TB5-10735

Immigration and Refugee Board of Canada Refugee Appeal Division Commission de l'immigration et du statut de réfugié du Canada Section d'appel des réfugiés RAD File No. / N° de dossier de la SAR : TB5-10735 Private Proceeding / Huis clos Reasons and decision ? Motifs et décision Person(s) who is(are) the subject of the appeal XXXX XXXX XXXX a.k.a.XXXX XXXX XXXX XXXX Personne(s) en cause Appeal considered / heard at Toronto, Ontario Appel instruit à Date of decision December 18, 2015 Date de la décision Panel Roslyn Ahara Tribunal Counsel for the person(s) who is(are)the subject of the appeal N/A Conseil(s) du (de la/des) personne(s) en cause Designated Representative(s) N/A Représentant(e)(s) désigné(e)(s) Counsel for the Minister Mandeep S. Randhawa Conseil du ministre REASONS FOR DECISION [1] XXXX XXXX, (the Appellant) who is a citizen of Jamaica, is appealing the decision of the Refugee Protection Division (RPD), denying her claim for refugee protection. The Minister of Citizenship and Immigration (the Intervener) has submitted a Memorandum of Argument in accordance with rule 4(3) of the Refugee Appeal Division Rules. The Appellant has submitted new evidence in support of this appeal and is requesting that an oral hearing be conducted by the Refugee Appeal Division (RAD). The Appellant also requests that the RAD substitute a positive determination. DETERMINATION [2] Pursuant to subsection 111(1)(a) of the Immigration and Refugee Protection Act (IRPA), the RAD confirms the decision of the RPD. This appeal is dismissed. Background [3] The Appellant's claim is based on victim abuse at the hands of her former common-law partner. She also alleges that she is a "proud" lesbian and fears that she cannot live openly as such in Jamaica. [4] The Appellant arrived in Canada in XXXX 2011 on a student visa. She made a refugee claim in January 2015. ADMISSIBILITY OF NEW EVIDENCE PRESENTED ON APPEAL EXPRESS STATUTORY CONDITIONS [5] Section 110(4) of IRPA provides that the Appellant may present only evidence that arose after the rejection of her claim or that was not reasonably available, or that she could not reasonably have been expected in the circumstances to have presented, at the time of the rejection. [6] The following new evidence and explanations for why it was not submitted to the RPD has been submitted: * Letter of support from XXXX XXXX, dated XXXX XXXX, 2015. This letter was not submitted prior to the rejection of the claim, as the Appellant was unaware that she was required to demonstrate proof of love and support to the RPD. * Letter of support from XXXX XXXX, the Appellant's brother, dated XXXX XXXX, 2015. This letter was not submitted prior to the rejection of the claim, as the Appellant was not aware that she ought to have provided a letter to indicate support from her brother. This letter also indicates that the Appellant's brother is willing to attend as a witness if an oral hearing is conducted. * Letter of support from XXXX XXXX dated XXXX XXXX, 2015. The Appellant submits that she lacked knowledge from whom she could submit supporting letters. * Request for Police Record sent June 5, 2015 subsequent to the rejection of the claim on April 2, 2015. The request for this court document is dated XXXX XXXX, 2015, although the Appellant's testimony revealed attempts prior to this. * Medical report, dated XXXX XXXX, 2015, which speaks to an incident which occurred on XXXX XXXX, 2011. This was requested on April 27, 2015. The Appellant submits that after numerous attempts and long waiting periods to obtain this document, it only became available after the rejection of the claim. The Intervener questions the way in which this report was requested, as the NDP indicates that with "signed permission", these reports are available through individuals who reside in Jamaica. * Resident Magistrate court dated XXXX XXXX, 2015 requested on April 21, 2015. The Appellant submits that she had informed the RPD of her efforts to locate this document however this document was only made available to her on June 11, 2015. * Receipt of prescribed medication: in the form of XXXX XXXX XXXX. This document was received on March 25, 2015 prior to the rejection of the claim, and is, therefore not admitted. * Article on human trafficking of a teenage girl, dated May 5, 2015. INTERVENER'S SUBMISSIONS RE: NEW EVIDENCE [7] Does the new evidence meet the test as set out in ss. 110(4) of the IRPA? [8] The Minister submits that the support letters (first three items) could reasonably have been available prior to the rejection of the claim. It is argued that this evidence did not arise after the rejection of the Appellant's claim. [9] With respect to the court documents pertaining to the police report filed by the Appellant in Jamaica in XXXX 2011, it is submitted that the RAD ought to consider the date on which the document came into existence and also the timing of the event or circumstances which the documents seek to prove. It is argued that the information in the document refers to XXXX 2011 although the date that that this document was sent is XXXX 2015. Moreover, it is argued that the Appellant has not satisfactorily explained why this evidence was not reasonably available prior to the rejection of the claim. [10] With respect to the receipt of prescribed medication, the Appellant acknowledges that she received this document on 25 March 2015, therefore she could have provided it to the RPD prior to the hearing. It is argued that late disclosure of documents is an option for making an application as it is routinely done in refugee hearings. [11] In regard to the medical report, although this document was provided to the Appellant on XXXX XXXX, 2015, the information is from XXXX 2011, and therefore there is no reason as to why this document could not have been obtained prior to the rejection of the claim. It is noted by the Intervener that the Appellant did not request this document until after the hearing, and she was able to obtain it within a period of less than one month from the date of her request. It is acknowledged that the Appellant stated at her RPD hearing that she contacted their website and filled out a page, as well as asking a cousin who works at a doctor's office, however there was no corroborative evidence before the RPD to support this assertion. Finally, the Intervener questions the way in which this report was requested, as the NDP indicates that with "signed permission", these reports are available through individuals who reside in Jamaica. [12] Finally, it is argued that the Appellant's counsel indicated in his disclosure that the Appellant would be the only individual testifying. RAD'S FINDINGS WITH RESPECT TO NEW EVIDENCE [13] The RAD finds that although the support letters post-date the rejection of the claim, they could reasonably have been available prior to the rejection of the claim. The Appellant was represented by competent counsel, and given her purported attempts to obtain medical and police reports, it is not reasonable that these letters were not submitted in support of her claim prior to its rejection. [14] With respect to the medical prescription, this pre-dates the rejection of the claim and the Appellant has not provided a satisfactory explanation for not filing it at the hearing, particularly when this subject was discussed and the prescription was available at that time. Accordingly, it is not admitted. [15] Upon review of the audio recording, the RAD finds that the remainder of the documents (medical police and court documents) were referred to in evidence at the RPD hearing and the Appellant testified that she had attempted to obtain the police and medical reports without success. While some of the explanations provided by the Appellant were not accepted by the RPD, the RAD will adopt a "flexible" approach and admit them into evidence. We note that all documents refer to an incident which occurred in XXXX 2011 and we concur with the Intervener that proof of the Appellant's efforts to obtain these documents was not provided to the RPD. However, the RAD will analyze their probative value in the context of the entire claim. [16] The article referring to the human trafficking of a teenage girl will be admitted, as it post-dates the rejection of the claim. However, it provides little probative value in terms of the particular aspects of the Appellant's claim. [17] With respect to the Appellant's request that her brother attend a hearing, the RAD finds that he had the opportunity to do so before the RPD. ORAL HEARING [18] According to subsection (6), the Refugee Appeal Division may hold a hearing if, in its opinion, there is documentary evidence referred to in subsection (3): a. that raises a serious issue with respect to the credibility of the person who is the subject of the appeal; b. that is central to the decision with respect to the refugee protection claim; and c. that, if accepted, would justify allowing or rejecting the refugee protection claim. [19] The RAD finds that there are two determinative issues, namely sexual orientation and domestic abuse. With respect to sexual orientation, no new evidence has been submitted in support of this allegation. [20] With respect to the issue of domestic abuse, although the RAD has admitted the medical and court documents, as well as the request for the police report, the RAD finds that this new evidence does not meet the criteria as set out in ss. 110(6) of the IRPA. These reports refer to one incident which occurred in XXXX 2011, and do not address the credibility concerns of the RPD surrounding the timing of the Appellant's refugee claim and the overall credibility findings with respect to the alleged domestic abuse, which are analyzed below. Accordingly, the RAD denies the Appellant's request for an oral hearing. ROLE OF THE RAD [21] A recent Federal Court decision in Huruglica1 has provided the RAD with guidance, which the RAD will follow. Justice Phelan states in paragraphs 54 and 55 of the foregoing decision: 54. Having concluded that the RAD erred in reviewing the RPD's decision on the standard of reasonableness, I have further concluded that for the reasons above, the RAD is required to conduct a hybrid appeal. It must review all aspects of the RPD's decision and come to an independent assessment of whether the claimant is a Convention refugee or a person in need of protection. Where its assessment departs from that of the RPD, the RAD must substitute its own decision. 55. In conducting its assessment, it can recognize and respect the conclusion of the RPD on such issues as credibility and/or where the RPD enjoys a particular advantage in reaching such a conclusion but it is not restricted, as an appellate court is, to intervening on facts only where there is an "overriding and palpable error." Sensitivity [22] The RPD stated in its Reasons that it provided breaks to the Appellant and was sensitive in asking questions. The Appellant argues that the RPD in fact was not sensitive. [23] The RAD does not concur with the Appellant. Breaks were offered to the Appellant, and the tone of the RPD Member was in keeping with the guidelines. The RAD notes, in particular, that the only sensitive issues raised, were by counsel, who had the opportunity to take a break when necessary or pose questions in such a way that the Appellant did not react sensitively. Accordingly, the RAD finds that the Appellant's argument in this respect has no merit and the RPD's comments are absent of any error. Efforts to obtain state protection [24] The RPD found the Appellant's testimony surrounding her involvement with the police to be contradictory. It found that the lack of detail with respect to the number of visits to the police along with the timing undermined the Appellant's credibility. She was asked when her common-law partner was abusive to her in public, if she had approached the police, to which she responded "no". [25] The Appellant argues that she misunderstood the RPD and thought it was referring to all four incidents, when she responded in the negative. Likewise with respect to the number of times the Appellant went to the police, she argues that she did so on three occasions, although she acknowledged that she could not recall the correct dates. Moreover, in the absence of these dates, this was her explanation for omitting it in her Basis of Claim (BOC) form and addendum. [26] The Intervener argues that the Appellant provided inconsistent testimony as to the dates and frequency of her visits to the police. It further notes that the new evidence cites one visit to the police, and does not corroborate further visits. [27] The RAD finds that the attempts on the part of the Appellant to seek state protection are a significant issue and central to the claim. Upon review of the audio recording, the RPD was not requesting precise dates; in fact, the RPD stated on a number of occasions to provide only approximate dates. The RAD finds that in the absence of any information in this regard , the Appellant's credibility is undermined. The RAD concurs with the RPD that the absence of this information detracts from the Appellant's credibility. RPD Reasons Paragraph 10 of RPD reasons [28] The RPD found the absence of any medical records, given the Appellant's purported injuries, called into question her credibility. In particular, it noted that she failed to provide any proof that she had been attempting to obtain these documents. The Intervener noted that the documentary evidence indicates that as long as the patient gives written consent, medical reports can be sent to persons abroad. [29] The Appellant submits that the RPD erred when stating that she was hospitalized. [30] The RAD concludes that this issue has been addressed by the submission of a medical report. Accordingly, the Appellant's credibility ought not to be impugned in this regard. Paragraph 11 of RPD reasons [31] In response to the RPD's question as to whom the Appellant fears in Jamaica, she testified that in addition to her former common-law, she also fears her previous abusive boyfriends, XXXX XXXX XXXX. In the absence of this information in either the BOC form or the addendum, the RPD found that it undermined her credibility regarding any fears of these two men. [32] The Appellant argues that she was not asked whom she feared in Jamaica, but rather if she feared the previous abusers, to which she responded "yes". [33] The Intervener argues that the omission of the names of XXXX XXXX XXXX XXXX XXXX as agents of harm, undermines the Appellant's credibility. [34] The RAD concurs with the RPD that this information was not included in either the original BOC form or the addendum. Having said this, however, the RAD finds that while undermining her credibility, the Appellant's response when questioned further was not definitive with respect to these fears. According to her testimony, it was the abuse at the hands of XXXX XXXX XXXX, which caused her to want to leave Jamaica. Therefore, the RAD finds that this issue is peripheral to the central issue of the claim, which is the alleged abuse at the hands of XXXX XXXX XXXX. [35] More importantly, however, is the argument of the Intervener, that there is little detail in the Appellant's BOC form with respect to her alleged abuser, XXXX XXXX XXXX. The Appellant has not provided any argument in this regard. However, the RAD finds that this is the central issue of the claim and the purported reason for the Appellant's departure from Jamaica and not taking time to fill out the necessary forms is not an acceptable excuse for the lack of detail. Paragraph 12 of RPD reasons [36] The RPD noted that the last incident of abuse by her former common-law partner, XXXX. XXXX was in XXXX 2011. She testified that she lived with him until he took her to the airport when she left for Canada. The RPD further noted that he paid for the application fees for her study permit at the travel agency and her brother in Canada paid for her airfare to Canada. The RPD also noted that the last time she had spoken to XXXX XXXX XXXX was in early 2013, because she blocked his telephone number. However, she stated that he called from other numbers, sent messages, old pictures and voice notes including threats to her. Further allegations of derogatory posts by XXXX XXXX XXXX against the Appellant appeared on Facebook, yet the Appellant was unable to provide any corroborative evidence in this regard. The RPD did not accept the Appellant's explanation that her telephone was damaged that that she was unable to provide any corroborative evidence regarding threats against her while in Canada. [37] The Appellant submits that the RPD erred with respect to the foregoing as it was her brother who paid her visa application fee and the airline ticket; the perpetrator paid only a fee to the travel agent to help her fill out the application. The Appellant further argues that the last time the Appellant spoke to XXXX XXXX XXXX was 2014, not 2013, as stated by the RPD. [38] The Intervener does not accept the Appellant's explanation that the alleged agent of persecution is illiterate and therefore unable to write anything. The Intervener submits that this is in contrast to the statement provided in the BOC addendum in which the Appellant stated that XXXX XXXX XXXX called from other numbers, sends messages and the derogatory posts on Facebook. [39] Upon review of the audio recording, the RAD finds that there was no evidence with respect to who had paid for the visa application. There was only reference to a fee paid to the travel agent, (but not for the visa itself) which was paid by the Appellant's former common-law and her brother, who had paid her air fare. Accordingly, the Appellant's argument cannot succeed. [40] With respect to the last contact the Appellant had with XXXX XXXX XXXX, in person, according to the Appellant's testimony, it was XXXX 2011. However upon review of the audio recording, the RAD concurs with the Appellant that the last contact of a non-direct nature, was early in 2014, not 2013. [41] Having said this, the RAD found the testimony with respect to this contact after 2011 to be vague and contradictory. At one point, the Appellant had damaged her telephone after which no messages were communicated. Moreover, the RAD notes that the Appellant failed to provide any proof of continued pursuit on the part of the perpetrator following her arrival in Canada in 2011. In fact, the audio recording reveals that the Appellant provided contradictory evidence surrounding the agent of persecution's ability to communicate if he was, in fact, illiterate, notably the alleged comments on Facebook. Accordingly, while the RPD erred with respect to this date, the RAD finds that the Appellant has failed to establish that the Appellant has been pursued by the agent of persecution since her arrival in Canada. The RAD concurs with the RPD that in the absence of corroborative evidence of some kind, i.e. social media and the lack of a reasonable explanation, that the evidence in this regard cannot be given much weight. The RAD concludes that the Appellant could have provided printouts of the comments from Facebook as evidence of some social media contact. Paragraph 14 of RPD reasons [42] The RPD noted that the Appellant had testified that she is currently prescribed XXXX XXXX XXXX, however she did not provide a medical note to corroborate this. She did, provide a psychological report, however, this letter simply indicates that the Appellant has attended four counselling sessions between XXXX XXXX, 2015 and XXXX XXXX, 2015. The RPD notes that the letter does not contain a diagnosis nor does it indicate that the Appellant is taking any medication. Moreover, the letter indicates that the Appellant required several medical interventions, when the Appellant indicated that she only went to the hospital on one occasion only. Accordingly, the RPD accorded little weight to this letter and found that it was not sufficient to overcome the credibility issues already identified. [43] While the RAD concurs that this report cannot overcome the credibility concerns, with due respect to the RPD, it does indicate that "she has reported symptoms consistent with XXXX". However, there was no questioning in this regard surrounding the diagnosis and how it was arrived at by the clinician. She did testify that she was prescribed XXXX XXXX XXXX, however the prescription was not submitted to the RPD, even though it was available. The RAD concurs with the RPD that the contradiction in the report with respect to the number of hospital visits, calls into question the contents of the report, which were self-reported. I concur with the RPD that this report cannot be accorded much weight and does not establish the purported domestic abuse the Appellant sustained. Paragraph 15 of RPD reasons [44] The RPD noted the Appellant's decision to work without authorization for three months until discovered by Canada Border Services Agency (CBSA), rather than make a refugee claim. The RPD further noted that the Appellant's permanent residence application was rejected in XXXX 2014 and a work permit was denied in XXXX 2014. Given that the Appellant was unable to reasonably explain her delay in making a refugee claim, the RPD found that it undermined her subjective fear and credibility, regarding her alleged gender-based persecution, including death, if she returns to Jamaica. [45] The Appellant takes issue with the foregoing. Firstly, she alleges that she did not work continuously for three months, but rather it was only a few days as she was travelling back and forth to XXXX and XXXX. Furthermore, the Appellant argues that her work permit application remained in process in XXXX 2014. [46] The RAD finds upon review of the audio recording, that this part-time work was not raised at the hearing. Nevertheless, even if it were, the fact of the matter is that the Appellant worked without authorization, she came to the attention of the authorities and then made a refugee claim. The RAD concludes that there is no difference between part-time or full-time work, when she was working without authorization. [47] There was much questioning surrounding the issue of delay in claiming, as the Appellant had arrived on a student visa. It was confusing as to exactly when she was in status on this visa, and when she was authorized to work. However, the RPD towards the end of the hearing asked the Appellant how many types of visas she had subsequent to her arrival in Canada. She responded "5 or 6". It is unclear if her work permit application remained in process in XXXX 2014, however it is clear that she worked for some of the time during the last three months without authorization. Upon review of the audio recording, it was also abundantly clear that the Appellant, although never intending to return to Jamaica, came here in XXXX 2011 with the view to attaining permanent residency. The RAD further notes that the Appellant has had 15 years of education, and obtained four diplomas here in Canada. In other words, it is reasonable to expect that the Appellant would have researched her options over this period of time, as she is an educated individual, who speaks English and is capable of conducting that research. The RAD finds that refugee status was never on her mind, until she was detained for working without authorization. While not determinative, the RAD finds that the Appellant's behavior is inconsistent with a person who is fleeing persecution, particularly when she was unable to provide a reasonable explanation for this delay in claiming; only that she was anticipating another means for attaining residency. Accordingly, the RAD finds that the RPD's findings in this regard are justifiable. State protection [48] Although not contained in the Appellant's "memorandum", the Intervener wishes to note that the police report indicates that charges were actually laid against the agent of persecution, indicating that there does exist a judicial system in Jamaica. While acknowledging that domestic violence remains a problem in Jamaica, the Intervener notes the documentary evidence2 which speaks to remedies, laws, jail sentences, restraining orders, and steps to educate police with sensitivity training. [49] In totality, the Intervener submits that the new evidence does not overcome the credibility concerns and the lack of subjective fear as found by the RPD. Furthermore, the Intervener argues that the new evidence does not establish that the Appellant faces a forward-looking risk of gender-based persecution if she returns to Jamaica or that she would face a personal risk to her life. RAD'S CONCLUSIONS [50] The RAD finds that the Appellant has not established that she would face a risk of gender based persecution if she were to return to Jamaica today. [51] The RAD finds that the one incident which occurred in XXXX 2011, has now been corroborated by the new evidence. However, it does not speak to the other incidents which the Appellant described in her testimony and which affected her overall credibility. [52] Moreover, the Appellant has not provided a reasonable explanation as to why details about the alleged agent of harm were not provided in her BOC form at paragraph 7. [53] The RAD finds that the Appellant failed to provide any corroborative evidence with respect to the alleged threats through online sites. The RAD does not accept the Appellant's explanation that the alleged agent of persecution is illiterate and therefore unable to write anything. The Intervener submits that this is in contrast to the statement provided in the BOC addendum in which the Appellant stated that he calls from other numbers, sends messages, and that that he makes derogatory posts against the Appellant on Facebook, according to a friend. [54] The RAD further finds that the new evidence indicates that charges were actually laid against the agent of persecution, indicating that there does exist a judicial system in Jamaica. The RAD finds that domestic violence is a problem in Jamaica, however, the government has taken steps to improve the situation. [55] The National Documentation Package (NDP)3 for Jamaica speaks to remedies, laws, jail sentences, restraining orders, and steps to educate police with sensitivity training. [56] The RAD finds that that the Domestic Violence (Amendment) Act of 2004, provides for men and women who have been victims of domestic violence to apply for the protection of the courts. Moreover, in its August 2010 report for the Universal Periodic Review, the government of Jamaica also states that the Sexual Offences Act, passed in 2009, "creates new provisions for the prosecution of rape and other sexual offences, including marital rape.4 This same documentation references the Bureau of Women's Affairs (BWS) "which is the main state agency responsible for gender issues, as having implemented projects aimed at addressing gender-based violence and sexual harassment". As well, the BWS "operated crisis hotlines and managed a public education campaign to raise the profile of domestic violence". [57] In its August 2010 report to the UN for the Universal Periodic Review, the government of Jamaica stated that the BWA, "which is the main state agency responsible for gender issues, has implemented projects aimed at addressing gender-based violence and sexual harassment" (20 Aug. 2010, para. 31). In its report to the UN Economic and Social Council, the government of Jamaica also states that the BWA, along with other Government agencies, NGOs and community-based organizations (CBOs), continues to conduct gender-based violence and human rights education workshops as part of a comprehensive public education programme and integrated prevention strategy to eliminate attitudes that foster, justify, and tolerate violence. (14 June 2011, para. 92) [58] In its February 2012 report to CEDAW, the Jamaican government specified that "the Bureau of Women's Affairs continues to coordinate and organize sensitizations workshops and seminars for Resident Magistrates and High Court Judges" adding that, [a]s part of this endeavour, over twenty-two (22) Resident Magistrates received training in how to offer greater redress to women and girls who are victims of violence, especially sexual violence and domestic abuse. Similar training sessions have also been held throughout the period with members of the Office of the Director of Public Prosecutions (DPP). (Jamaica 8 Feb. 2012, para. 3) [59] According to Country Reports 2010, the BWA also "operated crisis hotlines and managed a public education campaign to raise the profile of domestic violence" (US 8 Apr. 2011, 18). Information on whether the hotlines were still in operation could not be found among the sources consulted by the Research Directorate. 3.3 Police Country Reports 2012 states that "NGOs expressed concerns that in the short term there was insufficient funding for police investigations of gender-based violence and for counselling and shelter for victims" (US 19 Apr. 2013, 16). The same report adds that "the NGO Woman Inc. reported that women frequently complained that police failed to treat domestic violence as a crime and take the necessary reports," but notes that that the Jamaican Constabulary Force "instituted a domestic abuse sensitivity training program for police officers in downtown Kingston" (ibid.). CONCLUSION [60] The RAD finds that the Appellant has not established that there is a serious possibility that she would face persecution, if she were to return to Jamaica today. I concur with the RPD that her behavior since her arrival in Canada, indicates a lack of subjective fear and undermines her credibility. [61] The RAD further finds that the Appellant has provided conflicting evidence with respect to her efforts to seek state protection. I find that the new evidence does not overcome this credibility finding and therefore concur with the RPD with respect to this issue. [62] The RAD concurs with the RPD that the Convention refugee definition is forward-looking. The RAD finds that the evidence surrounding any continuing pursuit on the part of the agent of persecution is lacking in credibility. [63] With respect to the alleged fear of persecution due to being a lesbian, firstly, the RAD finds that there was no new evidence submitted with respect to the Appellant's sexual orientation Moreover, the Appellant has made no submissions in this regard in her memorandum of argument. [64] The RPD had not accepted this claim based on sexual orientation due to lack of any corroborative evidence on this issue. The RAD concurs with the RPD, given the lack of details in her BOC form or any information about any female partners, either in Jamaica or Canada, that the Appellant has not established her sexual orientation. [65] For the foregoing reasons, the RAD finds that the Appellant is not a Convention refugee or a person in need of protection. Accordingly, pursuant to subsection 111(1)(a) of the Immigration and Refugee Protection Act (IRPA), the RAD confirms the decision of the RPD. This appeal is dismissed. (signed) "Roslyn Ahara" Roslyn Ahara December 18, 2015 Date 1Huruglica, Bujar v. M.C.I. (F.C. no. IMM-6362-13, Phelan, August 22, 2014; 2014 FC 799). 2 Exhibit RPD-1, RPD Record, National Documentation Package (NDP) for Jamaica (version 27 February 2015), items 5.1, 5.4 and 2.6 3 Ibid. 4 Ibid., item 5.2, JAM104717.E --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ RAD.25.02 (June 23, 2014) RAD File No. / N° de dossier de la SAR : TB5-10735