Vermont Bar Association

Seminar Materials

58th

Mid-Year Meeting

US-Canada Transactions; plus Obama

Immigration Reform

March 20, 2014

Hilton Burlington, VT

Faculty:

Mark D. Oettinger, Esq. (Moderator)

Claude Schwesig, CPA

Jeffrey P. Guevin, Esq.

Sidney Collier, Esq.

George W. Katz, Esq.

VBA Midyear Meeting Burlington, Vermont – Friday March 20, 2015

US - Canada Transactions

Jeffrey P. Guevin Pratt Vreeland Kennelly Martin & White, Ltd.

64 North Main Street Rutland, Vermont 05701

Tel. (802) 775-7141 Fax. (802) 775-6483

jpg@vermontcounsel.com

Præsumptio veritatis et solemnitatis: Verification of Documents

I. Why – Authenticity and Efficiency II. What: vital records (e.g., birth, death and marriage certificates), court judgments and

corporate records III. Our local knowledge

a. Not so local b. Too local?

IV. Terms V. We are the world

a. Apostille Convention b. Bilateral/multilateral agreements c. Authentication

VI. O Canada

Terms

Acknowledgment – “A formal declaration made in the presence of an authorized officer, such as a notary public, by someone who signs a document and confirms that the signature is authentic. A ‘verification of the fact of execution, but … not a verification of the contents of the instrument executed.’” Black’s Law Dictionary, 9th ed. (quoting 1A CJS Acknowledgments § 2 (1985)).

• Identity; • Personal appearance – date & place • Voluntary signing

Apostille Convention – Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents, drafted by the Hague Convention on Private International Law. a.k.a. Hague Convention Abolishing the Requirement for Legalisation for Foreign Public Documents, the Apostille Convention, or the Apostille Treaty.

Authentication – “Broadly, the act of proving that something (as a document) is true or genuine, esp. so that it may be admitted as evidence; the condition of being so proved.” Black’s Law Dictionary, 9th ed.

Certification – “The act of attesting.” Black’s Law Dictionary, 9th ed.

Legalization – The process of certifying authenticity or genuineness, usually in the cross-border context. Recognition by the destination country of the authentication of a document by the origin country.

Notaire (Quebec) – Public officer who writes, verifies, and registers contracts, obligations, wills, real estate transactions, and other voluntary acts, including documents related to marriages and divorces. Quebec notaries are required to be members of the Chambre des Notaires. Although they are lawyers who must pass an exam and internship, notaires do not make court appearances.

Notary public – “A person authorized by a state to administer oaths, certify documents, attest to the authenticity of signatures, and perform official acts in commercial matters, such as protesting negotiable instruments.” Black’s Law Dictionary, 9th ed. “Every notary public is empowered to take acknowledgements, administer oaths and affirmations, certify that a copy of a document is a true copy of another document, and perform any other act permitted by law.” 24 V.S.A. § 445.

Notarization – Attestation of authenticity.

Verification – “1. A formal declaration made in the presence of an authorized officer, such as a notary public, or (in some jurisdictions) under oath but not in the presence of such an officer, whereby one swears to the truth of the statements in the document. Traditionally, a verification is used as a conclusion for all pleadings that are required to be sworn. 2. An oath or affirmation that an authorized officer administers to an affiant or deponent. 3. Loosely, acknowledgment. 4. [Attestation or exemplification of a copy, usually by the officer responsible for issuing or keeping the original]. 5. Certificate of Authority [e.g., proof of incorporation]. 6. Any act of notarizing.” Black’s Law Dictionary, 9th ed.

General Approach

• Purpose • Evidentiary standard / requirements

o VRE 902 o VRCP 44.1 o Green books

• Language & Translations • Drafting considerations • Origin

o Abroad (inbound) USA Consulate or Embassy Notarial Services Apostille Convention Country Competent Authority “Authentication” Country the “chain” of authenticity

• Verification by local government authority • Certification • Authentication by origin government authority (may be central/federal

or provincial) or • Legalization by US consulate / embassy

o Consular officer authenticates document; o US Government verifies authenticating signature.

o USA (outbound) Apostille Convention Country Competent Authority “Authentication” Country the “chain” of authenticity

• Verification by local government authority • Certification by State (or County and State) government authority • Authentication by US State Department • Legalization by foreign consulate / embassy

o Foreign consular officer authenticates document; o Foreign central government verifies authenticating signature.

Inbound – For use in Vermont

• Notarial Services: USA Consulate or Embassy o American citizen or o Documents to be used in USA

• Authentication o Document coming from Canada

Notary public, Commissioner of Oaths, Notaire, court officer, Directeur de l’état civil

Provincial Official or Authentication and Service of Documents Section (JLAC), Ministry of Foreign

Affairs, Trade and Development, Canada Legalization by U.S. Consulate or Embassy

o Document already in USA Consulate or Embassy Limitations

Outbound – For use in Canada

• Destination: “Authentication” Country – Canada o Notary o Certification by Vermont Secretary of State (Do not get an apostille!) o Authentication by Office of Authentications, U.S. Department of State in Washington,

D.C., for signed certificate of authenticity o Consulate or Embassy for Legalization

• Receipt

Resources

Apostille Section, Hague Convention on Private International Law: http://www.hcch.net/index_en.php?act=text.display&tid=37

A Practical Guide to Document Authentication [book]: http://legalsolutions.thomsonreuters.com/law-products/Treatises/A-Practical-Guide-to-Document-Authentication-Legalization-of-Notarized-and-Certified-Documents-2014-2015-ed/p/100461063

Canada

Canada Evidence Act: http://laws.justice.gc.ca/eng/acts/C-5/

Government of Canada – Travel – Notarial Services: http://travel.gc.ca/travelling/documents/notarial-services

Foreign Affairs, Trade, and Development Canada – Authentication of Documents: http://www.international.gc.ca/department-ministere/authentication-authentification_documents.aspx?lang=eng

United States

Vermont Secretary of State. Notary Guide: https://www.sec.state.vt.us/media/68413/notaryguide_2015.pdf

US Department of State, Office of Authentications: http://travel.state.gov/content/travel/english/legal-considerations/judicial/authentication-of-documents/office-of-authentications.html

US Embassy, Ottawa: http://canada.usembassy.gov/consular_services/notarial-services.html

V.R.E. Rule 902

VERMONT COURT RULES ANNOTATEDCopyright 2015 LEGISLATIVE COUNCIL OF THE GENERAL ASSEMBLY FOR THE STATE OF VERMONT

*** Rules current as amended through January 13, 2015 ***

RULES OF EVIDENCE IX. AUTHENTICATION AND IDENTIFICATION

V.R.E. Rule 902 (2015)

Rule 902. Self-authentication

Extrinsic evidence of authenticity as a condition precedent to admissibility is not required withrespect to the following:

(1) Domestic public documents under seal. -- A document bearing a seal purporting to be that of theUnited States, or of any state, district, commonwealth, territory, or insular possession thereof, or thePanama Canal Zone, or the Trust Territory of the Pacific Islands, or of a political subdivision,department, officer, or agency thereof, and a signature purporting to be an attestation or execution.

(2) Domestic public documents not under seal. -- (A) A document purporting to bear the signature inhis official capacity of an officer or employee of the State of Vermont, or of any political subdivision,department, or agency thereof. (B) A document purporting to bear the signature in his official capacityof an officer or employee of any other entity included in paragraph (1) hereof, if accompanied by acertificate under oath of such person that he acts in that capacity or if a public officer having a seal andhaving official duties in the district or political subdivision of the officer or employee certifies under sealthat the signer has the official capacity and that the signature is genuine.

(3) Foreign public documents. -- A document made authentic by treaty between the United Statesand a foreign country or, if no treaty applies, a document purporting to be executed or attested in hisofficial capacity by a person authorized by the laws of a foreign country to make the execution orattestation, and accompanied by a final certification as to the genuineness of the signature and officialposition (A) of the executing or attesting person, or (B) of any foreign official whose certificate ofgenuineness of signature and official position relates to the execution or attestation or is in a chain ofcertificates of genuineness of signature and official position relating to the execution or attestation. Afinal certification may be made by a secretary of embassy or legation, consul general, consul, viceconsul, or consular agent of the United States, or a diplomatic or consular official of the foreign countryassigned or accredited to the United States. If reasonable opportunity has been given to all parties toinvestigate the authenticity and accuracy of official documents, the court may, for good cause shown,order that they be treated as presumptively authentic without final certification or permit them to beevidenced by an attested summary with or without final certification.

(4) Certified copies of public records. -- A copy of an official record or report or entry therein, or of adocument authorized by law to be recorded or filed and actually recorded or filed in a public office,including data compilations in any form, certified as correct by the custodian or other personauthorized to make the certification, by certificate complying with paragraph (1), (2), or (3) of this ruleor complying with any statute of the United States or the State of Vermont or rule prescribed by theSupreme Court.

(5) Official publications. -- Books, pamphlets, or other publications purporting to be issued by publicauthority.

(6) Newspapers and periodicals. -- Printed materials purporting to be newspapers or periodicals.

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(7) Trade inscriptions and the like. -- Inscriptions, signs, tags, or labels purporting to have beenaffixed in the course of business and indicating ownership, control, or origin.

(8) Acknowledged documents. -- Documents accompanied by a certificate of acknowledgmentexecuted in the manner provided by law by a notary public or other officer authorized by law to takeacknowledgments.

(9) Commercial paper and related documents. -- Commercial paper, signatures thereon, anddocuments relating thereto to the extent provided by general commercial law.

(10) Presumptions created by statute. -- Any signature, document, or other matter declared by anystatute of the United States or of the State of Vermont to be presumptively or prima facie genuine orauthentic.

(11) Certified domestic records of regularly conducted activity. -- The original or a duplicate of adomestic record of regularly conducted activity that would be admissible under Rule 803(6) ifaccompanied by a written declaration of its custodian or other qualified person, made under oath,certifying that the record:

(A) was made at or near the time of the occurrence of the matters set forth by, or frominformation transmitted by, a person with knowledge of those matters;

(B) was kept in the course of the regularly conducted activity; and

(C) was made by the regularly conducted activity as a regular practice.

A party intending to offer a record into evidence under this paragraph must provide written notice ofthat intention to all adverse parties, and must make the record and declaration available for inspectionsufficiently in advance of their offer into evidence to provide an adverse party with a fair opportunity tochallenge them.

(12) Certified foreign records of regularly conducted activity. -- The original or a duplicate of aforeign record of regularly conducted activity that would be admissible under Rule 803(6) ifaccompanied by a written declaration by its custodian or other qualified person certifying that therecord:

(A) was made at or near the time of the occurrence of the matters set forth by, or frominformation transmitted by, a person with knowledge of those matters;

(B) was kept in the course of the regularly conducted activity; and

(C) was made by the regularly conducted activity as a regular practice.

The declaration must be signed in a manner that, if falsely made, would subject the maker to criminalpenalty under the laws of the country where the declaration is signed. A party intending to offer arecord into evidence under this paragraph must provide written notice of that intention to all adverseparties, and must make the record and declaration available for inspection sufficiently in advance oftheir offer into evidence to provide an adverse party with a fair opportunity to challenge them.

HISTORY: Amended March 31, 2004, eff. July 1, 2004.

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V.R.C.P. Rule 44.1

VERMONT COURT RULES ANNOTATEDCopyright 2015 LEGISLATIVE COUNCIL OF THE GENERAL ASSEMBLY FOR THE STATE OF VERMONT

*** Rules current as amended through January 13, 2015 ***

RULES OF CIVIL PROCEDURE VI. TRIALS

V.R.C.P. Rule 44.1 (2015)

Rule 44.1. Determination of Local and Foreign Law

(a) Notice of State and Foreign Law. -- A party who intends to raise an issue concerning anadministrative regulation of any agency of this state or a private law enacted by the legislature of thisstate, or concerning such a regulation, private law, or the general law of another state or of anyterritory or dependency of the United States or of a foreign country shall give notice by pleadings orother reasonable written notice. The court, in determining such law, may consider any relevantmaterial or source, including testimony, whether or not submitted by a party or admissible under theVermont Rules of Evidence. The court's determination shall be treated as a ruling on a question of law.

(b) Notice and Proof of Municipal Ordinances and Regulations. -- A party who intends to raise an issueconcerning an ordinance or administrative regulation of any political subdivision of this or another stateof the United States, or of a political subdivision of any territory or dependency of the United States orof a foreign country, shall give notice thereof by pleadings or other reasonable written notice. Thatparty shall thereafter produce at the hearing or trial evidence of the contents of such ordinance orregulation sufficient to support a finding that the contents are what the party claims them to be. Thecourt shall determine the contents of the ordinance or regulation as a question of fact. The court shalldetermine the legal significance of such contents as a question of law in the manner provided insubdivision (a) of this rule.

HISTORY: Amended Dec. 28, 1982, eff. April 1, 1983.

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Apostille Convention Signatories

Apostille/Certification Application - VT

Apostille Examples

Authenticated Document Example

Immigration Law Update Executive Actions on Immigration

Burlington, Vermont – Friday March 20, 2015

Attorney George Katz Immigration Law

289 Southfield Drive Williston, VT 05495 Tel (802) 878-0767 Fax (802) 878-0767

gwkatz@comcast.net

I. U.S. Immigration Laws

A. The Immigration and Nationality Act of 1952 (INA), 8 U.S.C. section 1101, et sequens

B. The Immigration and Control Act of 1986 (IRCA), 8 U.S.C. section 1324

C. The Immigration Marriage Fraud Amendments of 1986, 8 U.S.C. section

1325 D. The Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA) II. U.S. Immigration Agencies A. Department of Homeland Security (DHS) 1. U.S. Customs and Border Enforcement (CBE) 2. U.S. Citizenship and Immigration Services (USCIS) 3. U.S. Immigration and Customs Enforcement (ICE) B. U.S. Department of Justice (DOJ), Civil Rights Division, Office of Special Counsel for Unfair Immigration-Related Practices (UIREP), 8 U.S.C. section 1324b C. U.S. Department of State (DOS), Bureau of Consular Affairs

Attorney George Katz Tel: (802) 878-0767 Email: gwkatz@comcast.net

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D. U.S. Department of Labor (DOL) III. Immigrant and Non-immigrant Visas A. Immigrant Visas 1. Family-sponsored preferences 2. Employment-based preferences B. Non-immigrant visas 1. Visitors 2. Students 3. Temporary Agricultural Workers (H-2A) 4. Temporary Non-agricultural Workers (H-2B) 5. Professional and Specialty Occupation Workers (H-1B, H-1B1, and E-3) 6. Registered Nurses (H-1C) IV. Executive Actions on Immigration

USCIS states on November 20, 2014, the President announced a series of executive

actions to crack down on illegal immigration at the border, prioritize deporting felons

not families, and require certain undocumented immigrants to pass a criminal

background check and pay taxes in order to temporarily stay in the U.S. up to 3 years

without fear of deportation.

These initiatives include DACA and DAPA:

A. Expanding the population eligible for the Deferred Action for Childhood Arrivals

(DACA) program to people of any current age who entered the United States

Attorney George Katz Tel: (802) 878-0767 Email: gwkatz@comcast.net

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before the age of 16 and lived in the United States continuously since January

1, 2010, and extending the period of DACA and work authorization from two

years to three years.

B. Allowing parents of U.S. citizens and lawful permanent residents to request

deferred action and employment authorization for three years, in a new

Deferred Action for Parents of Americans and Lawful Permanent Residents

(DAPA) program, provided they have lived in the United States continuously

since January 1, 2010, and pass required background checks.

C. (DACA) The existing DACA provided at USCIS:

On June 15, 2012, the Secretary of Homeland Security announced that certain

people who came to the United States as children and meet several key guidelines

may request consideration of deferred action for a period of three years, subject to

renewal, and would then be eligible for work authorization.

D. DACA: you may request consideration of the existing DACA if you:

1. Were under the age of 31 as of June 15, 2012;

2. came to the United States before reaching your 16th birthday;

3. Have continuously resided in the United States since June 15, 2007, up to the

present time;

4. Were physically present in the United States on June 15, 2012, and at the time of

making your request for consideration of deferred action with USCIS;

5. Had no lawful status on June 15, 2012, meaning that:

You never had a lawful immigration status on or before June 15, 2012, or

Any lawful immigration status or parole that you obtained prior to June 15, 2012,

Attorney George Katz Tel: (802) 878-0767 Email: gwkatz@comcast.net

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had expired as of June 15, 2012;

6. Are currently in school, have graduated or obtained a certificate of completion

from high school, have obtained a General Educational Development (GED)

certificate, or are an honorably discharged veteran of the Coast Guard or Armed

Forces of the United States; and

7. Have not been convicted of a felony, a significant misdemeanor, three or more

other Misdemeanors, and do not otherwise pose a threat to national security or

public.

USCIS Update:

Due to a federal court order, USCIS will not begin accepting requests for the expansion of DACA on February 18 as originally planned. The court's temporary injunction, issued February 16, does not affect the existing DACA. Individuals may continue to come forward and request an initial grant of DACA or renewal of DACA under the guidelines established in 2012.

V. Enforcement

The Secretary of Homeland Security Jeh Charles Johnson provided a Memorandum

dated November 20, 2014 regarding Policies for the Apprehension, Detention and

Removal of Undocumented Immigrants which reads in pertinent part:

A. Civil Immigration Enforcement Priorities

The following shall constitute the Department's civil immigration enforcement

priorities:

Priority 1 (threats to national security, border security, and public safety)

Attorney George Katz Tel: (802) 878-0767 Email: gwkatz@comcast.net

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Aliens described in this priority (ONE) represent the highest priority to which

enforcement resources should be directed:

(a) aliens engaged in or suspected of terrorism or espionage, or who otherwise pose a

danger to national security;

(b) aliens apprehended at the border or ports of entry while attempting to unlawfully

enter the United States;

(c) aliens convicted of an offense for which an element was active participation in a

criminal street gang, as defined in 18 U.S.C. § 52 l(a), or aliens not younger than 16

years of age who intentionally participated in an organized criminal gang to further

the illegal activity of the gang;

(d) aliens convicted of an offense classified as a felony in the convicting jurisdiction,

other than a state or local offense for which an essential element was the alien's

immigration status; and

(e) aliens convicted of an "aggravated felony," as that term is defined in section

101(a)(43) of the Immigration and Nationality Act at the time of the conviction.

The removal of these aliens must be prioritized unless they qualify for asylum or

another form of relief under our laws, or unless, in the judgment of an ICE Field

Office Director, CBP Sector Chief or CBP Director of Field Operations, there are

compelling and exceptional factors that clearly indicate the alien is not a threat to

national security, border security, or public safety and should not therefore be an

enforcement priority.

Attorney George Katz Tel: (802) 878-0767 Email: gwkatz@comcast.net

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Priority 2 (misdemeanants and new immigration violators)

Aliens described in this priority, who are also not described in Priority 1, represent

the second-highest priority for apprehension and removal. Resources should be

dedicated accordingly to the removal of the following:

(a) aliens convicted of three or more misdemeanor offenses, other than minor traffic

offenses or state or local offenses for which an essential element was the alien's

immigration status, provided the offenses arise out of three separate incidents;

(b) aliens convicted of a "significant misdemeanor," which for these purposes is an

offense of domestic violence; sexual abuse or exploitation; burglary; un lawful

possession or use of a firearm; drug distribution or trafficking; or driving under the

influence; or if not an offense listed above, one for which the individual was

sentenced to time in custody of 90 days or more (the sentence must involve time to

be served in custody, and does not include a suspended sentence);

(c) aliens apprehended anywhere in the United States after unlawfully entering or re-

entering the United States and who cannot establish to the satisfaction of an

immigration officer that they have been physically present in the United States

continuously since January 1, 2014 ; and

(d) aliens who, in the judgment of an ICE Field Office Director, USCIS District

Director, or USCIS Service Center Director, have significantly abused the visa or visa

waiver programs.

Attorney George Katz Tel: (802) 878-0767 Email: gwkatz@comcast.net

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These aliens should be removed unless they qualify for asylum or another form of

relief under our laws or, unless, in the judgment of an ICE Field Office Director, CBP

Sector Chief, CBP Director of Field Operations, USCIS District Director, or users

Service Center Director, there are factors indicating the alien is not a threat to

national security, border security, or public safety, and should not therefore be an

enforcement priority.

Priority 3 (other immigration violations)

Priority 3 aliens are those who have been issued a final order of removal2 on or after

January 1, 2014. Aliens described in this priority, who are not also described in

Priority 1 or 2, represent the third and lowest priority for apprehension and removal.

Resources should be dedicated accordingly to aliens in this priority. Priority 3 aliens

should generally be removed unless they qualify for asylum or another form of relief

under our laws or, unless, in the judgment of an immigration officer, the alien is not a

threat to the integrity of the immigration system or there are factors suggesting the

alien should not be an enforcement priority.

B. Apprehension, Detention, and Removal of Other Aliens Unlawfully in the United

States

Nothing in this memorandum should be construed to prohibit or discourage the

apprehension, detention, or removal of aliens unlawfully in the United States who are

not identified as priorities herein. However, resources should be dedicated, to the

greatest degree possible, to the removal of aliens described in the priorities set forth

Attorney George Katz Tel: (802) 878-0767 Email: gwkatz@comcast.net

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above, commensurate with the level of prioritization identified. Immigration officers

and attorneys may pursue removal of an alien not identified as a priority herein,

provided, in the judgment of an ICE Field Office Director, removing such an alien

would serve an important federal interest.

C. Detention

As a general rule, DHS detention resources should be used to support the enforcement

priorities noted above or for aliens subject to mandatory detention by law. Absent

extraordinary circumstances or the requirement of mandatory detention, field office

directors should not expend detention resources on aliens who are known to be

suffering from serious physical or mental illness, who are disabled, elderly, pregnant,

or nursing, who demonstrate that they are primary caretakers of children or an infirm

person, or whose detention is otherwise not in the public interest. To detain aliens in

those categories who are not subject to mandatory detention, DHS officers or special

agents must obtain approval from the ICE Field Office Director. If an alien falls within

the above categories and is subject to mandatory detention, field office directors are

encouraged to contact their local Office of Chief Counsel for guidance.

D. Exercising Prosecutorial Discretion

Section A, above, requires DHS personnel to exercise discretion based on individual

circumstances. As noted above, aliens in Priority l must be prioritized for removal

unless they qualify for asylum or other form of relief under our laws, or unless, in the

judgment of an ICE Field Office Director, CBP Sector Chief, or CBP Director of Field

Attorney George Katz Tel: (802) 878-0767 Email: gwkatz@comcast.net

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Operations, there are compelling and exceptional factors that clearly indicate the

alien is not a threat to national security, border security, or public safety and should

not therefore be an enforcement priority. Likewise, aliens in Priority 2 should be

removed unless they qualify for asylum or other forms of relief under our laws, or

unless, in the judgment of an ICE Field Office Director, CBP Sector Chief, CBP Director

of Field Operations, USCIS District Director, or USCIS Service Center Director, there

are factors indicating the alien is not a threat to national security, border security, or

public safety and should not therefore be an enforcement priority. Similarly, aliens in

Priority 3 should generally be removed unless they qualify for asylum or another form

of relief under our laws or, unless, in the judgment of an immigration officer, the

alien is not a threat to the United States. (Note: Footnotes deleted.)

REFERENCES

USCIS

1) Frequently Asked Questions – DACA. http://1.usa.gov/1j1NhUn

2) Executive Action on Immigration. http://1.usa.gov/1F6g8lf

3) Flier for DAPA. http://1.usa.gov/1AisK8Q

4) Consideration of Deferred Action for Childhood Arrivals. http://1.usa.gov/1i64USU

Department of Homeland Security

1) Memoranda by Jeh Charles Johnson: “Policies for the Apprehension, Detention, and Removal of Undocumented Immigrants.” http://1.usa.gov/1uNqfdE

White House

1) Remarks by the President in Address to the Nation on Immigration: http://1.usa.gov/1xI7XfV

Remarks by the President in Address to the Nation on Immigration

http://www.whitehouse.gov/the-press-office/2014/11/20/remarks-president-address-nation-immigration

Personal Background George W. Katz, Esq.

I graduated from the Ohio State University College of Law, and in 1973, I was admitted to the Supreme Court of Ohio Bar as an attorney. I have served on the Governor's Committee for the Employment of People with Disabilities during the term of Governor Jim Douglas. In 2005, I was named to the Board of the State Rehabilitation Council for the Division of the Blind where I served for four years, two years as Chair of the Council. I am a retired long-term attorney of the Immigration and Naturalization Service. I currently help people receive immigration benefits and services. I have learned policies, practices, and procedures while working for INS for nearly twenty years. I personally know many of the employees and officers, and I have extensive experience with various types of DHS cases and issues. Specifically, in my career with INS, I handled many kinds of cases including deportation, asylum, business, family and fiancée visas, foreign adoption, legalization, convention against torture, and citizenship. I recommended for approval that aliens be granted lawful permanent resident status (i.e. "green card" status), and I recommended immigrants be granted U.S. citizenship through naturalization. I was involved in hearings in Baltimore, Miami, Buffalo, Philadelphia, Hartford, Boston, New York, Atlanta, Washington DC (in Arlington), Cleveland, El Paso and Harlingen, Texas. Some of my cases were published in the United States bound volumes of the Immigration and Naturalization Board Decisions. I am continuing to use my skills and knowledge to help people from many different backgrounds to legally enter the United States and contribute to the American way of life. I am also accepting clients who seek help with DACA and DAPA. Lastly, I am involved in my church. This gives me a focus for service. George W. Katz 289 Southfield Drive Williston, VT 05495 (802) 878 0767 gwkatz@comcast.net