The following excerpt is from Munoz v. Lynch, 15-738 (2nd Cir. 2016):
1. "[W]e require [p]etitioner to raise issues to the BIA in order to preserve them for judicial review." Foster v. INS, 376 F.3d 75, 78 (2d Cir. 2004) (internal quotation marks and emphasis omitted). Failure to do so "constitutes a clear jurisdictional bar." Id. at 77.
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