She does qualify under 245i. She tried to adjust status with my dad and had an interview. The lawyer advised them not to go because he didn't get rid of my dad's deportation order. The lawyer didn't provide any reason to the USCIS for not showing up to the interview and the application was denied for lack of prosecution. My dad was deported a few years ago and my mom now wants to apply again. My mom never had any removal proceedings. I heard a few stories that people had been deported when they went to the interview but they had a final order of removal.
Simply file FOIAs to see if your mother has any record with the EOIR. If she has an A# you can also call the hotline, but I would advise filing a FOIA for good measure.
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