Memo from Michael Aytes, Acting Deputy Director for Domestic Operations discusses adjudication of I-212 waivers in light of the Ninth Circuit decision in Perez-Gonzalez v. Ashcroft, rescinded by a 5/19/09 Aytes Memo which discusses adjudicating Forms I-212 for aliens inadmissible under INA 212(a)(9)(C) or who are subject to reinstatement under 241(a)(5) in light of Duran Gonzalez v. DHS, 508 F.3d 1227(9th Cir. 2007).