I'm working through the timeline for a legal memo. The admission date is February 1, 2014, and the notice came through November 15, 2020 but was incomplete until April 20, 2021 when the specification was finalized and the residence period ended. That gives us seven years, two months, and nineteen days total—and the seven-year threshold actually accrued by February 1, 2021, well before the April 20 completion date. There's also a cannabis citation from January 5, 2021 where there was a guilty plea involved.

For the cannabis offense, the key issue is whether it qualifies as a clock-stopping conviction. The guilty plea with deferred adjudication and probation imposed on March 10, 2021 technically creates a conviction under the applicable rule, but there's a critical exception: simple possession of five grams or less of cannabis—and this case involved four grams with no other controlled substance offenses—falls outside the clock-stopping and disqualifying categories. This exception is dispositive because if the cannabis offense were clock-stopping, the residence period would have ended on the commission date of January 5, 2021, which would have defeated eligibility by twenty-seven days. So the exception saves the case.

On the fraud matter, the actual loss was $8,900, and while restitution for audit expenses of $2,500 is excluded from the calculation, the remaining amount still falls below the $10,000 threshold, so it's neither disqualifying nor clock-stopping. The fraud occurred in 2018 anyway, which would have been catastrophic if it were a clock-stopping offense, so the rule text on what counts toward loss is critical to argue.

For the reckless injury conviction, the offense doesn't qualify as a crime of violence because the rule requires intentional or knowing force, not mere recklessness. Even though the fourteen-month sentence exceeds the one-year threshold, both the sentence and offense-element prongs must be satisfied, and the offense-element prong fails here. The conviction itself is valid for moral character purposes, but it's not disqualifying or clock-stopping.

On good moral character, I'm evaluating the seven-year residence period from February 1, 2014 through April 20, 2021, looking at the three dispositions—the 2018 fraud, 2019 reckless injury, and January 2021 cannabis offense. The argument is that all three are minor, completed, with restitution paid and employment history intact, and the rule requires actual record evaluation rather than speculation about misconduct. The government might try to argue cumulative adverse conduct across all three offenses, but the statute doesn't limit moral character findings to the listed offenses alone.

The fraud involving dishonesty against the employer is the strongest vulnerability here, so I need to present rehabilitation evidence: it was a single episode, restitution is fully paid, it's remote in time, probation is completed, there's no recidivism in similar conduct, the cannabis possession is de minimis and legislatively excepted, and the reckless injury was accidental rather than intentional. The statutory command to evaluate the actual record and the rule 6(b) exception both reflect legislative judgment that minor cannabis possession shouldn't disqualify.

For hardship, the daughter is a citizen child, age ten, with a rare blood disorder requiring home infusions four nights weekly, no other trained caregiver available, and substantial hospitalization risk if care is unavailable—all undisputed. The government doesn't dispute this satisfies the medical dependency and unavailable care requirements, though they might argue a caregiver could be trained, which I'd counter by pointing to the statute's language about "unavailable care."

On the government's strongest textual arguments: the notice issue hinges on whether the November 15 notice plus later specification together satisfy rule 2(a), but rule 3 directly answers that residence stops on the later specification, not the earlier incomplete one. For the clock-stopping offense, cannabis qualifies as a controlled-substance offense, and the exception for simple possession of no more than five grams is met; the government might argue the exception applies to disqualification but not clock-stopping, but rule 5 says clock-stopping offenses must be listed in rule 6, and rule 6(b) excludes the excepted offense from that list, so it's not a clock-stopping offense at all.

The restitution amount of $11,400 exceeds the $10,000 threshold, but rule 7 excludes audit expenses and "actual property loss" calculates to $8,900. The reckless injury with 14 months suspended is defeated by rule 8's second sentence. Even accepting the government's November 15 stop-time date would only give Idris six years nine months fourteen days—still short. The complete-notice argument is dispositive, and there's only a 27-day margin on the cannabis issue, so I need to emphasize these razor-thin margins and build the record carefully, particularly around continuous residence without absences.

For the motion strategy: I'm not challenging jurisdiction through the notice defect since it was cured; instead, I'll file a motion for a legal ruling on the stop-time date before the hearing, stipulating to the record. I'll also move in limine to exclude the $2,500 audit restitution and request judicial notice of the restitution order breakdown. I need certified conviction records showing the statutory elements of the reckless-injury statute to establish it's categorical based on recklessness, plus certified disposition documents from the cannabis case documenting the four grams, single offense, and deferred adjudication status.

For the hardship phase, I'm gathering evidence including specialist declarations and medical records, infusion logs, documentation of training availability, insurance and home-health denial letters, school records, hospitalization risk assessments, country-condition evidence showing treatment unavailability abroad, and the daughter's birth certificate proving citizenship. I'll also compile employment records and other Good Moral Character evidence.

I need to preserve the record by objecting to any government reliance on the November 15 notice date and verify there's no earlier charging document or service of a complaint by DHS.  I should also confirm continuous residence with no departures, watch for the government amending charges to add offenses, and obtain FBI and state criminal history to verify the single-offense exception applies. On the disqualifying offense requirement, the text doesn't impose a time limit, but all three convictions fail under rule 6 anyway so this doesn't help the case.