TB5-05696

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 : TB5-05696 Private Proceeding / Huis clos Reasons and decision ? Motifs et décision Person(s) who is(are) the subject of the appeal XXXX XXXX XXXX Personne(s) en cause Appeal considered / heard at Toronto, Ontario Appel instruit à Date of decision August 12, 2015 Date de la décision Panel M. Pettinella Tribunal Counsel for the person(s) who is(are)the subject of the appeal Paul Vandervennen Barrister and Solicitor 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 N/A Conseil du ministre REASONS FOR DECISION [1] XXXX XXXX (the Appellant) alleges to be a citizen of Somalia and appeals a decision of the Refugee Protection Division (RPD) denying his claim for refugee protection. He has submitted new evidence in support of his appeal and requests an oral hearing. The Appellant asks the Refugee Appeal Division (RAD) to declare him to be a Convention refugee. In the alternative, the Appellant asks that the decision of the RPD be set aside and that a new hearing be ordered at the RPD pursuant to paragraph 111(1)(c) of the Immigration and Refugee Protection Act (IRPA). DETERMINATION [2] Pursuant to Section 111(1)(b) of IRPA, the RAD sets aside the determination of the RPD and substitutes its determination that the Appellant is a Convention refugee. This appeal is allowed. Background [3] The Appellant alleged before the RPD that, upon return to Somalia, he will be harmed by members of Al Shabaab and majority tribe members because he is a member of a minority tribe. [4] The Appellant's application for refugee protection was heard on April 27, 2015. By a decision rendered orally on the same date, the RPD rejected the claim, finding that the Appellant had not established his personal identity and had not discharged his onus of proving who he is or what clan he belongs to. The RPD also found on a balance of probabilities that the Appellant's testimony was not credible and trustworthy. [5] The Appellant submits that the RPD erred in finding that he had not established on a balance of probabilities that he belongs to the Midgan, or Madhiban, tribe. He further submits that the RPD erred in its credibility findings. ANALYSIS Role of the RAD [6] What is the role of the RAD in considering an appeal against a decision of the RPD? The Appellant submits that the RAD is required to conduct a full appeal on the merits of the claim, and not simply review the decision to determine if the inferences drawn by the RPD were reasonably open to it. He refers to the decision of the Federal Court in Huruglica1 to support his submission. [7] The RAD acknowledges, in Huruglica, that the Court considered the appropriate relationship between the RAD and the RPD. It found that the RAD had erred in simply reviewing the RPD's decision on a standard of reasonableness, rather than conducting its own independent assessment of the Appellants' refugee claims. The Court held that the RAD's application of a reasonableness standard curtailed the tribunal's appellate role, contrary to the purpose of the RAD and the provisions of IRPA. In the Court's view, the RAD should not even engage in a standard of review analysis; rather, it should consider the purpose of the appellate tribunal, the statutory provisions, comparable expertise, and comparative appellate regimes.2 [8] Justice Phelan stated the following in Huruglica: 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.3 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."4 [9] Considering the Court's decision in Huruglica, the RAD will review all aspects of the RPD's decision and come to an independent assessment of the Appellant's refugee claim, recognizing and respecting the conclusion of the RPD on such issues as credibility and/or where the RPD enjoys a particular advantage in reaching such a conclusion. Where the RAD's assessment departs from that of the RPD, the RAD will substitute its own determination. Admissibility of Evidence Submitted on Appeal [10] Section 110(4) of the IRPA provides that the Appellant may present only evidence that arose after the rejection of his claim or that was not reasonably available, or that he could not reasonably have been expected in the circumstances to have presented, at the time of the rejection. It is for the Appellant to make full and detailed submissions in his Memorandum of Argument about how any proposed new evidence meets the requirements of Section 110(4) and how that evidence relates to him.5 [11] The Appellant has tendered two documents as proposed new evidence in support of his appeal. The documents are as follows: * Letter from XXXX XXXX, Executive Director of the XXXX XXXX (XXXX XXXX XXXX XXXXCentre), dated May 21, 2015;6 and * Affidavit of XXXX XXXX XXXX, sworn May 27, 2015, along with a copy of her Refugee Protection Claimant Document.7 [12] XXXX XXXX indicates in his letter that the Appellant attended his office on May 7, 2015 and he subsequently provided the Appellant with the phone number for XXXX XXXX XXXX, a former client and member of the XXXX clan. XXXX XXXX XXXX states in her affidavit that she spoke with the Appellant by phone on May 10, 2015 and by video conference on May 11, 2015. She also states that she knew the Appellant's family in Somalia and confirms that the Appellant is a member of the XXXX clan. [13] The Appellant submits that the proposed new evidence was not available at the time of his hearing and is relevant and credible. The RAD notes that the Appellant's claim for refugee protection was heard by the RPD on April 27, 2015 and rejected the same day. The Appellant indicated at his hearing that he had not met anyone in Canada who had known him from before. He also indicated that he had searched for someone who knew him. He said he searched Somali gathering places such as mosques and restaurants and asked people. The information in the letter and affidavit proposed as new evidence indicates that the Appellant came to the attention of the authors on or after XXXX XXXX, 2015; thus the documents were not reasonably available at the time the Appellant's claim for refugee protection was rejected by the RPD. Considering that the documents were not reasonably available at the time of rejection, the documents will be accepted as new evidence in this appeal. Application for an Oral Hearing [14] The Appellant submits that the RAD should hold a hearing pursuant to sub-section 110(6) of the IRPA if there are questions about the credibility of the new evidence as the new evidence is central to the decision and if accepted would justify allowing the appeal. He further submits that his witness, XXXX XXXX XXXX could testify by tele-conference at a hearing.8 [15] Section 110(3) of the IRPA requires that the RAD proceed without a hearing, on the basis of the RPD record, while allowing the RAD to accept documentary evidence and submissions from the Minister and the Appellant. The person who is the subject of the appeal may, pursuant to Section 110(4), present only evidence that arose after the rejection of their claim or that was not reasonably available, or that the person could not reasonably have been expected in the circumstances to have presented, at the time of the rejection. [16] According to Section 110(6) of the IRPA the RAD may hold a hearing if, in its opinion, there is documentary evidence referred to in 110(3) that raises a serious issue with respect to the credibility of the Appellant, that is central to the RPD's decision, and that, if accepted, would justify allowing or rejecting the refugee protection claim. In this appeal, where there is no further evidence from or in response to the Minister, the documentary evidence referred to in Section 110(3) must be understood in relation to Section 110(4). [17] When read together, Sections 110(3), (4), and (6) establish that the RAD must not hold a hearing in an appeal such as this unless there is new (Section 110(4)) evidence, in which case the RAD may hold a hearing if that new evidence raises a serious issue with respect to the credibility of the Appellant, is central to the RPD's decision, and that, if accepted, would justify allowing or rejecting the refugee protection claim. [18] The RAD has considered the new evidence in this appeal and is addressed below. The Appellant submits that the RAD should hold a hearing pursuant to sub-section 110(6) of the IRPA if there are questions about the credibility of the new evidence. The RAD does not have any questions about the credibility of the new evidence. Therefore, there is no requirement for a hearing. ANALYSIS OF THE MERITS OF THE APPEAL Identity [19] The RPD found that the Appellant is more likely than not a citizen of Somalia. It noted that the Appellant amended his Basis of Claim Form (BoC) to indicate that he was of the XXXX clan. It also noted that the Appellant acknowledged that XXXX is a term of insult. The RPD indicates in the reasons for its decision that the Appellant did not provide a reasonable explanation as to why he would self-identify by using a term of insult. The RPD noted that the Appellant had no identity documents or other evidence of his personal or clan identity. It acknowledged that identity documents are rare in Somalia, however, given the late amendment to his BoC and his self-description as XXXX, it found it difficult to accept that the Appellant belongs to the XXXX clan. It concluded that the Appellant had not established his clan identity which goes to the heart of his fear of returning to Somalia. [20] The Appellant submits that the RPD erred in finding that he had not established on a balance of probabilities that he belongs to the XXXX, or XXXX tribe. He notes that the RPD found he did not provide a reasonable explanation as to why he would self-identify as a XXXX, a term of insult, when he had indicated to the RPD that it was a word that was always used since he was a kid, he grew up with that term and he only found out about the term XXXX when he was older. He submits that the RPD erred by not considering his explanation for self-identifying as a XXXX and failing to give reasons explaining why his explanation was not acceptable. [21] The RAD finds that the RPD was wrong to not explain why it found the Appellant's explanation for self-identifying as XXXX to be unreasonable. The following is an excerpt from the Appellant's hearing: RPD: You made a brief reference to your tribe. Which clan do you belong to? Appellant: XXXX clan. RPD: Any reason you did not list your clan in your original claim form? Appellant: When I was completing the claim someone was writing it. I told that person and they probably didn't put that in. RPD: You said the information was complete and correct and someone interpreted it to you in your language. You would have known it was not mentioned in the area for ethnicity and tribe wouldn't you? Appellant: I told him like several times but I don't know what he put in there. RPD: You told me you knew what was in the form and it was true and complete. Are you telling me you don't know what is in the form? Appellant: I was told what was in the form. I don't remember him asking me what is your tribe or clan. I know he asked me questions. It was a long form. RPD: Is there another word you or others use for XXXX? Appellant: Yes you can say XXXX. It is two words with the same meaning. RPD: Are they terms of respect or derision? Appellant: XXXX can be used as an insult or derogatory. XXXX is a little more respectful. RPD: On page three of your form you wrote the following, "I am no different from thousands of XXXX that suffer daily". Why use a term that does not respect your people? Appellant: It's a word being used since I was a little child. It's used all the time. I grew up with that. RPD: You grew up with it instead of XXXX? Appellant: Yes, I found out about XXXX when I was older. [22] Documentary evidence indicates that the Gabooye are also known as Midgan or Midgaan people and the Gabooye can be divided in four other sub-groups: Madhiban, Muuse Deriyo, Tumaal, and Yibir.9 Minority Rights Group International (MRG) indicates that, in Somaliland, Gabooye is a preferred and non-insulting term replacing the historically pejorative associations of Midgan as used by majority clans. MRG also states that the commonly accepted term in Somalia is Madhiban.10 MRG indicates that the three main occupational groups are the Midgan/Gabooye, the Tumal, and the Yibr, and that the Midgan are subdivided into Madhiban and Musse Deriyo lineages.11 [23] Considering that the Appellant was exposed to the term XXXX since childhood, that he has limited formal education, that he had interaction with majority clan members during his adolescence and early adulthood, and considering that XXXX was a term used by majority clans, the RAD finds that it is not unreasonable that the Appellant would describe himself as XXXX in his BoC. Furthermore, even though the documentary evidence suggests that the commonly accepted term in Somalia is XXXX, the term "XXXX" continues to be used, even in documents describing lineages as noted above. [24] The RAD notes that the information the Appellant provided at his hearing in response to questions about the XXXX or XXXX clan was consistent with the information about the clan contained in the National Documentation Package. For example, when asked if the XXXX tend to have cattle or animals like other Somalis, the Appellant indicated that they did not. He went on to say that the XXXX don't have livestock and usually do work other Somalis feel unworthy doing like cutting hair, making shoes or cleaning the streets or washrooms. Documentary evidence indicates that the traditional occupations of the XXXX include shoemaking and hairdressing. Also indicated is that they can only obtain jobs as street sweepers or janitors, shoe maker/shoe mender, shoe polishing, blacksmith, potter, and circumcision practitioner.12 [25] The RAD has also considered the new evidence in this appeal. XXXX XXXX indicates in his letter that he concluded that the Appellant is a person of Somali origin who hails from the XXXX clan. This conclusion was based on his assessment of the Appellant following a discussion with him. The author claims to have XXXX years of experience working with refugees, including Somali-speaking refugee claimants.13 XXXX XXXX XXXX indicates in her affidavit that she confirms the Appellant's identity as a Somali and a member of the XXXX clan since she knew the Appellant's family in Somalia. She also indicates that she recalls that the Appellant's brother was killed by powerful militias from dominant tribes because of his clan identity.14 [26] The RAD finds no good reason to reject the Appellant's evidence, noted above, regarding his membership in the XXXX or XXXX clan. The author of the letter and the affiant, noted above, are credible and the Appellant's explanations for the RPD's concerns were reasonable. The RAD finds that the Appellant has established on a balance of probabilities that he is a citizen of Somalia and a member of the XXXX tribe. Credibility - work and resident history [27] The RPD found on a balance of probabilities that the Appellant's testimony was not credible and trustworthy. It noted that there were a number of omissions in the Appellant's documents. One example was that he stated at his hearing that he had worked for two years on a farm in the XXXX XXXX area whereas it was not indicated in his Schedule A and it is suggested in his Basis of Claim Form (BoC) narrative that he did that work for up to four years. The RPD also noted that the Appellant was vague in his testimony about the length of time he stayed in the XXXX area of XXXX XXXX. The RPD noted that the Appellant consistently blamed interpreters for inconsistencies or omissions in his claim forms and gave no acceptable explanation for why he would sign documents that had been interpreted to him. It indicated that the Appellant would have or should have noticed the inconsistencies and omissions before he signed the documents. [28] The Appellant submits that it was wrong for the RPD to draw a negative inference from the omission of his work on a XXXX XXXX in Schedule A since it was written in his BoC and it was not something he made up at the hearing. He further submits that his work on the XXXX XXXX was not employment, but forced labour without pay, and therefore would not necessarily be considered work history for inclusion on Schedule A. [29] The Appellant submits that the RPD was wrong to say that he testified at his hearing that he had worked for two years on a farm in the XXXX XXXX area whereas it is suggested in his BoC narrative that he did that work for up to four years. He argues that his BoC narrative says that in the years from 2007 to 2011 he was in XXXX and then in the XXXX XXXX outside of XXXX, but there are no indication when he moved from XXXX to the XXXX XXXX. The Appellant submits that the RPD was wrong to say that the BoC suggests he spent four years at the XXXX XXXX. [30] Instructions for completing the Personal History section of Schedule A - Background Declaration are clear in asking refugee claimants to provide details of their personal history since the age of 18, or the previous 10 years, whichever is most recent. They are instructed to start with the most recent information. They are also instructed to write their occupation or job title if they were working. If they were not working they are to provide information on what they were doing. They are instructed to not leave any gaps in time. [31] The Appellant indicates in his BoC that in or about 2007 he was forced to work for free at XXXX XXXX outside of XXXX. The RAD notes that the Appellant does not list this activity in his Schedule A - Background Declaration. Instead of listing his activities between 2007 and 2011, he indicates the region and locations where he resided. Under the heading for Activity for the period XXXX 2007 to XXXX 2011, the Appellant writes XXXX XXXX (XXXX and XXXX XXXX). Even though his activities are for that period are not listed in his Schedule A - Background Declaration, the information regarding his whereabouts for the same period is consistent with the information in his BoC narrative. When asked about the anomaly at his hearing the Appellant said he could not explain it and thought maybe it had to do with the person who translated for him. He also indicated that he realized it was a mistake on his part and that he should have checked more carefully. The RAD notes that the information in the Appellant's Schedule A is consistent with the information in his BoC with respect to his whereabouts during the 10 year period prior to coming to Canada. [32] It would be reasonable to expect refugee claimants to provide accurate and complete information in the forms they are required to complete in claiming refugee protection. It is obvious that the Appellant in this case inserted incorrect information in the Activity field of his Schedule A - Background Declaration. He listed his locations rather than activities for a certain time period. The Appellant acknowledged the error at his hearing. The RAD finds that the error does not undermine the Appellant's credibility. Credibility - travel arrangements to Kenya [33] The RPD noted that the Appellant's testimony at his hearing was not consistent with what he had stated in his Schedule A and he gave inconsistent information about his travel from Somalia to Kenya. One example was that the Appellant stated that he had a phone call with his cousin in Australia immediately prior to leaving Somalia and his cousin had told him that he was having difficulty raising money to assist him whereas he later testified that everything had been paid for by his cousin in Australia when he arrived in Nairobi. [34] The Appellant submits that the RPD erred in finding that he gave inconsistent evidence about his travels and the financing of his travels. He argues that he answered the questions that were asked of him and his evidence was consistent and not contradictory. Further, he argues that he testified about multiple communications with his cousin in Australia, with no indication of the timelines, about needing money and help to leave the country. The Appellant indicates that he testified that his cousin finally told him that he paid XXXX XXXX $7,000, gave him XXXX phone number and XXXX told the Appellant to take a bus with a specific driver. The Appellant submits that the RPD may have assumed that he took public transport rather than a private minibus and this may have led to its confusion and negative findings. [35] The following is an excerpt from the Appellant's hearing: RPD: You contact your cousin when you were in Somalia? Appellant: Yes. RPD: What did you tell him? Appellant: I told him about the problems I experienced and the situation with the land that I went through. I asked if he could help or assist me and get some word from God and he's my relative. RPD: What did your cousin say to you? Appellant: He said it was difficult to get all that money but he would do what he could. [36] The RPD then questioned the Appellant about his travel to Kenya and it was clear from his testimony that he had had further discussions with his cousin from Australia. For example, when asked if it was his understanding that his cousin sent XXXX $7,000 before he arrived in Nairobi, the Appellant said, "yes, that's what my cousin told me". The RPD was wrong in indicating that the Appellant stated that he had a phone call with his cousin in Australia immediately prior to leaving Somalia and his cousin had told him that he was having difficulty raising money to assist him whereas he later testified that everything had been paid for by his cousin in Australia when he arrived in Nairobi. The Appellant was not asked about a phone conversation with his cousin immediately prior to leaving Somalia and he did not specifically testify about a phone conversation with his cousin immediately prior to leaving Somalia. It is clear to the RAD that the Appellant had a number of conversations with his cousin but was not asked about them specifically at the hearing. The RPD's assessment of this evidence was wrong. Credibility - name of employer [37] The RPD noted that the Appellant did not name his employer in his Schedule A, yet, came up with his employer's name right away when asked about it at his hearing. It also noted that the Appellant failed to mention in his BoC that he paid money to XXXX XXXX to avoid forced recruitment and it was only conveyed in his testimony at his hearing. The RPD rejected the Appellant's explanation for how he could omit such an important fact from his story. [38] The Appellant submits that the RPD made an unfair inference by stating the he could not name his employer in his Schedule A but in his oral testimony he came with the employer's name right away. He argues that it was simply wrong to state that he could not name his employer on the Schedule A and he clearly did not put his mind to the question of who the owner of the plantation was since he was forced to work there. [39] The RAD notes that the Appellant failed to indicate his employment at a XXXX XXXX in his Schedule A and admitted the error. Since he failed to indicate his employment, it makes little sense that he would indicate his employer's name. The error of failing to indicate his employment at the XXXX XXXX extends to the name of his employer. Well-foundedness [40] The RPD acknowledged that a refugee claimant from the XXXX clan could face significant difficulties in Somalia because of his or her belonging to a minority clan according to the documentary evidence but found that it was unable to conclude that the Appellant is truly a member of the XXXX clan. [41] The RAD has found that the Appellant established on a balance of probabilities that he is a citizen of Somalia and a member of the XXXX tribe. As noted above, the XXXX is a minority clan in Somalia. The RAD has considered the documentary evidence on Somalia in relation to the Appellant's circumstances and profile. The United Nations High Commissioner for Refugee report International Protection Considerations with regard to People fleeing southern and Central Somalia indicates that persons belonging to minority clans remain at particular disadvantage in Mogadishu and other parts of Southern and Central Somalia. Members of minority clans are identified as a group at particular risk in Somalia. Some 80 percent of Southern and Central Somalia was reported to fall under Al Shabaab control. Given the wide geographic reach of Al Shabaab, a viable internal flight or relocation alternative may not be available to individuals at risk of being targeted by Al Shabaab.15 [42] MRG indicates that civil war, and later an Islamist insurgency against a weak transitional government in south-central Somalia, have forced thousands of minorities from their homes, both to other parts of Somalia and abroad. Minorities have been targeted due to lack of protection as well as, in some cases, for their religious or other traditional beliefs and practices.16 A United Kingdom Home Office report on Somalia indicates that minority groups, often lacking armed militias, continued to be disproportionately subject to killings, torture, rape, kidnapping for ransom, and looting of land and property with impunity by faction militias and majority clan members.17 Also indicated is that there is no guarantee of clan protection in Somalia, in particular members of minority clans and ethnic minority groups are vulnerable.18 [43] The Appellant is a young man, a member of a minority clan, a person displaced from his home and a person returning to Somalia from abroad; all risk factors that would cause him to be an easy and likely target. Two fellow clan members were killed when he was working at a XXXX XXXX near XXXX. He fled to XXXX where clan profiling and abuses against minority clan members was common The RAD finds that he fits the profile of those who are most at risk on return to Somalia. The RAD recognizes the difficulty faced by ethnic minorities living in Somalia. There was also credible evidence indicating that the Appellant was forced to work at a XXXX XXXX without pay for a number of years. He paid XXXX XXXX to avoid forced recruitment. This is significant in assessing what harm the Appellant might face upon return to Somalia. [44] The documentary evidence is clear in indicating that Somalia is unable to provide its citizens with adequate state protection. Furthermore, the Appellant has limited familial support in Somalia. His father and sister were killed in 1992 and his brother in 1999. The Appellant has demonstrated that he would have limited support from family members in Somalia. The Appellant testified that he has six years of formal schooling and had limited sporadic employment. [45] The Appellant is a 27 years man who has worked for very short periods of time which was mainly unpaid. He is from a minority clan. His only surviving family member is his mother who resides in XXXX. He suffered abuses by majority clan members in the past. Considering the Appellant's gender, his clan affiliation, his age, his lack of economic means, his lack of significant familial support in Somalia, and a history which includes encounters with Al Shabaab and majority clan members, combined with a lack of adequate state protection in Somalia, the RAD finds on a balance of probabilities the Appellant has satisfied the burden of establishing a serious possibility of persecution should he return to Somalia. The RAD therefore concludes that the Appellant has established a well-founded fear of persecution under section 96 of the IRPA. Section 97 [46] The RPD acknowledged the documentary evidence that indicates the likely targets of attacks by Al Shabaab would be government officials, the international peace-keeping forces of the African Union and those working for international agencies. It noted that the Appellant is not a member of an armed force and does not belong to an international agency. The RPD concluded that the Appellant can return to XXXX and he will not be targeted by Al Shabaab because the area is no longer controlled by them and has not been under their control since the end of 2011. It also found that the Appellant's fear is general and not particular to him. [47] The RAD has found that the Appellant has a well-founded fear of persecution in Somalia based on a Convention ground as per section 96 of the IRPA. Therefore, the RAD is not required to address the RPD's section 97 analysis. CONCLUSION [48] Pursuant to Section 111(1)(b) of IRPA, the RAD sets aside the determination of the RPD and substitutes its determination that the Appellant is a Convention refugee. This appeal is allowed. (signed) "M. Pettinella" M. Pettinella August 12, 2015 Date 1 Huruglica, Bujar v. M.C.I. (F.C., no. IMM-6362-13), Phelan, August 22, 2014; 2014 FC 799. 2 Huruglica, para. 45. 3 Huruglica, para 54. 4 Huruglica, para 55. 5 Refugee Appeal Division Rules, Section 3(3)(g)(iii). 6 Exhibit P-3. XXXX XXXX Letter. 7 Exhibit P-4. XXXX XXXX XXXX Affidavit. 8 Exhibit P-2, Appellant's Record, at p. 18. 9 Exhibit RPD-1, RPD's Record, at pp. 60-104, National Documentation Package for Somalia (March 31, 2015), item 13.7, at p. 1. 10 Exhibit RPD-1, RPD's Record, at pp. 60-104, National Documentation Package for Somalia (March 31, 2015), item 13.13, at p. 2. 11 Exhibit RPD-1, RPD's Record, at pp. 60-104, National Documentation Package for Somalia (March 31, 2015), item 13.13, at p. 3. 12 Exhibit RPD-1, RPD's Record, at pp. 60-104, National Documentation Package for Somalia (March 31, 2015), item 13.13, at pp. 3-4. 13 Exhibit P-3. XXXX XXXXLetter. 14 Exhibit P-4. XXXX XXXX XXXX Affidavit. 15 Exhibit RPD-1, RPD's Record, at pp. 60-104, National Documentation Package for Somalia (March 31, 2015), item 1.10, at p. 11. 16 Exhibit RPD-1, RPD's Record, at pp. 60-104, National Documentation Package for Somalia (March 31, 2015), item 13.1, at p. 5. 17 Exhibit RPD-1, RPD's Record, at pp. 60-104, National Documentation Package for Somalia (March 31, 2015), item 1.7, section 3.11.3. 18 Exhibit RPD-1, RPD's Record, at pp. 60-104, National Documentation Package for Somalia (March 31, 2015), item 1.7, section 3.11.4. --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ RAD.25.02 (June 23, 2014) RAD File No. / N° de dossier de la SAR : TB5-05696