MEMORANDUM **

Maria Navarro-Figueroa petitions for review of the decision of the Board of Immigration Appeals (“BIA”) finding her removable for having assisted an undocumented alien in entering the United States. See 8 U.S.C. § 1227(a)(l)(E)(i). We deny the petition.

*695 Navarro-Figueroa contends that the BIA erred in relying on three 1-213 forms and a G-166 report of investigation because those documents contained statements obtained in violation of 8 C.F.R. § 287.3(c). Section 287.3(c) provides that an alien who has been “arrested without warrant and placed in formal proceedings” must be informed that she has a right to counsel and that statements she makes may be used against her. Formal proceedings commence with the filing of a notice to appear in the immigration court. Samayoa-Martinez v. Holder, 558 F.3d 897, 901-02 (9th Cir. 2009). Because Officer Rivera questioned Navarro-Figueroa before a notice to appear was filed in the immigration court, Navarro-Figueroa was not entitled to be informed of her rights.

Substantial evidence supports the BIA’s determination that Navarro-Figueroa affirmatively assisted Beatrice Perez-Cej a in entering the United States in violation of law. The immigration forms and the testimony of Officer Rivera indicated that Navarro-Figueroa met with Perez-Ceja in Tijuana and agreed to drive Perez-Ceja to Los Angeles after she crossed the border, knowing that Perez-Ceja lacked permission to enter the United States legally.

Petition DENIED.