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Sheridan Green (SBN: 24083103)
Gonzalez Olivieri LLC
2200 Southwest Freeway, Suite 550
Houston, Texas 77098
Tel: (713) 4...
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3. Plaintiff, Mr. Felizzola, has been described as “among the most brilliant electrical reliability
and engineering expe...
3
10. Defendant Jeh Johnson is the Secretary of the United States Department of Homeland Security
(hereafter “DHS”) and is...
4
1. working abroad as a contractor for Exxon Mobil in South Korea, Russia, and Qatar. CIS has
granted Plaintiff approval,...
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31. The duty to make a decision on all applications is implicit in the regulations. See, e.g., 8 C.F.R.
§ 103.2(b)(19); ...
6
United States or any agency thereof to perform a duty owed to the
plaintiff.
37. A mandamus plaintiff must demonstrate t...
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43. Plaintiff re-alleges and incorporates by reference, as if fully set forth herein, the allegations in
paragraphs 1-42...
8
48. As such, Plaintiff has four viable claims under the APA.
49. First, pursuant to § 706(2)(A), Defendants have acted i...
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MANDAMUS PETITION--INDEX OF EXHIBITS
_____Document EXHIBIT
Log of and Responses to CIS Status Inquiries A
Case 4:15-cv-...
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Exhibit A
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FELIZZOLA v. USCIS Complaint 9-16-2015

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FELIZZOLA v. USCIS Complaint 9-16-2015 [EB-2 NIW MANDAMUS COMPLAINT] Hopefully he will get a definite answer soon!

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FELIZZOLA v. USCIS Complaint 9-16-2015

  1. 1. 1 Sheridan Green (SBN: 24083103) Gonzalez Olivieri LLC 2200 Southwest Freeway, Suite 550 Houston, Texas 77098 Tel: (713) 481-3040 Fax: (713) 588-8683 Counsel of Record for Petitioner UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS CESAR FELIZZOLA Plaintiff, JEH JOHNSON, SECRETARY OF UNITED STATES DEPARTMENT OF HOMELAND SECURITY; LEÓN RODRÍGUEZ, DIRECTOR OF UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES; DAVID ROARK, DIRECTOR OF TEXAS SERVICE CENTER, UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES; U.S. DEPARTMENT OF HOMELAND SECURITY; and UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES, Defendants. Case No. PLAINTIFF’S PETITION FOR WRIT OF MANDAMUS INTRODUCTION 1. This mandamus action is brought by Cesar Felizzola (“Plaintiff” or “Petitioner”)—a citizen of Venezuela—to compel Defendants to complete the adjudication of Plaintiff’s Form I-140 National Interest Waiver petition (“Form I-140” or “I-140 petition”), which has been pending with Defendants since October 11, 2013, despite the latter’s clear duty to render a decision within a reasonable time. 2. Plaintiff, a Senior Lead Electrical Engineer for Brunel Energy, Inc., in Houston Texas, is a leader with 35 years of experience and a renowned expert in his field of power engineering and designing electrical systems. His work benefits the U.S. economy, benefits the lives and health of U.S. workers, and protects the environment from potential catastrophes. Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 1 of 30
  2. 2. 2 3. Plaintiff, Mr. Felizzola, has been described as “among the most brilliant electrical reliability and engineering experts in the petroleum industry” and has been “appointed to lead the most important power systems projects ever made.”1 Moreover, the national interest waiver petition cited numerous sources as to the severe shortage of experienced power engineers in the United States. Finally, multiple authorities noted that Plaintiff’s continued expertise could very well prevent future economic and environmental disasters like the infamous Deepwater Horizon rig explosion and subsequent oil spill of 2010. 4. For nearly 2 years, Plaintiff has waited patiently for Defendant United States Citizenship and Immigration Services (hereafter “CIS”) to render a decision or a request for evidence on his National Interest Waiver immigrant visa petition. 5. CIS has a non-discretionary duty to adjudicate all immigrant visa petitions, including Plaintiff’s petition. Moreover, CIS has a duty to perform the adjudication in a reasonable time. To date, CIS has not adjudicated Plaintiff’s petition in a reasonable time. 6. Current processing times for Form I-140, Petition for Alien Worker based on a national interest waiver, indicate that cases filed before December 2, 2014 should have been adjudicated and a determination rendered. Plaintiff’s application was filed with CIS on October 11th, 2013, and is still pending without decision or request for additional evidence. 7. CIS has acted in bad faith in refusing to adjudicate Plaintiff’s I-140 petition within a reasonable time. CIS knows that because of its failure to adjudicate the I-140 petition in a reasonable time, Plaintiff and his employer may be forced to endure economic burdens attached to unnecessarily drawn out immigration procedures and left questioning his ability to work and contribute his exceptional abilities to the U.S. workforce and U.S. national interest. Plaintiff and his employer are also injured by the continuing expense and burden of maintaining non- immigrant status in the United States which requires complicated and expensive H-1B renewals and difficulty and costly delays in travelling internationally. 8. Plaintiff therefore files this action in order to ensure that his I-140 petition is promptly adjudicated. PARTIES 9. Plaintiff Cesar Felizzola (hereafter “Felizzola”) is a dual citizen of Venezuela and Italy and a power engineer currently on an H-1B visa in Houston, Texas. Due to his incomparable education, training, experience, and abilities as a power engineer, he filed Form I-140 to obtain immigrant status as an individual with an advanced degree and exceptional ability in the national interest of the United States. 1 Letters from leading engineers containing these statements were submitted with the National Interest Waiver application and have not been reproduced here; nevertheless, both parties to this suit have these letters in their possession. Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 2 of 30
  3. 3. 3 10. Defendant Jeh Johnson is the Secretary of the United States Department of Homeland Security (hereafter “DHS”) and is sued in his official capacity only. He is charged with the administration of the United States Citizenship and Immigration Services (hereafter “CIS”) and implementing the Immigration and Nationality Act (hereafter “INA”). 8 C.F.R. § 2.1. 11. Defendant León Rodríguez is the Director of CIS and is sued in his official capacity only. CIS is the component of DHS that is responsible for adjudicating Plaintiff’s I-140 petition. 12. Defendant David Roark is the Director of the Texas Service Center and is sued in his official capacity only. The Texas Service Center is charged with the administration of the INA and the adjudication of I-140 petitions. Plaintiff’s I-140 petition has been pending at the Texas Service Center since October 11, 2013. 13. Defendant DHS is the department within which the CIS adjudicates immigrant based petitions. DHS operates within this district, with headquarters in Washington, D.C. 14. Defendant CIS is the component of DHS that adjudicates I-140 petitions. CIS operates within this district, with headquarters in Washington, D.C. JURISDICTION AND VENUE 15. Jurisdiction of the Court is predicated upon 28 U.S.C. §§ 1331 in that the matter in controversy arises under the Constitution and laws of the United States. This Court also has jurisdiction over the present action pursuant to 5 U.S.C. § 702, the Administrative Procedures Act; and 28 U.S.C. § 1361, regarding an action to compel an officer of the United States to perform his or her duty. 16. Venue is proper in this District under 28 U.S.C. § 1391(e) because a substantial part of the events and omissions giving rise to the claim occurred in this District, and because Defendants operate within this District. FACTS AND BACKGROUND 17. On October 9, 2013, Plaintiff, through counsel, filed Form I-140, Immigrant Petition for Alien Worker requesting a National Interest Waiver under 8 U.S.C. § 203(b)(2)(B)(i), with the Texas Service Center of CIS. 18. On October 11, 2013, CIS received Plaintiff’s Form I-140. 19. On October 14, 2013, CIS sent Plaintiff a receipt notice for his Form I-140 filing with receipt number SRC1400950371. 20. To this date, CIS has never approved or denied Plaintiff’s properly filed I-140 petition. This petition has been pending for nearly 2 years. 21. In the meantime, Plaintiff has successfully filed other non-immigrant applications with CIS, including a nearly three-year extension of his H-1B status to recapture time Felizzola spent Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 3 of 30
  4. 4. 4 1. working abroad as a contractor for Exxon Mobil in South Korea, Russia, and Qatar. CIS has granted Plaintiff approval, without issue, for these applications. 2. Plaintiff has also diligently tracked the status of his Form I-140 adjudication by requesting numerous inquiries to CIS regarding adjudication of the Form. See Exhibit A, Log and Responses to CIS Status Inquiries. 3. For each request, Plaintiff received a generic response from CIS, only acknowledging that his application is under extended review. Id. Plaintiff did not receive any further explanation for the delays. Some of Plaintiff’s status requests never received a response. 4. CIS processing times for Form I-140, Petition for Alien Worker, based on a national interest waiver, indicates that all cases filed before December 2, 2014 have been adjudicated and a determination rendered. Plaintiff’s application has been pending with CIS since October 11th, 2013. A nearly two-year delay in the adjudication of Plaintiff’s form is an unreasonable delay. 5. CIS has a nondiscretionary duty to adjudicate all immigration applications, and in reasonable time. CIS has failed to adjudicate Plaintiff’s I-140 application in a reasonable time. 6. Subsequently filed petition approvals, including a 3-year H-1B extension to recapture time spent abroad, show that Plaintiff is not suspect nor deemed a security threat by CIS, but rather meets or exceeds all the criteria to have his I-140 petition approved. Therefore, with little to no explanation for the extended review of his I-140 application, CIS has acted in bad faith by not rendering a decision in reasonable time. 7. Moreover, Plaintiff and his employer have suffered significant real damages as a result of the delay. Plaintiff travels across the globe to provide his expertise on numerous power development projects. During the course of one such recent trip, Plaintiff was required to renew his H-1B visa at the U.S. consulate in Milan before he could return to seek entry into the U.S. He was subjected to a nearly three-week delay when his H-1B visa was held in extended administrative processing. Such delays cost his employer and contractor thousands of dollars. If his national interest waiver had been adjudicated timely, he would likely be able to seek permanent residency in the U.S. and would no longer be subject to such burdens. 8. Plaintiff has a clear right to the relief requested. The INA and its regulations impose a duty to issue a decision in reasonable time. 9. Plaintiff has exhausted all administrative remedies and there are no further administrative acts Plaintiff can take to obtain the benefits to which he is entitled. 10. Plaintiff is not seeking that the Court compel the agency to render a specific decision, Rather, because the Immigration and Nationality Act imposes a nondiscretionary duty to adjudicate immigration applications, we respectfully request the Court to compel Defendants to do exactly what the law orders them to do: 1) adjudicate Plaintiff’s I-140 petition, and 2) adjudicate Plaintiff’s I-140 petition in a reasonable time. DEFENDANTS HAVE FAILED TO CARRY OUT THEIR NON-DISCRETIONARY, STATUTORY DUTY TO PLAINTIFF Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 4 of 30
  5. 5. 5 31. The duty to make a decision on all applications is implicit in the regulations. See, e.g., 8 C.F.R. § 103.2(b)(19); 8 C.F.R. § 245.2(a)(5). Additionally, the instructions from CIS inform an applicant that he or she will be notified in writing of a decision on the application. The instructions are incorporated into the regulations, with the same effect. See, e.g., 8 C.F.R. § 103.2(a)(1). This non-discretionary, ministerial duty of notifying an applicant of a decision cannot be carried out unless the application is decided. Thus, the duty to make a decision and notify the applicant carries with it a duty to adjudicate the application. 32. Furthermore, CIS’ imposition of a mandatory adjudication fee creates a duty to actually decide the application. Congress intended that CIS would charge a fee to cover the cost of adjudicating benefit applications such as those for adjustment. See 8 U.S.C. §1356(m). Specifically, CIS is authorized by 8 U.S.C. §1356(m) to set “fees for providing adjudication and naturalization services…at a level that will ensure recovery of the full costs of providing all such services.” Id. (emphasis added). The regulations mandate that a non-refundable adjudication fee be paid in advance. See 8 C.F.R. §§ 103.2(a)(1) and (a)(7). As such, because Plaintiff has already paid the fees associated with Form I-140, CIS’ failure to provide adjudication of this form runs afoul of the very purpose for which Congress imposed the statutory provision for the disposition of moneys collected, as the sole purpose of collecting these fees is to “provide all such services.” 33. The remaining regulatory structure demonstrates that CIS has a duty to adjudicate the application, as it is clear that the regulations presume that a decision must be made on all applications. EXHAUSTION OF REMEDIES 34. Plaintiff has exhausted all administrative remedies and acts and there are no further administrative acts Plaintiff can take to obtain the benefits to which he is entitled. There is no other adequate remedy available other than to compel Defendants to render a determination on Plaintiff’s Form I-140. Plaintiff has repeatedly attempted to ascertain the status of his I-140 petition and to compel Defendants to make a decision on that application. See Exhibit A. Despite these efforts, it has become apparent that no remedy is forthcoming due to the agency’s disregard for reasonable adjudication of applications under the Immigration and Nationality Act. FIRST CAUSE OF ACTION: MANDAMUS PURSUANT TO 28 U.S.C. § 1361 35. Plaintiff re-alleges and incorporate by reference, as if fully set forth herein, the allegations in paragraphs 1-34 above. 36. The Mandamus Act, codified at 28 U.S.C. § 1361, says, in its entirety: 1361. Action to compel an officer of the United States to perform his duty. The district courts shall have original jurisdiction of any action in the nature of mandamus to compel an officer or employee of the Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 5 of 30
  6. 6. 6 United States or any agency thereof to perform a duty owed to the plaintiff. 37. A mandamus plaintiff must demonstrate that: (1) he or she has a clear right to the relief requested; (2) the defendant has a clear duty to perform the act in question; and (3) no other adequate remedy is available. Newsome v. E.E.O.C., 301 F.3d 227, 231 (5th Cir. 2002). 38. For a mandamus plaintiff to have standing under the Mandamus Act, he must satisfy not only the constitutional requirements of injury, causation, and redressability, but must also establish that such duty is owed to him. Giddings v. Chandler, 979 F.2d 1104, 1108 (5th Cir. 1992). Any duty owed to the plaintiff must arise from another statute—or from the United States Constitution. Id. When the right alleged stems from a statute, a duty is owed to the plaintiff for the purpose of the Mandamus Act if, but only if, the plaintiff falls within the “zone of interest” of the underlying statute. Id. The “zone of interest” test requires that the interests sought to be protected by the complainant be “within the zone of interests to be protected or regulated by the statute or constitutional guarantee in question.” Id. at 1108-09. Only then may the Court compel the government to take action under the Mandamus Act. 39. First, Plaintiff has a clear right to have CIS adjudicate his Form I-140. His right stems from 8 U.S.C. § 1153(b)(2)(A) and (B). He falls within the “zone of interest” of this statute. Compare Razik v. Perryman, No. 02-5189, 2003 U.S. Dist. LEXIS 13818, *6-07 (N.D. Ill. Aug. 6, 2003) (courts have consistently held that 8 U.S.C. § 1255 provides a right to have an application for an adjustment of status adjudicated). Similarly, Plaintiff has met or exceeded all the necessary requirements to obtain a decision on his immigrant visa petition. Moreover, he has paid the required, non-refundable CIS filing fee to facilitate CIS in adjudication of his petition. 40. Second, Defendants owe Plaintiff the duty to process his Form I-140 and to provide him with an answer as to whether he may apply for an immigrant visa, in reasonable time. Courts have held that mandamus actions can be used to compel the government to exercise its discretion in a case where the government has failed to take any action. See Iddir v. INS, 301 F.3d 492, 500 (7th Cir. 2002) (duty to adjudicate applications under the diversity lottery program). A two- year delay is an unreasonable amount of time to await an adjudication. See Alkenani v. Barrows , 356 F. Supp. 2d 652, 657, n.6 (N.D. Tex. 2005) (finding 15-month delay was not unreasonable, but noting that decisions from other jurisdictions suggest that delays approximating two years may be unreasonable). 41. Third, no other adequate remedy is available to Plaintiff. 42. Therefore, because the Plaintiff possess a clear right sufficient to bring him within INA 203(b)(2)(B)’s zone of interest, he has standing to invoke the Mandamus Act to compel the government Defendants to discharge the statutory duties owed to Plaintiff. SECOND CAUSE OF ACTION: VIOLATION OF ADMINISTRATIVE PROCEDURE ACT, 5 U.S.C. §§ 555, 706, et seq. Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 6 of 30
  7. 7. 7 43. Plaintiff re-alleges and incorporates by reference, as if fully set forth herein, the allegations in paragraphs 1-42 above. 44. The Administrative Procedure Act (“APA”), codified at 5 U.S.C. § 706 states, in pertinent part: The reviewing court shall-- (1) compel agency action unlawfully withheld or unreasonably delayed; and (2) hold unlawful and set aside agency action, findings, and conclusions found to be-- (A) arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law; (B) contrary to constitutional right, power, privilege, or immunity; (C) in excess of statutory jurisdiction, authority, or limitations, or short of statutory right; (D) without observance of procedure required by law; (E) unsupported by substantial evidence in a case subject to sections 556 and 557 of this title or otherwise reviewed on the record of an agency hearing provided by statute; or (F) unwarranted by the facts to the extent that the facts are subject to trial de novo by the reviewing court. (emphasis added). 45. Additionally, the APA at 5 U.S.C. § 555 states, “With due regard for the convenience and necessity of the parties or their representatives and within a reasonable time, each agency shall proceed to conclude a matter presented to it.” § 555(b) (emphasis added). See, e.g., Pedrozo v. Clinton, 610 F. Supp. 2d 730, 738 (S.D. Tex. 2009) (holding that an eleven-month delay of a non-immigrant visa was not unreasonable only as a result of CIS’ prior intent to revoke and petitioner’s contributed delays). Additionally, “although there appears to be no statutory or regulatory deadlines by which an [I-140] petition for [immigrant] status must be processed, at some point failure to take action runs afoul of the APA.” Id. 46. “Prompt notice shall be given of the denial in whole or in part of a written application, petition, or other request of an interested person made in connection with any agency proceeding.” § 555(e) (emphasis added). 47. Courts have consistently held that policies or practices of federal agencies—including INS (now CIS)—which fail to follow statutory or regulatory requirements violate the APA. See, e.g., Nader v. F.C.C., 520 F.2d 182, 206 (1st Cir. 1975) (holding that administrative agencies have a duty to decide issues presented to them within a reasonable time, and reviewing courts have a duty to compel agency action unlawfully withheld or unreasonably delayed); Silverman v. N.L.R.B., 543 F.2d 428, 429-30 (2d Cir. 1976) (holding that inaction by Labor Board for five years after judgment violated mandate of APA providing for prompt disposition of agency proceedings); In re American Rivers and Idaho Rivers United, 372 F.3d 413, 420 (D.C. Cir. 2004) (six-year delay by Federal Energy Regulatory Commission in answering environmental group's petition was plainly unreasonable and warranted mandamus relief for prompt answer). Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 7 of 30
  8. 8. 8 48. As such, Plaintiff has four viable claims under the APA. 49. First, pursuant to § 706(2)(A), Defendants have acted in a way that is “arbitrary, capricious…or otherwise not in accordance with law” when they disregarded 8 U.S.C. § 1153(b)(2)(B) by causing Plaintiff to wait nearly 2 years for a determination on Form I-140. Thus, judicial review is warranted under § 706(1) to “compel agency action unlawfully withheld or unreasonably delayed.” 50. Second, pursuant to § 706(2)(C), Defendants’ failure to adjudicate Plaintiff’s Form I-140 was “short of [Plaintiff’s] statutory right” to have his Form I-140 adjudicated, as determined by INA 203(b)(2)(B). Thus, judicial review is warranted under § 706(1) to “compel agency action unlawfully withheld or unreasonably delayed.” 51. Third, pursuant to § 706(2)(D), Defendants failed to observe the clear non-discretionary “procedure required by law” that specifically set out a time frame for adjudicating I-140 petitions, i.e. in reasonable time. Thus, judicial review is warranted under § 706(1) to “compel agency action unlawfully withheld or unreasonably delayed.” 52. Finally, pursuant to § 555(b) and (e), Defendants failed to conclude the matter of Form I-140 presented to it nearly 2 years ago within a “reasonable time,” and they have failed to provide “prompt notice” of such determination to Plaintiff. Plaintiff provided a timely application and has exercised the utmost diligence in pursuing the processing of his application. In turn, CIS has provided Plaintiff inaction and little to no explanation for the ongoing delay in adjudication, thus causing undue inconvenience to Plaintiff. 53. As a result of Defendants’ practices, policies, conduct, and failures to act which have directly violated 5 U.S.C. §§ 555 and 706, Plaintiff has been unduly prejudiced. PRAYER FOR RELIEF 54. Plaintiff requests the Court to grant the following relief: A. Accept and retain jurisdiction during the adjudication of the I-140 petition in order to ensure compliance with the Court’s orders; B. Issue a writ in the nature of mandamus, pursuant to 8 U.S.C. § 1153(b)(2)(B) compelling defendants to perform non-discretionary adjudication of Plaintiff’s I-140 petition and perform adjudication of the petition in a reasonable time; C. Order Defendants to undertake the actions dictated in Paragraph B above on or before 60 days from the filing of this complaint, or within a reasonable period of time determined by this Court; D. Award reasonable costs and attorneys’ fees under the Equal Access to Justice Act, 5 U.S.C. § 504 and 28 U.S.C. § 2412; and E. Grant such other relief as the Court may deem just and proper. Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 8 of 30
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  10. 10. 10 MANDAMUS PETITION--INDEX OF EXHIBITS _____Document EXHIBIT Log of and Responses to CIS Status Inquiries A Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 10 of 30
  11. 11. 1 Exhibit A Case 4:15-cv-02705 Document 1 Filed in TXSD on 09/16/15 Page 11 of 30
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