVAL]
──────────────────────────────────────────────────────────

Hearing Date: [__/__/____]
Hearing Time: [____]
Calendar: ☐ Master Calendar ☐ Individual Merits Hearing

Date Filed: [__/__/____]

2. PRELIMINARY STATEMENT

TO THE HONORABLE IMMIGRATION JUDGE:

Respondent, [________________________________] ("Respondent"), by and through undersigned counsel, respectfully moves this Honorable Court pursuant to 8 C.F.R. § 1003.10(b), 8 C.F.R. § 1240.12(c), and INA § 240 (8 U.S.C. § 1229a) to TERMINATE the above-captioned removal proceedings on the following grounds:

☐ The Notice to Appear ("NTA") is statutorily defective under INA § 239(a)(1), 8 U.S.C. § 1229(a)(1), because it fails to specify the time and/or place of the initial removal hearing.

☐ The Department of Homeland Security ("DHS") has not met and cannot meet its burden of establishing removability by clear and convincing evidence under INA § 240(c)(3)(A), 8 U.S.C. § 1229a(c)(3)(A).

☐ Respondent is the beneficiary of a pending or approved immigration benefit before USCIS, and termination is warranted to allow adjudication of that benefit.

☐ DHS has exercised or should exercise prosecutorial discretion, and termination or administrative closure is appropriate.

☐ Termination is warranted in the interest of justice and judicial economy.

☐ Other: [________________________________]

In the alternative, Respondent requests that the Court:
- ☐ Administratively close these proceedings pending adjudication of [________________________________]; or
- ☐ Dismiss the NTA without prejudice; or
- ☐ Grant any other relief the Court deems just and proper.

This motion is supported by the attached memorandum of law, exhibits, and the declaration of [________________________________].

3. PROCEDURAL HISTORY AND STATEMENT OF FACTS

3.1 Procedural History

1. On [__/__/____], DHS served a Notice to Appear ("NTA") on Respondent alleging removability under INA § [________________________________], 8 U.S.C. § [________________________________].

2. The NTA was filed with this Court on [__/__/____], at which time removal proceedings were initiated.

3. Respondent first appeared before this Court on [__/__/____] at a Master Calendar hearing.

4. At the initial hearing, Respondent, through counsel:
   ☐ Admitted the factual allegations
   ☐ Denied the factual allegations (specifically: [________________________________])
   ☐ Conceded the charge(s) of removability
   ☐ Denied the charge(s) of removability
   ☐ Designated [________________________________] as the country of removal

5. Respondent has sought the following forms of relief:
   ☐ Asylum under INA § 208
   ☐ Withholding of Removal under INA § 241(b)(3)
   ☐ Protection under the Convention Against Torture (CAT)
   ☐ Cancellation of Removal under INA § 240A
   ☐ Adjustment of Status under INA § 245
   ☐ Voluntary Departure under INA § 240B
   ☐ Other: [________________________________]

6. Subsequent hearing dates and actions:
   - [__/__/____]: [________________________________]
   - [__/__/____]: [________________________________]
   - [__/__/____]: [________________________________]

3.2 Statement of Facts

7. Respondent is a [____]-year-old citizen and national of [________________________________], who entered the United States on [__/__/____] by:
   ☐ Inspection and admission at [________________________________] with classification [________________________________]
   ☐ Parole at [________________________________]
   ☐ Without inspection near [________________________________]
   ☐ Other: [________________________________]

8. Respondent currently resides at [________________________________] with [________________________________] (relationship).

9. Respondent's immigration history includes:
   [________________________________]
   [________________________________]
   [________________________________]

10. Additional facts relevant to this motion:
    [________________________________]
    [________________________________]
    [________________________________]
    [________________________________]

4. LEGAL STANDARDS

4.1 Authority to Terminate

Immigration Judges possess broad authority to terminate removal proceedings. Under 8 C.F.R. § 1003.10(b), an Immigration Judge "shall exercise independent judgment and discretion and may take any action consistent with their authorities under the Act and regulations that is appropriate and necessary for the disposition of such cases." The regulatory authority at 8 C.F.R. § 1240.12(c) expressly provides that an Immigration Judge's orders "may direct ... termination of proceedings, or other such disposition of the case as may be appropriate."

4.2 Burden of Proof

In removal proceedings, DHS bears the burden of establishing by clear and convincing evidence that the respondent is an alien and is removable as charged. INA § 240(c)(3)(A), 8 U.S.C. § 1229a(c)(3)(A). Where the respondent has made a prima facie showing of citizenship or nationality, DHS bears the burden of proving alienage. INA § 240(c)(2), 8 U.S.C. § 1229a(c)(2).

4.3 NTA Statutory Requirements

INA § 239(a)(1), 8 U.S.C. § 1229(a)(1), enumerates the required contents of an NTA, including:
- The nature of the proceedings against the alien (subparagraph (A))
- The legal authority under which the proceedings are conducted (subparagraph (B))
- The acts or conduct alleged to constitute a violation of law (subparagraph (C))
- The charges against the alien and the statutory provisions alleged to have been violated (subparagraph (D))
- The right to representation (subparagraph (E))
- The consequences of failure to appear (subparagraph (F))
- The time and place at which the proceedings will be held (subparagraph (G))

4.4 Controlling Case Law

The Supreme Court addressed NTA requirements in Pereira v. Sessions, 138 S. Ct. 2105 (2018), holding that a putative NTA that fails to specify the time or place of removal proceedings does not qualify as a "notice to appear" under 8 U.S.C. § 1229(a). The Court subsequently held in Niz-Chavez v. Garland, 141 S. Ct. 1474 (2021), that the government must provide all required information in a single document, rather than across multiple documents.

The BIA has addressed the jurisdictional implications of defective NTAs in Matter of Bermudez-Cota, 27 I&N Dec. 441 (BIA 2018), holding that filing of a defective NTA that omits time and place information does not deprive the immigration court of jurisdiction, provided a subsequent notice of hearing is served.

Controlling circuit precedent in this case: [________________________________]

5. ARGUMENT

5.1 The Notice to Appear Is Statutorily Defective

(Select if applicable)

INA § 239(a)(1)(G), 8 U.S.C. § 1229(a)(1)(G), requires that an NTA specify "the time and place at which the proceedings will be held." The NTA served on Respondent on [__/__/____] is defective in the following respects:

☐ The NTA failed to specify the date of the initial hearing, instead stating "TBD" or "to be determined" or leaving the date field blank.

☐ The NTA failed to specify the time of the initial hearing.

☐ The NTA failed to specify the location of the hearing.

☐ The NTA contained an incorrect date, time, or location.

☐ The NTA was not properly served on Respondent in accordance with INA § 239(a)(1).

☐ The NTA was served via [________________________________] rather than personal service as required.

☐ Other deficiency: [________________________________]

A copy of the defective NTA is attached hereto as Exhibit [____].

Analysis under Pereira v. Sessions:

In Pereira v. Sessions, 138 S. Ct. 2105, 2110 (2018), the Supreme Court held that "[a] putative notice to appear that fails to designate the specific time or place of the noncitizen's removal proceedings is not a 'notice to appear under section 1229(a)' and therefore does not trigger the stop-time rule." While Pereira directly addressed the stop-time rule under INA § 240A(d)(1), its reasoning regarding the statutory definition of an NTA has broader implications.

In Niz-Chavez v. Garland, 141 S. Ct. 1474 (2021), the Supreme Court reinforced that the government cannot meet the NTA requirements by serving information piecemeal across multiple documents.

Circuit-specific analysis: [________________________________]

[Additional argument regarding NTA deficiency]

5.2 DHS Has Not Met Its Burden to Establish Removability

(Select if applicable)

DHS bears the burden of establishing by clear and convincing evidence that Respondent is removable as charged. INA § 240(c)(3)(A). DHS has failed to sustain this burden for the following reasons:

☐ DHS has not established Respondent's alienage. The certified DHS file lacks sufficient, legally admissible evidence to prove that Respondent is not a United States citizen or national. Specifically: [________________________________]

☐ DHS has not established the charged ground of removability. The evidence in the record does not support a finding that Respondent violated INA § [________________________________] because: [________________________________]

☐ The Form I-213 (Record of Deportable/Inadmissible Alien) relied upon by DHS is unreliable and should be accorded diminished evidentiary weight because: [________________________________]

☐ DHS has failed to produce credible evidence of the alleged conviction or criminal disposition. The court records submitted are incomplete, ambiguous, or do not constitute qualifying convictions under the categorical approach established by the Supreme Court in Taylor v. United States, 495 U.S. 575 (1990), and its progeny.

☐ The conviction record does not satisfy the modified categorical approach because: [________________________________]

☐ Other: [________________________________]

Accordingly, because DHS has failed to carry its burden under INA § 240(c)(3)(A), these proceedings must be terminated.

5.3 Termination Is Warranted Due to Pending Immigration Benefit

(Select if applicable)

Respondent is the beneficiary of a pending or approved immigration benefit before USCIS, and termination of these proceedings is appropriate to permit adjudication of that benefit.

☐ Approved Petition: Respondent is the beneficiary of an approved Form [________________________________] (receipt number: [________________________________]), filed by [________________________________] on [__/__/____] and approved on [__/__/____].

☐ Pending Petition: Respondent is the beneficiary of a pending Form [________________________________] (receipt number: [________________________________]), filed by [________________________________] on [__/__/____].

☐ Visa Availability: A visa number is currently available to Respondent under the [________________________________] preference category per the Department of State Visa Bulletin dated [________________________________].

☐ Naturalization: Respondent has a pending Form N-400 (Application for Naturalization) filed on [__/__/____] (receipt number: [________________________________]).

☐ VAWA Self-Petition: Respondent has a pending or approved Form I-360 VAWA self-petition.

☐ Other: [________________________________]

The regulations and case law support termination where a respondent has an avenue for obtaining lawful status outside removal proceedings. See, e.g., Matter of Yauri, 25 I&N Dec. 103 (BIA 2009); Matter of Lozada, 19 I&N Dec. 637 (BIA 1988).

Evidence of the pending/approved benefit is attached as Exhibit [____].

5.4 Prosecutorial Discretion and Administrative Closure

(Select if applicable)

☐ DHS/OPLA has indicated that it does not oppose termination. A copy of DHS's statement or correspondence is attached as Exhibit [____].

☐ Respondent has submitted a prosecutorial discretion request to the Office of the Principal Legal Advisor (OPLA) on [__/__/____]. A copy of the request is attached as Exhibit [____].

☐ Respondent requests administrative closure pending resolution of [________________________________], in accordance with the regulatory framework governing administrative closure.

The Department of Justice has promulgated regulations codifying the authority of EOIR adjudicators to administratively close or terminate removal proceedings when appropriate. Under the current regulatory framework, immigration judges may consider the totality of the circumstances, including but not limited to:

• The reason administrative closure is sought
• The basis for any opposition
• The likelihood that the respondent will succeed on any petition, application, or motion
• The anticipated duration of the closure
• The responsibility of the parties in contributing to any current or anticipated delay
• The ultimate outcome of the case if the motion is granted

No single factor is dispositive.

5.5 Termination Is Warranted in the Interest of Justice

Termination of these proceedings is warranted in the interest of justice and judicial economy for the following reasons:

☐ Respondent has strong equitable ties to the United States, including:
- Length of residence: [________________________________]
- U.S. citizen or LPR family members: [________________________________]
- Employment history: [________________________________]
- Community ties: [________________________________]
- No criminal history (or minimal/dated criminal history): [________________________________]

☐ Continuation of proceedings serves no valid immigration enforcement purpose because: [________________________________]

☐ Termination will conserve judicial resources and promote administrative efficiency because: [________________________________]

☐ DHS retains the authority to reinstate proceedings if warranted, and termination without prejudice poses no prejudice to DHS.

☐ Other equitable considerations: [________________________________]

5.6 Constitutional and Due Process Grounds

(Select if applicable)

☐ Respondent's due process rights under the Fifth Amendment have been violated because: [________________________________]

☐ The immigration enforcement action was the product of racial profiling or selective prosecution in violation of the Equal Protection Clause.

☐ Respondent was denied meaningful access to counsel during critical stages of the proceedings.

☐ Respondent was subjected to coercion, duress, or other improper conduct during the arrest or processing.

☐ Other constitutional ground: [________________________________]

Evidence supporting these claims is attached as Exhibit [____].

6. PRAYER FOR RELIEF

WHEREFORE, Respondent respectfully requests that this Honorable Court:

A. TERMINATE these removal proceedings with prejudice, or in the alternative, without prejudice;

B. In the alternative, ADMINISTRATIVELY CLOSE these proceedings pending adjudication of [________________________________];

C. In the further alternative, DISMISS the Notice to Appear;

D. In the further alternative, CONTINUE these proceedings to a date certain to permit [________________________________];

E. GRANT any and all other relief that justice may require.

7. STAY OF REMOVAL REQUEST

(Include if applicable)

Respondent respectfully requests that the Court enter an order staying Respondent's removal from the United States pending adjudication of this Motion, or in the alternative, that the Court affirmatively stay removal to preserve jurisdiction and prevent irreparable harm.

Grounds for Stay

1. Respondent is likely to succeed on the merits of this motion because: [________________________________]

2. Respondent will suffer irreparable harm if removed because: [________________________________]

3. The balance of hardships tips in Respondent's favor because: [________________________________]

4. A stay of removal is in the public interest because: [________________________________]

See 8 C.F.R. § 1003.23(b)(1); Nken v. Holder, 556 U.S. 418 (2009) (establishing stay factors in the immigration context).

8. EVIDENCE AND EXHIBIT CHECKLIST

Required Documents

☐ Copy of Notice to Appear (NTA) and all subsequent hearing notices
☐ Form EOIR-28 (Notice of Entry of Appearance as Attorney or Representative), if not previously filed
☐ Respondent's Declaration or Affidavit (sworn under 28 U.S.C. § 1746)
☐ Copy of this Motion to Terminate with Memorandum of Law
☐ Proposed Order

Identity and Status Documents

☐ Copy of Respondent's passport (biographical page)
☐ Copy of I-94 Arrival/Departure Record
☐ Copy of any visa stamps or immigration documents
☐ Copy of any prior immigration applications or petitions
☐ Birth certificate (with certified English translation if applicable)

Evidence Supporting Termination Grounds

NTA Deficiency (Section 5.1):
☐ Original or copy of the defective NTA
☐ Envelope or mailing documentation showing service method
☐ Any subsequent hearing notices (Form I-830, EOIR hearing notices)
☐ Controlling circuit case law on NTA defects (printed copies)

Burden of Proof (Section 5.2):
☐ DHS evidence file (Form I-213, Form I-862, etc.)
☐ Expert affidavits challenging alienage or removability
☐ Criminal disposition records (certified copies)
☐ Modified categorical approach analysis for conviction-based charges

Pending Immigration Benefit (Section 5.3):
☐ Copy of approved/pending petition (I-130, I-140, I-360, etc.)
☐ USCIS receipt notices
☐ Visa Bulletin showing current priority date
☐ Proof of prima facie eligibility for the benefit

Prosecutorial Discretion (Section 5.4):
☐ Copy of prosecutorial discretion request to OPLA
☐ DHS/OPLA response or correspondence
☐ Evidence of positive equities (employment records, tax returns, community service)

Equitable Grounds (Section 5.5):
☐ Proof of family ties (birth certificates, marriage certificates of USC/LPR family members)
☐ Employment verification letters
☐ Tax returns (last 3-5 years)
☐ Letters of support from community members, employers, religious leaders
☐ School records (for Respondent or Respondent's children)
☐ Property ownership or lease agreements
☐ Medical records (if health conditions relevant)

Due Process / Constitutional Grounds (Section 5.6):
☐ Declarations from witnesses to the arrest or enforcement action
☐ Body camera or surveillance footage (if available)
☐ Records of requests for counsel that were denied
☐ Evidence of racial profiling or selective enforcement

Exhibit Index

9. SIGNATURE BLOCK

Respectfully submitted,

_________________________________ Date: [__/__/____]
[________________________________]
Attorney Name, Esq.
[________________________________]
Law Firm / Organization
[________________________________]
Street Address
[________________________________]
City, State, ZIP
[________________________________]
Telephone
[________________________________]
Email Address
[________________________________]
State Bar Number

Attorney for Respondent

10. CERTIFICATE OF SERVICE

I, [________________________________], hereby certify that on [__/__/____], I served a true and correct copy of the foregoing Motion to Terminate Removal Proceedings, together with all attached exhibits, on the following parties by the method indicated:

Department of Homeland Security / Office of Chief Counsel:

☐ Hand delivery at the Immigration Court, [________________________________]
☐ First-class U.S. mail, postage prepaid, to:
Office of Chief Counsel
U.S. Department of Homeland Security
Immigration and Customs Enforcement
[________________________________]
[________________________________]
☐ Electronic filing via EOIR Courts & Appeals System (ECAS)
☐ Other: [________________________________]

Immigration Court (if required by local rule):

☐ Filed with the Immigration Court Clerk at [________________________________]
☐ Filed electronically via ECAS
☐ Other: [________________________________]

_________________________________ Date: [__/__/____]
[________________________________]
Attorney Name

11. PROPOSED ORDER

UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
IMMIGRATION COURT — [________________________________]

──────────────────────────────────────────────────────────
In the Matter of: )
)
[________________________________], ) File No.: A-[________________________________]
)
Respondent. ) ORDER
──────────────────────────────────────────────────────────

Upon consideration of Respondent's Motion to Terminate Removal Proceedings
and any opposition thereto, and for good cause shown, it is hereby:

☐ ORDERED that the Motion is GRANTED, and these proceedings are
TERMINATED [☐ with prejudice / ☐ without prejudice].

☐ ORDERED that the Motion is GRANTED IN PART, and these proceedings
are ADMINISTRATIVELY CLOSED pending [________________________________].

☐ ORDERED that the Motion is DENIED for the following reasons:
[________________________________]

☐ ORDERED that removal is STAYED pending [________________________________].

SO ORDERED.

Dated: [__/__/____]

_________________________________
Immigration Judge
[________________________________]

12. PRACTITIONER NOTES AND COMMON PITFALLS

Filing Requirements

1. Practice Manual Compliance: All filings must comply with the EOIR Immigration Court Practice Manual. See Chapter 3 (Filing with the Immigration Court) and Chapter 4 (Motions Before the Immigration Court). Motions must include a proposed order. See Practice Manual § 4.16(d).

2. Service Requirements: A copy of every filing must be served on DHS/ICE Office of Chief Counsel simultaneously with filing. Proof of service must be included. See Practice Manual § 3.1(a).

3. Response Deadlines: DHS typically has 10 days to respond to a motion filed before a master calendar hearing. Check local court standing orders for any variations.

4. Page Limits: Check local standing orders for any page limitations on motions.

5. EOIR-28 Requirement: If counsel has not previously entered an appearance, file Form EOIR-28 (Notice of Entry of Appearance) with this motion.

Substantive Considerations

6. Circuit Law Matters: The legal standards for termination vary significantly by circuit. In particular, the impact of Pereira v. Sessions and Niz-Chavez v. Garland on NTA-based termination arguments differs across circuits. Always research current circuit precedent.

7. Termination vs. Dismissal vs. Administrative Closure: These are distinct forms of relief with different consequences:
   - Termination: Ends proceedings; DHS must file a new NTA to recommence.
   - Dismissal: Similar to termination but may be with or without prejudice.
   - Administrative Closure: Removes the case from the active docket but does not end proceedings; either party may move to recalendar.

8. Timing: File this motion as early as possible, ideally before the merits hearing. Some courts prefer these motions at the master calendar stage.

9. DHS Opposition: Be prepared for DHS opposition. Consider requesting oral argument if the motion is contested.

10. Prejudice Argument: If seeking termination due to a pending USCIS benefit, articulate clearly why administrative closure (rather than termination) is insufficient, or in the alternative, why administrative closure would be acceptable.

Evidentiary Tips

11. Organize Exhibits: Use tabbed dividers and consecutive numbering. Place the most critical exhibit first. See Practice Manual §§ 3.3 and 4.5.

12. Translations: All non-English documents must be accompanied by certified English translations per 8 C.F.R. § 1003.33.

13. Declarations: Declarations should be signed under penalty of perjury pursuant to 28 U.S.C. § 1746 and should be detailed, specific, and tied to the legal elements.

14. Country Conditions: If relevant (e.g., for a pending asylum case), include recent country conditions evidence from the Department of State, human rights organizations, or news reports.

15. Criminal Records: If the charge of removability is based on a criminal conviction, obtain certified court records, plea transcripts, and judgment documents. Apply the categorical approach or modified categorical approach as appropriate.

Post-Filing Considerations

16. Appeal: If the motion is denied, the denial may be appealable to the Board of Immigration Appeals (BIA) via Form EOIR-26 within 30 days. However, consider whether an interlocutory appeal is available.

17. Renewed Motions: If the court denies the motion, consider whether changed circumstances or new evidence would support a renewed motion.

18. Preserving the Record: Object on the record to any procedural irregularities or evidentiary rulings to preserve issues for appeal.

13. SOURCES AND REFERENCES

Statutes

• INA § 101(a)(42)(A), 8 U.S.C. § 1101(a)(42)(A) — Definition of Refugee
• INA § 208, 8 U.S.C. § 1158 — Asylum
• INA § 239(a), 8 U.S.C. § 1229(a) — Notice to Appear Requirements
• INA § 240, 8 U.S.C. § 1229a — Removal Proceedings
• INA § 240(c)(2)-(3), 8 U.S.C. § 1229a(c)(2)-(3) — Burden of Proof
• INA § 240A, 8 U.S.C. § 1229b — Cancellation of Removal
• INA § 240B, 8 U.S.C. § 1229c — Voluntary Departure
• INA § 241(b)(3), 8 U.S.C. § 1231(b)(3) — Withholding of Removal

Regulations

• 8 C.F.R. § 1003.10(b) — Immigration Judge Powers and Authority
• 8 C.F.R. § 1003.13 — Filing of Charges
• 8 C.F.R. § 1003.14(a) — Jurisdiction and Commencement of Proceedings
• 8 C.F.R. § 1003.23 — Motions to Reopen or Reconsider
• 8 C.F.R. § 1003.33 — Translation of Documents
• 8 C.F.R. § 1240.12(c) — Orders of the Immigration Judge
• 8 C.F.R. § 265.1 — Change of Address Notification

Case Law

• Pereira v. Sessions, 138 S. Ct. 2105 (2018)
• Niz-Chavez v. Garland, 141 S. Ct. 1474 (2021)
• Nken v. Holder, 556 U.S. 418 (2009)
• Taylor v. United States, 495 U.S. 575 (1990)
• Matter of Bermudez-Cota, 27 I&N Dec. 441 (BIA 2018)
• Matter of Yauri, 25 I&N Dec. 103 (BIA 2009)
• Matter of Lozada, 19 I&N Dec. 637 (BIA 1988)

Practice Resources

• EOIR Immigration Court Practice Manual (current edition)
• EOIR Policy Manual, Part III (BIA)
• American Immigration Council, Practice Advisory: Seeking Administrative Closure and Termination (February 2025)
• Immigrant Legal Resource Center (ILRC), Practice Advisories on NTA Defects and Termination
• National Immigration Litigation Alliance (NILA), Defective NTA Case Write-Ups

This template is provided for informational purposes only and does not constitute legal advice. Immigration law is complex, subject to frequent change, and outcomes may depend on jurisdiction-specific precedent. This document must be reviewed and customized by a qualified immigration attorney admitted to practice before the relevant immigration court. No attorney-client relationship is created by the use of this template.