The Eighth Circuit has determined that the filing of a Petition to Remove Conditions on Residence, when the marriage underlying the residence was fraudulent, is a continuation of a conspiracy to commit marriage fraud. As such, when that petition is submitted within 5 years of the applicant's admission as a permanent resident, the applicant can be charged with deportability based on the commission of a crime involving moral turpitude within 5 years of admission.
The full text of Ashraf v. Lynch can be found here: http://media.ca8.uscourts.gov/opndir/16/04/143179P.pdf