What grounds are grounds for equitable relief in a claim of misconduct by a non-attorney immigration specialist?

A more appropriate grounds for equitable relief is a theory of fraud of a non-attorney immigration specialist, which we find implicit in the petitioners' argument. See Fajardo v. INS, 300 F.3d 1018, 1021 (9th Cir. 2002) (holding that an argument of ineffective assistance could be construed as an argument of fraud because "[i]n the present case, the distinction between arguing misconduct and fraud is merely semantic" and "the precise language used should not prohibit resolution" of a petitioner's claim).