COMES NOW, Counsel for Respondent, Client CLIENT, and respectfully requests that this Court permit her to withdraw as attorney of record. Respondent has moved to Georgia and has requested that the Court change venue in her case to the Atlanta, Georgia Immigration Court. In support of this motion, the undersigned states the following:
The National Immigrant Justice Center (NIJC) began representing Respondent in January of 2006. In about June of 2007. Respondent moved to Riverdale, Georgia, to be near friends who could support her during the pendency of her asylum application. In April of 2008, while continuing to reside in Georgia, Respondent gave birth to twins. The father of Respondent’s twin children is a U.S. citizen.
Respondent is currently set for a master calendar hearing on December 15, 2008 before Judge Katsivalis.
Based on her residence in Georgia and the birth of her twins, Respondent has requested that the Court change venue in her case to the Atlanta, Georgia Immigration Court and Counsel has filed a motion for change of venue with the Court on Respondent’s behalf.
Counsel is employed by the NIJC, a nonprofit that provides free and low-cost representation to immigrants in removal proceedings. NIJC has limited resources and can only represent respondents who reside within the Chicago area. NIJC does not have the resources to represent Respondent before the Atlanta Immigration Court or to assist Respondent with the cost of traveling to and from Georgia to this Court.
Respondent is aware that she will need to secure counsel in Georgia should this Court grant Counsel’s motion to withdraw and motion to change venue. Counsel has provided Respondent with a list of immigration attorneys from whom she can seek assistance. Respondent is also aware that if this Court grants Counsel’s motions, she must attend any scheduled hearings before the Atlanta Immigration Court even if she has not secured new counsel.
WHEREFORE, given Respondent’s relocation to Georgia and NIJC’s limited resources, Counsel respectfully requests that she be permitted to withdraw as attorney of record in this case.
CERTIFICATE OF SERVICE I, ___________________, hereby certify that I delivered a copy of Motion to Withdraw to the Office of the District Counsel, located at 55 East Monroe St., Suite 1700, Chicago, IL 60603-5701, on _______________________.
In the Matter of Client Client A Number: XXX-XXX-XXX
ORDER OF THE IMMIGRATION JUDGE
Upon consideration of the Respondent’s Motion to Withdraw, it is HEREBY ORDERED that the motion be _____ GRANTED _____ DENIED because:
_____DHS does not oppose the motion.
_____ A response to the motion has not been filed with the Court.