this person has had an ICE hold for at least 24 hours.
I agree with my colleagues. Whenever you are dealing with ICE, it is important to at least get a consultation with an experienced Immigration Attorney. All of the issues and the immigration consequences are not always obvious. Before you submit anything, do talk with an attorney.
I'd retain counsel to do that. Many times the ICE office is looking for reasons to release the foreign national and providing them proof of status is one of the avenues. With that said, if they have a hold on them, then that usually means there is some criminal activity that could cause mandatory detention without bond. So again the best avenue is to retain counsel.
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