dismissed EB-1C Case: Food Import And Distribution

MATTER OF M-F- INC. 
Non-Precedent Decision of the 
Administrative Appeals Office 
DATE: AUG. 30, 2018 
MOTION ON ADMINISTRATIVE APPEALS OFFICE DECISION 
PETITION: FORM I-140, IMMIGRANT PETITION FOR ALIEN WORKER 
The Petitioner, a food import and distribution company, seeks to permanently employ the 
Beneficiary as_ its president under the first preference immigrant classification for multinational 
executives or managers. Immigration_and Nationality Act (the Act) section 203(b)(l)(C), 8 U.S.C. 
§ 1153{b)(l)(C). This classification allows a U.S. employer to permanently transfer a qualified 
foreign employee to the United States to work in ail executive or managerial capacity. 
The Director of the Texas Service Center denied the petition, concluding that the record did not 
establish, as required, that: (1) the Petitioner had a qualifying relationship with the Beneficiary's 
former foreign employer; (2) the Petitioner was doing business in accordance with the regulations; 
and (3) the Beneficiary would act in a managerial or executive capacity in the United States. In 
addition, the Director concluded that the Petitioner and Beneficiary willfully misrepresented material 
facts related to his claimed.foreign employment. 
The Petitioner later appealed the decision and we dismissed the appeal. We withdrew the Director's 
determination that the Petitioner was not doing business, and affirmed the remaining grounds for 
denial. In addition, we concurred with the Director's determination that the Petitioner and 
Beneficiary willfully misrepresented material facts and noted additional misrepresentations in the 
record. The matter is now before us on a motion to reopen and a motion to reconsider. 
On motion, the Petitioner disputes our conclusion that it and the Beneficiary willfully misrepresented 
several material facts and contends that we misinterpreted its assertions and the evidence. The 
Petitioner further states that the submitted evidence clearly demonstrates that it has a qualifying 
relationship with the foreign employer and that the Beneficiary will work in an executive capacity in 
the United States. 
Upon review, we will deny the motion to reopen and the motion to reconsider. 
I. MOTION REQUIREMENTS 
A motion to reopen is based on factual grounds and must (1) state the new facts to be provided in the 
reopened proceeding; and (2) be supported by affidavits or other documentary evidence. 8 C.F.R. 
§ I03.5(a)(2). A motion to reconsider is based on legal grounds and must (1) state the reasons for 
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Maller of M-F- Inc. 
reconsideration; (2) be supported by any pertinent precedent decisions to establish that the decision 
was based on an incorrect application of law or policy; and (3) establish that the decision was 
incorrect based on the evidence of record at the time of the initial decision. 8 C.F.R. § l03.5(a)(3). 
We may grant a motion that satisfies these requirements and demonstrates eligibility for the 
requested immigration benefit. 
II. ANALYSIS 
A. Motion to Reconsider 
As noted, the Director denied the petition and we further dismissed the appeal on three separate 
grounds, including affirming the Director's conclusion that the Petitioner had willfully 
misrepres~nted material facts. The Petitioner's motion is not supported by pertinent precedent or 
adopted decisions, statutory or regulatory provisions , or statements of U.S. Citizenship and 
Immigration Services (USCIS) or Department of Homeland Security policy, and does not establish 
that our decision was based on an incorrect application of law or policy, as required . 8 C.F.R. 
§ 103.5(a)(3). 
Accordingly, we find that the Petitioner does not meet the requirements of a motion to reconsider. 
B. Motion to Reopen 
On motion, the Petitioner makes several additional assertions with respect to the willful 
misrepresentations we found in the record, its ownership, and the Beneficiary's asserted executive 
capacity in the United States. The Petitioner also submits additional evidence specific to the 
Beneficiary's claimed foreign employment in support of its claim that it did not misrepresent 
material facts regarding that employment. ~s such, we will address the Petitioner's assertions and 
new evidence . However, upon review, we conclude that the Petitioner has not submitted sufficient 
new facts supported by affidavits or other documentary evidence to warrant the reopening of this 
matter. 8 C.F.R. § l03 .5(a)(2). 
1. Beneficiary's Foreign Employment 
In our previous decision, we affirmed the Director's conclusion that both the Petitioner and 
Beneficiary had willfully misrepresented material facts related to his foreign employment. 
We noted that the Petitioner submitted a copy of the Beneficiary's resume, indicating that the 
Beneficiary was a manager for from 
September 2001 to July 2013. The Beneficiary's resume also reflected that he previously worked as 
a marketing/sales manager for from 
September 1994 to August 2001. We further stated that the Beneficiary had appeared at various 
U.S. consulates in China on five occasions between 2009 and 2013, to apply for nonimmigrant visas. 
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Maller of M-F- Inc . 
On each occasion, when asked to identify his current employer, the Beneficiary named 
or a variation of that name. 
We later issued a notice of intent to dismiss and request for evidence (NOID/RFE) to advise the 
Petitioner of the above discrepancies. We requested "credible and verifiable documentation" of the 
Beneficiary's employment with from 2010 to 2013, and "a persuasive explanation for 
why the Beneficiary never mentioned ____ when repeatedly asked to name his current 
employer" to consular officials . 
The Petitioner responded to the NOID/RFE, but disregarded our request for an explanation as to why 
the Beneficiary never claimed as his employer during his consular interviews between 
2009 and 2013. The Petitioner submitted partially translated copies of monthly payroll records from 
covering various months from December 2001 to October 2012. We noted 
discrepancies in these documents that called into question their credibility and concluded that the 
evidence was in~ufficient to establish that the Beneficiary was employed by from 2001 
to 2013 as asserted. We determined that the Petitioner did not overcome substantial credibility 
issues arising from the Beneficiary's conflicting employment histories . We also noted that the 
Beneficiary's resume identified him as the marketing/sales manager of not as its general 
manager, majority shareholder, or "legal representative" as the evidence reflected in response to our 
NOID/RFE . . 
In addition, we concluded that both the Petitioner and the Beneficiary had made willful and material 
misrepresentations. 1 We indicated that the Beneficiary had provided his resume as supporting 
evidence with the petition and that he bore some proportional responsibility for the assertions 
included therein. We also concluded that the Beneficiary willfully made misrepresentations , 
reasoning that he would have knowledge. of his own employment history. Lastly, we determined 
that the misrepresentations were material to eligibility as they cut off a potential line of inquiry 
regarding his claim of past employment with 
On motion, the Petitioner makes several additional assertions specific to the Beneficiary's claimed 
foreign employment. The Petitioner reaffirms that the Beneficiary stopped working for m 
2001 and that he joined at this time. It further asserts that, in 2001, the Beneficiary was 
asked by his brother to oversee while employed by The Petitioner states that 
the Beneficiary referred to as his employer while being interviewed by consular officers so 
as to present his "stronger side" while applying for nonimmigrant visas. The Petitioner 
acknowledges that the Beneficiary was employed as the sales and marketing manager .of but 
1 For an immigration officer to find a willful and material misrepresentation in visa petition proceedings , the officer must 
detennine : I) that the petitioner or beneficiary made a false representation to an authorized official of the United States 
government : 2) that the misrepresentation was willfully made ; and 3) that the fact misrepresented was material. See 
Matter of M-, 6 l&N Dec. 149 (BIA 1954); Matter of L-L-, 9 I&N Dec. 324 (BIA 1961 ); Matier of Kai Hing Hui, 15 
l&N Dec. at 288 . 
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Maller of M-F- Inc. 
indicates that he later acted as general manager or "boss" of the company when he took over its 
management from his brother after 200 I. 
The Petitioner also submits additional evidence specific to the Beneficiary 's claimed foreign 
employment with The Petitioner provides documents titled "Recorded List for 
Employees Who Have Signed Employment Contracts" listing the Beneficiary and other employees 
who signed employment contracts with These documents reflect that the Beneficiary 
signed employment contracts for the following periods: January I, 2008 to December 31 , 20 l 0, 
January 1, 2010 to December 31, 2013, January 1, 2014 to December 31, 2016, and January 1, 2017 
to December 31 , 2019, In addition, the Petitioner submits employment contracts between the 
Beneficiary and indicating that he worked as "executive manager of overseas 
investment department" for the following periods : 2008 through 2010, 2014 through 2016, and 2017 
through 2019. In addition , the Petitioner provides partially translated payroll documentation 
identical in form to that previously submitted in response to our NOID/RFE . However, the updated 
payroll documents are still lacking full English translations and cover random months from 
December 2005 to December 2011. 
,,. 
Upon review, we do not find that the Petitioner 's additional assertions and the newiy submitted 
evidence overcome our previous finding that the Petitioner and Beneficiary willfully misrepresented 
material facts related to his foreign employment. 
First, we issued a RFE/NOJD directly addressing the discrepandes between the Beneficiary's 
employment with as "general manager" reported to consular officers and his purported 
employment with set forth in the current petition. In the same RFE/NOID, we pointed 
to the Beneficiary 's resume which reflected that he was a manager for from September 
2001 to July 2013 and marketing/sales manager for from September 1994 to August 2001, 
evidence in apparent contradictiOQ to the employment he asserted with in several consular 
interviews from 2009 through 2012. We requested that the Petitioner submit the following: 
Any evidence you chose to submit must include credible and verifiable 
documentation to establish that the Beneficiary worked for from 2010-
2013 as claimed on your petition , and a persuasive explanation for why the 
Beneficiary never mentioned when repeatedly asked to name his 
current employer [in consular interviews]. 
In response to this direct request, the Petitioner did not provide any explanation as to the material 
discrepancies discussed in our RFE/NOID, but provided only a confusing array of monthly 
payroll documents covering random months from December 2001 to October 2012.2 This 
2 The Petitioner submitted asserted payroll documentation from the following months: December 200 I, 
December 2002, December 2003, March·2003, March 2005, December 2005, July 2006, December 2007, April 2007, 
December 2007, October 2008, December 2008, June 2009, December 2009, February 2010, December 2010, 
September 20 I I, December 2011, July 2012, and October 2012. 
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Matter of M-F- Inc. 
evidence did not directly address the material question of whether the Beneficiary was employed in a 
managerial or executive capacity by for one year out of the three years preceding the 
date the petition was filed. In fact, the submitted evidence only reflected salaries paid to him during 
six nonconsecutive months during the relevant three year period. Therefore, the Petitioner's 
response did not properly address the material discrepancies we noted in our RFE/NOID. We stated 
in our NOID/RFE that if the Petitioner did not sufficiently respond, we would affirm the Director's 
finding of willful misrepresentation. 
Now on motion, the Petitioner addresses the discrepancies discussed in our RFE/NOID, but does not 
explain why this information was not provided previously, leaving question as to the credibility of 
these statements. For instance, the Petitioner indicates that the Beneficiary had taken over control of 
from his brother in 2001, and explains that this is why he reported this company as his 
employer to consular officers on several occasions from 2009 to 2012. However, the Petitioner did 
not discuss this secondary employment in response to our direct inquiry in the RFE/NOID, nor is 
this claimed employment and ownership reflected in his resume, which indicated that his 
employment with ended in 2001. Likewise, when directly requested to list his previous 
employment and his last occupation abroad within five years on the G-325A, Biographic 
Information completed in July 2014, the Beneficiary provided no information regarding his 
employment and did not disclose the purported,joint employment he now asserts with both 
and throughout this period. Further, the Petitioner also provided very limited evidence 
of the Beneficiary's foreign employment, beyond a resume, in support of the petition and in response 
to the Director's separate notice of intent to deny. 
We acknowledge that in response to the RFE/NOID the Petitioner submitted documentation related 
to This documentation, which included translated Chinese tax documents and articles of 
association for indicated the Beneficiary's involvement with this company abroad after 
2001. However, the Petitioner did not explain the relevancy of these documents at the time of the 
RFE/NOID response. Further, these documents only raise further question as to the Beneficiary's 
foreign activities. For instance, the submitted articles of association appear to be several 
pages long, but the Petitioner only provided a partial translation reflecting that in 2001 the 
Beneficiary paid. $200,000 in capital into the company, and paid $100,000. Any 
document in a foreign language must be accompanied by a full English language translation. 
8 C.F.R. § 103.2(b)(3). The translator must certify that the English language translation is complete 
and accurate, and that the translator is competent to translate from the foreign language into English. 
Id. Because the Petitioner did not submit a properly certified English language translation of the 
document, we cannot determine whether the translated material is accurate and thus supports the 
Petitioner claims. 
In addition, the translation of purported articles of association is dated in December 2008, 
several years after the asserted capital was paid. Further, a document titled "Cancellation of Tax 
Registration Application Approval Table" reflected that "actual operating period" was 
from June 15, 1996 to March 10, 2002 and indicated that the Chinese government entity involved 
had "approve{d] business termination." Likewise, a similar tax document dated in August 2002 
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Matter of M-F- Inc. 
appears to reflect that had no "current tax payable" at this time, appearing to corroborate that 
the company had been approved for termination in March 2002. This documentation leaves only 
further question as to the Beneficiary's assertions on motion; namely, that he was employed with 
both and ___ when he reported employment with to consular officers on 
several occasions. 
In sum, despite several opportumties, the Petitioner has not provided concrete evidence of the 
Beneficiary's foreign employment with for the required one year period. Again, on 
motion the Petitioner submits incomplete foreign employment documentation; for instance, it only 
provides payroll documentation for two non-consecutive months during the relevant three year 
period and this documentation is again not fully translated.3 
We acknowledge that the Petitioner provides a "Recorded List for Employees Who Have Signed 
Employment Contracts" listing the Beneficiary's employment contracts covering 2008 through 2019 
and the accompanying employment contracts covering 200·8 through 20 l 0, 2014 through 2016, and 
2017 through 2019. However, the documentation incomplete, as it excludes the Beneficiary's 
employment co_ntract for the relevant three year period from 2011 to 20 l 4. The lack of this relevant 
employment contract leaves further doubt as to the provided assertions and evidence on motion. The 
Petitioner and Beneficiary have repeatedly been unable to provide complete, consistent, and 
verifiable evidence of the Beneficiary's foreign employment with throughout this 
proceeding, including in response our direct request for this evidence in the RFE/NOID. The 
Petitioner must resolve inconsistencies with independent, objective evidence pointing to where the 
truth lies. Matter of Ho, 19 l&N Dec. 5 82, 591-92 (BIA 1988). Unresolved material inconsistencies 
may lead us to reevaluate the reliability and sufficiency of other evidence submitted in support of the 
requested immigration benefit. Id. 
For the reasons discussed above, the Petitioner has not submitted evidence to overcome our previous 
finding that the Petitioner and Beneficiary willfully misrepresented material facts related to his 
foreign employment. 
2. The Beneficiary's Residence in the United States 
In our previous decision, we also concluded that the Beneficiary had misrepresented the nature and 
purpose of his travel when he applied for nonimmigrant tourist visas in August 2012 and July 2013. 
We noted that the record indicated that the Beneficiary did not only travel to New York during these 
periods as claimed to consular officials, as he listed his residence in the United States as being at 
in Virginia during this same time. In our NOID/RFE, we asked the 
Petitioner to explain why he claimed to have resided for more than a year at an apparent commercial 
property, in Virginia. In response, the Petitioner submitted a copy of a 
residential lease agreement for a home on ___ m · dated September 2012, and an 
3 The Petitioner provides monthly payroll listing the Beneficiary for the following months during the 
relevant three year period prior to the date the petition was filed: August 2011 and December_ 2011. · 
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Matter of M-F- Inc. 
affidavit from the company's secretary and general manager stating that the Beneficiary had lived at 
"during his time in the United States working at [the Petitioner]." The lease agreement 
indicated it was for a five-year term beginning January 1, 2013. Therefore, the document provided 
no information about where the Beneficiary had resided in 2012." We concluded that-the Petitioner 
did not adequately explain why the Beneficiary listed a commercial property on ____ as 
his residential address from August 2012 to December 2013. 
On motion, the Petition states that it is a "true fact" that the Beneficiary resided at the commercial 
premises on from 2012 to 2013. The Petitioner indicates that the Beneficiary left 
this premises when he was discovered there by a fire marshal who told him that his residence there 
was illegal. Further, the Petitioner indicates that it began searching for a residence for the 
Beneficiary "in the beginning of 2014" and also states that "the house [was] not made ready for 
moving in until 2014." It also explains that the Beneficiary reported New York as his residence to 
consulates in China when applying for nonimmigrant visas because this was his port of entry, noting 
that he would typically spend a few days there visiting his daughter. In addition, the Petitioner states 
that the Beneficiary reported New York as his only destination and place of residence to consular 
officials because "[he] was afraid that he may [have to] explain why he would stay in and 
what he would do there." The Petitioner further indicates that "if that is considered as 
misrepresentation, the beneficiary will take the fact but never ever willfully did it." 
The Petitioner has made and acknowledged additional misrepresentations on motion. For instance, 
in response to our question regarding the Beneficiary's residence at the commercial 
address during 2012 and 2013 the Petitioner previously provided an affidavit from the company's 
secretary and general manager stating that the Beneficiary had lived at in 
Virginia "during his time in the United States working at [the Petitioner]" and that he had "also 
designated the address for various mailings related to his personal · affairs." In 
addition, it provided a lease agreement specific to the address in response to our 
RFE/NOID indicating that its term began January 1, 2013 and stated in a support letter that the 
Beneficiary resided at this address "during his time in the United States." 
However, now on motion, the Petitioner acknowledges that the Beneficiary was living illegally at the 
commercial property on during 2012 and 2013 until another residence was sought at 
the beginning of 2014. The Petitioner also stated that this unidentified residence (presumably the 
residence) was not ready until 2014. In sum, this evidence indicates that the Petitioner 
willfully misrepresented the Beneficiary's place of residence as ___ m m response 
to our direct inquiry as to this issue in our RFE/NOID. 
In addition, the Petitioner acknowledges that the Beneficiary also misrepresented his intended place 
of residence to consulates in China when applying for nonimmigrant visas in August 2012 and July 
20 I 3. The Petitioner states that the Beneficiary attested to consulates in China that he only intended 
to stay in New York, but indicates on motion that he only planned to stay in New York for a few 
days before traveling to his admitted place of residence, the commercial property on 
m __ Indeed, the Petitioner appears to admit, despite its assertions otherwise, that the 
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Matter of M-F- Inc. 
Beneficiary willfully misrepresented himself to the consulates, noting, he "was afraid that he may 
[have to] explain why he would stay in and what he would do there." Therefore, on motion, 
the Petitioner has not submitted new facts or evidence to overcome our previous conclusion that the 
Beneficiary misrepresented himself to consulates in China. In fact, the Beneficiary appears to admit 
to_this misrepresentation through the Petitioner. 
The Beneficiary asserts that this misrepresentation was not willful. However, the Beneficiary's 
direct statements indicate otherwise, as he asserts through the Petitioner that he misrepresented 
himself to the consulates in order to evade questions regarding his true activities in the United States, 
namely, his travel to and residence in As such, we are not persuaded that the Beneficiary's 
admitted misrepresentation was not willful and the Petitioner and Beneficiary have not articulated 
clearly why these misrepresentations cannot be considered willful. 
Therefore , the Petitioner has not submitted sufficient new facts supported by documentary evidence 
to overcome our previous conclusion that the Beneficiary willfully misrepresented the nature and 
purpose of his travel when he applied for nonimmigrant tourist visas in August 2012 and July 2013. 
3. Ownership of The Petitioning Company 
ln our previous decision, we also affirmed the Director 's conclusion that the Petitioner had willfully 
misrepresented its ownership. We indicated that the Petitioner stated that it was always organized as 
a 50/50 joint venture between and However, 
when we advised the Petitioner in our NOIDIRFE that the Commonwealth of Virginia had 
terminated corporate status, it then claimed that had transferred its shares to a 
in December 2012, nearly two years prior to the date the petition was filed. We noted that 
the Petitioner did not explain why it withheld this information until confronted with evidence that 
10 longer exists. 
The Petitioner asserts on motion that it was unaware that a terminated company could not act as a 
shareholder, and that after it had consulted with an attorney, it transferred the shares to 
with all relevant corporate paper work post-dated to December 2012. The Petitioner does not 
indicate when this transfer actually_ took place. However, in response to our direct inquiry in our 
RFE/NOID, the Petitioner did not disclose the truth, but merely submitted the documentation 
indicating the transfer of shares from to in 2012. Again, it appears that the 
Petitioner attempted to insulate us from the whole truth. Again, the Petitioner must resolve these 
inconsistencies with independent, objective evidence pointing to where the truth lies. Matter of Ho, 19 
I&N Dec. at 582, 591-92. Unresolved material inconsistencies may lead us to reevaluate the reliability 
and sufficiency of other evidence submitted in support of the requested immigration benefit. Id 
Considering this, we conclude that the Petitioner has not provided sufficient new facts and evidence to 
overcome our previous determination that it willfully misrepresented its ownership. 
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Mauer of M-F- Inc. 
4. Qualifying Relationship 
We also concluded that the Petitioner did not establish that it had a qua~ifying relationship with the 
foreign employer : See generally section 203(b)(l)(C) of the Act; 8 C .F.R. §.204.5G)(3)(i)(C). We 
determined that the Petitioner had seriously compromised its credibility as to its ownership having 
provided contradictory information and evidence. The Petitioner submits no new evidence on 
motion to alleviate these concerns . For instance, it now states the following with respect to the 
qualifying relationship issue: 
The truth is that [the Petitioner] is the baby by and through 
as soon as [the Petitioner] started. Just as a baby of a mother and a father, if 
the mother died, can we say there is not qualifying relationship between the baby and 
the father? The baby itself tells everything by keeping moving forward as the parents 
were expecting. Therefore our lawyer is right is saying "ownership and control 
arrangement [between and continues through present time[.]" 
As long as the child does not die, it continues the relationship. 
We do not find this reasoning persuasive. The Petitioner has continually provided conflicting 
assertions regarding its ownership . In fact, the Petitioner acknowledges that the shares owned by 
were not transferred to in 2012 as asserted, but only transferred after it realized 
that a terminated company could not own shares. The Petitioner now concedes that it post-dated 
corporate documentation in an attempt to make it appear that this had been the company's ownership 
all along. In addition, the Petitioner does not indicate when the share transfer to actually 
took place and this leaves material uncertainty as to its actual ownership as of the date the petition 
was filed and throughout the adjudication. Further, there is question as to whether a post-dated 
transfer of shares is legally effectual. The Petitioner must establish that all eligibility requirements 
for the immigration benefit have been satisfied from the time of the filing and continuing through 
adjudication . 8 C.F.R. § 103.2(b)(l) . 
For these reasons, we affirm our previous conclusion that the Petitioner has not established that it 
has a qualifying relationship with the Beneficiary's asserted foreign employer, The 
Petitioner has not submitted new facts or docwnentary evidence to overcome this conclusion . 
5. U.S. Employment in an Executive Capacity 
Lastly, we will analyze whether the Petitioner has met the requirements of a motion to reopen with 
respect to our conclusion that it did not establish that the Beneficiary would act in an executive 
capacity in the United States. In denying the petition on this ground, we indicated that the Petitioner 
did not address the Director's conclusion that the Beneficiary's U.S. duty description was vague and 
generic. We noted that it was not convincing for the Petitioner to merely respond to this conclusion 
by only stating on appeal that his duty description was "sufficiently detailed ." We also pointed to 
discrepancies in the Petitioner's asserted organizational chart and operations, noting that the record 
contains references to positions and to a warehouse and vehicles that did not appear to exist. 
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Matter of M-F- Inc. 
The Petitioner does not provide any additional insight into the Beneficiary's U.S. duties on motion, 
only vaguely stating that he would "lead the directions for the company," exercise power to direct 
the company," and "set it[s] goals and directions.'' As such, we affirm our previous conclusion that 
the Beneficiary's U.S. duty description is overly vague and generic and that it does not sufficiently 
detailed establish his actual day-to-day duties. Likewise, the Petitioner does not provide additional 
evidence to address the discrepancies in its staffing and operations that we noted in our previous 
decision. 
In fact, the Petitioner's assertions on motion only leave further question as to whether the 
Beneficiary would act in his claimed executive capacity under an approved petition. For instance, 
the Petitioner states that it "only [has] 4 employees left plus a contracted employee not on the 
payroll" and adds that "other same sized companies will require at least 7 employees." This 
statement indicates that the Petitioner is understaffed compared to companies of its same size raising 
addition~! question as to whether it has sufficient employees to primarily relieve the Beneficiary 
from performing non-qualifying operational tasks and whether he would oversee a subordinate level 
of managerial employees to allow him to primarily focus on the broad goals and policies. of the 
organization rather than its day-to-day operations. Section 101(a)(44)(B) of the Act. 
Therefore, the Petitioner has not submitted sufficient new evidence specific to the Beneficiary's 
executive capacity in the United States to reopen this issue. -
Ill. CONCLUSION 
For the reasons discussed, the Petitioner has not shown proper cause for reopen mg or 
reconsideration of our prior decision. 
ORDER: The motion to reopen is denied. 
FURTHER ORDER: The motion to reconsider is denied. 
Cite as Maller of M-F- Inc., ID# 1581963 (AAO Aug. 30, 2018) 
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