XXXXX, Esq. NON DETAINED
American Gateways
Formerly the Political Asylum Project of Austin (PAPA)
314 E. Highland Mall Blvd.
Suite 501
Austin, TX 78752
UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
IMMIGRATION COURT
SAN ANTONIO, TEXAS
)
In the Matter of: )
) File No.: Axxx xxx xxx
XXX, )
)
In Removal Proceedings )
)
.
Immigration Judge Margaret Burkhardt Next ICH: November 2, 2011 at 8:30 a.m.
INDEX OF DOCUMENTS IN SUPPORT OF RESPONDENT’S I-589 APPLICATION FOR ASYLUM, WITHHOLDING OF REMOVAL, AND RELIEF UNDER THE CONVENTION AGAINST TORTURE
Table of Contents
TAB PAGE
A. Affidavits and Personal Documents in Support of Respondent’s Application
**Please note that Respondent will bring all envelopes with postmarks from letter and documents received from Nepal to his final hearing.**
· Original Birth Certificate of the Respondent with certified English
Translation 5-7
· Original Letter from the Rastriya Prajantra Party (RPP) Central
Office verifying Respondent’s active membership and political affiliation 8
· Original Letter from the Nepal Maoist Victim Association regarding
Respondent’s membership in the group and the film that he showed
with certified English translation, dated November 20, 2010 9-11
· Original Letter from the Nepal Maoist Victim Association regarding
Respondent’s membership in the group and his arrest for a protest he
Participated in with certified English translation, dated August 3, 2011 12-14
· Copy of the Movie about the Maoists that the Respondent showed,
Referenced in his I-589 15
Letter from Respondent’s father with certified English translation,
Dated January 22, 2011 16-20
· Letter from Respondent’s father with certified English translation,
Dated July 15, 2011 21-24
· Letter from Respondent’s wife with certified English translation,
Dated December 1, 2010, with copy of her Nepali identity card 25-31
· Copy of the response from the US Ambassador to Nepal in response
To the request for help from the Maoist Victims Association, dated
April 15, 2004 32-33
· Letter from XXXXXX at the Center for Survivors of Torture
Verifying that the Respondent has been receiving regular services due
To the trauma and persecution he suffered in Nepal 34
· Expert Affidavit of Dr. XXXXXX, regarding the current conditions in
Nepal with curricula vitae 35-74
B. Official State Department and UN Reports on the Human Rights Situation in Nepal
· “Nepal, Country Reports on Human Rights Practices – 2010,” US
Department of State, Bureau of Democracy, Human Rights and Labor,
Released April 8, 2010 75-95
· “Nepal, Country Reports on Human Rights Practices – 2009,” US
Department of State, Bureau of Democracy, Human Rights and Labor,
Released March 11, 2010 96-125
· “Nepal, Country Reports on Human Rights Practices – 2008,” US
Department of State, Bureau of Democracy, Human Rights and Labor,
Released February 25, 2009 126-159
· Report of the United Nations High Commissioner for Human Rights
On the human rights situation and the activities of her office, including
Technical cooperation in, Nepal, Document A/HRC/16/23, February
16, 2011 160-177
· NHRIs Nepal’s Response to UPR Final Report Submitted by the
Government of Nepal, Gauri Pradhan Commissioner, NHRC-Nepal,
June 7, 2011 178-180
· Allegations of Human Rights Abuses by the Young Communist League
(YCL), UN Office of the High Commissioner for Human Rights in Nepal
June 2007 181-195
C. NGO Reports Illustrating the Ongoing Violence and the General Human Rights Situation in Nepal
· “Nepal” Country Summary, Human Rights Watch, January 2011 196-198
· “Nepal” Amnesty International Report 2011 199-201
· “Nepal” Amnesty International Report 2010 202-205
· “Nepal: Identity Politics and Federalism,” Asia Report No. 199,
International Crisis Group, 13 January 2011 206-238
· “Nepal: Peace and Justice,” Asia Report No. 184, International
Crisis Group, 14 January 2010 239-276
· “Indifference to Duty: Impunity for Crimes Committed in Nepal,”
Human Rights Watch Report, December 2010 277-299
· “Still Waiting for Justice: Unpunished Crimes from Nepal’s Armed
Conflict,” Human Rights Watch Report, October 2009 300-325
· Refugee Review Tribunal Research Response, Australia, “Nepal,”
Document number NPL32007, August 1, 2007 326-338
· “Nepal’s Political Rights of Passage,” Asia Report No. 194,
International Crisis Group, 29 September 2010 339-368
D. Media Reports on the Human Rights Situation in Nepal
· “Nepal: As Army Chief Visits, US Should Insist on Accountability,”
Human Rights Watch, April 6, 2011 369-370
· “Enact Law on Enforced Disappearances: NHRC. OHRC,” Joint Press
Statement, August 29, 2011 371
· “What Political Movements are in Nepal,” Kathmandu Metro, January
11, 2009 372-378
· “Victims of Maoist Insurgency Warn to Launch Agitation,” Hindustan
Times, July 2, 2009 379
· Maoist Victims Press for Their Demands,” Kantipur Report, December
8, 2008 380-384
· “Maoist Victims Announce Agitation Programme,” Nepal Biz News,
May 7, 2007 385
· “Displaced Families Live in Fear,: IRIN, August 22, 2006 386-387
· “Dozens Held at Nepalese Rally,” BBC News, September 20, 2006 388
· “Nepal Anti-Rebel Leader Shot Dead,” BBC News, February 15, 2004 389
· “Amnesty International Condemns the Killing og Ganesh Chiluwal,”
Amnesty, February 17, 2004 390
· “Maoist Victims Restart Campaign,” BBC News, August 3, 2004 391
Certificate of Service 392
CERTIFICATE OF SERVICE
I, XXXX, hereby certify that a true and correct copy of the following specifically described document(s):
· I-589 and Index and supporting documents in support of Form I-589, Application for Asylum, Withholding of Removal and Relief under the Convention Against Torture
were properly served on the Department of Homeland Security by first-class mail to:
US Immigration and Customs Enforcement
Office of Chief Counsel
8940 Fourwinds Drive, 5th Floor
San Antonio, TX 78239
on the of October 2011.
______
Signature