We previously circulated a sample brief,  Using and Defending PC 1473.7 Vacaturs. But, at times, DHS continues to object to 1473.7 vacaturs.  Thanks to Pangea Removal Defense Attorney Luis Angel Reyes Savalza for agreeing to share his recent redacted response to DHS opposition. This briefing includes a response as to why the 2019 amendments to 1473.7 do not, in fact, turn the statute into a rehabilitative mechanism.