USCIS states that the purpose of Form I-191 is "for a legal permanent resident of the United States to apply for permission to return to their home in the United States after time spent outside the United States." This person is an LPR and already in the U.S. Thank you.
If this person is in removal proceedings .... run, don't walk, to the closest immigration lawyer's office.
You're way off-base with your understanding of what needs to be done.
PROFESSOR OF IMMIGRATION LAW for over 10 years -- firstname.lastname@example.org -- www.capriotti.com -- This blog posting is offered for informational purposes only. It does not constitute an attorney-client relationship. Also, keep in mind that this is an INTERNET BLOG. You should not rely on anything you read here to make decisions which impact on your life. Meet with an attorney, via Skype, or in person, to obtain competent personal and professional guidance.
Professor Capriotti is actually very correct in his assessment of your situation. Do yourself a favor and heed his advice.
NYC EXPERIENCED IMMIGRATION ATTORNEYS www.myattorneyusa.com; email: email@example.com; Phone: (866) 456-8654; Fax: 212-964-0440; Cell: 212-202-0325. The information contained in this answer is provided for informational purposes only, and should not be construed as legal advice on any subject matter.