Almost twenty years later he filed a motion to reopen through new counsel claiming that his original counsel provided ineffective assistance. The immigration judge denied the motion to reopen on the basis that Rodriguez-Manzano failed to comply with Matter of Lozada, 19 I&N Dec. 637 (BIA 1988), in which the Board set out three requirements for motions to reopen based on allegedly ineffective assistance. Rodriguez-Manzano No. 09-60795, slip op. at 2.