IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Civil Action No. 03-M-0102 (OES)

John Doe,

Petitioner,

V.

MICHAEL COMFORT, Acting District Director (ADD), Immigration and Naturalization Service (INS), Denver District, Executive Office for Immigration Review,

Respondent,

U.S. ATTORNEY GENERAL, John Ashcroft,

Respondent.

PETITIONER’S MOTION TO GRANT WRIT OF HABEAS CORPUS 

POSTURE: 
 
On May 29, 2003, Petitioner received his final order of determination from the Board of Immigration Appeals (BIA or the Board), sustaining the denial of the Immigration Judge (IJ) ’s denial of Petitioner’s Motion to reopen his case. Petitioner has exhausted his administrative remedies. This Motion follows Petitioner’s prior request for Motion to Grant Writ of habeas Corpus.

WHEREFORE, Petitioner requests this honorable court grant a writ of habeas corpus to the Petitioner, order the Respondent to release Petitioner from INS detention, or order Respondent, INS, District Director, (now U.S. Department of Homeland Security) to permit Petitioner a bond hearing and grant Petitioner a reasonable bond, and to grant any further relief as this court deems just and equitable.

Respectfully submitted,                                                             Date: July 24, 2003

PATRICK C. HYDE, P.C.

_____________________________________

Patrick C. Hyde,
Attorney
Reg. No. 14633
139 West Tenth Avenue
Denver, CO 80204
303-825-2220
303-825-1718 (fax)
lawoffice@patrickchydepc.com  

CERTIFICATE OF SERVICE

I, _______________________________________, certify that I served the above:

 PETITIONER’S MOTION TO GRANT WRIT OF HABEAS

By depositing it in the US mail, the 24th day of July, 2003, postage prepaid to:
DHS, Office of the District Director
4730 Paris Street
Denver, CO 80239

DHS, District Counsel
4730 Paris Street
Denver, CO 80239

US Attorney
ATTN: Deputy Chief, Michael Hegarty
1225 17th  Street, 7th Floor
Denver, CO 80202

US Department of Justice
US Attorney General John Ashcroft
1440 Pennsylvania Street NW Suite 4400
Washington, DC 20530

                                                             ____________________________________