an offer of permanent resident status citizenship or some other type of permanent resettlement the government bears the burden to establish the existence of such an offer here of the evidence is that mr allgood bori received a temporary permit allowing him to reside in brazil for one year and he renew that permit once or perhaps twice the record is not entirely clear on that point but under the plain text of the regulation and this court's precedent that does not establish an offer of permanent resettlement and i'd like indefinitely or is not expected to change in the examples that the regulation provides a permanent residence in citizenship are the quintessential categories of a kind of permanent changes data that has to be the person would what the regulation does is you need an offer a permanent resident status and gyp or some other type of permanent settlement and so the the adjective permanent modifies the type of status that is needs to be given to the person in order for them to fall within the regulation the answer question your honor you have to be you have to receive an offer that you can live in the country permanently that's correct that's ok  so the evidence in this case at the outset just doesn't support that any such offer was given there's literally nothing in the record showing anything other than that mr barry simply received a temporary permit and literally nothing in the record to support the government's view that this temporary permit could be renewed indefinitely and all we know it d was early evidence is that the permit would convert to more of a permanent kind of but it appears to be essentially a one year residence permit and i think it's not uncommon for many countries to offer a century when your temporary residence permit didn't allow you to work in in brazil it allowed him to work in brazil but it did not allow him for example even then reenter brazil it simply work in brazil for that one year is there anything anywhere in the record that says that this document this one year thing or anything else that says welcome to brazil here's your in effect offer that you can live your permanent one there's absolutely nothing in the record that says that at all and in fact the only thing the record says about brazil's willingness or i should say unwillingness to provide any kind of permanent offer is that brazil does not offer asylum and so the only thing in the record at all coming to accept that there is i understand that  that's given by the government and the government the by the foreign government and that our government can meet its burden to establish firmer selman by pointing to the fact that someone had an apartment and a girl from i would also please the court jennifer corey on behalf of the attorney general it was a government burden in this case to show prime facia evidence to mr albury had established for resettlement in brazil  and what we are working with here with his testimony that he had a residency permit they could be renewed annually and that on the permit he could live and work in brazil  that's absolutely true that's what makes that renewable there's also never been held that a renewable permit can't be considered a form of permanent refuge if we did have that whole thing or that policy were applied it would say well you have a girlfriend and there's a process for you know a possible renewal and he has an iraqi friend there he is with there for seventeen months is that does that satisfy the government's burden of showing what point in this in this process mr ellsworth he had to two opportunities to come back with the evidence to say that this wasn't  what is a crime of a ship burden and what you're saying is the government can list some factors the borscht from any documents that permits permanent prove a negative that he wasn't you and the ability to live in brazil permanently reside in that country indefinitely never been noodling indefinitely once we get it it does unless the evidence that the it indefinitely by definition means lasting for an unknown or unstated length of time in brazil gave no indication that there was any sort of indefinite amount of time and i think that the burden of the fact that the burden can be can be the petitioner burden could be met with just the testimony just like in  just the testimony that he had been told that threatened with not having it renewed or not actually the court's holding there is that there is added to the contrary to say that like listen you may not get that again but there's no evidence here he had a permit that was renewable and that was his testimony that he successfully renewed it and there was no engine si documents were not not in the record your honor again that the the that you that suggested you might that somebody might have and decided not to do anything with it might have sorry had known the regulation but not then what you know what we see is brazil's a very sophisticated country i'm sure they have rules and regulations that govern how these documents work yes your honor i agree and i think they were just working with his testimony about what his visa was and the visa itself which again i think we're we're working with fact that often are applied to permanent right that you can live there you can work there it's renewable  the i think they called it a residency permit i'm sorry if using that term council what's your response to opposing counsel of observation that the government had the actual documents and did not present them into evidence with the import anything more than the fact that it is the new level that is in you'll be renewable and you can live and work on it and so there was also what was the reluctance of the government to actually produce the documents i don't i don't know that firsthand all i can say is that there was no need to introduce the document if it proves nothing more the evidence was the same and so  i'm contested his testimony he's not saying that it was any more restrictive than what the testimony said just not think it was any more restrictive by anything that if there had been evidence that it was less restrictive than terms of you know what and restrictions if any were on the permit that's why was curious to me that the government did not introduce a permit i will say again i think if it had fact that the parameters of the permit and the whole point of firmly settlement is to give refuge to people who can but nowhere else to turn and all the evidence in here in and i believe the government met its burden of showing prima evidence that he could stay in brazil and the question so you don't dispute the characterization of whatever th that it is a consideration but it doesn't negate that he had refuge in brazil the right to live and work are really the most the most primary rights i'm due to mean he's not a right to travel and come back and and he could have said that as an exception again we're talking about the prime official burden that the government had and he could have said as an exception to fermi settlement this is too restrictive that this not having this r only after that point does the burden switch to the respondent to show that what on its face appears to be a permanent offer such as you know permanent residence is not in fact but here the government just didn't meet its  obligation in the st instance and i think it's telling that counsel for the government can't identify any case to support the government's position because there is none and we would unless the court has any further questions we would ask that the case be reversed