First Edition · Manuscript complete · Publication forthcoming
From first file review to a filing-ready motion to reopen.
A forthcoming practitioner’s manual for EOIR motions to reopen — bringing doctrine, evidence, drafting, procedure, and verification into one structured reference, whether you are learning the field, updating your analysis, or strengthening an established practice.
Built from the author’s work on more than 160 motions to reopen, drafted in collaboration with U.S. immigration attorneys and law firms.
12chapters
3parts
7motion-specific chapters
Free preview
See the actual book before it is published.
Browse the complete Table of Contents and read a selected passage reproduced from the current manuscript.
Selected reading · Chapter 2, § 2.9
Strategic Considerations in Multi-Ground Motions
- The complete Table of Contents, exactly as it appears in the current manuscript
- Six consecutive pages of § 2.9 — when reopening grounds combine, where pairings break down, and the D-E-B- supplement trap
- The manuscript’s own typography, citations, footnotes, and practice notes
Grounds are compatible only if one theory does not contradict or undermine the facts supporting another.
— from § 2.9.1, The Factual-Consistency Test
Read on this site · a selected passage, not a complete chapter
Inside the motion chapters — Chapter 5, IAC / Lozada
Actual pages from the manual, shown at reading distance. The full treatment — verified authorities, checklists, and circuit classification — is in the complete edition.
The preview shows one strategic section. The manual develops every motion chapter in full depth. Browse the complete Table of Contents →
New to motions to reopen? Read the practitioner orientation →
What’s inside
A Disciplined System for EOIR Motions to Reopen
Chapters 3 through 8 follow the same recurring framework — purpose, threshold screening, strategic risk assessment, required documents and evidence, affidavit guidance, common failure points, and strategic notes. Chapter 9, the Calderon Jimenez settlement framework, follows its own specialized structure. A motion may look persuasive and still fail; the framework exists to catch what sinks filings.
01
Defective Notice & In Absentia
Challenge improper service, defective NTAs, and in absentia orders with verified authority chains.
02
Exceptional Circumstances
Build compelling showings with the evidentiary standards that actually hold up.
03
IAC / Lozada Framework
Lozada’s three-prong compliance, circuit-specific relaxation standards, and Fifth Amendment grounding.
04
VAWA
Special filing rules, confidentiality protections, and evidentiary frameworks for VAWA-based motions.
05
New Evidence & Changed Country Conditions
New-evidence standards, change-in-law grounds, and country-condition documentation strategies.
06
Sua Sponte Reopening
When deadlines have passed — the adjudicator’s inherent authority and the governing circuit split.
07
Calderon Jimenez (Joint Motions)
The time-limited class-action settlement framework for government-agreed reopening.
Three parts wrap the grounds — the decision tree and universal motion requirements up front; evidence assembly, filing mechanics, and fees at the back; plus appendices, a Table of Authorities, and a Topical Case Index. Authorities reviewed for currency through July 22, 2026.
Why it exists
Built for how removal defense actually moves
Motion practice leaves little room for preventable error.
Deadline traps
The manual organizes the principal deadlines, statutory exceptions, equitable-tolling questions, and numerical limitations so they can be addressed before drafting begins.
Circuit-specific standards
Compliance, prejudice, equitable tolling, and reviewability vary by circuit. The manual identifies those differences and ties them to the governing authorities.
Authorities reviewed for currency
The statutes, regulations, agency materials, Board decisions, and circuit authorities cited in this edition were reviewed through July 22, 2026. Practitioners must still confirm current law and applicable filing requirements before relying on any authority.
About the author
Julio Costa, LL.M.
Brazilian attorney · legal consultant collaborating with U.S. immigration attorneys and law firms
Julio Costa, LL.M., is a licensed Brazilian attorney with more than 15 years of litigation experience in Brazil. He holds an LL.M. from Northeastern University School of Law.
As a legal consultant, he collaborates with U.S. immigration attorneys and law firms on removal-defense strategy, motion practice, appellate briefing, legal research, case analysis, and team training. In that collaborative capacity, he has drafted more than 160 motions to reopen and more than 60 appellate briefs for proceedings before the Board of Immigration Appeals.
This manual reflects that drafting experience and a structured review of the governing statutes, regulations, agency materials, Board decisions, and circuit authorities.
Julio Costa is not admitted to practice law in any U.S. jurisdiction and does not independently provide U.S. legal representation.
“What distinguishes this manual is its practical approach. Rather than simply explaining the law, Julio Costa provides attorneys with a clear, structured framework for evaluating cases, avoiding common pitfalls, and preparing well-supported, filing-ready motions to reopen. This is the kind of resource practitioners will turn to again and again in their daily practice.”
Oksana Specter, Esq. Sakhniuk Immigration Law“His ability to navigate complex legal challenges while maintaining clear, persuasive communication consistently impressed colleagues and clients. His contributions were pivotal in securing favorable outcomes.”
Hon. Marna M. Rusher Retired Immigration Judge“A highly structured and practice-oriented resource that helps practitioners organize their strategic analysis and reduce critical errors in Motions to Reopen, which are notoriously complex. I see it as a valuable tool for both internal standardization and team training.”
Elena Jovanovic, Esq. Nova Law Group“Julio achieved an exceptional grant rate on motions to reopen before both the Immigration Court and the BIA. His work was consistently delivered with clarity, accuracy, and efficiency — and he never missed a deadline.”
Durcio Belz, Esq. Gardini Law“Mr. Costa drafts and reviews legal documents with precision. His deep understanding of immigration law, particularly removal proceedings, was instrumental in delivering high-quality legal services.”
John Paul Galang, Esq. Centurion Legal Group“I had the opportunity to read part of this book before its publication and was genuinely impressed by the quality of the work. The author has succeeded in turning a complex subject into a clear, practical, and highly valuable resource for immigration practitioners. It is a rare combination of deep legal knowledge and real-world experience. I have no doubt this book will become an important reference for attorneys and other professionals who practice before the EOIR. I highly recommend it.”
Luciano Barcellos, Esq. Founder, Barcellos LawPlanned editions
Two editions at publication
The Manual
The complete reference system for EOIR motions to reopen.
- All seven motion-specific chapters, element by element
- Filing framework & decision tree
- Recurring ground-specific framework
- Circuit-split analysis tables
- Topical case index & reference matrix
Pricing announced at publication
The Manual + Template Pack
Everything in the Manual, plus editable templates and practice tools that must be adapted to the record, governing law, and procedural posture.
- Everything in The Manual
- Pre-filing assembly checklist
- Lozada / Melgar compliance checklist
- Quick-reference motion matrix
- Editable document templates
Pricing announced at publication
Every individually issued digital copy is personalized with a unique Copy ID and recorded in a distribution ledger.
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