Matter of Cisneros, 23 I. & N. Dec. 668, 672 (BIA 2004) ([B]oth the overall design of the statute and Congress' concerns leading to its enactment indicate that the ``stop-time'' rule was not intended to extend to charging documents issued in earlier proceedings. Consequently, we conclude that the ``notice to appear'' referred to in section 240A(d)(1) pertains only to the charging document served in the proceedings in which the alien applies for cancellation of removal, and not to charging documents served on the alien in prior proceedings.).
Thanks to Jonathan Moore.