Respondent is not subject to INA 236(c) because she has no criminal history and should not be detained indefinitely unless there is a risk to person or property or pose a risk to national security. Matter of Adeniji (BIA 1999); Matter of Patel, (BIA-1976). Respondent is not a threat to national security is not likely to abscond and is not a poor bail risk. Ms. Pan has a brother who lives in NY and is willing and able to support her while her case is pending before the Court. (Exhibit ). Respondent's husband and son are also living in New York. Respondent has a fixed address in the United States and she will reside with her brother and her family after her releasing. (Exhibit B1-5). In fact, Respondent traveled a half of the world to the
