engage in the central question of whether an overt act of persecution can constitute a change in country conditions on which a motion to reopen may be based. The BIA’s cursory and dismissive treatment of this issue is a flagrant abuse of its discretion given the gravity current thinking has brought to citizenship the and analysis the Seventh of revocation Circuit’s of recent criticism of the BIA on this very issue. Haile, 591 F.3d at 574. 3. The BIA provided no reasoning or analysis of Petitioners’ argument that Kazakhstan revoked their citizenship on pretexual grounds and that non-Kazak nationals are regularly persecuted The BIA’s denial of the Petitioner’s motion to reopen is two paragraphs in length and contains only one sentence regarding the central claim that conditions in Kazakhstan have materially changed: The evidence proffered with the respondents’ present motion indicating that they are no longer considered citizens of Kazkhstan because they failed to register with the Consulate as required by law does not reflect changed country 27

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