[00:00:04] Speaker 02:
Good morning, Your Honors, and may it please the Court.

[00:00:07] Speaker 02:
My name is Jordan Cunnings, and with Mr. Manning I represent Petitioner Mr. Gerson Alfredo Manzano.

[00:00:12] Speaker 02:
I'd like to reserve three minutes for rebuttal and I'll try to watch the clock.

[00:00:16] Speaker 02:
Petitioner, a devout Jehovah's Witness, preached a message of peace to members of the gang Mara 18 on the streets of his native El Salvador.

[00:00:24] Speaker 02:
The gang reacted violently, physically harming him and threatening to kill him if he did not stop preaching.

[00:00:30] Speaker 02:
In spite of significant direct evidence,

[00:00:33] Speaker 02:
that the gang targeted the petitioner because of his religious beliefs.

[00:00:37] Speaker 02:
The agency found that Mr. Alfaro Manzano's religion was not one central reason for the harm he would suffer at the hands of the gang if returned to El Salvador.

[00:00:45] Speaker 02:
The BIA got it wrong for two reasons.

[00:00:47] Speaker 02:
First, the record evidence compels the conclusion that religion was one central reason for the harm in question here.

[00:00:54] Speaker 02:
Second, the agency erred by impermissibly ignoring petitioners' well-developed political opinion argument and by misstating and misapplying the relevant one central reason test.

[00:01:04] Speaker 02:
Either reason requires that you grant the petition today.

[00:01:07] Speaker 02:
I'll start with the first argument that the record compels the conclusion that his religion was one central reason for his harm.

[00:01:14] Speaker 02:
The record is replete with concrete evidence of nexus, making clear that the Mara 18 targeted the petitioner for harm, specifically because of the public exercise of his religious beliefs.

[00:01:24] Speaker 02:
And I'm going to quote from the record here.

[00:01:25] Speaker 02:
The gang reacted violently when he preached, specifically naming his preaching and his identity as a Jehovah's Witness as the reason for their reaction.

[00:01:33] Speaker 02:
They called him vulgar names associated with his religion.

[00:01:36] Speaker 02:
They told him they, quote, knew he was a Jehovah's Witness and that they didn't want to see him preaching anymore, that if he continued doing it he would have to live up to the consequences, end quote.

[00:01:46] Speaker 02:
Quote, they made it very clear that they did not want him to preach at all, end quote.

[00:01:52] Speaker 02:
When he continued to preach, the gang members told him, quote, they had seen him continue to preach and that he had not paid heed and that he was going to pay back very dearly, end quote.

[00:02:03] Speaker 02:
Mr. Alfredo Manzano understood this to mean that they were going to kill him.

[00:02:07] Speaker 02:
Gang members then approached him and said, quote, so what's the deal?

[00:02:10] Speaker 02:
I mean, you continued preaching and we had forbidden you to do that, end quote.

[00:02:14] Speaker 02:
Then the gang member raised his shirt and showed him a weapon.

[00:02:18] Speaker 02:
Quote, they said that now he was going to have to pay the consequences because they had not obeyed what they had asked him to do by continuing to preach.

[00:02:25] Speaker 02:
These strong, unequivocal statements of why the gang targeted Mr. Alfredo Manzano specifically for harm make clear that his religion would be one central reason for his future persecution.

[00:02:34] Speaker 03:
So it seems that the agency thought that the demand for money, the extortion, was also a reason that he might get killed.

[00:02:43] Speaker 03:
And we have some language in some cases about a but for cause.

[00:02:48] Speaker 03:
So it seems like maybe what the agency was thinking was,

[00:02:53] Speaker 03:
the demand for money was a reason he was going to get killed in and of itself.

[00:02:58] Speaker 03:
And so because that was going to happen, nothing else could be a but for cause.

[00:03:01] Speaker 03:
What's wrong with that reasoning?

[00:03:03] Speaker 02:
Thank you for the question.

[00:03:04] Speaker 02:
I think that's wrong for two reasons.

[00:03:06] Speaker 02:
One, I think that's a misstatement of the law.

[00:03:08] Speaker 02:
There can be multiple central reasons.

[00:03:10] Speaker 02:
The IJ talks about a primary or an overriding reason.

[00:03:13] Speaker 02:
That's a misstatement.

[00:03:15] Speaker 02:
There can be multiple central reasons.

[00:03:16] Speaker 02:
So even if the gang was motivated by a desire to increase its power and obtain money for him and they did extort him, that doesn't mean they couldn't have another central reason, which is his religion.

[00:03:28] Speaker 02:
And I also think that's just not supported by the record, right?

[00:03:31] Speaker 02:
I think there's some quoting of the expert about how this is the gang's modus operandi, that they extort people in the neighborhood, that they're very violent.

[00:03:37] Speaker 02:
We don't dispute that.

[00:03:37] Speaker 02:
That was our expert, right?

[00:03:39] Speaker 02:
But the reason that they targeted him and their specific statements and the harm they inflicted on him, specifically because he continued to preach, I think the agency ignores that by exclusively focusing on the extortion facts.

[00:03:52] Speaker 02:
The BIA's opinion suggests that the court can ignore all this direct evidence that I just pointed you to, explaining their motivation.

[00:04:00] Speaker 02:
But this court's precedent states otherwise.

[00:04:02] Speaker 02:
I don't think it's often that we have such clear statements from persecutors about their motivation, and I don't think this precedent allows the court to ignore that.

[00:04:13] Speaker 02:
The BIA's reasoning that the gangs desire to exert its power and enrich itself was the central reason for the harm and that religion was only secondary Is not supported by the record and as we were just discussing So a motive is a central reason if that motive standing alone would lead the persecutor to harm the applicant But I think the record here makes clear that the gang would have targeted and indeed did target Mr. Alfredo Monsano on the basis of his religion alone Because that is what they said and that's why they continue to threaten him

[00:04:40] Speaker 01:
Is there any finding by the IJ or the BIA with respect to whether his religion standing alone was the reason that he was being persecuted?

[00:04:52] Speaker 02:
I think they didn't find that, which is what we disagree with, right?

[00:04:54] Speaker 02:
So the IJ finds and the BIA affirms the finding that that was a secondary or subordinate reason, which we think is wrong.

[00:05:02] Speaker 02:
Again, the gang members specifically told him they didn't want him to preach, and they came after him when he continued to preach and told him that.

[00:05:10] Speaker 02:
So I don't think we can ignore that.

[00:05:13] Speaker 02:
Focusing so narrowly on the fact that the gang also extorted him is an impermissibly selective reading of the evidence.

[00:05:18] Speaker 02:
And to hold that such a reading is permissible would suggest that the existence of extortion alone negates the possibility of asylum, which can't be the case in its counter to this court's precedent.

[00:05:27] Speaker 02:
See Rodriguez-Zuniga and several other recent cases.

[00:05:30] Speaker 02:
This goes to the second reason the petition should be granted.

[00:05:34] Speaker 02:
The BIA impermissibly ignored Mr. Alfaro-Monsano's well-developed political opinion argument and applied the incorrect legal standard.

[00:05:41] Speaker 02:
So while it's true the agency need not write a treatise on each issue that it raises, it must provide a reasoned explanation for its actions, and the decision must be stated in terms sufficient to enable a reviewing court to perceive that it's heard and thought and not really reacted.

[00:05:53] Speaker 02:
That's Agunofar v. Sessions.

[00:05:55] Speaker 03:
His political opinion argument really different from his religion argument?

[00:05:58] Speaker 02:
We only need to win on one, but I do think he expressed a political message.

[00:06:03] Speaker 02:
It was a message of peace.

[00:06:04] Speaker 02:
He was preaching to the gang members.

[00:06:05] Speaker 02:
He specifically said, I'm trying to keep people out of the gang.

[00:06:08] Speaker 02:
I think the gang is violent.

[00:06:09] Speaker 02:
We don't want you to join the gang.

[00:06:11] Speaker 02:
And so I think the BIA and the IJ by finding that the gang's actions were purely political, right?

[00:06:16] Speaker 02:
Because an exercise of power is inherently political.

[00:06:18] Speaker 02:
And then ignoring his argument that his then reaction to that and his opposition to the gang was political is impermissible.

[00:06:26] Speaker 02:
The government would have you rest on the BIA's language at AR 8, stating that the gang would have targeted him, irregardless of any other protected characteristic, but that's simply reading too much into that phrase because there's absolutely no analysis of the political opinion argument.

[00:06:41] Speaker 02:
The IJ and BIA's conclusion that the gang was motivated by a desire to exert its power over the territory actually supports his arguments that he was targeted on account of his political opinion.

[00:06:50] Speaker 02:
If the gang's desire is to increase its power, then logically it would target those who resist its power.

[00:06:55] Speaker 02:
In other words, I don't believe you can buy the argument that the gang's motivation is purely political without at least analyzing how resistance to the gang's political actions is political in and of itself.

[00:07:04] Speaker 02:
And I'll try to reserve the rest of my time.

[00:07:05] Speaker 00:
Thank you.

[00:07:06] Speaker 00:
Well, that was well done in terms of hitting it three minutes.

[00:07:27] Speaker 04:
And with that, good morning, Your Honors, Sarah Pergolese for the government, and may it please the court.

[00:07:32] Speaker 04:
The court should deny this petition for review because, critically, the problem with this applicant's claim is that he failed to prove that his protected grounds were central reasons that motivated the gang.

[00:07:44] Speaker 01:
Let me ask you a question.

[00:07:45] Speaker 01:
Would the petitioner's religion, standing alone, have led the gang to harm him?

[00:07:52] Speaker 04:
The totality of the evidence doesn't indicate that that is the case.

[00:07:56] Speaker 01:
What do you mean?

[00:07:57] Speaker 01:
The IJ found him to be credible.

[00:08:01] Speaker 01:
He was a devout Jehovah's Witness.

[00:08:04] Speaker 01:
That requires active public practice of his faith.

[00:08:08] Speaker 01:
The gang repeatedly warned him about preaching, threatened to kill him, attempted to kill him, pushed him, kicked him.

[00:08:21] Speaker 01:
Why doesn't that all add up to persecution?

[00:08:24] Speaker 04:
Because there are other facts in the record that point the other way, Your Honor.

[00:08:28] Speaker 04:
And prospectually, the applicant was only ever approached by the two specific gang members that he fears when he was leaving work.

[00:08:35] Speaker 04:
He was never approached or threatened by them directly when he was preaching.

[00:08:39] Speaker 04:
He said to multiple immigration officers before his testimony and in his asylum application, primarily that he was extorted.

[00:08:48] Speaker 04:
His statements from people that he knew.

[00:08:50] Speaker 03:
Can I interrupt you about that for a second?

[00:08:52] Speaker 03:
So he was found credible.

[00:08:54] Speaker 03:
And I don't understand how you can go back to the border interview and say, well, he didn't mention everything at that point.

[00:09:02] Speaker 03:
And so now we don't treat him as credible later when actually he was treated as credible in the testimony later.

[00:09:08] Speaker 03:
You're kind of going back to a piece that I don't understand.

[00:09:11] Speaker 03:
If it contradicted his later testimony and you said that showed he was not credible, I would understand the move.

[00:09:17] Speaker 03:
But once he is credible, I don't understand how you can discount his credible testimony by saying, well, he didn't mention something earlier.

[00:09:23] Speaker 04:
It's more about the weight of the evidence as a whole.

[00:09:25] Speaker 04:
The immigration judge, you're right, exactly did find that he was credible.

[00:09:30] Speaker 04:
But this also is evidence about what the applicant viewed as the central reasons of the harm he experienced, just the primacy of which reasons he emphasized where.

[00:09:40] Speaker 03:
But he later is saying they're targeting me because of my religion.

[00:09:44] Speaker 03:
He says all the things that Jadorek just said and that your opposing counsel just listed.

[00:09:48] Speaker 03:
So if you're treating that as credible, how can it not be that he's being targeted for his religion?

[00:09:53] Speaker 04:
Credible testimony is not necessarily persuasive testimony.

[00:09:56] Speaker 04:
And again, the agency and we in defending their decisions are looking at the record as a whole, not just the applicant's testimony.

[00:10:03] Speaker 03:
Okay, but how do you get back to he didn't mention it earlier without undermining the credibility of what he says later?

[00:10:09] Speaker 04:
I'm not really sure that you do.

[00:10:10] Speaker 04:
I understand your question and I'm trying to address it, of course.

[00:10:14] Speaker 04:
But it's more about what the applicant himself was presenting as his claim at different points in proceedings.

[00:10:23] Speaker 04:
And again, the immigration judge, as you pointed out, did not find that the statements were so inconsistent that they rendered him not credible.

[00:10:30] Speaker 04:
but that it is about the weight of what reasons he thinks motivated the gang to act.

[00:10:37] Speaker 04:
And the fact that it appears later and is not in those first statements, or again, that element of the religious claim is also missing in the statements from people he knew in El Salvador that described his experiences.

[00:10:52] Speaker 04:
saying that only he was, only stating that he was extorted and not that his religion was- That's again undermining his credibility, right?

[00:10:58] Speaker 03:
That's a way of saying when he said it was all this religion stuff he was lying.

[00:11:01] Speaker 04:
No, respectfully no.

[00:11:02] Speaker 04:
It's about the weight of the evidence as a whole and what motives, again, I think Perusimova makes very clear and we've never argued, right, that a persecutor needs to come in with an itemized list of their motives.

[00:11:15] Speaker 04:
That would be ridiculous and impossible for an applicant to prove.

[00:11:18] Speaker 04:
But what is evidence of motive is direct and circumstantial evidence in the record as a whole.

[00:11:24] Speaker 04:
And these points are circumstantial evidence of the gang's motives and circumstantial evidence that can be used in weighing those motives and figuring out which ones are central and which ones aren't.

[00:11:37] Speaker 04:
And the agency didn't find the applicant was incredible, but they did find that what he's saying he experienced and what other people said he experienced based on his own claims to them, those all point to even his own subjective belief of the centrality of each of these motivations.

[00:11:58] Speaker 00:
Can you explain in this case where we have withholding was found?

[00:12:03] Speaker 00:
Yes, we're going to withhold removal, but not asylum.

[00:12:06] Speaker 00:
Right.

[00:12:06] Speaker 00:
Pretty rare for that to happen.

[00:12:08] Speaker 00:
I think this is the only case I can remember I've ever seen this happen before.

[00:12:11] Speaker 04:
Yeah, and in my eight years of practice with oil, this is the only time I've ever seen it as well.

[00:12:16] Speaker 00:
Walk us through that if you could.

[00:12:18] Speaker 04:
I think this is where the rubber meets the road, the difference between these motive standards.

[00:12:23] Speaker 04:
This court held in Barajas Romero, based on the text of the statute, the differences between asylum and withholding, that an applicant need only prove that their protected ground was a reason for the harm they experienced to meet withholding.

[00:12:37] Speaker 04:
But the statute says something different for asylum.

[00:12:40] Speaker 04:
They must show that their protected ground or grounds were at least one central reason.

[00:12:44] Speaker 04:
And again, I think the court's decision in Parusimova is really instructive here in that centrality means primacy.

[00:12:54] Speaker 04:
It means that the protected ground was essential to motivate the persecutor to act.

[00:13:01] Speaker 04:
And so it doesn't mean what this court previously had as their mixed motive standard, at least in part, motivation.

[00:13:08] Speaker 04:
It doesn't simply mean, as the petitioner has stressed, awareness of the person.

[00:13:13] Speaker 04:
It doesn't only mean that they stood out and then, therefore, were targeted for harm that was more generalized.

[00:13:22] Speaker 04:
And it also doesn't mean, as is clear in Elias Zacharias,

[00:13:26] Speaker 04:
that a gang's generalized motivation to control a population means that they were politically motivated.

[00:13:33] Speaker 00:
All right, so let me ask you about this.

[00:13:34] Speaker 00:
So let's say I'm a low-level gang member.

[00:13:36] Speaker 00:
My boss comes to me and says, okay, Owens, you got to go rob someone today.

[00:13:40] Speaker 00:
Okay, so my job today is to rob someone.

[00:13:43] Speaker 04:
Right.

[00:13:43] Speaker 00:
And then I say, you know who's really easy to rob?

[00:13:46] Speaker 00:
It's that guy who's always talking on the street corner about Jesus in a nice suit.

[00:13:50] Speaker 00:
I'm going to rob him because he's much easier to rob than a fellow gang member.

[00:13:54] Speaker 00:
So there it is.

[00:13:55] Speaker 00:
So I wake up, I'm given my order, and then immediately Jehovah's Witness pops in my head.

[00:14:00] Speaker 00:
You're saying that under that scenario, that would not meet the asylum standard.

[00:14:04] Speaker 04:
No, it wouldn't because it's just about visibility and you're not, you as a gang member are not motivated by that characteristic.

[00:14:10] Speaker 00:
So let's say the next day I wake up and say, you know what, my boss is going to tell me to rob someone.

[00:14:15] Speaker 00:
I'm going to rob without him even telling me today.

[00:14:17] Speaker 00:
I want to rob a Jehovah's Witness because I know that'll make my boss happy.

[00:14:23] Speaker 04:
I mean, again, because it has nothing to do with the person being, nothing to do with that person's religious beliefs or convictions.

[00:14:30] Speaker 00:
But I only end up robbing that guy because he's a Jehovah's Witness.

[00:14:35] Speaker 00:
So in both scenarios, I'm only robbing this person because he's a Jehovah's Witness.

[00:14:38] Speaker 00:
I didn't rob the Catholic priest.

[00:14:40] Speaker 00:
I didn't rob the Buddhist.

[00:14:41] Speaker 00:
I robbed the Jehovah's Witness.

[00:14:42] Speaker 00:
Under all those scenarios, my decision tree led to one person, the Jehovah's Witness.

[00:14:47] Speaker 00:
So how can it be under all those scenarios that him being a Jehovah's Witness is not a central reason?

[00:14:52] Speaker 04:
Because you could have robbed him for any other reason.

[00:14:55] Speaker 04:
If you had had the exact same hypothetical and you said, oh, well, that guy that walks around in a clown costume, he's easy to spot.

[00:15:03] Speaker 00:
But I'm saying, if you had the priest, the monk, you had all the rabbi, you had them all, it sounds like a joke out in a bar, you had them all in the bar, and every time under that scenario, I end up robbing the Jehovah's Witness.

[00:15:14] Speaker 04:
I think the pattern might be, again, circumstantial evidence that that may have become a central motivation, but that's not what happened in this case.

[00:15:24] Speaker 04:
And Elizabeth Kennedy, the expert from The Respondent, also testified that any religious person that was out proselytizing in the street was, again, equally visible, stood out to the gang, and then targeted for the generalized extortion that this applicant experienced.

[00:15:39] Speaker 03:
But then why did they tell him to stop preaching?

[00:15:42] Speaker 04:
I don't know.

[00:15:43] Speaker 04:
The record really doesn't say why they told him to stop preaching.

[00:15:46] Speaker 03:
If they tell him to stop preaching and threaten him if he doesn't, doesn't that show a motive that they're caring about the preaching?

[00:15:52] Speaker 04:
So I think it shows that it played a part, but not that it was central.

[00:15:56] Speaker 04:
And again, that's where the rubber meets the road in this case.

[00:15:59] Speaker 04:
And it's not even that we can think this.

[00:16:01] Speaker 04:
It can be evidence that it's central.

[00:16:03] Speaker 04:
A reasonable judge could have found that it was central.

[00:16:05] Speaker 04:
But we're dealing with a substantial evidence standard of review here, and I can't say with a straight face that it compels only the conclusion that it was central.

[00:16:15] Speaker 03:
So what if all of the stuff about religion were in this case, but not the extortion?

[00:16:22] Speaker 03:
Okay, so like we had all these statements and the driving off the road and everything about the religion, but they never mentioned give us money.

[00:16:29] Speaker 03:
Would it be a claim?

[00:16:29] Speaker 03:
Probably that's a that's a very critical difference And so how how does that mean that if the conditions in a country are bad enough?

[00:16:37] Speaker 03:
Like basically everyone is being threatened all the time.

[00:16:39] Speaker 03:
You can never have a religion claim No, I don't think so and I'm running out of time.

[00:16:43] Speaker 04:
So I'd like to answer your question if that's yes it doesn't but again, I think the

[00:16:50] Speaker 04:
Parusumova is really instructive.

[00:16:51] Speaker 04:
Other cases from this court's precedent are instructive, especially Ayala versus Sessions where the court basically held that there can be, and they called it an extortion plus case.

[00:17:01] Speaker 04:
There can be extortion and there can be a protected ground and they can exist concurrently and they can both be central.

[00:17:07] Speaker 04:
That is absolutely possible and we're not saying that that's not possible and the agency in this decision did not find that that was impossible.

[00:17:15] Speaker 04:
Rather, they carefully weighed these motives on this record and found that only the non-protected motives met that centrality threshold and the protected motive didn't.

[00:17:25] Speaker 04:
And that is just what this analysis is at work.

[00:17:29] Speaker 03:
What would an extortion plus case look like if this isn't one of them?

[00:17:33] Speaker 04:
where there is actual intent to overcome the religion, right, or an intent to subjugate the religion.

[00:17:40] Speaker 04:
And that doesn't exist here.

[00:17:41] Speaker 03:
And again... What do you mean by that?

[00:17:43] Speaker 03:
I mean, they told him not to preach.

[00:17:44] Speaker 03:
So what are you thinking of?

[00:17:45] Speaker 04:
I mean, I'm not the agency.

[00:17:47] Speaker 04:
I don't know exactly.

[00:17:48] Speaker 04:
But again, I think the line is probative.

[00:17:51] Speaker 04:
The probative nature of the line can be seen with the facts of Parusimova itself.

[00:17:56] Speaker 04:
The applicant was a native Russian person in Kazakhstan, and she was assaulted by two Kazakh men.

[00:18:03] Speaker 04:
They called her a Russian pig, told her to get out of the country, and tried to sexually assault her.

[00:18:08] Speaker 04:
But the Ninth Circuit found that her ethnicity, her Kazakh ethnicity, was not one central reason.

[00:18:14] Speaker 04:
It didn't motivate them to act.

[00:18:17] Speaker 04:
It wasn't essential to their action.

[00:18:20] Speaker 04:
They would have assaulted her anyway.

[00:18:22] Speaker 04:
And it also didn't, once they became aware of it, indicate any escalation of treatment compared to the general population or if that characteristic hadn't existed.

[00:18:33] Speaker 03:
You haven't told me what it would look like.

[00:18:34] Speaker 03:
Exactly.

[00:18:35] Speaker 04:
So to come back to your hypothetical, I think

[00:18:37] Speaker 04:
the negative of that, or the opposite of that.

[00:18:40] Speaker 04:
If, for example, Jehovah's Witnesses were treated differently from other people in the society, if they were subjected to more extortion, or if the gang had said something like, hey, stop preaching, we ordinarily charge everybody $25 a month, but for you, we want $1,000 a month.

[00:18:59] Speaker 04:
The gang didn't say that in this case.

[00:19:01] Speaker 04:
They didn't express that the applicant's religion was affecting the content or extremity of the kinds of harms that they subjected him to.

[00:19:11] Speaker 04:
And I think that's the critical missing piece in this case.

[00:19:15] Speaker ?:
Anything else?

[00:19:16] Speaker 00:
No.

[00:19:16] Speaker 00:
All right.

[00:19:16] Speaker 00:
Thank you very much, counsel.

[00:19:17] Speaker 04:
Thank you.

[00:19:18] Speaker 00:
Sorry, I went over time.

[00:19:20] Speaker 00:
No.

[00:19:20] Speaker 00:
We had something to do with that.

[00:19:31] Speaker 02:
So I think the government is asking you to value circumstantial evidence over direct evidence, and I just don't think that your precedent allows you to do that here.

[00:19:40] Speaker 02:
The government also said that he was targeted for generalized extortion.

[00:19:43] Speaker 02:
Again, I just think that's belied by the record when you look at the specific reasons that they said that they were targeting him.

[00:19:49] Speaker 02:
The government is also basically saying the existence of extortion defeats the possibility of asylum in any case, and I think that's wrong based on your case law.

[00:19:59] Speaker 02:
Allowing this decision to stand could eviscerate asylum eligibility for anyone whose persecutor was attempting to increase their own power.

[00:20:05] Speaker 02:
through the use of violence, which is basically any persecutor.

[00:20:09] Speaker 02:
In a quintessential political asylum case, the government exercises its power to stifle an anti-government protester, for example.

[00:20:15] Speaker 02:
In doing so, the government is attempting to increase and solidify its own power, but that doesn't defeat an asylum case on those facts.

[00:20:22] Speaker 02:
It cannot be the case that just because a persecutor is motivated by their ability to increase their own power through extortion or through other means that all other motivations are deemed subordinate to that motive, regardless of other strong evidence in the record suggesting why they targeted their specific victim for harm.

[00:20:37] Speaker 02:
I think this is the case where you have that strong evidence.

[00:20:40] Speaker 02:
We should take the persecutors at their word.

[00:20:43] Speaker 02:
He was a street preacher who was targeted because exactly for his street preaching.

[00:20:47] Speaker 02:
Thank you.

[00:20:48] Speaker 00:
All right, thank you very much, counsel.

[00:20:49] Speaker 00:
Thank to both of you for your briefing and argument in this case.

[00:20:52] Speaker 00:
This matter is submitted.