BASED ON THE POINTS TAKEN ABOUT A CASE ON REMOVAL ORDER FROM CANADA TRYING TO DO THEORY OF THE CASE ON THE APPELLANT SIDE AND TRY TO DO A THEORY OF THE CASE FROM THE MINISTER COUNCILS SIDE . I need help with creating a strong theory from both parties can a law expert help me please thank you in advance !

IRB Reconsideration of the removal order file t9 represented by mr . Ross respondant is represent by ( minister council Andrew Ross) ( the appellant is Haseeb. Iqlibar)

Appeal received June 5th 2009 (pages 30) Deportation order last page going through minister disclosure previous hearing in 2018! Minister statement February 17 2020 (7pages) from the 9 of December but sent on the December 16, 2021 ICON Report (3pages) statutory declaration sent on the 9th of December 2020 April 27 2022 ICON report of April 25,2022 (4pages staclotry declaration) august 5 2022 ICON DATED AUGUST 3 2022 (3 pages) statutory declaration ( chakirov appellant representative) disclosure July 22. 2022 witness statement included (81 pages contains medical notes etc) august 3 2022 eateries (15 pages) august 9 2022 consisting disclosure mrs. Mrs.Mc Brian support person for the applicant / witness ) landing date convicted 3 counts for breaking and entering 2 years probation and 6 months community service 2 counts coviteced of two admissibility on May 20 2009 first appeal 2019 put on a four year stay of deportation

outstanding charges

since the reportable offence first conviction jan 11 2011 driving while impaired

many charges over the year that's been withdrawn or stayed

since Appllent 2011 hasn't been convicted of an offence recent

ICON REPORT FROM (AUGUST 3 2022 in regards to charges

adjourn to august 30 2022 outstanding charges: uttering thereats unauthorized weapon fail to comply without undertaking

August 7 2018 despense through drug program it's a diversion program spoke to criminal council august 11 2022 8 charges withdrawn (needs to get it confirmed)

appllent currently in a secured facility

minister council leaning towards his stay waiting in the testimony from the applent

order history: with his crimes , rehabilitated, go through what happened and how to avoid in the future, then current family situation and what would happen if you get deported to Pakistan applicant council direct examination how did he obtained status in Canada his dad worked in Canada got the pr card and worked for over 16 years he get is his mom sponsored to him 2005 June 21 , in Canada esl a b c school after that he hung around with wrong friends starred drugs crack and cocaine at schooll at lunch time he was doing the drugs first reportable offence breaking and entering he was in school two friends at the time said you want to go for a ride he went with them friend broke into a house came out the house with stuff said they broke into the house he was sitting in the car got pulled over and got arrested with the friends his lawyer advised him to plea guilty he was taking crack cocaine alcohol weed last time he did crack cocaine May 5 2021 it's been 1 1/2 year without drugs yes he was high on crack and cocaine when assuming these charges put before him , he took the following medication pills Remron/ mertrasophane samething mertasephane, ceperlex . Smart recovery meeting aaa alcohol unamyous aaa cocaine unamyous courage to change he attends outside of launch pad checks to see if he goes to these meetings goes to church every Sunday provided personal hand written journal he provided it to prove he can do this and not do drugs anymore it's his way to keep his mind on track appreciated the program he baptized at lunch pad he says it's not to late to change motivated the journal helps him with his addiction provided certificate of baptism freedom section 1 certificate is a 12 week program through church medication

he is taking right now remron and cerperplex the affect on him is for depression and anxiety January 14 2022 been in launchpad he's required to not use drugs . Spoke to his mom and dad he likes Windsor city he plans to live there to work through the launchpad houses he has aftercare plans with lunch pads plans to continue to attend the programs. Self reflection on his actions he's aware that what he did was wrong with friends of Hamilton and he's remorseful he doesn't want to live that drug lifestyle anymore his dad recommended him to go to lunchpad Recent criminality he has 9 outstanding charges obstruction of police officer Tuesday charge withdrawn jan 11 2019 unauthorized possession of weapon it came about in Brampton was used by friends Winston robisho asked him to look after his house needed a place to stay to do drugs he was dealing with stealing cars and he was being the applent had a knife (mail cutter) and attacking motor vehicle council shouldn't be talking about these outstanding charges will incriminate him the minister council stated the IRB wanted to hear about the outstanding charges he's more concerned about the drug rehab programs the app council wanted to show he was hanging out with the wrong crowd . He was on drugs while these occurred says wrong crowd of people outstanding charges are to be dropped through deverstion programs outstanding to adjourn to NOVEMBER possession of firearm , failed to comply RETURNING TO PAKISTAN He feels like he's going to be killed as they're killing a lot of Christian's he'll be lost without his family his relationship with his family is strong and it would affect them if he gets deported what he was giving a chance what's his long term goal get sober , life on track , get married and have kids follow his dads path he's confident that he's not doing no more drugs or alcohol hasn't done anything since Jan 14 2022 knows he has disappointed family and doesn't want to do that he's had a spiritual waking has mom dad sister and two brothers. Says mom will live with him no matter where he resides . (Support person Lindsey Mc Brain)

CROSS EXAMINATION FROM ANDREW ROSS MINISTER COUNCIL lived in Pakistan his whole life before coming to Canada while he was in Pakistan he was helping his mom brother sister he was 17 when he came to Canada he went to high school when he came here he went to adult school in Toronto he didn't complete his schooling he did drugs and alcohol his highest level of education grade 10 worked with his dad as a butcher he worked at tim hortins last employment 2015-2016 with his dad his family supports him he gets disability for 6 years $1000 hasn't used drugs before Canada started alcohol 2006 January 11 on his birthday his friends gave him a bottle 3 months later he did crack cocaine , weed when he went to jail first time 2007 he said when he took crack cocaine his mind was stuck took anger management classes knows his lunchpad schedule the issues the minister council issue: mentioned that very well he failed to report the issues to Canada boarder services and didn't comply on his conditions

IRB ASKING THAT HE HAS $900 IN FINES OUTSTANDING WANTS TO KNOW HOW HE PLANS ON PAYING THOSE FINES HIGHWAY TRAFFIC ACT AND LIQUOR LICENSE ACT HIS DAD WILL PAY

MRS.LINDSEY BRIAN WITNESS SUPPORT PERSON she works for the Canadian mental health helps persons who get released helps with community goals so he can connect with his family doctor assisted working on anger management techniques supporting coinciding helps with depression and anxiety on a weekly basis to make sure he stays in recovery worked at cmha for 12 years since 2012 has masters in mental health her focus is mental health and addictions na aaa meetings freedom section engage with social activities with members of lunch pad meets with her once or twice a week with her he's made a significant process he's very open for support she said also that she'll have a strong relapse if he goes back to Pakistan MINISTER COUNCIL AGREED TO ADJOURN THE STAY FOR 2 YEARS COUNCIL SAID APPRALNSHOULD OF BEEN DISPOSED OF MANY YEARS AGO THEYRE HERE CAUSE OF THE APP PREVIOUS CRIMINALITY 2 YEAR STAY WILL ALLOW THOSE CHARGES TO DISPOSE AND HOPEFULLY CONTINUE TO STAY FOR TWO YEARS HES BEEN IN CANADA FOR HALF OF HIS LIFE SUGEST DIFFICULTY FOR HIM TO RETUN THERE SAY HES TAKEN POSITIVE STEPS IN THAT SUPPORT RECOMMENDATION. THAT HE SHOULD STAY FOR TEO YEARS HE RECONGNIZED WHAT HAPPENED IN HIS LIFE WHAT APPEARS TO BE GETTING TO THE ROOT OF HIS ACTIONS LEADING TO DRUGS AND ALCOHOL HE HOPES HE CONTINUES TO REVUILD THOS CONNECTIONS WITH HIS FAMILY DIDNT MAKE A DECISION YET HE SAID HE DOESNT SEE NO REASON TO NOT MAKE IT THE 2 year stay as the (IRB) minister stated Desicion will be mailed to him in 60 days advised he follow the conditions one condition from minister ongoing prove of attending programs for his addictions a letter containing every six months needs to know when the program ends at the two year mark he can stay long or transistion there's no specific end date January 2024 is when it the lunch pad ends to end his program with lunchpad needs an official document from lunchpad ol suggest it's important that his treatment be ongoing wants him to provide proof for obtaining services ongoing as documentation provide letter or report from lunchpad detailing his participation in their programs for the duration of the stay remain in the program till 2024 with a letter stating that he's involved in lunch pad programs .