The following excerpt is from Henderson v. I.N.S., 157 F.3d 106, 1998 WL 665783 (2nd Cir. 1998):
Petitioners argue that both factors support a holding that the Attorney General is a proper respondent. They cite the district court in Nwankwo to the effect that the government could "seriously undermine the remedy of habeas corpus by detaining illegally a large group of persons in one facility so that the resulting 'torrent of habeas corpus petitions' would overwhelm the district and magistrate judges of the local United States District Court." 828 F.Supp. at 174; see also Strait v. Laird, 406 U.S. at 345, 92 S.Ct. 1693 (expressing the desirability of avoiding the "concentration of similar cases in the district" in which the reserve officers personnel office was located).
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