The petitioner may file a motion with the court of appeals asking the court to order his or her return to the United States after deportation. See Federal Rule of Appellate Procedure 27(a)(1) ("An application for an order or other relief is made by motion unless otherwise provided by these rules"). The motion could be entitled a motion to enforce the courts order, or a motion to order respondent to cause petitioners return to the United States. In extreme situations, some attorneys also have filed contempt motions for refusal to comply with the courts order. The motion should inform the court of its authority to order petitioners return to the United States (see next section), the efforts made to arrange for petitioners return, the reasonableness of petitioners proposed return plan, the governments actions or position (and/or noncompliance), and it should ask the court to order petitioners return. Document the motion to the extent possible. If the only evidence of the governments refusal to return the client is oral, submit a sworn declaration from a person with personal knowledge, attesting to the conversation. While attorneys generally should avoid becoming witnesses for their clients, alternative evidence of the governments refusal to return petitioner may not be available. Thanks to Richard Breitman.