With over twenty-five years of experience in the customs and trade law area, Jessica has a deep understanding of all aspects of compliance with and enforcement of Customs and international trade laws and regulations.  In addition to agency practice, Jessica has successfully litigated numerous cases before the U.S. Court of International Trade (“CIT”) and U.S. Court of Appeals for the Federal Circuit (“CAFC”) and has obtained reversals of adverse CBP classification determinations and Department of Commerce AD/CVD scope rulings.  While much of her practice focuses on assisting clients in the food and agriculture, dietary supplements, medical devices, and pharmaceutical industries, Jessica has routinely represented clients of all industry types.

Her primary areas of focus include:

Practice before CBP

Jessica regularly provides advice and counsel to clients on CBP and international trade compliance issues and enforcement actions, including advice as to tariff classification, valuation, country of origin, utilization of special tariff provisions, duty preference programs, and bilateral and regional free trade agreements.  She has provided guidance to numerous pharmaceutical clients on tariff and trade issues, including duty savings that may be obtained through use of the prototype entry process and temporary importations under bond.

Jessica advises and advocates for clients on the full spectrum of CBP enforcement and potential enforcement issues, including responses to CBP requests for information and notices of action, detentions, seizures, pre-penalty proceedings, and penalty proceedings; filing and perfecting prior disclosures; and obtaining duty refunds through the protest process.

CIT and CAFC Litigation

Jessica is a creative and experienced litigator who has represented clients in numerous cases before the CIT and the CAFC, and has first chaired these cases through both briefing and oral argument.  She has filed a number of IEEPA tariff cases currently pending before the CIT.  She has also served as co-counsel in the Northen District of California and the District of New Jersey in litigation related to false or misleading advertising and marketing of a pharmaceutical; has litigated labor issues before the U.S. Court of Appeals for the Eighth Circuit; and has assisted in litigation regarding private enforcement of California Proposition 65.

Forced Labor/UFLPA

Jessica has deep experience in the area of forced labor, including the “traditional” prohibition on the importation of goods made in whole or in part with forced labor found in 19 U.S.C. § 1307 and the more recent prohibitions imposed by the Uyghur Forced Labor Prevention Act (UFLPA).  She has assisted multiple foreign producers whose goods were the subject of withhold release orders (WROs) and/or Findings to resolve those enforcement actions and obtain the lifting of the import bans, including obtaining the first lifting of a Finding that had occurred in 27 years.  She also aids foreign producers and U.S importers in connection with forced labor and UFLPA due diligence issues, including advice on assessment and remediation of forced labor risks.