MEMORANDUM
DuBOIS, District Judge.
I. INTRODUCTION
Petitioner, Dan Sulaiman, is a Nigerian alien currently detained in the Berks County Prison, Leesport, Pennsylvania. He is subject to a deportation order as a result of a 1996 conviction for bank fraud in the Eastern District of New York and an Immigration & Naturalization Service ("INS") determination that he entered the United States illegally. Although petitioner...
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