i'm ready please the court this is douglas nelson on behalf of the a note that i had previously reserve fifteen minutes i think ten would be sufficient and i would like to reserve two minutes i will keep my time the petition fears return to one of the most dangerous places on the planet iraq contrary to what the board decided the petition is not fleeing general strife norse's fear speculative he is quite a remarkable person in that when american and coalition forces invaded iraq in two thousand and three instead of taking iraq's side he chose the side of the invaders the americans because he knew that they were on the right side it's apparent that he learned this from his father who also took the side of the americans and worked for the americans both of them in fact would eventually work for the americans assisting the us military and both of them witnessed as members of their separate companies were threatened with death for their work the titian or had to call the skit not one of them was killed was released and fled the country his father had two employees that were also threatened and kidnapped and it's interesting that the father in the son had been treated differently by the u s government in that the father was granted a special immigrant visa and allowed to come to the united states whereas the son has to go through this on a process and so far two agencies and two parts of the same agency have said no to him now in the government's answer in brief it notes that we should be precluded from raising the argument about this father's special immigrant visa i'm not arguing with a response to the petition is not arguing that he deserves or qualifies for special immigrant visa so those are quite difficult to get their limited take many many years as evidenced by the fathers have occasion process but instead he's making the comparison the united states awarded the father the special immigrant visa status because he risked his life for the united states and when a foreigner risks his life for our u s forces we use americans are obligated to help that person that was the intent of the special immigrant visa process that same logic should apply to respond to the petition or circumstances he worked for the and in assisting the u s government but by two thousand five it became clear to him that he could not remain there as he continued to stay in iraq he would be harmed so he found alternative employment and went to the emirates now the government states that the tissue went back to iraq many times after that and that's true but that does not diminish his clan we have to take a look a little deeper look as to the motives for returning and the circumstances surrounding him when he returned but before i do that i want to mention one thing it's interesting that often it seems that the authorities the u s authorities expect a person to receive a threat and then abandon the country in never go back and often that's what's presented in these claims but here the petitioner felt threatened left the country in two thousand and five at a time when he was still optimism there was still hope that the circumstances might improve he waited and ultimately he observed there was a psych cycle from bad to worse from bad to worse different groups entering several times you're after so if you would you argue why those saying it's substantial isn't to get very very good and the government has argued that that your father when he goes isn't pleasant two of his colleagues are killed i mean if you place yourself in that circumstance and you realize that you have the same characteristics as those men who were threatened sometimes killed clearly you would have the same fear now i know that generally thirty's look for some clear threat that would make anyone feel return but it's not necessary and a good example of that after the american invasion well let me back up before the american invasion in two thousand and three christians were somewhat oppressed but not persecuted as a population but after two thousand and three they became oppressed and persecuted now there were many christians who were not living there at the time but because of the circumstances that existed there  just a pattern and practice of terrorists killing christians and that allowed them to win simon claims whether or not they had ever been threatened directly this petition has more than that he's got his government says there's no objective evidence of that in the record but in fact page one hundred and four dollars there's evidence that isis killed three hundred people by firing squad because they were accused of promoting democracy in the country and a page six hundred and ten dollars is another report for the us government included that iraq security forces were so infiltrated by sunni extremists and shiite personnel that any american assigned to advise that forces would face a risk to their lives the same holds for these people who assisted the americans and the proof of that is the program that we allow those persons who work with us to receive our protection now there's no well i hope that answers your point i continue but let's see let me check my time i apologize mistreated no i'm glad you asked that page seven of our brief we have the seven different reasons why he fears returns and that is one of them no i would just simply note that each of those characteristics are enough alone to be persecuted for or at the very least it elevates is visibility in the community for example suppose he's invited to participate at a mosque that he objects to the person who invited him are going to take a deeper look at and if they learned of his employment with the americans that would be enough for them to harm him special immigrant status to starr and iraqis who rendered faithful and valuable service and then therefore faced a serious threat does not relieve the petitioner of his individual burden of demonstrating an object reasonable fear of person he notably the standards for the special immigrant visa and a claim for asylum will call into our mobile are very different the special i'm grant these are require only shelling of a serious threat whereas to me the standard for asylum a petitioner has to demonstrate a fear of persecution which this court has repeatedly stated is an extreme concept but does not include every sort of individual petitioner eligible for asylum or withholding of removal it could have done so it could have amended the definition of a refugee or provided a statement about persecution for example congress specifically amended the definition of a refugee to encompass claims involving opposition to of course the family planning all but congress did not do so and this court should decline that company whether and when he made numerous return trips to iraq over the course of more than two years about every other month he would return to the country he claims to  or any sort of threatening interaction with a government official undermines his client fear of persecution from the iraqi government which is what this court indicated to be and rejecting a petitioners claim of a well founded fear of persecution this court specifically noted that the petitioner had been able to travel freely without any interference from government officials even though and that a government official had come to the petitioner looking for him the evidence here is much less than that where a petition or specifically tested he never had any adverse interaction with the united states or with the iraqi government and therefore the fact that he continued to return to that country undermines his claim of an object of fear future persecution to the extent that the petitioner argues that opinion and yet nobody had ever threatened him for expressing such and he also testified that nobody had ever tried to kidnap him and nobody ever directly threatened him he also specifically testified that his father had iraqi government history or harm from terrorists is also speculative again the sister was never harmed or threatened by any of the groups he claims to fear instead she simply relies in generalize stress and violence and under this court of evidence is insufficient to demonstrate a fear of objective really reasonable fear persecution  indiscriminate and general strike which again is not a basis for asylum or withholding or movable notably and well cari the holder this court rejected a claim of a pattern or practice of persecution against ethnic and chinese christians in indonesia explaining that even if a large number of people for discrimination or treatment and even those people experience harm rising to the level of persecution that was not sufficient to demonstrate a pattern or practice rich which this court has called as requiring evidence of systemic persecution and that is the situation in this case as well i notably the record containing contrary evidence for instance the two thousand and twelve religious freedom or provides a government generally respected a religious freedom  is and practice and the government continue to call for tolerance and acceptance of all religious minorities in short the agency weigh the evidence and the record including the evidence  protected by the us military scenario for numerous rockets as long as the americans were there so clearly he was affiliated with the americans and if anybody knows that employment and they may wan respondent had not returned to iraq he likely would have lost his job and sponsorship and his temporary residence was entirely based on that job meaning that if he had not gone back with that security detail he would have lost his job and he would be forced to go to the only country where he had to permanently reset it which is iraq and so it was entirely voluntary that he was going back to government council noted that some of the reports show mosque we bombed and it goes back and forth they are being targeted for their religious differences and one last point was to the two minute mark the father was government counsel correctly notes that the father was not threatened but nevertheless received the protection from the united states and that protection was granted to the petitioners mother and the petitioners brother likewise we should use people and like i said it's cyclical we had groups such as just on monday later on in iraq they just keep coming back and back and back usually with the same ideology persecuting person to differ from them and in this instance the respondent is list seven reasons why they would want to harm seven of his brief so he just needs to be persecuted for one of those persecutor has to decide which one is most important to them and they may have different reasons for selecting so but he's shown by what happened to his colleagues and by the country reports that people in similar situations are being persecuted on account of those reasons thank you thank you