Tonka Bajlo vs. United States. Answer to Return

 

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON. NORTHERN DIVISION.

In the matter of the Application of Tonka Bajlo for the Writ of Habeas Corpus.

2459 No.1328

ANSWER TO RETURN.

Comes now the petitioner Tonka Bajlo and for answer to the return of the Hon. Ellis DeBruler, Commissioner of Immigration at the port of Seattle, upon the issuance of an order to show cause why a Writ of Habeas Corpus should not be issued, and alleges as follows:

That said report is not true, correct, or accurate in this to-wit::

-I-
That Tonka Bajlo is reported as having testified to statements which she did not make at said hearing.

-II-
That statements which she did make at such hearing are entirely omitted from the said report.

-III-
That the said report fails to show that the action of Jack Bajlo in making his affidavit and attempting to procure deportation of the petitioner was based wholly upon revenge, which fact was testified to by a witness at the hearing, but was not translated from the foreign language in which the testimony was given and not reported.

-IV-
That the petitioner made application for a rehearing   supported by affidavits setting forth the above facts, which said application was refused.

All of the above statements are supported by affidavits which have been filed herein.

Chas H Ennis
Fenley Bryan
Attorneys for Tonka Bajlo.