IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF TEXASHOUSTON DIVISIONSHIRLEY PERSONS PIGOTTPetitionerCASE NO. 12 CV 917vs.GREGG ABBOTT,JOSH MCCOWN ANDJESS HOWELLRespondents
MOTION FOR EXPEDITED CONSIDERATION
The objective of this motion is to obtain a Stay of all State action against Petitionerwhile this case is pending. Petitioner would show the Court as follows:1.
Petitioner is mentally disabled. Her disability causes her to sufferuncontrollable fear, extreme anxiety, under stress.2.
The current circumstances create extreme anxiety for Petitioner; she doesnot know whether a police officer will come to her door, arrest her and takeher to prison for 2 years.3.
Given the history of vindictive conduct toward Petitioner, it is uncertainwhether the prosecution will arrest Petitioner, even after being notified of Petitioner’s filing for habeas relief.