Case Name in Immigration Case - Unavailable

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
ZHI MING ZHANG,
Petitioner,
v.
KENNETH GENALO, New York City Field
Office Director, U.S. Immigration and Cus-
toms Enforcement, KRISTI NOEM, U.S.
Secretary of Homeland Security; PAMELA
BONDI, U.S. Attorney General,
Respondents.
ORDER
25-CV-06781 (NRM)
NINA R. MORRISON, United States District Judge:
In advance of oral argument scheduled for December 22, 2025, Respondents
are ordered to produce the following documents and, if necessary, supplemental writ-
ten responses as set forth below by 12:00pm noon on December 18, 2025.
First, Respondents shall produce a copy of the Order of Supervision (or
“OSUP”) to which they refer in their Opposition to the Petition. Opp. Memorandum
(“Opp.”), ECF No. 16. Respondents have filed an Order of Supervision dated May 14,
2012 as an Exhibit. Ex. E, ECF No. 14-5. However, this OSUP does not contain much
of the language quoted in Respondents’ Opposition that Respondents represent as
being taken verbatim from the OSUP. For example, the Opposition states that the
OSUP expressly advised Zhang that he was prohibited from committing crimes or
“be[ing] associated with any such activity,” but there is no such language in the filed
SUP. Compare Opp. at 3–4, with Ex. E at 2. Respondents also claim that the OSUP
“further warned Zhang that any violation of the conditions ‘may result in you being
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taken into Service Custody and you will be criminally prosecuted.’” Opp. at 4. This
quoted language is also not present in the filed OSUP. See Ex. E at 2. Respondents
shall produce the OSUP(s) cited in their Opposition, or otherwise provide a written
explanation to the Court as to the apparent discrepancies between the representa-
tions in their briefing and the filed OSUP.
Second, the declaration of Deportation Officer Rocco Kish states that ICE ob-
tained a “valid travel document from the consulate of China” for Zhang on May 23,
2012, which expired three months later. Kish. Decl. ¶ 16, ECF No. 15. Respondents
shall produce a copy of this travel document.
Third, the February 27, 2025 Notice of Revocation of Order of Supervision
states that “a travel document has been procured” to effect Zhang’s removal. Ex. I at
10, ECF No. 14-9. This appears to refer to a new 2025 travel document that has been
obtained by ICE. Respondents shall also produce this copy of this travel document,
if it exists.
Finally, despite the aforementioned representation in the Notice of Revocation
as to a recently “procured” travel document, Respondents have also represented that
ICE is currently in the process of obtaining a new travel document in connection with
Zhang’s anticipated removal from the United States. See, e.g., Opp. at 2, 6, 15, & 18–
19; Kish Decl. ¶¶ 32, 33. According to Respondents’ submissions, ICE first detained
Zhang on February 27, 2025, forfeited custody to the U.S. Marshals Service on June
22, 2025, and re-detained Zhang on October 23, 2025. See Opp. at 6; Kish Decl. ¶¶ 24,
29, 31. It has been 292 days since Zhang’s initial detention, at which time ICE
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informed Zhang that his “removal is now imminent.” Ex. I at 10. It has also been 54
days since Zhang’s renewed detention by ICE following the conclusion of his criminal
proceedings.
On December 1, 2025, Respondents filed a letter with the Hon. Paul Oetken
stating that Zhang’s removal was “reasonably foreseeable” because once ICE “sub-
mits the travel document request to the Chinese embassy,” “[i]ssuance of the re-
quested travel document may occur within 7-10 days from the date of the request,”
and “[r]emoval to China can usually be completed within two weeks of obtaining valid
travel documents.” Supp. Letter to J. Oetken at 1, ECF No. 26. Respondents have
also represented that “[o]n November 4, 2025, Zhang completed identification verifi-
cation documents required by ICE and the Consulate of China to obtain travel docu-
ments.” Kish. Decl. ¶ 32.
In light of these assertions, Respondents shall produce any travel document
that has been procured for Zhang from the Consulate of China at any time since he
was first taken into ICE custody on February 27, 2025. If Respondents have not yet
obtained any such document, they shall provide a written explanation to the Court
as to the status of that process, including, but not limited to, whether the Consulate
of China has responded to such request(s). If Respondents have received any re-
sponse to their request(s) for travel documents from the Consulate of China, they
shall provide the Court with a copy of any written or electronic communications re-
ceived from Chinese officials in connection with these request(s).
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/s/ Nina R. Morrison
NINA R. MORRISON
United States District Judge
Dated: December 16, 2025
Brooklyn, New York
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