Teryaeva-Reed

BACKGROUND

13 Petitioner Julia Teryaeva-Reed was a lawful permanent resident who was “convicted 14 of wire fraud and arson charges” and “sentenced to” “162 months of imprisonment.” 15 (ECF 1, at 11.) She was released directly to ICE custody on “March 18th, 2025.” (Id.) “On 16 April 21st, 2025,” Teryaeva-Reed received a final “order of removal” to her “country of 17 origin, Ukraine,” and “waived her right to appeal.” (Id. at 12.) To date, ICE has not 18 successfully removed her. So Teryaeva-Reed sought her court-ordered release by applying 19 for a writ of habeas corpus under 28 U.S.C. § 2241. (See generally id.) Since the filing of 20 her habeas petition, ICE has “obtained a travel document” for her and “intends to remove” 21 her “to Ukraine no later than November 24, 2025.” (ECF 16, at 2.)

DISCUSSION

23 Teryaeva-Reed moves for emergency injunctive relief and for appointed counsel. 24 A. Motion for Temporary Restraining Order 25 A temporary restraining order, like all injunctive relief, is “an extraordinary remedy 26 that may only be awarded upon a clear showing that the plaintiff is entitled to such relief.” 27 Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 22…