Supreme Court here we come

Today we filed  an application to recall and stay the issuance of  the mandate in an immigration case, pending the filing of a petition for writ of certiorari with  the U.S. Supreme Court. 

When we got the client's approval to proceed with his appeal,  I was a little hesitant that we did not have a real issue  to pursue, however, in working on this case  the last two days, IO have really found a bona fide conflict in the manner by which the Board of Immigration Appeals handles a motion to  reopen.  

More to follow.