An order of deportation or of exclusion shall not be reviewed by any court if the alien has not exhausted the administrative remedies available to him as of right under the immigration laws and regulations or if he has departed from the United States after the issuance of the order. The court of appeals for this circuit has an established tradition of leniency towards pro se petitioners, especially where summary judgment is sought by the government. See Williams v. Kullman, 722 F.2d 1048 (2d Cir.1983) (“due to the pro se petitioner’s general lack of expertise, courts should review habeas petitions with a lenient eye, allowing borderline cases to proceed.... pro se complaints must be liberally constructed”); see also United States v. Gonzalez-Roque, 165 F.Supp.2d 577 (S.D.N.Y.2001) (<HOLDING>). F. Immediately Available Visa The Gabryelsky
holding that although pro se briefs are liberally construed even pro se litigants must brief arguments in order to preserve them holding that where petitioners did not simply challenge the validity of their orders of removal but had questioned whether the statute grants the ins authority to remove them to a country that cannot accept them the court of appeals retains jurisdiction holding petitioners pro se status did not constitute adequate cause for failure to raise claims earlier holding that a party may not raise a claim on appeal that was not presented to the trial court holding that pro se petitioners need not raise issues in ins terms but may raise them as they may have understood them