Technical Comments for "EAD for I-140" rule

[avsnprasad]

Can you please explain what have you personally got to offer in a constructive way.Even if you have got something its that you have tried different ways and had the experience of the trial and error. I have never said that I am leaving nor am I sobbing.

IF THERE IS SOMETHING CONSTRUCTIVE THAT YOU ARE EXPECTING FROM ME THEN PLEASE LET ME KNOW. IF POSSIBLE I WOULD DO THAT. IN THE LAST FOUR MONTHS THAT I HAVE TRIED TO UNDERSTAND THE WAY THINGS WORK WITH IV AND THE FORUM HERE APART FROM POSTING COMMENTS ON THE I140-EAD THERE IS NOTHING CONSTRUCTIVE THAT HAS BEEN DONE. WE NEED LOT MORE MATURE PERSONS TO MANAGE IV AND TO PLAN THINGS IN A CONSTRUCTIVE WAY. PLEASE STOP YOUR IDIOTIC RANT AND IF YOU HAVE ANYTHING CONSTRUCTIVE THEN LET US KNOW......

[messengerofgod]

Originally Posted by avsnprasad

Can you please explain what have you personally got to offer in a constructive way.Even if you have got something its that you have tried different ways and had the experience of the trial and error. I have never said that I am leaving nor am I sobbing.

IF THERE IS SOMETHING CONSTRUCTIVE THAT YOU ARE EXPECTING FROM ME THEN PLEASE LET ME KNOW. IF POSSIBLE I WOULD DO THAT. IN THE LAST FOUR MONTHS THAT I HAVE TRIED TO UNDERSTAND THE WAY THINGS WORK WITH IV AND THE FORUM HERE APART FROM POSTING COMMENTS ON THE I140-EAD THERE IS NOTHING CONSTRUCTIVE THAT HAS BEEN DONE. WE NEED LOT MORE MATURE PERSONS TO MANAGE IV AND TO PLAN THINGS IN A CONSTRUCTIVE WAY. PLEASE STOP YOUR IDIOTIC RANT AND IF YOU HAVE ANYTHING CONSTRUCTIVE THEN LET US KNOW......

Yelling on forums does nothing for anyone.

If you want to help, go talk to your Congressman about our issues. You can (and should) use HR.213 as a vehicle for getting our concerns heard. That is the only thing we can do here. Some time ago, IV published a detailed guide on how to do this - I suggest you go through it and do your part instead of screaming on forums. http://immigrationvoice.org/media/HR...se_Edition.pdf

I don't think IV needs peoples help to push for the EO. Ultimately we need Congress to act and Congress will not act if we don't communicate our concerns to them.

[Eadfor I140]

USCIS hosts a teleconference on Friday, June 3, from 2 to 3 p.m. (Eastern) with USCIS Director León Rodríguez. Director


Is anyone joining call for Employment-Based Immigration Reform?

Did anyone notice that "Modernization of Employment-Based Immigration System" I-140 EAD Reform final rule making date is showing as 05 / 0 / 2016.

[messengerofgod]

one of the things that bugs me is how these fucking immigration lawyers who have rigged the system against us are blaming USCIS for this mess. Look at this tweet by Siskind

Unbelievable. If it isn't obvious to everyone now, let me restate it - as IV said the regulation was written in DHS General Council office - where the Chamber of Commerce Lobbyist got the job at the exact same time they were writing our regulation.

Blaming USCIS for this is like blaming the postman for bringing you a rejection letter. The fault lies with the person writing the regulation - not the messenger.

[thankstooptx]

Originally Posted by messengerofgod

one of the things that bugs me is how these fucking immigration lawyers who have rigged the system against us are blaming USCIS for this mess. Look at this tweet by Siskind

Unbelievable. If it isn't obvious to everyone now, let me restate it - as IV said the regulation was written in DHS General Council office - where the Chamber of Commerce Lobbyist got the job at the exact same time they were writing our regulation.

Blaming USCIS for this is like blaming the postman for bringing you a rejection letter. The fault lies with the person writing the regulation - not the messenger.

I came across this term yesterday called "Regulatory Capture", USCIS/DHS should be on this list for sabotaging the I140-EAD rule.

[messengerofgod]

USCIS and DHS are no angels, but in 2007 they let everyone file for Adjustment of Status. This tells me that they are just following the agenda set by political appointees - like Amy Nice.

The real villains are Amy Nice, Chamber of Commerce, AILA and people like Greg Siskind. DHS/USCIS are just convenient whipping boys.

Why is Greg blaming USCIS/DHS and conveniently ignoring his fellow immigration lawyer and friend Amy Nice - who WROTE THE REGULATION?

[stuckinline]

CIS Ombudsman report is out and they have made the exact same point you made in your "Technical comments" for I-140 EAD.

On Page 50 of CIS Ombudsman report, they cite the exact same case law that you mentioned in your comments - Patel v. USCIS, Kurapati v. USCIS and Mantena v. Johnson. They very well could have lifted this section of the report straight from your comments.

Not only that - but they make the exact same point that you made in your submission:

Originally Posted by CIS Ombudsman

AC21 included clear Congressional intent to provide certain qualified employees greater employment mobility while awaiting the completion of the permanent residence process. USCIS must reconsider its position on I-140 employee standing and make a corresponding regulatory change, fully aligning its policy to the letter and spirit of AC21.

Of all the regulatory submissions (even those from Lawyers and Lawyers Groups) - you were the only ones who could actually articulate the legal framework for I-140 EAD.

It is encouraging to see CIS Ombudsman making the very similar legal arguments as you made in your comments. It gives me confidence your legal arguments aren't just convincing, but they are correct!

[RandomizedPrecision]

What an incredible report! Hits on everything that IV has been talking about. If USCIS doesn't fix the rule, this is our legal standing to sue these ma'fuhkers

I don't see how they go about issuing a rule now without making the changes that we and this report are asking for. Gotta keep the pressure on them until this becomes a reality. Keep donating, advocating and whatever u can do.

Also, watch how many of these AILA assholes, FWD.is etc. talk about this part.... My guess is ZERO.

Originally Posted by stuckinline

CIS Ombudsman report is out and they have made the exact same point you made in your "Technical comments" for I-140 EAD.

On Page 50 of CIS Ombudsman report, they cite the exact same case law that you mentioned in your comments - Patel v. USCIS, Kurapati v. USCIS and Mantena v. Johnson. They very well could have lifted this section of the report straight from your comments.

Not only that - but they make the exact same point that you made in your submission:


Of all the regulatory submissions (even those from Lawyers and Lawyers Groups) - you were the only ones who could actually articulate the legal framework for I-140 EAD.

It is encouraging to see CIS Ombudsman making the very similar legal arguments as you made in your comments. It gives me confidence your legal arguments aren't just convincing, but they are correct!

[bpk]

Any idea on when the rule is supposed get published?

[tspiv]

I read the OMB annual report. This should be such a proud moment for all the volunteers who worked behind the scene -- for drafting the IV's comment -- to the proposed rule. Your arguments were totally inline with the expectations of an independent US authority who understands the complexities of the immigration system. Though it does not mean USCIS will act accordingly, it definitely proves IV is in right direction.

I remember the days, when you guys were working on the technical comment, and many of us were impatient and complaining on why there is no updates from IV.