Neufeld's 2009 Memo - ‘‘Consolidation of Guidance Concerning Unlawful Presence for Purposes of Sections 212(a)(9)(B)(i) and 212(a)(9)(C)(i)(I) of the Act’’
available at https://
www.uscis.gov/sites/default/files/USCIS/Laws/
Memoranda/Static_Files_Memoranda/2009/
revision_redesign_AFM.PDF.
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