The Massachusetts Law Reform Institute (MLRI) respectfully submits this comment on behalf of the Immigration Coalition (IMCO) of the Massachusetts Law Reform Institute, which consists of the 14 regional legal aid programs in the Commonwealth of Massachusetts, including Greater Boston Legal Services, the largest and oldest legal service provider in New England and co-founder of the coalition, along with 140 other immigration service providers, representing thousands of low-income immigrants in the state and the region. A list and brief description of the coalition members signing on to these comments individually is attached as an Appendix. We submit these comments to oppose the Department of Homeland Security and Department of Justice’s Notice of Proposed Rulemaking entitled “Procedures for Asylum and Withholding of Removal; Credible Fear and Reasonable Fear Review Applicants”, EOIR Docket No. 18-0002 (published in the Federal Register on June 15th, 2020), and urge that the Proposed Rule be withdrawn.
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