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WEEKLY IMMIGRATION UPDATE 8.09.2021

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WEEKLY IMMIGRATION UPDATE 8.09.2021

IMMIGRATION UPDATE – August 9, 2021

HEADLINES

1. Biden Administration Develops Plan to Require Full Vaccination for Most Travelers to United States – The Biden administration is developing a “phased” plan to require most travelers to the United States to be fully vaccinated, with exceptions. The idea is to make it possible to safely re-open travel to the United States and lift pandemic-related restrictions on foreign travelers.

2. 125 Indian and Chinese Nationals Sue USCIS Over Risk of Green Card Loss – Plaintiffs argue that delayed processing is risking the potential loss of up to 100,000 “rollover” green cards. They ask the court to compel USCIS to adjudicate their adjustment applications by the end of this fiscal year, September 30, 2021, or reserve the visa numbers through the next fiscal year.

3. USCIS Is Sending RFEs for I-693s; Medicals Should Be Filed Soon After Receiving RFE – USCIS) informed the American Immigration Lawyers Association (AILA) that it is sending communications to adjustment applicants or their representatives with notice that a Request for Evidence (RFE) will be sent for Form I-693, Report of Medical Examination and Vaccination Record.

4. USCIS Extends Initial Registration Period for New TPS Applicants From Venezuela, Syria, and Burma, and Corrects Venezuelan TPS Notice – USCIS extended the initial registration periods from 180 days to 18 months for initial (new) applicants under the TPS designations for Venezuela, Syria, and Burma. The notice also corrected the Federal Register notice regarding Venezuela.

5. DHS Suspends Requirements for F-1 Nonimmigrant Students Who Are Haitian Citizens – Eligible students may request employment authorization, work an increased number of hours while school is in session, and reduce their course loads while continuing to maintain F-1 nonimmigrant student status. The notice is effective through February 1, 2023.

6. U.S. to Defer Removal of Certain Hong Kong Residents in United States – President Biden directed the Department of Homeland Security to “take appropriate measures to defer for 18 months the removal for Hong Kong residents presently in the United States.” Such residents may also seek work authorization.

7. New Refugee Resettlement Program Announced for Certain Afghans Not Eligible for Special Immigrant Visas – Secretary of State Antony Blinken announced a new resettlement program for Afghans who assisted the United States but who do not qualify for special immigrant visas. The “Priority-2” (P-2) designation will grant access to the U.S. refugee admissions program for eligible Afghans and their family members.

8. New USCIS Director Appointed: Ur M. Jaddou – Ur M. Jaddou was appointed on August 3, 2021, as the new director of USCIS. Ms. Jaddou previously served as chief counsel at USCIS from June 2014 to January 2017.

9. USCIS Conducts Second Random Selection From Previously Submitted FY 2022 H-1B Cap Registrations – On July 28, 2021, USCIS selected additional previously submitted electronic registrations using a random selection process. The petition filing period based on registrations selected on July 28 will begin on August 2 and close on November 3, 2021.

10. Consent Order Provides Interim Relief to Certain Applicants Filing I-765s for OPT and STEM OPT – Under a court order, USCIS extended flexibilities for certain foreign students affected by delayed receipt notices for work authorization applications. The extension includes applications received on or after October 1, 2020, through October 31, 2021.

11. DHS Announces Registration Process for Haitian TPS – The 18-month initial registration period runs from August 3, 2021, through February 3, 2023. To be eligible, individuals must demonstrate that they have continuously resided in the United States since July 29, 2021.

12. USCIS Issues Reminder About Immigration Services That May Help Those Affected by Natural Disasters and Other Unforeseen Circumstances – Immigration services may be available on a case-by-case basis to help people “affected by unforeseen circumstances such as natural disasters.” Examples include “the wildfires in the western United States and the recent building collapse in Surfside, Florida.”

13. Biometrics Processing Unit Closes in Alexandria, VA – USCIS has closed the Biometrics Processing Unit in Alexandria, Virginia, which no longer receives mail.

14. New Asylum Office Opens in Tampa – USCIS will open a new asylum office in Tampa on August 2, 2021, “in response to an increasing asylum workload in Florida.”

15. New Credentialing Organization Approved for Healthcare Workers in Nursing – Josef Silny Associates, Inc., is approved as a credentialing organization for individuals seeking to enter the United States to work as a nurse.

16. Mass Afghan Evacuations Begin in Operation Fraught With Risk – In a complex operation fraught with delays, difficulties, and risk, the U.S. government is evacuating groups of Afghans eligible for Special Immigrant Visas based on their work for the United States, such as serving as translators and interpreters for U.S. forces in Afghanistan.

17. USCIS Updates Policy Manual – USCIS made several updates to its USCIS Policy Manual.

DETAILS

 

1. Biden Administration Develops Plan to Require Full Vaccination for Most Travelers to United States

According to reports, the Biden administration is developing a “phased” plan to require most travelers to the United States to be fully vaccinated, with exceptions. The idea is to make it possible to safely re-open travel to the United States and lift pandemic-related restrictions on foreign travelers.

A White House official told CBS News that federal interagency working groups “are working to develop a plan for a consistent and safe international travel policy, in order to have a new system ready for when we can reopen travel. This includes a phased approach that over time will mean, with limited exceptions, that foreign nationals traveling to the United States (from all countries) need to be fully vaccinated. Currently, the interagency working groups are developing a policy and planning process to be prepared for when the time is right to transition to this new system.”

Under discussion are the details of how to implement such a policy, what proof of vaccination will be accepted, and which vaccines will be accepted. It is unclear whether only air travel will be affected or whether vaccines will also be required before crossing land borders.

2. 125 Indians and Chinese Sue USCIS Over Risk of Green Card Loss

A group of 125 Indian and Chinese immigrants approved for employment-based green cards sued U.S. Citizenship and Immigration Services in federal court in Maryland on August 3, 2021. In Chakrabarti v. USCIS, they argue that delayed processing is risking the potential loss of up to 100,000 “rollover” green cards from the unused family preferences to the employment preferences. Family-based green cards went unused due to closures at U.S. consulates as a result of the Covid-19 pandemic and former President Trump’s ban on the issuance of immigrant visas in April 2020. Any green cards that are not given by September 30, 2021, will be wasted. Plaintiffs ask the court to compel USCIS to adjudicate their adjustment applications by the end of this fiscal year, September 30, 2021, or reserve the visa numbers through the next fiscal year.

Jeff Joseph of Joseph & Hall PC, Charles Kuck of Kuck Baxter Immigration LLC, and Greg Siskind of Siskind Susser PC are representing the immigrants.

3. USCIS Is Sending RFEs for I-693s; Medicals Should Be Filed Soon After Receiving RFE

U.S. Citizenship and Immigration Services (USCIS) informed the American Immigration Lawyers Association (AILA) that it is sending communications to adjustment applicants or their representatives with notice that a Request for Evidence (RFE) will be sent for Form I-693, Report of Medical Examination and Vaccination Record. USCIS said it is attempting to adjudicate as many adjustment of status applications as possible before the end of the fiscal year. Applicants may respond to the RFE with completed medicals. The RFE will provide instructions for filing. The I-693 should be filed as soon as possible after receiving the RFE so the case can be adjudicated before September 30, 2021.

4. USCIS Extends Initial Registration Period for New TPS Applicants From Venezuela, Syria, and Burma, and Corrects Venezuelan Notice

U.S. Citizenship and Immigration Services (USCIS) extended the initial registration periods from 180 days to 18 months for initial (new) applicants under the Temporary Protected Status (TPS) designations for Venezuela, Syria, and Burma. The notice also corrected the Federal Register notice regarding Venezuela.

USCIS said this extension allows an individual to apply as an initial applicant any time during the 18-month designation periods for the three countries. However, USCIS noted that “applicants should be aware that the ability to file a late initial TPS application may not be available during any potential subsequent extensions of these designations, so individuals desiring TPS should take action to apply during this 18-month initial registration period in order to ensure that they do not miss the opportunity to obtain TPS.”

The notice also makes several corrections to the Venezuela notice, including changing September 7, 2021, to September 9, 2021, and making other adjustments in the sentence, “Although not required to do so, if you want to obtain an EAD valid through September 9, 2022, you must file an Application for Employment Authorization (Form I–765) and pay the Form I–765 fee or request a fee waiver.”

5. DHS Suspends Requirements for F-1 Nonimmigrant Students Who Are Haitian Citizens

The Department of Homeland Security suspended certain regulatory requirements for F–1 nonimmigrant students whose country of citizenship is Haiti (regardless of country of birth) and who are experiencing severe economic hardship as a direct result of the current crisis in Haiti. Eligible students may request work authorization, work an increased number of hours while school is in session, and reduce their course loads while continuing to maintain F-1 nonimmigrant student status. The notice is effective through February 1, 2023.

DHS said it will deem an F-1 nonimmigrant student who receives work authorization by means of the notice to be engaged in a “full course of study” for the duration of the employment authorization, if the student satisfies the minimum course load requirement as described in the notice.

6. U.S. to Defer Removal of Certain Hong Kong Residents in United States

On August 5, 2021, Secretary of Homeland Security Alejandro Mayorkas announced Deferred Enforced Departure would be provided to eligible Hong Kong residents in the United States. President Biden issued a memorandum directing the Department of Homeland Security to “take appropriate measures to defer for 18 months the removal for Hong Kong residents presently in the United States.” Such residents “may also seek employment authorization through U.S. Citizenship and Immigration Services,” he said.

Secretary Mayorkas said the decision was made “based on the ongoing assault on democracy, and rights and freedoms in Hong Kong by the People’s Republic of China.”

7. New Refugee Resettlement Program Announced for Certain Afghans Not Eligible for Special Immigrant Visas

At a press conference on August 2, 2021, Secretary of State Antony Blinken announced a new resettlement program for Afghans who assisted the United States but who do not qualify for special immigrant visas. The Department of State has created a “Priority-2” (P-2) designation “granting access to the U.S. refugee admissions program for many of these Afghans and their family members,” he said.

Secretary Blinken gave a few examples of Afghans who might be eligible for the P-2 designation, including some who worked for a project funded by the U.S. government but not for the government itself; who began working for the United States more recently and may not have met the minimum time and service requirements for a special immigrant visa; or who were employed by American media or nongovernmental organizations (NGOs) “doing vital work to support democratic progress in Afghanistan.”

The Department’s Bureau of Population, Refugees, and Migration (PRM) created a U.S. Refugee Admissions Program (USRAP) Afghan Referrals Workgroup comprising federal agencies to refer individuals directly to the USRAP. Once cases receive access to the USRAP, they will undergo the same processing steps as other refugees, including extensive security vetting. A fact sheet released on August 2, 2021, by the Department says that Afghans who do not qualify for the P-2 program may be referred to the P-1 program by the United Nations High Commissioner for Refugees, a U.S. Embassy, or a designated NGO.

8. New USCIS Director Appointed: Ur M. Jaddou

Ur M. Jaddou was appointed on August 3, 2021, as the new director of U.S. Citizenship and Immigration Services (USCIS). Ms. Jaddou previously served as chief counsel at USCIS from June 2014 to January 2017.

More recently, Ms. Jaddou directed DHS Watch, an America’s Voice-led project focused on good governance and accountability in the Immigration system. She also served as an adjunct professor of law at American University’s Washington College of Law, and counsel at Potomac Law Group, PLLC.

From 2012 to 2014, Ms. Jaddou was responsible for developing and implementing congressional strategy for the Department of State as deputy assistant secretary for the Bureau of Legislative Affairs. Ms. Jaddou also served as chief counsel for the Subcommittee on Immigration and Citizenship in the U.S. House of Representatives, and as senior counsel to Rep. Zoe Lofgren.

Ms. Jaddou, a daughter of immigrants from Mexico (mother) and Iraq (father), received her bachelor’s and master’s degrees from Stanford University and her law degree from UCLA School of Law.

9. USCIS Conducts Second Random Selection From Previously Submitted FY 2022 H-1B Cap Registrations

U.S. Citizenship and Immigration Services (USCIS) announced on July 29, 2021, that it needed to select additional H-1B registrations to reach the fiscal year (FY) 2022 quota. On July 28, 2021, the agency selected additional previously submitted electronic registrations using a random selection process. The petition filing period based on registrations selected on July 28 will begin on August 2 and close on November 3, 2021. Individuals with selected registrations will have their myUSCIS accounts updated to include a selection notice, which includes details of when and where to file. Registration selection only indicates that petitioners are eligible to file H-1B cap-subject petitions; it does not indicate that the petition will be approved.

USCIS conducted an initial random selection in March 2021 of electronic registrations submitted for the FY 2022 H-1B cap and of beneficiaries eligible for the advanced degree exemption. The initial filing period for those selected for FY 2022 was April 1, 2021, through June 30, 2021.

On July 27, 2021, a group of plaintiffs in Liu v. Mayorkas filed a motion seeking to preliminarily enjoin the defendants from implementing, applying, or enforcing the H-1B cap registration rules (8 CFR § 214.2(h)(8)(iii)). They alleged that the Department of Homeland Security exceeded its authority and argued that implementation of the rules is arbitrary, capricious, an abuse of discretion, and not in accordance with the law. This was because there was evidence and data indicating that the FY 2022 registration process, if implemented, would lead to fraud, abuse, and a likely second lottery. Arguments regarding the injunction request will be heard on August 27, 2021.

10. Consent Order Provides Interim Relief to Certain Applicants Filing I-765s for OPT and STEM OPT

Under a court order, U.S. Citizenship and Immigration Services (USCIS) extended flexibilities for certain foreign students affected by delayed receipt notices for Form I-765, Application for Employment Authorization. USCIS said the extension includes applications received on or after October 1, 2020, through October 31, 2021. Applicants can file Form I-765 up to 120 days before the program end date if the application is received by October 31, 2021.

For applicants who timely filed Form I-765 for Optional Practical Training (OPT) and Science, Technology, Engineering, and Mathematics (STEM) OPT and whose applications were later rejected, USCIS will accept a refiled Form I-765 as filed on the original filing date if:

  • The original, timely filed application was received on or after October 1, 2020, through October 31, 2021; and
  • USCIS subsequently rejected it.

For USCIS to treat the application as though filed on the original received date, refiled applications must be received by November 30, 2021.

11. DHS Announces Registration Process for Haitian TPS

The registration process for Haitian Temporary Protected Status (TPS) will open on August 3, 2021, when the Federal Register notice is published. The 18-month initial registration period runs from August 3, 2021, through February 3, 2023.

Those who wish to request TPS under the Haiti designation must file an application, including approximately 55,000 current TPS Haiti beneficiaries whose TPS-related documentation was automatically extended at least through October 4, 2021, in compliance with court orders who must file a new TPS application under this designation to retain their status. An estimated 100,000 additional individuals can file initial applications for TPS if otherwise eligible.

To be eligible, individuals must demonstrate that they have continuously resided in the United States since July 29, 2021. Department of Homeland Security (DHS) Secretary Alejandro Mayorkas modified the date from what was previously announced “in light of recent events in Haiti, including the July assassination of President Jovenel Moïse.” DHS said that those “who attempt to travel to the United States after July 29, 2021, will not be eligible for TPS and may be subject to expulsion or removal.”

12. USCIS Issues Reminder About Immigration Services for Those Affected by Natural Disasters and Other Unforeseen Circumstances

U.S. Citizenship and Immigration Services (USCIS) issued a reminder on July 28, 2021, that immigration services may be available on a case-by-case basis to help people “affected by unforeseen circumstances such as natural disasters.” Examples the agency listed include “the wildfires in the western United States and the recent building collapse in Surfside, Florida.” USCIS suggested the following measures:

  • Changing a nonimmigrant status or extending a nonimmigrant stay for an individual currently in the United States. Failure to apply for the extension or change before expiration of an authorized period of admission may be excused if the delay was due to extraordinary circumstances beyond the individual’s control;
  • Re-parole of individuals previously granted parole by USCIS;
  • Expedited processing of advance parole requests;
  • Expedited adjudication of requests for off-campus employment authorization for F-1 students experiencing severe economic hardship;
  • Expedited adjudication of employment authorization applications, where appropriate;
  • Consideration of fee waiver requests due to an inability to pay;
  • Flexibility for those who received a Request for Evidence or a Notice of Intent to Deny but were unable to submit evidence or otherwise respond in a timely manner;
  • Flexibility if an individual was unable to appear for a scheduled interview with USCIS;
  • Expedited replacement of lost or damaged immigration or travel documents issued by USCIS, such as a Permanent Resident Card (Green Card), Employment Authorization Documents, and Arrival/Departure Record (Form I-94); and
  • Rescheduling a biometrics appointment.

Those making such a request “should explain how the impact of unforeseen circumstances, such as a natural disaster, created a need for the requested relief. If you lost all forms of evidence in an unforeseen circumstance, include an explanation in your description and a copy of a police report, insurance claim, or other report, if available, to support your request.”

13. Biometrics Processing Unit Closes in Alexandria, VA

U.S. Citizenship and Immigration Services (USCIS) has closed the Biometrics Processing Unit in Alexandria, Virginia. Those who need to reschedule an appointment for biometric services must call the USCIS Contact Center at 800-375-5283 before the date of the original appointment and “establish good cause for rescheduling.” The unit in Alexandria no longer receives mail.

14. New Asylum Office Opens in Tampa

U.S. Citizenship and Immigration Services (USCIS) will open a new asylum office in Tampa on August 2, 2021, “in response to an increasing asylum workload in Florida.” The agency reported that the new office becomes the 11th asylum office in the United States and the second in Florida, joining the existing Miami Asylum Office.

According to USCIS, Florida currently leads the country in asylum applications filed with the agency, and more than a quarter of the national pending caseload is from Florida residents. The addition of the Tampa Asylum Office “will help USCIS resolve urgent cases quickly and better address the large number of asylum applications pending with USCIS in the state,” the agency said.

The Tampa Asylum Office will adjudicate asylum claims filed by individuals residing in western and northern Florida as well as portions of central Florida. The Miami Asylum Office will continue to adjudicate asylum claims filed by individuals residing in south Florida and portions of central Florida. Asylum interviews are by appointment only.

15. New Credentialing Organization Approved for Healthcare Workers in Nursing

U.S. Citizenship and Immigration Services (USCIS) announced that Josef Silny Associates, Inc., is approved as of July 22, 2021, as a credentialing organization for individuals seeking to enter the United States to work as a nurse.

16. Mass Afghan Evacuations Begin in Operation Fraught With Risk

In a complex operation fraught with delays, difficulties, and risk, the U.S. government is evacuating groups of Afghans eligible for Special Immigrant Visas based on their work for the United States, such as serving as translators and interpreters for U.S. forces in Afghanistan. Among other obstacles, the Taliban have been expanding across the country and setting up checkpoints on various roads, and airport operations are threatened by violence. Although the situation is fluid and the numbers are somewhat unclear, below are reported highlights of the evacuations under “Operation Allies Refuge”:

  • About 200 Afghans were flown to Fort Lee, Virginia, for processing before resettlement in the United States. They are among a larger group of about 2,500 eligible for Special Immigrant Visas who are further along in processing.
  • About 4,000 Afghans and their relatives who are earlier in the visa application process will be flown to other countries for lengthier processing.
  • There are roughly 20,000 applicants in the pipeline, along with family members. It is unclear whether all of them will be evacuated safely or what will happen to applicants who were deemed not qualified. The Department of State and the Pentagon reportedly are working together on relocation options at U.S. military installations in the country and elsewhere, possibly to include Qatar and Kuwait, with a goal of evacuating eligible Afghans by August 31, 2021, when the U.S. combat presence is targeted to end.
  • Approximately 74,000 Afghans under the program have already been resettled since 2008.
  • A bill passed the U.S. Senate and House of Representatives last week to provide more than $1 billion to pay for the evacuations, related transportation and housing, and resettlement costs. The bill also provides 8,000 additional visas over the 26,500 allocated currently. President Biden said he will sign the bill.

“About 200 Afghan Interpreters and Family Members Arrive in U.S., in First Wave of Evacuations,” Washington Post, July 30, 2021, https://www.washingtonpost.com/world/2021/07/30/afghan-interpreters-evacuations/

17. USCIS Updates Policy Manual

U.S. Citizenship and Immigration Services (USCIS) made several updates to its USCIS Policy Manual. Highlights include:

  • Policy guidance to address the urgent need for additional civil surgeons to conduct immigration medical examinations in support of Operation Allies Refuge (for certain Afghan Special Immigrant Visa applicants)
  • Technical update adding references to the EB-5 visa program in Child Status Protection Act guidance
  • Revised policy guidance to comply with a recent court order involving immigrant investors and investment of loan proceeds
  • Policy guidance on change of status to nonimmigrant student (F-1) visa classification
  • USCIS Policy Manual updates, https://www.uscis.gov/policy-manual/updates

I-94/E-VERIFY WEBINARS

Immigrant and employee rights webinars. The Department of Justice’s Immigrant and Employee Rights Section (IER), of the Civil Rights Division, is offering a number of free webinars for workers, employers, and advocates. For more information, see https://www.justice.gov/crt/webinars.

E-Verify webinar schedule. E-Verify has released its calendar of webinars at https://www.e-verify.gov/calendar-field_date_and_time/month.

AGENCY PROCESSING TIMES

USCIS case processing times: https://egov.uscis.gov/processing-times/

US Department of Labor:   https://flag.dol.gov/processingtimes

Department of State Visa Bulletin: https://travel.state.gov/content/visas/en/law-and-policy/bulletin.html

COVID-19 RESOURCES

COVID-19 resources. The response of the U.S. immigration agencies to the coronavirus (COVID-19) pandemic is constantly evolving, making it difficult to report relevant information that is not rendered immediately obsolete. The list of online resources below is intended to serve as a quick reference to the most current available agency information.

General Information

Coronavirus.gov: Primary federal site for general coronavirus information

USA.gov/coronavirus: Catalog of U.S. government’s response to coronavirus

CDC.gov/coronavirus: Centers for Disease Control and Prevention information

American Immigration Lawyers Association:  (links to practice alerts on this site are restricted to members)

NAFSA

Immigration Agency Information

Department of Homeland Security: DHS.gov/coronavirus

–        https://www.dhs.gov/coronavirus-news-updates

–        https://www.dhs.gov/news/2020/03/17/fact-sheet-dhs-notice-arrival-restrictions-china-iran-and-certain-countries-europe

USCIS: USCIS.gov/coronavirus

ICE:

–        Overview and FAQs: https://www.ice.gov/coronavirus

–       Requirements for ICE Detention Facilities: https://www.ice.gov/doclib/coronavirus/eroCOVID19response

ReqsCleanFacilities.pdf

CBP:

–        Updates and Announcements:   https://www.cbp.gov/newsroom/coronavirus

–        Accessing I-94 Information: https://i94.cbp.dhs.gov/I94/#/home

Department of Labor:

–        OFLC Announcements (COVID-19 announcements included here): https://www.foreignlaborcert.doleta.gov/

–        COVID-19 FAQs:

Round 1 (Mar. 20, 2020): https://www.foreignlaborcert.doleta.gov/pdf/DOL-OFLC_COVID-19_FAQs_Round%201_03.20.2020.pdf

Round 2 (Apr. 1, 2020): https://www.foreignlaborcert.doleta.gov/pdf/DOL-OFLC_COVID-19_FAQs_Round%202_04.01.2020.pdf

Round 3 (Apr. 9, 2020): https://www.foreignlaborcert.doleta.gov/pdf/DOL-OFLC_COVID-19_FAQs_Round%203.pdf

State Department: https://www.state.gov/coronavirus/

Travel advisories: https://travel.state.gov/content/travel/en/traveladvisories/ea/covid-19-information.html

Country-specific information: https://travel.state.gov/content/travel/en/traveladvisories/COVID-19-Country-Specific-Information.html

J-1 exchange visitor information: https://j1visa.state.gov/covid-19/

Justice Department

Executive Office for Immigration Review: https://www.justice.gov/eoir/eoir-operational-status-during-coronavirus-pandemic

AGENCY TWITTER ACCOUNTS

EOIR: @DOJ_EOIR

ICE: @ICEgov

Study in the States: @StudyinStates

USCIS: @USCIS

I-9 AND E-VERIFY WEBINARS

USCIS and Immigrant and employee rights webinars. The Department of Justice’s Immigrant and Employee Rights Section, Civil Rights Division,has joined with USCIS to present webinars on employee rights during the E-Verify and Form I-9 employment eligibility verification processes.  For more information or to register, see: https://www.justice.gov/crt/webinars.

E-Verify webinar schedule:  https://www.e-verify.gov/calendar-field_date_and_time/month/202004.

___________________________________________________________________________________________

This newsletter was prepared in collaboration with ABIL, the Alliance of Business Immigration Lawyers, comprised of twenty U.S. immigration lawyers who head some of the top immigration practices in the country.   Larrabee Albi Coker LLP is an active member of ABIL.

Legal Disclaimer:   This newsletter is provided for informational purposes only and does not substitute for legal advice based on the circumstances of a specific matter.

 

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