In this unpublished decision, the Board of Immigration Appeals (BIA) remanded the record for further consideration of the respondent’s motion to reopen based upon ineffective assistance of counsel. The Immigration Judge had faulted the respondent for filing a complaint against her former attorney with the Supreme Court of the Virgin Islands rather than the Virgin Islands Bar Association, but the Board stated that the requirements of Matter of Lozada, 19 I&N Dec. 637 (BIA 1988), “need not be rigidly enforced where their purpose is fully served by other means.” The decision was written by Member Elise Manuel.