Khodja v. Holder, 666 F.3d 415 (7th Cir. Dec. 12, 2011) (waiver under INA 212(c) was available to applicant who was found guilty following jury trial prior to April 1, 1997, where applicant was able to show actual reliance on the availability of a 212(c) by showing that he had affirmatively abandoned his right to pursue a Judicial Recommendation Against Deportation; INS attorney showed up at the JRAD criminal sentencing hearing, described the 212(c) hearing process, and argued that the waiver was best left to the federal immigration judge; the state court agreed and denied the JRAD; after the denial, his defense attorney withdrew the JRAD motion).