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Dear Editor:
I concur wholeheartedly with Mr. Murray's assessment, the fact that the petition controls, whether it be the I-129S in the case of a Blanket, or an I-129H - was part of what was cropped from my letter. However, my point in raising the issue was not to seek assistance in advising clients, but rather to highlight these errors in the context of allegations of abuse of the L-1 program. If corporate petitioners are coming under fire, then the government should make sure it's house is in order. Then of course there are the security concerns involved when an alien is given a visa or an authorized stay much longer than that to which he is entitled. It is also true that some authorized stays are granted for less than the petition allows, and in these cases, the client is in jeopardy of falling out of status. I don't believe that aliens routinely send copies of their I-94's from each entry into the U.S. to their counsel, and the "last action rule" could create a situation where, though the petition remains valid, the I-94 has expired, and the client is technically out of status. I don't believe that it is acceptable for an L1 visa holder to be given a different authorized stay each time he enters the U.S. under the same petition and visa. Certainly, isolated mistakes are the result of simple human error, but I contend that the errors made with L visas and authorized stays, particularly under a Blanket approval, are due to misconceptions about the the program by consular and BP officials. In my experience they are far more than occasional. I believe that CIS should devote some resources to educating consular and BP officials on the L rules before passing legislation to further restrict the program.

SJD



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