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Petitioners respectfully request the director of Texas Service Center and all USCIS representatives with authority over this matter reconsider its decision to deny the Petitioners Motion to ReopenReconsider due to abandonment based on the following grounds The required initial evidence was submitted with I-140 petition and L-1 extension application The I-140 petition contained the most requested evidence While the documents submitted for rebuttal of Intend to Deny on Nov 23 2012 were merely copied and combined together of the documents previously submitted in I-140 petition except 2011 tax that was unavailable at the time of filing I-140 petition in August 2011 2 The Officer should exercise hisher discretion and consider a compelling circumstances that the husband of the undersigned counsel was admitted to an intensive care unit of the hospital in October of 2012 to exempt the petitioners delayed response to intend to Deny and to grand its Motion to ReopenReconsider for the humanitarian concern 3 The petitioners equity in the US subdivision outweighs any reasons of denial stated in its denial of the petitioners motion to reopenreconsider 4 The officer should grand motion to reopen based on newly available evidence of 2011 tax return that was unavailable at the time of filing its I-140 petition II STATEMENT OF FACTS A THE COMPANY BACKGROUND Ocho Ros is located on the north central coast of Jamaica It was formerly a fishing port and was also known for its banana exports It is perhaps most notable
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