Herard v. Holder
November 30, 2009
**Motion to reopen**
The agency did not abuse its discretion in denying Herard’s motion to reopen as untimely because the motion was filed more than five years after the final order of removal and Herard failed to demonstrate changed circumstances in Haiti to qualify for the regulatory exception to the time limits for filing motions to reopen.
http://www.ca9.uscourts.gov/datastore/memoranda/2009/11/30/08-73784.pdf
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