Need some advice on I140 RFE

grncrdskr

Registered Users (C)
Dear forum contributors,

Thank you for taking the time to read my post. I will summarize my pending case and ask the question at the end. Please read patiently.

1) I submitted my initial I140(Texas Service Center) on June of 2007 and got a first RFE on August the 16, 2007 with a 6 weeks response time. My attorney with the help of the company responded to the RFE with all the evidence requested including an expert opinion of a CPA. Basically the evidence requested was "ability to pay." The lawyer's office do have the courier service's receipt showing that thesubmission of first RFE was indeed deliverd to and received by USCIS.My company told me that the online website(CRIS) never updated to reflect the first RFE was issued. After the response was submitted the website never updated to receiving the first RFE submission and resume processing.There was no response from USCIS until a second RFE was sent.

2) According to my attorney the second RFE is identical to the first except the officer number that issued the RFE. To my surprise the online website(CRIS) has an updated status for my second RFE issued. There is no mention of receiving, reviewing, denying or requesting lack of evidence based on the first RFE submitted. USCIS did not even reference the first RFE on the second RFE. My second RFE is due in 3 weeks. Now my attorney wants to respond to the second RFE as though the first RFE was reviewed and further evidence is requested. My attorney decided that the best practice is to treat
this second RFE as if it is a Notice of Intent to Deny. That means that they have to make any and all arguments to preserve the clients right to argue them on appeal a necessary.She plans to resubmit the CPA letter supporting the ability to pay of the company the second time with supporting arguments.
My questions are:

1) Since USCIS never mentioned the first RFE while issuing the second RFE. Is there a mechanism to find out if the first RFE was ever reviewed? This is important since if it was USCIS's error then why submit a second response.

2) what if USCIS made a mistake of issuing a second RFE without acknowledging the first RFE?

3) What is my course of action should be? I am having a difficult time convincing my attorney to provide some options.

4) In my first RFE response we included an expert CPA opinion on ability to pay and company do have the ability to pay. Since the second RFE never mentioned the CPA opinion, I am worried that the second response will be a repetition.

Please advice what I should suggest to my attorney to do. I requested that they request an inquiry to what happened to my first response on my first RFE. At the beginning, the attorney said there is no such inquiry mechanism with the USCIS. After insisting about the importance of the first RFE status and outcome,the lawyer's office did finally called-in to follow-up on my first RFE.

When the lawyer's office called-in, the IO representative could not find any evidence of my first RFE issued by USCIS on August and receiving my response to first RFE from my lawyer's office on end of September. The only status available was the statement of my second RFE been issued and mailed
out. My I-140 application has already passed the processing time frame. My lawyer's office did receive the second RFE. I would appreciate all the help and all the responses to this thread. Please share your thoughts and experiences with me. Thank you in advance.
 
IMO, if there is no trace of first RFE anywhere, it is not too big a deal. Yes, it is important to know what happened to 1st RFE and the response, but for now, just forget about 1st one and focus on the one in hand. Remember, this is just my opinion.

You have not provided any details how the company has the Ability to Pay (A2P). So I hope you/employer/lawyer/CPA have done a good job of proving the A2P. If you want, you can provide details about how you are proving A2P, someone should be able to say if that is good enough or not. In addition to what you sent for 1st RFE, provide some additional evidence of A2P also.
 
Thank you very much for your respond and sharing your experiences, EricS. My company showed its A2P based on net asset and it has the ability to pay me. I don't know whether this second RFE is a flow-up on the first RFE after USCIS read my first RFE or its the first time USCIS is asking for RFE.

So, you suggest that I should resubmit the A2P evidence one more time and provide any other evidence on top of it? right? I am worried that I might repeat myself by providing the same evidence. I was hoping that I could find out in advance before I proceed with the second RFE.
 
Yes, that is my suggestion. Mixups like this happen some times at USCIS, there is no harm in providing the whole evidence again. You should try to find what happened to first one but do not delay the response to 2nd RFE.
 
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