Whether the petitioner should be released from federal custody due to the COVID-19 pandemic and the petitioner's underlying medical conditions

No question identified. : ay . ¥ OBJECTIVE . 1. In the mercy of the Supreme Court of the United States of America, here the alien petitioner would like the sitting Honorable Justices to consider the exceptional circumstances of the matter and the imminent impact that can be potentially will result into an irreparable injury to the petitioner alien. Petitioner alien is seeking a release from any federal custody through a Humanitarian Parole Release, see. C.F.R. 212.5(b)(1) or any Declaratory or Injunctive Relief that is seem to be deem and proper. The alien is under chronic care of respiratory disease called asthma and chronic care for allergies. Therefore, the Petition For Writ Of Habeas Corpus should be favorably granted. CUSTODY : 2. Petitioner is in physical custody of respondent and is detained at (SLIPC) . 6 South Louisiana ICE Processing Center of GEO at 3843 Stagg Ave. Basile LA 70515 ao pursuant to contractual agreement with the Department of Homeland Security. JURISDICTION 3. Petitioner is now detained in the custody of respondent at (SLIPC) South = Louisiana ICE Processing Center of GEO Corporation at 3843 Stagg Ave. Basile LA 70515. 4, This Court has the subject matter jurisdiction over this Petition under 28U.S.C 2241 (power to grant Habeas Corpus) and 28 U.S.C. 1651 (All Writs Act); and the Administrative Procedural Act, 5U.S.C. 701. 5.The action arise under the United States Constitution, the Immigration Nationality Act of 1952, as amended, 8U.S.C. 2241 et. seq. ( “The Act”) and the Administrative Procedural Act, 5 U.S.C. 701 et, seq. And The All Writs Act, 28 U.S.C. 1361. 6. The District Court shall have the original jurisdiction of all civil actions arising under the constitution, treaties or laws of the United States.28U.S.C. 1391. : 2. , ¥ PARTIES 7, Respondent William Barr is named in his official capacity as the Attorney General of the United States of America. He is responsible of the administration of the immigration laws as exercised by the Executive Office for Immigration Review, 8U.S.C. 1103 (g). He routinely transacts business with this facility. As such he is the legal custodian of the Petitioner. His address is United States Attorney General, Department Of Justice, 950 Pennsylvania Ave. NW, Washington DC 20530-0001. 8. Respondent Chad Wolf is named in his official capacity as the secretary of the DHS. His address is MS-0285, Department Of Homeland Security. 2707 Martin Luther King Jr, Avenue. SE, Washington DC 20528-525. He is responsible for the administration of the immigration laws 8U.S.C. 1103(a). He routinely transacts business with this facility. As such he is the legal custodian of the Petitioner. 9. Respondent Gary Chamberlain is named in his official capacity as the ICE Field Office Director of New Orleans. In this capacity he is the legal custodian of the petitioner. His address is 1250 Poydras St. Suite 325, New Orleans LA 70113. PRELIMANARY STATEMENT 10.This case challenges the government authority (Immigration Custom Enforcer Officers, Department Of Homeland Security) to indefinitely detain without the substantial “burden of proof” to support the finding of dangerousness or flight risk. It ask that this Court will grant the petitioner release from prolonged immigration detention. 11. Petitioner was not and is not now detained on the account of security or terrorism concerns. 8C.F.R 114(d)(1). 12. Petitioner is not an alien with a “highly contagious disease) posing a danger to the public health”. 8C.F.R. 241.14(b). 13. Petitioner has not committed a violent crime as defined 18U.S.C. (f)(1). Her release therefore would not pose a special danger to the society. 8C.ER. 241.14(f). 3. 14. World Health Organization on March 11, 2020 declare a global pandemic of a very dangerous and harmful disease, a virus called COVID 19. 15.Currently CNN News has covered the data of the COVID 19. The severe damages of the virus. The data showed on October 19, 2020 globally there is 39,858,453 cases of peop