Antia-Perea v. Holder

Record contained sufficient evidence to support Bd.’s removal order, even though it was based solely on documentary evidence that included Form I-213, which contained alien’s admission that he was not U.S. citizen and was citizen of Columbia. Alien did not testify at removal hearing so as to call into question statements contained in Form I-213, and finding of removal can be supported based only on documentary evidence. Also, IJ did not err in denying alien opportunity to cross-examine author of Form I-213, where alien failed to introduce evidence challenging contents or reliability of Form I-213.