Friday, October 30, 2009

US Takes Steps Towards Protecting Abused Women Seeking Asylum

U.S. May Be Open to Asylum for Spouse Abuse
Published: October 29, 2009

"In an unusually protracted and closely watched case, the Obama administration has recommended political asylum for a Guatemalan woman fleeing horrific abuse by her husband, the strongest signal yet that the administration is open to a variety of asylum claims from foreign women facing domestic abuse...

Immigration lawyers said the administration had taken a major step toward clarifying a murky area of asylum law and defining the legal grounds on which battered and sexually abused women in foreign countries could seek protection here."

Thursday, October 29, 2009

Chinese Government Posts Pictures of Recovered Kidnapped, Stolen, Sold Children in Effort to Find Parents

Chinese officials try to find parents of 60 lost children
October 29, 2009

"The Chinese government is trying to find the parents of these 60 homeless children, some of them so young that they had not yet developed the strength to hold their own heads up.
This week the Chinese Ministry of Public Security posted pictures of these rescued children on its Web site.
Many of them had similar stories. They were kidnapped, stolen or sold and somehow had been rescued by authorities.
Police tried to find their parents but could not find them through the national DNA database, state-run China Daily reported.
And for the first time, the Ministry of Public Security posted their pictures...

About 30,000 to 60,000 children are reported missing every year, but it is hard to estimate how many are involved in child trafficking cases, the Ministry of Public Security told China Daily.
Police have rescued 2,000 children this year since China launch a nationwide anti-trafficking campaign, China Daily reported.

But after rescuing the children finding the parents can prove difficult. One issue is that in some cases the parents sold the children."
Read the full story:

UN Torture Investigator Deported from Zimbabwe

Zimbabwe Deports U.N. Investigator
Published: October 29, 2009

"The Zimbabwe government on Thursday deported a torture investigator from the United Nations, Manfred Nowak.

Mr. Nowak, who was detained at the airport in Harare, Zimbabwe’s capital, a day earlier, was put on a plane to Johannesburg, news reports said.

Mr. Nowak questioned the reason given by the government for blocking his visit 'at such a late stage': that it needed to change the timing because of a gathering of regional ministers looking into a breakdown in the power-sharing government, according to a United Nations statement.
The statement also said allegations that human rights workers and supporters of Prime Minister Morgan Tsvangirai had been intimidated and arrested in recent days 'highlights the urgency of objective fact-finding by an independent U.N. expert.'”

Wednesday, October 28, 2009

Ponzi-like Adoption Scam

"N.Y. man charged in Ponzi-like adoption scam
Prosecutors have charged a New York attorney with victimizing 13 couples in a multistate, Ponzi-like adoption scam.
Kevin Cohen of Roslyn was arraigned Wednesday on an indictment accusing him of grand larceny and other charges.
Nassau County prosecutors say Cohen promised couples from New York, Georgia, Ohio, Texas and Florida that he could arrange adoptions. In reality, the babies never existed."
Read the full story:

Monday, October 26, 2009

I.C.E. News

"ICE names new leader of the Office of Investigations in New York City
NEW YORK - U.S. Immigration and Customs Enforcement (ICE) Assistant Secretary John Morton has named James T. Hayes Jr. as the special agent in charge of the ICE Office of Investigations in New York City.

As special agent in charge, Hayes supervises a cadre of special agents who enforce immigration and customs laws by conducting investigations in a variety of areas, including: narcotics, financial- and trade-related, gangs, intellectual property rights, human smuggling, and child pornography."
Read the full story:

"More than 300 arrested in two-day nationwide takedown
'Project Coronado' results in nearly 1,200 arrests during 44-month operation,seizures of more than 11.7 tons of drugs and $32.8 million in US currency

The arrest of nearly 1,200 individuals on narcotics-related charges and the seizure of more than 11.7 tons of narcotics was announced as part of 'Project Coronado,' a 44-month multi-agency law enforcement operation, which included U.S. Immigration and Customs Enforcement (ICE)

...303 individuals in 19 states were arrested as part of Project Coronado, which targeted the distribution network of a major Mexican drug trafficking organization known as 'La Familia,' through coordination between federal, state and local law enforcement. More than 3,000 agents and officers operated across the United States to make the arrests during the two-day takedown. During the two-day operation alone, participating agencies seized the following: $3.4 million in U.S. currency, 729 pounds of methamphetamine, 62 kilograms (136 pounds) of cocaine, 967 pounds of marijuana, 144 weapons and 109 vehicles."

"2 alien smugglers from Miami sentenced to federal prison
1 of the 6 indicted defendants in this 2007 alien smuggling operation remains a fugitive
On Nov. 14 and 15, 2007, the U.S. Border Patrol (USBP) received information from the Juno Beach Police Department regarding three possible smuggling operations. Within hours, the Town of Palm Beach Police Department notified USBP that 34 migrants had landed. The U.S. Coast Guard (USCG) responded and discovered that one of the migrants, Carlos Alberto Pons-Arias, drowned as he tried to swim to shore on Palm Beach. The migrants consisted of 35 Cuban nationals, including 17 men, two juvenile males, 12 women, three juvenile females, and the deceased man who drowned. All the migrants stated that they recently swam ashore from a boat that traveled directly from Cuba. The incident was referred to ICE special agents in West Palm Beach for investigation.
To date, all five defendants arrested have pleaded guilty and were sentenced to prison....Luis Arce Perez is believed to have fled to Cuba and is armed and dangerous. ICE urges anyone with information on his whereabouts to contact 1-866-DHS-2ICE (347-2423)."
"North Texas man sentenced to the maximum of 70 years in federal prison for producing, possessing child pornography
Dickson took pornographic photos of baby boy entrusted to his care 
This case was prosecuted as part of Project Safe Childhood, a nationwide initiative to combat the growing epidemic of child sexual exploitation and abuse launched in May 2006 by the Department of Justice. Led by U.S. Attorneys' Offices and the Criminal Division's Child Exploitation and Obscenity Section (CEOS), Project Safe Childhood marshals federal, state and local resources to better locate, apprehend and prosecute individuals who exploit children via the Internet, as well as to identify and rescue victims. For more information about Project Safe Childhood, visit"
"Bosnian sentenced to prison for failing to disclose murder
A Bosnian man was sentenced to eight months in prison Friday for failing to disclose that he had been charged with murdering a man when he applied for a U.S. immigration benefit. This sentence was announced by U.S. Attorney Matthew G. Whitaker, Southern District of Iowa; U.S. Immigration and Customs Enforcement (ICE) conducted the investigation."

"Washington State pair sentenced to prison on immigration fraud charges
The former owner of an immigration consulting business in King County, Wash., and his ex-wife were sentenced Oct. 23 in federal court on charges of conspiracy to commit immigration fraud, following an investigation by U.S. Immigration and Customs Enforcement (ICE.)
Steven Mahoney, 41, of Kent, Wash., was sentenced to 18 months in prison and three years of supervised release. Helen Mahoney, 39, also of Kent, was sentenced to six months in prison and two years of supervised released for her role in the conspiracy.

Steven Mahoney owned Mahoney and Associates where he counseled, advised and prepared immigration applications for immigrants seeking legal status to live in the United States. Helen Mahoney assisted in completing and submitting the applications to the federal government.
According to court documents, from October 1998 until June 2007, Steven Mahoney filed up to 99 false asylum claims on behalf of immigrants. The applications falsely stated that these individuals would be abused because they were homosexual, or they held religious or political views that would result in torture in their home countries.
Once the fraudulent applications were completed, Helen Mahoney submitted them to U.S. Citizenship and Immigration Service (USCIS), the federal agency that processes these documents. Court documents show that the Mahoneys knew these statements were not true for certain applicants, but still filed the claims.
The Mahoneys coached applicants on how to pursue immigration status based on these false claims. They were paid between $1,000 and $4,000 for each falsified application."

Iranian 'Blood Money' Law

Iran lawyer in 'blood money' plea
An Iranian lawyer has appealed for money to spare the lives of four of his clients, who face execution for murders committed when they were aged under 18.

"Mostafaie is defending 25 young people, all facing the death penalty

Under Iranian law, a family can pardon a relative's murderer,
and compensation - called blood money - is often paid.

Mohammad Mostafaie said he needed to raise
$200,000 (£120,700) to pay the families of his clients' victims.
Amnesty International says Iran has executed at least 42 juvenile offenders since 1990, flouting international law...Murder, rape, armed robbery, kidnapping, and drug trafficking are all punishable by death in Iran."

Karadzic Fails to Appear for Trial, Claims Needs More Time to Prepare Defense

Karadzic boycotts start of trial
Former Bosnian Serb leader Radovan Karadzic has failed to appear at his trial on 11 charges including genocide, war crimes and crimes against humanity.

Mr Karadzic denies the charges, which relate to the Bosnian war of the 1990s.
The judge adjourned the case for a day, and requested Mr Karadzic, who is representing himself, to appear.
However, a legal adviser for Mr Karadzic told the BBC he would not appear as he still needed at least nine months to prepare his defence.

Iraq Vet's Wife May Be Deported

"Struggling Iraq vet may lose his anchor
His wife, brought here illegally at age 6, is about to be deported. 'She's my everything,' her husband says."
By Teresa Watanabe
October 26, 2009

"Two years after returning from his service in Iraq, U.S. Army Spc. Jack Barrios, 26, is fighting sleeplessness, sudden angry outbursts, aversion to emotional intimacy and other fallout from his post-traumatic stress disorder.
But as he undergoes counseling and swallows anti-depressants, the soldier is fighting an even bigger battle: to keep his family from collapsing as his wife, an undocumented immigrant from Guatemala, faces deportation.
His wife, 23-year-old Frances, was illegally brought to the United States by her mother at age 6, learned of her status in high school and discovered just last year that removal proceedings have been started. Her possible deportation has left Barrios in panic as he contemplates life without her.
The Army reservist says his wife is the family's anchor, caring for their year-old daughter and 3-year-old son and helping him battle his post-traumatic stress.",0,4800387,full.story

Saturday, October 10, 2009

U.S.C.I.S. Updates

USCIS Update: Change of Filing Location for Form I-600 and I 600A
"WASHINGTON—U.S. Citizenship and Immigration Services (USCIS) today announced a new address for prospective adoptive parents to submit Form I 600, Petition to Classify Orphan as an Immediate Relative, and Form I 600A, Application for Advance Processing of Orphan Petition. While the change takes affect today [October 6, 2009], applicants have a 30-day transistion period before USCIS will return incorrectly filed petitions."
For complete update click here:

USCIS Clarifies Requirements for Agents Filing as Petitioners for the O and P Visa Classification

"U.S. Citizenship and Immigration Services (USCIS) is clarifying for performing arts associations and their members the regulatory requirements for agents who file as petitioners for the O and P visa classification."
For complete update click here:

Rapper Son of Belize PM Facing Deportation From US

Son of Belize PM faces deportation from US

"The son of Belize Prime Minister Dean Barrow faces deportation to his country of birth after serving more than nine years in jail.

Jamal Barrow, better known as rapper Shyne, was released from prison yesterday after serving more than nine years for his role in a 1999 New York night club shooting that allegedly involved Sean `P Diddy` Combs and actress Jennifer Lopez...

Representatives for the rapper revealed to MTV News that the Brooklyn MC is being detained by US Immigration and Customs Enforcement at an unspecified facility in Western New York State. Officials are determining whether or not to deport him.  

Under US immigration law, a non-citizen who committed a crime faces deportation back to their home land."

Canada: Despite UN Ruling on Civil Rights, Son Deportable Because Sentenced for Federal Crime and Parents Never Became Citizens

Haitian man deported despite UN ruling
22-year-old Montrealer discovers he is not Canadian

"A Haitian-born man who was fighting deportation from Canada after serving a prison sentence for theft and assault was sent back to his native country this week.

This comes despite a UN ruling that said the expulsion would violate John Michael Dauphin's civil rights.
Dauphin, 22, was put on a private plane in Montreal and sent back to Haiti early on Monday, just hours before his immigration lawyer, Chantal Ianniciello, was scheduled to argue for his release from detention, a request she said was supported by a UN Human Rights Committee ruling in Dauphin's favour.

'Immigration could have deported him at any time before today,' Ianniciello told CBC News. 'They decided not to. They decided to wait for the [UN] decision and surprisingly, now that it is in his favour, they decided to remove him, without nobody knowing.'...

Dauphin was scheduled for deportation because of his criminal record. Under Canadian law, non-citizens can be returned to their home countries when they are sentenced to federal prison terms...

Dauphin was sentenced to 33 months in jail after he attacked and robbed a Quebec court appeals judge in Old Montreal in 2005.
That's when he discovered his parents never obtained Canadian citizenship on his behalf, despite having moved to Montreal when he was two years old. Dauphin's brothers and sisters were all born in Canada and are citizens."

Afghan Asylum Seekers Claim Persecution by Taliban as Basis

Afghans seek refuge in Tajikistan
By Rayhan Demytrie
BBC News, Vahdat

"Sitting on the floor in her one-bedroom flat in the Tajik city of Vahdat, Afghan refugee Farzona Sakhi is sifting through dozens of certificates obtained on completion of Western NGO-run courses in Afghanistan.
Her latest job was with Save the Children in Kabul. But she was forced to leave the country after being threatened by the Taliban.

'I taught underage girls their rights, I explained [to] them what is forced marriage or early marriage. Child abuse is a huge problem in Afghanistan. I worked with them for four years but then I received a warning letter,' says Ms Sakhi, holding back tears.

'They said my teaching is against Islam, and that I am teaching Christian values. I had to leave Kabul.'
According to the UN refugee agency, cases like hers mark one of the new trends among Afghan asylum seekers in Tajikistan - educated English-speakers who claim they are escaping persecution from the Taliban for their association with Western NGOs."

Lisbon Treaty Adds Poland

Polish leader ratifies EU treaty
Polish President Lech Kaczynski has signed the European Union's much-delayed Lisbon Treaty.

"Mr Kaczynski, a noted Eurosceptic, said he was convinced the treaty would be successful but that the EU should remain a union of sovereign states.
The treaty's prospects of coming into force received a major lift last week when Irish voters approved it in a second referendum.

But the Czech President Vaclav Klaus then raised fresh doubts when he said he would not sign the treaty unless his country was granted an opt-out from the EU's Charter of Fundamental Rights.
Mr Klaus raised fears about possible property claims by Germans expelled from the then Czechoslovakia after World War II."

Written Order in Deportation Case

Judge issues written order in Megahed deportation case
By Kevin Graham, Times Staff Writer
Saturday, October 10, 2009

"The immigration judge in Miami-Dade County who spared Youssef Megahed from deportation said in a written order Friday that the government failed to prove the University of South Florida student is linked to a terrorist cell or that he has an escalating interest in terrorism.
'In spite of an FBI investigation which delved deeply into (Megahed's) Internet usage and network of friends, the (Department of Homeland Security) never alleged or proved that (Megahed) belongs to a network of individuals who share anti-American beliefs or terrorists ambitions,' Immigration Judge Kenneth S. Hurewitz wrote in a 66-page order.
The document elaborated on his August oral ruling that dismissed a deportation case against Megahed and set him free. That followed a weeklong deportation hearing in South Florida."

Saturday, October 3, 2009

New Forms for Notice of Entry of Appearance as Attorney or Accredited Representative

USCIS Update: USCIS Announces Publication of New Notice of Entry of Appearance forms for Attorneys or Accredited Representatives

"U.S. Citizenship and Immigration Services (USCIS) announced today that a revised Notice of Entry of Appearance as Attorney or Accredited Representative (Form G-28) and the new Notice of Entry of Appearance as Attorney in Matters Outside the Geographical Confines of the United States (Form G-28I) has been issued.

USCIS will provide a 30-day grace period for the Form G-28, until Oct. 30, so that Forms G-28 currently in the mail will be considered valid when received at the USCIS Lockbox facility or USCIS Service Center. After Oct. 30, any prior versions of the Form G-28 that are received will be considered invalid. All Forms G-28 filed before Oct. 30, will be honored for previously filed cases as long as the Forms G-28 were properly completed by an eligible attorney or accredited representative. The new Form G-28 is not required for receiving updates or interviews unless a new attorney is representing the applicant.

The new Form G-28I is for use by attorneys admitted to practice law who seek to appear before the Department of Homeland Security (DHS) in matters outside of the United States. Acceptance by a DHS entity of a completed Form G-28I does not itself constitute approval by the DHS entity for the attorney to represent the applicant or petitioner in the matter for which Form G-28I was filed. The Form G-28I may not be filed for matters in DHS offices within the United States.

To obtain the new Form G-28 and G-28I, and instructions for completion of the forms, please visit the USCIS forms page."

I.C.E. News

Convicted drug trafficker sentenced in third largest marijuana seizure at Miami International
"A former resident of Broward County was sentenced Oct. 2 to 10 years in prison for his involvement in the third largest importation of marijuana at Miami International Airport with an estimated street value of $4.3 million following a U.S. Immigration and Customs Enforcement (ICE) investigation.

Ryan Gayle, 32, was sentenced in the Southern District of Florida before District Court Judge Richard W. Goldberg to 121 months in federal prison and five years supervised release.

On Nov. 30, 2006, U.S. Customs and Border Protection (CBP) officers at the Miami International Airport seized approximately 3,540 pounds of marijuana concealed inside cargo manifested as black pepper and seasoning coming from Kingston, Jamaica. The seizure was the result of a long term undercover investigation conducted by ICE special agents in Miami, who determined that the intended recipient of the marijuana was Ryan Gayle.

During the course of the investigation, ICE special agents documented several attempts by Ryan Gayle to unlawfully import other marijuana shipments concealed aboard commercial cargo flights in May 2007 and August 2007 into Miami International Airport."

Canadian predator on the run for more than 20 years nabbed by ICE, Florida law enforcement officials

"A Canadian national that has been evading law enforcement for more than 20 years for sexually molesting a child was nabbed in Homestead, Fla., Tuesday by U.S. Immigration and Customs Enforcement (ICE) special agents and officers from the Collier County Sheriff's Office and the Homestead Police Department.
 Douglas Elmore Brenner, 65, is wanted by the Waterloo Regional Police in Canada for sexual assault on a juvenile under 14. He entered the United States. in 1984 and assumed the identity of a deceased man in 1986.

ICE agents learned about Brenner after receiving information from the Collier County Sheriff's Office who learned that Brenner was hiding in Florida. An investigation was immediately launched to track down Brenner. He was found in a hotel located at 841 North Krome Avenue in Homestead.

Brenner has been charged administratively for being illegally present in the county. He has been placed in administrative removal proceedings and will appear before an immigration judge. If ordered removed, Brenner will be turned over to Canadian authorities based on an outstanding arrest warrant."


ICE deports illegal alien wanted in Jamaica for murder

"A Jamaican national who fled to the United States to avoid serving a criminal sentence for murder was deported Sept. 24 by U.S. Immigration and Customs Enforcement (ICE) deportation officers.

Mark Dixon, 39, was returned to Jamaica under ICE escort without incident. The New Orleans Field Office of Detention and Removal coordinated his removal with the assistance of the ICE Attaché in Kingston, Jamaica.

In 1998, Dixon illegally entered the United States in Buffalo, N.Y. On Feb. 27, 2008, he was convicted in Arizona for being an illegal alien in possession of a firearm and for making a false claim to U.S. citizenship. Dixon was sentenced to a year and six months in prison. He subsequently appealed the conviction to the Ninth Circuit Court of Appeals and on Feb.12, 2009, the court affirmed the conviction.

On June 16, 2008, Dixon was released from the Bureau of Prisons into ICE custody. He was later served with a Notice to Appear before an immigration judge charging him with immigration violations. On July 1, 2008, an immigration judge ordered Dixon removed to Jamaica."


ICE, Texas law enforcement arrest 20 in 3-day anti-gang operation
"Twenty people were arrested this week during a three-day, joint anti-gang operation with U.S. Immigration and Customs Enforcement (ICE), Big Spring Police Department (BSPD) and Howard County Sheriff's Office that ended Wednesday.
This is the latest joint, local action of an ongoing national initiative of ICE's National Gang Unit called Operation Community Shield, in which ICE partners with other federal, state and local law enforcement agencies to target the significant public-safety threat posed by street gangs, many with transnational ties.

During this operation, all of those arrested are U.S. citizens who live in Big Spring. Eight had outstanding arrest warrants; the others were arrested on various criminal charges. Of those arrested, 15 were active gang members or their associates of the following gangs which operated in Big Spring: Blood, Mexican Mafia, Tango Blast and Aryan Brotherhood."

Detainee passes away at South Carolina hospital
"On Sept. 30, Ruben Sandoval, a 21-year-old Guatemalan national being held pending immigration removal proceedings, passed away at the Providence Memorial Hospital (PMH) in Columbia, S.C., due to cardiopulmonary arrest as a result of metastatic cancer.

Mr. Sandoval entered ICE custody on May 7, 2009, in Omaha, Neb. He was served with a Notice to Appear before an immigration judge and his bail was set at $2,500. At the time of his arrest, Mr. Sandoval stated that he had no known medical conditions. However, on May 7, the day of his arrest, jail officials and medical staff observed that Mr. Sandoval was having difficultly breathing and took him to the University of Nebraska Medical Center (UNMC) for evaluation.
Mr. Sandoval was subsequently diagnosed with having a malignant tumor around his airway and heart and began receiving chemotherapy at UNMC. On June 15, Mr. Sandoval was transferred to Columbia Care Center (CCC) in Columbia, S.C., for continued, long-term treatment."

Bank president arrested by ICE in Puerto Rico
"The executive president of Cooperativa de Ahorro y Crédito La Comerieña was arrested Monday by U.S. Immigration and Customs Enforcement (ICE) special agents for violations of the Bank Secrecy Act.

Arnaldo Calderón-Rivera, 51, has been charged with violations to Title 31 USC 5318 (g) (2) (A) (1) for allegedly disclosing sensitive information contained in Bank Secrecy Act reports to a person who was not employed by his bank."

ICE deports Mexican fugitive sought for sexually assaulting a child
"U.S. Immigration and Customs Enforcement (ICE) officers deported a Mexican national on Thursday wanted by authorities for sexually assaulting a minor in his home country.
Jose Luis Martinez-Gonzalez, 23, was turned over to Mexican authorities at 10 a.m. on Sept. 29 at the Port of El Paso's Stanton Street Bridge. Martinez-Gonzalez is wanted in Oaxaca, Mexico, for raping a minor."

Airport temporary staffing employees sentenced for harboring illegal aliens who were given access to secure areas

Assisted illegal workers in obtaining unauthorized airport security badges
"The owner of a Bensenville temporary employment agency and her assistant were sentenced in federal court Wednesday for harboring illegal aliens and assisting those workers in obtaining unauthorized access to secure areas at O'Hare International Airport, including the tarmac. The sentences resulted from a multi-agency federal investigation conducted in 2007 and led by U.S. Immigration and Customs Enforcement (ICE)."

New ICE initiative uses biometrics to enhance identification and removal of criminal aliens from Prince William County

Now criminal and immigration records of all those arrested to be checked
"Beginning Tuesday, law enforcement agencies in Prince William County will benefit from a new initiative developed by the Departments of Justice (DOJ) and Homeland Security (DHS) that modernizes the process used to accurately identify and remove dangerous criminal aliens from the community.

The initiative, Secure Communities, is administered by U.S. Immigration and Customs Enforcement (ICE). Secure Communities enables ICE to determine whether an individual arrested by a participating state or local law enforcement agency is a dangerous criminal alien and take the appropriate action to remove the individual from the community."

Justice Awaits those Involved in Killings Following 2007 Elections

International court to handle Kenya post-election violence
CNN's David McKenzie contributed to this report.

"Kenya's coalition government promised action after more than 1,000 people were killed following a disputed election in December 2007. Hundreds of thousands were displaced amid the bloodshed. One of the chief promises was the formation of a tribunal to try the perpetrators of that violence.

Now that Kenya has missed the deadline, Moreno-Ocampo [chief prosecutor of the International Court], announced a plan to address the issue.
In the statement, he said the International Criminal Court would prosecute those most responsible, and other perpetrators would be subject to 'national accountability proceedings as defined by the Kenyan Parliament, such as a Special Tribunal.'"

Ireland OKs EU Treaty

Ireland votes in favor of EU treaty
CNN's Brooke Bowman and Barry Neild contributed to this report.

"Ireland has voted in favor of the Lisbon Treaty, which would modernize the structure of the European Union, according to official government results released Saturday.

The agreement passed 67.13 percent to 32.87 percent.
A 'yes' vote had been anticipated in the Friday referendum for the controversial plan.
Irish Prime Minister Brian Cowen proclaimed victory as the votes were counted Saturday, saying, 'we have done the right thing for our own future and the future of our children.'

'Today the Irish people have spoken with a clear and resounding voice. This is a good day for Ireland and a good day for Europe. We as a nation have taken a decisive step for a stronger, fairer and better Ireland, and a stronger, fairer and better Europe,' Cowen said."