Matter of Balderas, 20 I&N Dec. 389 (BIA 1991), held that immigration authorities can combine a conviction waived in a first set of removal proceedings with a conviction obtained after a grant of relief to charge the person with removability in a second set of proceedings. Several unpublished cases distinguished Balderas when the person in a single set of proceedings seeks to waive the pre-96 offenses and terminate proceedings because there is only one CIMT conviction occurring after 1996. Matter of Ortiz-Perez, 2006 WL 3203617 (BIA 2006) (unpublished); Matter of Horns Bazuaye, 2006 WL 3203592 (BIA 2006) (unpublished); Matter of Ayinde Smith, 2006 WL 1558824 (BIA 2006) (unpublished). Judulang had a pre-96 manslaughter conviction, but he also had a 2005 theft conviction. From the Supreme Court's decision, the government did not make an argument that the 2005 theft conviction might be a CIMT that could disqualify him. Judulang v. Holder, 132 S.Ct. 476, 479"481 (2011). In Carillo-Jaime v. Holder, 572 F.3d 747 (9th Cir. 2009), the court referred to the Board's decision that found him eligible for 212(c) relief to waive a 1993 aggravated felony conviction despite a 2005 conviction for running a chop-shop. Counsel can therefore argue that the client can obtain a 212(c) waiver in removal proceedings of a qualifying CMT conviction, leaving only a single CMT which cannot trigger multiple CMT deportability, provided the waiver is obtained in a single removal proceeding. Thanks to Thalassa Kingsnorth.