First Circuit Reply Brief
First Circuit Reply Brief
2008
“In its briefing on appeal, and in all of its briefing and argument relating to exhaustion on remand, BIA grounded its arguments in the traditional exhaustion and equitable exceptions. [...] In its Answering Brief recently submitted in this appeal, now well over three years into this litigation, BIA has set forth a wholly new and different set of arguments.”
BIA Raises novel arguments on appeal
5/7/09
NN’s reply brief and motion to supplement record has been filed.
Download:
1)Reply Brief 2009-04-29 -- NN Reply Brief (Final).pdf
2)Supplement 2009-04-30_Appellants Motion to Supplement the Record.pdf