should he return be ordered to return to brazil there's a substantial likelihood he will be attacked and tortured by the drug macedo lived for four years after this incident in some place not terribly far away from where the a drug lord was right this goes to the issue of internal relocation your honor i am prepared to address that issue i would say just very briefly to respond to your question it's clear from the record that mr sedo returns to brazil after three years after he resigned after the first attack by all of era and he lives he hides out he's hiding out living on a small farm out of the city for twelve to fifteen months that's his testimony he then  together with a few of his associates friends in going on you went to a nightclub and on the very night that he went into that nightclub for the first essentially for the first time he was that went back into going on that that's where he encountered the drug lord and that there well he was on the outskirts and that he also could live elsewhere for away from going on would make exhibit eighteen and page three forty three you will find that he did an extensive review of all of the many of the facts and documents in this case the police incident reports the medical records and so on anything on that at page three eighty seven that you say that his life would not be protected by moving to another part of brazil particularly as the admin you're referring to the administrative record to the ministry record in this rather large country for his ill and this is evidenced by the fact that he was attacked and i club in the very town where this little thing started we always keep going back to the only evidence he could relocate seems to be related to them right well i would respectfully disagree with with that point your honor that what we need the evidence and i you know like the evidence evidence of all the evidence is  you know if it's in a state or had been rio and the attack occurred then you know we wouldn't we wouldn't be asking this question because it would be completely apparent that internal relocation would be impossible or reasonably  to my question no no the answer to your question is is is yes he did offer substantial evidence the you see the the fact of the matter is that the drug lords in brazil are the fourth power of the country after the legislative judicial and executive branches that's not in dispute i don't think there's any dispute about that there their influence is pervasive inside the jails outside in small towns and large towns there are networks that run rampant through the entire country not only up to the borders of the country but beyond the borders for example in bolivia into bolivia and other states and south  level or was responsible for putting into jail and prison in one of the highest ranking members of the italian mafia what would that it given this italy with that individual be saved if this occurred in say rome and he decided that well move to a milan and hopefully i'll be safe there because the influence has doesn't doesn't extend to that would be factor specific to the case but the question both of my colleagues have asked you and you seem to be struggling with a bit you understand we don't confer on the merits before we take the bench i do not like and one unlike other courts you now have all three of us asking the same question the i j a noted that when he went back to brazil he lived in a rural area and until he went to the nightclub in the very city were this drug lord operates principly  left i'm going to kill you i think that when you combined they say i can find you anywhere well i don't think that he i think you certainly can imply that is the case because located if you look at that at the various exhibits that i have attached here their apartment estate outlines there are country condition reports there are letters from the chief of a declaration from the chief of police who  says this if you're not safe in this country you have to leave those but let me get back to this one point before before i can arc me point here on this deferred cat is that that is not what's required all that is required is a willful blindness and and that's exactly what happened here that the immigration judge specifically asked in a in a tie the events in brazil to an enumerated ground and that he was not did not establish his eligibility for cat protection based on an absence of government acquiescence and the fact that petitioner could relocate within the country the cause of their unwillingness or inability to oppose a thank you your honor the government of brazil did not show willful blindness in this case while the chief of police did say to petitioner that they did not have the resources to provide him protection essentially affirmative protection a security detail the police did intervene when petitioner was in fact attacked by the drug dealer and stopped the fight so it's not a question of the government being government i couldn't that be deemed acquiescence it wasn't is it conceivable in this country that if a local police officer participated in the arrest of a major drug lord was later attacked by that drug lord and hospitalized that any long course in an agency anywhere in the united states would not offer him protection until the threat dissipated with the with that united states hypothetically gone or i don't know if it's a direct corollary with the situation in brazil the indication to given the petitioner was that they lacked the resources to afford him they predict a protective detail but as far as whether that constitutes a situation that rises to the level of willful willful blindness i believe it would depend upon the natures of the unwillingness as far as the allocation of resources for for purposes of satisfying that question the state department reports reveal that witnesses and a criminal case specifically a murder that involved two mayors as suspects in the commission of the crime did receive protection so it appears individual chief of police that there would have been protection i don't have i don't believe the record is sufficient to answer that question on it however that's not the question that was presented to the agency but isn't isn't one of the problems here is that they were trying to develop a record that basically shown that there was no corruption within the police department and that some of these so called lack of resources were a result of the whole structural situation  police department and i jason and i can't even go there so isn't one of the problems as they were even permitted to develop the kind of record you would need to address this precise issue you know your own or the state department reports reveal that while there were localized incidents where crime and corruption was a significant problem in local governments such as i believe the situation in cell paulo where there was a problem with with corruption and one of the other cities it did not the state department reports do not indicate that it is a generalized or pervasive problem is especially to the extent the petitioner presents and the record does not compel a country conclusion to the immigration judges finding it's not that that didn't answer my question i didn't ask that state department i asked about evidence that the petitioner was trying to get in about the local situation in which he wasn't permitted to get in because as the i j a said while that's not relevant to ca did testify that there were several honest police officers also in his police department and based on his present based on that representation it does not appear that corruption was sufficiently pervasive to where it would inhibit the government's ability to protect questioning off saying this doesn't have any relevance to cast so why why doesn't if the issue is whether then there aren't able to provide protection why isn't it relevant as to what is the situation in that locale it falls under your honor the immigration judges conclusion that petitioner could relocate and effected so safely for four years in brazil before returning to the area where he encountered the drug dealer in the first place position or whether there is a local corruption problem in the area where petitioner was targeted so ceases to be relevant when it becomes apparent the petitioner could relocate away from that area and remain safe for purposes of analysis under cat that was the essence of the immigration judges finding on the cat question apart from the fact that the government did not acquiesce petitioner did not establish that he could not relocate and remain safe again the question is why it's the government's evidence on this point relevant and in the petitioners  petitioners the evidence goes to the specific locale and has not addressed the concern of his ability to relocate your honor the government's evidence bears on the general the more general conditions that wouldn't answer the question of his ability to relocate and support petitioners own testimony that he was that he was safe when he stayed outside the area where he had encountered the drug dealer originally and as far as the record does not compel a contrary conclusion especially in light of admissions regarding his safety in brazil prior to the incident in the nightclub and regarding petitioners withholding klein the immigration judge found that he did not tie it to a protected ground and the record does not compel a contrary result it's missioners testimony and his declaration in the record revealed that the drug dealer's motivation was because of the death of the drug dealers wife coming to visit him after petitioner arrested him and  the subsequent death of one of his colleagues there it is evident from the record that drug dealers motivation in that regard was personal in nature and a private without any attachment to a government without any attachment to the government does not rise to the level of persecution and is certainly not tied to any regret on the issue of military to relocate the petitioner did offer evidence including affidavits about the general level of corruption countrywide in the influence of drug lords yes sure he did did the government rebut that evidence in any way the did it present any contrary evidence to the state department reports your honor other than that i do not recall any for any other country evidence from the record however to an extent petitioners on testimony does contradict the assertions in the documents he submitted based on his apparent safety subject to any further questions from the court that concludes that no further questions thank you counselor case just argued will be submitted for decision