The Eleventh Circuit has determined that the “zipper clause” does not prevent a District Court from reviewing the denial of a L-1A visa petition even after removal proceedings are commenced against the applicant. The court noted that an L-1A visa petition cannot be reviewed in removal proceedings, nor is it a decision to commence removal proceedings or execute a removal order.
The full text of Canal A Media Holding, LLC v. USCIS can be found here:
http://media.ca11.uscourts.gov/opinions/pub/files/201911193.pdf