good morning your honor has been a sharp crystal helicon i think the main issue in this case is clearly the credibility determination that i j i cited a number of grounds and i think the most logical thing to do is to sort of divide them corroborative letter that this claim that that claim persecution had occurred there's nothing in that there's nothing in the record to indicate that that this particular party member had any personal knowledge of the extent and manner to which in which might my plan was persecuted and even if there were such evidence in the record there are plenty of understandable reasons that the that he wouldn't want to include them in there something i mean including information like that in a letter it would be t amount to accuse the government of persecution and if something like that fell into the wrong hands which i don't think is very unlikely scenario that individual self would find himself in great danger so i think for a variety of reasons the i j a erred and faulting  in holding against my client that persecution wasn't mentioned in that corroborative letter another instance had to do with my client's testimony that he did basically rested for a couple of days after being arrested and tortured in two thousand  about how a person in that situation would act and i think it's unwarranted because if you take a guy like my client he's been he's had numerous run ins with the police he's been tortured numerous times i think i think it's is just as reasonable to for him to do what he did which is to basically go home lie low a couple of days and figure out a way to get out of town as opposed to seeking external medical condition and there wasn't any evidence in the records indicate that he had that he hadn't sought any kind of home his national i his national id card with him but once again i think that's i'm going to speculation that my client had somehow managed to procure a false passport with which he managed to leave pakistan and i think having done that and having basically secured the manner in which he felt he could leave undetected it's understand it was understandable prince at least have some evidence on him of his actual identity of his true identity to present once he once he left the country and come to seek asylum so i think that's it he never he never relied on the false identity that he the false passport he used to invade pakistan once he came to this country he was forthright about his identity once he was here another category  another category the grounds on which my claim was found to be incredible were basically alleged inconsistency between this testimony and not other parts of his testimony or testimony from other people but the general background information in the record in the form of government reports one notable instance of that was had to do with my client's testimony that in two thousand part of his being arrested in two thousand several months before that that  that the police came to his home and beat him up in front of his wife and told him to cease political activity the i actually felt that this was inconsistent with the background information because the background information i just didn't explicitly state that that these kind of preemptive house calls were being paid by the government or by the police but i just i don't think that's borne out by the record i think there's a state department record in there which indicated that that in two thousand there were prevented it that the government with that information that's that someone came to his home and beat him up and at that and at that time didn't actually detain him i think that's i think the conduct that's just described the state department report is far more beyond the pale than what he within what my client i don't think there's any inconsistency there another alleged inconsistency between my client's testimony and and the record i think you with the i think interpretation of a portion of my client party members in the area which he fled the province of good drugs were actually in hiding and so i think there is just a mis mistreating of the testimony by the i j and at any rate i don't think it's particularly inconsistent with the information we have in the record which which indicated that in march of two thousand there was an ordinance passed that basically banned all outdoor political gatherings and i think i think when you're faced with a situation in which you can a political party may not assemble at out of doors without breaking the law you can certainly say that they've been driven underground and possibly in hiding there's nothing to directly contradict what he said there another other main class of alleged inconsistency had to do with my client's political knowledge there were basically three three alleged three three events cited or whatever first of all there is my client's assertion that there had been martial law in one thousand nine hundred three the i just said that there is nothing in the record inconsistent with the record but i think if you look at the record it indicates that in april of that year the president of the country dissolve the parliament dissolve the assembly and dismissed the dismissed the prime minister and that elections weren't held  for another six months so i think given a situation in which basically there is no legislature and for much of those six months no prime minister the workers are clear as to whether there was technically martial law in the sense of suspension of civil authority but i think it's part might mike my client's description of the situation was probably reflective of at least the mood in pakistan at that time for much of that year also the i j a found that my client didn't know what type of government existed in pakistan in one thousand nine hundred two this precise testimony on that issue is basically what type of government was there she said oh i don't exactly remember and i think that that's actually an understandable answer it was the year before he became a member of the pakistan people's party and we're talking about a country in which there was a great deal of political turmoil at that time there's a timeline i think around page twenty three of the administrative record showing that turmoil given time given that there was a coalition government at the time and not a monolithic government and given that it was before my client was even a member of the pakistan people's party and was basically about twenty two years old i don't think that that that alleged lack of knowledge or precise knowledge should be held against required going to assuming that my client's testifying credibly whether he could internally relocate and i think that's that's an issue that would probably you would if you're stealing my client's touched testimony is credible i don't know if you bother to assess internal relocation if asylum application that's the next case sorry they are i'm sorry leave the argument what is the next case every all the facts are just summarized are this case in this case the immigration judge correctly made a credibility finding based on is that there be some evidence to support the decision and that more importantly the petitioner bears the burden of showing that the record compels a contrary conclusion and in this case the record simply does not compel a conclusion contrary to the immigration judge from pakistan in other words just sorry all he had carried was a phony id and not a real i d that would have been evidence of actual credibility it would have landed some rossley to a story in that if he was afraid of flee with his own identification he didn't present as he didn't have his own passport rather he and his father obtained a false passport a false passport he used that to get out of the country that he felt was persecuting him and from that point on used his authentic couldn't if the cation but but that is that first up that's very important here are he said he claimed he needed to get out of the country or he believed that he needed to get out of the country the real problem is when he gets searched if the subject of the scrutiny claims to be they find the other implication he's caught now that is just one of the immigration judges findings there are several others that the bear a little bit have been caught using the false id it could have been t list that his testimony was inconsistent with the state department report and quite frankly i've read both and i don't understand that finding maybe you can help us there well they're the immigration judge just position door to door and tell folks they cannot join political parties in fact a state department report explains why the opposite political parties were still entitle to exist albeit the government in march two thousand and put limitations on public gatherings us believe therefore we're not conduct pieces that is you know it's a little bit more subtle than that your honor it's more that he wants he wanted the immigration judge to believe that the pakistanis that the pakistani government was intent that he not be a member of a party was just you know actively telling him he can't be a member of the party when what the state department the climate the state department reveals is quite the contrary that political parties were still allowed to exist that membership in political parties would still allowed to exist although was limited at that point were public gatherings there's not one country reports say that the government arrested individuals to prevent them from ending specific opposition political rallies that is correct your honor and that's the point that i'm making which is the government acted against put more against political gatherings than actual party membership so that was the immigration judges basis addition to that basis there are several other problems that are in the record that are contradictions that do lend credence to the immigration judge as credibility thought in your opinion is the strongest grounds for determining adverse credibility well there are at least three strong grounds that asked for your strong so you have certainly on the strongest goes to the story that mr khan would like to have the court believe and indeed as counsel brought up that the police were intent on with the party and that is the record evidence not one thousand nine hundred three that's when he may have joined b p but his active interest began in one nine hundred ninety one nine hundred eighty nine but when it came to bringing up certain bits of information that somebody who was acutely interested in poorly on your knowledge of the political system yes you are as i said i'm not an expert and you're proving the point that i'm not an expert in the politics of the united states if i said i were an expert in state politics was going on in one thousand nine hundred he should have known what the government was like in one thousand nine hundred two he should have known who the political pawn would have been in the campaigns he was involved in these are things he should know based on his experience and the he claims calculating who of martin van buren might have been or not polk was later is a little bit of a different circumstance that's more based on your your prior study than your your personal experience and that's the big difference here when mr conne was not subject to some random examination of the breath of his knowledge he was sort of inquired about his actual experiences and the things he should have known if he had the experience that he was in power in one thousand nine hundred two he said i don't remember exactly they were doing follow up questions after that that's that's certainly i don't remember exactly certainly doesn't equate to total ignorance and you know there was a close in government at the time i don't think that was an unreasonable answer  specially in the light in light of the lack of a follow up question for as for who is the opponent who's the some people's party opponent in one thousand nine hundred nine my client said that he believed it was part it was he said he was asked what party approached him which was actually a kind of incorrectly frame that question the first place because it's actually a coalition of parties called i think islami term where it's tied and my client can answer that question said he thought it was a party call them with its had and