There is a question whether a CMT conviction, for which a JRAD was validly obtained before November 29, 1990, can trigger deportation for multiple CMT convictions when combined with a later (or earlier) second CMT. Immigration counsel could argue that under the former statute, still enforced, deportation cannot be based on a CMT for which a JRAD was granted. The government can argue that the CMT for which a JRAD was granted forms one CMT of a two-CMT deportation ground. They could analogize to those cases that hold if a noncitizen has CMTs that trigger deportation, and then respondent obtains a waiver of deportation for them under former INA 212(c) waiver, and the client suffers another CMT conviction, the old waived CMT can be combined with the new CMT conviction to trigger deportation for multiple CMTs. The waiver does not eliminate the old CMT. It merely waivers deportation for that ground and that ground only. The two-CMT deportation ground is a different ground, and both CMT convictions continue to exist, and so can trigger deportation. The question would be whether counsel can distinguish those 212(c) cases.