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ANSWER: In this case, you should file the I-539 immediately - as in today - with an explanation of everything that occurred, and a copy of the SR you filed. This shows your good faith efforts to fix the issue proactively. I would also provide the medical documentation that you sent in as well, to reiterate the basis for this request.
The I-102 might result in a denial. If it dos, then your mother would be out of status for quite some time, instead of just the short one day lapse that might be overlooked for good cause.
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