NEW!Redacted Memorandum in Support of Plaintiff's Motion for Temporary Custody. This Memorandum outlines the authority of the New Jersey Court to retain jurisdiction past the age of 18, discusses the definitions of abuse, neglect and abandonment under New Jersey law, analyzes the best interest standard the New Jersey Court employs and finally applies this standard to the factual findings required to apply for special immigrant juvenile status. February 1, 2007.
NEW! Redacted Supplemental Brief in Support of Motion to Petition for Custody. This Supplemental Brief explains to the court that when a child has been released from the custody of the federal government, consent need not be obtained. Essex County. 2006.
NEW! Redacted Letters to the court instructing that consent need not be obtained for a child released from the custody of the federal government. Essex County. 2007.