FGM. Nor did the Petitioners alert the BIA to the fact that they sought derivative asylum through their daughter, who allegedly fears persecution if forced to travel to her parents’ homeland. The Petitioners have no direct claim to asylum based on FGM. Since “[n]otices of appeal are filed directly with the BIA, and the regulations specifically contemplate that supporting briefs are not required to be filed by a party ..., the notice of appeal is of great importance in raising claims before the BIA.” Ladha, 215 F.3d at 903 (internal citations omitted). A party who fails to raise an issue in the Notice of Appeal may still exhaust his administrative remedies by adequately addressing the issue within his brief to the BIA. Zhang v. Ashcroft, 388 F.3d 713, 721 (9th Cir.2004) (per curiam) (<HOLDING>); see also Ladha, 215 F.3d at 901 n. 13
holding that the prisoner has the burden of demonstrating he has exhausted his administrative remedies in his complaint holding that the appellant waived his claim on appeal because he failed to address that claim in either his application for a coa or his brief on appeal holding political persecution claim administratively exhausted by applicants raising of the issue before the ij and general challenge of the ijs determination in his brief to the bia holding that petitioner had exhausted his claim by explicitly mentioning in his brief to the bia that he was requesting reversal of the ijs denial of relief under the convention against torture holding that we will not review an issue or claim that was not presented to the bia in the petitioners notice of appeal or brief to the bia even if the bia considered the issue or claim sua sponte