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They are very strict on requiring de facto evidence of the relationship for the entire three years prior to applying. So if you don't have much hard evidence in that way, then you likely won't get to skip the two year waiting period. Time dating doesn't count towards those three years.

Also, you still make the combined 820/801 application and wait for a decision on the 820 just like everybody else, it's the two year waiting period between the 820/801 application and 801 eligibility that gets waived if the CO deems you've met the requirements.
 
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