Dandache v. Holder
November 30, 2009
**Ineffective assistance of counsel**
The BIA did not abuse its discretion in denying Dandache’s motion to reopen because Dandache did not substantially comply with the Lozada requirements and has not established prejudice from the alleged ineffective assistance of counsel.
http://www.ca9.uscourts.gov/datastore/memoranda/2009/11/30/08-74836.pdf
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