From the below affidavit, draft an oral advocacy to present to the Immigration Refugee Board on this client seeking PR under the H&C grounds.

1. A brief opening statement that identifies your client's goal, gives a brief summary of the relevant facts of their case, and provides an outline of your argument
2. A statement of the central legal issue and a brief summary of the relevant H&C factor that you have identified, drawing from the relevant law and policy
3. The legally relevant facts raised in your client's affidavit that support your argument
4. Your argument (including applying the law and policy that you know to the facts you have identified) as to the reasons the H&C exemption should be granted.
5. A brief conclusion

CANADA PROVINCE OF QUEBEC CITY OF MONTREAL

) ) ) ) )

IN THE MATTERof a Humanitarian and Compassionate application (H&C) for MARYSE SOPHIE TROUILLOT, in accordance with section 25(1) of the Immigration and Refugee Protection Act.

AFFIDAVIT OF MARYSE SOPHIE TROUILLOT

I, MARYSE SOPHIE TROUILLOT, born on April 25, 1959, in the commune of Jacmel, Haiti, mother-tongues French and Haitian Creole, and currently residing in the borough of Villeray in the City of Montral, Qubec, DO SOLEMNLY SWEAR TO THE FOLLOWING:

1. I was born on April 25, 1959, in the commune of Jacmel, to Haitian parents named Jean-Marie Trouillot and Madeline Toutsainte. I am a citizen of Haiti and no other country and do not have permanent status in any country other than Haiti.

1. I grew up in Jacmel along with my mother, my father, and six siblings. My parents are now deceased, and my siblings all live in Canada and the United States.

1. I have three sisters and one brother who live in Montreal and who are now Canadian citizens. I have two brothers who live in Tampa, Florida, and who currently have no legal status in the US. I have no family remaining in Haiti.

1. I have lived in Canada since I first arrived here in May of 2004 and the Greater Montral Area has been my home ever since. I have never lived in any country other than Canada and Haiti.

1. In February of 2004, there was a coup that removed Haiti's President Jean Bertrand Aristide from office. This came after many years of political turmoil. At that time, I made the decision to leave Haiti with my older sister, Patrice, and my two children - my son Boniface (Bony), then 11, and my daughter Ophelie, then 8. When my daughter was 2 years old, my husband was killed in a robbery while working in a depanneur in Jacmel. I never remarried.

1. We had three siblings who were already living in Montreal with their families. We decided to join them there.

1. Like many Haitians who fled after the coup, we had no papers. We travelled by boat to Florida. Our trip was arranged by human smugglers. We then travelled to Buffalo, New York.

1. While in Buffalo, we contacted an immigration consultant recommended by the smugglers who brought us there. The consultant provided us with false documents and told us what to say at the border. They gave us a story to tell where we said that we were wanted by rebels from the National revolutionary front for the liberation and reconstruction of Haiti. There were many Haitians fleeing to Canada at the same time, and we would speak together, and we knew that many people were being given similar stories. We were very frightened that we would be sent back to Haiti, where there was so much violence, and so we did what we were told.

1. When I entered Canada for the first time in May 2004, I regretfully followed the precise instructions given to me by the immigration consultant and lied about my reasons for claiming refugee status upon arrival at the Canadian border. I was terrified and confused and doing what I thought was best for my children. I was wrong and I am deeply sorry for my mistake.

1. My sister and I and my children were permitted to enter Canada to have our refugee claims heard because of our close family in Montreal. We settled in with them at first, eventually finding our own apartment in Villeray.

1. Our refugee claims were heard together in Montreal in July of 2005. Our claims were denied, because the Member did not believe our story. Our Legal Aid lawyer appealed to the Federal Court, but leave was denied. Our departure orders required us to leave Canada voluntarily in October of 2005. We did not leave. Our departure orders then became deportation orders. I was afraid of being sent back to Haiti at that time, and I decided to keep my head down and do nothing, hoping that I would not be noticed.

1. My sister Patrice died of cancer in 2015. My children are now grown and have both married Haitian Canadians. They became Canadian citizens. I am the only living member of my family in Canada who does not have Canadian citizenship. But I have done my best to be a productive member of Canadian society despite my lack of status.

1. I am in indefinite limbo in Canada. I cannot go back to Haiti - but I have no status in Canada. For this reason, I am asking that you exercise your compassion and grant me permanent residence status in Canada. I acknowledge that I made mistakes in my past. However, in addition to my fear, I have nothing and no one in Haiti. I have no life there.

1. My brothers in Tampa also have no status in the United States. They have little money, and they need to look after their own families. With no way to obtain status in the United States myself, I do not feel that I can go and live with them.

1. Even though I do not face immediate deportation to Haiti, I feel that my lack of status in Canada is preventing me from fulfilling my potential and fully giving back to Canada.

1. There have been some practical hardships associated with my lack of status, such as difficulty in some employment situations and with securing credit. I have had to forgo certain opportunities due to my irregular immigration status. For example, a few years ago, I wanted to start a small handicraft business, but I could not secure a loan to buy supplies.

1. Even more than these practical hardships, however, I am making an H&C application because I want to be here to help support and care for my family. I cannot return to Haiti; it would be devastating to be separated from my family here and potentially very dangerous for me in Haiti as a woman. I want to regularize my status in Canada so that there is no worry that I will not be here to be with my family.

1. In 2022, my son, his wife and I moved into a flat we purchased in Villeray, on Rue Fabre. On paper, my son and daughter-in-law are the owners, as my immigration status does not allow me to be a legal owner. I gave them most of my life savings to help with the down payment. I also help pay household bills through part-time cleaning work.

1. The flat was purchased for $322,000 (three hundred and twenty-two thousand) dollars and my son and daughter-in-law obtained a mortgage in her name from Scotiabank for the purchase. I paid over 1/3 of the down payment, a sum of about $5,500.

1. I am mainly responsible for the care and upkeep of our home, which includes doing the laundry, cleaning, and cooking.My daughter-in-law works full-time during the day as a teacher. They are hoping to start a family soon, and I want to be here to look after my future grandchildren.

1. My daughter lives with her husband nearby in a flat in Parc Extension. It is a 15-minute walk, and I visit her several times a week. My daughter works as a nurse.

1. My two sisters, Angeline and Judeline, and my brother, Franois, also live in Parc Extension with their adult children and grandchildren. We go to the same church, the glise de Dieu Centrale.We get together as a family and we see each other all the time.

1. Removing me to Haiti will put a tremendous amount of stress on the well- being of my family. My daughter-in-law works full-time as a teacher. They want to start a family, and I need to be here for them when they do.

1. I am currently employed as a part-time cleaner with Maison Menage. I have worked for them since about the summer of 2018. I have been there for a long-time, and I have several regular clients. I have positive working relationships with my colleagues and my clients, and I am grateful that our workplace is healthy and collaborative.

1. Beyond my part-time job and caregiving responsibilities, I am fortunate to have been able to invest in my community, and my social relationships in Canada. There are many charitable organizations that I volunteer for. For example, since 2010 I have volunteered for the Bureau de la communaut hatienne (BDCH) for their summer camp. At some community events around our city, I sit at the camp's table and talk to people about why the camp is a great opportunity for their children, and I pass out brochures. I help direct parents to the application forms, and I tell them about the bursaries we have so that even families who do not have much money can send their children.

1. I am also an artist. I make traditional beaded flags called Hatian Drapo. They are hand embroidered flags with glass beads and sequins. This art is very renowned in Jacmel, where I learned it from my grandfather. I teach this traditional art to the children at the BDCH camp every summer as a way of helping them know their culture and heritage.
2. I deeply enjoy participating in community-building projects and organizing social events for our community. It is a huge honour for me to be able to give back to my community. I have used my art as a platform to raise money for the BDCH camp and other charities too. It allows me to share a very important part of my life and at the same time benefit the people that I love.

1. I have been giving back to my community through my art in collaboration with the BDCH on other projects too. In the summer of 2020, for example, a friend asked me if I would donate one of my drapos to their fund-raising efforts at the glise de Dieu Centrale I agreed without hesitation. The proceeds from the sale of my drapo - $400.00 - went to fund the community food bank. I also make a drapo for BDCH every year at their summer fundraiser. It is auctioned off, along with handicrafts from other local artists. The proceeds help to fund the BDCH Options Program, which provides counselling for families and at-risk youth in the local Haitian community.

1. I go to the Haitian glise de Dieu Centraleseveral times a week. I teach Sunday school classes there in the winter. Just like at the summer camp, I make sure that the children in our community know their traditional stories, culture, arts, and can speak Creole with their elders.

1. I am very grateful for how vast and tight-knit my support network in Canada is, as I have very reciprocal and intimate relationships with many of them. For example, two of my best friends from our church, Simone Baptiste and Lovelie tienne, I consider to be like my own sisters. I have known each of them for more than 19 years and I am very close with their families as well. They are now grandmothers, and we come together all the time at our church to keep our community and its traditions alive for our young ones.

1. I have absolutely no family or friends left in Haiti, and I have never gone back there since I left in 2004. I have no means by which I could reintegrate into Haitian society, as I have been away now for most of my adult life. Having close family is a very important part of life in Haiti, and necessary for survival in difficult times. Without any close family members to look out for me, I would be left with few resources. As a single woman, I would be at risk from violence.

1. I believe that my circumstances warrant compassion, and I am asking that you allow me to remain in Canada. I have done my best, and I am now leading an organized and balanced life. My entire family is here, and they need me as much as I need them. I beg you to grant me permanent resident status in Canada, on humanitarian and compassionate grounds.

SWORN BEFORE ME

in the City of Montral, in the Province of Qubec

this 12th day of August, 2024.

Gabrielle Calixte MARYSE SOPHIE TROUILLOT

Barreau du Qubec

Commissioner for Taking Oaths in the Province of Qubec

Accueil Aux Immigrants De L'Est De Montral

Draft a brief submission in point form and then deliver that submission orally to the Immigration Officer via a recording.

First, draft your brief point-form argument (aim for about 300 words). Keep the FILAC (legal reasoning) and CREAC (legal writing) structures in mind as you prepare your notes. Even though the main goal is an oral (not written) submission, these structures help to keep you organized and clear in your reasoning and your presentation. Make sure to use only the facts presented in the affidavit. Do not make up additional factsthat were not in the affidavit.

Then, based on your written point-form argument, prepare a brief oral submission arguing your client's case on H&C considerations. Follow the guidance provided in Advocacy for Paralegals (pp. 105-110) as well as by Prof. Erik Knutsen in "Persuasive Oral Advocacy: The Role of Oral Submissions" (You'll find both sources in theOral Advocacy page).

Remember, that no additional legal research is required to complete this assignment. Use the law and policy from the assigned course materials.

Your submission must include:

1. 1. A brief opening statement that identifies your client's goal, gives a brief summary of the relevant facts of their case, and provides an outline of your argument
   2. A statement of the central legal issue and a brief summary of the relevant H&C factor that you have identified, drawing from the relevant law and policy
   3. The legally relevant facts raised in your client's affidavit that support your argument
   4. Your argument (including applying the law and policy that you know to the facts you have identified) as to the reasons the H&C exemption should be granted.
   5. A brief conclusion

Be sure to present in a natural speaking voice and imagine you are speaking directly to the Immigration Officer.

You are encouraged to rehearse in advance and/or re-record as many times as you like until you feel your presentation is ready.

During your oral presentation, avoid reading directly from your notes. Your oral submission should appear natural, and you should have your argument memorized as far as possible, so as to maximize the persuasiveness of your presentation. Your point-form notes are there for support - they are not a script.

Length of recording

You will havefour minutesfor your oral presentation. The average person speaks approximately 125-150 words per minute.