1. Do the terms "encouraging" and "inducing" an alien to reside in the
United States, within the meaning of 8 U. S.C. § 1324(a)(1)(A)(iv), extend to the filing
of lawful and permissible immigration applications that confer some legitimate benefit
to the alien, simply because the alien is allegedly misled as to the
extent of the benefit?

2. May the terms "encourage" and "ind uce" as stated in 8 U.S.C. §
1324(a)(1)(A)(iv) be validly interpreted to incl ude anything that helps or facilitates an
alien who is already residing illegally in the United States, and already illegally
employed in the United States, to remain there?

3. Does the language of 8 U.S.C. § 1324( a)(1)(A)(iv) provide fair notice that
it encompasses conduct that provides a le gitimate benefit to an alien and seeks
certifications that can be lawfully applied for on the alien's behalf, simply on the
ground that the alien is allegedly misled rega rding the extent of the benefit, and is the
statute unconstitutionally vague as applied to such conduct?

4. Did the application of Section 1324(a)(1)(A)(iv) in this case violate
petitioner's First Amendment right to pers uade aliens already residing and employed
illegally in the United States to pursue available legal remedies?

Do the terms 'encouraging' and 'inducing' an alien to reside in the United States, within the meaning of 8 U.S.C. § 1324(a)(1)(A)(iv), extend to the filing of lawful and permissible immigration applications that confer some legitimate benefit to the alien, simply because the alien is allegedly misled as to the extent of the benefit?