Consular Corner: November 2009
Editor's note: We carry November's issue of Consular Corner in early December because of the long Thanksgiving holiday weekend.
Thank You Embassy London
Many thanks to Embassy London for the extremely valuable educational tour provided to attendees of the AILA Rome District Chapter Fall Conference. Kudos to CG Woody Staeben for opening the gates for the tour, and to Acting CG Debra Hein for her graciousness in introducing the 50 conference attendees to the operations of one of the world's busiest - and most interesting - consular posts.
For the AILA participants, the tour served to humanize the visa application process through the fantastic personal interaction with consular officers that it provided. Indeed, speaking with the consular officers helped the attendees more fully appreciate the principal reasons why many of the consular officers signed up for this line of work: their love of country and desire to make a difference in people's lives. The fact that these are exactly the same reasons why many of us became immigration lawyers was not lost on anyone.
One of the outcomes of Woody and Debra's efforts was to emphasize that the visa application process is partially about the interaction between well-meaning and passionate Americans, some of whom practice law and some of whom implement it. The visit to Embassy London has moved this interaction forward, and for this Woody, Debra and their superior staff (Michael Veasy, Christine Kagarise, Gary Westfall and the line officers) deserve our thanks and appreciation.
(Special thanks to Attorney Nita Nicole Upadhye and her crew for organizing the RDC conference!)
Following the disappearance of The Consuls' Files weblog, we went in search of evidence that speech not officially approved by 7th floor censors still existed in Consular Cyberspace. Our starting point was Frontline Diplomacy: The Foreign Affairs Oral History Collection of the Association for Diplomatic Studies and Training (ADST). The Frontline Diplomacy project was compiled before the Bureau of Consular Affairs became so jittery about public expressions of consular experiences and insights. It's here we found the 2007 interview of Larry Colbert by Frontline's amazing director, Charles Stuart Kennedy.
Larry Colbert served as Foreign Service Officer for some 35 years, holding a variety of positions including Consular Section Chief in Dublin, NIV Chief in Manila, Consul General in Madrid and Paris, and Principal Officer at Consulates General in Tijuana and Ciudad Juarez.
Like Madam Le Consul of The Consuls' Files, Colbert offers a refreshing view of world in which U.S. consuls operate. The following selections from the Colbert interview emphasize how senseless are the actions of those who treat uncensored consular speech as if it were graffiti needing to be scraped off the walls of the Internet. The entire Colbert interview can be accessed here:
On the Sense of Entitlement of Visa Applicants
"Obviously doing the job that I was doing I got annoyed occasionally when the people thought they had a God given right to go to my country because they were Irish and Irish had a special relationship with us, hence the rules don't really apply. I am talking about visas obviously.
I remember a member of the Doyle, the parliament, calling me on the phone once because an Irish gentleman had been sent back, I don't know if it was voluntary departure or deportation but he had been living illegally in the States for a number of years had been sent back, and he wanted a visitors visa to go back to resume his life in America, clearly an impossible situation if we are going to abide by the law and do our jobs. So this man who had applied several times had been refused appropriately each time. Well this member of the parliament who often called me - I mean the prime minister called me more often than he called the ambassador because I had a product, the ambassador just had a mission. He said, 'How could you not give this person a visa? He's a good citizen of our country,' which you just want to grind the dentine off your teeth because obviously you're talking past one another and you can't take a member of parliament and rip his heart out as much as sometimes you would like to be able to do."
On the Previous Consul General at Tijuana
"My predecessor was inept, detached and ineffective, and I'm being polite."
On Pressures from Congress in Visa Cases
"When you refused a visa of interest to a Senator Kennedy or a Tip O'Neil or those folks, you heard about it. This Irish specialty cook, sort of oxymoron when you think about it, had been voluntarily departed back to Ireland. He had been living and illegally working in Massachusetts, but he no more got back than an approved H petition came. This was before, now of course H-1Bs are not subject to Section 214B but in those days they still were. That is to say, you could refuse this person. He had been living in the States illegally so the vice consul was very excited and said, 'This is awful. How can they approve this petition? How can they do this?' He was young so I said, 'Well why don't we just call back to Boston and ask to talk to the district director about this?' So we did. This was a different age when you do this sort of thing. So I called the district director who I know and I said, 'I've got this vice consul who is really upset that this H1B was approved for this specialty cook who you just sent back on voluntary departure. How can this be?' He said, 'Well can I talk to the young man?' 'Sure.' He said, 'Well George,' he said, 'may I call you George?' 'That's fine' George said. 'Why don't you just refuse the visa and we'll see what happens?' So George went back and refused the visa and, again, it was still possible then to do it. That was a Thursday, on Monday we had a call from Kennedy's office and a call from Tip O'Neil's office and we had a call from H (Congressional Relations) and we had a call from somebody else, all of them were calling about this particular case. It was not one that you really could refuse, because everybody in Boston wanted this person back. It seems that all these good folk, including the district director, ate regularly in the Irish pub where the applicant worked."
On Young NIV Line Officers and Temptation
"Q: Well did you have a concern about bribery with your young officers but also in particularly with the male officers?
COLBERT: They had loose zippers. In my case, I was deathly afraid of my wife so I was on the straight and narrow."
On God and Visa Fraud
"There was this person who applied many, many times for a visa and was refused each time. Finally in pure disgust he said, 'Mr. vice consul, I bring you more documents each time I come here.' He asked, 'What would it take, what do I need to get a visa from this place?' The vice consul said, 'From you, a letter from Jesus Christ.' The next day he is back and he's got a letter from Jesus Christ co-signed by God. Didn't get the visa but, no, we asked for it and we got it."
Changes to 9 FAM - Monthly Report
This month's report on updates to 9 FAM (Visas) of the Foreign Affairs Manual includes a veritable Thanksgiving cornucopia of items, including the following:
Adam Walsh Act Clearances (9 FAM 42.41)
New clarification regarding actions needed to be taken by consular officers in obtaining Adam Walsh clearances for petitioners in certain immigrant visa (IV) cases. Among the highlights of this clarification:
- A typo that appears to dis the DAS,
- Important guidance on releasing criminal information about a petitioner to the beneficiaries he or she might harm,
- A warning to renegade consular posts using non-approved forms,
- A distressing recommendation that consular officers use cheat sheets in making legal determinations on inadmissibilities and waivers, and
- Misleading information about the applicability of a key provision of the INA.
Consular Affairs/Visa Office (9 FAM Appendix E, Exhibit II)
The Office of Visa Services (a/k/a "The Visa Office") interprets visa laws and regulations, acts as the point of contact for visa inquiries from the public, and liaises between the Department and consular posts on visa matters. An updated chart has been published depicting the organization and functional responsibilities of the Visa Office.
Either someone has a dry sense of humor, or a regrettable error has been made with regard to the most senior person in the entire hierarchy - the Deputy Assistant Secretary for Visa Services ("DAS"). The updated Visa Office Chart lists the DAS as "Deputy Assistant Sectary." As you may know, a "sectary" refers to a member of a sect that is intolerant of the views of others and is generally considered schismatic. Is someone on the inside trying to tell us something?
Criminal Convictions - Release of Information (9 FAM 42.63)
The Visa Office provides important updated guidance on the release of information about an IV petitioner's criminal convictions to beneficiaries who might be at risk.
According to this guidance, consular officers may release information regarding certain criminal convictions of a visa petitioner if the officer finds "compelling circumstances" affecting the health and safety of a visa beneficiary. Such a release is limited to circumstances in which the petitioner's conviction relates to a criminal offense against a minor or a sexually violent offense.
Disclosure of this information may only be made if the officer intends to approve the visa application. The information may be revealed to the visa applicant or to a minor applicant's parent or guardian so that he or she can decide whether to proceed with the visa application. NOTE: A consular officer is authorized to disclose this information even in petitions in which USCIS has already issued an Adam Walsh Act clearance.
Homeless Nationalities (9 FAM 40.68 Exhibit I)
A "homeless" visa applicant is one who is a national of a country in which the United States has no consular representation or in which the political or security situation is too tenuous or uncertain for the limited consular staff to process visa applications. The Department has now published an updated list of countries whose nationals are considered homeless (example: Iran). This list also indicates the consular posts which have been designated as the processing posts for given homeless nationalities (example: Abu Dhabi, Ankara, Naples, Vienna and Frankfurt for Iranians).
H-1B and EAWA (9 FAM Appendix I, Exhibit X)
President Obama signed the Employ American Workers Act ("EAWA") into law earlier this year. EAWA places additional requirements on employers who receive funds through the Troubled Asset Relief Program or under section 13 of the Federal Reserve Act before they may hire a foreign national to work in the H-1B specialty occupation category. The Department has now published a flow chart to assist consular officers in processing H-1B visa cases in which EAWA restrictions may apply.
Immigrant Visa Forms and Information (9 FAM 42.63)
The Visa Office (VO) provides a lengthy reminder to consular posts that it has developed standard procedures and forms for three specific purposes:
- If the relationship appears valid, the petitioner's biodata must be sent to the National Visa Center (NVC), which then forwards them to USCIS for the mandatory Adam Walsh check.
- The case should remain in provisional status until NVC returns the results of the Adam Walsh check to post.
- If the Adam Walsh check results in a clearance, the consular officer may approve the petition and begin processing the IV case.
- If the Adam Walsh check results in "not cleared" status, the petitioner must return to post to be fingerprinted. The fingerprints are to then be sent, together with other relevant documentation, to USCIS for further processing aimed at verifying whether the petitioner has a prior conviction for one of more of the crimes cited in the Adam Walsh Act.
Accordingly, posts are cautioned that only official forms (such as Form DS-230) may be used; post-specific forms or information sheets should be avoided unless approved in advance by VO.
Inadmissibility Chart (9 FAM 40.6 Exhibit I)
The Department recommends that busy consular officers seeking a quick way for determining whether a ground of ineligibility exists - and whether a waiver is available - turn to the summary reference chart it provides at 9 FAM 40.6 Exhibit I.
This is distressing.
Informed decisions on the law cannot be made on the basis of cheat sheets; and there is no substitute for reading the actual FAM regulation or INA provision.
Case in point: the section in the chart dealing with "Membership or Affiliation with Communist or Other Totalitarian Party" has just been corrected to reflect that Immigrant Visa (IV) waivers are available in the case of an applicant who is the parent, spouse, son, or daughter of a U.S. citizen. Oops - someone just noticed that the availability of this waiver had been left off…
Alas, Exhibit I still contains substantive errors. Example: According to the chart, the factors to be considered in recommending a nonimmigrant (NIV) waiver for Crimes Involving Moral Turpitude include: "The nation and date of the offense, possible rehabilitation of the alien's character, and the necessity for, or urgency of, the alien's proposed trip to the United States."
Don't they mean "nature" and not "nation?" Considering the nation in which the offense was committed is the exact opposite of what the consular officer is supposed to be doing, given that "the presence of moral turpitude in a statutory offense is determined according to United States law" (9 FAM 40.21(a) N2.1).
There's a lot at stake in ensuring that legal determinations about inadmissibilities and waivers are made correctly. See, for example the quote from Matter of S- and B-C which the Department provides consular officers in the context of a (6)(C) determination:
"Shutting off the opportunity to come to the United States actually is a crushing deprivation to many prospective immigrants. Very often it destroys the hopes and aspirations of a lifetime, and it frequently operates not only against the individual immediately but also bears heavily upon his family in and out of the United States."
The Department should trust its officers to be sufficiently intelligent to understand the FAM (and not have to resort to cheat sheets). Moreover, the Department should also reaffirm and reissue 99 State 21138, which offers the simple premise that immigration attorneys can be a useful utensil in the consular toolbox for understanding immigration law. There's really no better way to maximize accuracy in a field that can have such a substantial impact on people's lives.
INA 222(g) Chart (9 FAM 40.68 Exhibit I)
This FAM update provides even further proof of how a busy consular officer can be misled by the Department's summary charts. The chart that consular officers are asked to use as a handy reference for understanding the applicability of the provisions of INA 222(g) has been updated. As a reminder, INA 222(g) generally renders void the visas of nonimmigrants who remain in the United States "beyond the period of stay authorized by the Secretary of Homeland Security".
When does INA 222(g) not apply? Examples included in the chart include:
"Alien admitted until specified date; maintains status; departs by date specified."
"Alien admitted until specified date; violates status; departs by date specified."
When does INA 222(g) apply? Examples given in the chart include:
"Alien admitted until specified date; maintains status; departs after date specified."
"Alien admitted until specified date; stays beyond specified date; but granted voluntary departure."
But note: The chart is terribly misleading in indicating that the following scenario is one in which INA 222(g) does apply:
"Alien admitted until specified date; applies in timely fashion for extension or change of status; departs the U.S. after expiration of Form I-94, but before a decision on the Form I-94 extension/change of status application."
The busy consular officer relying on this summary chart may not be aware that the substantive FAM provisions at 9 FAM 40.68 N2.2-3 actually provide otherwise:
"An alien is not ineligible under INA 222(g) even though the departure date on Form I-94, Arrival-Departure Record, passes, if:
(1) The alien files a timely application for extension of stay or for a change of status; and
(2) The application is subsequently approved. In addition, if an alien departs after the date on the Form I-94 passes, but before his or her application for extension or change of status has been decided by the Bureau of Citizenship and Immigrations Service (BCIS), they shall be subject to a blanket exemption from INA 222(g), if the application was filed in a "timely manner" and is "nonfrivolous" in nature. A consular officer may consider an application nonfrivolous if it is not, on its face, a groundless excuse for the applicant to remain in the United States to engage in activities incompatible with his or her status." (emphasis added.)
Officers and attorneys interested in delving deeper into this subject should have a look at USCIS's May 2009 consolidated guidance concerning unlawful presence (see especially the discussion on the "tolling" of unlawful presence starting at page 32). http://www.uscis.gov/files/nativedocuments/revision_redesign_AFM.PDF
Information Media and Reciprocity (9 FAM 41.52)
The Department justifiably believes that we should not allow foreign media representatives unrestricted access to our country if their own respective governments hinder the activities of American media representatives. Consular officers are urged to report to Washington any limitations imposed by their host countries on the local employment of representatives of the U.S. information media. These data are needed to help the Department ensure that the admission to the U.S. of foreign media representatives is done on the basis of reciprocity.
Ministers of Religion (9 FAM 41.31)
New guidance clarifying that ministers may engage in evangelical tours in B-1 status, provided they do not take an appointment with any one church and are supported by offerings contributed at each evangelical meeting.
This FAM guidance should be read in conjunction with an earlier 2009 cable that in essence pleads with consular officers to issue B-1 visas to missionaries who are ineligible for R-1 visas, in order to avoid the wrath of Congress and the religious community.
Nonimmigrant Status (9 FAM 41.11)
Reworded text underlining two of the basic principles of nonimmigrant status:
- To ensure uniformity in explaining legal requirements to visa applicants;
- To reduce the need for individual correspondence and to minimize any misunderstandings arising from this correspondence;
- To eliminate needless files and record keeping
"P" Visas and Immigrant Intent (9 FAM 41.46)
New language in the FAM section relating to the P nonimmigrant classification clarifies the impact of immigrant intent on eligibility for P status. Per this language, a foreign national may legitimately come to the U.S. for a temporary period as a P nonimmigrant and, at the same time, lawfully seek to become a permanent resident of the U.S. (Essential support personnel are not included in this benevolent provision.)
Private Immigration Bills (9 FAM Appendix I, Exhibit X)
Notice of new rules of procedure and statement of policy for private immigration bills, as expressed by the House Subcommittee on Immigration, Citizenship, Refugees, Border Security, and International Law (110th Congress).
The new statement of policy creates a brave new world for private immigration bills, one in which only cases of "extraordinary nature" will have a chance of being passed. The new chill on private immigration bills can be felt by remarks such as the following:
(1) Doctors: "The Subcommittee is dismayed to find that doctors who are beneficiaries of private laws often seek more lucrative employment upon gaining permanent residence, thereby leaving medically underserved areas without any medical assistance. Because of these experiences, the Subcommittee views doctor bills unsympathetically."
(2) Medical Cases: "The Subcommittee will be reluctant to schedule bills on behalf of persons who entered the United States for the purpose of seeking medical treatment. Many cases have come to the attention of the Subcommittee in which persons obtained admission to the United States for medical reasons and decided to stay here permanently…. Persons may seek all available medical assistance while in the United States, but upon completion of any medical treatment the purpose of the visa expires and the alien must return home."
(3) Deferred Action and Parole Cases: "The Subcommittee will be reluctant to schedule any bill on behalf of an alien who is in 'deferred' status or has been paroled into the United States indefinitely. It is the Subcommittee's understanding that the Department of Homeland Security reserves the conferral of such status to cases of a particularly compelling nature. In view of this, the Subcommittee will view such cases unsympathetically."
- Foreign nationals who fail to maintain nonimmigrant status will be subject to removal or other measures to enforce removal from the United States.
- The most significant restriction on activities of nonimmigrants relates to employment.
(4) Draft Evaders: "There are few precedents for favorable action on behalf of aliens who seek permanent residency to avoid conscription. It will be the Subcommittee's policy to continue to view such bills unsympathetically."
(5) Visa Fraud: "The Subcommittee has been extremely reluctant to act favorable on cases involving visa fraud. It will be the policy of the Subcommittee to adhere closely to precedents in such cases."
(6) Naturalization: "The Subcommittee will require that any bill expediting naturalization be accompanied by evidence indicating that such actions would be in the national interest as opposed to personal interest. It is the Subcommittee's intent generally to view unfavorably legislation of this type. The Subcommittee is extremely concerned by requests to expedite citizenship on behalf of athletes seeking to compete in national, international, or Olympic games. The Subcommittee does not believe U.S. citizenship should be provided because of a person's athletic ability."
Residence and Place of Abode (9 FAM 41.11 and 9 FAM 41.31)
The term "place of abode," which is an essential element of the definition of "residence" under INA(a)(33), has been clarified Per this clarification, "residence" means the place of general abode; the "place of general abode," in turn, means a person's principal, actual dwelling place in fact, without regard to intent.
Student Visa Abusers (9 FAM 40.67)
New guidance emphasizing that current immigration law intends to prevent F-1 students from being educated at public expense. In particular, a foreign national who violates the provisions of INA 214(m) is inadmissible until he or she has been outside the United States for a continuous period of five years.
NOTE: The provisions of INA 214(m) are discussed at 9 FAM 41.61 N11. In a nutshell, 214(m) provides for two principal restrictions on the use of F-1 visas: (1) F-1 visas cannot be issued to persons seeking to enter the United States in order to attend a public primary school or a publicly funded adult education program. (2) Intending F-1 students at public high schools cannot attend such school for more than 12 months and must repay the school system for the full, unsubsidized, per capita cost of providing the education to him or her.
Supporting Documentation (9 FAM 41.101)
The FAM provisions relating to supporting documentation in nonimmigrant visa cases have been modified by the addition of the following comment:
"If local documents are unreliable, easily and often forged, or otherwise implausible, you should consider the utility of requiring them of applicants as they add no value to the NIV adjudication."
Officers in training receive a reference called The NIV Interviewing Handbook, an informal, homespun manual that's chock-a-block with visa interviewing wisdom. Somewhat oddly, one of the sections mentions "Docu-Cat," by which it is implied that documents are like cats: If they're so difficult to live with, why have them around at all? (The argument is that you can make decisions that are just as valid without looking at paper anyway. Document requirements may serve to simply line the pockets of paper vendors; another problem with requiring certain pieces of paper is that applicants may believe that if they check off every item on the list, then they're guaranteed a visa.)
The above addition to the FAM seems to put some official teeth (claws?) behind that recommendation, and the Department is now apparently making an official suggestion that consular posts in fraud-prone societies just refuse to accept supporting documents at all.
Tibetans and IVs (9 FAM 42.73)
Current policy is to show "China" as the country of chargeability and/or place of birth on the immigrant visas of applicants of Tibetan origin. According to the Department, these Tibetan applicants have on occasion "vehemently protested" against this policy. Still, the Department reaffirms that Tibet is part of China for visa chargeability purposes.
TN Family Members (9 FAM 41.59)
Revised guidance connected with the spouses and minor children of TN professionals. This guidance includes the following points:
Visa Annotations (9 FAM 41.31)
Consular officers are newly encouraged to place notations on nonimmigrant visas where such notations would be helpful to DHS inspectors or other consular officers in the future. Still, the Department warns that these visa notations should be "positive" in nature. What is an example of a positive notation? "VISIT UNCLE SAN FRANCISCO, THREE WEEKS." What is an example of a "negative" (and thus unhelpful) annotation? "NO EXTENSION OF STAY RECOMMENDED," which in essence tells DHS what to do or which questions the foreign national's veracity.
Parenthetically, this same language appears in an extended form at 9 FAM 113 PN12, which provides:
"Under no circumstances should an annotation prohibit activity in the United States which would be permitted under the visa category, or prohibit the alien from seeking an extension or adjustment of status. These questions are appropriately the responsibility of immigration inspectors and the DHS."
About that "veracity" comment: Reading between the lines, the Department is probably emphasizing to officers that if they have questions about the applicant's veracity, then they shouldn't be issuing the visa in the first place.
Are You Smarter Than A Junior Consular Officer?
(1) True or false: Silence or the failure to volunteer information does not in itself constitute a misrepresentation for the purposes of INA 212(a)(6)(C)(i).
(2) What can you expect a consular officer to do if a visa applicant shows a CLASS entry of "DPT-OO?"
- TN family members may be admitted to the U.S. in the TD classification. TD nonimmigrants are permitted to attend school but not accept employment.
- Non-Canadian or non-Mexican family members are entitled to TD visas; no problem in issuing these visas in non-Canadian or non-Mexican passports.
- The reciprocity schedule of the TN principal governs. For example, a Chinese spouse married to a Canadian TN status holder would be issued a TD visa in his or her Chinese passport based on the Canadian reciprocity schedule.
(a) Proceed to visa issuance; a previous CLASS entry has been deleted.
(b) Refer the visa applicant to a panel physician.
(c) Request a Security Advisory Opinion - this case requires Washington's input.
(3) True or false: A consular officer may require a visa applicant to relinquish his or her Permanent Resident Card as a condition to issuance of a nonimmigrant visa.
(4) What is the maximum period of attendance at public secondary schools permitted for foreign nationals in F-1 status?
(5) True or false: A misrepresentation made by a visa applicant to a panel physician is one which falls within the purview of INA 212(a)(6)(C)(i).
(6) Which four nonimmigrant visa categories are involved in the visa related provisions of NAFTA?
(7) True or false: Derivative beneficiaries are entitled to apply for visas to follow and/or join principals who are maintaining status in the United States, even when the principal was never issued a visa in the classification being sought by the dependent.
(8) Name five visa categories in which foreign nationals are required to maintain a residence abroad.
(9) Which Visa Office Division is responsible for security and terrorism issues related to a foreign national's visa application?
(a) Advisory Opinions Division
(b) Coordination Division
(c) Waiver Review Division
(10) Warren Delano, Acting Consul for the United States in Canton and Macao in the 1840s, was grandfather of which U.S. President?
Top Ten Visa Wait Times at U.S. Consular Posts, November 2009
Havana's wait times have swelled by 77 days over the last two months, and are closing in on the once unimaginable mark of 900 days. Caracas has not budged from the #2 slot all year; it began 2009 with a wait time of 200 days and could welcome in 2010 at 300 days. The bad days of big wait times in Brazil may be back: two Brazilian posts have surged into the Top Ten list with a third just one day behind.
Updated to November 2009 and based on published Department of State data. The "visa wait time" is the estimated time in which individuals need to wait to obtain a nonimmigrant visa interview appointment at a given consular post.
Top Wait Times by Region:
The Americas (excluding Cuba) Venezuela/Caracas (270 days)
||US Consular Post
||Visa Wait Time
||Increase/Decrease from last month
||Top 10 Position Last Month
||US Interests Section Havana
||+ 21 days
||+ 25 days
||+ 10 days
||+ 11 days
||+ 13 days
||+ 30 days
||+ 7 days
||+ 11 days
Middle East and North Africa Saudi Arabia/Dhahran (110 days)
Europe and Eurasia Montenegro/Podgorica (78 days)
Africa Nigeria/Lagos (40 days)
East Asia and Pacific Singapore (30 days)
Central and South Asia Kyrgyzstan/Bishkek (14 days)
Answers to "Are You Smarter Than A Junior Consular Officer?"
1. True.9 FAM 40.63 N4.2
3. False. 9 FAM 42.22 N4.1
4. 12 months. 9 FAM 40.67 N9
5. False. 9 FAM 40.63 N4.3
6. Temporary Visitors for business (B-1); Treaty Trader and Investors (E); Intra-company transferees (L), and NAFTA professionals (TN). 9 FAM 41.59 N1
7. True. 9 FAM 41.11 N6
8. B, F, H (except H-1), J, M, O-2, P, and Q. 9 FAM 41.31 N2.1
10. Franklin Delano Roosevelt.
Quote of the Corner
"I've seen much of the rest of the world. It is brutal and cruel and dark, Rome is the light.' - Russell Crowe as Maximus"
Offered by "No Double Standards" at Calling a Spade a Spade as one of the principles guiding his service as a consular officer.
All rights reserved to the author.
About The Author
Liam Schwartz is a principal in Liam Schwartz & Associates, a corporate relocation law firm. He can be reached at: Liam@lsa-law.com.
The opinions expressed in this article do not necessarily reflect the opinion of ILW.COM.
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