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Your honor if it please the court
Your honor if it please the court












your honor if it please the court

“The Ninth Circuit allows law students to have that opportunity.”Ĭoincidental to Hong joining the BC Law faculty, Dean Vincent Rougeau appointed Clinical Professor of Law Paul Tremblay as Faculty Director of Experiential Learning. “For an attorney to have one appellate argument during his or her entire career is a pretty remarkable achievement,” Hong says. The program helps the court with its docket, provides legal representation to people in serious need, and offers a singular educational opportunity to law students. The court schedules the briefing and oral arguments to coincide with the academic calendar.

#YOUR HONOR IF IT PLEASE THE COURT PRO#

Hong knew that the court had a program that permits law students, pro bono and under supervision, to handle a small number of immigration appeals hand-picked by the court from among thousands of cases. With a geographic area that includes California and Arizona, the court has an extensive immigration docket. She estimates that she’s handled just shy of 100 appeals before the Ninth Circuit. She clerked for the court after law school, and later had her own private practice specializing in immigration and criminal appeals. Hong, who joined the BC Law faculty in the fall of 2012, has a long history with the Ninth Circuit. Professor Hong coached Ozolins, Trombly, Houck, and Kete in the fine art of brief writing. “Marija’s ability to call this up this evidence on the spot was exceptional.” This was a critical argument because it pointed the court to evidence that the BIA had not considered when dismissing all of the presented evidence,” Hong says. “On her feet, Marija identified the one piece of evidence-a police report about the harm facing the mother-that did not have the taint of Ms. Hong explains what made Ozolins’ exchange with the judge exemplary. That Ozolins held her own is testimony to her intelligence, dedication, and hard work-and also to the tutelage of Assistant Professor Kari Hong, founder of the Law School’s Ninth Circuit Appellate Project (NCAP). Questioning like that would have been tough even for an experienced appellate lawyer. Carrion’s abuser who continually visited her home and threatened her daughter with death if she ever returned to the Dominican Republic.” The police report was based on the mother’s continued harassment by Ms. Judge McKeown: “Based on what she told her mother.”

your honor if it please the court

Ozolins: “No, your honor, the police report is submitted by her mother, the two witness affidavits…” Her credibility underlies all of those things, doesn’t it?” Judge McKeown: “No, but she has an adverse credibility finding so we don’t have all of that. Carrion’s reasonable-fear interview, and her application for a withholding of removal which compel holding that she had been raped, beaten,… Ozolins: “On the torture issue under CAT we have a police report, two witness affidavits, Ms. Ozolins: “We would argue that there is substantial evidence that compels reversing the BIA decision on the CAT claim as well…” Margaret McKeown stops Ozolins to say that the BIA had no credible evidence upon which to grant relief. Ozolins is arguing that the Board of Immigration Appeals (BIA) erred in denying Ms. Carrion’s case, and even though her lawyers were two third-year law students, they didn’t hold back. Her credibility was in question because the record showed that she had lied to authorities, including to a district court judge, on a number of occasions. Carrion’s case was a particularly tough one for her young lawyers. Carrion was seeking to stay and work in the US under the status “withholding of removal” and under the Convention against Torture (CAT) Treaty. This was the real thing, with a real client who had fled her native Dominican Republic as a refugee of terrifying domestic violence and, in the course of seeking safe haven, got entangled in the US immigration system and was imprisoned in an Arizona detention center. To be clear: This was not an educational moot court program being indulged by the Ninth Circuit. So began the oral argument of Ozolins ’14, before a three-judge panel of the Ninth Circuit Court of Appeals sitting in San Francisco on March 11, 2014. Carrion.” So began the oral argument of Ozolins 14’, before a three-judge panel of the Ninth Circuit Court of Appeals sitting in San Francisco on March 11, 2014. We represent petitioner Rita Maria Carrion Garcia, whom we will refer to as Ms. We are appearing under the supervision of Professor Kari Hong who is seated at the counsel table. My partner Mackenzie Houck and I are certified law students participating in the Boston College Law School Ninth Circuit Appellate Project.














Your honor if it please the court