Edwards v. INS, ___ F.3d ___, 2004 U.S. App. LEXIS 26335 (2d Cir. December 17, 2004) (Unpublished) (petitioner's claims are ripe for judicial review, even though she will not become eligible for release from criminal custody until 2006, since the determination of her claims may take that long in any event and may be necessary to proceed now to avert possibility of mandatory immigration detention pending litigation of the immigration claims after the criminal custody release date), distinguishing Simmonds v. INS, 326 F.3d 351 (2d Cir. 2003)(holding immigration claims not yet ripe where petitioner would not be released from criminal custody for 10 years, because the law governing the immigration consequences of the criminal disposition might well change in the meantime).