We'll hear argument first this morning in case 23-929 Velasquez v. Garland. Mr. Cedrone.

Thank you, Mr. Chief Justice, and may it please the Court. The 60-day time period in the

voluntary departure statute works like any routine legal time period. When the last day falls on a

weekend or holiday, the period continues to run until the next business day.

Congress would have expected people to read the statute this way.

In 1996, common law principles, case law, established rules and regulations,

and years of consistent practice all pointed to that interpretation.

If Congress had meant to deviate from that traditional

understanding, it would have said so. Even the government now acknowledges that other

deadlines in the same section of IRA follow the traditional rule in light of a long-standing

immigration regulation defining the word day. So the only way to adopt the government's interpretation

is to believe that Congress used two different meanings of the word day in the same section

of the same statute. There's simply no indication that Congress took that kind of split approach.

The government's interpretation would also spell chaos for regulatory definitions and deadlines.

In the government's view, even though Section 1001.1H provides a single definition for the word

day, the immigration regulations actually use that term to mean different things throughout.

And so the only way to tell which deadline follows which

time calculation rule is to trace each deadline's history back through earlier and earlier

versions of the Code and Code of Federal Regulations. Answering a question, as simple, as does

my deadline fall on Saturday or Monday, shouldn't depend on this kind of complex

historical investigation, especially when deportations on the line. The default rule for weekends

and holidays exists precisely to avoid this kind of case-by-case guesswork. The government identifies

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