Kattra v. Holder
September 10, 2009
**Failure to exhaust administrative remedies**
Kattra’s new facts regarding the ineffective assistance of counsel of his attorneys cannot be reviewed because he did not present them to the BIA. However, a stay of 120 days is warranted to allow for Kattra to file a motion to reopen with the BIA to add to the record now that he has competent counsel.
http://www.ca9.uscourts.gov/datastore/memoranda/2009/09/10/05-70387.pdf
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