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Matter of Nchifor, 28 I&N Dec. 585 (BIA 2022) - A respondent who raises an objection to missing time or place information in a notice to appear for the first time in a motion to reopen has forfeited that objection.
"We ... agree with the Fifth Circuit’s approach in Pierre-Paul and will apply it to motions to reopen filed outside the jurisdiction of the Seventh Circuit. Applying this approach, we conclude that the respondent, who raised an objection to the missing time or place information in his notice to appear for the first time in a motion to reopen, “waited too long to raise this issue” and forfeited his objection to this missing information."