[00:00:00] Speaker 01:
God save these United States and this honorable court.

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Please be seated.

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We have four cases that are on calendar that will be

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submitted on the briefs, and those are 25-1683, Dignamarina Sorto Cruz versus Pamela Bondi, 25-1690, Gusharan Singh versus Pamela Bondi, 25-2747, Evelyn Castro Rivera versus Pamela Bondi, and 25-3484,

[00:00:49] Speaker 02:
Yinghuan Xi versus Pamela Bondi.

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In accordance with the respective orders previously entered on the dockets of those cases, those four cases are hereby submitted on the briefs.

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And we will proceed to hear argument in the first case on calendar for argument this morning, which is 24-6466, Eldar Guforov,

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versus Pamela Bondi, and we will hear first from Mr. Adcock.

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You may proceed.

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Good morning, Your Honors.

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My name is Utku Gayri Pakchok, appearing on behalf of the Gafferow family, the petitioners.

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I would like to reserve five minutes for rebuttal, if possible.

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Your Honour, three things as far as I understand are not in dispute.

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This family are Mescanian Turks, and the IJ found them fully credible, and the IJ found Mescanian Turks are this favourite group in Russia.

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Today I will be making four arguments, and if I have time, I would like to point out other things as well.

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First, the IJ and the BIAs, I believe, mischaracterized the actors and failed to apply the Sharma correctly.

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Second, I will be talking about the family's unborn baby, who unfortunately died in the state hospital.

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And third,

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my client's conscription and his political and imputed political opinion.

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Can we start?

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Can we actually just start with that issue about conscription?

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Because how is it that there is the prospect that he would be conscripted?

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How would that be based on a political opinion or imputed political opinion where it doesn't appear that

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he's ever expressed one to them.

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They're not aware that he has this opposition.

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And what in the record suggests that that's why they would conscript him.

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They just want to conscript everybody.

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So they're not particularly discriminatory or selective.

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They'll just take anyone who's a male within the age ranges.

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So I don't see that there's an imputed political opinion.

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And then how is it on account of?

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So can you address that, please?

[00:03:16] Speaker 03:
Yes, Your Honor.

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Thank you very much.

[00:03:17] Speaker 03:
Your Honor, so actually we are talking about a person who is a Meskenian Turk who fled to the United States of America for asylum.

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who fled the country to avoid draft and who tells in the court under the penalty of perjury that he doesn't believe in this war.

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So we are not talking about like a person who lives in Russia who just doesn't go to the army for some reason.

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He is in the United States, speaking for asylum, and he avoids the draft.

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So also, Your Honor, so he is a Palestinian Turk.

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He's a minority in Russia.

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Well, but that's good.

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I understand the claim that they selectively conscript and they actually prefer to get the ethnic

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you know, minorities and send them to the front line in Ukraine.

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That argument, I understand, is separate.

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But I'm focusing for the moment on the political opinion argument.

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And it seems to me that your political opinion argument is in some tension with the Supreme Court's decision in Ilias Tsikaryas, where the claim was sort of similar.

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The gangs, you know,

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or trying to, or whatever, the organization is trying to recruit me, and I have an opinion of opposition, and the court said, well, the fact that they try and recruit doesn't mean that everything's a political opinion.

[00:04:51] Speaker 03:
Yes, Your Honor.

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Your Honor, but I believe that Eldar's situation is a little bit different.

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So he escapes Russia to seek asylum to the United States.

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And also, I believe that he

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might be in danger should he go back to Russia, he sought asylum in the United States.

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And I found one case law, Al Harbi, and asks one question, actually.

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It says, when this person returns in the case law, what will his government think?

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So the answer, I think, is parallel to Al Harbi case.

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And when he goes back to Russia, I believe that the Russian government might impute the political opinion of

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like evading the Russian wars by seeking asylum in the United States.

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So I believe it's a little bit dangerous for him in this scenario.

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I believe he's not a person just living in Russia, avoiding the draft, just living in Moscow.

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He's not like that kind of person.

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He came to the United States of America

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to avoid the draft.

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I believe that is a parallel to Al Harvey case as far as I understand from the case.

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And what's the basis for that conclusion you have that he would be treated worse than someone in Russia who avoided conscription?

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I'm sorry.

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Yeah, go ahead.

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Your honor, I believe that he is already treated differently than the other people who are enlisted in the army.

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He is a minority group.

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He is just like a disposable soldier.

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Even if he complies with the Russian government's enlistment, he is going to be sent to the war field because he is an ethnic minority group.

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And this is what happens

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even if he complies, he's being treated badly.

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And when he comes back from the United States seeking asylum,

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I believe that he's going to be treated differently than the other people, than the people who are living in Russia and just avoiding the draft for some reason.

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So I believe he's going to be treated differently because he also sought asylum in the United States.

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Are there country conditions evidence or any other evidence of the record that would suggest that?

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I understand you're saying intuitively that may be the case, but is there something, testimony or country conditions evidence or anything else that would suggest that?

[00:07:56] Speaker 03:
I am not aware of that, Your Honor.

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He just testified that the police came to the door and then he said that he needs to come, otherwise that would be consequences.

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So I believe that he's actually one of the targets.

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And I believe that he's not just like a general person that just avoids the draft in Russia.

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And it's just a 10% of fear for persecution, Your Honor.

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I mean, I believe he hits that 10%.

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May I continue, Your Honor?

[00:08:47] Speaker 02:
Oh, yes.

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It's your argument, your time.

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So if there's not a question, the floor is yours.

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OK.

[00:08:54] Speaker 03:
Thank you, Yoran.

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Also, I would like to talk about, I counted almost 30 incidents that he suffered with his family in Russia.

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And it was all because of his ethnicity, because he's a Meskenian Turk.

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younger than 40 years old.

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I mean, 30 different incidents that he endured in Russia.

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I think it's a lot of incidents.

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And IJ and BIA just, you know, counted the incidents, says this is not enough, this is not enough, this is not enough, this is not enough.

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But I believe that they failed to look at the

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look at the general, like the combination of the harm, the portraits, I believe that they failed to do the Sharma analysis in this case.

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And I believe that they misidentified the actors.

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Because as far as the testimony I see, the state police beat Eldar, threatened to drone him in the Cuban River.

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State prosecutors warned him the police could do worse.

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State farm collectors destroyed his crops while Russian neighbors were untouched.

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So there were a lot of incidents that he endured, but I don't believe that the BIA and the IJ checked the whole totally of the circumstances.

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And Your Honor, I also would like to talk about the baby, the unborn baby of Eldar.

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I believe that this is the most serious harm in this record.

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And I believe that Ajay made two errors here.

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First, he said that Leyla, the wife, was not in the position to observe differential treatment because she never left the room.

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but on cross-examination when the government asked how she knew others were treated differently she said it's also in the transcript because in one room there were several people lying there so she was in a shared room and watched other patients get evaluated and treated and she was able to see it from her own bed but the IJ I believe got the facts wrong there and also

[00:11:16] Speaker 03:
IJ asked whether genetics or other medical conditions could explain the miscarriage, but Leila said that I don't think so because in 2016 she had the same kind of

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pains and then she was able to go to the hospital with the family and the family pressured the doctors and then she was able to get some treatment and IV and she gave birth to Imran who is thankfully alive today but in 2020 unfortunately she was not getting she didn't get the proper treatment and she her unborn child unfortunately died

[00:12:00] Speaker 03:
And the IJ also said that, oh, maybe it is the genetics that there could be other reasons why she lost her baby.

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And I believe that this is kind of speculation, respectfully.

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And I believe that any other person could have just said, OK, then this guy, this person got the treatment in 2016.

[00:12:25] Speaker 02:
Did you want to save time for rebuttal?

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Because you're down to four minutes.

[00:12:31] Speaker 03:
Yes, your honor.

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Okay.

[00:12:32] Speaker 03:
Oh, yes.

[00:12:33] Speaker 02:
All right.

[00:12:34] Speaker 02:
Thank you, counsel.

[00:12:34] Speaker 02:
All right.

[00:12:35] Speaker 02:
So we'll hear now from Mr. Rabin.

[00:12:41] Speaker 01:
Good morning, your honors.

[00:12:42] Speaker 01:
May it please the court?

[00:12:44] Speaker 01:
My name is Arthur Rabin.

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I am the respondent's counsel in this case.

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Substantial record evidence supports the agency's determination that petitioners failed to establish past persecution or a well-founded fear of future persecution in Russia.

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Now, the incidents they described were many, but they were isolated, sporadic, and spread over many years with long periods of no harm.

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As to their fear of future harm, this claim rests largely on routine military conscription.

[00:13:12] Speaker 02:
Well, let me just stop you there.

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Routine military conscription, when even the IJ acknowledged that the Russian government has

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a preference, and the country condition report says the Russian government likes to round up ethnic minorities so it can send them to the front line in Ukraine, which the US government considers to be a war, an unlawful war of aggression and violation of international law with numerous human rights violations.

[00:13:43] Speaker 02:
So to characterize this as ordinary conscription doesn't seem to be consistent with the record.

[00:13:51] Speaker 01:
Well, Your Honor, first of all, that was one, the judge cited a single source.

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That was one report, not even a government one.

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Number two, petitioners never raised the fact to the board that their claim is based on ethnic targeting, that the conscription was because they were ethnic minorities.

[00:14:13] Speaker 01:
They never raised that claim.

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They raised the claim that he was fleeing Russia due to conscription.

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Now, the record shows that the Russians are so in such dire need of men.

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I mean, they're scrubbing the bottom of the barrel at this point.

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I mean, they're getting North Koreans to fight for them.

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So the fact that they're looking for him, that's nothing out of the ordinary in Russia.

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whether it's a war of aggression or not, I don't think that's an issue.

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I think the issue here is, did he show that this was something other than generally a call for conscription?

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And if so, what's the exception here?

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Is he saying that he will be disproportionately punished when he returns?

[00:15:02] Speaker 01:
No, he never argued that.

[00:15:03] Speaker 01:
In fact, there's nothing in the record that shows he received any threat

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other than the police showing up after he left Turkey and saying, hey, where is he?

[00:15:13] Speaker 01:
And if he doesn't show, he's going to be in trouble.

[00:15:16] Speaker 01:
Now, that's not saying that the judge issued a warrant for his arrest or the military police were there rounding up his family or any other action was going to be taken against him.

[00:15:29] Speaker 01:
So at this point, what we have is a lack of proof of anything other than

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And he's fleeing conscription in military service because he doesn't want to go fight for a country he doesn't believe in.

[00:15:42] Speaker 01:
He does not like the Russians because he, obviously for obvious reasons, he was harassed, discriminated against.

[00:15:49] Speaker 01:
So he does not want to go there.

[00:15:51] Speaker 01:
Now, as far as his claim that he was a conscientious objector, he voiced that to whom?

[00:15:57] Speaker 01:
No one.

[00:15:58] Speaker 01:
He did never claim to anyone, any public official.

[00:16:01] Speaker 01:
In fact, the record shows he never claimed to anyone.

[00:16:04] Speaker 01:
He was a conscientious objector who would have then imputed a political opinion to him.

[00:16:12] Speaker 01:
Now, turning to the past persecution claim,

[00:16:18] Speaker 01:
The agency recently concluded that they did not experience what amounted to the harm amounting to persecution.

[00:16:27] Speaker 01:
It was discrimination, harassment, a single police assault, a brief period of two hour detention, and economic difficulties that did not threaten life or freedom.

[00:16:38] Speaker 02:
I want to stop you because you said a few minutes ago that he did not raise to the board the argument that

[00:16:48] Speaker 02:
the Russian government engaged in selective recruitment for the military of ethnic minorities.

[00:16:59] Speaker 02:
And I'm looking at his brief before the BIA on page 19, and it says, moreover, respondents submitted evidence showing that minorities in Russia picked by the Russian government to conscribe

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and send into the war zone.

[00:17:19] Speaker 02:
The government specifically picks minorities to conscribe and send into the war zone.

[00:17:25] Speaker 02:
So that was just, what you said before was just inaccurate, correct?

[00:17:29] Speaker 02:
I mean, that's right there on the brief.

[00:17:31] Speaker 01:
Yes, yes, that is inaccurate.

[00:17:33] Speaker 02:
Now the BIA did not even address this claim.

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It's not even mentioned in the BIA's discussion of conscription.

[00:17:42] Speaker 02:
So here we have an argument, which is frankly his best argument,

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It is in fact raised, contrary to what you said.

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And now we have the BIA just blows past it without any consideration.

[00:17:55] Speaker 02:
So why shouldn't we send this back?

[00:17:57] Speaker 02:
Because this is a serious claim, and maybe the BIA needs to take a look at this.

[00:18:04] Speaker 01:
Well, because before the immigration judge, he submitted a very lengthy, single-spaced, eight-page statement.

[00:18:12] Speaker 01:
He testified, his wife testified, his brother, his brother-in-law, his parents all submitted statements.

[00:18:18] Speaker 01:
None of that stated that he was claiming that he was being sought by the Russian authorities.

[00:18:24] Speaker 02:
They're raising a whole menu of claims.

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They don't want to go back.

[00:18:28] Speaker 02:
Everyone understands they don't want to go back.

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And they've made every argument.

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But you're allowed to make five alternative arguments.

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And it could be that four of them have nothing to them.

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And not all of them need to mutually support each other.

[00:18:41] Speaker 02:
But here we have one argument which does seem to have some legs.

[00:18:46] Speaker 02:
And the BIA, it was presented to the BIA, and the BIA ignored it.

[00:18:51] Speaker 01:
Well, I think the BA did not ignore it.

[00:18:53] Speaker 01:
It's just they reviewed what he raised and the evidence showed.

[00:18:59] Speaker 01:
And as Mr. Atchcock stated, the most severe thing that they're raising is the miscarriage of the wife's baby.

[00:19:10] Speaker 01:
So even now, the center of mass for their argument is not this.

[00:19:16] Speaker 01:
So it is not unreasonable for the board never to have reached that argument because it was never meaningfully raised to the board in a way that the evidence reflected that.

[00:19:26] Speaker 01:
Because if the board is sent back, this case was sent back and remanded, and then the board is going to take a look at this, they're going to say there was a single instance in one non-government report that shows that the Russian authorities are disproportionately targeting minorities for the draft.

[00:19:46] Speaker 01:
He never claimed that to the immigration judge.

[00:19:50] Speaker 01:
None of his statements or testimony.

[00:19:53] Speaker 02:
The immigration judge specifically noted in a footnote that that evidence had been presented.

[00:19:57] Speaker 02:
Now, the immigration judge noted it and then didn't do anything with it.

[00:20:03] Speaker 02:
But at least the immigration judge acknowledged it.

[00:20:05] Speaker 02:
But then the BIA didn't address it at all.

[00:20:10] Speaker 01:
He didn't address it because it was in a footnote that was never meaningfully raised by petitioner.

[00:20:17] Speaker 01:
The petitioner was represented by counsel in front of the immigration judge, and that was not the focus of his claim.

[00:20:26] Speaker 01:
It was not that he was being targeted for the draft because he is a Musketian Turk.

[00:20:35] Speaker 01:
He was just wanting to escape the draft regardless of how they came to his door.

[00:20:42] Speaker 01:
So to send this case back would, I think, not lead to a different, I mean, I think the court can convince itself that it would not lead to a different result and that this was harmless error because

[00:20:56] Speaker 01:
Even he never argued that.

[00:20:59] Speaker 01:
In fact, he didn't argue that here.

[00:21:00] Speaker 02:
I'm looking now.

[00:21:02] Speaker 02:
I think you said that this was mentioned in one report, and it wasn't a government report.

[00:21:08] Speaker 02:
Is that correct?

[00:21:10] Speaker 01:
It was mentioned in a report.

[00:21:14] Speaker 01:
It was some kind of house.

[00:21:16] Speaker 01:
I'd have to find it, Your Honor.

[00:21:17] Speaker 02:
Again, I'm looking at the record.

[00:21:20] Speaker 02:
I'm at page 681 of the administrative record.

[00:21:26] Speaker 02:
which has Russia 2002 human rights reports, and it says at the bottom country reports on human right practices for 2022, United States Department of State.

[00:21:38] Speaker 02:
And then you go, it's quite a ways into the report, but it specifically has a statement about the selective recruitment of minorities.

[00:21:55] Speaker 02:
On page 56 of the report going to 57, so it's administrative record 737, it says, there were reports Russian authorities disproportionately mobilized members of non-Russian ethnic groups to fight in Russia's war against Ukraine.

[00:22:13] Speaker 02:
So your statement that that was not an official government report was also not accurate.

[00:22:24] Speaker 01:
I'm sorry, Your Honor, where are you pointing that to?

[00:22:27] Speaker 01:
Page 56.

[00:22:27] Speaker 02:
Page 737 of the administrative record.

[00:22:37] Speaker 02:
It says... It's right on the top of the page, first full paragraph.

[00:22:45] Speaker 01:
I know your restriction, senior government official.

[00:22:51] Speaker 01:
Yeah, I'm not seeing on page 56, your honor.

[00:22:54] Speaker 02:
No, it's it's page 737 of the administrative page 57 of the report.

[00:23:02] Speaker 01:
Okay.

[00:23:03] Speaker 02:
Yeah.

[00:23:04] Speaker 01:
Yes, sure.

[00:23:04] Speaker 01:
Okay, I see that now.

[00:23:06] Speaker 01:
Again, I apologize to the court.

[00:23:07] Speaker 01:
I did not see that earlier.

[00:23:09] Speaker 01:
As I noted in my brief, it was contained in a different report.

[00:23:13] Speaker 01:
But again,

[00:23:15] Speaker 01:
The focus of my argument is that this is not a claim that was meaningfully made to the immigration judge that said, I am fleeing Russia because of ethnic persecution, given that they are seeking minorities and targeting minorities for conscription.

[00:23:37] Speaker 01:
That was never argued or raised to the immigration judge other than in this report, which the immigration judge in fairness mentioned and so did the board.

[00:23:49] Speaker 01:
And so did I in the statement of facts, just to be fair.

[00:23:54] Speaker 01:
But I don't think that was, as presented today, was the focus of their argument.

[00:23:59] Speaker 01:
The focus of their argument is that he was fleeing conscription, just general conscription, not because he's a Muscatian Turk, other than the fact that he's been persecuted his whole life and he didn't want to join because he said, one, he's a conscientious objector, and two, he testified he didn't want to fight for the Russians.

[00:24:23] Speaker 01:
To continue, Your Honors,

[00:24:32] Speaker 01:
So even cumulatively, the incidents that they raised do not rise to the severe persecution that they've alleged.

[00:24:41] Speaker 01:
This court has repeatedly held that isolated incidents without serious harm do not compel a finding of persecution.

[00:24:47] Speaker 01:
Petitioners remained in Russia for more than two decades after the 2002 incident without similar violence against Mr. Gafurov.

[00:24:55] Speaker 01:
That strongly supports agency's conclusion and denial of asylum.

[00:24:59] Speaker 01:
Now, without past persecution, petitioners can still show an objective of reasonable fear, but they have not done so.

[00:25:07] Speaker 01:
As noted, petitioner argued that he was a conscientious objector.

[00:25:12] Speaker 01:
But military conscription by itself, as noted, is knock grounds for asylum.

[00:25:16] Speaker 01:
And this court has held that repeatedly in a case called Zahattie and others.

[00:25:22] Speaker 01:
In any event,

[00:25:24] Speaker 01:
He was classified as having very limited military capability because he never actually served in the Russian military before when he was a young man.

[00:25:33] Speaker 01:
He lacked military training and he never expressed any political opposition publicly so as to establish his conscious objector status.

[00:25:42] Speaker 01:
Moreover, and this is just as important, his voluntary return following his departure to Turkey after he learned of the conscription of men his age shows that it undercuts or at least weakens his claim of having an objectively reasonable fear of persecution in Russia.

[00:26:04] Speaker 01:
Now, moving on to his disfavor group claim, even though petitioners were Muscatian Turks and were part of a disfavor group, that alone is insufficient.

[00:26:17] Speaker 01:
They must still show individualized risk.

[00:26:22] Speaker 01:
There was no threats against them individually.

[00:26:26] Speaker 01:
There's no actual government or proof of government interest in petitioners.

[00:26:31] Speaker 01:
And there's no evidence they will be targeted personally because other than the one brief visit by the draft enforcement people, there has been no official contact with any of his relatives in Russia.

[00:26:45] Speaker 01:
Finally, as a pattern in practice, petitioners also claim a pattern in practice of persecution, but that requires systemic pervasive persecution of an entire group.

[00:26:56] Speaker 01:
But the country conditions already show that yes, there is discrimination, strong societal bias, economic hardship, but not systemic persecution by the Russian government, or that it tolerates de facto discrimination.

[00:27:10] Speaker 01:
Petitioners themselves lived in Russia for decades, were issued Russian passports, were able to leave freely without severe harm.

[00:27:18] Speaker 01:
That evidence also supports the agency's conclusions.

[00:27:22] Speaker 01:
Now, petitioners also raised a number of other claims, including due process.

[00:27:29] Speaker 01:
But as noted in our brief, there was no exhaustion of those claims.

[00:27:34] Speaker 01:
Thus, their claim that their hearing was fundamentally unfair because of interpreter errors or that the judge somehow mistakenly referenced the date of his return.

[00:27:49] Speaker 01:
That claim the petitioner voluntarily returned is undisputed.

[00:27:57] Speaker 01:
What they're disputing is the actual date he returned and that the IJ mistakenly noted in his decision.

[00:28:03] Speaker 01:
But the board actually went back and went through the chronology and got it right.

[00:28:10] Speaker 01:
So in this case, I do not think there was a fundamental unfairness as to the hearing.

[00:28:17] Speaker 01:
The court's questions that concludes my argument.

[00:28:20] Speaker 02:
All right.

[00:28:21] Speaker 02:
Thank you, counsel.

[00:28:22] Speaker 02:
We'll hear rebuttal now.

[00:28:29] Speaker 03:
Thank you very much, Your Honor.

[00:28:31] Speaker 03:
Your Honor, I believe we submitted the evidence the Department of State reports and then it says that ethnic minorities are sent to the war field as a disposable soldier.

[00:28:44] Speaker 03:
So I believe that the reason why he also doesn't want to be enlisted in the army is because he's going to be sent to the war field because he's going to be treated differently.

[00:28:56] Speaker 02:
Where before the IJ?

[00:28:59] Speaker 02:
did you assert the claim that the Russian government engaged in differential recruiting and targeting ethnic minorities?

[00:29:12] Speaker 03:
Your honor, I do not remember precisely.

[00:29:16] Speaker 03:
But as far as I remember, and because the IG noted there, I believe that we actually asserted that point.

[00:29:25] Speaker 03:
But I am not sure about this.

[00:29:29] Speaker 03:
But I do, I am sorry if I am wrong, but I believe that we did and I believe that that's why the IJ actually highlighted that point.

[00:29:40] Speaker 02:
Did you just have the, you know, the I-589 and the attachments and that an oral presentation or was there also sometimes there's a written brief

[00:29:49] Speaker 02:
to the IJ in the IJ proceeding, the other respondent.

[00:29:55] Speaker 02:
Do you recall whether you submitted such a document in this case, or it was just the application and the oral argument?

[00:30:03] Speaker 03:
Your Honor, as a practice, we actually submit the legal brief for all asylum clients.

[00:30:09] Speaker 02:
Even at the IJ stage?

[00:30:12] Speaker 03:
Yes, Your Honor.

[00:30:12] Speaker 02:
All right, so we can look at that document then.

[00:30:15] Speaker 03:
I believe so, Your Honor, yes.

[00:30:18] Speaker 03:
Yes, so as to the returning to Russia, I would like to answer that too.

[00:30:26] Speaker 03:
So, I mean, he went one time and he stayed 16 days.

[00:30:30] Speaker 03:
And the reason why he went back is to rescue wife and children.

[00:30:35] Speaker 03:
And actually, IJ said that he went back for 30 days, which was not wrong.

[00:30:40] Speaker 03:
And then I think he corrected himself in the written decision.

[00:30:46] Speaker 03:
He just wanted to rescue wife and children.

[00:30:50] Speaker 03:
And he actually had some incident because the military called them personally on the day 12 and they fled on the day 16.

[00:30:59] Speaker 03:
And after he fled, the police came.

[00:31:01] Speaker 03:
He found credible evidence.

[00:31:04] Speaker 03:
There are two similar cases, Loho and Hakem, and I think it's very different than what our situation is right now.

[00:31:14] Speaker 03:
Also, I would like to point out this favorite group.

[00:31:20] Speaker 03:
Your honor, I believe that the law is simple here, because the more group persecution you show, the less individual evidence you need.

[00:31:31] Speaker 03:
This is my understanding.

[00:31:32] Speaker 03:
And the less group persecution, the more individual evidence you need.

[00:31:37] Speaker 03:
So they kind of work together.

[00:31:39] Speaker 03:
And the government says that the group threat is low.

[00:31:42] Speaker 03:
Okay.

[00:31:43] Speaker 03:
When you look at the individual evidence, I mean, police beat him in 2002.

[00:31:48] Speaker 03:
Doctors destroyed his field while Russian neighbours were untouched.

[00:31:53] Speaker 03:
The military called him by name.

[00:31:56] Speaker 03:
He lost the baby because she was not getting proper treatment.

[00:32:03] Speaker 03:
count the 30 incidents from his written and oral declaration, Your Honor.

[00:32:09] Speaker 03:
I don't really... I think I need to learn more, but there are so many incidents that he endured.

[00:32:19] Speaker 03:
When you look at the totality of circumstances, I believe that he was actually persecuted in Russia as a Meskenian Turks, Your Honor.

[00:32:28] Speaker 03:
So that concludes my argument, Your Honor.

[00:32:32] Speaker 02:
Thank you, counsel.

[00:32:33] Speaker 02:
The case just argued will be submitted.

[00:32:37] Speaker 03:
Thank you, Your Honor.