F.3d at 115 (The BIA erred in failing to consider other forms of persecution). VII. CONCLUSION For motion the to foregoing reopen reasons, removal the Petitioners’ proceedings should be granted and the Petitioners should be allowed to file an application for asylum, withholding of removal, and relief under the Convention Against Torture with the Immigration Court. Respectfully submitted, _________________________ C. Mario Russell Attorney for Petitioner Jodi Ziesemer BIA-Accredited Representative New York Law School student Dated: August 1, 2011 41