Petitioners provided substantial evidentiary support. VI. ARGUMENT A. The BIA abused its discretion in its legally flawed and myopic treatment of Petitioners’ change of country conditions argument 1. The standard of review for a Motion to Reopen is abuse of discretion This Court reviews the BIA’s denial of a Motion to Reopen for abuse of discretion. Kaur v. BIA, 413 F.3d 232 (2d Cir. 2005); Zhao v. DOJ, 265 F.3d 83 (2d Cir. 2001). An abuse of discretion: may be found in those circumstances where the Board’s decision provides no rational explanation, inexplicably departs from established policies, is devoid of any reasoning, or contains only summary or conclusory statements; that is to say, where the Board has acted in an arbitrary or capricious manner. Zhao, 265 F.3d at 93. The Supreme Court has held that the “arbitrary and capricious” standard is narrow, and that a court is not to substitute its judgment for that of the agency. Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 19

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