Takhar v. Holder
**Exhaustion of remedies**
The BIA found the IJ’s adverse credibility finding clearly erroneous. However, by not explicitly contesting in his BIA brief the IJ’s finding that he should have provided corroborating statement, Takhar failed to exhaust his claim that the BIA should have accepted his explanation for failing to produce corroborating evidence.
http://www.ca9.uscourts.gov/datastore/memoranda/2009/09/16/08-70020.pdf
Mendez-Hernandez v. Holder
Mendez-Hernandez is removable for having committed an aggravated felony—sexual abuse of a minor– and ineligible for a § 212(c) waiver of this ground of removability under Abebe v. Mukasey, 554 F.3d 1203 (9th Cir.2009).
http://www.ca9.uscourts.gov/datastore/memoranda/2009/09/16/06-72610.pdf
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