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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION SHIRLEY PERSONS PIGOTT

Petitioner CASE NO. 12 CV 917 vs. GREGG ABBOTT, JOSH MCCOWN AND JESS HOWELL Respondents

MOTION FOR EXPEDITED CONSIDERATION

The objective of this motion is to obtain a Stay of all State action against Petitioner while this case is pending. Petitioner would show the Court as follows: 1. Petitioner is mentally disabled. Her disability causes her to suffer uncontrollable fear, extreme anxiety, under stress. 2. The current circumstances create extreme anxiety for Petitioner; she does not know whether a police officer will come to her door, arrest her and take her to prison for 2 years. 3. Given the history of vindictive conduct toward Petitioner, it is uncertain whether the prosecution will arrest Petitioner, even after being notified of Petitioners filing for habeas relief.

4. Petitioner will continue to suffer extreme anxiety unless this Court orders that all State action against Petitioner be Stayed while this case is pending.

WHEREFORE, Petitioner prays that this Court Stay all State action against petitioner while this case is pending.

Respectfully Submitted,

Jerry S. Payne St. Bar #15658000 11505 Memorial Dr. Houston, Texas 77024 713-785-0677 Fax-713-781-8547

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