Lema v. INS 341 F.3d 853 (9th Cir. September 2, 2003) (removable noncitizen who refuses to cooperate fully in securing travel documents from a foreign government cannot meet the burden of showing no significant likelihood of removal in the foreseeable future, and such noncitizens continued detention is authorized).
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http://caselaw.lp.findlaw.com/data2/circs/9th/0235901p.pdf