The sticking point for the DHS Assistant Chief Counsel was safe relocation within Mexico. We argued that the client could not safely relocate anywhere in Mexico that her persecutor would not be able to locate her. Our office retained two wonderful expert witnesses that gave testimony and provided written declarations to the Court explaining why the persecutor could find her anywhere inside of Mexico.
DHS has reserved appeal and we will need to wait the 30-days to see what the Service is going to do. I am optimistic that we can prevail on any appeal because the record before the Court is so strong.