they are no longer nationals of Kazakhstan. See
Norani, 451 F.3d 292 (finding that the BIA abused
its discretion in denying a motion to reopen for
failing
to
account
for
the
substantial
record
evidence).
a. Revoking citizenship on pretextual
grounds must be addressed
The Petitioners argued that the revocation of
their citizenship was based on protected grounds
(their ethnicity and religion). The reasons given
by the Kazak government in its revocation letter
reference
(i.e.
when
only
that
routine
citizenship
citizens
fail
to
administrative
is
procedures
automatically
register
with
revoked
the
Kazak
consulate within five years of residency abroad).
The
Petitioners
provided
substantial
support
for their contention that the revocation of their
citizenship was pretextual and discriminatory. R.
at 99-134. The Petitioners presented an affidavit
from
Maureen
Statelessness
Lynch,
the
Senior
Initiatives
29
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at
for
Refugees
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