provide specific examples of violence against nonKazak nationals. Finally, the expert states in her
affidavit that “[I]f the Jourbin[as] were returned
to
Kazakhstan,
severe
they
hardship
in
would
the
almost
form
certainly
of
denial
of
face
their
right to a nationality.” R. at 100.
The
BIA
Petitioners’
failed
to
arguments
Kazakhstan
amount
nationals
and
revocation
of
to
that
any
of
the
conditions
in
persecution
that
their
address
the
for
Kazak
citizenship
non-Kazak
government’s
now
placed
them
within a group that is routinely persecuted. The
failure to consider the central argument in the
Petitioners’ motion to reopen constitutes an abuse
of discretion and should be reversed.
B. The BIA failed to address the Petitioners’
central prima facie asylum claim
To
refugee,
obtain
which
asylum,
an
means
that
35
applicant
he
or
must
she
be
must
a
be
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