good morning your honour's may it please the court i'm katherine lewis appearing on behalf of the petitioner it ball stating since none of the alleged in discrepancies cited by the immigration judge can be supported by substantial evidence this court must reverse immigration judges adverse credibility findings several of the alleged inconsistency cited by the immigration judge are based on pure speculation one of the immigration judges main focus is and mr mr singh's testimony about a filed within the one year and the immigration judge made her decision on the one year issue based largely on her adverse credibility decision was there any documentation mr singh did have a letter from a  is finding on the one year if she turns largely on her adverse credibility finding therefore i think that issue is still in play in this case and have jurisdiction over that issue i believe so your honor the speculation for clear evidence and so this was a legally erroneous decision on the adverse credibility and therefore i believe that is a legal issue that would make every question of fact arguably a legal question if you say well that's  wrong decision what makes this uniquely legal question why isn't that a factual determination i believe because here it was it wasn't just a weighing of evidence issue the judge was actually the erroneous in  speculation or erroneous in in the factual conclusions drawn but i'm still much sure what the legal defect is you can say well it's a wrong decision so that's defective but if it's a factual decision and i worry what testimony re evaluate the evidence and they would be the appropriate agency to make that determination or make this the last time but what makes it a question of all where the real i d act restores are jurisdiction for questions of law and you're basically saying well they should be revisiting this determination of fact sort of question of law and you know i again i would i would just argue on this point you know an opportunity to bri filing a complaint about a month after this death and he and his mom were both arrested he was in custody in police custody and and beaten and tortured for a few days during that time on account of this of filiation talking millions of people i understand that there were millions of people involved in the movement are affiliated with families who are very active in this movement so i do think that if you look at the country conditions evidence and miss seeing and the fact that he about sixty five percent of the population interestingly about sixty five percent of the as this court knows and i'm sure judge roth you know from the third circuit a lot of the claims that we get from india are sixty five or  actually eight percent of the claims that we get from india are people claiming to be sikhs who are persecuted because of imputed political opinions or political opinion this case is no different than a lot of the cases they're usually decided on a immigration judge cite one substantial factor that goes to the heart of the answer claim and it is beyond dispute that the the issue here is whether mr saying was persecuted on account of his singh was saying that his father was died the day before the day well the psyche day is not a single day it's a festival as the immigration judge noted it was held that year because it was the three hundred year anniversary man there is evidence in the record he submitted a membership letter i know that it's not a membership card that the father had throughout the years it was a letter that he got from his mother for this litigation the say you know mother can you please get someone to get a letter about their membership in a colleague man and i'd like to know that this letter says absolutely nothing about his father being killed is that the father was a member of a bridge in which we do know that he was found on april nineteenth under a local bridge between we don't know as i said who did it other than by mr sayings testimony mr saying himself he said he wasn't there the the fathe jailed and may on account of his father's activities they don't want him to report the father's death well we have no idea the immigration judge had absolutely no idea why he was prosecuted  requiring cooperation with choirs more than it could be because the immigration judge found him less than candid or the immigration judge just didn't know what to believe and if you love her speculation really seem to be  unfounded like well he says he's responsible for supporting the family why isn't he supporting the family he says he's responsible for supporting the family why isn't this just you're supporting the family well i think for her to assume and eight entirely different culture that the sister would have an equal responsibility is the port the family as the brother does i don't see any basis for that i think that's a fair assessment the immigration gender gap or his bringing up the gender issue and he made it he made a point to say his mother and he were both the rest of the mother was arrested or released on that day without paying a br was arrested he says he was tortured and that he was detained for three days well because both arrests were because legibly the police didn't want him and his mother to report the incident  apparently to them the question is well what makes him so different than the mother or the sister of the sisters weren't arrested at all the mother was arrested but she was released after a day he didn't put up any resistance if you they assume that young men are terrorists well that's not the basis of your claim claim was that they arrested you know stares very young men most terrorists are young men but that's not the claim here we go a colleague down man is actually one of the  big day it was a three hundredth anniversary you know and your holiday you should know you say you go and you go to church when you are in your hometown three times a week when you are in delhi you went to church three or excuse me three times a week when the united states you went three times a week you should know the specifics surrounding your father's death and i think that was one of the things the immigration note the lack of specificity when it came to issues that were outside of the asylum claim outside of the asylum application new jurisdiction over the asylum claim you heard the petitioner argue that at the time the opening brief was filed the riyadh real i d act had not been passed to give us jurisdiction over a question of law country we actually don't even know if he really is really as you say answered someone named sutton and saying as opposed to it paul saying but we have nothing that says when he came in we don't even have a fraudulent passport to say that he came  it when he came into the country you can't even say that you entered at a certain time because we don't even know who you are you have no proof you got things from your mother you got no by certificate or anything you know once again i would argue that the claim was only the combination of factors cited by the immigration judge was deficient for the adverse credibility finding thus in this court were to conclude that even one of the immigration judge's findings is not supported by substantial evidence evidence from the remain and to the board doesn't seem to logically follow from what they said they said is that some of the deficiencies standing alone would be insufficient that's not the same as saying that other insufficiencies would not suggesting that each of the discrepancies could have supported the adverse credibility finding in there the board affirmed without opinion so this court looked at the eye j s decision and because it wasn't a cumulative analysis this case is a potentially different from when so to how the board might then reconsider the credibility analysis i'd also just like to point out that the government talks about some of the emissions and some of the documents but  about how emissions and documents is not sufficient to support an adverse credibility finding the judge can't speculate about what a an official death certificate for example might look like whether or not an indian death certificate would include the cause of death and so because there was nothing in the record about what it does certificate might include the fact that it omitted that fact should not be sufficient and is not substantial evidence to support the adverse credibility finding and i'd also just like to