a basis for determining whether counsel’s assistance was in fact ineffective”). . We have recognized before that “the BIA should consider ineffectiveness claims in the first instance in order to avoid any premature interference with the agency’s processes,” and that “review on the merits [before this Court] may be conditioned on substantial compliance with the reasonable requirements set forth in Lozada.” Jian Yun Zheng v. U.S. Dep’t of Justice, 409 F.3d 43, 46 (2d Cir.2005) (collecting cases) (internal quotation marks omitted). Accordingly, an applicant such as petitioner “who has failed to comply substantially with the Lozada requirements ... forfeits [his] ineffective assistance of counsel claim in this Court.” Id. at 47; see also Hamid v. Ashcroft, 336 F.3d 465, 469 (6th Cir.2003) (<HOLDING>); Arango-Aradondo v. INS, 13 F.3d 610, 614 (2d
holding that failure to develop a legal argument supporting a claim results in waiver of the claim holding that the petitioner was not entitled to claim ineffective assistance because she did not comply with the lozada requirements and made no effort to explain her lack of compliance holding that the petitioners failure to comply with the lozada requirements results in a forfei ture of his ineffectiveassistanceofcounsel claim recognizing that while slavish adherence to matter of lozada is not required when an alien does not comply with those requirements in any respect the ineffective assistance of counsel claim is forfeited holding that failing to substantially comply with the matter of lozada requirements in a motion to reopen before the bia forfeits an ineffective assistance claim in this court