District of New Jersey • 2:26-cv-11417

#1

Aug 25, 2026

First PETITION for Writ of Habeas Corpus filing fee $ 5, receipt number ANYEDC-20565074, filed by Xiao Ye Zhou. (Attachments: # 1 Civil Cover Sheet, # 2 Verification Page, # 3 589 Receipt, # 4 I-830, # 5 Notice to Admit, # 6 Written Pleadings) (Hoitsma, Justin) (Main Document 1 replaced on 8/25/2026) (SDM). (Attachment 1 replaced on 8/25/2026) (SDM). Modified on 8/25/2026 (SDM). (Entered: 08/25/2026)

#2

Aug 25, 2026

This attorney case opening filing has been checked for quality control. See the attachment for corrections that were made, if any. (SDM) (Entered: 08/25/2026)

#3

Aug 25, 2026

First MOTION for Order to Show Cause by Xiao Ye Zhou. (Hoitsma, Justin) (Entered: 08/25/2026)

Aug 25, 2026

Your proposed summons was not issued for one of the following reasons: No summons provided, please submit summons. The event can be found under the event Other Documents - Proposed Summons/Civil Cover Sheet., Please correct and resubmit using Proposed Summons/Civil Cover Sheet. (SDM)

Aug 25, 2026

Case Assigned to Judge LaShann DeArcy Hall. Please download and review the Individual Practices of the assigned Judges, located on our website. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. (SDM)

#4

Aug 26, 2026

Proposed Summons. by Xiao Ye Zhou (Hoitsma, Justin) (Entered: 08/26/2026)

Aug 26, 2026

Notice: Counsel for Xiao Ye Zhou is directed file a motion for pro hac vice admission to this district before proceeding with this case. Failure to do so may result in suspension of e-filing privileges. Brenna B. Mahoney, Clerk of Court. (ERG)

Aug 26, 2026

ORDER TO SHOW CAUSE: The Court is in receipt of the Petition 1 for Writ of Habeas Corpus ("Petition") and motion 3 for an Order to Show Cause. Petitioner is directed to serve a copy of this Order and the Petition on Respondents by August 27, 2026; Petitioner shall file proof of service on the docket by August 28, 2026. Respondents are directed to SHOW CAUSE no later than August 31, 2026, as to why the Petition 1 should not be granted. Petitioner shall file any reply on or before September 2, 2026. Petitioner shall not be removed from the Eastern District of New York absent further order of this Court. Ordered by Judge LaShann DeArcy Hall on 8/26/2026. (AIH)

Aug 27, 2026

Your proposed summons was not issued for one of the following reasons: Did not use the correct Summons form AO 440 Rev 6/12, SUMMONS IN A CIVIL ACTION or AO 441 Rev 7/10, SUMMONS ON A THIRD-PARTY COMPLAINT. The forms are located on the Courts Website located under Document Search - Forms - Clerks Office Forms., Please correct and resubmit using Proposed Summons/Civil Cover Sheet. (SG)

#5

Aug 28, 2026

Proposed Summons. by Xiao Ye Zhou (Hoitsma, Justin) (Entered: 08/28/2026)

#6

Aug 31, 2026

RESPONSE TO ORDER TO SHOW CAUSE by Attorney General of the United States, New York Field Office Director, Secretary, U.S. Department of Homeland Security, U.S. Immigration and Customs Enforcement, Warden, Delaney Hall Detention Facility (Attachments: # 1 Declaration) (Schachner, Elliot) (Entered: 08/31/2026)

#7

Sep 03, 2026

Summons Issued as to Attorney General of the United States, New York Field Office Director, Secretary, U.S. Department of Homeland Security, U.S. Immigration and Customs Enforcement, Warden, Delaney Hall Detention Facility, U.S. Attorney and U.S. Attorney General. (MLR) (Entered: 09/03/2026)

#8

Sep 03, 2026

Certified Copy of Transfer Order and docket received, Case transferred in from District of New York Eastern; Case Number 1:26-cv-05234. Original file certified copy of transfer order and docket sheet received. (Entered: 09/03/2026)

#9

Sep 03, 2026

Clerk's Letter: Justin G. Hoitsma, Esq. is not admitted to the Federal Bar of New Jersey. Notice has been mailed to 38-08 Union Street, Suite 13B, Flushing, New York 11354. (jjc, ) (Entered: 09/03/2026)

#10

Sep 03, 2026

ORDER. Respondents are hereby enjoined from transferring Petitioner from New Jersey pending further Order of the Court. Signed by Judge Brian R. Martinotti on 9/3/2026. (jjc, ) (Entered: 09/03/2026)

Sep 03, 2026

Judge Brian R. Martinotti added. (jjc, )

Sep 03, 2026

Case transferred to District of District of New Jersey. Original file, certified copy of transfer order, and docket sheet sent. ALL FILINGS ARE TO BE MADE IN THE TRANSFER COURT, DO NOT DOCKET TO THIS CASE.( Extract Civil Case due by 9/10/2026.) (JT)

Sep 03, 2026

Order

Sep 03, 2026

Add and Terminate Judges

Sep 03, 2026

TRANSFER ORDER: Xiao Ye Zhou ("Petitioner") filed a Petition 1 for Writ of Habeas Corpus ("Petition") pursuant to 28 U.S.C. § 2241. In an August 26, 2026 Order, this Court directed Respondents to show cause as to why the Petition should not be granted. In their September 02, 2026 letter responding to the Court's Order to Show Cause, Respondents confirm that Petitioner was detained at the Delaney Hall Detention Facility in Newark, New Jersey at the time the Petition was filed. Petitioner remains detained at Delaney Hall. (Resp. O.S.C., ECF No. 6.) Under 28 U.S.C. § 2241(a), district courts are limited to granting habeas relief "within their respective jurisdictions." When interpreting this language, the Supreme Court has held that habeas petitions challenging present physical confinement may be brought in "one district: the district of confinement." Rumsfeld v. Padilla, 542 U.S. 426, 443 (2004). As such, this action is TRANSFERRED to the United States District Court for the District of New Jersey. See Moussaoui v. Biden, No. 25-CV-0691, 2025 WL 457804, at *1 (S.D.N.Y. Jan. 28, 2025). The Clerk of Court is respectfully directed to transfer this action in accordance with this Order and close this case. When doing so, it is further ordered that the seven-day waiting period in Local Civil Rule 83.1 shall be waived. Petitioner shall not be transferred outside the District of New Jersey without further order from the United States District Court for the District of New Jersey. SO Ordered by Judge LaShann DeArcy Hall on 9/3/2026. (JT)

#11

Sep 08, 2026

NOTICE of Appearance by BRIDGET ELLEN ZARRILLO on behalf of ATTORNEY GENERAL OF THE UNITED STATES, New York Field Office Director, Secretary U.S. Department of Homeland Security, U.S. Immigration and Customs Enforcement, Warden, Delaney Hall Detention Facility (ZARRILLO, BRIDGET) (Entered: 09/08/2026)

#12

Sep 08, 2026

Letter from Respondents regarding Petitioner's release. (ZARRILLO, BRIDGET) (Entered: 09/08/2026)

#13

Sep 09, 2026

TEXT ORDER: Before the Court is Respondents' letter informing the Court of Petitioner's release from custody. (ECF No. 12.) Accordingly, it is ORDERED that the Clerk of the Court shall CLOSE this case. So Ordered by Judge Brian R. Martinotti on 09/09/2026. (lr, ) (Entered: 09/09/2026)

Sep 09, 2026

Terminate Civil Case

Sep 09, 2026

***Civil Case Terminated. (wh)

Sep 09, 2026

Text Order