Higgs v. Atty. Gen. of the United States, 655 F.3d 333 (3d Cir. Aug. 25, 2011) (a petitioner has satisfied his administrative remedies if he made some effort, however insufficient, to place the Board on notice of a straightforward issue being raised on appeal.); citing Lin v. Att'y Gen., 543 F.3d 114, 120 (3d Cir.2008); citing Joseph v. Att'y Gen., 465 F.3d 123, 126 (3d Cir. 2006).