Alexandria Division

Clarke-Frederick-Winchester Regional Adult Detention Center
141 Fort Collier Rd. Winchester, VA 22603

pro se, detained, indigent


Immigration and Naturalization Service District Director, Washington District Office
4420 N. Fairfax Drive, Room 510, Arlington, VA 22203



Petition, the extensive evidence enclosed thereto and the Memorandum In Support of this Motion indicate that Respondent and his agents committed or may have committed a number of actions which constitute or are likely to constitute offenses under US laws, including:

The said offenses are very serious and evidence which suggests that all or at least some of them were committed are abundant. Indeed, in August of 1996 this Honorable Court itself established that Respondent made a number of misrepresentations to the Court. See Transcript, 8/12/96 at 67. Moreover, during this habeas corpus proceeding Respondent perpetrated another fraud in an attempt to avoid the review of his previous wrongdoings and offenses by the Court and/or obtain prolonged detention of Petitioner. See Respondent's Motion For an Extension of Time and Petitioner's Letter In Opposition of said motion. Respondent demonstrated his intention to cover his wrongdoings and offenses even by criminal means, and Petitioner (detained, indigent, unrepresented) lacks the ability to investigate said offenses. Therefore Petitioner appeals to the Honorable Court for proper investigation of Respondent's actions.

The proper investigation of whether the abovelisted offenses were committed by Respondent and his agents would not only be in the public interest and in the interest of justice, but would also help to establish additional facts, relevant to this Habeas Corpus proceedings; facts, which Petitioner has had no resources or possibilities to investigate.

The proper inquiry into INS practices will be strictly in the public interest in the light of present controversy caused by the new Immigration and Naturalization Act and allegations that the lack of proper judicial supervision of the INS results in numerous abuses of power by its officers.

This Motion together with the enclosed Memorandum, the Petition and the documents enclosed thereto may be considered a Complaint under Rule 3 of Federal Code of Criminal Procedure or the Rule 3A-3 of the Rules of Supreme Court of Virginia.


For the reasons set forth herein, as well as the points and authorities submitted to the Court on March 31, 1997 in the Petition and the Memorandum, Petitioner hereby respectfully requests this Honorable Court :

1.1. to instruct an US Attorney to investigate promptly and properly whether the abovementioned offenses were committed by Respondent and his agents and to prosecute the offenses, should the investigation confirm them;

1.2. to report to the Court the results of the investigations at the date set by the Court;

1.3. to postpone the rendition of the decision in this Habeas Corpus proceeding until the investigation report is submitted to the Court and to release Petitioner on his own recognizance pending the Court's final determination of the case.

2. Or, alternatively, to summarily grant the Writ of Habeas Corpus on the grounds, which in the opinion of the Court do not require additional investigation or represent questions of law.

Dated: April 19, 1997

Alexandre Konanykhine