Thursday, July 28, 2011

More Than Two Dozen Indicted For Marriage Fraud Scam

A California immigration consultant and 13 other individuals have been indicted by the U.S. government for an elaborate immigration fraud scheme in which foreign nationals from Russia and Eastern European countries paid thousands of dollars to American citizens to enter into sham marriages in order to immigrate to the United States according to a press released issued by the Department of Homeland Security this week. Foreign nationals paid up to $20,000 to American citizen sponsors to enter into sham marriages with the assistance of Sergey Potepalov, a 55-year-old immigration consultant from Citrus Heights, California.

U.S. Attorney Ben Wagner said, "The indictment in this case alleges that Mr. Potepalov essentially built a business out of phony marriages between U.S. citizens and persons who sought citizenship." Potepalov aided the U.S. citizens in getting fiance' visas to allow the foreign nationals to enter the U.S. for the purpose of entering into sham marriages. All of the petitions were ultimately denied according to the press release.

You should note that Potepalov acted as a consultant and not as a licensed attorney. It is illegal to practice law without a license. The state of Indiana has shut down at least two individuals operating in Indiana as a "notario publico", giving Spanish-speaking clients the impression they were attorneys who could assist them with their immigration petitions when they in fact were only licensed as a notary public, which authorizes the person to do no more than administer oaths and witness the signing of legal documents. A "notario publico" is a Spanish-languish term for attorneys with special credentials. American lawyers do not carry the title of "notario publico."

In an unrelated case closer to home, a 35-year-old Mishawaka, Indiana man was sentenced to 42 months in prison for his role in running a sophisticated fraudulent document scam. Alejandro Gonzalez-Garcia ran a nationwide organization with 19 cells in 11 states that produced high-quality false identification cards for undocumented aliens. The ring manufactured phony counterfeit resident alien cards and social security cards that they sold for $150 to $200 a piece. The government also accused the organized crime ring of carrying out violent acts to drive competitors out of the territories in which they were operating.

Wednesday, July 27, 2011

Warning About Indiana's New Immigration Enforcement Law And Motor Vehicle Forfeiture

I've heard some rumblings that some local law enforcement agencies may be using Indiana's new immigration enforcement law to impound vehicles of persons suspected of being unlawful aliens after they are taken into custody for minor traffic violations and advising the owners the vehicles are subject to civil forfeiture. While it is true the new law allows law enforcement agencies to impound vehicles that are being used to traffic in unlawful aliens for financial gain, my interpretation of the new law does not permit law enforcement to seize any vehicle in which an unlawful alien is riding at the time he or she is arrested for an offense unrelated to alien trafficking.

Many aliens complain that they are stopped in some jurisdictions by police for no apparent traffic law violation other than driving while having the appearance of being an alien. They typically wind up being cited for driving without a valid driver's license as opposed to a traffic offense for which a police officer might have had probable cause for making a stop. After being taken into custody, the police will typically notify ICE if they suspect the person is unlawfully present, at which point ICE will place a hold on the person, which will prevent their release even after posting bond for the traffic offense for which the person is arrested. ICE is required to take a person being held by a local law enforcement agency into custody for questioning within 48 hours, excluding weekends and holidays.

If you are arrested under similar circumstances and advised that the motor vehicle that you were operating or in which you were a passenger at the time of your arrest is being impounded and subject to civil forfeiture, please get in touch with an attorney immediately to seek relief from what I consider to be an unlawful taking of your property. Never accept the law enforcement agency's claim that they have a right to seize your vehicle without first consulting an attorney for advice.

Monday, July 25, 2011

7th Circuit: Illinois Domestic Violence Repeat Conviction Deemed "Aggravated Felony" Supporting Removal Of Permanent Resident

Under 18 U.S.C. 16(a), a conviction for an "aggravated felony" is an offense that can result in the cancellation of a person's permanent resident status and their removal from the country. The 7th Circuit Court of Appeals recently held that a permanent resident's second conviction for domestic violence under Illinois' domestic battery statute constituted an "aggravated felony", which meant he was not eligible for the cancellation of the removal proceedings against him.

Jaimie De Leon Castellanos had been a permanent resident of the United States since 1988 after his arrival from Guatemala in 1981. De Leon has worked in the United States, married and fathered three children. In 1984, De Leon pleaded guilty to domestic battery after he was arrested for grabbing his wife by the neck, holding a knife to her, striking her and refusing to allow her to call the police. A year later, De Leon was again arrested, charged and convicted of domestic battery against his wife. Because of his prior conviction, his misdemeanor battery charge was elevated to a felony and he was sentenced to one year in prison.

The Department of Homeland Security initiated proceeding to revoke De Leon's permanent resident status and remove him from the country. The government's petition against him noted that he had two convictions for crimes involving moral turpitude, in addition to his felony domestic battery conviction. De Leon conceded he was removable because of his conviction for crimes involving moral turpitude, but he denied he had been convicted of an "aggravated felony." Although the convictions for crimes for moral turpitude are grounds for removal, a person can petition to cancel removal proceedings if it is proven the person had no prior convictions for an "aggravated felony." An immigration judge disagreed and concluded he had been convicted of an "aggravated felony", and the Board of Immigration Appeals affirmed the IJ's decision but on a more limited basis. It found that he had been convicted of a "crime of violence" rather than an aggravated felony in general.

On appeal, De Leon argued that his second conviction for domestic battery did not involve a crime of violence because it was not necessary under the state statute to prove he had used, attempted to use or threatened the use of physical force. The 7th Circuit Court of Appeals disagreed and held that his battery conviction necessarily involved causing bodily harm to his wife and was, therefore, a crime of violence. The court contrasted its decision in this case with another case  (Flores v. Ashcroft, 350 F.3d 666 (7th Cir. 2003)it had decided involving Indiana's battery statute, (I.C. 35-42-2-1), because it permitted a person to be convicted based on "slight offensive contact, such as tossing a paper airplane that causes a paper cut or a snowball that causes minor pain." The Supreme Court held in Johnson v. United States (2010) that a state statute for battery that does not include as an element the use of physical force cannot be categorically considered a crime of violence. The court noted that De Leon's second Illinois conviction for domestic battery was for "intentionally causing bodily harm to his wife."

Contrast this decision with the recent New York decision involving a man convicted of killing his wife where the court rejected the government's effort to block a long-time permanent resident from becoming a naturalized citizen after he had served time for his manslaughter conviction and to revoke his permanent resident status. In that case, the court took into consideration the fact that the permanent resident was a veteran of the Vietnam War who had suffered from post traumatic distress at the time he killed his wife and had subsequently demonstrated that he had been a person of good moral character by obtaining an education while in prison and being a good citizen following his release from prison for the statutory period for demonstrating good moral character prior to his application for naturalization.

BMV Changes Make It Difficult For Undocumented Aliens To Drive And Own Automobiles

Since 2007, the Indiana Bureau of Motor Vehicles has required anybody applying for an Indiana driver's license to provide additional evidence of their lawful status. One of the mechanisms used by the BMV to determine a person's lawful status is to verify with the federal government that a social security number used by an applicant to apply for a driver's license was actually issued to the applicant. According to recent news reports, the agency is now cracking down on the use of fake documents to register a vehicle with the agency. This is in response to the discovery of BMV branch workers in South Bend and Elkhart that third party businesses were being used to title and register vehicles in Indiana for undocumented aliens, a practice known as title running. An investigation has led to the federal indictment of two individuals in the federal district court of Indiana. The Fort Wayne Journal-Gazette explains how the men in question were operating their title running business:

Employees at BMV offices in Mishawaka and South Bend noticed over the past few months that representatives of a business called Servicios Mi Tierra in South Bend and Elkhart were coming into BMV branches to obtain titles and registrations for 10 to 20 vehicles every week.
The documents presented to BMV officials included power of attorney documents, which granted the Servicios representatives the right to act on behalf of other individuals, and IRS paperwork showing an LLC or corporation that almost always included the full name of a person, according to court documents.
The representatives of Servicios always paid in cash and always asked that the transactions be handled individually, rather than as a group as would usually be done, according to court documents.
They would then provide additional necessary documents, such as utility bills, that contained a mixture of false and legitimate information to prove Indiana residency, which was then bolstered by the vehicle title and registration.
After using surveillance and wiretaps, federal agents raided the offices of Servicios Mi Tierra in Elkhart and South Bend, as well as those of Agencia Latina in Highland.
The investigation resulted in a multicount indictment, issued by a federal grand jury meeting in South Bend, against Ramon Garcia and Paulino Ascencion-Apolino.
The two are accused of committing fraud and wire fraud and of conspiring to conceal illegal immigrants present in the United States and then profiting from that activity, according to court documents.
At one point in the investigation, Ascencion-Apolino told an undercover federal agent that most of their clients come to them because they do not have a Social Security number or a valid driver’s license, according to court documents.
Beginning in January, the BMV requires that license plates and registration and title information be mailed to the vehicle owner's address rather than allowing a third party with the power of attorney to come in and register and title vehicles for a third person and walk out of the license branch with license plates, renewal tags and other documentation.

It is easier for a business to register and title a vehicle in Indiana currently because the business can do so with a taxpayer identification for the business issued by the IRS instead of a social security number that is issued to individuals. An unlawful alien lacking a social security number creates a business entity instead to register vehicles he or she owns. The Secretary of State's office tells the Journal-Gazette the legislature may want to consider allowing the office to license title runners. The Secretary of State's office, in turn, would share information with law enforcement agencies about which business entities are relying on title runners to register vehicles.

Given the large number of undocumented aliens living and working in Indiana and the United States, the need for comprehensive immigration reform at the federal level is only increasing. Many undocumented aliens are married to U.S. citizens and have U.S. citizen children. Many have spent most of their lives living in the U.S. after they were brought here by their parents as young children. Without a comprehensive federal solution to the problem, these people are being marginalized and are being made very vulnerable to various scams promising to make it legal for them to remain here.

Tuesday, July 19, 2011

Manslaughter Conviction Doesn't Bar Permanent Resident From Becoming A Naturalized Citizen

A Jamaican immigrant and Vietnam War veteran won a big victory in front of a New York federal district court judge, who ruled he was eligible to become a naturalized citizen despite an earlier conviction for manslaughter. Vernon Lawson, who suffered from post traumatic stress disorder (PTSD) and a severe drug addiction, stabbed his wife to death in 1985 and served more than 13 years in prison. While in prison, Lawson earned a GED and a bachelor's degree before his release in 1998. In 2006, he applied to become a naturalized citizen but was turned down by USCIS because of his manslaughter conviction. He also was arrested for drunk driving in 2007,  but the charges against him were dismissed.

Immigration officials had attempted for 7 years to cancel Lawson's permanent resident status, which he had held since he arrived in the country at the age of 14, and remove him from the country because of his criminal conviction. Judge Denny Chin ruled that Lawson had sufficiently established his good moral character since 2005. "He has redeemed himself," Chin wrote in his decision. "The manner in which he has overcome his challenges is a testament to his character." As to Lawson's 2007 DUI arrest, Chin wrote,
"The lapse does not spoil the quality of Lawson's moral character as a whole," the federal judge wrote in his decision earlier this month." "Of course, Lawson committed an unspeakable act when he killed his wife. But that was more than 25 years ago, and he has paid for his actions," Chin wrote. "He became a productive and responsible member of society."

In order to become a naturalized citizen, an applicant generally must: (1) be at least 18 years of age; (2) have continuously resided in the U.S. for the requisite period, which is five years unless you obtained a green card based on marriage to a U.S. citizen, in which case it is three years; and (3) have been a person of good moral character during the required period of continuous lawful permanent resident status. USCIS had objected to Lawson's naturalization application on the grounds that he lacked good moral character.

Anyone convicted of murder is automatically deemed ineligible to lack good moral character. Lawson was saved by this bar because he was convicted of manslaughter in the killing of his wife rather than murder. Other criminal convictions can also serve as a permanent bar to naturalization, including aggravated felony convictions after November 29, 1990. Other crimes committed during the required statutory period of good moral character may also serve as a bar to naturalization, including: crimes of moral turpitude; drug-related crimes; convictions for two or more offenses that carried an aggregate sentence of five years or more; a criminal conviction for which a person is confined in a penal institution for an aggregate period of 180 days or more; giving false testimony to obtain an immigration benefit; voting unlawfully and falsely claiming to be a U.S. citizen; involvement in prostitution or commercialized vice; alien smuggling; polygamy; two or more gambling-related convictions; or being deemed a habitual drunkard.  

Indiana Won't Appeal Injunction Against Enforcement Of Immigration Law Provisions

Indiana Attorney General Greg Zoeller announced today that his office will not appeal an earlier federal court order granting a preliminary injunction against two provisions of Indiana's new illegal immigration enforcement law, Senate Enrolled Act 590. Judge Sarah Evans Barker ruled weeks ago that two provisions of the law were constitutionally suspect and temporarily barred their enforcement. One provision allowed law enforcement officials to make warrantless arrests of certain alien residents, and a second provision barred aliens from using consular photo identifications cards for identification purposes.

The Indiana Civil Liberties Union brought the suit on behalf of several aliens who claimed to be affected by the law's reach. Other provisions of the law, including those that provide a carrot and stick approach to encouraging Indiana employers to use E-Verify in order to determine whether an alien worker is authorized to work in the U.S., took effect on July 1. The Attorney General's office will still press the case against a permanent injunction against the two provisions temporarily blocked from taking effect by Judge Barker.

Thursday, July 14, 2011

ICE Memorandum On Prosecutorial Discretion In Immigration Removal Proceedings

ICE Director John Morton last month issued an important memorandum that addressed the manner in which the agency should prioritize enforcement decisions concerning the apprehension, detention and removal of aliens from the United States. Prosecutorial discretion covered by the memorandum includes the following proceedings:
  • deciding to issue or cancel a notice of detainer;
  • deciding to issue, reissue, serve, file or cancel a Notice to Appear ("NTA");
  • focusing enforcement resources on particular administrative violations or conduct;
  • deciding whom to stop, question or arrest for an administrative violation;
  • deciding whom to detain or release on bond, supervision, personal recognizance, or other condition;
  • seeking removal or other forms of removal by means other than a formal removal proceeding in an immigration court;
  • settling or dismissing a proceeding;
  • agreeing to voluntary departure, withdrawal of an application for admission or other action in lieu of obtaining a formal order of removal;
  • pursuing an appeal;
  • executing a removal order; and
  • responding to a motion to reopen removal proceedings and to consider joining in a motion to grant relief or a benefit.
Important to those facing an immigration enforcement action is the factors the memorandum indicates should be utilized in prioritizing. They include:

  • a person's length of presence in the U.S. with particular consideration given to the length of time in a lawful status;
  • the circumstances of the person's arrival in the country and the manner of entry, particularly if the person was brought to the country as a young child;
  • the person's pursuit of an education in the U.S.;
  • whether the person's immediate relative has served in the U.S. military;
  • a person's criminal history;
  • a person's history of immigration-related actions;
  • whether the person poses a national security or public safety concern;
  • whether the person has a U.S. citizen spouse and/or children;
  • whether the person's spouse is pregnant or nursing;
  • whether the person suffers from a mental or physical illness; and
  • whether the person is likely to be granted a temporary or permanent status or other relief from removal
The memorandum further instructs us on which factors should be given particular importance, which would include: veterans and members of the U.S. military; long-time lawful permanent residents; minors and elderly individuals; individuals present in the country since early childhood; pregnant or nursing women; crime victims; and persons with serious mental and physical conditions. Individuals who are serious felons or repeat offenders, known gang members, persons who pose a national security or public safety concern and persons with egregious immigration violations are going to be afforded the least favorable consideration.

The memorandum advises officers to make prosecutorial discretionary decisions earlier rather than later in immigration proceedings. If you are the subject of an immigration proceeding, consult an immigration attorney early on in the process rather than waiting until an adverse action has been taken against you. Your attorney can help you evaluate factors that will assist you in favorable consideration of relief and make a formal request for a favorable exercise of prosecutorial discretion.

Obtaining A Driver's License In Indiana

In recent years, Indiana's Bureau of Motor Vehicles has significantly tightened up the requirements for obtaining a driver's license, which has meant certain aliens who may have previously been able to obtain a driver's license issued by the state of Indiana will no longer be able to renew or obtain a driver's license. There are four categories of documents you will need to produce in order to obtain a driver's license in Indiana:

  • A document proving your identity;
  • A document proving your social security number;
  • A document proving your lawful status in the United States; and
  • At least two documents proving you are a resident of the state of Indiana.
There are several acceptable forms you may use to prove your identity, including: a U.S. birth certificate; a U.S. passport; a foreign passport containing your non-immigrant visa and I-94 arrival record; a consular report of child of a U.S. citizen born abroad; an employment authorization card issued by USCIS; a naturalization certificate issued by the U.S. government; or any other document issued by an agency of the federal government to show identity and lawful status.

To prove your social security number, you can present a social security card with your name and number, a W-2 IRS form, a 1099 IRS form or a pay stub that includes your name and social security number.

To prove you are a resident of Indiana, you may use any number of forms of evidence, including present a voter registration card, a utility bill or other bills addressed to you at your Indiana residence, bank account statements addressed to you at your Indiana residence, a mortgage or lease document for your Indiana residence, or pay stubs or tax forms showing your Indiana residence.

If you are an alien, you can prove your lawful status in the U.S. by presenting a permanent resident card, an unexpired foreign passport with an unexpired non-immigrant visa and I-94 arrival record, an I-797 Notice of Action form issued by USCIS or proof of application for asylum status in the United States using Form I-589.

You can use the same forms of evidence to obtain a valid identification card from the BMV should you not desire to have a driver's license or are otherwise ineligible to hold a driver's license due to past driving offenses or certain medical conditions.

I would offer a word of caution to any alien visiting a BMV branch in Indiana to obtain a driver's license. If you are asked by a employee if you would like to fill out a form to register to vote, please say no. You MUST be a U.S. citizen in order to register to vote. Registering to vote and/or casting a vote if you are not a U.S. citizen is a violation of the law that could have serious ramifications that could affect your current or future status, including removal from the country. A conviction for unlawful voting is not required in order to deny you an immigration benefit.

Indiana's New Immigration Enforcement Law Incentivizes Employers To Use E-Verify

While a federal district court judge in Indianapolis has temporarily blocked provisions of a new Indiana law, Senate Enrolled Act 590, that would have permitted warrantless arrest of aliens under certain conditions and barred them from using consular-issued photo identification cards for identification purposes, several key changes made by the new law have gone into effect, including a provision that provides an added incentive to Indiana employers to use E-Verify for employees they hire.

Under the new law, an Indiana business that hires an alien worker who has not been granted authorization to work in this country, would be required to add back the amount of any deduction the employer had taken on a federal tax return for a business expense related to the employment of the unauthorized alien worker. Employers who are enrolled in the federal E-Verify program and utilize it to determine whether a worker is authorized to work in this country will not be penalized for payments it makes to workers who turn out to lack proper work authorization. Similarly, businesses that benefit from state economic development tax credits also will be penalized if they are found to be employing unauthorized workers unless they are relying on E-Verify.Businesses could also face civil actions by the Indiana Department of Workforce Development if unemployment insurance benefits are paid out to persons who turn out to lack work authorization, unless the business had relied on E-Verify in the hiring its employees.

Starting July 1 of this year, all state and local government agencies are required to utilize E-Verify to verify the work eligibility status of any prospective employees. This requirement will extend to contractors hired by state and local governments. Government contractors, too, will have a requirement that they also enroll in and participate in the use of E-Verify to verify the work eligibility status of its employees. A governmental entity may terminate a contract with a business who knowingly employs unauthorized aliens. Additionally, a business that receives grants from the government will also be required to enroll in and participate in E-Verify.

A separate provision of the new law will prohibit local governments from enacting ordinances that effectively create what are known as sanctuary communities, whereby law enforcement and officials of the governmental body as a matter of policy are not allowed to take certain actions against a person because of their immigration status in order to undercut enforcement of federal immigration laws. This provision even provides a right of a private citizen in Indiana to bring a cause of action against a government entity to enforce compliance with the law. The law does provide, however, some protection to persons who are merely witnesses or victims of a crime. A law enforcement agency will be prohibited from requesting verification of a person's citizenship or immigration status when they have contact with a law enforcement agency as a witness to or a victim of a crime.

The new law also adds a couple of new crimes to the state's criminal code regarding illegal immigration. It establishes a crime of false identity statement as a Class A misdemeanor. It is also becomes a Class A misdemeanor for a person to knowingly or intentionally: (1) transport or move an alien; or (2) conceal, harbor or shield from detection an alien in any place; for the purpose of commercial advantage or private financial gain, knowingly or in reckless disregard of the fact that the alien has come to, entered, or remained in the United States in violation of law. This crime is elevated to a Class D felony if the violation involves more than nine aliens. In addition, it requires a law enforcement officer to impound a motor vehicle that is used to commit alien trafficking-related crimes.

The enactment of the so-called Arizona-styled laws have popped up in a number of states this year as state lawmakers grow frustrated with what they consider the federal government's lack of enforcement of federal immigration laws and the consequential unreimbursed costs to state and local governments for problems arising out of illegal immigration. Challenges to the laws are taking place on a state-by-state basis in the federal court system and will likely reach the U.S. Supreme Court in the near future, which will answer the question of the extent, if any, states can enact immigration enforcement laws. In the meantime, the millions of undocument aliens in the country will face increasing challenges in obtaining employment opportunities and providing for their family members, who often include U.S. citizen spouses and children. That is one of the primary reasons organizations like the American Immigration Lawyers Association, of which I'm a member, have pressed Congress to enact a comprehensive federal immigration reform law to deal with the issue on a nationwide basis.

Wednesday, July 13, 2011

Federal District Court In Indianapolis Blocks Enforcement Of Two Provisions Of Indiana Immigration Enforcement Law

During the recent session of the Indiana General Assembly, state lawmakers approved and Gov. Mitch Daniels signed into law Senate Enrolled Act 590, which contains a number of provisions aimed at bolstering enforcement of federal immigration laws. The American Civil Liberties Union of Indiana brought suit on behalf of several aliens who claimed they would suffer harm if state and local law enforcement officers were allowed to enforce two provision of the new law.

The most controversial provision of SEA 590 authorized state and local law enforcement officers to make a warrantless arrest of a person if an immigration court has issued a removal order against the person, a detainer or notice of action has been issued by the Department of Homeland Security concerning the person, or the officer has probable cause to believe the person has been indicted for or convicted of one or more aggravated felonies. The ACLU's lawsuit contended this provision violated an affected person's Fourth Amendment rights and was pre-empted by the federal government's exclusive right to adopt and enforce immigration laws under the U.S. Constitution.

As the federal district court explained in temporarily granting an injunction against enforcement of this provision, a person may be in removal proceedings but still be permitted to remain in the country after being released on bond or conditional parole. A person ordered removed may seek administrative and judicial review of an order of removal and be released on bond until a final decision is rendered. Even after a final order of removal has been entered against a person, there may still be opportunity to have the case reopened and have a stay of a final removal order. In yet other cases, there may be an opportunity for a person to elect voluntary departure.

In other cases, federal immigration enforcement officers may place a detainer on persons arrested by state and local law enforcement officers, which is commonly referred to as a "ICE Hold." The person may be held for up to 48 hours, excluding weekends and holidays, in order to  provide federal agents the opportunity to assume custody of an alien for questioning of the alien's immigration status. The 48-hour detention is suppose to expire automatically and the person released if federal agents fail to assume custody of the alien within the 48-hour period.

The provision of the law allowing for warrantless arrests of aliens who are the subject of a notice of action caused particular concern for the federal district court. A notice of action may be issued for any number of reasons that may or may not have anything to do with an alien's right to remain in the country lawfully. As such, it is not a reliable indicator of an alien's current immigration status or whether the alien has engaged in any illegal activity. Similarly, it cannot always be readily determined whether an "aggravated felony" for which the person has been indicted or convicted is an offense that would lead to an alien's removal or exclusion from the country.

Because the court determined that the law on its face allowed for aliens to be arrested for conduct that both parties agreed was not a crime, the court granted a preliminary injunction against enforcement of this provision of the law on Fourth Amendment grounds. The court also concluded that the plaintiffs were likely to prevail on its claim that federal law pre-empted the state from enacting an immigration enforcement law of this nature.

The second provision of the law blocked by the court from being enforced bars the use of consular identification cards issued by a foreign consulate as a form of identification. The use of this form of photo of identification by aliens while present in a foreign country is part of the Vienna Convention on Consular Relations and Optional Protocol to which the United States is a signatory. As with the warrantless arrest provision of the law, the court similarly concluded this provision was pre-empted by federal law, which specifically permits the use of consular identification cards issued by foreign governments as an acceptable form of identification for aliens to use while present in the United States.

Mission Of Blog

Navigating the ever-increasing intricacies of immigration law is a challenge to everyone, including attorneys. My mission is to share with you from time to time issues of interest to individuals who may be seeking to become lawful immigrants or naturalized citizens of the United States or assistance with bringing their family members to this country, employers who would like to employ alien workers or anyone who is interested in the requirements for complying with our nation's immigration and naturalization laws. Feel free to pose questions you would like me to address by e-mailing me at