Adams v. Holder, 692 F.3d 91 (2d Cir. Aug. 15, 2012) (the five-year limitation on rescinding an alien's adjusted status, INA 246(a), 8 U.S.C. 1256(a), does not apply to persons who obtained LPR status via consular processing: adjustment of status under the INA is properly construed as a technical term describing a process whereby certain aliens physically present in the United States may obtain permanent resident status ... without leaving the United States. Succar v. Ashcroft, 394 F.3d at 13 (quoting 3B Am.Jur.2d Aliens & Citizens 2134) (omission in original). Such a process does not extend to consular grants of immigrant visas.; five-year statute of limitations also does not bar removal proceedings).