INA 292, 8 U.S.C. 1362 (statutory right to counsel in removal proceedings); INA 240(b)(4)(A), 8 U.S.C. 1229a(b)(4)(A); Sanchez v. Keisler, 505 F.3d 641, 649 (7th Cir. 2007) (the attorneys performance was so deficient that Sanchez did not have the fair hearing to which the immigration statutes entitle her); Zeru v. Gonzales, 503 F.3d 59, 72 (1st Cir. 2007) (" aliens in deportation proceedings have a statutory right to be represented by counsel at their own expense."); Borges v. Gonzales, 402 F.3d 398, 408 (3d Cir. 2005) ("[A]liens have a statutory right to counsel, see 8 U.S.C. 1362 . Implicit in the right to counsel is the requirement that the assistance rendered not be ineffective.").