Category Archives: citizenship

COVID-19 Update: Certain USCIS Field Offices Plan to Reopen to the Public

Posted on June 5, 2020 | Comments Off on COVID-19 Update: Certain USCIS Field Offices Plan to Reopen to the Public

As of June 4, some USCIS Field Offices are planning to reopen for in-person services to the public. The Application Support Centers plan to reopen later. The Field Offices and Application Support Centers have been closed to the public since March 18, in response to the COVID-19 pandemic.

The reopening of certain USCIS Field Offices will allow the scheduling and rescheduling of interviews for green cards, naturalization, and other U.S. immigration benefits. Biometrics appointment scheduling and rescheduling will also resume when the Application Support Centers reopen.

USCIS is following the Centers of Disease Control and Prevention’s guidelines to protects its employees and the public. USCIS intends to limit the number of appointments and interviews per day, regularly clean and sanitize its facilities, and restrict the number of persons in waiting rooms.

USCIS’ Health & Safety Guidelines

USCIS provided the following guidelines when visiting their offices.

  • You may not enter a USCIS facility if you:
    • Have any symptoms of COVID-19, including cough, fever or difficulty breathing;
    • Have been in close contact with anyone known or suspected to have COVID-19 in the last 14 days; or
    • Have been individually directed to self-quarantine or self-isolate by a health care provider or public health official within the last 14 days.
  • You may not enter the facility more than 15 minutes prior to your appointment (30 minutes for naturalization ceremonies).
  • You are encouraged to use hand sanitizer provided at entry points. 
  • You must wear facial covering (face mask) that covers both the mouth and nose when entering facilities. If you do not have one, USCIS may provide one or you will be asked to reschedule your appointment.
  • You should pay close attention to markings and physical barriers in the facility and follow social distancing guidelines.
  • You may have to answer health screening questions before entering a facility. 
  • You are encouraged to bring your own black or blue ink pens.
  • Individuals are encouraged to bring their own black or blue ink pens.

USCIS will send you an appointment notice when your interview or biometrics appointment is scheduled or rescheduled. The notice will provide more details for visiting USCIS offices. If you feel sick, you are urged to request a cancellation or rescheduling of your appointment.

While USCIS is readying certain offices to reopen on or after June 4, its employees are continuing to perform mission-critical services that do not involve face-to-face contact with the public. Most likely, the earliest date for reopening of some offices will be in July.

The reopening will not only provide relief to applicants, but may help bring much-needed revenue to USCIS. In Mid-May, the agency announced it will run out of money by the summer because the coronavirus pandemic led to a steep drop in applications and filing fees since March. Unlike most federal agencies, USCIS operates almost entirely on revenue from application fees. It requested $1.2 billion from Congress to help it stay afloat, and proposed a 10% surcharge to application fees in the coming months.

Not every application or petition for a U.S. immigration benefit requires a face-to-face interview with a USCIS officer. The USCIS Service Centers are also continuing to accept applications and petitions and issue Receipt Notices and other correspondences, even while Field Offices remain closed to the public.

For the latest information on individual offices, check the USCIS Office Closing page.

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This article provides general information only. It is based on law, regulations and policy that are subject to change. Do not consider it as legal advice for any individual case or situation. Each legal case is different and case examples do not constitute a prediction or guarantee of success or failure in any other case. The sharing or receipt of this information does not create an attorney-client relationship.

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Posted in adjustment of status, citizenship, green card, I-751, immigrant petition, naturalization, The Legal Immigrant - Immigration Blog

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COVID-19 Update: USCIS Offices Temporarily Closed to the Public, March 18 to April 1

Posted on March 18, 2020 | Comments Off on COVID-19 Update: USCIS Offices Temporarily Closed to the Public, March 18 to April 1

As of March 18, 2020, U.S. Citizenship and Immigration Services has suspended routine in-person services until at least April 1 to help slow the spread of COVID-19 (Coronavirus Disease 19). There will be no USCIS Field Office interviews, USCIS Application Support Center biometrics appointments, asylum interviews, or naturalization oath ceremonies during this period.

Field Office Appointments

USCIS Field Offices will send notices with instructions to applicants and petitioners with scheduled interview appointments. When normal operations resume, USCIS will automatically reschedule the interviews and issue new notices.

Persons who had InfoPass appointments with a Field Office must reschedule through the USCIS Contact Center, after the Field Office is reopened.

Check the USCIS Field Offices page to see if your field office has reopened before reaching out to the USCIS Contact Center.

Application Support Center (ASC) Appointments

All biometrics appointments at USCIS Application Support Centers are suspended. When normal operations resume, USCIS will automatically reschedule the biometrics appointments and issue new notices. If you do not receive a new appointment notice by mail within 90 days, call 800-375-5283.

USCIS is unable to automatically reschedule appointments for Canadian and United Kingdom visa applicants.

Asylum Appointments

USCIS asylum offices will send interview cancellation notices and automatically reschedule asylum interviews. When the interview is rescheduled, asylum applicants will receive a new interview notice with the new time, date, and location.

Naturalization Oath Ceremonies

Naturalization oath ceremonies are cancelled. When normal operations resume, USCIS will automatically reschedule naturalization oath ceremonies. If you do not receive a new naturalization oath ceremony notice by mail within 90 days, you may contact the USCIS Contact Center.

During the temporary closure, USCIS staff will continue to perform duties that do not involve contact with the public. USCIS Service Centers and the National Benefits Center will receive and process applications and petitions; the National Records Center will receive and process FOIA requests; and the Administrative Appeals Office will receive and adjudicate appeals of denied benefits.

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This article provides general information only. It is based on law, regulations and policy that are subject to change. Do not consider it as legal advice for any individual case or situation. Each legal case is different and case examples do not constitute a prediction or guarantee of success or failure in any other case. The sharing or receipt of this information does not create an attorney-client relationship.

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Posted in adjustment of status, citizenship, green card, I-751, naturalization, The Legal Immigrant - Immigration Blog

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Combined Approval of Form I-751, Petition to Remove Conditions on Residence + Form N-400, Application for Naturalization = A True Success Story

Posted on March 15, 2019 | Comments Off on Combined Approval of Form I-751, Petition to Remove Conditions on Residence + Form N-400, Application for Naturalization = A True Success Story
USCIS Field Office in California

A USCIS Field Office in California approved both our client’s Form I-751 petition to remove conditions on residence and Form N-400 application for naturalization in a single naturalization interview, held in early March 2019. With the conditions on his residence now removed, he is set to attend his naturalization oath ceremony and become a U.S. citizen.

Conditional Resident Awaiting I-751 Decision May Consider Filing For Naturalization

In many cases, conditional residents are eligible to file for naturalization before the conditions on their residence are removed and they get the regular, 10-year green card. Persons who are granted marriage-based permanent residence when the marriage to the U.S. citizen petitioner is less than two years old are issued a two-year, conditional green card. To get the conditions removed and maintain lawful permanent residence, the applicant and his spouse must file a joint I-751 petition before the two-year card expires, and no earlier than 90 days before the expiration. There are only three types of waivers (exceptions) to the joint filing requirement.

Continuous residence is one eligibility requirement for naturalization. You must reside continuously in the U.S. for at least 5 years as a permanent resident at the time you file your naturalization application. An exception is if you are a qualified spouse of a U.S. citizen, in which case your continuous residence must be at least 3 years at the time you file for naturalization. Continuous residence for naturalization purposes begins on the start date of your permanent residence, even if it is conditional.

As of June 2018, USCIS began issuing Receipt Notices for I-751 petitions that automatically extend the conditional resident status for 18 months past the expiration date of the two-year card. Previously, the extension was for 12 months, after which the person would need to obtain a temporary I-551 stamp (evidence of conditional residence) at a local USCIS office. The change was made to accommodate longer processing times for I-751s and to allow conditional residents to automatically keep their lawful status and maintain work and travel authorization in the interim.

Naturalization Interview Scheduled Before Conditions Removed

Our client’s naturalization interview was scheduled before he received a decision on the Form I-751 petition. At the naturalization interview, the USCIS officer exercised his authority to approve the I-751 even though it was still sitting at a USCIS Service Center awaiting adjudication. This cleared the way for the conditional resident to become a U.S. citizen.

Filing of Form I-751 Petition

Although both the Form N-400 and Form I-751 may be pending at the same time, the I-751 must be filed first in most cases. The two exceptions are if the conditional resident is filing for naturalization on the basis of qualifying military service or as the spouse of a U.S. citizen employed abroad, and thus may be naturalized without removal of conditions. In all other situations, such as our client’s, USCIS needs to first approve the I-751 petition before naturalization may be granted.

In December 2017, we filed a timely, joint Form I-751 petition with the USCIS California Service Center in Laguna Niguel, California. To demonstrate the conditional resident entered into and continued to have a good faith marriage with his U.S. citizen spouse, we submitted affidavits describing their relationship, shared car insurance policy, joint bank account and credit card account statements, and evidence of their home ownership.

The I-751 was initially transferred from the California Service Center to another USCIS Service Center. In June 2018, we received a Transfer Notice from the Service Center in Arlington, VA stating it was transferring the I-751 back to the California Service Center to speed up processing. Then in December 2018, we received a Transfer Notice from the California Service Center stating it completed a preliminary review of the petition and was transferring the case to the National Benefits Center in Lee’s Summit, MO for adjudication.

Filing of Form N-400 Application

The I-751 had been pending with USCIS for 10 months when the naturalization application was filed. Within three months of receiving the Form N-400, our client received his naturalization interview notice. It did not instruct him to have his U.S. citizen spouse accompany him or to bring evidence of their bona fide marriage. Nonetheless, I counseled him to do so, particularly because USCIS had yet to approve the I-751 petition and lift the conditions on his residence.

Attorney Appearance at Out-of-State Naturalization Interview

With our law firm based in Minneapolis, Minnesota, I flew out to California to attend the naturalization interview. My client could have retained local counsel to appear with him, but he insisted on having me there. (U.S. immigration is governed by federal laws, regulations and policies, which allow for representation at a USCIS Field Office by an out-of-state attorney.) 

The naturalization interview started off with his completing and passing the Civics Test and English Test. Then the USCIS officer went through his naturalization application, page by page. 

To prepare for the naturalization interview, my client and I had discussed potential questions about his marriage to the U.S. citizen petitioner, their relationship history, and his U.S. immigration record. Among his concerns was that he had been previously denied entry to the United States as a visitor by the U.S. Customs & Border Protection, after being employed in the country on a temporary worker visa for an extended period. I advised him on how to best respond truthfully to this issue, which did end up being raised by the USCIS officer at the interview.

Naturalization Expected

When the USCIS officer stated he would approve the N-400 application, I reminded him the I-751 petition was still pending. The officer was not aware of this because the file had not been flagged. He agreed to call in the U.S. citizen spouse, who had accompanied us to the Field Office and was seated in the waiting room.

Both the conditional resident and his spouse answered questions and presented documentary evidence on the bona fide nature of their marriage. At the end of the interview, the officer said he would also approve the I-751 petition. Even though he did not have the original I-751 filing,  and did not review the copy we had with us, he favorably adjudicated the petition based on the testimony and evidence presented.

A day after the interview, USCIS issued the Form I-797, Approval Notice for the I-751 petition. My client soon sent me an email stating, “When I checked online the status of the N-400 on USCIS website it now says they approved my application, and the next step is to wait for the Oath Ceremony invitation letter in the mail, so looking forward to this very much…Thanks again for all your help. You really made a difference in our lives.“

We expect him to be scheduled for a naturalization oath ceremony and to become a U.S. citizen. This is a true success story. 

Cheers,

Dyan Williams

Founder & Principal Attorney
Dyan Williams Law PLLC
(612) 225-9900
info@dyanwilliamslaw.com

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This article provides general information only. It is based on law, regulations and policy that are subject to change. Do not consider it as legal advice for any individual case or situation. Each case is different and case examples do not constitute a prediction or guarantee of success or failure in any other case. The sharing or receipt of this information does not create an attorney-client relationship.

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Posted in bona fide marriage, citizenship, I-751, immigrant petition, naturalization, success story, The Legal Immigrant - Immigration Blog

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Updated Notice to Appear (NTA) Guidance Requires USCIS to Initiate Removal Proceedings In More Cases

Posted on August 9, 2018 | Comments Off on Updated Notice to Appear (NTA) Guidance Requires USCIS to Initiate Removal Proceedings In More Cases

On June 28, 2018, USCIS issued updated guidance requiring its officers to initiate removal proceedings in more cases to align with President Trump’s executive order, Enhancing Public Safety in the Interior of the United States.  USCIS Director L. Francis Cissna said the new policy equips USCIS officers to better support the immigration enforcement priorities of the Department of Homeland Security (DHS).

The 2018 memorandum instructs USCIS to issue a Notice to Appear in removal proceedings before an Immigration Judge to inadmissible or deportable persons in an expanded range of situations, instead of referring NTAs to the U.S. Immigration & Customs Enforcement (ICE) in limited cases.  One major change is that an NTA must be issued whenever a person’s immigration benefit request is denied and he or she is “not lawfully present” in the United States.

What is a Notice to Appear?

A Notice to Appear is a Form I-862 the DHS issues to initiate removal proceedings against a person. The NTA includes the charges against the person and alleges the immigration laws he or she violated.  Some NTAs include the date and time of the initial hearing, when you first appear before an immigration judge who decides whether you should be removed or whether you qualify for relief, including voluntary departure in lieu of a removal order.

What Was the Previous USCIS Policy on Issuing a Notice to Appear? 

The November 7, 2011 Policy Memorandum (PM), which is now superseded by the June 28, 2018 PM, provided “USCIS guidelines for referring cases and issuing Notices to Appear (NTAs) in a manner that promotes the sound use of resources of the Department of Homeland Security and the Department of Justice to enhance national security, public safety, and the integrity of the immigration system. ”

The 2011 policy instructed USCIS to issue an NTA in the following situations:

  • Cases where it is required by statute or regulation, such as termination of Conditional Permanent Resident Status and denials of Form I-751, and asylum referrals.
  • Fraud or willful misrepresentation/section INA 212(a)(6)(C) cases when a Statement of Findings substantiating fraud is part of the record.
  • In naturalization (Form N-400 application) cases where the applicant is removable, including those who were inadmissible at the time of obtaining permanent residence.

The 2011 policy further directed USCIS to refer matters to ICE in the following situations:

  • Egregious Public Safety (EPS) cases “where information indicates the alien is under investigation for, has been arrested for (without disposition), or has been convicted of” certain specified aggravated felonies as defined under section 101(a)(43) of the INA; is a Human Rights Violator, is a known or suspected street gang member or is subject to Interpol  hits; or has re-entered the U.S. after removal subsequent to a felony conviction where no Form I-212, Application for Consent to Reapply for Admission, has been approved.
  • Cases where the person is inadmissible or removable due to a criminal offense falling outside of the EPS definition, after USCIS completes adjudication.

What is the Current USCIS Policy on Issuing a Notice to Appear?

The June 28, 2018 Policy Memorandum (PM) requires USCIS to issue a Notice to Appear in a broader range of cases without first consulting ICE.

Many more persons will be placed in removal proceedings as USCIS is now required to issue an NTA in the following situations:

  • If an application or petition for immigration benefits is denied and the person is not in lawful status (not lawfully present).
  • If an application or petition for immigration benefits is denied and the person is removable (i.e. subject to any removability grounds under INA 237), especially when there is evidence of fraud or misrepresentation and/or abuse of public  benefit programs.
  • Criminal cases in which the applicant is removable and has been convicted of or charged with any criminal offense, or has committed acts that are chargeable as a criminal offense, even if the criminal conduct was not the basis for the denial or is the ground of removability.
  • Naturalization cases in which the applicant is removable and USCIS denies a Form N-400, Application for Naturalization, on good moral character grounds due to a criminal offense.

USCIS will continue to apply the 2011 NTA guidance to the following:

  • Cases involving national security concerns.
  • Cases where issuing an NTA is required by statute or regulation.
  • Temporary Protected Status (TPS) cases, except where, after applying TPS regulatory provisions, a TPS denial or withdrawal results in an individual having no other lawful immigration status.
  • Deferred Action for Childhood Arrivals (DACA) recipients and applicants when USCIS is: (1) processing an initial or renewal DACA request or DACA-related benefit request; or (2) processing a DACA recipient for possible termination of DACA.

UPDATE: On September 27, USCIS announced it will begin implementing the new guidance on October 1 in certain cases. For instance, it may issue NTAs on denied status-impacting applications, including Form I-485, Application to Register Permanent Residence or Adjust Status, and Form I-539, Application to Extend/Change Nonimmigrant Status. The June 2018 NTA Policy Memo will not be implemented with respect to employment-based petitions and humanitarian applications and petitions at this time. 

In a September 27th teleconference, USCIS also said it will not issue an NTA immediately upon denial of an immigration benefit.  Normally, it will wait for the expiration of the motion or appeal period before issuing an NTA. If an NTA is issued before a motion or appeal is filed or while it is pending, and USCIS takes favorable action on the motion or appeal, USCIS will notify ICE. Withdrawing an application does not cancel USCIS’s authority to issue an NTA. 

Potential Negative Effects of the NTA Policy Change

The new NTA guidance might discourage eligible applicants from seeking immigration benefits out of fear of getting their requests denied and being placed in removal proceedings if they are not lawfully present.  This includes persons applying for a green card (lawful permanent resident status), a change or extension of status, a waiver of inadmissibility and other immigration relief.

Departing the United States on one’s own, after being denied an immigration benefit, will bring harsh penalties when an NTA is issued and the person fails to appear for the scheduled Immigration Court hearing. An in absentia removal order is issued if there is clear, unequivocal and convincing evidence that written notice was provided and that the person is removable, but did not attend the proceeding.

At the same time, those who wait in the United States for an initial court date to appear before an immigration judge will continue to accrue unlawful presence toward the 3/10-year bar to re-entry under INA 212(a)(9)(B).  A person who accrues unlawful presence of more than 180 days but less than one year is barred from re-entering the U.S. for three years. The bar to re-entry is 10 years if the person accrues unlawful presence of more than one year prior to departure. The initiation of removal proceedings does not stop the accrual of unlawful presence.

Furthermore, the updated policy turns USCIS into another immigration enforcement component of DHS, along with ICE and the U.S. Customs & Border Protection (CBP).  An increase in the issuance of NTAs will create additional backlog in the immigration court system and lengthen USCIS processing times.

Conclusion

Besides the new NTA policy, USCIS issued updated guidance to make it easier to deny a petition or application without first issuing a Request for Evidence or Notice of Intent to Deny. Another  USCIS policy change also subjects more nonimmigrant students and exchange visitors to accruing unlawful presence toward the 3/10-year bar, as well as the permanent bar under INA 212(a)(9)(C).

All these new policies are in line with the February 2018 change in USCIS’ mission statement, deleting sentences that refer to the United States as “a nation of immigrants” and to noncitizens who apply and pay for immigration benefits as “customers.” USCIS Director Cissna explained that this is “a reminder that we are always working for the American people.”

For more information, read our related articles:

Updated Policy Makes It Easier for USCIS to Deny Petitions and Applications Without First Issuing a Request for Evidence (RFE) or Notice of Intent to Deny (NOID)

USCIS Policy Change Makes Nonimmigrant Students and Exchange Visitors More Likely to Accrue Unlawful Presence Toward 3/10-Year Bar and Permanent Bar

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This article provides general information only. It is based on law, regulations and policy that are subject to change. Do not consider it as legal advice for any individual case or situation. Each legal case is different and case examples do not constitute a prediction or guarantee of success or failure in any other case. The sharing or receipt of this information does not create an attorney-client relationship.

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Posted in adjustment of status, bona fide marriage, citizenship, deferred action, green card, immigrant petition, immigration consequences of criminal convictions, immigration fraud, marriage fraud, naturalization, nonimmigrant visa, The Legal Immigrant - Immigration Blog, waiver

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Trump’s Four Pillars for Immigration Reform

Posted on February 24, 2018 | Comments Off on Trump’s Four Pillars for Immigration Reform

In his State of the Union address on January 30, 2018, after completing his first year in office, President Trump officially introduced his Administration’s four pillars for immigration reform.

The first pillar “offers a path to citizenship for 1.8 million illegal immigrants who were brought [to the United States] by their parents at a young age…”  Commonly known as Dreamers, individuals within this group who meet education and work requirements, and show good moral character, will be eligible for naturalization (U.S. citizenship), according to Trump.

The second pillar aims to enhance border security. It involves building a big wall on the U.S.-Mexico border and hiring more border patrol officers. “Crucially, our plan closes the terrible loopholes exploited by criminals and terrorists to enter our country — and it finally ends the dangerous practice of ‘catch and release’,” Trump said.

The third pillar ends the Diversity Visa Lottery, which Trump criticized as “a program that randomly hands out green cards without any regard for skill, merit, or the safety of our people.” He further called for a “merit-based immigration system.”

The fourth pillar “protects the nuclear family by ending chain migration” and restricting family-based immigration to only spouses and minor children. Trump claimed that under the current system, “a single immigrant can bring in virtually unlimited numbers of distant relatives.”

Trump deems the Diversity Visa Lottery program and “chain migration” as sources of terrorist attacks and threats to the national security of the United States.

While Trump has said Congress should pass a “bill of love” for young, undocumented immigrants who qualified for the Obama Administration’s Deferred Action for Childhood Arrivals (DACA) program, which he rescinded on September 5, 2017, his support does not come without conditions.

Conditioning protections for Dreamers and DACA holders on federal funding for a Southern border wall and  reductions in legal immigration, in particular, makes it harder for a gridlocked Congress to reach a mutually agreeable, workable solution. Congress’ failure on February 15 to secure enough votes to advance any of the four immigration bills up for a vote is a prime example. To learn more, read White House-Backed Bill Proposing Protections for Dreamers/DACA Holders, Restrictions on Family-Based Immigration, and End to Diversity Visa Lottery Fails to Pass in the Senate; Worries Prevail.

In the meantime, the Trump Administration has relied on presidential proclamations and executive policies to bypass Congress and impose travel restrictions and broaden immigration enforcement priorities. While the termination of prior, executive orders and the introduction of new ones are subject to checks and balances, including review by U.S. federal courts and the U.S. Supreme Court, they still have ripple effects.

Section 212(f) of the Immigration and Nationality Act (INA) gives the President broad authority to suspend entry of a class of foreign nationals temporarily if he or determines the entry of such aliens would be detrimental to the U.S. interest.

Trump’s Presidential Proclamation Enhancing Vetting Capabilities and Processes for Detecting Attempted Entry Into the United States by Terrorists or Other Public-Safety Threats (Proclamation 9645) – dubbed “Travel Ban 3.0” – indefinitely suspends entry to the United States for nationals of eight countries (Chad, Iran, Libya, North Korea, Syria, Venezuela, Yemen, Somalia).

There are a few exceptions, such as lawful permanent residents, asylees, and diplomatic visa holders from these countries. Consular officers and immigration officials may also grant case-by-case waivers to those who would otherwise be subject to the entry ban, if denial of their admission would cause them undue hardship and their admission would not pose a threat to the national security of public safety of the United States and would be in the national interest.

Federal courts in Hawaii and Maryland issued preliminary injunctions partially blocking Travel Ban 3.0, but they were lifted by the U.S. Supreme Court on December 4, 2017, allowing Trump’s proclamation to go into effect. The U.S. Supreme Court is expected to hear oral argument on April 25 regarding whether the ban violates U.S. immigration law or the U.S. Constitution.

Trump’s termination of the DACA program has spurred federal lawsuits, which resulted in February 13th New York and January 9th San Francisco court orders, issuing temporary injunctions to block the Administration’s rescission. As a result, U.S. Citizenship & Immigration Services (USCIS) — which recently changed its mission statement to remove the term “nation of immigrants” and emphasize “protecting Americans” — continues to accept DACA renewal requests for now.

The Administration’s expansion of immigration enforcement priorities has also made certain, undocumented immigrants increasingly vulnerable at their USCIS interviews. Spouses of U.S. citizens are now more likely to be apprehended by U.S. Immigration & Customs Enforcement (ICE) at in-person interviews with USCIS, when they seek an approval of a marriage-based petition to legalize their status, but have already been issued a removal order, been previously caught unlawfully entering the United States, have criminal convictions, etc.

In light of the Administration’s immigration policies, it has become more critical to have experienced, attentive immigration counsel evaluate your eligibility for immigration benefits (preferably before you file for them) and accompany you to in-person interviews with USCIS. For more information, read 5 Benefits of Having Immigration Counsel at Your In-Person Interview with USCIS.

Contact Dyan Williams Law to help you evaluate your qualifications for permanent residence or naturalization, overcome visa refusals, apply for waivers of inadmissibility, and represent you at green card or citizenship-related interviews with USCIS.

Cheers,

Dyan Williams

Founder & Principal Attorney
Dyan Williams Law PLLC
(612) 225-9900
dw@dyanwilliamslaw.com

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This article provides general information only. It is based on law, regulations and policy that are subject to change. Do not consider it as legal advice for any individual case or situation. Each legal case is different and case examples do not constitute a prediction or guarantee of success or failure in any other case. The sharing or receipt of this information does not create an attorney-client relationship.

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