i mean who is who i am we have mohammed but i've got a tough mountain to climb because this court has in the past ruled that m p un is a terrorist organisation and there have been plenty of cases to that effect  were arguing that in her circumstances mr butt is within the exceptions and because he was the he is within the exceptions his have that he is within this group and they also found his testimony being credible as through garden testimony st i want to state that his testimony at all times was coherent and identical the minor difference is that both the immigration judge in the board found relied on were exceptionally minor in this court has ruled in other cases that minor testimony happening twenty years after these acts are not unusual given people's memories given ideas and whatnot so maybe you should focus so as you know immigration judge had credibility problem and looking at pages fifteen and sixteen of the judge's opinion and the judge is saying in light of the extensive history of violence and terrorism undertaken by m q i may the court finds responded to very least should have known that engaged in terrorist activities and ticks off a bunch of things his rank what he was doing his recruiting activities sent him over sleazy raises money in new york and chicago and so on and the immigration just doesn't isn't that enough to defeat you or your lack of knowledge argument well the fact is that mr butt for his number of years being involved was out of the country for many of those years in which the but when he did go back to iran or if i may lead that in part of that time he was in hiding he was afraid of what might happen to him he he joined in eighty eight and when he joined nineteen one hundred and eighty eight dollars all he did and i'm saying all he did his particular activity was related to labor matter is he one to make sure that workers within that country were accorded status of individuals instead of and then wanted them to get a fair shake in what they did and therefore he was not involved in anything when he did leave the country and that's at that time and i'm looking at the may that was founded and ninety s you're correct that he did go back to the country but when he did return of the country we would argue that because of his activities as it turned out because of his banking activities and others in the threats that he had forced  it was directed against him particularly and all of his activities were directed in one direction only and that's towards the workers well you know the other another point the immigration judge makes is that his would require us to assign greater credibility to mr about judge was willing to well if i recall correctly this court has ruled that asylum applicants generally the focus that they have and what happens he was represented previously by some outstanding attorneys and i'm sure that they went through with him make sure that everything that he did was coherent and while i know that the is that individuals in the situation finally when they've got competent counsel do at least come forward in advice and i want to relate on that i believe in reading through the decisions that when he did have that his counsel was very very competent nd found around i don't know what happed the st time around but the nd time around exceptionally confident and i would place a lot of weight on that particular counsel in the work that he did th was we were doing to novo review maybe we could do that but we're not right seriously i agree with you but in this particular situation because he was coherent in what he get originally because of his labor activities and whatnot that's what i to focus on and and the fact is that looking at the history of the m q m looking at how they developed and there we thing like that originally they were an organization that arose because of student admissions universities all of their activities were to give the moon jeers the one particular group a fair shake within pakistan  but we believe that he applies a exception to the terrorist ban because we believe he did not know that he not couldn't not have known reasonably and because he was so focused on what he was doing that was particularly all he was concerned about everything else that happened terms of the government and everything else he was totally uninvolved in that if i may i've got i want reserved two minutes but what i wanted to say was yes he worked but because of his travels i believe that that because of his travels he basically could not have known that he finally knew that something was up and he wouldn't self was threatened that's when he finally left the country to escape he was afraid for his light but prior to that i don't believe you knew anything thank you very much i know you made this boils down to the burden that the petitioner in this court has which is that there are two factual questions whether and i think my counsel has conceded in terms of the material support issue what is it issue here is whether mr butt weasely should have known of the activities of this organization in which he spent is something that bothers me a little bit about these cases tearing one i get to or two of course is also fine you get down to tears three and the definition is extremely broad so i wonder if every we're going to say sion in the world that has ever engage in some kind of violent activity maybe the people in hong kong who have been demonstrating in the streets and there's been no punches thrown in different activity are they supposed to know that the united states it's feels like it might decide that they're not just a group of people who have been gauging some violence but they're actually a terrorist organization  it was left open the reason that reasonably should have known known or recently should have known is exactly for that reason because if you are involved in an organization that is involved in violence or terrorism well that's that's my question really you may know perfectly well that you're involved in the alpha organization you know you attend meetings and you see people and  but do you have to know that the united states thinks that the alpha organization has a two year three terrorist organization or is it enough that you know you're affiliated with the alpha or working with the alpha organization and it's meant to be broad to take into account all different types of groups and all different types of violence and terror terrorism violence and terrorism i mean it's intended to sweep up organizations of every sort or engage in terrorist activity but it does give an out for people who might not have known and can show that they recently did have or didn't it and i'm trying to figure out what they need to know you know because i can't remember where in the briefs the definition is but what i don't remember is that by the time we get to tear three it's just or otherwise to gauge and violent acts and i want to know whether we have designated every organization on the globe that sometimes engages in violent acts that is it's a it's a factual question about whether an organization constitutes a tier three in this case though there was not a question about in exactly the same type of activity so that really wasn't the question and it wasn't also i mean my cancer focuses a very much not on what he did for you know what is going to for the organization that also really doesn't matter because there are a multitude of cases it's say if you are involved in a terrorist organization it doesn't matter if you brought you know food to all of ladies oh you know we have all sorts of case you know that right so so his involvement in the labor winning of this organization qualifies him as engaging in material support of a terrorist organization the only thing that was a question was whether he reasonably should have known that is also a factual question and he has to show to this court that no reasonable that any reasonable person would have been compelled to find you know to reach a different conclusion than the agency reached and he has he not only hasn't done asked for multiple extensions because he was trying to get a labor sort under you know to allow him to work here that was what originally happened he only applied for asylum because the company that he came to work for went for ten years he's an educated person and as the court noted he tried to walk back his involvement but even if he was just involved at a local level he admitted that he read the media reports he also said that  four he was arrested when he went as a representative of the organization he was involved in this panel he was arrested by the cia which was part of the police and he was persecuted by the police because of his involvement in the organization any rational person would have thought well why are the police after me if i was part of this labor division of this organization they would have asked that question he would reasonably should have known th case of willful blindness if that but i believe that the evidence shows he did know and as far as the adverse credibility he also has to convince this court that any reasonable person would have thousand and four application bears no resemblance to to his two thousand and eleven application and whereas in his original application where he talked about being this the i believe believe it was a secretary general of the labor division he completely walks back his his involvement in the organization when he testified putting himself as a very very minor person if the court doesn't have any other questions i would just say that there's substantial evidence both supporting the adverse credibility