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In the Matter of Emmanuel Ako Tabi, A-File No. Pending - Brief in Support of Application for Asylum, Withholding of Removal, and Protection Under the Convention Against Torture
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Table of Contents
Introduction & Summary of Claim
Statement of Facts
Protected Ground
Past Persecution
Well-Founded Fear of Future Persecution
Nexus (One Central Reason)
Government Action or Inaction
No Reasonable Internal Relocation
Country Conditions
Credibility & Corroboration
One-Year Filing Deadline
Conclusion & Relief Requested
Index of Exhibits
In the Matter of Emmanuel Ako Tabi, A-File No. Pending - Brief in Support of Application for Asylum, Withholding of Removal, and Protection Under the Convention Against Torture
Applicant Emmanuel Ako Tabi, a native and citizen of Cameroon from the Southwest Region, respectfully submits this brief in support of his application for asylum, withholding of removal, and protection under the Convention Against Torture. As an Anglophone Cameroonian who openly opposed the marginalization of the English-speaking regions, Applicant fears persecution on account of his political opinion and membership in a particular social group arising out of the ongoing Anglophone crisis. The claim is grounded in INA 208 and 241(b)(3), 8 U.S.C. 1158 and 1231(b)(3), and the regulatory standards set out at 8 CFR 1208.13 and 1208.16. The record establishes past persecution, a well-founded fear of future persecution, and a clear nexus between the harm suffered and a protected ground.
Index of Exhibits (5)
test-prior-marriage-termination.txt
Divorce decree establishing termination of any prior marriage and applicant's
test-marriage-certificate.txt
Marriage certificate evidencing the legal formation of marriage between applicant and
test-bona-fide-marriage-evidence.txt
Photographs of applicant and spouse together corroborating the existence of a genuine,
test-i864-affidavit-of-support.txt
Form I-864 establishing that the sponsor meets the income requirement for the
test-country-conditions-cameroon.txt
Country conditions report documenting the Anglophone crisis in the Southwest Region
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Response to Request for Evidence, EB-1A
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Drafting the RFE Response
Reframing under Kazarian, citing 8 CFR 204.5(h)(3), tying each criterion to the record.
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