United States v. Ramirez-Salazar, ___ F.3d ___, 2016 WL 1457892 (1st Cir. Apr. 13, 2016) (defendant was not found in United States when his wife filed petition to facilitate defendant's immigration to United States, and thus statute of limitations for federal offense of being found in the U.S. after removal, under 8 U.S.C. 1326(a), did not begin to run and prosecution was not time-barred; the court did not rule categorically that an I-130 Form can never create the basis for actual knowledge of physical presence, but only affirming a finding in this case that the document did not put officials on notice.).
http://www.ca5.uscourts.gov/opinions/pub/14/14-50996-CR0.pdf