Time-Critical Routing

Deadline and Chokepoint Timeline

High-level sequencing for 0-24h through 10-30d windows to preserve lawful options and avoid deadline forfeiture.

Timestamp

Timeline synced to the expanded memo

Updated

Includes Stone no-tolling and First Circuit stay timing.

Time-Sensitive Playbook

Window Priority Focus Critical Outputs Failure Risk if Delayed
0-24h Confirm custody reality, final-order status, and controlling forum Master timeline + custody-document set + hard-date calendar Wrong legal lane and immediate deadline loss
24-72h Lock detention-statute classification and stay posture Initial routing decision + stay-channel map + equities packet start Missed emergency stay opportunities
3-10d Build prolonged-detention and due-process record Detention chronology + transfer history + updated filing calendar Weak habeas/bond record, poor emergency posture
10-30d Maintain dual-track deadlines (appellate + agency motions) Verified deadline control dashboard and refreshed support evidence PFR forfeiture or motion-window expiration

Known Timing Signals (Must Be Verified)

  1. 2026-02-15 (media report): ICE custody was reported and Suffolk Superior hearing was reported as reset to March.
  2. If final removal order exists: PFR is generally due within 30 days of the final order date.
  3. First Circuit stay mechanics: Local Rule 18.0 describes an administrative 10-business-day stay for a timely first stay motion.
  4. Agency motion windows: reconsideration typically 30 days; reopening typically 90 days, while no automatic stay generally applies.

Watchlist

  • Any signed notice of scheduled removal date.
  • Any ICE transfer that changes district of confinement.
  • Any final-order service date mismatch in records.
  • Any filing plan that assumes PFR tolling.