Patel-Natvarlal v. Holder
November 30, 2009
**Motion to reconsider; due process, address change**
The agency did not abuse its discretion in denying Patel-Natvarlal’s motion to reconsider because the motion failed to identify any error of fact or law in the IJ’s prior decision denying his motion to reopen. In addition, Patel-Natvarlal’s contention that the delay in filing the Order to Show Cause violated due process fails for lack of prejudice because the record does not indicate that his address changed during the period of delay or that he attempted to update the government regarding an address change.
http://www.ca9.uscourts.gov/datastore/memoranda/2009/11/30/08-73837.pdf
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