As reported in the August 10, 2006 Litigation Clearinghouse Newsletter, USCIS headquarters issued a memo instructing field officers to deny I-212s in any case where the person is inadmissible for having been deported (INA 212(a)(9)(C)(I)(i)(II)) and ten years have not elapsed since the applicants last departure from the United States. See http://www.ailf.org/lac/litclearinghouse/litclr_newsletter_81006.pdf. USCIS memo conflicts directly with the Ninth Circuit decision Perez-Gonzalez v. Ashcroft, 379 F.3d 783 (9th Cir. 2004). AILF and the Northwest Immigrant Rights Project would like to hear from attorneys whose Ninth Circuit clients are affected by this memo.