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he had a valid removal order because he didn't submit the proper paperwork to finalize his naturalization which would have happened this year...

Doesn't have anything to do with anything, really. He misfiled his paperwork and forgot to submit a form and the government is not obligated to...

That Form I-751 is for upgrading from a special, conditional spouse green card that's only valid for 2 years, to a regular 10-year one. You cannot...