... Moreover, several law enforcement officers, including Officers Crader and Meyer, Detective
Knapp, an immigration officer, and a probation officer, testified about defendant's proficiency
in English based upon their observations and conversations with him. ...
... 25. The United States Supreme Court, in the context of deportable offenses under immigration
law, has refused to assign a fixed meaning to the term "moral turpitude," other than to hold
that crimes involving an element of fraud implicate that term. ...
... The federal court implied that the absence of a pre-removal complaint had deprived it of jurisdiction.
Cf. Stewart v. US Immigration & Naturalization Serv., 762 F.2d 193, 198-99 (2d Cir.1985)
(Preliminary injunctive relief can be obtained only after an action has commenced. ...