Your assignment is to compose a submission letter to the Immigration Division on behalf of your client, Mr. Shinoda, who is currently in detention and is seeking release in his upcoming detention review hearing. Your submission letter should cite the reasons why Mr. Shinoda should be released from detention, the evidence that supports your arguments, and include the proposed release plan for him with alternatives to detention.

SCENARIO

Kenichi Shinoda has called your office just as the day was ending on Monday afternoon. He has been detained at Toronto Pearson Airport by CBSA as he was clearing customs. Mr. Shinoda is a dual United States/Japanese citizen and is 50 years old. He has flown to Toronto from New York to attend his nephew's graduation from the University of Toronto medical school.

Mr. Shinoda owns several exclusive art galleries in New York, Los Angeles, San Francisco, Tokyo, Hokkaido, and London and travels between them frequently. He has brought an original painting with him to Toronto as a surprise gift for his nephew's graduation.

CBSA believes that Mr. Shinoda is inadmissible to Canada due to ties to the Japanese Yakuza organization and has misrepresented this fact. CBSA also believes that the painting Mr. Shinoda has brought with him is stolen and was used for payment of a shipment of illegal guns from the United States to Japan based on information obtained via data sharing with the FBI and Interpol. Further, CBSA also believes that he is a flight risk due to his extensive financial means and social network, and poses a danger to the public due to his Yakuza ties.

Mr. Shinoda tells you that he is simply an art dealer who has come to Toronto for a few days to celebrate his beloved nephew's achievement. He tells you that he answered CBSA's questions honestly and to the best of his ability. He says that he bought the painting from an artist who has had several shows at his Los Angeles gallery, and that he does not know anything about illegal weapons or the Yakuza. Mr. Shinoda maintains that if he had ties to such a powerful and well-known organization, he would not have come to Canada in the first place.

Mr. Shinoda's detention review is on Wednesday morning at 9:30am.

You ask Mr. Shinoda if he has anyone in Canada who can act as his bondsperson. He advises that the only person he knows in Canada is his nephew who is graduating. Mr. Shinoda begs you not to contact his nephew, Shigeo, as he would be ashamed for his nephew to know he has been detained. Even though Mr. Shinoda has paid for all of Shigeo's schooling, and nothing would make him happier than to see his nephew's graduation, he will miss the ceremony on Friday if he is not released from detention on Wednesday. It is unclear whether Mr. Shinoda may change his mind about a bondsperson once he has spent the night in detention.

Format: As always, your submission letter should be in the format and tone of a business letter.

Length: Take as long as you need to make your arguments comprehensively, but remain succinct. More is not necessarily better. Make your arguments and provide supporting evidence; do not talk simply to hear yourself talk.

Inclusions: A matter this serious should refer to the relevant sections of the Act/Regulations at minimum, and should realistically include a reference to legal precedent.