good afternoon and may it please the court alexandria hi i'm certified law student on behalf of followed by a discussion of the multiple orders with regard to her well founded future fear theory of her silent claim st withholding of removal following the p i a s two thousand and seventeen order the legal standard for withholding the removal changed in broadcasts from arrow requiring and now to show a protected ground is simply a reason for the persecution seventeen order to distinguish whether or not her protector ground was a central reason or a reason for the persecution but this argument fails because mr website is entitled to have her claim examined by the b i and examined under the appropriate law so which protected ground are you relying on for the withholding klan understand there were three different grounds there was women in ghana who cannot leave their it's a pretty important procedural argument that we need to just recognize that back in page fifty four of the pre but i think that that's the most important issue that we need to address st and that's regard that relates to the scope communicating the fact that she is a lesbian she identified herself with b l g b t q acts as a woman who cheat on their husbands with another woman so we position or believe that she has clearly stated her particular social having authority to do so having you in your jurisdiction is not the same as being required to do so i do not see anything in the case law that address that point which i think is a significant distinction because the opposite is that error your honor because this was for multiple reasons this was error because mr what's up was unable to provide the country conditions on an earlier point so this would have been her st opportunity with counsel to provide the  after the fact this is all that pressure that existed you're arguing hardship because of her circumstances and that we should conclude she was precluded from presenting this information as i correct she was precluded because they would not accept while they accepted her credible appeal including checking the box and the standard form to appeal she was also represented by counsel off and on throughout this period and overlapping counts multiple counsel at various points and the fact that document was withdrawn by one of her counsel so how did to be i had the abuse its discretion in not considering the withdrawn notice of appeal why should they consider that motion to reopen your honor at the time that she filed that she was pro se and while people are pro se the court construe their findings liberally but what i suggest to your question you won is on the record in this case that she is not entitle to that liberality standard because she had counsel and in  discretion by not considering a document that it had been told by counsel was withdrawn your honor the court still has an independent obligation to assist the pro se applicant as much as possible when she says your assumption is that she should be treated as a pro so you could tell us why you keep saying that she is pro se when there seems to be some evidence in the record that she had counsel in fact it seems as if the record record is quite confused  jurisdiction and then the most courtroom and some were pro se and some were with counsel so it is very confusing but in the moment in which mrs woods offered that document motion to reopen  it's not an issue and it satisfies the subjective problem beyond a rejected her well founded future fear claim based on the object of conditions and the component requires that an applicant show persecution is a reasonable probability by demonstrating at least a ten percent chance of future persecution as a member either as an individual and with individual circumstances or as a member of a disparate group and st to analyze her as an individual missile was as credible testimony that she was warned by her mother that her husband had searched for her and had labeled her as a lesbian to multiple communities not just his neighborhood but the mother's neighborhood shows that she was unable to not still find a pattern and practice of persecution with offered country conditions it clearly passes the ten percent threshold of records just passed on this if there are no remaining questions orientation claim was fully exhausted and considered based on the fact that gonna according to multiple items in the record does not prohibit same sex lesbian couples in fact the  the outcome is in in favor of the government if the petitioner is asking us to really look at new documents which were submitted as exhibit our one into the new agency  been and is asking the court to to consider those documents those documents again don't change the outcome in this document identify hateful rhetoric but they identify only two or three instances of violence over an eight year period again that doesn't identify a pattern  practice of persecution certainly if your honour's feel that the board must look at these decisions or the immigration judge must look at these decisions we can go back for a rd go around the multiple bites of the apple in this case are extending error that the board limited the scope and then the agency the immigration judge agreed with the board so let me raise the same issue with you that i raised with your opposing counsel which is with respect to the procedur between having the authority meeting having jurisdiction and being with choir tribune issue but if we look at these orders and conclude that the agency either the i j a or the b i may mistakenly believe that the i  if we were to look at those documents again or the other judges were to look at them have a different view or convince me of a different view and say no these these orders indicate that the agency thought that i did not have jurisdiction when that would be erroneous what do we do about that fact finding needs to be made and certainly the agency would have to make that finding in the st instance but i'm asking your honor that you've been assuming that there was some error in what the immigration  decision would still be that this particular petitioner did not meet her burden of establishing asylum or withholding or so i don't know how this specific case i don't i question here your honour's the substantial evidence to support the agency's decision missed it was or did not present past persecution of it and sufficient to meet her burden it was not physically harm being for has been has abandoned the marriage she has claimed that she would be able to divorce him upon returning to ghana and that there would be no issue with her being able to leave the marriage or not being forced to remain in a marriage and so with and sixteen didn't get to that issue which it's allowed to do simply because it remained the decision miss it was to have asked on appeal to discuss other issues she did not focus on the cat issue she focused on the fact that she wanted her claim to be considered based on matter of r c g and to be considered a domestic violence victim so the board at that point really and so i don't see the error exactly would be more likely than not tortured by her husband gone or by the neighbors there's an again to show that she must show that there's a greater than fifty percent chance that her husband would be looking for her would want to torture her and would incite the neighbors to do so as well and that evidence is simply not there according to the agency and that was the proper decision that   husband and the neighbors she was not physically harmed and she was able to remain in gone out unharmed until she was able to leave the country and again there was no no testimony that she was unable to relocate to another part of governor or that her family required her to remain in the marriage or that anyone was pressuring her to come back to the marriage so again i would present the government's arguments in its brief that are supported by the substantial evidence in this case and i would simply note that mr wooster has just not met her burden in mr particular case five years after the incident in question in the five years after the documentary evidence that she submitted it and the record simply does not compel reversal of the agency's finding that she failed to meet her burden so accordingly i asked this court to deny the petition for review thank you judge  reasons the other reason is that the b i asked mr woods to supplement the record with facts and conditions to show domestic violence be limited her to domestic violence when she wanted to show