This cannot be allowed to persist. There is no showing of dangerousness — let alone any felony indictment. To the extent he is suspected of anything, it was a peaceful protest at Columbia U, months ago now. Even if Noem thinks he wasn’t completely candid on his entry application (now over a decade ago)… not a jot of it suggests any real security concern.

But I am reprinting his counsel’s entire letter, to the able USDC Judge in Newark — as it makes clear that for Rubio / Noem / Trump… lawless cruelty is the sole end goal here. There is no policy being advanced — just fascist terror and abduction — at will. [I will not link the PDF, as it contains the doctor’s full name — and there are lots of MAGA nuts that might come after her, as they did Mr. Abrego Garcia’s wife. Damn.] So here it is, in full, with only the redactions I indicated:

…Dear Judge Farbiarz:

Petitioner respectfully writes with an urgent request for this Court’s intervention regarding his ongoing detention. Specifically, and for the reasons set forth below and to aid in his habeas and proceedings, Petitioner requests that this Court issue an order: (1) requiring the LaSalle Detention Facility to permit Mr. Khalil to have a private contact visit with his wife, Dr. [Redacted], and newborn child today, May 21, 2025, for two hours1 and/or (2) at a minimum, permit Dr. [Redacted] to join a contact visit currently scheduled with immigration counsel at LaSalle so the legal team can discuss legal strategy and facts known collectively between Dr. [Redacted] and Mr. Khalil and which is relevant to his pending habeas case and for pending motions in his immigration proceedings. One of the first orders issued in this case was to direct the U.S. Attorney’s office to ensure that DHS would provide regular access to counsel, Khalil v. Joyce, 1:25-cv-01935, ECF 29 (S.D.N.Y.), which is an equitable power this Court retains and authorizes the relief requested — modest as it is as compared to the painful costs of denial.

As the Court is aware, the Khalil family welcomed their first child one month ago, on April 21, 2025. In order to provide the most indispensable human connection and to help Mr. Khalil prepare for his ongoing habeas proceeding and for the upcoming immigration hearing, Petitioner’s wife and his newborn baby have traveled over 6 hours and 1500 miles to visit Mr. Khalil in detention, which will be the first time he will be able to see or hold his family since his arrest and transfer to Louisiana, over 10 weeks ago. As this Court well knows, Mr. Khalil is purportedly in civil immigration detention, where he cannot be subject to punishment or retaliation; yet currently, routine legal or family visits only occur in a confined space permitting muffled communication through a full plexiglass window that permits no human touch.

Petitioner’s counsel have made repeated requests for a contact visit to occur between Mr. Khalil and his wife and baby to the relevant ICE and GeoGroup administrators at the LaSalle Detention Facility in Jena. Such a visit is necessary for the most elementary human reasons and given the ongoing strain of his pending habeas petition, this visit is critical to ensure Mr. Khalil, who is an active participant his legal case, can continue to meaningfully contribute to the proceedings before this Court.

The relevant administrators have responded that they are unable to accommodate this request, including a confirmation of this refusal this morning. (Email correspondence attached as Exhibit A). ICE policy authorizes contact visits between detained individuals and family members, subject to the reasonable discretion of DHS officials. The refusal to permit a contact visit is not reasonable and is further evidence of the retaliatory motive behind Mr. Khalil’s arrest and faraway detention as well as the ongoing punitive nature of his detention. Petitioner, his wife and infant son are, as all the evidence in this case demonstrates, the farthest thing from a security risk. It is the government who chose to detain Mr. Khalil and send him 1500 miles from his family rather than detain him, as they could have (and as we have requested in seeking a transfer there), in Elizabeth, New Jersey, where counsel confirmed with an EDC official that family contact visits are ordinarily provided on a daily basis and where a parent is permitted to hold their child.

In addition, a legal contact visit has been authorized for today between Mr. Khalil and his counsel, from 11-3pm CT. It thus appears the facility can accommodate contact visits absent a plexiglass barrier. Thus, the facility should make accommodations during or after this time for a private in-person visit where the family can be alone together for the first time. In addition, and at a minimum, counsel needs to meet with Petitioner and his wife together to discuss the factual circumstances surrounding his arrest on March 8, 2025. This discussion is relevant both to his habeas proceedings and his immigration proceedings. For the former, this conversation is relevant to his claims of retaliatory arrest and detention and the unusual circumstances surrounding both events that reflect the government’s retaliatory motive. For the latter, Petitioner has an outstanding motion to terminate his removal proceedings on the grounds of his warrantless arrest and to rebut DHS’s misrepresentation to the immigration court that Mr. Khalil attempted to evade his arrest.

Undersigned counsel emailed the government to seek assistance with this request and their position on this motion, and agreed to give the government until 12:30 PM ET to communicate a response. The government finally responded that they would not facilitate a contact visit as “doing so would pose security concerns, such as requiring the visit to occur in an unsecure part of the facility or requiring Mr. Khalil’s wife and newborn inside a secured part of the facility.” Petitioner has responded asking for clarification regarding these responses in the hope of reaching an accommodation, but is filing this motion nevertheless in the interest of expediency….

/s/

And, contrary to Ms. Noem’s idiotic answers (yesterday at a hearing on the Hill), the great writ of habeas corpus is the opposite of what she said. It is not the preznit’s right to deport. It secures the PEOPLE’S right to be released from lawless detentions, like these. Damnation. Out.

नमस्ते