ok may please the court i'm robert job and i'm appearing on behalf of the petitioner balbir single this is much like the last case except in this case the claim is not that he has been persecuted by congress party members but that he was persecuted by members of a cali doll bottle which is another seek political party but it's a political party that does not support this movement for an independen now just as in the last case however in addressing whether or not mr gill could relocate the board never discussed whether he might face harm at the hands of the bottle party that attacked him in the past again their entire and alice this is whether the punjab police or the central police would track him down to some other part of india to persecute him they analysis from the board begins on page three of the record where the board says the immigration judge found that the local police no matter whom they may support in different states do not cooperate to find individuals who are not of interest to the central authorities only high profile militants are targeted for arrest by police acting outside of their home state not person such as respondent or low level akali dal mon members goes on to say  police have the motivation or means to look for him outside of punjab internal relocation is reasonable but he wasn't persecuted by the punjab because the guy was persecuted by members of a bottle this entire an is you know in opposite for that reason again we would submit that the board committed a legal air it did not apply the required presumption which has to be based on the original claim and as a result the case has to be sent back so that they can engage in the proper analysis i assume that in this case like in the previous case though you would indicate that if there based on the original fear i e that he was being persecuted because of his active political involvement and advocacy of his party that either the police or these people in the i forget which what they got name of the other party is but the other sikh party that was persecuting him would need to be he would need to be protected from either if you were relocated is that correct yes i mean the analysis would have to consider the central police the pun police of course it's relevant whether the punjab police are going to track this guy down in some other state although it's extremely unlikely but it also has to consider the local police in the state of relocation and the members of the political party that political parties and a kind of bottle does primarily operate in punjab but it's in an alliance with the b j p which is a hindu nationalist party which controls the entire federal government and india the only other thing i want to say is the government keeps going back to this library of congress report to suggest that it says that only high ranking or hard core  individuals high profile individuals are risk in the state of relocation that's what it is what the reports as is if a person seeks to escape the attention of local police in this case the punjab pleas and is not of interest to the central authorities then internal relocation is feasible and it makes clear throughout that it's not talking about local police in the area of relocation it's talking about whether you can escape the punjab police by moving to another state for example on the following page it quotes a report that says that internal location to escape the attentions of the local police in their home area would not be unduly harsh in the home area and then it goes on to say the most incredibly that the in this report it's folk it it it's summarizes and characterizes the two thousand and three report that was prepared by a us c i s and it's that report upon which the government relies and the board relies on all these cases but the most incredible thing about their reliance is that this library of congress report which is characterizing the two thousand and three u s c i s report says expressly that the u s c i s report does not specifically address the situation of how members of the mon party who relocate in fear of persecution are treated the government's entire case this is the sole piece of evidence upon which it relies in every one of these cases and yet the report is express it doesn't address the situation i'm around where party members were in the library of congress report the reply and what you just referred to what page that your honor is the most relevant pages are two fifty one and two fifty two it's a short report it begins at two forty nine a page two forty nine is the summary of its findings which talks about the scaping the attention of the local police and what of what i'm really talking about those were the library of congress report says that the us yes report does not deal with the issue of  i can't i'm not going to concede that these clients don't have a high profile they don't define that the simple the point however is that when you look at these decisions half the time when judge greer's wildest characterizing this he's saying that the that the finding is that members of a collie damayan who don't have a high profile are not at risk from the punjab police if they relocate it doesn't say that it doesn't say anything about that because they couldn't find information about how a colleague damayan members are treated the report makes two claims high profile militants are at risk and people who simply hold procol astonied views are not ok and then it goes on to say but we don't have any information about how to call it on nonmembers are treated argyl none of these people were persecuted simply for possessing procol astonied views they were put each and every in each and every case they were persecuted for engaging in public advocacy on behalf of palestine so even if you accept those finding limited to the region first on page two of the be a decision the agency clearly recites the petitioners argument appeal was that members of the ba dol party who are affiliated with the national b j p party so the allies and he claimed that the agency was not aware of and considering petitioners claim as a release the ba da party similarly page four of the immigration judge's decision also indicates that it is considering as part of his claim fear at the hands of the doll party this leads into the next point party is is in part holding pro coliseum views where the agency relies on documentary evidence talking about the treatment of individuals who hold pro coliseum views it is specifically relevant to man party members and in this case the between the four cases there are all slight variances in what the claims were in this case we have a petitioner who limited his claim to  mistreatment at the hands of but all party members while he was in the punjab region and then i fear that is somewhat related in that the punjab police will seek him out in the future if he relocates and so  specifically talk about members of the congress party or the doll party how does that i mean i know there was the allegation that they were both controlled by the same people that may have been true by the congress party but how could that be true of all part testimony itself and flecked in the country of course the ba da party is limited to the punjab party so petitioners claim has to rely in part on some way that outside of the job that somebody going outside of being relocated one the police that harmed him it was people in the bull party but doesn't talk about how that relocation solves that problem how can that be reasonable well so the relocation analysis is past experiences that his father experienced in that case because it's not necessarily related to the original claim the burden would be on petitioner but in this case the agency did consider all that because that is what is that exactly what's presented to them and the the i think the reason that some of the focus is on the long arm of force men in punjab police is because it's petitioners way of showing that because his claim is related to a political party that is geographically limited to the p for example but all parties seeks and that the broader point that i just wanted to raise is that the country conditions evidence show why this claim is such a local claim and it is the unique history of the  of the party right well it addresses it to the extent that it shows that outside of the punjab region that the mom party members don't face the type of treatment that they would face in the punjab region for expressing the same views doesn't say that it does to the extent that it says that holding so it is a more specific piece of evidence than perhaps some of the more general country conditions records in there and i think the report as a whole gives the background of what distinguishes mom party members from other from but all party members or relocation outside of the treatment of mom party mart members different than it would in the one of the other twenty eight states in india and that is really the basis of the agency's decision and that is well supported by the country conditions evidence and even petitioners own testimony in this case which indicates that the not operate outside of the punjab region and that his fear would be somehow that some other local police become aware of his activities which i think my colleagues have shown the record demonstrates that the infrastructure mechanisms are simply not in place for that sort of long on enforcement to occur and so the agencies decision here is well supported to show that the government met its burden to to rebut the presumption showing evidence that is contrary to what the government has submitted i don't know that the regulation provides for a standard to rebut the rebuttal the presumption thank you up very well you're almost done almost perhaps the most frustrating part of arguing these four cases is the government's reliance on this these two sentences in that library of congress report they read that as as being that people who simply hold a procol stony view will not be mistreated in the area of relocation but the report doesn't say that  drops a foot now and explains where this u s c i s report is online it's available to anybody who wants to look at it and the discussion that they're characterizing here in that report is under a section and called pursuit of certain sikhs who have relocated to other parts of india by punjab police with help of the national or other state authorities consistent with everything else in the report those two sentences there are talking about whether the punjab police would have the motivation to track down certain individuals in other parts of india it says that if you simply hold a procol astonied opinion punjab police aren't likely to do that on the other hand if you're a high profile terrorist then they are likely to do that big surprise when you know anything at all about  the man i guess there are presumably men party members in other parts of india there are certainly other sikh communities although well there's nothing in this in any of limited that's why we would say the government has made its presumption but in that one library of congress support not this one about internal relocation but the other one that i referenced earlier it does talk about people being charged with  fifty times and they're a different case fifty years or something yeah all right thank you very much thank you both for your argument because just