De La Cruz v. Maurer, 483 F.3d 1013 (10th Cir. April 3, 2007) ("where a specific issue was not addressed in administrative proceedings in the manner it is now addressed before us, general statements in the notice of appeal to the BIA are insufficient to constitute exhaustion of administrative remedies."), citing Ramani v. Ashcroft, 378 F.3d 554, 560 (6th Cir. 2004).
jurisdiction:
Tenth Circuit