Family based Green card , non-availability of Birth certificate, born before 1970

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I am an US citizen and sponsoring family based green card for my mom. My I-130 is still in process and I-485 is in RFE to submit medical test and birth certificate by June 2024. My mom was born before 1970 and does not have birth certificate available. I do see the details on USCIS site that Indians born before 1970 doesn't require the birth certificate.

My question now is that how do i respond to RFE as it is requesting the birth certificate now. what document should be submitted explaining it is not available? Is there self affidavit document required to be submitted for birth certificate non-availability? if so, is there a sample format that someone could share? 

We have obtained a supporting document from my mom's birthplace with couple of Neighbours supporting/knowing her birth as well. can that also be submitted along with it? 

Appreciate your timely help in advance. 


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