(and any changes of [his] address and telephone number) as required ... and did not appear at [his] hearing through no fault of [his] own. In the administrative proceedings, Jobe claimed that he received inadequate notice of the hearing on his OSC, but he has abandoned that claim in this court. 3 . Because deportation proceedings are civil, the Sixth Amendment guarantee of effective counsel in criminal proceedings is inapplica ble. Nonetheless, we have recognized that "there is a due process violation if [a deportation proceeding] was so fundamentally unfair that the alien was prevented from reasonably presenting his case." Bernal-Vallejo v. INS, 195 F.3d 56, 63 (1st Cir.1999) (collecting cases). It is in this sense that the phrase "ineffective assistance of counsel" has made 1999) (<HOLDING>); cf. Iavorski v. INS, 232 F.3d 124 (2d
holding that ina  242bc3as time bar is not jurisdictional and thus subject to equitable tolling holding title vii subject to equitable tolling holding that oneyear limitations period set forth in  2255 is not a jurisdictional bar and is thus subject to equitable tolling holding that the ninetyday filing requirement is not a jurisdictional prerequisite and is subject to equitable tolling holding that ina  242bc3a sets forth a mandatory and jurisdictional time bar