WILLIAMS, Circuit Judge.
After being found inadmissible due to a 2002 conviction for fraud, Cheikh Lam sought a waiver of inadmissibility under section 212(h)(1)(B) of the Immigration and Nationality Act ("INA"), 8 U.S.C. § 1182(h)(1)(B). That section provides that a noncitizen may obtain a waiver if he is the spouse, parent, son, or daughter of a United States citizen or lawful permanent resident who would suffer extreme hardship if the noncitizen is removed...
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