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Advanced Motions to Reopen and Reconsider

The One-Motion Rule After Matter of M-M-L-J-

INA §240(c)(7)(A) generally permits one motion to reopen. This page addresses filing, evidence, exceptions, and current EOIR practice.

Reviewed by Peter Messersmith September 17, 2026
Direct Answer

INA §240(c)(7)(A) generally permits one motion to reopen. Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar.

Core Standard

M-M-L-J one-motion rule core standard starts with the final order. M-M-L-J one-motion rule core standard identifies the current tribunal. M-M-L-J one-motion rule core standard applies this rule: INA §240(c)(7)(A) generally permits one motion to reopen. M-M-L-J one-motion rule core standard checks every prior motion. M-M-L-J one-motion rule core standard states the requested remedy. M-M-L-J one-motion rule core standard separates reopening from reconsideration. M-M-L-J one-motion rule core standard identifies any claimed exception.

M-M-L-J one-motion rule core standard uses evidence tied to procedure. M-M-L-J one-motion rule core standard avoids unsupported factual assertions. M-M-L-J one-motion rule core standard applies this additional rule: Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar. M-M-L-J one-motion rule core standard cites affidavits and exhibits precisely. M-M-L-J one-motion rule core standard explains prior unavailability when required. M-M-L-J one-motion rule core standard addresses contrary record material. M-M-L-J one-motion rule core standard connects procedure to requested relief.

M-M-L-J one-motion rule core standard should produce a reviewable ruling. M-M-L-J one-motion rule core standard preserves timeliness disputes. M-M-L-J one-motion rule core standard preserves numerical-limit disputes. M-M-L-J one-motion rule core standard applies this preservation rule: A timely motion can still fail when it is numerically barred. M-M-L-J one-motion rule core standard records the DHS position. M-M-L-J one-motion rule core standard requests findings on disputed requirements. M-M-L-J one-motion rule core standard treats any stay separately.

Authority

M-M-L-J one-motion rule authority starts with the final order. M-M-L-J one-motion rule authority identifies the current tribunal. M-M-L-J one-motion rule authority applies this rule: Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. M-M-L-J one-motion rule authority checks every prior motion. M-M-L-J one-motion rule authority states the requested remedy. M-M-L-J one-motion rule authority separates reopening from reconsideration. M-M-L-J one-motion rule authority identifies any claimed exception.

M-M-L-J one-motion rule authority uses evidence tied to procedure. M-M-L-J one-motion rule authority avoids unsupported factual assertions. M-M-L-J one-motion rule authority applies this additional rule: The statute contains a limited exception for qualifying battered spouses, children, and parents. M-M-L-J one-motion rule authority cites affidavits and exhibits precisely. M-M-L-J one-motion rule authority explains prior unavailability when required. M-M-L-J one-motion rule authority addresses contrary record material. M-M-L-J one-motion rule authority connects procedure to requested relief.

M-M-L-J one-motion rule authority should produce a reviewable ruling. M-M-L-J one-motion rule authority preserves timeliness disputes. M-M-L-J one-motion rule authority preserves numerical-limit disputes. M-M-L-J one-motion rule authority applies this preservation rule: INA §240(c)(7)(A) generally permits one motion to reopen. M-M-L-J one-motion rule authority records the DHS position. M-M-L-J one-motion rule authority requests findings on disputed requirements. M-M-L-J one-motion rule authority treats any stay separately.

Forum

M-M-L-J one-motion rule forum starts with the final order. M-M-L-J one-motion rule forum identifies the current tribunal. M-M-L-J one-motion rule forum applies this rule: Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar. M-M-L-J one-motion rule forum checks every prior motion. M-M-L-J one-motion rule forum states the requested remedy. M-M-L-J one-motion rule forum separates reopening from reconsideration. M-M-L-J one-motion rule forum identifies any claimed exception.

M-M-L-J one-motion rule forum uses evidence tied to procedure. M-M-L-J one-motion rule forum avoids unsupported factual assertions. M-M-L-J one-motion rule forum applies this additional rule: A timely motion can still fail when it is numerically barred. M-M-L-J one-motion rule forum cites affidavits and exhibits precisely. M-M-L-J one-motion rule forum explains prior unavailability when required. M-M-L-J one-motion rule forum addresses contrary record material. M-M-L-J one-motion rule forum connects procedure to requested relief.

M-M-L-J one-motion rule forum should produce a reviewable ruling. M-M-L-J one-motion rule forum preserves timeliness disputes. M-M-L-J one-motion rule forum preserves numerical-limit disputes. M-M-L-J one-motion rule forum applies this preservation rule: Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. M-M-L-J one-motion rule forum records the DHS position. M-M-L-J one-motion rule forum requests findings on disputed requirements. M-M-L-J one-motion rule forum treats any stay separately.

Deadline

M-M-L-J one-motion rule deadline starts with the final order. M-M-L-J one-motion rule deadline identifies the current tribunal. M-M-L-J one-motion rule deadline applies this rule: The statute contains a limited exception for qualifying battered spouses, children, and parents. M-M-L-J one-motion rule deadline checks every prior motion. M-M-L-J one-motion rule deadline states the requested remedy. M-M-L-J one-motion rule deadline separates reopening from reconsideration. M-M-L-J one-motion rule deadline identifies any claimed exception.

M-M-L-J one-motion rule deadline uses evidence tied to procedure. M-M-L-J one-motion rule deadline avoids unsupported factual assertions. M-M-L-J one-motion rule deadline applies this additional rule: INA §240(c)(7)(A) generally permits one motion to reopen. M-M-L-J one-motion rule deadline cites affidavits and exhibits precisely. M-M-L-J one-motion rule deadline explains prior unavailability when required. M-M-L-J one-motion rule deadline addresses contrary record material. M-M-L-J one-motion rule deadline connects procedure to requested relief.

M-M-L-J one-motion rule deadline should produce a reviewable ruling. M-M-L-J one-motion rule deadline preserves timeliness disputes. M-M-L-J one-motion rule deadline preserves numerical-limit disputes. M-M-L-J one-motion rule deadline applies this preservation rule: Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar. M-M-L-J one-motion rule deadline records the DHS position. M-M-L-J one-motion rule deadline requests findings on disputed requirements. M-M-L-J one-motion rule deadline treats any stay separately.

Number Rule

M-M-L-J one-motion rule number rule starts with the final order. M-M-L-J one-motion rule number rule identifies the current tribunal. M-M-L-J one-motion rule number rule applies this rule: A timely motion can still fail when it is numerically barred. M-M-L-J one-motion rule number rule checks every prior motion. M-M-L-J one-motion rule number rule states the requested remedy. M-M-L-J one-motion rule number rule separates reopening from reconsideration. M-M-L-J one-motion rule number rule identifies any claimed exception.

M-M-L-J one-motion rule number rule uses evidence tied to procedure. M-M-L-J one-motion rule number rule avoids unsupported factual assertions. M-M-L-J one-motion rule number rule applies this additional rule: Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. M-M-L-J one-motion rule number rule cites affidavits and exhibits precisely. M-M-L-J one-motion rule number rule explains prior unavailability when required. M-M-L-J one-motion rule number rule addresses contrary record material. M-M-L-J one-motion rule number rule connects procedure to requested relief.

M-M-L-J one-motion rule number rule should produce a reviewable ruling. M-M-L-J one-motion rule number rule preserves timeliness disputes. M-M-L-J one-motion rule number rule preserves numerical-limit disputes. M-M-L-J one-motion rule number rule applies this preservation rule: The statute contains a limited exception for qualifying battered spouses, children, and parents. M-M-L-J one-motion rule number rule records the DHS position. M-M-L-J one-motion rule number rule requests findings on disputed requirements. M-M-L-J one-motion rule number rule treats any stay separately.

Evidence

M-M-L-J one-motion rule evidence starts with the final order. M-M-L-J one-motion rule evidence identifies the current tribunal. M-M-L-J one-motion rule evidence applies this rule: INA §240(c)(7)(A) generally permits one motion to reopen. M-M-L-J one-motion rule evidence checks every prior motion. M-M-L-J one-motion rule evidence states the requested remedy. M-M-L-J one-motion rule evidence separates reopening from reconsideration. M-M-L-J one-motion rule evidence identifies any claimed exception.

M-M-L-J one-motion rule evidence uses evidence tied to procedure. M-M-L-J one-motion rule evidence avoids unsupported factual assertions. M-M-L-J one-motion rule evidence applies this additional rule: Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar. M-M-L-J one-motion rule evidence cites affidavits and exhibits precisely. M-M-L-J one-motion rule evidence explains prior unavailability when required. M-M-L-J one-motion rule evidence addresses contrary record material. M-M-L-J one-motion rule evidence connects procedure to requested relief.

M-M-L-J one-motion rule evidence should produce a reviewable ruling. M-M-L-J one-motion rule evidence preserves timeliness disputes. M-M-L-J one-motion rule evidence preserves numerical-limit disputes. M-M-L-J one-motion rule evidence applies this preservation rule: A timely motion can still fail when it is numerically barred. M-M-L-J one-motion rule evidence records the DHS position. M-M-L-J one-motion rule evidence requests findings on disputed requirements. M-M-L-J one-motion rule evidence treats any stay separately.

Materiality

M-M-L-J one-motion rule materiality starts with the final order. M-M-L-J one-motion rule materiality identifies the current tribunal. M-M-L-J one-motion rule materiality applies this rule: Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. M-M-L-J one-motion rule materiality checks every prior motion. M-M-L-J one-motion rule materiality states the requested remedy. M-M-L-J one-motion rule materiality separates reopening from reconsideration. M-M-L-J one-motion rule materiality identifies any claimed exception.

M-M-L-J one-motion rule materiality uses evidence tied to procedure. M-M-L-J one-motion rule materiality avoids unsupported factual assertions. M-M-L-J one-motion rule materiality applies this additional rule: The statute contains a limited exception for qualifying battered spouses, children, and parents. M-M-L-J one-motion rule materiality cites affidavits and exhibits precisely. M-M-L-J one-motion rule materiality explains prior unavailability when required. M-M-L-J one-motion rule materiality addresses contrary record material. M-M-L-J one-motion rule materiality connects procedure to requested relief.

M-M-L-J one-motion rule materiality should produce a reviewable ruling. M-M-L-J one-motion rule materiality preserves timeliness disputes. M-M-L-J one-motion rule materiality preserves numerical-limit disputes. M-M-L-J one-motion rule materiality applies this preservation rule: INA §240(c)(7)(A) generally permits one motion to reopen. M-M-L-J one-motion rule materiality records the DHS position. M-M-L-J one-motion rule materiality requests findings on disputed requirements. M-M-L-J one-motion rule materiality treats any stay separately.

Exceptions

M-M-L-J one-motion rule exceptions starts with the final order. M-M-L-J one-motion rule exceptions identifies the current tribunal. M-M-L-J one-motion rule exceptions applies this rule: Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar. M-M-L-J one-motion rule exceptions checks every prior motion. M-M-L-J one-motion rule exceptions states the requested remedy. M-M-L-J one-motion rule exceptions separates reopening from reconsideration. M-M-L-J one-motion rule exceptions identifies any claimed exception.

M-M-L-J one-motion rule exceptions uses evidence tied to procedure. M-M-L-J one-motion rule exceptions avoids unsupported factual assertions. M-M-L-J one-motion rule exceptions applies this additional rule: A timely motion can still fail when it is numerically barred. M-M-L-J one-motion rule exceptions cites affidavits and exhibits precisely. M-M-L-J one-motion rule exceptions explains prior unavailability when required. M-M-L-J one-motion rule exceptions addresses contrary record material. M-M-L-J one-motion rule exceptions connects procedure to requested relief.

M-M-L-J one-motion rule exceptions should produce a reviewable ruling. M-M-L-J one-motion rule exceptions preserves timeliness disputes. M-M-L-J one-motion rule exceptions preserves numerical-limit disputes. M-M-L-J one-motion rule exceptions applies this preservation rule: Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. M-M-L-J one-motion rule exceptions records the DHS position. M-M-L-J one-motion rule exceptions requests findings on disputed requirements. M-M-L-J one-motion rule exceptions treats any stay separately.

DHS Response

M-M-L-J one-motion rule dhs response starts with the final order. M-M-L-J one-motion rule dhs response identifies the current tribunal. M-M-L-J one-motion rule dhs response applies this rule: The statute contains a limited exception for qualifying battered spouses, children, and parents. M-M-L-J one-motion rule dhs response checks every prior motion. M-M-L-J one-motion rule dhs response states the requested remedy. M-M-L-J one-motion rule dhs response separates reopening from reconsideration. M-M-L-J one-motion rule dhs response identifies any claimed exception.

M-M-L-J one-motion rule dhs response uses evidence tied to procedure. M-M-L-J one-motion rule dhs response avoids unsupported factual assertions. M-M-L-J one-motion rule dhs response applies this additional rule: INA §240(c)(7)(A) generally permits one motion to reopen. M-M-L-J one-motion rule dhs response cites affidavits and exhibits precisely. M-M-L-J one-motion rule dhs response explains prior unavailability when required. M-M-L-J one-motion rule dhs response addresses contrary record material. M-M-L-J one-motion rule dhs response connects procedure to requested relief.

M-M-L-J one-motion rule dhs response should produce a reviewable ruling. M-M-L-J one-motion rule dhs response preserves timeliness disputes. M-M-L-J one-motion rule dhs response preserves numerical-limit disputes. M-M-L-J one-motion rule dhs response applies this preservation rule: Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar. M-M-L-J one-motion rule dhs response records the DHS position. M-M-L-J one-motion rule dhs response requests findings on disputed requirements. M-M-L-J one-motion rule dhs response treats any stay separately.

Respondent Proof

M-M-L-J one-motion rule respondent proof starts with the final order. M-M-L-J one-motion rule respondent proof identifies the current tribunal. M-M-L-J one-motion rule respondent proof applies this rule: A timely motion can still fail when it is numerically barred. M-M-L-J one-motion rule respondent proof checks every prior motion. M-M-L-J one-motion rule respondent proof states the requested remedy. M-M-L-J one-motion rule respondent proof separates reopening from reconsideration. M-M-L-J one-motion rule respondent proof identifies any claimed exception.

M-M-L-J one-motion rule respondent proof uses evidence tied to procedure. M-M-L-J one-motion rule respondent proof avoids unsupported factual assertions. M-M-L-J one-motion rule respondent proof applies this additional rule: Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. M-M-L-J one-motion rule respondent proof cites affidavits and exhibits precisely. M-M-L-J one-motion rule respondent proof explains prior unavailability when required. M-M-L-J one-motion rule respondent proof addresses contrary record material. M-M-L-J one-motion rule respondent proof connects procedure to requested relief.

M-M-L-J one-motion rule respondent proof should produce a reviewable ruling. M-M-L-J one-motion rule respondent proof preserves timeliness disputes. M-M-L-J one-motion rule respondent proof preserves numerical-limit disputes. M-M-L-J one-motion rule respondent proof applies this preservation rule: The statute contains a limited exception for qualifying battered spouses, children, and parents. M-M-L-J one-motion rule respondent proof records the DHS position. M-M-L-J one-motion rule respondent proof requests findings on disputed requirements. M-M-L-J one-motion rule respondent proof treats any stay separately.

Drafting

M-M-L-J one-motion rule drafting starts with the final order. M-M-L-J one-motion rule drafting identifies the current tribunal. M-M-L-J one-motion rule drafting applies this rule: INA §240(c)(7)(A) generally permits one motion to reopen. M-M-L-J one-motion rule drafting checks every prior motion. M-M-L-J one-motion rule drafting states the requested remedy. M-M-L-J one-motion rule drafting separates reopening from reconsideration. M-M-L-J one-motion rule drafting identifies any claimed exception.

M-M-L-J one-motion rule drafting uses evidence tied to procedure. M-M-L-J one-motion rule drafting avoids unsupported factual assertions. M-M-L-J one-motion rule drafting applies this additional rule: Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar. M-M-L-J one-motion rule drafting cites affidavits and exhibits precisely. M-M-L-J one-motion rule drafting explains prior unavailability when required. M-M-L-J one-motion rule drafting addresses contrary record material. M-M-L-J one-motion rule drafting connects procedure to requested relief.

M-M-L-J one-motion rule drafting should produce a reviewable ruling. M-M-L-J one-motion rule drafting preserves timeliness disputes. M-M-L-J one-motion rule drafting preserves numerical-limit disputes. M-M-L-J one-motion rule drafting applies this preservation rule: A timely motion can still fail when it is numerically barred. M-M-L-J one-motion rule drafting records the DHS position. M-M-L-J one-motion rule drafting requests findings on disputed requirements. M-M-L-J one-motion rule drafting treats any stay separately.

Stay Issues

M-M-L-J one-motion rule stay issues starts with the final order. M-M-L-J one-motion rule stay issues identifies the current tribunal. M-M-L-J one-motion rule stay issues applies this rule: Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. M-M-L-J one-motion rule stay issues checks every prior motion. M-M-L-J one-motion rule stay issues states the requested remedy. M-M-L-J one-motion rule stay issues separates reopening from reconsideration. M-M-L-J one-motion rule stay issues identifies any claimed exception.

M-M-L-J one-motion rule stay issues uses evidence tied to procedure. M-M-L-J one-motion rule stay issues avoids unsupported factual assertions. M-M-L-J one-motion rule stay issues applies this additional rule: The statute contains a limited exception for qualifying battered spouses, children, and parents. M-M-L-J one-motion rule stay issues cites affidavits and exhibits precisely. M-M-L-J one-motion rule stay issues explains prior unavailability when required. M-M-L-J one-motion rule stay issues addresses contrary record material. M-M-L-J one-motion rule stay issues connects procedure to requested relief.

M-M-L-J one-motion rule stay issues should produce a reviewable ruling. M-M-L-J one-motion rule stay issues preserves timeliness disputes. M-M-L-J one-motion rule stay issues preserves numerical-limit disputes. M-M-L-J one-motion rule stay issues applies this preservation rule: INA §240(c)(7)(A) generally permits one motion to reopen. M-M-L-J one-motion rule stay issues records the DHS position. M-M-L-J one-motion rule stay issues requests findings on disputed requirements. M-M-L-J one-motion rule stay issues treats any stay separately.

Relief Effect

M-M-L-J one-motion rule relief effect starts with the final order. M-M-L-J one-motion rule relief effect identifies the current tribunal. M-M-L-J one-motion rule relief effect applies this rule: Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar. M-M-L-J one-motion rule relief effect checks every prior motion. M-M-L-J one-motion rule relief effect states the requested remedy. M-M-L-J one-motion rule relief effect separates reopening from reconsideration. M-M-L-J one-motion rule relief effect identifies any claimed exception.

M-M-L-J one-motion rule relief effect uses evidence tied to procedure. M-M-L-J one-motion rule relief effect avoids unsupported factual assertions. M-M-L-J one-motion rule relief effect applies this additional rule: A timely motion can still fail when it is numerically barred. M-M-L-J one-motion rule relief effect cites affidavits and exhibits precisely. M-M-L-J one-motion rule relief effect explains prior unavailability when required. M-M-L-J one-motion rule relief effect addresses contrary record material. M-M-L-J one-motion rule relief effect connects procedure to requested relief.

M-M-L-J one-motion rule relief effect should produce a reviewable ruling. M-M-L-J one-motion rule relief effect preserves timeliness disputes. M-M-L-J one-motion rule relief effect preserves numerical-limit disputes. M-M-L-J one-motion rule relief effect applies this preservation rule: Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. M-M-L-J one-motion rule relief effect records the DHS position. M-M-L-J one-motion rule relief effect requests findings on disputed requirements. M-M-L-J one-motion rule relief effect treats any stay separately.

Review

M-M-L-J one-motion rule review starts with the final order. M-M-L-J one-motion rule review identifies the current tribunal. M-M-L-J one-motion rule review applies this rule: The statute contains a limited exception for qualifying battered spouses, children, and parents. M-M-L-J one-motion rule review checks every prior motion. M-M-L-J one-motion rule review states the requested remedy. M-M-L-J one-motion rule review separates reopening from reconsideration. M-M-L-J one-motion rule review identifies any claimed exception.

M-M-L-J one-motion rule review uses evidence tied to procedure. M-M-L-J one-motion rule review avoids unsupported factual assertions. M-M-L-J one-motion rule review applies this additional rule: INA §240(c)(7)(A) generally permits one motion to reopen. M-M-L-J one-motion rule review cites affidavits and exhibits precisely. M-M-L-J one-motion rule review explains prior unavailability when required. M-M-L-J one-motion rule review addresses contrary record material. M-M-L-J one-motion rule review connects procedure to requested relief.

M-M-L-J one-motion rule review should produce a reviewable ruling. M-M-L-J one-motion rule review preserves timeliness disputes. M-M-L-J one-motion rule review preserves numerical-limit disputes. M-M-L-J one-motion rule review applies this preservation rule: Matter of M-M-L-J- holds that equitable tolling does not apply to the number bar. M-M-L-J one-motion rule review records the DHS position. M-M-L-J one-motion rule review requests findings on disputed requirements. M-M-L-J one-motion rule review treats any stay separately.

Checklist

M-M-L-J one-motion rule checklist starts with the final order. M-M-L-J one-motion rule checklist identifies the current tribunal. M-M-L-J one-motion rule checklist applies this rule: A timely motion can still fail when it is numerically barred. M-M-L-J one-motion rule checklist checks every prior motion. M-M-L-J one-motion rule checklist states the requested remedy. M-M-L-J one-motion rule checklist separates reopening from reconsideration. M-M-L-J one-motion rule checklist identifies any claimed exception.

M-M-L-J one-motion rule checklist uses evidence tied to procedure. M-M-L-J one-motion rule checklist avoids unsupported factual assertions. M-M-L-J one-motion rule checklist applies this additional rule: Matter of M-M-L-J- counts reopening motions filed with either the Immigration Court or the BIA toward the single-motion limit. M-M-L-J one-motion rule checklist cites affidavits and exhibits precisely. M-M-L-J one-motion rule checklist explains prior unavailability when required. M-M-L-J one-motion rule checklist addresses contrary record material. M-M-L-J one-motion rule checklist connects procedure to requested relief.

M-M-L-J one-motion rule checklist should produce a reviewable ruling. M-M-L-J one-motion rule checklist preserves timeliness disputes. M-M-L-J one-motion rule checklist preserves numerical-limit disputes. M-M-L-J one-motion rule checklist applies this preservation rule: The statute contains a limited exception for qualifying battered spouses, children, and parents. M-M-L-J one-motion rule checklist records the DHS position. M-M-L-J one-motion rule checklist requests findings on disputed requirements. M-M-L-J one-motion rule checklist treats any stay separately.

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Frequently Asked Questions

What is the central rule for Matter of M-M-L-J one motion reopen number bar?
M-M-L-J one-motion rule follows this rule: INA §240(c)(7)(A) generally permits one motion to reopen.
What deadline matters for Matter of M-M-L-J one motion reopen number bar?
M-M-L-J one-motion rule requires separate analysis of the ordinary 90-day reopening deadline, the 30-day reconsideration deadline, and any exception actually invoked.
What evidence matters for Matter of M-M-L-J one motion reopen number bar?
M-M-L-J one-motion rule uses evidence tied to the governing procedural requirement; reopening ordinarily depends on supported new facts while reconsideration ordinarily relies on the existing record.
Does Matter of M-M-L-J one motion reopen number bar automatically stay removal?
No. M-M-L-J one-motion rule does not itself create an automatic stay; a separate stay request may be necessary.
Can equitable tolling solve every limit affecting Matter of M-M-L-J one motion reopen number bar?
No. M-M-L-J one-motion rule must distinguish the time bar from the number bar, and Matter of M-M-L-J- holds that equitable tolling does not apply to the statutory number bar.
How should Matter of M-M-L-J one motion reopen number bar be preserved for review?
M-M-L-J one-motion rule should preserve forum, deadline, prior motions, exceptions, evidence, the DHS response, and the adjudicator's ruling.
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