Matter of Ordaz, 26 I&N Dec. 637 (BIA 2015) (a notice to appear that was served on an alien but never resulted in the commencement of removal proceedings does not have "stop-time" effect for purposes of establishing eligibility for cancellation of removal pursuant to INA 240A(d)(1), 8 U.S.C. 1229b(d)(1)).

NOTE: This decision could potentially be used to argue for something like repapering (issuing a new NTA to allow noncitizen to have 10 years presence) as a form of prosecutorial discretion, except one would need to intercept the NTA before it is served on the court.