Basis of Claim Narrative of Michelle Ebi

1. I was born on January 27, 1994 in Abuja, Nigeria. I am a citizen of Nigeria and no other country. 2. Prior to coming to Canada, I resided in Abuja. My parents and my brother continue to live there. 3. I am afraid to return to Nigeria because of the physical, verbal and financial abuse from my husband, Michael Ebi. 4. I knew my husband since we were children. Our parents were close friends with his parents. My husband and I began dating when we were attending University of Abuja. We married in 2020. 5. One day in 2021, during an argument, my husband physically abused me. In shock, I left him and went to my parents' home. A few days later, my husband came and apologized to me. He promised to never hit me again. My parents also convinced me that I should forgive him. I accepted his apology and returned to live with him. 6. Unfortunately, the abuse continued after that. He was physically, verbally abusive towards me. For example, in July 2021, my husband threw a beer bottle at me and cut my arm. I had to go to a medical clinic to get stitches. I sometimes received bruises from his abuse. 7. I tried to report the abuse to the police. However, the police in Nigeria do not take domestic abuse seriously. They believe that it is a "family matter". On one occasion, I called the police after one argument. The police came to my home and gave a warning to my husband. They did not charge him or arrest him. This only made my husband angrier towards me. After this incident, I did not try to report any more abuse to the police. 8. My husband is a very traditional man. He had a traditional view of gender roles. He was very controlling. He did not let me work. He controlled all the finances in the home. I had to let him know where I was going every time I wanted to leave the home. 9. Many times, I thought about leaving my husband. However, there was nowhere I could go. My family would not assist me. They do not want me to separate with my husband. They would encourage me to return to my husband as they did before. It is very difficult to relocate anywhere in Nigeria as a single woman. It would be nearly impossible for me to find housing or employment were I to relocate to a different city. 10.Further, I believe that my husband has the resources to find me wherever I go. He is a very successful businessman who is very influential in Abuja area. He was a runner up in a recent municipal election in Abuja. He also has close friends high up in the government and the police force. 11.On October 30, 2023, I came to Canada as a visitor to attend a friend's wedding. I was supposed to return to Nigeria on November 12, 2023. I decided not to return due to the fear of my husband. 12.Ever since then, my husband has been furious with me. He has called and sent hundreds of texts to me demanding that I return to him. My family is also angry with me. They told me that there are rumours in the church and the community that I ran away. They told me that I was ruining their reputation. 13.Initially, I did not know that I could make a refugee claim in Canada based on my fear of domestic violence. It was only in January 2024, when I spoke to a social worker at a shelter who told me that a person in my situation could make a refugee claim. I immediately looked for a representative and initiated this refugee claim.

This assignment has two deliverables:

• Part 1: "Country Conditions Document Package"
• Part 2: Preparatory notes in point form

Prepare both parts in response to the issue ofwhether client's claim has rebutted the presumption of state protection.

Part 1

Conduct additional country conditions research. Find the strongest 2 or 3 online documents (human rights reports, newspaper articles, etc.) that can be used in oral submissions to support the position. Evidence should be:

1. current (within the last three years)
2. from credible sources, and
3. not already be in the NDP

The evidence found should be submitted as a single PDF in the form of a "Country Conditions Document Package" in compliance withRPD Rules31 and 32.

Part 2

Draft a set of preparatory notes in point form on a single issue, that is, whether client's claim has rebutted the presumption of state protection.

Remember to think through case carefully using the FILAC framework. Then, keep the CREAC structure in mind while drafting. Recall that the most persuasive argument is structured as a clear legal conclusion that is supported by reference to the relevant legal authority - legislation, case law and government policy where relevant - as applied to your client's specific facts.