UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

EVELIN JOSEFINA PEREZ, et al.,

Petitioners, Case No. 25-cv-13931 v. Honorable Robert J. White KEVIN RAYCRAFT, et al.,

Respondents.

ORDER REGARDING PETITIONERS’ LOCATION AT THE TIME OF FILING

Evelin Josefina Perez and her minor son, SJZP, filed a petition for a writ of habeas corpus under

. (ECF No. 1). They allege that respondents are detaining them without a bond hearing in violation of the Immigration and Nationality Act (INA). Because the petition is unclear about where the United States Department of Homeland Security had been detaining Perez and her son, the Court directed Perez’s counsel to verify their exact location at the time he filed the petition on their behalf. (ECF No. 3). On December 9, 2025, Perez’s counsel filed a declaration asserting that, upon information and belief, Perez and her son were detained in Michigan when he filed the habeas petition. (ECF No. 4, PageID.71-72, ¶ 5). But an email from respondents’ counsel to Perez’s counsel, submitted along with Perez’s counsel’s declaration, conflicts with this representation. Respondents’ counsel claims that Perez and her

son “left Detroit around 8am this morning [December 8, 2025] and were likely far from the district when this suit was initially filed.” (Id., PageID.76). Because Perez and her son’s location at the time counsel filed the habeas

petition is critical to ascertaining whether territorial jurisdiction is appropriate in the Eastern District of Michigan, see Rumsfeld v. Padilla,

(2004), it is hereby,

ORDERED that Perez’s counsel and respondents’ counsel are directed to file a joint stipulation attesting to Perez and her son’s exact location (city, state, and name of the detention facility) at the time counsel filed the habeas petition – which,

according to CM/ECF, is December 8, 2025 at 2:09 P.M. Eastern Standard Time. The stipulation must be filed no later than Wednesday, December 17, 2025 at 5:00 P.M.

IT IS FURTHER ORDERED that in the event their exact location cannot be determined, a statement in the stipulation that Perez and her son were located outside the territorial jurisdiction of the Eastern District of Michigan at the time counsel filed

the habeas petition is sufficient to comply with this order. See

(a). IT IS FURTHER ORDERED that in the event Perez’s counsel and respondents’ counsel cannot agree on where Perez and her son were exactly located

at the time counsel filed the habeas petition, they are directed to file separate declarations, under penalty of perjury, stating (1) where they believe Perez and her son were located at the time of filing, and (2) the factual basis supporting that

representation. The declarations must be filed no later than Wednesday, December 17, 2025 at 5:00 P.M.

IT IS FURTHER ORDERED that Perez’s counsel is directed to serve a copy

of this order on respondents’ counsel no later than Monday, December 15, 2025 at 5:00 P.M.

Dated: December 12, 2025 s/ Robert J. White Robert J. White United States District Judge