it please the court my name is abby from maryland i'm a certified law student and with lauren ellis i represent petitioner's daisy ordinates good boy and her son caleb i'll be presenting the opening argument and my colleague lauren will be presenting the rebuttal which i'd like to reserve three minutes for because i did not applied the circuits precedent stablish in asylum where i petitioner is a politically active member of a large politically active family many of whom have already been persecuted for their political beliefs second the i j a misapplied the law and her analysis about the is a member of the velasquez family because she is perceived as such she and her sin have been a couple for fourteen years and have two children together she is the mother of two blood relatives of the bosco's hamley and she lived in the mandeville ask as her mother in law's home for four years while she was in honduras at two forty two in the record the secretary of the labor party in the case that he views her as a member of the velocity as family and daisy indicates in her asylum application that she is treated by society as a member of council is that belied by some by by other testimony in the record to suggest that the people that came to persecute the family recognized that she was that she was that she was not a blood relative and that she was from a different family and knew who or father was and said that's fine and left her alone well this this occasions she at first i foretold in the record indicates a after gerson c d g and they called the family and said that they said that quote when they least suspected they would kill him and the rest of his family second at five six on the record your son your a close relative of the leader of the figure oh it's said that daisy you particularly and their new family generally were quote on the list to be killed by the figure was and then the third time she was threatened was at twenty seven in the record in the amount of alaska's letter would quote murder my entire family if i do not give up my campaign and then the violence that her family has suffered it has been recognized as part of the persecution just for clarity or you going she suffered previous persecution and therefore there's an assumption that she'll be persecuted are you just saying she should generally she has an expectation of proper persecution in the future both that she has said what's the  by these question and then his mind with respect to the first where's the person the person has the persecution just because you've been threatened with persecution well with i thought the whole idea was used you think there's persecution in the future because you've been persecuted in the past well this court's precedent in machinery indicates that for particular things will lead to a finding of past persecution threats to family harm to family economic harm and psychological harm ok here daisy has suffered all of those there's been harmed her family has four o the members of her family have been killed five has these attempted five different family members have faced attempted assassinations and then five have been forced to flee and then there's been threats to the family generally as previously discussed they also face economic harm as a well to the fig persecution won and gerson daisy's father in law on husband said that they were forced to stay inside and quit their job for weeks because of the persecution of the figure i was and then daisy testified that she faced psychological harm as a result this court found imputed political opinion where the petitioner was a member of a politically active family where the persecutors had previously imputed a political opinion to a similarly situated family member and where the petitioner having been highly visible political activity the i g found sufficient facts to meet the legal requirements of ramirez for us at one eighty eight in the record does it indicate that she was heavily involved in carlos's mayoral campaign that she invited people to and attended campaign meetings and rallies that she cooked food for these events and that she generally helped her she could and at one seventy three in the record she indicates that these are the same activities that edith alaska's her aunt was killed for so if the figure was imputed a political opinion to edith and they must have also done the daisy it is hard to keep all the different family member straight but so the aunt who you mentioned was killed she was not a political candidate herself but rather just a helper on one of the campaign that's correct it indicates that a man to and juan are still heavily involved in honduran politics that in fact amanda is running for the exact same position that so many of them lost as family members were killed for another b i found this letter was merely cumulative but this was both legally an factually incorrect it's legally incorrect because the standard for a while found if you're a future persecution is whether all the evidence few cumulatively tends toward a finding of future persecution never how are they being  persecuted in the letter it indicates that the figure as have been calling amanda and threatening that if she doesn't end her mayoral campaign that they're going to kill her and the rest of their family that she knows that she's at risk of death as a as a result of her campaign involvement but it's also it's standard of you does not require if the court determined that the board's decision wasn't that correct it only requires that the court determined that the decision was reasonable and i would submit that there is substantial evidence supporting the board's  policy of the united states with respect to breaking up a fight then when they've allowed one member of the family to remain well the policy that states will every case is different so just because someone obtains on the silent primitive relief ministry of closure does not automatically mean that  apply for any kind of spousal visa based on her husband because all her husband has as is is is just some is administrative closure as opposed to i do not know the answer that question i do not know yet that question so but do you know why the government is so interested in removing her but not most powerful part of that letter it seems to me is that there is an explicit threat that the mother in law communicates that the figaro said we will kill your entire family if you continue with your political activities and you're not disputing that the petitioner here is in fact a member of that family right you think that we need some more people to get murdered by the figaro's before we will be able to conclude that the threats are credible trip and what kind of policy as you understand well i just there have been a lot of people murdered right at the hands of the figure rose because of their political activities with that that might be the turning general wrong on that point i don't see just because you disagree with it doesn't mean we have to accept that in our decision i don't understand why you're giving us a command ok it's a request so i mean i think the court court can n status in the united states in light of his of his status temporary and undefined is that maybe is there any reason to think that mediation would situation that we would allow the husband to remain in the united states i'll be in some kind of legal limbo and then ship his wife and kids back to honduras i think it strikes me as a very very strange situation right now if you would check on that and get require physical harm for either finding a past persecution or persecution as established in machinery and under merits rebus second the government contends that the violence is the result of a personal vendetta however this court's president also that does not require that does not distinguish between where the violence began whether the violence began as a result of a personal vendetta is not relevant what is critical is whether the subsequent persecution  protected ground here the persecution is on account of the blast his family membership and political opinion and just help me with the imputed political opinion for your your client i know she was active the that one campaign but it seems like the vast majority the evidence relates more just to her membership in the family right and i take it those are two separate grounds that you're kind of pursuing well th is so intertwined with family this is exactly similar to the case in the mere three of us where she is politically active she is a member of a large politically active family she also is included on this death list which suggests that she was this imputed political opinion was imputed to her where are there people who have been physically persecuted who in the family who were not politically active yes your hon the record that the police have been consulted about any of this no you are but these are the figures are the incumbent national parties hitmen these are government actors they act on behalf of the national party and suppress political or the national party is is