See also U.S. Department of Justice, Executive Office for Immigration Review, Immigration Court Practice Manual, Chapter 2.2(c) “Address Obligations” (revised June 10, 2013), http://www.justice.gov/eoir/vll/OCIJPracManual/Practice_Manual_review.pdf#page=25. According to a study conducted by the Transactional Records Access Clearinghouse Immigration (“TRAC Immigration”) at Syracuse University, from fiscal year 2005 through June 2014, 31% of closed cases were marked “in absentia,” and those persons were consequently ordered removed. “New Data on Unaccompanied Children in Immigration Court,” (July 15, 2014), http://trac.syr.edu/immigration/reports/359/.
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