Yirenkyi

IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

EMMANUEL S. YIRENKYI, : No. 3:25cv2414

Petitioner :

: (Judge Munley)

V. :

ANGELA HOOVER, Warden of the :

Clinton County Correctional Facility, :

et al., :

Respondents :

MEMORANDUM

Emmanuel S. Yirenkyi is an immigration detainee in the custody of the

United States Department of Homeland Security (“DHS”), Immigration and

Customs Enforcement (“ICE”). He is currently detained at the Clinton County

Correctional Facility in McElhattan, Pennsylvania pursuant to an

intergovernmental service agreement.

Yirenkyi commenced this action by filing a petition for a writ of habeas

corpus under 28 U.S.C. § 2241.' (Doc. 1). Yirenkyi seeks immediate release

1 Like many recent filings by pro se litigants, Yirenkyi’s petition and traverse were drafted with

the aid of generative artificial intelligence. The court sees two issues with petitioner's reliance

Al. First, his petition analyzes several seminal cases but omits controlling Third Circuit

case law, German Santos v. Warden Pike Cnty. Corr. Facility, 965 F.3d 203 (3d Cir. 2020).

Second, and more troublesome, Yirenkyi’s traverse cites cases from the Middle District of

Pennsylvania which do not exist—further examples of legal hallucinations created by large

language models. (See Doc. 11 at 7 (citing “Frederick v. Warden, 2019 WL 1318445 (M.D. Pa

Mar. 22, 2019)” and “Rodriguez v. Lowe, 2018 ‘WL 683974 (M.D.Pa. Feb. 2, 2018)”). Yirenkyi

cites these two cases to argue that “[c]ourts have found detention in the 8-10 month range

constitutionally significant and requiring a release or a bond hearing[.]” Id. Although

“Rodriguez” would appear to involve a detainee held at the Pike County Correctional Facility

from detention under conditions of supervision. In the alternative, he seeks a

“constitutionally compliant” bond hearing with an immigration judge (“lJ”).

“(T]he Fifth Amendment entitles aliens to due process of law in deportation

proceedings.” Reno v. Flores, 507 U.S. 292, 306 (1993). Based on the record

and for the reasons discussed below, due process compels a bond hearing with

an IJ conducted in accordance with German Santos v. Warden Pike Cnty. Corr.

Facility, 965 F.3d 203 (3d Cir. 2020).

Background

Yirenkyi was born in Ghana in 1994. (Doc. 1-5). He has lived in the

United States since December 31, 2012. Id. He was issued a permanent

resident card by United States Customs and Immigration Services. Id. Yirenkyi

has a four-year-old child, a United States citizen. (Doc. 1-6). He asserts that he

is the only caregiver for his mother. (Doc. 1 at ECF p. 14).

On September 13, 2023, Yirenkyi pled guilty to conspiracy to commit bank

fraud and conspiracy to commit access device fraud in the United States District

Court for the District of New Jersey, United States v. Yirenkyi, No. 1:23-CR-723-

where Craig Lowe is the warden, the Westlaw citation provided for that “case” directs to a

family court decision from Québec (in French). No case in this district stands for the

proposition that detention in the 8-10 month range requires release or a bond hearing, at least

since German Santos was decided in July 2020. To be sure, the court has researched

decisions from the Middle District of Pennsylvania since that time and supplied its findings in

an appendix to this memorandum. In this instance, no show cause order will be issued

regarding any possible sanctionable conduct. The petitioner is pro se, in ICE custody at a

county jail, and appears to be relying on outside sources to supply him with legal materials.

CPO-1 (D.N.J.), (Doc. 8-3 at 13). The Honorable Christine P. O’Hearn

sentenced the petitioner to six (6) months imprisonment in August 2024.? Id. at

14. Judge O’Hearn further sentenced petitioner to a five (5) year term of

supervised release. Id. at 15. Yirenkyi is thus a convicted felon.

The judgment in his criminal case indicates that Yirenkyi is subject to

special conditions of supervised release, including the Location Monitoring

Program administered by U.S. Probation. Id. at 15. Specifically, he must submit

to home detention for a period of six (6) months, but is able to leave his

residence for employment, education, and religious services. Id. He is required

to undergo mental health treatment in a program approved by the U.S. Probation

Office. Id. A condition of supervised release also includes cooperation with ICE.

Id.

Following his conviction and sentence, Yirenkyi was charged with being a

removable alien pursuant to 8 U.S.C. § 1227(a)(2)(A)(iii). (Doc. 8-1). In the

removal proceedings, the government alleges that petitioner's conviction was an

aggravated felony, i.e., that the loss in his case exceeded $10,000. Id.

On April 7, 2025, an IJ ordered the petitioner removed to Ghana. (Doc. 8-

4). Yirenkyi then appealed to the Bureau of Immigration Appeals (“BIA”). On

2 Defendant filed a pro se appeal of his conviction and sentence in February 2025. That

appeal remains pending. See United States v. Yirenkyi, No. 25-1294 (3d Cir.).

September 30, 2025, the BIA denied his appeal. (Doc. 8-6). Yirenkyi

subsequently filed a Petition for Review with the United States Third Circuit Cour

of Appeals. ° A temporary stay of removal has been entered by the appellate

court pending full consideration of Yirenkyi’s motion to stay. See United States v.

Yirenkyi, No. 25-3113 (3d Cir.), (Doc. 3).

On December 15, 2025, Yirenkyi filed a petition for a writ of habeas corpus

pursuant to 28 U.S.C. § 2241 challenging his continued immigration detention.

(Doc. 1). In that petition, Yirenkyi seeks immediate release or an individualized

bond hearing before an IJ. Id. The government filed a response to the petition or

January 6, 2026, (Doc. 8), and the Clerk of Court docketed Yirenkyi’s traverse on

January 27, 2026, (Doc. 11).

From the record provided by respondents, Yirenkyi has been in ICE

custody since April 15, 2025, or presently for 9.5 months. (Doc. 8-1 at 1; Doc. 8

at 8, Doc. 8-7, BOP Inmate Locator Result). This is generally not considered an

unreasonable amount of time in immigration detention. However, due primarily

to the conditions of confinement and the supervised release provisions in

Yirenkyi’s criminal sentence, the petition for writ of habeas corpus will be

3 Claims regarding the length of immigration detention without a bond hearing do not get

funneled into the Petition for Review process. Khalil v. President, United States, No. 25-2162, -

-- F.4th ----, 2026 WL 111933, at *12 (3d Cir. Jan. 15, 2026)

granted. In this petitioner’s specific circumstances, his detention has become

unreasonable, and he has a due process right to a bond hearing.

Jurisdiction

Under 28 U.S.C. § 2241(c), a prisoner or detainee may receive habeas

relief when he “is in custody in violation of the Constitution or laws or treaties of

the United States.” See 28 U.S.C. § 2241(c)(3); Maleng v. Cook, 490 U.S. 488,

490 (1989). Yirenkyi filed the instant petition while he was detained within the

jurisdiction of this court. He remains in ICE custody at the Clinton County

Correctional Facility. Clinton County is located within the boundaries of the

United States District Court for the Middle District of Pennsylvania. 28 U.S.C. §

118(b). Consequently, the court has jurisdiction over his Section 2241 petition.

See 28 U.S.C. § 2241(a) (“Writs of habeas corpus may be granted by...the

district courts...within their respective jurisdictions.”).

Analysis

Yirenkyi contends that his immigration detention has become prolonged

and unconstitutional. Based on the government’s response to the petition and

the case law cited by Yirenkyi, the parties agree that he is currently detained

pursuant to 8 U.S.C. § 1226(c). Section 1226(c) applies to the detention of a

“criminal alien,” including those who are “deportable by reason of having

committed any offense covered” in 8 U.S.C. § 1227(a)(2)(A)(iii), the provision the

government argues is applicable to Yirenkyi.*

Section 1226(c) does not limit the length of the detention it authorizes,

Jennings v. Rodriguez, 583 U.S. 281, 303 (2018), but “a petitioner may still bring

an as-applied constitutional challenge alleging that his continued detention has

become unconstitutional under the Due Process Clause of the Fifth Amendment.

Ibrahim v. Superintendent of Miami Corr. Facility, No. 1:25-CV-00727, 2026 WL

116489, at *4 (M.D. Pa. Jan. 15, 2026) (Wilson, J) (citing German Santos, 965

F.3d at 208-09); see also Zadvydas v. Davis, 533 U.S. 678, 690 (2001)

(“statute[s] permitting indefinite detention of an alien would raise a serious

constitutional problem’). In such as-applied challenges, “when detention

becomes unreasonable, the Due Process Clause demands a hearing.” German

Santos, 965 F.3d at 210 (quoting Diop v. ICE/Homeland Sec., 656 F.3d 221, 233

(3d Cir. 2011), abrogated in part on other grounds by Jennings, 583 U.S. at 304-

05.°

4 An “alien” means any person not a citizen or national of the United States. 8 U.S.C. §

1101(a)(3). “Any alien who is convicted of an aggravated felony at any time after admission is

deportable.” 8 U.S.C. § 1227 (a)(2)(A)(iii). An “aggravated felony” includes “an offense

that...involves fraud or deceit in which the loss to the victim or victims exceeds $10,000.” 8

U.S.C. § 1101(a)(43)(M).

5 Jennings did not call into question the holding in Digan that detention under Section 1226 may

violate due process if unreasonably long. Borbot v. vivarden Hudsor Cinty. Carr Facility, 906

F.3d 274, 278 (3d Cir. 2018).

The question to be answered is whether the petitioner’s detention is

reasonable—‘“a ‘highly fact-specific’ inquiry.” Id. (quoting Chavez-Alvarez v.

Warden York Cty. Prison, 783 F.3d 469, 474 (3d Cir. 2015), abrogated in part on

other grounds by Jennings, 583 U.S. at 304—05).® In this circuit, there is a non-

exhaustive list of four factors to consider in assessing whether an alien’s

detention has grown unreasonable: 1) duration of detention; 2) whether the

detention is likely to continue; 3) the reasons for the delay; and 4) whether the

conditions of confinement are meaningfully different from criminal confinement.

Id. at 211 (citations omitted). By its very nature, the use of a balancing

framework makes any determination of reasonableness a fact-intensive

proposition. See Chavez-Alvarez, 783 F.3d at 474.

Duration of Detention — Duration of detention is the most important factor.

German Santos, 965 F.3d at 211. Under the case law, “[t]here is no presumptior

of reasonableness or unreasonableness of any duration.” German Santos, 965

F.3d at 211 (citing Chavez-Alvarez, 783 F.3d at 474 n.7; Diop, 656 F.3d at 234).

After five (5) months, however, “the constitutional case for continued detention

without inquiry into its necessity becomes more and more suspect as detention

6 Jennings did not abrogate the holdings in Diop and Chavez-Alvarez that Section 1226(c) is

unconstitutional “when applied to detain an alien an unreasonably long [time] without a bond

hearing.” German Santos, 965 F.3d at 210.

continues[.]” Diop, 656 F.3d at 234 (discussing Demore v. Kim, 538 U.S. 510,

530 (2003)).

With respect to the first and most important consideration, Yirenkyi has

been detained by DHS since at least April 15, 2025, or 9.5 months. At least one

court within the appellate jurisdiction of the Third Circuit has determined that a

nine-month period was an unreasonably long time where DHS appealed an lJ

decision granting asylum and there was “no end in sight” to the detention.

Mashchenko v. Rokosky, No. CV 25-12387 (RK), 2026 WL 185204, at *3 (D.N.J.

Jan. 25, 2026) (Kirsch, J.) (quoting German Santos, 965 F.3d at 213) (applying

factors to Section 1225(b) family-separation detention); see also A.L. v. Oddo,

761 F. Supp. 3d 822, 826 (W.D. Pa. 2025) (holding that detention of ten months

weighed in favor of a bond hearing for a 1225(b) detainee under the German

santos factors).

Such cases appear to be outliers when compared to decisions within the

Middle District of Pennsylvania. See Appx. Because 9.5 months is less than the

periods typically found unreasonable in this district, the undersigned finds that

the duration factor weighs against relief at this time.

With that said, there are no bright lines in the reasonableness analysis. See

Chavez-Alvarez, 783 F.3d at 474, n.7. The Fifth Amendment requires a more

granular look at the other facts of this case.

Likelihood of Continued Detention — As to whether detention will

continue, the court finds that Yirenkyi’s detention will continue into the

foreseeable future. Yirenkyi is detained on a pre-final order of removal. His

appeal to the BIA was summarily dismissed for “not contain[ing] statements that

meaningfully apprise the Board of specific reasons underlying the challenge to

the [IJ’s] decision.” (Doc. 8-6 at ECF p. 4). His appeal of the BIA decision has

been pending with the Third Circuit since October 2025. A motion to stay

removal has also been pending since that time. The court cannot reasonably

determine how long Yirenkyi’s appeal will be pending before the Third Circuit or

forecast whether it will be remanded. There will be a delay of undefined

duration. See Davydov v. Doll, No. 1:19-CV-2110, 2020 WL 969618, at *5 (M.D.

Pa. Feb. 28, 2020) (Kane, J). “When the alien's removal proceedings are

unlikely to end soon, this suggests that continued detention without a bond

hearing is unreasonable.” German Santos, 965 F.3d at 211 (3d Cir. 2020).

Consequently, this factor weighs in favor of relief.

Reasons for the Delay - The third factor considers the reasons for the

delay, “such as a detainee's request for continuances.” Id. (citing Diop, 656 F.3d

at 234; Demore, 538 U.S. at 531). The court also asks, “whether either party

made careless or bad-faith ‘errors in the proceedings that cause[d] unnecessary

delay.’ ” Id. (quoting Diop, 656 F.3d at 234).

In this case, the government has indicated that Yirenkyi’s conduct

prevented meaningful review by the BIA because he did not file the proper

supporting documents. (Doc. 8 at 3). However, from the BIA decision, it appears

that Yirenkyi’s such conduct may have been attributable to lapses with the

attorneys the petitioner hired to represent him. (Doc. 6). Consequently, the court

cannot call such conduct “bad faith.” Therefore, because the petitioner has also

not demonstrated that the government has acted in bad faith, this factor is

neutral. See German Santos, 965 F.3d at 212.

Conditions of Confinement — This factor requires a determination of

whether “the alien's conditions of confinement are meaningfully different from

criminal punishment.” Id. at 211 (cleaned up). Under the law, “if an alien's civil

detention under § 1226(c) looks penal, that tilts the scales toward finding the

detention unreasonable.” Id. (citing Chavez-Alvarez, 783 F.3d at 478) (emphasis

added).

The Clinton County Correctional Facility is a county jail. A jail is a jail and

there is no evidence that Yirenkyi is treated any different than the criminal pretria

detainees in county lockup or those inmates serving state criminal sentences of

shorter durations. Therefore, Yirenkyi’s detention is indistinguishable from

criminal punishment. See id. at 213 (regarding the conditions at Pike County

40

Correctional Facility); see also Chavez-Alvarez, 783 F.3d at 478 (regarding the

conditions at York County Prison).

Additionally, the “conditions of confinement” factor and “length of detention

factors are interdependent parts of the German Santos reasonableness test.

See 965 F.3d at 211 (citing Chavez-Alvarez, 783 F.3d at 478) (“And as the lengftl

of detention grows, so does the weight that” courts must give to the conditions of

confinement factor). Put another way, with the interdependence of factors, the

more conditions look like a jail sentence as confinement continues, the more the

court must worry about due process. Id. at 212-13. Here, Yirenkyi has been hel

at a county jail for over nine (9) months without bail for an alleged violation of civ!

law. In Yirenkyi’s case, this factor weighs in favor of granting relief.

Other Considerations — German Santos further sets forth that its four

factors are a non-exhaustive list of considerations. Id. at 210. Given the

purposes of Section 1226(c), the statute that Yirenkyi is being detained under,

the court considers whether detention without bond in Yirenkyi’s specific case

“necessarily serves the purpose of preventing deportable criminal aliens from

fleeing prior to or during their removal proceedings, thus increasing the chance

that, if ordered removed, [petitioner] will be successfully removed.” Demore, 538

U.S. at 528. Therefore, the court takes a step back and looks at the whole

44

picture. This birds-eye view reveals some inconsistencies within the federal

system with respect to the petitioner.

First, a federal judge in Yirenkyi’s criminal case granted him bond and

allowed him to report to prison voluntarily. The government trusted Yirenkyi to

get himself from New Jersey to a federal prison in the center of Pennsylvania.

Second, the Federal Bureau of Prisons (a federal law enforcement agency

under the United States Department of Justice) evaluated Yirenkyi and assigned

him to a low-security prison. In the criminal world, the BOP decided that he was

a low risk. From the record provided by respondents, Yirenkyi fully served his

federal prison sentence without incident in a prison environment with lower

security measures. Yet, in the civil immigration world, ICE (a federal law

enforcement agency under DHS) keeps Yirenkyi in a county Jail.

Third, in the absence of an ICE detainer, Yirenkyi would be subject to five

years of supervised release by the U.S. Probation Office with at least the first six

(6) months spent on a strict location monitoring program. (Doc. 8-3, ECF p. 16).

Upon leaving prison, Yirenkyi would have to report to U.S. Probation to be fitted

for an ankle monitor and to meet with his probation officer. Instead, the petitione

is awaiting removal proceedings behind bars under the watch of a local

government’s prison guards. This is an irrational outcome. In a balancing test,

such irrationality weighs against continued detention without a bond hearing.

49

Weighing the Factors — While Yirenkyi has been held in detention for 9.5

months—a fact that weighs against him—the remaining circumstances reveal

that his detention has become unreasonable. Yirenkyi’s petition for a writ of

habeas corpus will be granted.

Although Yirenkyi has requested his release, the order issued in this case

will not grant that request. Rather, the petitioner is entitled to a timely bond

hearing with an IJ where the government will bear the burden to justify his

continued detention by clear and convincing evidence. German Santos, 965

F.3d at 214. The court will add one caveat. If the government does not provide

Yirenkyi with a bond hearing within thirty (30) days, the petitioner will be ordered

released and directed to comply with the supervised release provisions of the

criminal sentence imposed on him by the United States District Court for the

District of New Jersey.

Conclusion

Based on the foregoing, the court will grant Yirenkyi’s petition for a writ of

habeas corpus pursuant to 28 U.S.C. § 2241 and enter an appropriate order

the terms discussed in this memorandum.

aff

Date: Pecan Ne

ted Staten K. MUNLEY

d States District Court

42

| APPENDIX

| Case Approximate Factor —_| Disposition

Shonhai v. Lowe, No. CV 3:24-229, | 24 months Weighs in Bond

|} 2025 WL 510975, at *5 (M.D. Pa. favor of relief | hearing

Feb. 14, 2025) (Mannion, J.). granted

| Ologbenla v. Lowe, No. 3:25-CV- 24 months Weighs in Bond

|| 1351, 2025 WL 2375272, at *3 favor of relief | hearing

|| (M.D. Pa. Aug. 14, 2025) (Munley, granted

J,).

|| Barradas-Jacome v. Lowe, No. 22 months Weighs in Bond

|| 1:22-CV-1412, 2023 WL 2742741, favor of relief | hearing

at *3 (M.D. Pa. Mar. 31, 2023) denied

(Conner, J.).

Diahn v. Lowe, No. 1:24-cv-1936, 19 months Weighs in Bond

|| 2025 WL 2115442, at *4 (M.D. Pa. favor of relief | hearing

July 11, 2025) (Bloom, C.M.J.), R&R granted

adopted, 2025 WL 2112074 (M.D.

Pa. July 28, 2025) (Munley, J.).

|| Baptista v. Lowe, No. 1:23-CV- 19 months Weighs in Bond

|| 1666, 2024 WL 3410600, at *2 favor of relief | hearing

|| (M.D. Pa. Apr. 30, 2024) (Bloom, granted

C.M.J.), R&R adopted, No. 1:23-CV-

|| 01666, 2024 WL 3410587 (M.D. Pa.

|| May 7, 2024) (Mannion, J.).

| Elyardo v. Lechleitner, No. 1:23-CV- | 19 months Weighs in Bond

01089, 2023 WL 8259252, at *2 favor of relief | hearing

| (M.D. Pa. Nov. 29, 2023) (Kane, J.). granted

Appiah v. Lowe, No. 3:24-CV-2222, | 18 months Does not Bond

2025 WL 510974, at *4 (M.D. Pa. weigh in favor | hearing

Feb. 14, 2025) (Mariani, J.). of relief denied

Malede v. Lowe, No. 1:22-CV- 18 months Weighs in Bond

|} 01031, 2022 WL 3084304, at *6 favor of relief | hearing

|| (M.D. Pa. Aug. 3, 2022) (Schwab, granted

Clarke v. Doll, No. 3:20-CV-00031, 18 months Weighs in Bond

2020 WL 4983215, at *4 (M.D. Pa. favor of relief | hearing

June 3, 2020) (Saporito, M.J.), R&R granted

adopted, 481 F. Supp. 3d 394 (M.D.

Pa. 2020) (Conner, J.), app.

dismissed, No. 20-3162, 2021 WL

1740271, at *1 (3d Cir. Jan. 13,

2021).

Santana-Rivas v. Warden of Clinton | 15 months Weighs in Bond

Cnty. Corr. Facility, No. 3:25-CV- favor of relief | hearing

01896, 2025 WL 3522932, at *11 granted

(M.D. Pa. Nov. 13, 2025) (Camoni,

M.J), R&R adopted in part, rejected

in part on other grounds, 2025 WL

3513152 (M.D. Pa. Dec. 8, 2025)

(Wilson, J).

White v. Lowe, No. 1:23-CV-1045, 15 months Does not Bond

2023 WL 6305790, at *2 (M.D. Pa. weigh in favor | hearing

Sept. 27, 2023), rev'd and of relief denied

remanded sub nom. White v.

Warden Pike Cnty. Corr. Facility,

No. 23-2872, 2024 WL 4164269 (3d

Cir. Sept. 12, 2024) (detention had

reached 27 months).

Saint Jacques v. Dep't of Homeland | 14 months Does not Bond

Sec., No. 1:21-CV-1144, 2021 WL weigh in favor | hearing

4494623, at *2 (M.D. Pa. Sept. 30, of relief denied

2021) (Mariani, J.).

Ibrahim v. Superintendent of Miami | 13 months Neutral factor | Bond

Corr. Facility, No. 1:25-CV-00727, hearing

2026 WL 116489, at *4 (M.D. Pa. granted

Jan. 15, 2026) (Wilson, J).

McDougall v. Warden, Pike Cnty. 13 months Does not Bond

Corr. Facility, No. 3:23-CV-759, weigh in favor | hearing

2023 WL 6161038, at *2 (M.D. Pa. of relief denied

Sept. 21, 2023) (Mariani, J.).

Shapovalov v. Immigr. & Customs 9 months Does not Bond

Enft Agency, No. 1:21-CV-0900, weigh in favor | hearing

2021 WL 3128747, at *3 (M.D. Pa. of relief denied

July 23, 2021) (Wilson, J.).

Sydykov v. Immigr. & Customs Enft, | 9 months Does not Bond

No. 1:21-CV-00575, 2021 WL weigh in favor | hearing

2222732, at *2 (M.D. Pa. June 2, of relief denied

2021) (Wilson, J.).

Acevedo v. Decker, No. 1:20-CV- 9 months Does not Bond

01679, 2021 WL 120473, at *4 weigh in favor | hearing

(M.D. Pa. Jan. 13, 2021) (Wilson, of relief denied

J.).

Barradas-Jacome v. Lowe, No. 8 months Does not Bond

1:21-CV-1885, 2022 WL 256299, at weigh in favor | hearing

*3 (M.D. Pa. Jan. 26, 2022) of relief denied

(Conner, J.).

Baghdad v. Doll, No. 1:21-CV-293, 8 months Does not Bond

2021 WL 1391784, at *6 (M.D. Pa. weigh in favor | hearing

Apr. 13, 2021) (Rambo, J.) of relief denied

Ema v. Wilkinson, No. 1:21-CV- 7 months Does not Bond

00172, 2021 WL 3878289, at *5 weigh in favor | hearing

(M.D. Pa. Mar. 17, 2021) (Schwab, of relief denied

M.J.), R&R adopted, 2021 WL

3871300 (M.D. Pa. Aug. 30, 2021)

(Mariani, J.)

Salau v. Hoover, No. 3:25-CV- 2 months Does not Bond

02295, 2026 WL 49557, at *4 (M.D. weigh in favor | hearing

Pa. Jan. 7, 2026) (Mehalchick, J). of relief denied

Ndungu v. Doll, No. 4:20-CV-2268, 1 month Does not Bond

2021 WL 1916700, at *5 (M.D. Pa. weigh in favor | hearing

Apr. 9, 2021) (Arbuckle, J.), R&R of relief denied

adopted, 2021 WL 1910083 (M.D.

Pa. May 12, 2021) (Mariani, J.)

2Q