RESPONDENT’S MOTION
FOR REDETERMINATION OF CUSTODY STATUS

The above named Respondent, through undersigned counsel, respectfully request your honor to reconsideration of custody status and to grand his motion for bond. The Respondent is found by the asylum officer credible and his case is currently pending before the Immigration Court at BTC. The Respondent respectfully requests that he be released on his own recognizance, or in the alternative, under bond at an amount of $7500 or the amount his family is able to pay or your honor deems to be proepr. In support of this application, Respondent states below:

1. RESPONDENT’S IDENTITY IS ESTABLISHED BY:

EXHIBIT A1: Chinese Resident Card ( Original is available)
EXHIBIT …show more content…
A CONTINUING DETENTION DOES NOT SERVE PUBLIC INTERESTS Respondent is not a threat to national security is not likely to abscond and is not a poor bail risk. A continuing detention would waste the U.S. tax payers’ hard working money because a report states that a detainee at BTC would cost tax payers about $120 per day. However, these unnecessary costs would be saved by releasing him and making his family supporting him while his asylum application is pending. In sum, releasing the Respondent on bond would reduce the burden to this society, would shift burden to the Respondent’s family and would serve the public interests. In light of the above factors, Respondent respectfully requests that your honor reconsider the Respondent’s custody status and he be ordered released under a bond. Should the Respondent be released on bond, he will prove his reliability in appearing at future proceedings and will be afforded the opportunity to adequately prepare his asylum application and the response to his removal proceedings. I hereby certify that a copy of the above Motion and attached documents as Exhibits A to D are served to the DHS (U.S. Immigration and Customs Enforcement -ICE ) at: 3900 N Powerline Rd, Pompano Beach, FL 33073 on May 5,