Kwong v. Holder, ___ F.3d ___, 2011 WL 6061513 (9th Cir. Dec. 7, 2011)(respondents action in making a motion to reopen and terminate removal generally challenging the sufficiency of the evidence to show he was convicted of first-degree burglary was sufficient to exhaust the issue of the sufficiency of the abstract of judgment to prove that fact: While Kwong is required to raise every issue in the administrative proceedings, this court retains jurisdiction where the issue in question [has] been argued in a slightly different manner [below].); quoting Cruz"Navarro v. INS, 232 F.3d 1024, 1030 n. 8 (9th Cir.2000).