the denial of asylum withholding of removal and to remain in the case to the board for consideration of asylum in the exercise of discretion in the alternative the board does have the ability to grant withholding of removal which is a mandatory form of relief and we would ask the court to consider that as well the case is a deferment without opinions of the entire decision comes from the immigration judge the immigration judge's decision was erroneous and three regards number one they found that there was no nexus between past persecution that my client suffered that he strongly implied was passed persecution at least what happened to him and the fear that he had if you free found no nexus between those and imputed political opinion the nexus set the reason for persecution and the thing that you claim this imputed political opinion is one central reason for the persecution to brenner morrow keen and other cases have stood for the proposition marking case that even in the gomez rivera case was a government heavily sides those are merely gang recruitment cases where a gang recruits anyone of a certain age or that could be useful to them this is a situation where my client was immigration judge your honor but it's not supported by substantial evidence in the record but if we start from the fact that you know i can explain it if you start on page one hundred and sixty three of the record where he talks about the kind of injuries he suffered because it was such a brutal  i would say quasi torture a city has long standing effects in the individual hearing itself your honor they stop the record at least three times i think maybe four times to allow him to vomit he has constant headache sensitivity to light n dizziness even at the end on the record that immigration judge advise him to get medical treatment and talk to cab then counsel about getting that in this case this isn't nearly as the government would have it well refusing to join a police because he didn't show up so his wife the gang leaders wife recognized him they gang leader came by a house identified this as the reason for the for why he was going to go get him the gang leader surround him with ten  people and apply this brutal beating citing and the fact that he led the police to his house the gang leader later after he tried to move his wife to safety threatened his wife and he also threatened his father to kill him obvious what happened here he cooperated with the police because it was his duty to do so acting to try to control i can remember again number one and to exact revenge even if there were a personal beef as the i j a called it a  show that it's only the reason matter v t s proving the actual reason may be impossible and the applicant is not obligated to show conclusively why this is what does the record show in the record shows that it's what he did working with the police in guatemala against this person and that caused him to be persecuted everything that happened in this case runners happen was an eleven month period it started in january two thousand and eleven by the end of the year he was out of the country three the adjudicator must consider other factors not just physically move but you know what he faces other serious harm is there any civil strife or administrative economic or judicial infrastructure and other things such as including health this is an immigration judge who identified on the record that my client had a very serious health issue and yet when he analyzed relocation no mention of it was made at all including any of these other factors just always seems like he could move it's not just a physical or financial they can i move but further evidence is that his wife did moved and was still threatened by the same person also the country reports and i would just have to give you a the unable or unwilling to control we have to show that there's a complete helplessness yes and again hernandez case mention of our got it he can show there because this statistics again government your honor with all due respect when he was executing their duties of what caused him to be in trouble he would know by working with the police better than anybody whether the police could protect him the police were there when they serve the papers but it had to be no small bit was like that nothing was done but even if you can say that it's a relevant inquiry that one should go to the police it's only one relevant inquiry what actually happened when the wife moved d and what actually happened as the document in the country reports and the citations are in the brief will have to leave it at that there is this isn't just a mere allegation that the government can't do it it's a well known fact and the government offered no evidence of change country conditions other than trying to frame the you can move to another part of the country has changed and british is a separate inquiry and i'm happy to answer questions i'd like to rese does not mean that even if we do have a true somehow narco state every street does not inherently become a political actor simply because some members money want to be involved politics but then we don't have any evidence the entire gang of pain in the entire narco perceived imputed resistance in arca state in support of the current government structure does pick seventeen and eighteen in my brief it's not the st time we talk about relocation because the burner the burden proof if you will the judge has to make a finding and follow the regulation and the regulation is cited in our brief we talk about that very clearly and i think so the judge has a requirement to consider things like health it's not it's not like a new idea that we came up with to ninety four the president was quoted as saying that drug traffickers have us cornered and that zetas were preparing to take control of the country to ninety three to ninety six united states like michigan refugees indicates that the state had lost territorial control organized crime