Even where evidence is presented in a Form I-213 Record of Deportable Alien, that evidence cannot constitute "clear, unequivocal, and convincing evidence" of removability where the information contained in the Form I-213 comes from an unknown source. Compare Espinoza v. INS, 45 F.3d 308, 311 (9th Cir. 1995) ("Here we have a government document in which a government agent simply noted a persons alienage, presumably from information out of the aliens mouth.") (emphasis added); Matter of Ponce-Hernandez, 22 I & N Dec. 784, 785 (BIA 1999)("there is nothing to indicate that [the information in the Form I-213] came from anyone other than the respondent"). Where the DHS does not identify the documents and databases upon which the agency relied in creating the I-213, counsel can argue that the I-213 should not be relied upon to make a finding of removability. See, Murphy v. INS, 54 F.3d 605, 610-11 (9th Cir. 1995) (concluding that an unauthenticated I-213 "merits little (if any) weight" because the petitioner disputed "significant information" on the form and "also provided information regarding the source of the information recorded on the form, an INS informant who apparently had some ulterior motive to make statements against" him); Cunanan v. INS, 856 F.2d 1373, 1374 (9th Cir. 1988) (BIAs reliance on an I-213 was fundamentally unfair because the information therein came from a woman, the petitioners wife, who had not been subject to cross-examination).