United States v. Harvey, 746 F.3d 87, 89-90 (2d Cir. Mar. 26, 2014) (per curiam) (federal conviction for illegal reentry after deportation affirmed, over objection that evidence of actual deportation was insufficient to sustain the conviction: a properly executed warrant of deportation, coupled with testimony regarding the deportation procedures followed at that time, is sufficient proof that a defendant was, in fact, physically deported from the United States.); citing United States v. Garcia, 452 F.3d 36, 43"44 (1st Cir.2006); United States v.

Kovacs v. United States, ___ F.3d ___ (2d Cir. Mar. 3, 2014) (in the context of an affirmative misadvice claim, a noncitizen defendant can demonstrate prejudice if she shows that, but for counsels unprofessional errors, there was a reasonable probability that the petitioner could have negotiated a plea that did not impact immigration status).

Kovacs v. U.S., 744 F.3d 44 (2d Cir. Mar. 3, 2014) (petitioner demonstrated reasonable probability that he could have negotiated a plea that did not affect his immigration status, and demonstrated reasonable probability that he would have proceeded to trial if he had known the truth).

Kovacs v. U.S., 744 F.3d 44, 49 (2d Cir. Mar. 3, 2014) (A petitioner seeking coram nobis relief must demonstrate that 1) there are circumstances compelling such action to achieve justice, 2) sound reasons exist for failure to seek appropriate earlier relief, and 3) the petitioner continues to suffer legal consequences from his conviction that may be remedied by granting of the writ. Foont v. United States, 93 F.3d 76, 79 (2d Cir.1996) (internal citations and quotation marks omitted).).