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About fifteen years ago,in Guzman-Heredia v. Gonzales , No. 04-72769 (9th Cir.), a child appeared pro se and was ordered removed. J.E.F.M. , 837 F.3d at 1037. Pro bono counsel raised the issue of the child’s right to counsel before the Board of Immigration Appeals ("BIA"), but the case ultimately settled. Id . Since then, thousands of unrepresented children have been ordered removed. Transactional Records Access Clearinghouse, Representation for Unaccompanied Children in Immigration Court (Nov. 25, 2014), http://trac.syr.edu/immigration/reports/371/_(tracking over 27,000 children without counsel ordered removed in a ten-year span).
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