Kovacs v. U.S., 744 F.3d 44, 52 (2d Cir. Mar. 3, 2014) (We conclude that a defense lawyer's incorrect advice about the immigration consequences of a plea is prejudicial if it is shown that, but for counsel's unprofessional errors, there was a reasonable probability that the petitioner could have negotiated a plea that did not impact immigration status or that he would have litigated an available defense. [Footnote omitted.] See United States v. Kwan, 407 F.3d 1005, 1017"18 (9th Cir.2005) (Kwan could have gone to trial or renegotiated his plea agreement to avoid deportation.). The petitioner must clearly demonstrate that he placed particular emphasis on [immigration consequences] in deciding whether or not to plead guilty. Id. at 1017 (internal quotation marks omitted).); also citing Sasonov v. United States, 575 F.Supp.2d 626, 639 (D.N.J.2008) (immigration consequences may have been enough to ... have allowed [petitioner] to negotiate a more favorable plea agreement with the Government.); United States v. Shaw, No. Civ.A. 03"6759, 2004 WL 1858336, at *11 (E.D.Pa.2004) (Defendant could have negotiated with the government in such a way as to produce a sentence that would not have triggered the INA mandatory removal provisions.).