Alhuay v. U.S. Atty. Gen., 661 F.3d 534 (11th Cir. Oct. 26, 2011) (per curiam) (a removal order ends lawful permanent resident status, even if issued more than five years after the grant of LPR status, because INA 246(a), 8 U.S.C. 1256(a), bars rescission after five years, and does not bar issuance of a removal order on the basis that the grant of LPR status was based on misrepresentations); see Matter of Belenzo, 17 I. & N. Dec.374, 382 (BIA 1981); Matter of S, 9 I. & N. Dec. 548, 548 (Att'y Gen.1962)(the statute has no effect on the government's power to remove an alien no matter when that alien's status was erroneously adjusted); Stolaj v. Holder, 577 F.3d 651, 656 (6th Cir.2009) (By its own terms, 1256 places a time bar only on the Government's attempt to rescind the status of a lawful permanent resident, and does not apply to removal proceedings.); Kim v. Holder, 560 F.3d 833, 837 (8th Cir.2009) (On its face, 1256(a) only discusses the five-year statute of limitations in terms of rescinding a status adjustment ....); Asika v. Ashcroft, 362 F.3d 264, 269"71 (4th Cir.2004) (deferring to the Attorney General's interpretation that 1256 does not limit the government's power to remove an alien more than five years after an erroneous adjustment of status); Oloteo v. INS, 643 F.2d 679, 682"83 (9th Cir.1981) (Congress has seen fit to do away with statutes of limitation with regard to deportation proceedings, but in its wisdom has engrafted such a limit to the rescission of status proceeding alone. (footnote omitted)); but cf. Garcia v. Att'y Gen., 553 F.3d 724, 728 (3d Cir.2009) (the last sentence of 1256(a), added by amendment in 1996, did not limit the statute's reach to rescission of adjustment of status); Bamidele v. INS, 99 F.3d 557, 559 (3d Cir.1996) (holding that 1256(a) applies to removal proceedings and vacating a deportation order issued more than five years after the government discovered that the petitioner's marriage was fraudulent).