What is the burden of proving that all state claims have been exhausted?

MultiRegion, United States of America

The following excerpt is from Gilchrest v. Gore, Case No.: 17-CV-668-DMS-WVG (S.D. Cal. 2018):

The burden of demonstrating that all state claims have been exhausted rests with the petitioner. See Kim v. Villalobos, 799 F.2d 1317, 1319-20 (9th Cir. 1986)

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