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UNITED STATES DISTRICT COURT
(Alexandria Division)
YAAACHAMPOMA,
Plaintiff,
V.
BOARD OF IMMIGRATION APPEALS,
Defendant
Ser...
COMPLAINT
The Plaintiffhereby sues the Defendant, stating as and for her cause ofaction the following:
COUNT ONE
(Administ...
ofstatutory authority or limitations, or short ofstatutory right; or without observance of
procedures required by law.
WHE...
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Achampoma_v_Board_of_Immigration_Appeals__vaedce-16-00668 COMPLAINT RE RESCISSION

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Achampoma_v_Board_of_Immigration_Appeals__vaedce-16-00668 COMPLAINT RE RESCISSION

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Achampoma_v_Board_of_Immigration_Appeals__vaedce-16-00668 COMPLAINT RE RESCISSION

  1. 1. UNITED STATES DISTRICT COURT (Alexandria Division) YAAACHAMPOMA, Plaintiff, V. BOARD OF IMMIGRATION APPEALS, Defendant Serve: Dana J. Boente, United States Attorney for the Eastern District of Virginia Justin W. Williams United States Attorney's Building 2100 Jamieson Ave Alexandria, VA 22314 Loretta E. Lynch, United States Attorney General, United States Department of Justice 950 Pennsylvania Avenue NW Washington, DC 20530-0001 United States Department of of Justice Executive Office for Immigration Review Office of the Chief Clerk Board of Immigration Appeals 5201 Leesburg Pike, Suite 2000 Falls Church, VA 22041 Civil Action No, FILED . Zfllb JUN 15 A 11= 22 CL-P.K US DiSTRlCT COURT J,LEX;.:iOF'^ViRGlK!A lo Case 1:16-cv-00668-GBL-MSN Document 1 Filed 06/15/16 Page 1 of 3 PageID# 1
  2. 2. COMPLAINT The Plaintiffhereby sues the Defendant, stating as and for her cause ofaction the following: COUNT ONE (Administrative Procedure Act, 28 USC §§702 et seq.) 1. This Plaintiffin this action seeksjudicial review ofthe Order ofthe Board of Immigration Appeals ("BIA") entered in this matter on May 15,2016, a copy ofwhich is attached, identified as "Exhibit 1" and incorporated by reference. 2. To date, no court has upheld the validity ofthe Order. 3. Jurisdiction is asserted pursuant to 28 USC §1331 (Federal Question) and 5 USC §§702 et seq. (Administrative Procedure Act). 4. Venue is asserted pursuant to 28 USC §1391(e). 5. The Plaintiffcontended before the BIA that the Immigration Judge erred by denying her motion to terminate rescission proceedings (pertaining to her lawfiil permanent resident status); that the proceedings were time-barred; that equitable estoppel should apply due to the government's error; and that the Department ofHomeland Security ("DHS") did not meet its burden ofestablishing by clear and convincing evidence that her status should be rescinded. 6. The Plaintiffcontends in this action that the BIA erred in rejecting her above-stated positions, affirming the Immigration Judge's order, and dismissing her appeal. 7. The Plaintiffcontends, moreover, that the BIA's rulings were arbitrary, capricious, an abuse ofdiscretion, or otherwise not in accordance with the law; and they were in excess Case 1:16-cv-00668-GBL-MSN Document 1 Filed 06/15/16 Page 2 of 3 PageID# 2
  3. 3. ofstatutory authority or limitations, or short ofstatutory right; or without observance of procedures required by law. WHEREFORE, the Plaintiffrequests: 1. That this Court hold unlawful and set aside the BIA's actions; 2. That she be awarded costs and attorney's fees; and, 3. For such other and further relief as the Court may deem just and proper. Date: J c 1-^ Z ^ ^ Robert J. Harris, Esquire VSBNo. 23143 2722 Merrilee Drive, Suite 340 Fairfax, VA 22031 Telephone: (703) 249-5108 Facsunile: (703) 962-7579 e-mail: ijharrisl01@msn.com Counsel for the Plaintiff Respectfiilly submitted, Yaa Achampoa, By counsel Case 1:16-cv-00668-GBL-MSN Document 1 Filed 06/15/16 Page 3 of 3 PageID# 3

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