Furthermore, reunification is not viable with mother. Although it is only Xxxxxx’s necessary that this court finds that reunification with of parents is not viable, one Xxxxxx’s reunification is also not viable with mother based on the threats to safety Xxxxxx’s Xxxxxx’s that Xxxxxx faced under his care. Xxxxxx was subjected to numerous death threats by mother’s the violent gang members who had already killed a member of his family. e. It is not in the best interest to return to their country of origin. child’s It is not in best interest to be returned to Home Country. There is no one in Xxxxxx’s home country that can protect him from gang violence. After the murder of his cousin Xxxxxx’s by gang members, Xxxxxx began to receive targeted death threats by gang members. He fears the gangs that threatened and harassed him in Home Country, and believes that he will be killed should he return to Home Country. The situation Xxxxxx and his family faced in Home Country convinced him that he needed to leave for the United States. Xxxxxx is presently living with his aunt and wishes to remain in her care. aunt Xxxxxx’s has enrolled Xxxxxx in high school and provides for his needs. It is in best interest to Xxxxxx’s remain in the United States in the custody of his aunt, where he is well cared for. ACCORDINGLY, the Petitioner respectfully requests that this Court enter the attached order making factual findings regarding his eligibility for special immigrant juvenile status. A Proposed Order is attached. Respectfully Submitted, Attorney Name, Esq. (VSB #xxxx) Attorney Address Phone Number
Furthermore, reunification is not viable with Xxxxxx’s mother. Although it is only necessary that this court finds that reunification with one of Xxxxxx’s parents is not viable, reunification is also not viable with Xxxxxx’s mother based on the threats to Xxxxxx’s safety that Xxxxxx faced under his mother’s care. Xxxxxx was subjected to numerous death threats by the violent gang members who had already killed a member of his family. e. It is not in the child’s best interest to return to their country of origin. It is not in Xxxxxx’s best interest to be returned to Home Country. There is no one in Xxxxxx’s home country that can protect him from gang violence. After the murder of his cousin by gang members, Xxxxxx began to receive targeted death threats by gang members. He fears the gangs that threatened and harassed him in Home Country, and believes that he will be killed should he return to Home Country. The situation Xxxxxx and his family faced in Home Country convinced him that he needed to leave for the United States. Xxxxxx is presently living with his aunt and wishes to remain in her care. Xxxxxx’s aunt has enrolled Xxxxxx in high school and provides for his needs. It is in Xxxxxx’s best interest to remain in the United States in the custody of his aunt, where he is well cared for. ACCORDINGLY, the Petitioner respectfully requests that this Court enter the attached order making factual findings regarding his eligibility for special immigrant juvenile status. A Proposed Order is attached. Respectfully Submitted, Attorney Name, Esq. (VSB #xxxx) Attorney Address Phone Number
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