Question

Part 1

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

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

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

Part 2

Once you have reviewed the documents and done your country conditions research,draft a set of preparatory notes in point form on a single issue, that is, whether your client's claim has rebutted the presumption of state protection.

Remember to think through your client's case carefully using the FILAC framework. Then, keep the CREAC structure in mind as you draft. 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.

The target length for your point-form notes is 650 words. A "grace range" of 50 words above or below is permitted.

You must provide the word count of your text at the end of the document (e.g., Word count: 652).

Anything above or below the target length will impact your mark for Communication. Fifty-one to one hundred (51-100) words over or under will be considered an "error." Anything over or under by more than 100 words will be considered a "significant error" and thus result in a "limited" for Communication.

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.

Claimant's Documentary Evidence

Item Title Page

1 Passport 1

2 National ID Card 2

3 Canadian Visitor's Visa 3

4 Marriage Certificate 4

5 Diploma from University of Abuja 5

6 Medical Letter confirming a cut on the arm 6

7 News articles about husband's election campaign 7

8 Wedding Invitation to Canada 9

9 Text Messages from husband and family 10