The following excerpt is from Solanki v. I.N.S., 122 F.3d 1073 (9th Cir. 1997):
An order of deportation entered in absentia may be rescinded only if an alien demonstrates that he failed to appear at the deportation proceeding because of exceptional circumstances. See 8 U.S.C. 1252b(c)(3) (1994). Exceptional circumstances are defined as "circumstances (such as serious illness of the alien or death of an immediate relative of the alien, but not including less compelling circumstances) beyond the control of the alien." 8 U.S.C. 1252b(f)(2) (1994). Traffic difficulties do not qualify as exceptional circumstances. See Sharma v. INS, 89 F.3d 545, 547 (9th Cir.1996).
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