ORDER Petitioner Fang Yi He seeks review of a BIA order denying his motion to reopen. We review that denial for abuse of discretion. See INS v. Abudu, 485 U.S. 94, 105, 108 S.Ct. 904, 99 L.Ed.2d 90 (1988) (<HOLDING>); see also 8 C.F.R. § 1003.2(a). At the outset,
holding that discretionary denials of motions to reopen are reviewed only for abuse of that discretion holding that the criminal jurisdiction bar applies to the denials of motions to reopen holding that the imposition of sanctions is reviewed for abuse of discretion holding that denial of joinder motion is reviewed for abuse of discretion holding that the dismissal of a frivolous action reviewed for abuse of discretion