Christina Brown The Law Office of Christina Brown EOIR ID: TF705453 Bar No.: CO 46137 1888 Sherman Street, Suite 200 Denver, Colorado 80203 303-747-3494 cbrownlawoffice@gmail.com MPP UNITED STATES DEPARTMENT OF JUSTICE EXECUTIVE OFFICE OF IMMIGRATION REVIEW HARLINGEN, TEXAS __________________________________________ In the Matter of: ) ) ) ) In removal proceedings ) __________________________________________) Immigration Judge: Crews Next Individual Hearing: RESPONDENTS’ EMERGENCY MOTION TO CONTINUE Christina Brown The Law Office of Christina Brown EOIR ID: TF705453 Bar No.: CO 46137 1888 Sherman Street, Suite 200 Denver, Colorado 80203 303-747-3494 cbrownlawoffice@gmail.com MPP UNITED STATES DEPARTMENT OF JUSTICE EXECUTIVE OFFICE OF IMMIGRATION REVIEW HARLINGEN, TEXAS __________________________________________ In the Matter of: ) ) ) ) In removal proceedings ) __________________________________________) RESPONDENTS’ EMERGENCY MOTION TO CONTINUE Respondents, through undersigned counsel, hereby request an emergency continuance of their individual hearing currently scheduled for at 1:00pm. In support of this continuance, respondents’ counsel states the following: 1. There has been a worldwide pandemic declared by the World Health Organization for Coronavirus-19, also known as COVID-19. 2. Counsel has potentially been exposed to this virus through her husband who is exhibiting respiratory and flu-like symptoms and a high fever. 3. Counsel is also experiencing flu-like symptoms and respiratory symptoms. 4. Given the potential danger this virus creates for vulnerable communities, counsel called EOIR to check in on whether a continuance is proper in this matter. Counsel was told to file a motion to continue via electronic mail and that it would be forwarded to the immigration judge handling this case. 5. The respondents in this matter include a medically vulnerable child with a . Potential exposure to the virus could present serious medical complications for him. 6. Many participants in MPP are medically vulnerable in Mexico. Potential exposure to COVID-19 could result in a significant increase in cases in refugee camps and shelters in Mexico. 7. Counsel’s interactions with government workers and contractors also presents a potential exposure point to MPP participants and other government workers and their families, as these same contractors will come into contact with hundreds, if not thousands, of respondents in a given day. 8. A continuance in this matter does not prejudice the government and is not being made for purposes of delay. WHEREFORE, given the seriousness of the potential consequences of COVID-19 exposure from counsel, respondents request a continuance of their individual hearing. Submitted this 11th day of March 2020. Christina A. Brown Attorney for respondents UNITED STATES DEPARTMENT OF JUSTICE EXECUTIVE OFFICE FOR IMMIGRATION REVIEW IMMIGRATION COURT HARLINGEN, TEXAS In the Matter of: ORDER OF THE IMMIGRATION JUDGE Upon consideration of the Respondents’ Emergency Motion to Continue Individual Hearing, it is HEREBY ORDERED that the Motion be □ GRANTED □ DENIED because: □ □ □ □ □ □ □ The 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 of the motion. The motion is untimely per ___________________________________. Other: ____________________________________________________. ___________________________ Date ______________________________ Immigration Judge UNITED STATES DEPARTMENT OF JUSTICE EXECUTIVE OFFICE FOR IMMIGRATION REVIEW IMMIGRATION COURT HARLINGEN, TEXAS In the Matter of: THE IMMIGRATION JUDGE Upon consideration of the Respondents’ Emergency Motion to Continue Individual Hearing, it is HEREBY ORDERED that the Motion be □ GRANTED □ DENIED because: □ □ □ □ □ □ □ The 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 of the motion. The motion is untimely per ___________________________________. Other: ____________________________________________________. ___________________________ Date ______________________________ Immigration Judge UNITED STATES DEPARTMENT OF JUSTICE EXECUTIVE OFFICE FOR IMMIGRATION REVIEW IMMIGRATION COURT HARLINGEN, TEXAS In the Matter of: ORDER OF THE IMMIGRATION JUDGE Upon consideration of the Respondents’ Emergency Motion to Continue Individual Hearing, it is HEREBY ORDERED that the Motion be □ GRANTED □ DENIED because: □ □ □ □ □ □ □ The 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 of the motion. The motion is untimely per ___________________________________. Other: ____________________________________________________. ___________________________ Date ______________________________ Immigration Judge CERTIFICATE OF SERVICE I, Christina A. Brown, hereby certify that on March 11, 2020, I served an exact copy of this Respondents’ EMERGENCY MOTION TO CONTINUE to the Office of Chief Counsel at: 1717 Zoy Street Harlingen, TX, 78552 By U.S. Priority Mail. _________________________ Christina A. Brown