Motion to Reopen Granted in One Day: After Prior Counsel’s Ineffective Assistance Leads to Removal Order
November 11, 2025

Table of ContenTS

Our client reached out to the Law Offices of Sabrina Li after receiving a removal order in June 2025, issued following his individual hearing. The order resulted from his prior counsel’s failure to submit supplemental evidence before the 30-day deadline set by the Immigration Judge. Acting swiftly, our team filed a Motion to Reopen on September 8, 2025, which was approved the very next day—September 9, 2025—restoring our client’s opportunity to pursue relief in the United States.

Prior Counsel’s Ineffective Assistance Led to Removal Order

During the client’s master hearing, the Immigration Judge clearly instructed the prior attorney to submit all supplemental evidence at least 30 days before the individual hearing. Despite this directive, the prior counsel failed to inform the client of the deadline, only requested documents less than a month before the hearing, and ultimately did not submit the required evidence on time. As a result, during the individual hearing in June 2025, the Judge refused to accept the late-filed supplemental documents and issued a removal order, concluding that the case lacked sufficient supporting evidence.

The decision left the client devastated, as he faced the possibility of being removed from the United States and separated from his family and community.

Strategic Action: Filing a Motion to Reopen

Recognizing the urgency of the situation, the Law Offices of Sabrina Li was retained shortly after the removal order was issued. Upon conducting a thorough review of the court record, our team identified clear procedural errors and deficiencies in prior counsel’s representation that warranted reopening the case.

We meticulously compiled evidence demonstrating the client’s diligence and the prior attorney’s negligence, including correspondence records, court transcripts, and proof of the previously prepared but unfiled documents. On September 8, 2025, we submitted a comprehensive Motion to Reopen, supported by detailed legal arguments and a request for equitable relief under the Matter of Lozada framework.

Rapid Success: Case Reopened the Next Day

In an exceptional outcome, the Immigration Judge granted the Motion to Reopen just one day after filing—on September 9, 2025. This swift approval underscored the strength of our legal arguments and the urgency of the client’s situation. The client has now received a new hearing date and can continue pursuing his immigration relief in the United States.

The Law Offices of Sabrina Li: Turning Setbacks into Second Chances

This case highlights our firm’s dedication to protecting clients who have been adversely affected by prior counsel’s ineffective assistance. Through careful case analysis, strategic planning, and persuasive legal advocacy, we transformed a removal order into a renewed opportunity for relief.

If you or someone you know has been affected by a similar situation, contact the Law Offices of Sabrina Li at (213) 375-8096 or email us at info@sabrinali.law. Our experienced immigration team is ready to fight for your right to a fair hearing and a second chance at relief.

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