TB5-06790

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 : TB5-06790 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 October 21, 2015 Date de la décision Panel Milton Israel Tribunal Counsel for the person(s) who is(are)the subject of the appeal Victor E Pilnitz 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 Kathryn Cowman Conseil du ministre REASONS FOR DECISION [1] XXXX XXXX (the Appellant), a citizen of Georgia, appeals a decision of the Refugee Protection Division (RPD) denying his claim for refugee protection. He has submitted new evidence and he has requested an oral hearing. The Appellant also requests that the Refugee Appeal Division (RAD) set aside the determination of the RPD and find that he is a Convention refugee or a person in need of protection. DETERMINATION [2] Pursuant to section 111(1)(a) of the Immigration and Refugee Protection Act (IRPA or the Act), the RAD confirms the decision of the RPD that the Appellant is neither a Convention refugee nor a person in need of protection. The appeal is dismissed. The Issues [3] The panel indicated the determinative issue in this claim is state protection. [4] The Appellant does not specifically list the issues in this appeal. It is clear however from the argument that the issue in this appeal is whether the panel has erred in its analysis and decision regarding the availability of state protection in Georgia. In addition the Appellant submits an argument regarding the standard of review. Role of the RAD [5] While the IRPA sets out grounds for appeal as well as possible remedies, it does not specify the standard by which the RAD is to review the decision of the lower tribunal. [6] The RAD now has the benefit of Federal Court jurisprudence which speaks to the appellate tribunal's role in relation to that of the RPD. [7] In this regard, the Court in Huruglica1 considered the appropriate relationship between the RAD and the RPD. In Huruglica, the Court determined that the RAD is to conduct a "hybrid appeal." It is to review all aspects of the RPD's decision and come to an independent assessment of the Appellant's refugee claim, deferring to the RPD only where the lower tribunal enjoys a particular advantage in reaching a conclusion. Where the RAD's assessment departs from that of the RPD, the RAD must substitute its own determination. [8] The Court determined that, in conducting its assessment, the RAD 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. The RAD is, however, not restricted, as an appellate court is, to intervening on the facts only where there is "palpable and overriding error". [9] The RAD will review all of the evidence in the RPD record and come to its own independent assessment of whether the Appellant is a Convention refugee or a person in need of protection. [10] The Appellant submitted a brief standard of review analysis and argued that the appeal should be considered a de novo review and the RAD should not defer to the RPD even regarding questions of credibility. The RAD disagrees and notes above its view concerning the RAD's role in considering this appeal. Exclusion [11] The Minister intervened in the RPD hearing and argued that the Appellant should be excluded on the basis of his use of fraudulent travel documents. The panel provided a lengthy analysis and found that the Appellant is not excluded from making a claim. The Minister's intervention in the appeal [12] The Minister makes an argument concerning the credibility of the new evidence provided by the Appellant. The Minister is not requesting a hearing in this regard. [13] The Minister submits the Appellant has failed to state how the evidence he seeks to include meets the requirements of section 110(4) of the Act and how it relates to the Appellant. The Minister further submits the Appellant fails to state why the RAD should hold a hearing under section 110(6) of the Act or if he definitively wants a hearing to be held. The Minister submits as well that the Appellant's statement that if the RAD does not decide in his favour he wants a hearing, is not sufficient and does not comply with the RAD rules. [14] The Minister also submits the case law on which the Appellant relies is missing as well as the errors that are the ground for the appeal. The Minister submits it is not sufficient to state the decision contains errors without stating what they are. [15] The Minister notes that the Appellant claims to be unrepresented, even though he provided submissions in English with no certified translation as evidence that he knows what is being submitted. [16] The Minister argues that the documentation submitted as new evidence by the Appellant should be given no weight and the RAD should affirm the original RPD decision. [17] The Minister notes that the Appellant has provided multiple decisions from other RPD hearings as evidence of no state protection in Georgia. The Minister submits the RAD is not bound by other refugee decisions and these should be given no weight. The Minister further submits in this regard that the evidence regarding state protection before these panels in these cases is unknown and the subjective fears of various claimants are different from the Appellant's. The Minister notes that the Appellant has provided no confirmation that he has permission to use and disclose these decisions and he has failed to take steps to keep the confidential information in these decisions as confidential. The Minister submits other claims have no bearing on this one, they are not binding, and they do no concern the same profile as the Appellant. [18] The Minister submits that the panel stated it has read the documentary evidence contained in the National Documentation Package (NDP)2 on Georgia and did not "cherry pick" that evidence as alleged. The Minister further submits the panel clearly laid out its reasons and it was not required to refer to every document. The Minister notes the Appellant is asking the RAD to reweigh the evidence without pointing out the actual error committed by the RPD panel. [19] The Minister submits that the personal circumstances of the Appellant's case were fully assessed and the panel found no forward-looking risk to the Appellant in Georgia. [20] The Minister submits there is no analysis regarding the proposed new evidence and why it is relevant to this claim and why it was not available prior to the RPD's decision. The Minister notes the statutory declaration is dated April 10, 2015,3 almost two months prior to the RPD's decision. The medical documentation is also dated two months before the decision. As well, the decisions provided by the Appellant are neither probative nor relevant to the Appellant for the reasons noted above. [21] The Minister submits that the Appellant is seeking to have the decision of the RPD overturned simply because other people from Georgia are being recognized as refugees and he was not. The Minister further submits this is not sufficient for the appeal to succeed. [22] The Minister asks that this appeal be dismissed for lack of perfection as the Appellant's record is deficient, or alternatively confirm the RPD's decision. [23] The RAD notes that the Appellant makes no response to the Minister's submissions. Admissibility of evidence presented on appeal [24] Section 110(4) of the IRPA provides that the Appellant may present only evidence that arose after the rejection of his/her claim or that was not reasonably available, or that he/she could not reasonably have been expected in the circumstances to have presented, at the time of the rejection of the claim. [25] The Appellant submits the following documents as new evidence: (a) An affidavit from XXXX XXXX dated April 10, 2015 (b) Medical document dated April 8, 2015 (c) 5 RPD Reasons [26] The RAD notes that document (a) is dated April 10, 2015, almost two months before the RPD panel rendered its decision. The RAD further notes the Appellant provides no argument as to why this document was not reasonably available to him before the RPD decision. The RAD further notes the document is not sworn under oath. The RAD finds this document does not meet the statutory test and is therefore not admitted. [27] The RAD notes that document (b) is dated April 8, 2015, approximately two months before the RPD panel rendered its decision. The RAD further notes the Appellant provides no argument as to why this document was not reasonably available to him before the RPD decision. The RAD notes as well, while this document indicated the patient died as a result of a shooting, there is no evidence in the document that ties this incident to the Appellant. The RAD finds this document does not meet the statutory test and is therefore not admitted. [28] The RAD notes documents (c), RPD Reasons, are not binding on the RAD. The RAD further notes that every refugee claim is distinctive as to the evidence disclosed and the circumstance of the Appellant. The RAD finds this evidence is not material to the case at bar and therefore it is not admitted as new evidence. Application for an oral hearing [29] The Appellant asks that an oral hearing be held pursuant to subsection 110(6) of the IRPA. 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. According to subsection 110(6), the RAD may hold a hearing if in its opinion, there is documentary evidence referred to in subsection 110(3) that raises a serious issue with respect to the credibility of the Appellant, that is central to the RPD's decision, and if accepted, would justify allowing or rejecting the refugee protection claim. The RAD notes that no new evidence in support of this claim has been admitted. Therefore the request for an oral hearing is dismissed. State Protection [30] The panel stated that it had read the documentary evidence in the Board's NDP on Georgia, assessed the written evidence presented by the Appellant and the oral evidence provided in the RPD hearing, considered as well the submissions presented and found that based on the totality of the evidence, the Appellant has failed to rebut the presumption of state protection. [31] The Appellant submits that the panel's decision contains a number of factual and legal errors, particularly in regard to its state protection analysis and conclusion. The Appellant further submits the panel "cherry picked" from the NDP package the evidence that supports its conclusion and ignored evidence that was contrary to its determination. [32] The panel cited the U.S. State Department 2013 Report on Human Rights in Georgia4 which indicates that Georgia is a democracy. It's government is accountable to parliament and the security force is under the control of civilian authorities. This document further indicates that while there are reports of security forces committing abuses with impunity, it is stated that the security forces are generally considered effective and operate within the confines of the law. [33] The panel further cited this documentary evidence which indicates there is enhanced police training in the curriculum which includes human rights and the legal basis for the use of force. It is further noted that specialized training on human rights is carried out in cooperation with international partners.5 [34] The panel found that this documentary evidence establishes that the police are provided with the skills to conduct proper investigations. The panel further found that the Appellant's evidence cited below, as to reports to the police, indicate that although imperfect, the Appellant was offered effective and adequate protection. The Appellant's allegations of attacks and the police response [35] The Appellant alleged he was stabbed by an unknown assailant on XXXX XXXX XXXX 2012. He was taken to a hospital and medical staff called the police. The police attended the hospital and interviewed the Appellant.6 He told the police he was an activist for the Unit National Movement (UNM) and his unknown assailant was not a local resident as he spoke a different dialect. He also indicated that he believed his attacker was from the Georgian Dream (GD), the current ruling party. The police initiated a criminal investigation. The panel noted that the Appellant did not provide evidence to suggest the police are not still trying to find his attacker. [36] The panel found the Appellant was offered adequate and effective protection. The panel noted it was not the Appellant but a doctor who contacted the police and the police immediately responded. The panel further noted there was very little evidence and given that the Appellant testified that his assailant was not from the local area, it is not surprising that the police failed to find any suspects. [37] The panel noted that the Appellant alleged he told the police the assailant was from GD and suggested the police would not investigate a case involving a GD member. The panel rejected this explanation as the evidence shows the police did initiate a criminal case and did record allegations against the GD. The panel further found that the police would not have done so if they sought to protect members of the GD. The panel found the reason the case has not been closed is lack of evidence. [38] The Appellant alleged he was kidnapped by unknown people and tortured on XXXX XXXX, 2012. He further alleged he was threatened that if he did not stop his political activity he would be killed. He was hospitalized and a doctor called the police. A police letter disclosed by the Appellant indicates they attended the hospital and interviewed the Appellant. They also interviewed the man who found the Appellant in the woods and initiated an investigation which is ongoing.7 [39] The Appellant indicated he could not identify those who kidnapped and assaulted him or provide information as to distinguishing features or the vehicle used. The panel found the police had little evidence to facilitate their investigation and that the Appellant had received a more than adequate and effective police response given the paucity of evidence. [40] The Appellant was asked why he believes the police were not providing him with adequate protection and he responded they could have investigated further and confirmed the vehicle from its track. He was further asked how he knew this was not done. The Appellant explained that his lawyer spoke to the police. The panel indicated it was not persuaded that the police were not conducting a proper investigation. The panel noted that the police letter cited above indicates witnesses were interviewed and the investigation remains open. [41] The Appellant alleged he was attacked again on XXXX XXXX, 2013,8 outside the UNM office. He was again hospitalized and the police responded to a call from the hospital and opened an investigation. In addition to interviewing the Appellant, they also interviewed witnesses who noted that three men came out of a black Mercedes jeep, attacked the Appellant and threatened trouble for his family if he did not stop his political work. [42] The panel noted the evidence provided to the police was vague and it asked the Appellant how he believes they would find these individuals quickly. The Appellant responded that there are different methods the police can use. The panel found that given the limited evidence it was unable to find that the police were not doing their job in the circumstances. The panel noted the Appellant failed to provide the police with material evidence. [43] The Appellant alleged that the Governor of XXXX asked him to join the GD9 and when he refused the Governor threatened him with violence. The Appellant further indicated he did not inform the police of the incident because they are connected to the GD. The panel noted there is evidence that some UNM members have been arrested for politically motivated reasons. It further noted however it had no objective evidence which suggests UNM members who report violence from GD members are being denied protection. The panel noted as well two or three incidents mentioned in the documentary evidence when police failed to conduct proper investigations of GD members' attacks on UMN members. The panel found it not reasonable that the Appellant would not report the threat from the Governor of XXXX, a known member of the organization allegedly responsible for all the attacks against him. [44] The Appellant alleged another attack on XXXX XXXX, 2013,10 followed by hospitalization, a police response, questioning of the Appellant and other witnesses, and a police report. The panel noted that despite criminal investigations, the Appellant continued to be attacked and it therefore could be concluded that the protection offered to the Appellant was inadequate. The panel found however that this would be the case if the police had evidence as to who the attackers were and failed to follow up. The panel noted the paucity of evidence offered to the police in regard to all these incidents and further noted investigations were opened and are ongoing. [45] The panel further noted the Appellant has failed to take his concerns to a higher authority and he failed to take the threat from the Governor of XXXX to the police. The panel notes the Appellant alleged that after this threat he received threatening calls every two weeks for over a year. When he was asked if he ever reported this to the police, he initially stated he did not. However subsequently in response to further questioning, he stated he did report to the police. The panel noted there was no police report on this regard and the Appellant explained the police pay no attention to UMN members. [46] The panel did not find this evidence credible and drew a negative inference from the contradiction in the Appellant's evidence. The panel further noted that the police provided reports noted above in regard to the various incidents alleged by the Appellant when the Appellant told them he was a member of UNM and he was attacked by GD members. The panel found the Appellant did not contact the police in regard to the phone calls. [47] The panel noted the Appellant indicated in his Basis of Claim (BOC) form that he did not contact the police when GD members surrounded him outside his office. The panel noted this incident followed the four incidents noted above and found it was not reasonable that the Appellant would not call the police when he was face to face with GD members, and his failure to do so obstructed his ability to obtain state protection. [48] The panel found that given the circumstances, the police provided the Appellant with a level of protection that is to be expected in a democratic country, and the Appellant has not provided sufficient evidence to suggest otherwise. The panel further found that if the Appellant were not satisfied with the conduct of the police he had other avenues of recourse. The panel noted that reports of police misconduct are considered by the Prosecutor General's Office and the law requires this office to open an investigation when it receives information about a possible violation. It is further noted that a decision by the Prosecutor's office can be further appealed to a higher level within the office.11 The panel noted the Appellant provided no evidence that he brought his concerns to the attention of the Prosecutor General and found this to be unreasonable. The panel found that the Appellant failed to engage all of the available avenues of recourse prior to leaving Georgia. [49] The panel further noted that counsel in the RPD hearing submitted evidence that on two occasions the police did not intervene to prevent violence against UNM members. The panel found this evidence did not overcome the four police reports which concern their investigations into the Appellant's allegations. [50] The panel found, in the context of country documentary evidence and the Appellant's evidence cited above, that the Appellant has failed to rebut the presumption of state protection. [51] The Appellant submits that the panel "cherry picked" from the NDP package the evidence that supports its conclusion and ignored evidence that was contrary to its determination. In support of this allegation, the Appellant cites the U.S. State Department 2013 Report on Human Rights Practices in Georgia.12 [52] This evidence indicates that among the human rights problems reported in 2013 were police abuse of detainees, poor but improving prison conditions, allegations of politically motivated harassment of UNM members, violent protests at some UNM presidential campaign events and external and internal influence on the judiciary. [53] The Appellant further cites the Amnesty International Report for 201313 which indicates opposition politicians were subject to violent attacks. This document indicates there are allegations of the selective prosecution and removal from office of figures associated with the UNM. In addition, it was reported that there were a number of violent attacks against opposition party politicians in which the police failed to prevent violence. [54] The document also notes several reports of torture and ill-treatment of detainees in prison and in police custody. [55] The RAD has reviewed all of the evidence in the RPD's record concerning state protection and the actions of the police. The RAD notes the Appellant provides no specific submissions concerning police response to the alleged incidents noted above. The RAD further notes the Appellant submits that the panel's decision, particularly in regard to state protection, contains a number of factual and legal errors, but the Appellant fails to indicate what these errors are. [56] The RAD notes, in regard to the Appellant's submission that the panel "cherry-picked" the documentary evidence and failed to note evidence contrary to its findings, that the panel did acknowledge country document evidence concerning police abuse. The RAD further notes that there is no requirement for the panel to cite all the documentation and there is no evidence that the panel did not take all the evidence before it into consideration in rendering its decision. [57] The RAD's extensive review and assessment of the documentary evidence indicates that the evidence is mixed in regard to state protection. The RAD notes there has been police abuse of detainees and politically motivated harassment, but it also notes the government that took office in 2012 has taken steps to promote accountability, in particular in regard to corruption among officials in the former government. According to the Council of Europe's Committee for Prevention of Torture (CPT) there were many allegations of torture under the former XXXX government but "hardly any" such allegations following the change of government in 2012.14 This document further indicates that in September 2012, the ombudsman created a system permitting civil monitoring of prisons. It is also reported that more disciplinary actions have been imposed on law enforcement officers than previously. [58] The RAD notes as well that this document, also cited by the panel,15 indicates that enhanced human rights training has been instituted for the police and that the police are generally effective despite incidents of abuse. [59] The RAD cites also the Office for Democratic Institutions and Human Rights (ODIHR) March 2014 report on trial monitoring in Georgia.16 This is particularly important as allegations have been made concerning political arrests and prosecutions of officials in the former (UNM) government, and this is pertinent to allegations in the case at bar as well. This report indicates the project is managed from Poland and implemented in Georgia by an international team leader at the invitation of the Georgian Foreign Ministry. The document also indicates that all stakeholders have welcomed ODIHR's engagement. It further indicates that "the legal and institutional framework regulating the Georgian judiciary and criminal justice system in particular is generally comprehensive and provides an increasingly sound basis to conduct trials in accordance with the rule of law principles and international fair trial standards."17 [60] The RAD notes that additional country document evidence from Freedom House18 indicates the trials of former government officials have been monitored by Transparency International. This report indicates that despite allegations by the UNM that the new government is practising selective justice; due process in these arrests appears to have been observed. The report also notes, despite the high level of antagonism between GD and UNM deputies from both parties proved capable of working together on several pieces of legislation in 2012. In regard to the 2013 elections, the Tbilisi-based International Society for Fair Elections and Democracy (ISFED) reported a number of violations by GD members. However, it indicated the number of such cases pales in comparison to the systematic harassment and intimidation of GD supporters by the UNM in the 2012 elections. In regard to trials of UNM former government officials, Transparency International Georgia which monitored these trials reported that both the defence and prosecution had enjoyed equal opportunities to present their cases. [61] The 2013 U.S. Department of State Department Report on Human Rights in Georgia19 cited above by the Appellant, indicates there were some reports that security force members committed abuses with impunity, although the government took steps to foster accountability during the year and the public defender documented cases when use of force by police exceeded permissible limits. [62] The RAD finds, on the basis of its review of all of the evidence concerning the Appellant's experience with Georgian police and also the country documentary evidence concerning state protection in Georgia, that although it is not perfect, it was open to the panel to find that the Appellant had failed to rebut the presumption that state protection was and is adequate and available to him. The RAD concurs with this finding. Investigation into the conduct of the United National Movement [63] The Appellant alleged he is currently wanted by the police for his alleged involvement with the XXXX of XXXX and he fears abuse if he is apprehended and wrongfully convicted solely based on his involvement with the UNM. [64] The panel cited documentary evidence that indicates that former UNM government officers are being arrested on charges of fraud, misappropriation of funds, corruption and other criminal acts associated with their positions of power.20 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. The panel further cites country documentary evidence that indicates the Office for Democratic Institutions and Human Rights (ODIHR) has been charged with monitoring the trials against former UNM leaders.21 [65] The panel found, in light of the trial monitoring report, it is clear the police were looking for evidence relating to misappropriation of funds and money laundering and therefore it is not unreasonable that the Appellant, who has admitted a close association with the XXXX, would be called in as a witness. The panel found this is not evidence of a persecutory act. [66] The panel noted the Appellant stated he was slapped by a police officer but found this action, though inappropriate, did not amount to persecution or a danger to his life. The panel further noted the Appellant did have the opportunity to approach the Prosecutor General's office and he did not. [67] The Appellant further stated that in XXXX 2014 he agreed to XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. The panel found it was likely that the police were watching the Appellant's movements and were aware that this transaction occurred. Five days later the Appellant was again summoned to the police station and he went into hiding. The panel found the Appellant was eluding possible prosecution and not persecution as he was a material witness. [68] The panel noted that country documentary evidence indicates that the monitoring of UNM trials by ODIHR was requested by the Ministry of Foreign Affairs after there were reports that charges were politically motivated. The panel noted that the Freedom House22 has reported that Transparency International (TI) Georgia has "...monitored the ensuing legal proceedings and found that both the defence and prosecution had enjoyed equal opportunities to present their cases." The panel further noted the monitoring has not produced any reports of significant violations of due process and there are no reports that those being detained are being mistreated while in detention. The panel found no indications that the Appellant would be treated any differently should he report to the police station for questioning in relation to the XXXX of XXXX case. [69] The panel noted that counsel in the RPD's hearing referenced 18 cases of alleged ill-treatment in prison documented by the Public Defender. It was alleged that in just one case an investigation was opened and no prosecutions were made. The panel noted these are allegations and no reasons were given as to why the 17 cases were dismissed. The panel found it could not assume they were credible as they could well have been unfounded and closed due to lack of credibility. [70] The RAD notes that the Appellant makes no specific submissions regarding the panel's findings concerning this issue. Allegations relating to threats made by the Appellant's former employer [71] The Appellant alleged that he was asked by his boss to partake in illegal activities at work. He further alleged he refused and contacted the police. The police asked if he wished to press charges and he told them he was just making a complaint. The police indicated there was nothing they could do without witnesses to corroborate his allegations. The Appellant alleged he was verbally threatened by his boss and told not to go to the police but his boss has not contacted him since XXXX 2013. The panel noted that there has been no further contact for over a year and there is no evidence that the Appellant's boss has any further interest in him. The panel found that if the Appellant were to return to Georgia he would not be at risk from his boss, and if the boss were to contact him again, he would be able to report the threats to the police and receive the adequate and effective protection he has received in the analysis noted above. [72] The RAD notes that the Appellant makes no specific submissions concerning the panel's findings in this regard. [73] The panel found that the Appellant has not provided clear and convincing evidence that the state is unable to provide him with protection from his attackers. The panel further found that the Appellant would not be at risk should he present himself to the police in relationship to the investigation against the former XXXX of XXXX, and that there was insufficient evidence to establish he would be at risk with relation to his former employer. [74] The RAD finds, in the context of the analysis above and its review of the evidence, that it was open to the panel to make the findings above concerning the availability of state protection for the Appellant and the lack of risk of persecution if the Appellant returned to Georgia and participated in the investigation concerning the former XXXX of XXXX. The RAD concurs with these findings. Disposition [75] Pursuant to section 111(1)(a) of the IRPA, the RAD confirms the determination of the RPD that the Appellant is neither a Convention refugee nor a person in need of protection. The appeal is dismissed. (signed) "Milton Israel" Milton Israel October 21, 2015 Date 1 Huruglica, Bujar v. M.C.I. (F.C. no. IMM-6362-13), Phelan, August 22, 2014, 2014 FC 799. 2 Exhibit RPD-1, RPD's Record, National Documentation Package (NDP) for Georgia (June 27, 2015). 3 Exhibit P-2, Appellant's Record, Minister's Notice of Intervention, unnumbered document, received on August 26, 2015. 4 Exhibit RPD-1, RPD's Record, National Documentation Package (NDP) for Georgia (June 27, 2015), item 2.1 5 Ibid. 6 Exhibit RPD-1, RPD's Record, at pp. 272-275. 7 Exhibit RPD-1, RPD's Record, at pp. 287-288. 8 Exhibit RPD-1, RPD's Record, pp. 268-320. 9 Ibid. 10 Ibid. 11 Exhibit RPD-1, RPD's Record, NDP for Georgia (June 27, 2015), item 2.1. 12 Ibid., item 2.1. 13 Exhibit RPD-1, RPD's Record, NDP for Georgia (June 27, 2015), item 2.2. 14 Ibid., item 2.1. 15 Ibid. 16 Exhibit RPD-1, RPD's Record, NDP for Georgia (June 27, 2015), item 9.1. 17 Ibid. 18 Exhibit RPD-1, RPD's Record, NDP for Georgia (June 27, 2015), items 2.3, 2.4. 19 Exhibit RPD-1, RPD's Record, NDP for Georgia (June 27, 2015), item 2.1. 20 Ibid. 21 Ibid. 22 Exhibit RPD-1, RPD's Record, NDP for Georgia (June 27, 2015), items 2.3, 2.4. --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ RAD.25.02 (June 23, 2014) RAD File No. / N° de dossier de la SAR : TB5-06790