Rahul Manchanda, Esq.

Manchanda Law Office PLLC

30 Wall Street, 8 th Floor
Suite 8207
New York, New York 10005
Tel: (212) 968-8600
Fax: (212) 968-8601

UNITED STATES DEPARTMENT OF JUSTICE

EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
IMMIGRATION COURT - DETROIT MICHIGAN

------------------------------x
)
In the Matter of )
)
XXXXXXXXXXXXXXXXXXXXXXX ) Alien No XXXXXXXXXXX
) (DETAINED)
)
In Removal Proceedings. )
------------------------------x

HON. IMMIGRATION JUDGE XXXXXXXXXXXXXXX

NEXT HEARING DATE: DECEMBER 31, 2020

RESPONDENT'S REPLY MEMORANDUM OF LAW TO DHS OPPOSITION TO VENUE

CHANGE
US DEPARTMENT OF JUSTICE - EOIR
IMMIGRATION COURT - DETROIT MICHIGAN
-----------------------------------x
IN THE MATTER OF
XXXXXXXXXXXXXXXXXXXXX
RESPONDENT.
-----------------------------------x
Respondent, XXXXXXXXXXXXXXXXXXX,
)
)
) ALIEN NO . XXXXXXXXXXX
)
) RESPONDENT REPLY MEMORANDUM
) OF LAW IN OPPOSITION TO DHS
) OPPOSITION TO VENUE CHANGE
)
respectfully submits this Reply

Memorandum of Law in Opposition to OHS's Opposition to Respondent's

Motion to Change Venue, through their counsel XXXXXXXXXXXXXX of

the Office of OHS/ICE Principal Legal Advisor.

Preliminary Matter

1. As a preliminary matter, Respondent more than satisfies the

federal legal standards outlined in his original Motion to

Change Venue, and any denial of that Motion would result in

federal causes of action under the Administration Procedure Act

("APA") , the Federal Tort Claims Act ("FTCA") , and other

federal statutes/questions, with the United States being a

defendant, wherein if Venue Change was denied herein, would

most certainly be reversed on appeal with actual and punitive

damages in Respondent's favor and against OHS/ICE, based on

decades long legal case precedent and statutory authority.

Good Cause Issues

2. OHS Counsel claims that Respondent has not shown "good cause"

for a venue change to Florida, when clearly each and every

single issue opposing counsel mentioned (administrative

convenience, expeditious treatment of the case, location of

witnesses, family members, and costs) would be drastically

ameliorated pursuant to 8 C.F.R. §§ 1003.14(a) and 8 C.F.R.

1003. 20 (a).

"Great Expense" Issues

3. Also, in stark contrast to OHS Counsel XXXXXXXXXXXXXXXXX

statement that venue change will be at "great expense" to the

Department, it is actually quite the opposite, as Detroit would

no longer have to pay for his detention, hold his hearings,

feed and cloth and provide him medical care, arrange for his

telecommunications, respond to his motions, process his

applications, and venue change would thin out the Detroit case

load including eliminating multiple Indivictual Hearings for his

newly filed applications/petitions resulting in judicial

economy for this Detroit Immigration Court.

Location of Witnesses
Conclusion

WHEREFORE, in light of the foregoing, Respondent hereby

respectfully requests that this Honorable Court transfer venue to

Miami Krome, or home fixed street address of XXXXXXXXXXXXXXXXX,

Miami Gardens, Florida 33056, and such other and further just and

proper relief, under the circumstances.

Dated: December 25, 2020

New York, NY Rahul Manchanda, Esq.
Manchanda Law Office PLLC
30 Wall Street, 8 th Floor
New York, NY 10005
Tel: (212) 968-8600
Fax: (212) 968-8601

ATTORNEY CERTIFICATION OF SERVICE

On December 25, 2020 the undersigned did deliver a copy of the

attached Respondent Reply Memorandum of Law to OHS Opposition to
Venue Change to Immigration Judge XXXXXXXXXXXXXXXXXXXXX located
at Detroit Michigan Immigration Court located at P.V. McNamara
Federal Building, 477 Michigan Avenue, Suite 440, Detroit, MI
48226 and televideo at 1170 Michigan Road, Port Huron, Michigan
48060 and OHS Counsel located at Rosa Parks Federal Building,
333 Mt. Elliott Street, 2nd Floor, Detroit, MI, 48207 via U.S.
Mail.

Rahul Manchanda, Esq.

Manchanda Law Office PLLC
30 Wall Street, 8 th Floor
New York NY 10005
Tel: (212) 968-8600
Fax: (212) 968-8601
 United States Department of Justice
Executive Office for Immigration Review
Immigration Court - Detroit Michigan

In the Matter of XXXXXXXXXXXXXXXXXXXXXXX A Number XXXXXXXXXXX

ORDER OF THE IMMIGRATION JUDGE

Upon consideration of the Respondent's Reply Memorandum of Law to OHS Opposition

to Motion to Transfer Venue, it is HEREBY ORDERED that the Respondent's Motion
be GRANTED DENIED because:

□ OHS 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
D Other:

Deadlines:
□ The application(s) for relief must be filed by
□ The respondent must comply with OHS biometrics instructions by

Date Immigration Judge

Certificate of Service
This document was served by: [ J Mail Personal Service
To: [ ] Alien [ J Alien c/o Custodial Officer Alien's Atty/Rep [ ] OHS
Date:

By: Court Staff