has a lot of difficulty discussing the details of her traumatic experiences which is very common people with p t s d as a result she concluded it is likely that it will be challenging for her to discuss the trauma during the hearing that's on page two eighty four in the immigration judge's decision he does not discuss this move as it's p t s d diagnosis in relation to assessing any of the perceived inconsistency during the hearing th doctor's report correct writes the doctors are poor he doesn't discuss it with respect to any of the inconsistences however during the hearing he concluded that he did not see any visible signs from her demeanor that she was having  without any explanation as to why in this case on the record and there's evidence that supports the psychiatry observations from all that yes supposing we were say that and assuming are you i know she's credible but how what they are saying it's not clear from the board that they relied on that they didn't rely on that risk but they didn't disturb his alternative finding in any way i disagree on i think that this is an independent this is a six page decision from the board it did not expressly and he pointed out the immigration judge is finding well let's assume we don't agree with you on that tell us about your nexus argument it seems to me you have three disparate events that don't hold together to match up us three theories a protected group well your hon with respect to next as we have the three particular social groups that were unchallenged the motivation of missile bases persecutors can be shown by direct i'll not challenge may not be exactly right but not evaluated because they really didn't reach it instead they said there's no nexus between the harm she suffered and the particular social group that's correct your honor so i don't know that it was a challenge to issues they didn't reach it they just said you cannot suggest that even one even if this is a particular social group that there's nexus this time john i don't and i guess i'm trying to figure out why they were wrong nothing seems to like it to happen because it was part of a group instead to see shows that she was the victim of criminal activity extortion or maybe stocking but the s m s three gang demands board's comment about gen y all right when there's generalize and widespread violence in a country this should not be used as a factor when against what i lived through course that's true but but they me the social groups that you're trying to define are least let's say not obvious i mean they're not and so there has to be  connective i mean it there are some reason to think that for example the reason these women beat her up was because she was a single woman there's three alternative whatever that any one of them any one of asked the question what was the motivation of the four women who attacked her at the nursing institution and she says said it was because she was new and because they ran the place isn't beat till torture their victims for multiple reasons and one of the central reasons or just one of the reasons under withholding of removal can certainly be one that is protected by law ok and you still haven't given us a connection and  first with there's that stance on the record that she was targeted for being a woman is and i can go through them this is in the reply brief ten page nineteen and twenty six on page three fifty eight there's information directly on point in two thousand and ten the year mr lopez fled her home five hundred eighty women were murdered because of their gender and some of these families sides are directly linked to modernise in the same age women's bodies are fun mutilated raped with little action from law enforcement on page force sixty five at least one women woman has been killed every day in el salvador since two thousand and two el salvador by the way is smaller than the state of new jersey and an article in the record describes how young women are viewed in by society in el salvador as property and easy targets here but it's the evidence in this record that you have to focus on and the next is that this petition or placed into the record apart from the generalized country information or are you just relying on the generalized country information and when it comes to her gender yes your honor the imus thirteen didn't tell her they were gangs of demanded small daily payments from everybody yes your honor and that doesn't undermine her claim or games to me it makes it such that there seems to be no nexus them your honor again general violence doesn't undermine her claim if anything it's all in general it doesn't mean the problem with the way you're arguing is you're giving us broad propositions which are accurate but you're not trying them into the facts of the case so you have to try t into the facts of the case ok so how in this case yes does the fact that she was i mean first of all your group isn't a woman i gather i've always wondered why woman isn't just social group but it doesn't appear that you're not claiming it and i don't nobody maybe it's nobody does you're claiming a subgroup of women essential so you have to show us how this ties in to the subgroup of women that you're talking about specifically in some fashion i mean even the evidence that your country evidence you're citing doesn't differentiate single women live was protected from other people so i think her testimony supports that portion of your honor with a certain to what with respect to her being a single woman with respect to her being so the people who attacked her in the school knew that she was a single woman as opposed to a woman that given the network that the m s thirteen has and that's supported in the record that this is and the timing of these events need to be tied all together and there's circumstantial evidence of that you understand that what we're trying to do very straight it says the desire to avoid harassment or activity by criminals motivated by theft or random violence by gang members there's no nexus to a protected ground so judge judge hers on is trying to give you a couple hints here she's saying come on you've got to distinguish that tino you haven't done it yet your honor i believe that tino is is about general crime and yes there is general crime in el salvador in this case there's circumstantial evidence given the way these events happened to her given the quick succession that they happened to her that she was being targeted for these particular reasons and n i believe that the errors that we identified in the board's able and willing analysis for purposes of asylum and withholding and given the substantial overlap of the evidence in the cat kept context presented evidence to show why she could not go to another part of our salvador he said he was doing it on all evidence relevant to the possible future torture and then included it did a list of including but not limited to should accept that at face value your honor i think again i think that if you read the decision the immigration this isn't it's clear that the burden is being put on miss lopez and well who are just one last question no i said i was what happened here that could possibly be torture your honor i think that the case that the immigration judge didn't reach that decision he didn't persecution and torture were both in the the way we do credibility findings for the petitioner might be applied to the i j a as well because the ising here said several things that were so silly and flat wrong even the be a recognize that some of the were flat wrong then i don't know why we should take  credibility finding at all what he just said this guy had had bias or blinders or something but he just made so many stupid mistakes then we should just forget him the immigration judge is errors the board corrected  three of them were flat out wrong left for behind that were not i understand that but that's if you go go about it that way why do we go about it that way if we're trying to decide whether a petitioner is credible we say well you may have says you know i they say three contradictions or not credible well this guy and making his judgment about whether she was credible main i would say at least four flat out mistakes because this read things ridiculous and why do we believe anything he said at that point and there in the declaration i think it was several in the hearing it was twice but he did not give her an opportunity to explain the distinction between several and twice even know that that several means more have two and two that i don't know what words you use in spanish but it's an awfully thin reed the difference between i mean generally it was more than one where there was  inconsistency but i can tell you if i went to many people in this country and said you know what this is something happened several times and tell what it was only till they went think that was a contradiction certainly if the court me on testify he did not know it was a letter and so we don't know why shouldn't really we don't know she didn't know if she didn't think anything of it or she didn't think she thought it was just you know some kind of thing of noxious who knows she also provided inconsistent statements regarding the number of times she was targeted outside of her nursing school she provided conflicting information regarding the telephone telephone calls who was asked for what happened when different people in through the phone in general the sequence of events was she way i believe so my worry about these is that you know when i first came to this court i thought this would be kind of a simple thing for at first credibility but now  look at looking our case law it's not quite the same first fall we have to have an inconsistency but about something that's really inconsistent we can talk about years we can talk about time and after we talk about what's inconsistent not only do we have to talk about what's inconsistent but then the person asked to be confronted with the inconsistency and then after being confronted with the then somebody has got to evaluate their explanation there of and if they have an explanation and they have valuate their explanation there of then at that point finally the b i or the i j a can be sustained when i went through most of these things that you have in front of us i can't find that general if you will outline there in so given that that's our case law can i eliminate all those where she was not confronted eliminate them i mean if he says that it isn't something on which they can base the adverse credibility all it takes is one i understand but then even if if she's not given a chance to explain or if the explanation they have operates by nation is frivolous as my good call they give suggested that at that point again we can't have that can't be an adverse appropriate measure of credibility right yes ok so then i go to the alternative approach so talk to me about the nexus here there's all kinds of violent crime going on in general and but they happen to like the chase really to attack you know that people so it's not it's no more useful the question is what about this case right ultimately it's the burden of proof to provide that evidence as judge test always was pointing out that it's about what this record shows and while there might be generalized violence and while she might have been under some unfortunate incidents the details of which are are somewhat hazy ultimately she bears the burden of proving a nexus between those incidents and her membership in an particular social group and if i find a nexus or about the inability or unwillingness to control  unwilling it's an able and we know the whole point of the crowd of them why spread violence is that the the police don't seem to be able to do anything about it i apologize for citing a case  at his record lopez says her hometown police often cited with the m s thirteen she says they ignored the gang related violence reports by women she says she feared retaliation if she reported to them that seems to be quite a quite a bit of evidence that would suggest that one can say that there's an ability and a willingness to control then if i look she calls her brother and the brother doesn't say well go down see the police and the brother's a policeman the brother says well change your telephone that's the only way to deal with it there's another will it is seems to me more evidence that there's no ability or willingness to control how do i deal with that in the record that unfortunately ties back to her credibility in terms of her own experiences as and probably the statement as well and she said but actually what she said was oh i didn't know i needed that i can get it if you want so so as to get her so if there's a problem there  again the questions about whether or not she had several or a few or two encounters with boris there were still underlying consistency there as to whether or not he was in his car he was in his car the first time was in his car the second time and that yes because it seems to me that even if we were to give you something on the other claims you got to pay out bad problem with the can't claim given the how they gave the bird to the petition that there's no burden on the petitioner to show it's impossible to relocate i thought your argument was that the i j cited all the factors and looked at the evidence in the record and didn't base it solely on absence of evidence of inability to rea strong adverse credibility finding where the immigration judge indeed gave the alien substantial opportunities to explain her numerous of consistencies and she said oh ok thank you very much finding the record needs to be remanded so that the red and procedural requirements can apply so that missile pres actually gets an opportunity to provide that corroboration that she never got an opportunity to with respect to the m s thirteen gang leader i'd just like to with respect to what happened there i missed thirteen this c n fwiw ghosts miss opus testified of the known murder and the community when she left her house he followed her meters away from her this was happening at the same time as she was receiving around the same time that she was receiving calls these calls she described him as well mannered imply didn't she that's that was the manner that he that he was speaking to her yes your honor and that's what terrified her she knew exactly who he was and the power that he had and that he was the leader of the m s thirteen in that area at the same time she's receiving calls that echo what's happening these calls are we know you're there we know when you leave we know when you come home when she walks out of her house thirteen leader and they're in his car saying you know what i can offer you protection if versus sessions will go on to united states for says charney ask and it will take a short break after the next