II. STATEMENT OF THE ISSUES (1) Whether the BIA’s denial of Petitioners’ Motion to Reopen constitutes an abuse of discretion when it failed to consider: a. Whether the revocation citizenship, Kazak of government’s the coupled Petitioners’ with recent Kazak Kazakhstan’s demonstrated persecution of denationalized individuals, constitutes a change of country conditions for the purposes of a motion to reopen pursuant to 8 U.S.C. § 1229a(c)(7)(C)(ii); b. Whether revocation of citizenship and fear of future persecution based on non-Kazak nationality prima facie is a sufficient eligibility withholding of removal. 10 for proffer of asylum or