Got Export Controlled Technology? Do not overlook Compliance with the Deemed Export Rule

The “deemed export” rule under the Export Administration Regulations (EAR) presents unique compliance challenges for universities, R&D centers, and any number of companies and organizations involved in high-tech fields.

In short, under the EAR, the release of export controlled technology to a foreign national is deemed to be an export to the country of which the foreign national is a citizen. A “release” includes giving a foreign national access to the controlled technology. The deemed export rule applies to foreign national employees who may be authorized to work in the U.S. under an H1-B, O, L-1 or other visa, as well as foreign national visitors, those employed by business partners, graduate assistants and other researchers and student interns. The deemed export rule does not apply, however, to foreign nationals who have become naturalized U.S. citizens; those who are legal permanent residents of the U.S. (have “green cards”). The rule applies equally to organizations with overseas operations, such as subsidiaries, JVs, affiliates, and other partners.

The sharing of or giving access to controlled technology, blue prints, formulations and the like with a foreign national during a meeting in a conference room, in an email or text message, in a Skype or phone call, are all considered to be a release under the deemed export rule. Therefore, just as an exporter of a commodity must determine whether its export controlled item is subject to licensing requirements or if it chooses to rely on an applicable export license exception, organizations that have controlled technology must similarly analyze whether a release of that technology, in whatever format and via whatever media, must also carefully analyze whether a deemed export license may be required before the release to the foreign national colleague can occur.

This week, a civil penalty settlement announcement made by the U.S. Department of Commerce, Bureau of Industry and Security (BIS), Office of Export Enforcement (OEE) gave organizations with controlled technology another reminder (perhaps a jolt for some) that violations of the deemed export rule are detectable and costly. In a press release, BIS announced that it reached a $115,000 civil settlement with a Santa Clara, California company resulting from five violations of the EAR’s deemed export rule.

The company’s violations included the unauthorized release of export controlled manufacturing technology to a Russian national engineer working at its U.S. headquarters. This occurred in 2007. The unauthorized release involved drawings and blueprints for parts, identification numbers for parts, and development and production technology. The information is used for a product in hard disk drive manufacturing. The controlled technology was stored on a server at the company’s headquarters. (Best Practice Tip: store controlled technology on U.S. servers only, not abroad and not in the cloud). The company “released” the controlled technology to its Russian national engineer by providing the employee with a login ID and password “that enabled him to view, print, and create attachments.” After that occurred, the company applied for a deemed export license from BIS, but continued to store controlled technology on its server and failed to take steps to deny access of the technology to its Russian national while the license application was pending.  This resulted in charges of knowingly violating the EAR on three occasions. Apparently, those applying for the license failed to inform the IT department to disable the engineer’s login or otherwise deny access to the controlled technology. In 2010, a similar release violation occurred when a Chinese national working in the company’s Shenzhen, China subsidiary accessed similar controlled technology on the company’s server in California using a login ID and password to open an attachment containing the technology.

The company voluntarily disclosed its violations to BIS. But it should be recalled that for many visa categories used to employee foreign nationals in the U.S. Part 6 of the I-129 requires the applicant to certify compliance with the EAR (and ITAR), including obtaining an export license when necessary and not releasing or giving access to the controlled technology to the foreign national employee. In other words, BIS and U.S. Citizenship and Immigration Services (USCIS) have information available to help detect and penalize deemed export violations in addition to information provided to BIS through a voluntary self-disclosure (VSD).

In announcing the penalty, BIS stated that the company’s failure to prevent access while the deemed export license was pending was considered to be an aggravating factor in determining the penalty. There can be no doubt that BIS is serious about protecting U.S. technology that is subject to export controls, enforcing the deemed export rule, and penalizing violators. “Deemed export compliance is a top priority for the Bureau of Industry and Security,” said David W. Mills, Assistant Secretary of Commerce for Export Enforcement. “Today’s settlement highlights the need for companies to be vigilant to prevent the unauthorized release of U.S. technology and data.”

The BIS case documents can be accessed here,http://1.usa.gov/1jCWCEk.

For assistance with understanding and complying with the deemed export rule, sections of the Export Administration Regulations (EAR) or other export controls and economic sanctions, as well as representation before BIS in investigations, civil penalty, and voluntary self-disclosure matters, please contact Jon P. Yormick, Esq., jon@yormicklaw.com or by calling +1.866.967.6425 (Toll free in Canada & U.S.) or +1.216.928.3474.

Mexican Trucks on U.S. Highways

On July 6, 2011, the U.S. Secretary of Transportation and the Secretary of Transportation of Mexico signed agreements resolving disputes over long-haul cross-border trucking services between the United States and Mexico, as provided for in the NAFTA treaty. The disputes related to implementation of the provisions in the NAFTA calling for access to U.S. highways by Mexican trucks. As a result of delays by the U.S., Mexico imposed over USD 2 billion in retaliatory tariffs on U.S. manufacturers.

On the U.S. side, the delays were caused principally by the Teamsters and the Owner-Operators Independent Driver’s Association (OOIDA). They objected to allowing Mexican trucks on U.S. highways, claiming that Mexican trucks and drivers were not safe. They did what they could to stonewall any possible settlement. However, as the costs of the tariffs continued to mount, FMCSA became more aggressive in working toward a resolution with Mexico that spoke to the safety objections raised by the Teamsters and by OOIDA.

As part of a final settlement with Mexico, each Mexican carrier that will operate in the U.S. will have to apply for rights from FMCSA. Mexican trucks will be required to meet all U.S. motor vehicle safety standards and to have electronic on board recording devices (EOBR’s) to keep track of hours of service and other safety requirements. The EOBRs will be installed and maintained by the Federal Motor Carrier Safety Administration.

In addition, the drivers of Mexican trucks will be subjected to drug testing managed through Department of Health and Human Services facilities. HHS will review the driving record of each driver and require drivers to undergo an assessment of their ability to understand English and U.S. traffic signs. Therefore, FMCSA will be able to monitor compliance with FMCSA regulations.

Mexican trucks have been operating within the U.S. border commercial zones for many years. Under the new regime, Mexican trucks will also be able to handle international traffic on U.S. highways.

Notwithstanding the safety requirements imposed on the Mexican carriers and Mexican drivers under the settlement agreement, the Teamsters and OOIDA continue to object to any implementation of the Mexican truck program in the NAFTA treaty. It may be that their real concern is that they will now have to compete with the Mexican trucks for the international traffic. Either way, the Obama Administration has determined that the tariffs imposed by Mexico had created an unreasonable and unnecessary burden on the U.S. economy and had to end.

Mexican carriers having questions and needing assistance with meeting U.S. regulatory requirements and accessing the U.S. market are encouraged to contact transportation/logistics lawyer Robert M. Spira, rspira@yormicklaw.com.

USCIS Certification on Release of Controlled Technology or Technical Data

The U.S. Citizenship and Immigration Service’s requirement for “Certification Regarding the Release of Controlled Technology or Technical Data to Foreign Persons in the United States” will go into effect on February 20, 2011.

The certification applies to employers submitting petitions under the visa categories H-1B (specialty occupation), H-1B1 (specialty occupation professionals from Singapore or Chile), L-1 (intra-company transferees) or O-1A (extraordinary ability). The requirement will impact universities, as well as aerospace, defense, high-tech, and advanced manufacturing businesses and organizations, regardless of size.

The certification requirement was to go into effect on December 23, 2010, but has been delayed for 2 months. The so-called “Part 6” certification is found on Form I-129 (Petition for a Nonimmigrant Worker) and is aimed at enforcing the “deemed export” rule. A “deemed export” refers to the release of technology or technical data that is subject to either the U.S. Department of Commerce Export Administration Regulations (EAR) or the U.S. Department of State International Traffic in Arms Regulations (ITAR). The release of such information to a foreign national inside the U.S. is considered to be a “deemed export” to the foreign national’s country of residence or, in some instances, to that person’s country of birth. A “deemed export” may be subject to an export license requirement. Making a “deemed export” without a required license is a violation of the EAR or the ITAR and is subject to administrative, civil, and even criminal penalties.

A “deemed export” can occur in many forms, including visual inspection (such as providing technical specifications, schematics, blueprints, etc.), a verbal exchange of the technology or technical data, or when the information is made available through business practices. Business meetings, conference calls, videoconferences, PowerPoint presentations, trade shows, and email exchanges all present instances in which a “deemed export” could occur.

As of February 20, employers submitting an I-129 petition under one of the covered visa categories will have to certify that: 1) it has reviewed the EAR and the ITAR; and either a) it has determined that an export license is not required for the release of technology or technical data to the beneficiary; or b) if an export license is required, that the beneficiary will not have access to the information until the employer obtains the required license.

Employers should plan now for the additional time needed to assess whether foreign national employees will have access to technology or technical data controlled under the EAR or the ITAR, determine whether an export license is required and, if so, submit a license application. In addition, employers should fully document the decision-making process so that it can be relied upon should questions arise. Failing to take these necessary steps and properly certify the I-129 petition will likely lead to entity-level administrative and civil penalties, as well as the possibility of entity-level and individual criminal penalties being imposed. If an employer becomes concerned that a violation may have already occurred, it should seek assistance to determine whether a voluntary self-disclosure (VSD) to all involved agencies should be made.

Key Supreme Court Adopts “Nerve Center” Test for Corporate Citizenship

U.S. and foreign companies with U.S. subsidiaries with multiple locations should now have a better understanding of their corporate citizenship when U.S. litigation arises.

Last month, the U.S. Supreme Court unanimously adopted the “nerve center” test to determine where a company’s principal place of business is for purposes of determining its citizenship. Companies with operations in multiple states will benefit from this decision.

The federal court diversity jurisdiction statute, 28 U.S.C. § 1332, creates the possibility for corporate citizenship in two (2) different states – where the company is incorporated and where it has its principal place of business. Since federal court jurisdiction often relies on diversity of citizenship between the parties, when a corporation is found to be a citizen of the same state as the plaintiff(s) the corporation may need to defend an action in a potentially less favorable state court forum because there is no diversity of the parties.

The case decided by the Supreme Court, Hertz v. Friend, was an action filed in a California state court that was removed to federal court. The lower federal courts found that Hertz, the rental car company, was a citizen of California because it had significant operations in the state, many employees there, and generated significant revenue there. The citizenship determination was made by the lower courts despite Hertz being incorporated in Delaware and having its headquarters in New Jersey. The result was that Hertz could not successfully remove the lawsuit to the federal court as it desired because there was a lack of diversity with the plaintiffs, who were also California citizens.

The Supreme Court has now simplified the test for determining corporate citizenship. The “nerve center” approach provides these companies with more predictability and the potential to remove cases to federal courts in jurisdictions like California that used a different test for citizenship. Under the “nerve center” test, a corporation’s principal place of business is now the place where its “high level officers direct, control and coordinate the corporation’s activities.”

The “nerve center” approach will replace a myriad of approaches that had been taken by federal courts throughout the U.S. For instance, the Sixth Circuit Court of Appeals’s “total activites” test will no longer be applied. That approach was used by a number of other federal courts of appeals and required a case-by-case analysis to determine corporate citizenship, taking into account factors such as the company’s character, its purposes, the kind of business involved, and the locations of its operations. Other courts of appeals used a variation on this test. Only the Seventh Circuit Court of Appeals used the more predictable “nerve center” test now to be used across the U.S.

With the Hertz decision comes the potential for companies to remove cases to federal courts when they could not do so previously. Companies are reminded that, in general, removal of a lawsuit filed in a state court must be removed within 30 days of learning of the action.

 

Preparing Now for FY 2009 H-1B Visa Applications

The Business and Global Immigration practice of Yormick & Associates is dedicated to serving the needs of our clients effectively and in a cost-efficient manner. We want to remind our clients and Friends of the Firm that the U.S. Citizenship and Immigration Service (USCIS) will begin accepting H-1B applications for FY 2009 on April 1, 2008.

While there is continuing talk and some proposed legislation regarding an increase in the number of available visas, we urge employers and qualifying employees to initiate the filing process now to ensure completed applications can be submitted to the USCIS by April 1, 2008. Since 2003, Congress has established an annual H-1B visa cap of 65,000. The documentation required for an H-1B application can be extensive – particularly for employers and employees for whom we have not provided assistance previously – and may take some time to obtain and, in many instances, translate.

Organizations intending to file an H-1B petition for an employee or prospective employee, should note that for FY 2008 USCIS reached its filing cap in just two days. Any petition filed after the cap was reached, and not falling in one of the few available exemptions, was rejected with instructions to re-file in the next fiscal year. For many employers, this meant losing valued employees or candidates for a year or permanently as workers were forced to return to their home countries.

Many of our H-1B clients have submitted or will soon submit the necessary documents and payments to our firm. To ensure the visa application filed on behalf of your employee is accepted, we want to stress the importance of thorough and timely preparation and filing of H-1B applications.

USCIS continues to accept and process certain quota-exempt H-1B petitions for employment at qualifying institutions of higher education or related or affiliated nonprofit entities; at nonprofit research organizations or governmental research organizations; for certain former J-1 physicians; for employees already counted against the quota during the past six years; and for quota-exempt H’s seeking concurrent quota-subject employment.

Disclosure: This Immigration Law Alert is provided for informational purposes only and is not intended to serve as or provide specific legal advice regarding a particular matter. Should you have specific questions regarding an immigration matter, please contact Jon P. Yormick, Managing Attorney, or Andrew J. Behnke, Immigration Specialist., Yormick & Associates, Co., L.P.A., T: +1.216.928.3474, F: +1.216.566.0857, e-mail: jon@yormicklaw.com or abehnke@yormicklaw.com.

 

Preparing Now for FY 2008 H-1B Visa Applications

Yormick & Associates is dedicated to serving the needs of our Business Immigration clients effectively and in a cost-efficient manner.  We want to remind our Clients and Friends of the Firm that the U.S. Citizenship and Immigration Service (USCIS) will begin accepting H-1B applications for FY 2008 on April 1, 2007.

While there is much talk and some pending legislation regarding increasing the number of available visas, we urge employers and qualifying employees to initiate the filing process now in order that completed application can be submitted to the USCIS by April 1, 2007.  Since 2003, Congress has established an annual H-1B cap of 65,000.  The documentation required for an H-1B application is substantial and may take some time to obtain.

If your organization plans to file an H-1B petition for an employee or prospective employee, please note that for FY 2007, USCIS began accepting applications for H-1B workers on April 3, 2006 and the cap was reached on May 26, 2006.  Any cases filed with USCIS after the cap was reached were returned with instructions to re-file after April 1, 2007.

Many of our H-1B clients have submitted the necessary documents and payments to our Firm and we are already preparing those applications.  To ensure the visa application filed on behalf of your employee is accepted, we want to stress the importance of thorough and timely preparation and filing of H-1B applications.

Please note, USCIS continues to accept and process quota-exempt H-1B petitions, for employment at institutions of higher education or related or affiliated nonprofit entities; at nonprofit research organizations or governmental research organizations; for certain former J-1 physicians; for employees already counted against the quota during the past six years; and for quota exempt H’s seeking concurrent quota-subject employment.

Disclosure: This Immigration Law Alert is provided for informational purposes only and is not intended to serve as or provide specific legal advice regarding a particular matter. Should you have specific questions regarding an immigration matter, please contact Jon P. Yormick, Managing Attorney, or Jennifer Cooper, Immigration Specialist., Yormick & Associates, Co., L.P.A., T: +1.216.928.3474, F: +1.216.566.0857, e-mail: jon@yormicklaw.com or jcooper@yormicklaw.com.

 

Lawsuit Strategy is Used to Break FBI Investigation Backlog

This month 10 Asian and Middle Eastern legal permanent residents filed a lawsuit against the government seeking citizenship.  The plaintiffs include a U.S. military veteran, a physician, and business owners whose applications have not been acted upon for two years or more.

The case also seeks class action status for individuals waiting at least 6 months for the U.S. Citizenship and Immigration Services’s Los Angeles District Office to adjudicate their naturalization petitions.  Federal law requires that legal residents who have satisfied all requirements must have their cases adjudicated within 120 days of their naturalization examinations.

Not surprisingly, the lawsuit alleges the FBI “name check” investigation is the cause for the delay in obtaining decisions.  Neither the USCIS nor the FBI has a deadline for completing the investigation.

Applicants for “green cards” can use this same litigation strategy to obtain approval of their I-485 applications.  Recently, our Firm has successfully obtained approvals for clients working at a leading Cleveland research hospital system whose cases were delayed for 3 years because of the FBI “name check” delay.  This month we are filing similar cases for professionals in other states and look forward to obtaining equally successful and expedited approvals.

Disclosure: This Immigration Law Alert is provided for informational purposes only and is not intended to serve as or provide specific legal advice regarding a particular matter. Should you have specific questions regarding an immigration matter, please contact Jon P. Yormick, Managing Attorney, or Jennifer Cooper, Immigration Specialist., Yormick & Associates, Co., L.P.A., T: +1.216.928.3474, F: +1.216.566.0857, e-mail: jon@yormicklaw.com or jcooper@yormicklaw.com.

E-3 SPECIALTY OCCUPATION WORKER VISA FOR AUSTRALIANS

The E-3 visa classification was established by the REAL ID Act of 2005.  It allows for the admission of Australian nationals entering the U.S. to perform work in the “specialty occupation” category.  Nonimmigrant Australian aliens who are already legally in the U.S. may change and extend their status in this category.

Guidelines recently issued by the United States Citizenship and Immigration Services (“USCIS”) specify the requirements and documentation needed for those interested in either changing their nonimmigrant status to E-3 or extending their E-3 status.

The qualifications for E-3 classification include: the alien is an Australian national who is seeking employment in a specialty occupation and the alien possesses a bachelor’s degree or higher (or its equivalent), as well as the appropriate degree (or its equivalent) in the field in which the alien wishes to work.  E-3 status is initially granted for a period of up to two (2) years and extensions are permitted in two (2) year increments that are indefinite.  One of the advantages of E-3 status is that it allows for the dependent spouse of the E-3 worker to receive work authorization.

The yearly cap for those in E-3 status is 10,500.  This cap applies to “new workers,”  defined as “those who are coming from abroad, [and] are admitted initially in E-3 classification or those who change their nonimmigrant status to [the] E-3 classification or change employers while in E-3 status” (USCIS January 6, 2006 Press Release).

Standard procedure for those in the U.S. and seeking E-3 status will be to request a change of status or extension of status through filing a Form I-129 (Petition for a Nonimmigrant Worker).  Currently, the cost for filing this petition is USD 190.00, but this fee is subject to change at any time.  Additional documents are required when filing the Form I-129.  These include:

    • Proof of Australian nationality;
    • A support letter from the prospective U.S. employer;
    • Evidence that the alien meets the educational requirements for the position;
    • Evidence that the alien meets any licensing or other occupational requirements; and
  • Evidence that a labor condition application (LCA) specifically designated for E-3 Specialty Occupations has been filed with the Department of Labor.

It should also be noted that an Australian alien seeking to be admitted in E-3 nonimmigrant classification at a U.S. Port-of-Entry must possess a valid E-3 visa issued by the U.S. Department of State.

Disclosure: This Immigration Law Alert is provided for informational purposes only and is not intended to serve as or provide specific legal advice regarding a particular matter. Should you have specific questions regarding an immigration matter, please contact Senior Attorney or Susan L. Riddle, Esq., or Associate Cathy C. Prusinski, Esq., Yormick & Associates, Co., L.P.A., T: +1.216.928.3474, F: +1.216.566.0857, e-mail: sriddle@yormicklaw.com or cprusinski@yormicklaw.com.

Preparing for FY 2007 H-1B Applications

Yormick & Associates is dedicated to serving the needs of our Business Immigration clients effectively and in a cost-efficient manner.  At this time, we would like to remind our Clients and Friends of the Firm that the U.S. Citizenship and Immigration Service (USCIS) will begin accepting H-1B applications for FY 2007 on April 1, 2006.

Since 2003, Congress has established an annual H-1B cap of 65,000.  The documentation required for an H-1B application is substantial and may take some time to obtain.  For example, all foreign documents (including academic credentials) must be submitted to USCIS with a certified English translation.

If your organization plans to file an H-1B petition for an employee or prospective employee, please note that for FY 2006, USCIS began accepting applications for H-1B workers on April 1, 2005 and the cap was reached in August 2005.  Any cases filed with USCIS after the cap was reached were returned with instructions to re-file after April 1, 2006.  Presuming similar filing patterns will occur, the FY 2007 cap can be expected to be reached in early to mid-summer 2006.

Many of our H-1B clients have submitted the necessary documents and payments to our Firm and we are already processing those applications.  To ensure the visa application filed on behalf of your employee is accepted, we would like to stress the importance of thorough and timely preparation and filing of H-1B applications.   If you have or will  hire an H-1B employee, we would be pleased for you to retain our services promptly.  A Legal Services Agreement will be forwarded upon request.  Once retained, we recommend that clients and beneficiaries forward to our office the following documents, as soon as possible:

    1. A copy of every page in the employee’s passport;
    1. A copy of his or her university degree;
    1. A copy of his or her professional license, if applicable;
    1. A copy of his or her current resume, including employment history;
    1. A copy of his or her current I-94 (if in the U.S.);
    1. A copy of all professional certificates;
    1. A copy of all U.S. immigration documents (including past I-20s and
      IAP 66s, if applicable);
  1. If his or her credentials were evaluated to the equivalent of a U.S.
    bachelors degree, a copy of the credentials evaluation.

Other documents may be necessary on a case-by-case basis.  To ensure proper and timely delivery, the above documents should be forwarded to our office via overnight courier.  Only early receipt of all required documents and filing fees will ensure that the H-1B application will be delivered from our office to USCIS on April 1, 2006.

If you have any questions regarding H-1B or other Business Immigration questions, please contact our office at +1.216.928.3474 and ask to speak with Senior Attorney Susan L. Riddle or Associate Cathy C. Prusinski or submit your question or request to info@yormicklaw.com.

Disclosure: This Immigration Alert is provided for informational purposes only and is not intended to serve as or provide legal advice relating to a particular matter. Should you have specific questions regarding an immigration matter, please contact Cathy C. Prusinski, Esq., Kim K. Alabasi, Esq., or Susan L. Riddle, Esq., Yormick & Associates, Co., L.P.A., T: +1.216.928.3474, F: +1.216.566.0857, e-mail: cprusinski@yormicklaw.com,  kalabasi@yormicklaw.com, or sriddle@yormicklaw.com.

 

International Travel Guidelines for Non-Immigrants

If you are a foreign national, non-immigrant planning international travel this holiday season, we recommend that you familiarize yourself with the immigration rules regarding your exit from and re-entry to the United States.  Please review this guidance on these immigration procedures before you finalize your travel arrangements.

WHICH DOCUMENTS MUST YOU TAKE WHEN YOU TRAVEL?
Before departing the U.S., all foreign nationals should ensure that they and their family members possess proper documents to apply for a visa overseas and to re-enter the U.S., including:

      1. Valid passport with an unexpired visa stamp that reflects your current nonimmigrant visa status
    1. Also, depending on your approval status the original, unexpired
      • Form I-797 Approval Notice (for work visas)
      • Valid I-20 (for student visas)
      • Valid form DS-2019 (for J visas)

If you do not have a valid visa in your passport, you will need to apply for one overseas before re-entry.

APPLYING FOR A VISA OVERSEAS
Before departing the U.S., you should contact the U.S. consulate or embassy overseas for specific information on application procedures and processing times.  See http://www.travel.state.gov/visa/questions_embassy.html for up-to-date consular contact information.  See http://www.travel.state.gov/visa/tempvisitors_wait.php for information on projected visa appointment and processing times.  Please note that you may also be subject to additional security and background checks that may increase the processing time for your visa.

EXIT PROCEDURES AT U.S. BORDERS
When departing the U.S, you may be required to undergo certain registration procedures depending upon your immigration status or security profile.  Foreign nationals may be required to go through the US-VISIT system if the system is in operation at your chosen exit port.  See http://www.dhs.gov/interweb/assetlibrary/USVisitPortsOfEntry.pdf for a list of the ports that have US-VISIT exit procedures.
If you have been entered as a special registrant in NSEERS, you must depart the United States only through a port that has been authorized for departure control, and report to a special departure control office, where your departure will be verified.  Seehttp://www.ice.gov/graphics/specialregistration/WalkawayMaterial.pdf for a list of authorized ports of entry and further departure control information.

RE-ENTERING THE UNITED STATES AFTER OVERSEAS TRAVEL
To be re-admitted to the U.S. you will need to present:

      1. Valid passport with unexpired visa stamp that reflects your current nonimmigrant visa status
    1. Also, depending on your approval status the original, unexpired
      • Form I-797 Approval Notice (for work visas)
      • Valid I-20 (for student visas)
      • Valid form DS-2019 (for J visas)

Any questions regarding these guidelines should be forwarded to Yormick & Associates Co., L.P.A.

Disclosure: This Immigration Alert is provided for informational purposes only and is not intended to serve as or provide legal advice relating to a particular matter. Should you have specific questions regarding an immigration matter, please contact Cathy C. Prusinski, Esq., Kim K. Alabasi, Esq., or Susan L. Riddle, Esq., Yormick & Associates, Co., L.P.A., T: +1.216.928.3474, F: +1.216.566.0857, e-mail: cprusinski@yormicklaw.com,  kalabasi@yormicklaw.com, or sriddle@yormicklaw.com.

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