Sign up now: CILA Mentorship Course: Practical Training on Stay Motions (November 5 – December 3, 2026)
Overcome your hesitation about handling urgent removal matters and gain the confidence to prepare and argue stay motions before the Federal Court with expert guidance. Learn how to assess removal matters, prepare deferral requests and persuasive motion records, and effectively advocate at a stay hearing in a four-week practical course with an optional practical assignment add-on, where an experienced litigation practitioner will review a stay motion record prepared by you.
Learn life-long practical skills
Have you ever hesitated to take on a stay motion because you were unsure how to manage the urgent timelines, prepare the motion record, or argue the case before the Federal Court? This hands-on mentorship program is designed specifically for immigration and refugee lawyers who want to develop practical, real-world skills in representing clients facing removal.
This is not theory. This is practical training from experienced litigation practitioners.
Course at a Glance
Program Dates: November 5, 2026 – December 3, 2026, with a practical add-on assignment.
Time: 5:30 PM – 7:00 PM ET
Format: Live online sessions (1.5 hours each)
Modules: 4 core modules + optional practical assignment
Class Size: Limited to 10 participants
Available Exclusively for CILA members
What You’ll Learn
Throughout this course, you’ll gain valuable insights into the practicalities of advising clients facing removal and preparing and arguing stay motions before the Federal Court, including:
- Assessing Removal Matters and Developing a Strategy: Learn how to assess the available options when a client is facing removal, including whether to pursue a stay motion in the context of a pending judicial review or request a deferral of removal.
- Preparing Effective Deferral Requests: Understand the required components of a deferral request, common grounds for seeking a deferral, supporting documentation, filing deadlines, and practical considerations for submitting the request to the appropriate parties.
- Best Practices for Motion Record Preparation: Take an in-depth look at preparing a procedurally compliant and strategically effective stay motion record, including supporting evidence and persuasive written submissions addressing the legal test for a stay.
- Identifying Issues in the Underlying Decision: Learn how to recognize relevant legal errors and deficiencies in underlying decisions, with particular attention to PRRA and deferral decisions, and effectively incorporate those issues into the stay motion record.
- Navigating Interactions with the Department of Justice: Explore common positions and arguments advanced by the Department of Justice and learn how to anticipate and proactively address them in the written record and overall litigation strategy.
- Appearing Before the Federal Court: Develop practical oral advocacy skills, including structuring persuasive submissions, responding to the Respondent’s position, answering questions from the bench, and adapting your arguments as the hearing unfolds.
- Optional Practical Assignment: Put your new skills to the test by preparing a supporting affidavit for use in a stay motion record and receiving individualized feedback from an experienced litigation practitioner. You will draft the affidavit and determine what type of evidence you would attach as exhibits.
After completing the course, you should have a practical framework for assessing removal matters, preparing a compelling stay motion, and confidently presenting your case before the Federal Court.
Course Instructors
Pia Zambelli holds a BA from the University of Toronto, an LL.B. from Osgoode, and an LL.M. from McGill. She is a member of the Quebec and New York State bars and served on the Immigration and Refugee Board of Canada from 1993 to 1998. Pia currently practices refugee law in Montreal, specializing in appeals and judicial review applications. She has authored several law journal articles, regularly speaks at conferences and training sessions hosted by refugee advocacy groups. She is currently an adjunct instructor in the Graduate Diploma in Immigration and Citizenship Law Programme at Queen’s University Faculty of Law.
Sarah Mikhail is an Associate Lawyer at Smith Immigration Law, where she also completed her articles. She practices exclusively in immigration and refugee law, with a strong focus on litigation. Sarah has successfully represented clients before the Federal Court of Canada, as well as before the Refugee Protection Division, Refugee Appeal Division, and Immigration Division. Sarah is a dedicated advocate for LGBTQ+ refugees and regularly appears before the RPD, RAD, and Federal Court on matters involving removal and protection. Her litigation practice is grounded in a deep commitment to procedural fairness and access to justice for marginalized clients.
Sarah earned her Juris Doctor from the University of Ottawa’s Common Law program in 2022 and holds a Bachelor of Arts from McGill University (2019), where she completed a double major in Political Science and Sociology and a minor in Education. While in law school, Sarah served as Co-Chair of the 2022 Lobbycon Conference with the Canadian Association of Refugee Lawyers (Ottawa Chapter), where she led student advocacy efforts for progressive refugee and immigration policy on Parliament Hill. She was also actively involved with the University of Ottawa Community Legal Clinic, further honing her skills in client-centered advocacy.
Why Attend
This four-module course is a unique opportunity to expand both your immigration and refugee law expertise and the services offered by your practice. Going well beyond a traditional CLE, this practical course will provide a step-by-step guide to assessing removal matters, preparing deferral requests and stay motion records, and effectively advocating before the Federal Court.
Designed for practitioners who have never completed a stay motion, but open to both new and experienced counsel, this course provides an opportunity to develop practical skills in a supportive group environment that fosters both community and collegiality.
Please note that purchases are non-refundable.
Speaker
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Mary Lam