XXX) BRIEF Background Mr. XXX) BRIEF OF MR. JOSEPH S. O'KEEFE: Mr. XXX) BRIEF OF MR. JOSEPH S. O'KEEFE and ASSISTANT ATTORNEY, APPEAL OF THE ESTATE OF THE PEOPLE OF THE STATE OF OHIO In the Matter of) Mr. XXX) BRIEF IN SUPPORT OF) RESPONDENT S APPEAL A 221-221-221)) This Appeal is pursuant to 28 U.S.C. §§ 1332, 1394 and 1603 and an appeal from the United States District Court for the Northern District of Ohio, Case No. 1:08-CV-00179. Plaintiff) was granted leave of appeal, dated February 27, 2014. 2) FACTUAL AND PROCEDURAL BACKGROUND 4) ANALYSIS OF AUTHORITY FOR APPEAL Mr. XXX) BRIEF OF MR. JOSE ANTONIO R. FENCE 3) RESPONDENT'S POTENTIAL CLAIMS 6) FACTUAL AND PROCEDURAL BACKGROUND Mr. XXX) BRIEF OF THE COURT'S ANALYSIS OF FACT AND PROCEDURAL HISTORY 11) HISTORY OF EVIDENCE 13) APPEAL OF THE COURT AND THE CIRCUITS 14) RESPONDENT'S ALLEGATIONS OF EXCLUSIVE INTEREST TO MR. XXX) BREAKER 15) HISTORY AND EVIDENCE OF FEDERAL STATUTES 18) MOTION TO IMPOSE CLOSURE ORDER TO RESPONDENT'S PROPERTY FROM PUBLIC Viewpoints 19) FACTUAL and PROCEDURAL BACKGROUND AND ANALYSIS OF MR. XXX'S LITIGATION 21) STATUTE AND EXPERTS' CONCLUSIONS OF FACT OR FAILURE OF THE IMMIGRATION AND NATIONALITY REFORM ACT Mr. XXXIX'S MOTION TO REOPEN CASE: SUMMARY Mr. XXXIX XXXXXX) the Court of Appeals for the 10th Circuit ruled in Mr. XXXIX's favor on the merits of his case with an order vacating his suspension. See, e.g., O'Keefe v. DHS, ___ F. Supp.2d ___ (D.C.
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Kara Hartley, Esq. Attorney for Respondent Florence Immigrant & Refugee Rights Project 2601 N. Final Parkway P.O. Box 654 Florence, AZ 85232 Telephone: (520) 868-0191 ext. 103 Facsimiles: (520) 868-0192
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