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Deliverable Description, Implementation, and TimeLine <br /> • ImmDef s approach to providing removal defense services is structured around fulfilling the <br /> requirements specified in Exhibit A,ensuring high-quality,culturally competent legal <br /> representation for individuals facing imminent deportation in Santa Ana. <br /> Deliverables: <br /> 1. Client Representation: ImmDef will provide comprehensive representation in removal, <br /> deportation,bond, and expedited removal proceedings as specified in Exhibit A.This includes <br /> conducting thorough client screenings to assess eligibility and providing on-the-spot <br /> representation when appropriate. Priority will be given to Santa Ana residents,with representation <br /> extended to individuals with a strong connection to the city if local residents are unavailable or <br /> decline representation. <br /> 2. Bond Hearings and Detained Representation: For detained individuals,ImmDef will provide <br /> representation in bond hearings,petitions for writ of habeas corpus,ICE detainer rescission <br /> requests,and parole requests when appropriate.This involves gathering evidence,presenting legal <br /> arguments,and challenging continued detention or conditions of detention. ImmDef staff, <br /> including experienced directing and staff attorneys,will provide comprehensive support to clients <br /> through on-site visits and virtual representation. <br /> 3. Asylum and Withholding Proceedings: ImmDef will offer representation in limited scope <br /> asylum-only and withholding-only proceedings before a federal immigration judge and assist with <br /> appeals to the Board of Immigration Appeals(BIA) and federal Court of Appeals as specified in <br /> Exhibit A when appropriate. This will involve preparing legal briefs, gathering supporting <br /> evidence,and presenting arguments in both immigration court and appellate settings. <br /> 4. Motions to Reopen and Reconsider: ImmDef will handle cases that require filing motions to <br /> reopen or reconsider directly with the immigration court. This involves gathering documentation <br /> to support reopening a case,developing a strong legal strategy,and coordinating with other legal <br /> staff to ensure comprehensive representation throughout the proceedings. <br /> 5. State Court Representation: ImmDef will provide representation in state court proceedings <br /> related to removal defense,such as Special Immigrant Juvenile Status and Post-Conviction Relief. <br /> This includes gathering necessary documentation,preparing declarations, and coordinating with <br /> relevant agencies to support our clients' cases in these forums. <br /> 6. Family Member Representation: ImmDef will provide representation for derivative family <br /> members in related immigration petitions or applications, ensuring that all relevant legal steps are <br /> taken to secure legal status for affected family members. <br /> 7. Rapid Response Representation: ImmDef will provide representation to individuals directly <br /> affected by new policies brought forth and actions taken by the Trump administration.This will <br /> involve immediate intervention if the community faces ICE raids at Santa Ana homes, schools or <br /> businesses,staying informed and aware of current trends and tactics adopted by DHS and <br /> ensuring our staff is trained to respond effectively. This plan involves assisting individuals who <br /> may be detained due to an ICE raid on a limited scope basis(such as bond hearings or stay of <br /> removal),without committing to full representation of their entire immigration case. This <br /> approach focuses on keeping individuals in the US so they can continue to fight their case. <br /> 16 <br />