Task: Text Completion
Input (English): linked’ to the order of removal, it is prohibited by section 1252(a)(5).” Martinez v. Napolitano, 704 F.3d 620, 623 (9th Cir.2012). Meanwhile, a § 2241 petition is not subject to § 1252(a)(5)’s jurisdictional bar if it is “independent” of the removal order. See Nnadika v. Att’y Gen., 484 F.3d 626, 632 (3d Cir.2007). Tonfaek claims that his § 2241 petition is independent of his removal order, but we do not agree. Critically, Tonfaek argues not just that the specific Cameroonian travel documents are invalid, but that Cameroon is not a proper country of removal. This issue is encompassed in the removal order — the IJ is obligated to designate a country of removal as part of the removal proceedings. See 8 C.F.R. § 1240.12(d); see also In re I-S- & C-S-24 I. & N. Dec. 432, 433-34 (BIA 2008) (<HOLDING>). The fact that the IJ here may have neglected 
 Holding statements: (A) holding that because the ij denied an asylum application as untimely we lacked subjectmatter jurisdiction to review the final order of removal as it pertained to the asylum claim (B) holding that review of an original removal decision and a subsequent removal order are distinct (C) holding that term order of removal does not include aliens ineffective assistance of counsel claim concerning attorneys actions taken after order of removal becomes final (D) holding that any defect in removal procedure must be cured within the 30day removal period or it is fatal to the removal and defendants failure to attach exhibits to the notice of removal within that time required remand (E) holding that when an ij issues a decision granting an aliens application for withholding of removal without a grant of asylum the decision must include an explicit order of removal designating a country of removal
Output (English): (E)