Tag: Immigration Law

DHS May Make Form I-9 Flexibility a Fixture

The Department of Homeland Security (DHS) announced it is considering changes to the Form I-9 documentation examination procedures. As human resources teams know, the remote workplace that became common during the COVID-19 pandemic made an already complicated I-9 process a logistical nightmare. With the U.S. government’s declaration of a national emergency due to the COVID-19 pandemic, DHS and Immigration and Customs Enforcement (ICE) announced certain flexibilities in March 2020 that suspended the requirement of in-person review of I-9 documents when a company was operating remotely due to COVID-19. Those flexibilities have been extended numerous times and are currently set to expire Oct. 31, 2022.

While DHS says it is considering making these temporary flexibilities permanent, the Notice of Proposed Rule Making (NPRM) published last month does not seek to do so. Instead, the NPRM seeks to validate the authority of the DHS secretary to enact flexibilities, offer alternative options, and/or implement a pilot program to evaluate existing and additional alternative I-9 procedures for some or all employers. DHS recognizes that more and more employers are utilizing telework and remote work for their employees and that requiring in-person review of I-9 documents is no longer consistent with work patterns of many businesses.

Some of the more notable possible changes to the I-9 process described in the NPRM include requiring employers to note on the Form I-9 which of the alternative procedures they used; requiring employers to retain copies of I-9 documents; requiring online training on fraudulent document and/or anti-discrimination training for employers who wish to utilize the alternative procedures; and limiting eligibility to use the alternative procedures to employers that utilize E-Verify, the government’s online employment verification system.

Comments to the NPRM are due on or before Oct. 17, 2022.

Article By Rebecca B. Schechter of Greenberg Traurig, LLP

For more immigration legal news, click here to visit the National Law Review.

©2022 Greenberg Traurig, LLP. All rights reserved.

New, Immigration-Friendly Mission Statement for USCIS

USCIS has changed its mission statement again – this time to adopt a more immigration-friendly stance.

In 2018, USCIS, under the Trump Administration, changed its mission statement to align with President Donald Trump’s focus on enforcement, strict scrutiny, and extreme vetting. The statement did not emphasize customer satisfaction, i.e., the satisfaction of petitioners, applicants, and beneficiaries. The change in emphasis was stark and did not go unnoticed. Instead, the mission statement focused on protecting and serving the American people and ensuring that benefits were not provided to those who did not qualify or those who “would do us harm ….” The 2018 statement did not speak of the United States as a “nation of migrants” and it focused on efficiency while “protecting Americans, securing the homeland, and honoring our values.”

The new 2022 USCIS mission statement reflects President Joe Biden’s belief that “new Americans fuel our economy as innovators and job creators, working in every American industry, and contributing to our arts, culture, and government.” Accordingly, he has issued executive orders directing the various immigration agencies to reduce unnecessary barriers to immigration. The 2022 mission statement also reflects President Biden’s directions and USCIS Director Ur M. Jaddou’s “vision for an inclusive and accessible agency.” Director Jaddou “is committed to ensuring that the immigration system . . . is accessible and humane . . . [serving] the public with respect and fairness, and lead with integrity to reflect America’s promise as a nation of welcome and possibility today and for generations to come.”

According to Director Jaddou, USCIS will strive to achieve the core values of treating applicants with integrity, dignity, and respect and using innovation to provide world-class service while vigilantly strengthening and enhancing security. On February 3, 2022, Director Jaddou, along with her deputies, briefed the nation on the agency’s efforts to improve service at USCIS. The leaders of the agency made clear that USCIS knows it must continue to eliminate backlogs, cut processing times, reduce unneeded Requests for Evidence and interviews, eliminate inequities in processing times across service centers and improve the contact center, among other things, to achieve its goals. Using streamlining and technological innovation, USCIS hopes to make itself much more consumer-oriented.

Article By Forrest G. Read IV of Jackson Lewis P.C.

For more immigration legal news, click here to visit the National Law Review.

Jackson Lewis P.C. © 2022

Travel Bans are Legal Diplomatic Tools to Further Foreign Policy

Commentary on Travel Bans

In spite of national and international criticism, the Trump Administration continues to use travel bans as part of its strategy to pursue American foreign policy objectives. On May 29th, President Trump signed an executive order on the Suspension of Entry as Nonimmigrants of Certain Students and Researchers.

This order bans Chinese graduate students and researchers who have ties to an entity that “implements or supports” China’s “military-civil fusion strategy.” It also calls on the State Department to consider if Chinese graduate students currently in the U.S. should have their visas revoked.  The goal of this travel ban is to prevent China from acquiring sensitive American technologies and intellectual property that could modernize and enhance the Chinese military.

This is just the latest in a series of travel bans that the Administration has used to pursue foreign policy interests.  In Syria, the U.S. has a tenuous relationship with the Assad regime and the security infrastructure was ravaged by years of civil war and radical insurgents. There is no mechanism for meaningful security and information sharing between the two nations.  The Administration has a full travel ban on Syrians to guard America’s security.

In Iran, the U.S. relationship has been tense for over four decades. The Trump Administration withdrew from the Joint Comprehensive Plan of Action and 1955 amity treaty. However, Trump’s foreign policy objective is to make a new nuclear deal with Iran.  Trump’s travel ban in Iran allows Iranian students to receive visas as a path for dialogue.

Nigeria and America are allies and major trade partners.  However countering the Islamic militant group Boko Haram, which abducted 300 girls in 2014, is also part of America’s foreign policy.  The travel ban in Nigeria is limited to only immigrant visas.  The State Department issued over 99,000 visas in Nigeria in 2019.  Of these only 6,746, or 7%, were immigrant visas.  Banning 7% of Nigerians sends a message that the Nigerian government must to more to counter terrorism. But it stops short of banning all travelers from a main trade partner.

Some Chinese graduate students are now part of a growing list of banned travelers to the United States.  Travel bans are controversial, but our government has the obligation to use all legal tactics at its disposal to pursue its foreign policy goals and to secure its citizens. Travel bans are diplomatic tools, not political weapons.

The opinions and views stated herein are the sole opinions of the author and do not reflect the views or opinions of the National Law Review or any of its affiliates.

© 2020 George Farag
For more on travel bans, see the National Law Review Immigration law section.

DHS Proposes Fee of $10 to File H-1B Petition

Department of Homeland Security (DHS) has proposed a fee of $10 per H-1B petition. The agency considers this to be an “appropriate, nominal fee” to recover some costs involved.

In January 2019, DHS published the rule establishing an H-1B electronic registration system. At that time, no fee was proposed, but the “door was left open.” In mid-August, DHS announced that there would be a fee.

As to what information will be required, that is still a bit up in the air – again, the door is left open by DHS. The agency wants enough information to be able to check for fraud, duplicate registrations filed by the same company, and to ensure that those selected during the registration period ultimately file H-1B petitions. In addition to company identification, each registration would include the beneficiary’s:

  • Full name
  • Date of birth
  • Country of birth
  • Gender
  • Passport number

Each registration also will require the petitioner to complete an attestation about the “bona fides” of the registration. Frivolous registrations, DHS warns, “may be referred to appropriate federal law enforcement agencies for investigation and further action as appropriate.” Under a “catch-all,” DHS could require: “any additional basic information requested by the registration system to promote certainty.”

Some concerned about frivolous registrations suggested that information include job title, worksite address, salary offers, SOC code, LCA wage level, and specific educational qualifications. Others suggested including disclosure of any recent labor violations or disputes and EEOC complaints and whether the petitioner is H-1B dependent. DHS rejected these ideas (for now), noting that much of that information would be used to review eligibility once an H-1B petition is filed.

Questions remain about what DHS does with the information it gathers during the electronic registration. In accordance with the Administration’s “Buy American, Hire American” Executive Order,  DHS is already gathering and sharing much information on its H-1B Data Hub. The public can search the number of H-1B approvals and denials by company and by year. The public also can see, by employer, the number of approved H-1B petitions by salary and degree type. In addition to making the information public, DHS has stated in a description of the H-1B registration tool that it “may share the information with other Federal, State, local and foreign government agencies” and “may also share [the] information, as appropriate, for law enforcement purposes or in the interest of national security.” The full scope of this statement is not yet known.

It is unclear whether the electronic registration will be ready in 2020 or when the promised trial period for stakeholders will occur.

Jackson Lewis P.C. © 2019

ARTICLE by Amy L. Peck of Jackson Lewis P.C.
For more on DHS filing, see the National Law Review Immigration Law page.

USCIS Revising, Updating Naturalization Test

USCIS is on its way to revising and updating the Naturalization Test. It will start with a pilot test involving about 1,400 volunteers this fall, then a second field testing pilot in spring 2020.

Last updated in 2008, the new Naturalization Test is expected to be implemented as soon as late-2020.

Recent issues surrounding the Administration’s attempt to add a citizenship question to the 2020 census and delays in processing naturalization applications have prompted the Acting Director of USCIS, Ken Cuccinelli, to tell the Washington Post that paranoia regarding the reason for these changes is not warranted. People who are paranoid will be “sorely disappointed when [the new test] looks like another version of the [current] exam.” Decennial revisions are proposed to “ensure that the civics education requirements remain a meaningful aspect of the naturalization process.”

The working group revising the test includes staff from across USCIS. The group is “soliciting the input of experts in the field of adult education to ensure that this process is fair and transparent.”

Currently, naturalization applicants are asked 10 randomly selected questions from a list of 100 (the list is available on the USCIS website). The questions are on American government, history, and civics and reflect middle school and high school curricula. To pass, 6 of the 10 questions must be answered correctly. There is a 90% pass rate among applicants. A 2018 survey by the Woodrow Wilson National Fellowship Foundation showed the pass rate among U.S. citizens was only 36%. Citizens over the age of 65 had the highest pass rate: 74%.

Test yourself. Answer the following (answers are at the bottom of this post)

  1. Why did the colonists fight the British?

  2. When was the Declaration of Independence adopted?

  3. How many amendments does the Constitution have?

Along with changes to the civics test, the agency also is considering changes to the English language proficiency test. According to the naturalization statute, applicants must read and write “simple words and phrases” and “no extraordinary or unreasonable condition shall be imposed upon the applicant.”

When Francis Cissna, then-Director of USCIS, announced the revision he noted that the new tests would continue to provide “special consideration” to those over 65 who have lived in the U.S. as green card holders for at least 20 years. He also stated that “due consideration” would be given to “applicants’ education, background, age, length of residence in the United States, opportunities available and efforts made to acquire the requisite knowledge, and any other elements or factors relevant to an appraisal of the adequacy of the applicant’s knowledge and understanding.”

Last year, 750,000 applicants were naturalized. In the years preceding presidential elections, the application levels typically increase.

****

The answers:

  1. Because of high taxes (taxation without representation), because the British army stayed in their houses (i.e., boarding and quartering), or because they did not have self-government
  2. July 4, 1776
  3. 27
Jackson Lewis P.C. © 2019
This article is written by Peter A. Reca of Jackson Lewis P.C.
For more immigration news, see the National Law Review Immigration type of law page.

DHS Announces Final Rule on STEM OPT Employment Authorization

The final rule adds employer obligations to the STEM OPT program.

The US Department of Homeland Security has released an advance version of its long-anticipated final rule that expands employment authorization for foreign students with science, technology, engineering, or mathematics (STEM) degrees. The rule, which will be published in the Federal Register on March 11 and take effect on May 10, 2016, will allow such students to extend their period of optional practical training (OPT) by an extra 24 months, for a total of 36 months of OPT employment authorization. Previously, students in STEM fields were allowed a total of 29 months of OPT. Foreign students with degrees in non-STEM fields will continue to be limited to 12 months of OPT.

The rule also improves and increases oversight over STEM OPT extensions by, among other things, requiring that employers implement formal training plans, adding wage and other protections for STEM OPT students and US workers, and allowing extensions only to students with degrees from accredited schools. The rule also allows US Immigration and Customs Enforcement to conduct site visits to employers of STEM OPT holders to ensure that the rule’s requirements are being complied with.

Previous 17-month STEM OPT employment authorizations issued before May 10 will remain valid until their expirations. Starting May 10, STEM students will have a chance to apply for an additional seven months of OPT.

Article By Eleanor Pelta, Eric S. Bord, A. James Vázquez-Azpiri, Lisa Stephanian Burton & Tracy Evlogidis of Morgan, Lewis & Bockius LLP
Copyright © 2016 by Morgan, Lewis & Bockius LLP. All Rights Reserved.

Department of State Releases March 2016 Visa Bulletin

Employment-based second- and third-preference China categories show significant advancement.

The US Department of State (DOS) has released its March 2016 Visa Bulletin. The Visa Bulletin sets out per-country priority date cutoffs that regulate immigrant visa availability and the flow of adjustment of status and consular immigrant visa application filings and approvals.

What Does the March 2016 Visa Bulletin Say?

The March 2016 Visa Bulletin includes both a Dates for Filing Visa Applications and Application Final Action Dates chart. The former indicates when intending immigrants may file their applications for adjustment of status or immigrant visa, and the latter indicates when an adjustment of status application or immigrant visa application may be approved and permanent residence granted.

If the US Citizenship and Immigration Services (USCIS) determines that there are more immigrant visas available for a fiscal year than there are known applicants for such visas, it will state on its website that applicants may use the Dates for Filing Visa Applications chart. Otherwise, applicants should use the Application Final Action Dates chart to determine when they may file their adjustment of status applications. For March 2016, it is not yet clear whether employment-based (EB) applicants may use the Dates for Filing Visa Applications chart or the Application Final Action Dates chart. USCIS will announce its decision within the next week.

Application Final Action Dates

To be eligible to file an EB adjustment application in March 2016, foreign nationals must have a priority date that is earlier than the date listed below for their preference category and country (changes from last month’s Visa Bulletin dates are shown in yellow):

EB All Chargeability
Areas Except
Those Listed		 China
(mainland born)		 India Mexico Philippines
1st C C C C C
2nd C 01AUG12—
(was 01MAR 12)		 15OCT08
(was 01AUG08)		 C C
3rd 01JAN16
(was 01OCT15)		 01JUN13

(was 01OCT12)

 15JUL04
(was 15JUN04)		 01JAN16
(was 01OCT15)		 15MAR08
(was 08JAN08)
Other Workers 01JAN16
(was 01OCT15)		 01FEB07
(was 22DEC06)		 15JUL04
(was 15JUN04)		 01JAN16
(was 01OCT15)		 15MAR08
(was 08JAN08)
4th C C C C C
Certain Religious Workers C C C C C
5th
Nonregional
Center
(C5 and T5)		 C 22JAN14
(was 05JAN14)		 C C C
5th
Regional
Center
(I5 and R5)		 C 22JAN14
(was 15JAN14)		 C C C

Filing Dates

The chart below reflects dates for filing visa applications within a timeframe that justifies immediate action in the application process. Visit www.uscis.gov/visabulletininfo for information on whether USCIS has determined that this chart can be used in March for filing applications for adjustment of status.

EB All Chargeability
Areas Except
Those Listed		 China
(mainland born)		 India Mexico Philippines
1st C C C C C
2nd C 01JUN13
(was01Jan13)		 01JUL09 C C
3rd C (was
01JAN16)		 01MAY15
(was 01OCT13)		 01JUL05 C (was
01JAN16)		 01JAN10
Other Workers C (was
01JAN16)		 01AUG07
(was 01JAN07)		 01JUL05 C (was
01JAN16)		 01JAN10
4th C C C C C
Certain Religious Workers C C C C C
5th
Nonregional
Center
(C5 and T5)		 C 01MAY15 C C C
5th
Regional
Center
(I5 and R5)		 C 01MAY15 C C C

How This Affects You

The largest changes in the Application Final Action Dates chart are in the EB-3 China category, which has advanced by eight months to June 1, 2013, and in the EB-2 China category, which has advanced by five months to August 1, 2012. The EB-2 India category advanced by three and a half months to October 15, 2008. The EB-3 category for the worldwide preference and Mexico categories advanced to January 1, 2016. The largest changes in the Dates for Filing Visa Applications chart are in the EB-2 and EB-3 China categories, which advanced by six months each. Other classification categories saw only minimal advancement of one week to one month. Read the full March 2016 Visa Bulletin.

Article By Eleanor Pelta, Eric S. Bord, A. James Vázquez-Azpiri, Lisa Stephanian Burton & Tracy Evlogidis of Morgan, Lewis & Bockius LLP
Copyright © 2016 by Morgan, Lewis & Bockius LLP. All Rights Reserved.

Department of State Issues March 2016 Visa Bulletin – China EB-3 Now Even with EB-5, Expectations Set For Coming Months

The July 2015 Visa Bulletin Brings Little ChangeThe March 2016 Visa Bulletin is now available online.  The significant news arises in the EB-3 category with respect to dates for filing visa applications: EB-3 Worldwide is now current. EB-3 China has advanced from Oct. 1, 2013, to May 1, 2015, making the native Chinese EB-3 and EB-5 filing dates identical. Compared to February, March 2016 brings modest-to-moderate movement forward in the “final action dates” for the employment-based cases.

Below are the two charts for March 2016:

APPLICATION FINAL ACTION DATES FOR EMPLOYMENT-BASED PREFERENCE CASES

Department of State Issues March 2016 Visa Bulletin – China EB-3 Now Even with EB-5, Expectations Set For Coming Months

DATES FOR FILING OF EMPLOYMENT-BASED VISA APPLICATIONS

Department of State Issues March 2016 Visa Bulletin – China EB-3 Now Even with EB-5, Expectations Set For Coming Months

The Visa Bulletin also put forth the following projection of EB visa availability in the coming months, setting the expectations for stakeholders:

  • EB-1 : Projected to stay current

  • EB-2:

    • Worldwide: Projected to stay current

    • China: Movement up to five months

    • India: Movement up to three months

  •  EB-3:

    • Worldwide: Recent forward moment will generate demand – once materialized it will be necessary to establish a cut-off date

    • China: Movement up to five months

    • India:  Movement up to one month

    • Mexico: Will remain at worldwide date

    • Philippines: Movement up to four months

  • EB-4: Current “for most countries”

  • EB-5:

    • All countries (except China): Will remain current.

    • China: “Slow forward movement”

Article By Matthew T. Galati of Greenberg Traurig, LLP

©2016 Greenberg Traurig, LLP. All rights reserved.

Department of State Releases February 2016 Visa Bulletin

Employment-based adjustment of status applicants must file using the Application Final Action Dates chart.

The US Department of State (DOS) has released its February 2016 Visa Bulletin. The Visa Bulletin sets out per-country priority date cutoffs that regulate immigrant visa availability and the flow of adjustment of status and consular immigrant visa application filings and approvals.

What Does the February 2016 Visa Bulletin Say?

The February 2016 Visa Bulletin includes both a Dates for Filing Visa Applications and Application Final Action Dates chart. The former indicates when intending immigrants may file their applications for adjustment of status or immigrant visa, and the latter indicates when an adjustment of status application or immigrant visa application may be approved and permanent residence granted.

If the US Citizenship and Immigration Services (USCIS) determines that there are more immigrant visas available for a fiscal year than there are known applicants for such visas, it will state on its website that applicants may use the Dates for Filing Visa Applications chart. Otherwise, applicants should use the Application Final Action Dates chart to determine when they may file their adjustment of status applications. For February 2016, USCIS has announced that employment-based (EB) applicants may only use the Application Final Action Dates chart.

To be eligible to file an EB adjustment application in February, foreign nationals must have a priority date that is earlier than the date listed below for their preference category and country (changes from last month’s Visa Bulletin dates are shown in yellow):

EB

All Chargeability
Areas Except
Those Listed

China
(mainland born)

India

Mexico

Philippines

1st

C

C

C

C

C

2nd

C

01MAR12—
(was 01Feb 12)

01AUG08
(was 01FEB08)

C

C

3rd

01OCT15
(no change)

01OCT12
(was 01JUL12)

15JUN04
(was 15MAY04)

01OCT15
(no change)

08JAN08
(was 01NOV07)

Other Workers

01OCT15
(no change)

22DEC06
(was 01AUG06)

15JUN04
(was 15MAY04)

01OCT15
(was 01SEPT15)

08JAN08

(was 01NOV07)

4th

C

C

C

C

C

Certain Religious Workers

C (was U)

C (was U)

C (was U)

C (was U)

C (was U)

5th
Nonregional
Center
(C5 and T5)

C

15JAN14
(was 08JAN14)

C

C

C

5th
Regional
Center
(I5 and R5)

C (was U)

15JAN14 (was U)

C (was U)

C (was U)

C (was U)

How This Affects You

The largest change in the Application Final Action Dates chart is in the EB-2 India category, which has advanced by six months to August 1, 2008. The EB-2 China category advanced by one month only, and the EB-3 China category advanced by two and a half months to October 1, 2012. Certain Religious Workers and EB-5 matters (Regional Center I5 and R5) became current once again, with the exception of China, which is backlogged to January 15, 2014, in the EB-5 category. Other classification categories saw only minimal advancement of three weeks to three months. Read the entire February 2016 Visa Bulletin.

Article By Eleanor Pelta, Eric S. Bord, A. James Vázquez-Azpiri, Lisa Stephanian Burton & Tracy Evlogidis of Morgan, Lewis & Bockius LLP
Copyright © 2016 by Morgan, Lewis & Bockius LLP. All Rights Reserved.

Visa Waiver Program Changes Now Being Implemented

visaVWP nationals who have visited Iran, Iraq, Sudan, or Syria since March 1, 2011, or who hold dual nationality with one of the countries are no longer eligible for the VWP.

The United States on January 21, 2016, began to implement changes to the Visa Waiver Program (VWP) that were mandated under the Visa Waiver Program Improvement and Terrorist Travel Prevention Act of 2015 (the Act). Under the Act, which was included as an amendment to the December 18, 2015, omnibus spending bill (H.R. 2029), certain individuals are no longer eligible to travel or be admitted into the United States under the VWP. The affected are

  • nationals of VWP countries who have traveled to or been present in Iran, Iraq, Sudan, or Syria on or after March 1, 2011 (with limited exceptions for travel for diplomatic or military purposes in the service of a VWP country) and

  • nationals of VWP countries who are also nationals of Iran, Iraq, Sudan, or Syria.

Individuals who are ineligible for the VWP are still eligible to apply for a B-1/B-2 visitor visa at a US embassy or consulate. Individuals who need a US visa for urgent business, medical, or humanitarian travel to the United States may be eligible for expedited visa processing at a US embassy or consulate.

A waiver of these restrictions may be granted on a case-by-case basis by the secretary of homeland security if he determines that such a waiver is in the interests of US law enforcement or national security. Procedures for seeking a waiver are not currently available, but will presumably be published in the future. Waivers may be available for

  • individuals who traveled to Iran, Iraq, Sudan, or Syria on behalf of international organizations, regional organizations, and subnational governments on official duty;

  • individuals who traveled to Iran, Iraq, Sudan, or Syria on behalf of a humanitarian nongovernmental organization on official duty;

  • individuals who traveled to Iran, Iraq, Sudan, or Syria as a journalist for reporting purposes;

  • individuals who traveled to Iran for legitimate business-related purposes following the conclusion of the Joint Comprehensive Plan of Action (July 14, 2015); and

  • individuals who have traveled to Iraq for legitimate business-related purposes.

The VWP allows citizens of participating countries to travel to the United States without a visa for stays of 90 days or less. Travelers must be eligible to use the VWP and have a valid Electronic System for Travel Authorization (ESTA) approval prior to travel. ESTA approval is issued by US Customs and Border Protection through the ESTA portal. ESTA will usually inform a traveler within one to two days whether his or her application has been approved, after which the traveler may purchase a plane ticket and travel to the United States.

Beginning January 21, 2016, travelers who currently have valid ESTAs and who have previously indicated that they hold dual nationality with one of the four countries listed above on their ESTA applications will have their current ESTAs revoked. However, it is unclear how government agencies will implement revocations for individuals who have traveled to any of the four countries since March 1, 2011.

Individuals whose ESTAs are being revoked should receive notification that that they are no longer eligible to travel under the VWP; however, revocation can occur without notice. All individuals should confirm that their ESTAs remain valid prior to making final travel plans by checking the US Customs and Border Protection ESTA website.

A person whose ESTA is revoked remains eligible to travel to the United States but will first need to obtain a valid nonimmigrant visa issued by a US embassy or consulate. Travelers affected by these new rules should apply for a US nonimmigrant visa well in advance of desired travel to minimize the chance of delays. The visa application process requires every individual traveler to complete an online visa application. Such travelers will be required to appear for an interview and obtain a visa in their passports at a US embassy or consulate before traveling to the United States. Individuals who will require a visa should check the website of the US embassy in their country of residence for instructions on how to apply for the visa. Visa processing times range from as little as one week to several weeks for an appointment, depending on the specific embassy or consular office.

Canadian citizens are visa exempt and are not participants in the VWP; thus, the new restrictions do not apply to Canadian citizens who have dual nationality in one of the specified countries.

Article By Eleanor Pelta, Eric S. Bord, A. James Vázquez-Azpiri, Lisa Stephanian Burton &
Tracy Evlogidis of Morgan, Lewis & Bockius LLP

© 2016 by Morgan, Lewis & Bockius LLP. All Rights Reserved.