reopen i believe the board has abused discretion in failing to reopen the case the evidence which was submitted in this case is quite substantial and it's not only in one area there were three expert affidavits in support of the petitioners motion to reopen there was substantial documentary evidence including evidence of converts to the motion to reopen contains evidence of new state department reports and there is a qualitative difference in that the threat of mental and physical abuse by their families and government officials and at times community members is different than what was stated in the prior reports that were done the latest i think was two thousand  and two in the case so how do they for example apply to this particular petition they for example talk about honor killings well that's this entirely respected women this is a man a woman earlier on revealing the names of relatives honor killings don't only apply to women the in fact as i noted in the briefing there's a first circuit case that discuss that issue but decision says that the evidence that they're denying is substantially similar to the evidence that this court tonight before but this court denied in substantial evidence standard the board wasn't supposed to be reviewing this evidence under a substantial evidence standard that's number one and it's substantially different in that from two thousand and two until when this motion was filed there's been tremendous changes in the middle east and there is evidence in the record from one of the experts who notes that christians have been killed converts have been killed we didn't have that evidence per se that the way that the way we're supposed to judge these things just cherry pick examples of the horrendous admittedly horrendous things that have happened to converts can you cherry pick that from newspapers and other things and then say this is what's going to happen to my client is that what the standard is well your honor i don't think we're cherry picking per se when well that may be the wrong term of the reality is what what i see is you've taken incidences that have been reported in newspapers and magazines and said look at this this and it is awful i like ranch all of that but i fail to see how that ties to your particular client situation it's been ten years since the early case roughly and you're saying you've got to reopen this because things have changed and my question is as to your client how have things changed what is new here that was not known before maybe the volume maybe different countries but the reality is you've shown nothing about what the state of jordan the kingdom of jordan has done indeed they've been pretty good in trying to protect people who are a pos dates from the islamic religion i just don't see anything new to help me with that what am i missing but you in your answers  at times tells families that people have converted which increases which increases or gets those family members to undertake these killings and there is a letter from the responding to news that's in the record who recently was in jordan i think that that is a new letter it's new evidence and she says knowing the conservative religious nature of the family she can assume that there will be adverse consequences for the petitioner if he returns to jordan and she doesn't see why members of the family will not harm him physically assault him but it's all conjecture again when you answer these questions years saying that something's going to happen with the acquiescence of the government and years well they took off the family is that it the government will tip off the family and i quote from the wreck from the record i don't think the family already knows i think that the family knows it but when he arrives in the morning what she's confirming based on her recent visit to jordan is that she believes that this is in issue that's going to happen ok so i think we're all struggling with there are incidents in the record  they could be subjected to danger on the streets the question is do the authorities tolerate do they acquiesced in it so that's what i did that was the second prong well there  he decided it is so i'm trying to get to the focus on ok so there's a case that's in the record at page two sixty seventy two seventy of a gentleman named mohammad of god who was talk in circles which we need some specifics doesn't really apply here we don't know the facts of the case we don't know why these other folks were well off we have instances in our court system where the government simply hasn't proven its case and we torture in jordan because he converted to islam from christianity one nine hundred ninety and also because he made it known to u s officials that his family had criminal involvement in his criminal conviction for conspiracy  was nonetheless just no clear probability of torture by with the acquiescence of the jordanian government and that wasn't a substantial evidence standard to review a petition stated the standard review in this case is more strict actually it's abuse of discretion them and you'll see it's certainly an arbitrary precision because nothing has materially changed in jordan since the prior two thousand and one proceedings first some of these documents don't pertain to someone simply situated to petition is noted somewhat petitioners argument that some pertain to the country of syria which of course is not relevant to this jordan petition or some pertain to honor killings of women and others pertain to anti regime protests in the wake of the arab spring one of these are centrally relevant to this petition for review just our focus is on are these three expert reports and if we go through them we're going to see that nothing would really change the fact issue the courts to not have authority to impose criminal punishment or criminal sentencing and you're also going to see that the jordanian government has not acquiesced when it has been of use of converts is your point that insofar as action if the families are those law makes or courts impose torture it's the issues that could be an issue however there's no tortured level pain and suffering on this man and if he goes back is there evidence that the journey and thirty's will a is let's suppose is quite clear that this person went back well suppose it was a woman would go back and they would they wouldn't killer but they would  needed also by petitioner joining tori's arrested the father that committed the army they are killing in that case and when you say council that there's no evidence in the record that the government will acquiesce to that you're talking about about the leaves took his report however his father then went to shari'a court to get family law judgments at that point he fled the country so anything that article in the end that article knows the past is not a criminal offense even in that article he filed a police report the police took his report there is and we go through this over and over again for the documents to see whether there has been place protections sought the police have taken reports in provided protection there's a two thousand  do in jordan and even that instance he finds he saw police protection and state police protected and hidden from this family and this is not dissimilar from what was before this court and immigration of two thousand and one ram air excuse me while other arab countries do not enjoy the protection of their government for christians we jordan christians do have the protection of our government and nothing has changed killing a woman or the father was arrested afterwards and there was another example where the petitioner was again taken to family law had his family job judgments imposed upon him and he was threatened by his family but there's no nothing in that evidence what is produced does not show that the jordanian government acquiesces and basically going after people who have apostatized boss aside from islam him reiterating his conversion would not be helpful i think it would not be helpful to him i wanted to no e that professor goodbye who is of israeli background had noted that it's more likely than i thought mr abbott failing would face a criminal conviction for his religious conversion sentenced to prison where he would face severe physical abuse and torture in the jordanian prison system now addressing council's argument that counsel i'm afraid you're out of time  we thank you for your argument and the case just like you to submit it ok thank you very much