With no explanation, chose the best option from "A", "B", "C" or "D". record, as counsel for the INS acknowledged at oral argument. Such misrepresentations of the record are poor advocacy and waste both the court’s and other litigants’ time. We expect better from counsel, including government counsel. Cf. Thomas v. Digital Equip. Corp., 880 F.2d 1486, 1490-91 (1st Cir.1989) (sanctioning a party that made material misrepresentations of the record in its appellate brief). In any event, Neverson’s § 2241 claims provide no basis for vacating his deporta tion order. First, Neverson has withdrawn his argument that the INS’s use of his manslaughter conviction as a ground for deportation represents an unauthorized retroactive application of the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA). See Choeum v. INS, 129 F.3d 29, 37 (1st Cir.1997) (<HOLDING>). Second, to the extent Neverson’s § 2241

A: holding that an ij or bia decision that occurs after september 30 1996 is an action taken that triggers iiriras aggravated felony rules
B: recognizing that 1996 amendment specifically applies regardless of date of prior conviction constituting aggravated felony
C: holding that drug felony under state law can constitute an aggravated felony for federal sentencing guidelines purposes even if the same conduct would not constitute a felony under federal law
D: recognizing that 1996 amendment to definition of aggravated felony applies retroactively
A.