The Board of Immigration Appeals has concluded that “[w]here a notice to appear fails to specify the time or place of a respondent’s initial removal hearing, the subsequent service of a notice of hearing specifying this information perfects the notice to appear and ends the accrual of physical presence for purposes of voluntary departure.”

The full text of Matter of Viera-Garcia can be found here:

https://www.justice.gov/eoir/page/file/1360626/download

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