Sarah K. Bazzi, Esq.

Bazzi Immigration Law

6878 Fleetwood Road Suite D
McLean, VA 22101

UNITED STATES DEPARTMENT OF JUSTICE

EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
ARLINGTON IMMIGRATION COURT
ARLINGTON, VIRGINIA

In the Matter of: )

)
)
TURCIOS-FAJARDO DE SAN JOSE, Nely Darleny ) File No.: A# 206-367-357
)
)
In Removal Proceedings )

Immigration Judge: Barnes, John C Next Hearing: Sept. 23, 2022 at 8 am

RESPONDENT’S MOTION TO ACCEPT UNTIMELY

SUPPLEMENTAL EVIDENCE SUBMISSION

RESPONDENT’S MOTION TO ACCEPT UNTIMELY

 SUPPLEMENTAL EVIDENCE SUBMISSION

The Respondent, acting by and through undersigned Counsel, respectfully requests that

the attached filing be accepted. A motion to accept an untimely filing must explain the reasons

for the late filing and show good cause for acceptance of the filing.

Respondent has suffered significant trauma, as described in the matter of MAM motion.

Due to some difficulty in taking and reviewing Respondent’s declaration, she requests

safeguards in the form of flexible filing deadlines.

In addition, Respondent works in electricity and has no service during business hours

and has been required to work unscheduled overtime. During the finalization of her declaration,

she informed Counsel of a recent additional threat her father received from her husband.

Respondent’s father does not have his own What’s App and he was unreachable for several

days.

Respondent requests that the following evidence be accepted. The documents are not

voluminous and will not prejudice the Court or the government:

Tab SS: Declaration of Nely Turcios Fajardo and translation

Tab TT: Declaration of Faustino Turcios Florez, translation, and copy of identification

Respectfully submitted,

Sarah K. Bazzi, Esq.

 UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
Arlington Immigration Court
1901 South Bell Street, Suite 200
Arlington, VA 22202

TURCIOS-FAJARDO DE SAN JOSE, Nely Darleny File No.: A# 206-367-357

ORDER OF THE IMMIGRATION JUDGE

Upon consideration of the Respondent’s Motion to Accept Untimely Supplemental Evidence Submission,
it is HEREBY ORDERED that the motion be [ ] GRANTED [ ] DENIED because:

[ ] DHS does not oppose the motion.

[ ] The respondent does not oppose the motion.
[ ] A response to the motion has not been filed with the court.
[ ] Good cause has been established for the motion.
[ ] The court agrees with the reasons stated in the opposition to the motion.
[ ] The motion is untimely per ____________________.
[ ] Other:

Deadlines:

[ ] The application(s) for relief must be filed by __________________________.

[ ] The respondent must comply with DHS biometrics instructions by _________.

_____________________________ _____________________________
Date Immigration Judge: Barnes, John C.

______________________________________________________________________
Certificate of Service
This document was served by: [ ] Mail [ ] Personal Service
To: [ ] Alien [ ] Alien c/o Custodial Officer [ ] Alien’s Atty/Rep [ ] DHS

Date: _____________________ By: Court Staff ________________

 UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
Arlington Immigration Court
1901 South Bell Street, Suite 200
Arlington, VA 22202

TURCIOS-FAJARDO DE SAN JOSE, Nely Darleny File No.: A# 206-367-357

ORDER OF THE IMMIGRATION JUDGE

Upon consideration of the Respondent’s Motion to Accept Untimely Supplemental Evidence Submission,
it is HEREBY ORDERED that the motion be [ ] GRANTED [ ] DENIED because:

[ ] DHS does not oppose the motion.

[ ] The respondent does not oppose the motion.
[ ] A response to the motion has not been filed with the court.
[ ] Good cause has been established for the motion.
[ ] The court agrees with the reasons stated in the opposition to the motion.
[ ] The motion is untimely per ____________________.
[ ] Other:

Deadlines:

[ ] The application(s) for relief must be filed by __________________________.

[ ] The respondent must comply with DHS biometrics instructions by _________.

_____________________________ _____________________________
Date Immigration Judge: Barnes, John C.

______________________________________________________________________
Certificate of Service
This document was served by: [ ] Mail [ ] Personal Service
To: [ ] Alien [ ] Alien c/o Custodial Officer [ ] Alien’s Atty/Rep [ ] DHS

Date: _____________________ By: Court Staff ________________

 UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
Arlington Immigration Court
1901 South Bell Street, Suite 200
Arlington, VA 22202

TURCIOS-FAJARDO DE SAN JOSE, Nely Darleny File No.: A# 206-367-357

ORDER OF THE IMMIGRATION JUDGE

Upon consideration of the Respondent’s Motion to Accept Untimely Supplemental Evidence Submission,
it is HEREBY ORDERED that the motion be [ ] GRANTED [ ] DENIED because:

[ ] DHS does not oppose the motion.

[ ] The respondent does not oppose the motion.
[ ] A response to the motion has not been filed with the court.
[ ] Good cause has been established for the motion.
[ ] The court agrees with the reasons stated in the opposition to the motion.
[ ] The motion is untimely per ____________________.
[ ] Other:

Deadlines:

[ ] The application(s) for relief must be filed by __________________________.

[ ] The respondent must comply with DHS biometrics instructions by _________.

_____________________________ _____________________________
Date Immigration Judge: Barnes, John C.

______________________________________________________________________
Certificate of Service
This document was served by: [ ] Mail [ ] Personal Service
To: [ ] Alien [ ] Alien c/o Custodial Officer [ ] Alien’s Atty/Rep [ ] DHS

Date: _____________________ By: Court Staff ________________

TURCIOS-FAJARDO DE SAN JOSE, Nely Darleny File No.: A# 206-367-357

PROOF OF SERVICE

On _________________________, I, ______________________ Esq., caused to be served a copy of this

Respondent’s Motion to Accept Untimely Supplemental Evidence Submission to the Office of the
Principal Legal Advisor, Immigration and Customs Enforcement, U.S. Department of Homeland
Security, 1901 South Bell Street, 9th Floor Arlington, VA 22202 via electronic delivery.

________________________________ ___________________________