[00:00:00] Speaker 01:
Good morning, Your Honours.

[00:00:07] Speaker 01:
May it please the court, my name is Leah Jamilova.

[00:00:10] Speaker 01:
I represent the petitioner in this case.

[00:00:14] Speaker 01:
Um, this case basically resides on one issue.

[00:00:18] Speaker 01:
How much of bad stuff happening to you is enough for post persecution for pattern or practice for this favorite group and for well established future persecution.

[00:00:29] Speaker 01:
And the judge in this case found that nothing is enough.

[00:00:33] Speaker 01:
Doesn't matter unless you are physically harmed.

[00:00:36] Speaker 01:
Nothing will matter.

[00:00:38] Speaker 01:
So in this case we have

[00:00:41] Speaker 01:
multi-generational experience of being called racial slurs.

[00:00:46] Speaker 01:
We have teachers telling a child that the child will never amount to anything because of the ethnicity, but the cleaning jobs.

[00:00:54] Speaker 01:
They would not, the petitioner would not get hired officially only under the table even though he had the right for work.

[00:01:02] Speaker 01:
He had authorization, he was a citizen.

[00:01:04] Speaker 01:
We have slurs from neighbors, threats from neighbors, poppy poisoned by neighbors, construction materials put on fire by neighbors, police refusal to help investigate, and racial slurs.

[00:01:15] Speaker 01:
Government refusing to delay into issue of passport and racial slurs.

[00:01:21] Speaker 01:
and then refusal to help when the father disappeared, plus racial slurs.

[00:01:26] Speaker 01:
Now, if you take each of them separately like the judge did in this case, sure, it's unpleasant.

[00:01:32] Speaker 01:
you know, harassment, discrimination.

[00:01:34] Speaker 01:
However, if you put it together, then every day of your life, you're pointed out your race, and you're being deprived of something every single day.

[00:01:43] Speaker 01:
You, your child, through not only your lifetime, but already your child's lifetime.

[00:01:49] Speaker 01:
And it didn't start these days, it started before.

[00:01:52] Speaker 01:
So we have decades of the same happening.

[00:01:55] Speaker 01:
We have it happening all over the country.

[00:01:58] Speaker 02:
In fact, excuse me, counsel, you have it happen in different countries.

[00:02:03] Speaker 02:
Isn't it correct that when Mr. Modalkov, am I pronouncing his name correctly, Mr. Modalkov?

[00:02:08] Speaker 02:
Modalkov, yes, it's Spasiba, thank you.

[00:02:13] Speaker 02:
But isn't it correct that when he was in Kyrgyzstan, he was mistreated for being Russian, and when he lived in Russia, he was mistreated for being a Kazakh?

[00:02:21] Speaker 01:
That's correct.

[00:02:22] Speaker 02:
So he has mistreatment in two different countries for two different reasons as to two different ethnic biases, correct?

[00:02:28] Speaker 01:
Correct.

[00:02:28] Speaker 02:
So we got it at both ends.

[00:02:30] Speaker 01:
Correct.

[00:02:30] Speaker 02:
But I don't know if that helps you in this case in terms of the issues he's faced in terms of living in two different countries and facing slurs in both countries.

[00:02:40] Speaker 01:
So basically, he is between a rock and a hard place.

[00:02:43] Speaker 01:
That's very true.

[00:02:44] Speaker 01:
However, the issue in this case is only what happened in Russia, because he does not have already citizenship in other countries.

[00:02:52] Speaker 01:
So he only has citizenship in this country.

[00:02:55] Speaker 01:
I do understand that for some reason,

[00:02:57] Speaker 01:
At the lower levels, it was argued whatever happened to him in other country, but in Russia.

[00:03:03] Speaker 01:
But it's not an issue in this case.

[00:03:05] Speaker 01:
It's only about Russia.

[00:03:06] Speaker 02:
Well, clearly, discrimination by itself is not the same as persecution under the analysis, correct?

[00:03:11] Speaker 03:
Absolutely.

[00:03:12] Speaker 03:
And I think on your list of things, unless I missed it, you left out stealing the meat from his bowls by the government officials.

[00:03:22] Speaker 01:
Yes, that also happened.

[00:03:24] Speaker 01:
Yeah, yeah, yeah.

[00:03:26] Speaker 01:
That also shows you it's everywhere, all the time, every day.

[00:03:31] Speaker 01:
Would that be enough?

[00:03:33] Speaker 01:
Would that be enough if you were called name every single day?

[00:03:36] Speaker 01:
If I just replace what happened to him with what was happening in this country during the segregation time, I don't think any of us would have a question, is it just mere discrimination and harassment, or is it a bigger issue, a systematic issue?

[00:03:53] Speaker 01:
But when we replace it with a Kazakh person,

[00:03:55] Speaker 01:
in Russia for the immigration judge, somehow it's just unpleasant experiences.

[00:04:00] Speaker 01:
Sure, it is unpleasant, but it doesn't contradict the fact that it may be persecution.

[00:04:04] Speaker 03:
So what cases do you have that we can set against the facts of this case that tell us that this rises to the level?

[00:04:14] Speaker 03:
So it's a very clearly unpleasant treatment.

[00:04:17] Speaker 03:
And it's very clear that the ground for the treatment is a forbidden ground.

[00:04:21] Speaker 03:
So the only issue is, as you stated, is this bad enough?

[00:04:25] Speaker 03:
So what cases do we have to compare in terms of what's bad enough?

[00:04:32] Speaker 01:
Sure.

[00:04:33] Speaker 01:
I understand what you're asking.

[00:04:35] Speaker 01:
So what I would say, case law is one thing, but common understanding of things in life, I think even more important in this case.

[00:04:46] Speaker 01:
For example, if we talk about Jews in Germany in the 1930s, is it discrimination or is it already persecution?

[00:04:55] Speaker 01:
if we talk about black African-Americans in this country during the segregation era?

[00:05:00] Speaker 03:
No, I understand that.

[00:05:02] Speaker 03:
I asked you something different.

[00:05:03] Speaker 03:
I'm asking for cases because we deal with cases and the standards set by the cases and the factual kaleidoscope of the cases.

[00:05:13] Speaker 03:
I get it.

[00:05:13] Speaker 03:
There's nothing that's going to be directly on point.

[00:05:16] Speaker 03:
But what are your best cases to compare to this one that says this rises to the level of persecution?

[00:05:22] Speaker 01:
Well, the very core cases, I want to say, of asylum law.

[00:05:30] Speaker 01:
Sorry, I'm blanking right now.

[00:05:32] Speaker 01:
The case that established that race can be the basis for past persecution, that it's a protected ground, I think that's enough.

[00:05:41] Speaker 03:
No, I understand that you've got the protected ground.

[00:05:44] Speaker 03:
Yeah.

[00:05:45] Speaker 03:
But the issue is how bad's the treatment.

[00:05:48] Speaker 01:
The prosecution itself, I understand what you're asking.

[00:05:52] Speaker 01:
Sorry, I'm spacing right now on the name of the case.

[00:05:57] Speaker 01:
I will get to it at some point.

[00:05:59] Speaker 03:
That's OK.

[00:06:00] Speaker 03:
Don't worry.

[00:06:01] Speaker 01:
But we did list it in the brief.

[00:06:07] Speaker 02:
Well, perhaps to help you with Judge Fletcher's question, first of all, as to his wife and two daughters, they only obtained derivative

[00:06:17] Speaker 02:
rulings under asylum.

[00:06:19] Speaker 02:
So asylum is the whole angle here.

[00:06:21] Speaker 02:
I mean, this is the crucial point.

[00:06:23] Speaker 02:
And in terms of given that the Board of Immigration Appeals affirmed the immigration judge without an opinion,

[00:06:32] Speaker 02:
then in that case the opinion becomes the final agency action and it's reviewed for substantial evidence, correct?

[00:06:39] Speaker 02:
Correct.

[00:06:39] Speaker 02:
So in terms of the analysis first, in terms of say past persecution and then ethnic discrimination and harassment, where is the past persecution in the context say of economic deprivation?

[00:06:51] Speaker 02:
I know that there's one incident of economic hardship

[00:06:55] Speaker 02:
But that's literally it.

[00:06:56] Speaker 02:
He has found ongoing employment.

[00:07:00] Speaker 02:
Even in Russia, he was able to gain employment with respect to unofficial jobs, but he was definitely able to gain employment.

[00:07:06] Speaker 02:
So I don't know that you really have strong grounds in terms of past persecution.

[00:07:10] Speaker 02:
So your thrust is as to ethnic discrimination and harassment, correct?

[00:07:16] Speaker 01:
I would disagree politely in this matter.

[00:07:18] Speaker 02:
What am I missing on past persecution?

[00:07:21] Speaker 01:
So we are talking about, yes, you can find a job, a job.

[00:07:27] Speaker 01:
We're not saying it's going to be a good job that provides you well.

[00:07:30] Speaker 01:
It's going to be saying you can merely make a living.

[00:07:34] Speaker 01:
And merely making a living by cleaning jobs or construction jobs under the table

[00:07:39] Speaker 01:
That's not enough.

[00:07:41] Speaker 01:
The standard is not enough.

[00:07:42] Speaker 02:
Well, these were unofficial jobs at state-sponsored construction companies, correct?

[00:07:46] Speaker 01:
That's correct.

[00:07:46] Speaker 02:
And he had no difficulty getting employment in that fashion, correct?

[00:07:50] Speaker 01:
No, he did have difficulty.

[00:07:52] Speaker 02:
And I'm saying as to the under-the-table employment, he was easily able to get that, apparently.

[00:07:57] Speaker 01:
Sure, under-the-table employment, yes.

[00:07:59] Speaker 01:
However, a person should be entitled to official employment when he is authorized to work and when official employment provides him social protections, which under-the-table does not provide.

[00:08:10] Speaker 01:
Like in this case, when he was injured, he was kicked out from the job and was not able to get any compensations and was just fired because there are many like you.

[00:08:20] Speaker 01:
So a job, sure.

[00:08:22] Speaker 01:
However, that's not a job that a person should be able to get officially if he is a Russian citizen in Russia.

[00:08:30] Speaker 01:
And that, I believe, is a post-persecution, because it doesn't happen once.

[00:08:34] Speaker 01:
It happens also not only to him.

[00:08:36] Speaker 02:
Well, this Court has ruled previously that economic deprivation that constitutes a threat to life or freedom may be persecution.

[00:08:44] Speaker 02:
But getting jobs under the table represents a threat to life or freedom for him?

[00:08:50] Speaker 01:
It in co in conjunction with everything else.

[00:08:54] Speaker 01:
I believe it does rise to the persecution because we're not.

[00:08:56] Speaker 01:
That's exactly what the judge did.

[00:08:58] Speaker 01:
He only took that issue alone and looked at it and said, well, not enough.

[00:09:02] Speaker 01:
He can get a job under the table.

[00:09:04] Speaker 01:
However, we're taking it all together with the rest of the experiences that he had in Russia, with government calling him names, government refusing to provide services, and yada, yada, yada.

[00:09:16] Speaker 02:
Are there any other instances besides the one that Judge Fletcher noted in terms of taking the best bull meat and calling him a churka?

[00:09:23] Speaker 02:
That was the slur, calling him a churka, correct?

[00:09:26] Speaker 02:
And then he has complained about failing to conduct an autopsy as to his father and he has allegations about the death of his mother.

[00:09:33] Speaker 02:
Are there any other specific instances of any kind of government acquiescence here?

[00:09:37] Speaker 01:
Yes, they delayed the issuance of the passport and also called him the same slur.

[00:09:43] Speaker 01:
And the schools are also state schools.

[00:09:46] Speaker 01:
So calling him names when he was a child, calling his child names at school already constitutes action by the government toward him.

[00:09:59] Speaker 01:
And the police refused to investigate what happened to his dog and what happened to his construction materials, so that also

[00:10:07] Speaker 01:
tells you how they treat him.

[00:10:10] Speaker 01:
And for the future purposes of persecution, I believe that judge did not look, looked at the factors that have nothing to do with him.

[00:10:19] Speaker 01:
You can go back and relocate.

[00:10:21] Speaker 01:
Sure, he can relocate.

[00:10:22] Speaker 01:
He's going to face the same treatment if he relocates.

[00:10:25] Speaker 01:
His sister is safe.

[00:10:27] Speaker 01:
Sure, she is safe.

[00:10:28] Speaker 01:
However, we're not talking, he's not Navalny.

[00:10:31] Speaker 01:
It's not like the government is going to go after family members of the people they discriminate racially and ethnically.

[00:10:38] Speaker 01:
That's just a different category of discrimination and persecution that factors just do not apply here.

[00:10:45] Speaker 01:
Do believe that actually a little over time, but I'll put a minute back on the clock so that you can have a little rebuttal.

[00:11:18] Speaker 00:
Morning, Your Honors.

[00:11:19] Speaker 00:
Sonia Sarge-Kirksick on behalf of the United States Attorney General.

[00:11:23] Speaker 00:
The Court should deny the petition for review.

[00:11:26] Speaker 00:
First, Mr. Moldahmedov is not compelled reversal of the agency's denial of asylum and withholding of removal.

[00:11:35] Speaker 00:
As an initial matter, the IJ reasonably and properly concluded that Mr. Moldahmedov's

[00:11:41] Speaker 00:
Past experiences of discrimination and harassment when considered together with his financial difficulties did not rise to the level of harm required to meet the persecution standard.

[00:11:55] Speaker 00:
Before I get into the facts, I will make a brief note about the standard of review, which my colleague agrees is substantial evidence.

[00:12:04] Speaker 00:
We did discuss in our brief that there is some

[00:12:09] Speaker 00:
debate going on, excuse me.

[00:12:14] Speaker 00:
within some case laws and concurrences in the circuit regarding what the standard of review is.

[00:12:21] Speaker 00:
And notwithstanding that debate, here substantial evidence applies.

[00:12:27] Speaker 03:
Well, the question really isn't substantial evidence in the sense of burden of proof.

[00:12:31] Speaker 03:
The facts are, I think, undisputed.

[00:12:33] Speaker 03:
I mean, the IJ accepts the testimony.

[00:12:36] Speaker 03:
We treat it as true.

[00:12:38] Speaker 03:
And the question is, OK, applying the law to the facts that we accept is true.

[00:12:42] Speaker 03:
Isn't that what we're doing?

[00:12:44] Speaker 00:
Well, yeah, I would push back on that a little bit, Your Honor.

[00:12:49] Speaker 00:
I think that the IJ did discuss in his decision how the evidence did not meet the burden of proof.

[00:12:57] Speaker 03:
I understand that.

[00:12:59] Speaker 03:
But substantial evidence usually is a question of what do we believe and what don't we believe.

[00:13:04] Speaker 03:
But here, I don't think anything is disputed.

[00:13:06] Speaker 00:
I disagree.

[00:13:07] Speaker 00:
I think that there are things that are disputed, as the immigration judge pointed out in his decision,

[00:13:14] Speaker 00:
You know, even accepting that the job that Mr. Moldakmetov got with the state-run construction agencies was an unofficial job, there wasn't, on page 78, he notes, there wasn't really any information provided about what unofficial versus official means.

[00:13:32] Speaker 00:
We don't really know.

[00:13:34] Speaker 00:
And there are other examples in his decision.

[00:13:36] Speaker 00:
The IJ noted on page 77 that his injury at work

[00:13:44] Speaker 00:
You know, he was injured.

[00:13:45] Speaker 00:
We can accept that.

[00:13:46] Speaker 00:
However, it's still unclear exactly what the impact of that was.

[00:13:51] Speaker 00:
What was the, you know, for example, how much were the medical bills?

[00:13:55] Speaker 00:
What were the dollar amounts?

[00:13:56] Speaker 00:
How much was his unofficial salary versus what his official salary would have been?

[00:14:00] Speaker 00:
There's a lot of things about what happened to him.

[00:14:04] Speaker 00:
that were not sufficiently fleshed out, I think.

[00:14:07] Speaker 00:
And the IJ did rely on that.

[00:14:10] Speaker 02:
In terms of future prosecution, the one issue in terms of it being a disfavored group, did the immigration judge make any clear findings on that point in terms of being a disfavored group?

[00:14:24] Speaker 00:
The IJ did not.

[00:14:26] Speaker 02:
Because it seems to me that the matter of economic discrimination

[00:14:32] Speaker 02:
The record seems to have a great deal of information in terms of against migrants generally, and it happens to include Kazakhs.

[00:14:40] Speaker 02:
But in terms of the disfavor group being particularly targeted,

[00:14:44] Speaker 02:
It seems to me from I can see from the record that's deficient there.

[00:14:48] Speaker 02:
There was not a Any indication, but I'm not sure what did the immigration did really make any findings that the Kazakhs if I'm pronouncing that correctly were more disfavored or pulled out as opposed to other Russian biases against other migrants, I guess just to clarify your honor you said something about

[00:15:07] Speaker 00:
the IJ's decision being deficient or the record being deficient?

[00:15:12] Speaker 02:
I'm asking if the immigration judge made any clear finding on the issue of a disfavor group.

[00:15:19] Speaker 00:
He did not.

[00:15:20] Speaker 00:
I will say as a threshold matter, the

[00:15:23] Speaker 00:
petitioner did not cite, and I did not find anything in the country conditions evidence regarding Kazakhs in particular.

[00:15:30] Speaker 00:
There was some information about migrants, although the I.J.

[00:15:35] Speaker 00:
noted Mr. Moldakhmetov is a Russian citizen, and so whether he could be categorized as a migrant is not clear.

[00:15:42] Speaker 00:
And then there also were sort of vague assertions made to the I.J.

[00:15:50] Speaker 00:
regarding non-Russian ethnicity, but again,

[00:15:53] Speaker 00:
That's an extremely large and broad group.

[00:15:56] Speaker 00:
However, to answer your question, the IG did not get into disfavored group.

[00:16:01] Speaker 00:
He did discuss pattern or practice.

[00:16:04] Speaker 00:
As the court is aware, there are two ways to establish a objectively reasonable fear of persecution in the regulations.

[00:16:14] Speaker 00:
The regulation is 8 CFR.

[00:16:16] Speaker 00:
The first way is the petitioners show that he will be singled out for harm, and the second way that's identified in the statute is they can show that their amendment

[00:16:33] Speaker 00:
a member of a group that is subject to a pattern or practice of persecution.

[00:16:37] Speaker 00:
The disfavored group, and I think it's really important to remember that the disfavored group analysis falls under that first category, the singled out category of the analysis because all that the disfavored group analysis does is allow the petitioner a slightly lower burden of proof.

[00:16:56] Speaker 00:
In terms of showing that they will be singled out for persecution.

[00:17:08] Speaker 00:
None of them were identified by name.

[00:17:10] Speaker 00:
There are no particular persecutors identified in the future.

[00:17:16] Speaker 00:
There were no specific threats that were reported by Mr. Moldakhmetov in terms of, if you come back here, we will find you and do this and that.

[00:17:26] Speaker 00:
There's no evidence showing that.

[00:17:30] Speaker 00:
that he will be subject to that kind of specific harm.

[00:17:36] Speaker 00:
And so in that regard, the IJ did address that evidence and did engage in that analysis.

[00:17:43] Speaker 00:
And so it wasn't necessary for him to go into the disfavored group piece of it because the burden, albeit lowered,

[00:17:51] Speaker 00:
They didn't even get to the threshold where that would kick in, I guess is what I'm trying to say.

[00:17:58] Speaker 00:
And then just one brief note again about the standard of review.

[00:18:02] Speaker 00:
Mixed questions of law and fact.

[00:18:07] Speaker 00:
that where the facts are undisputed are considered by the Supreme Court, as we all know, as questions of law.

[00:18:16] Speaker 00:
However, what the Supreme Court has also acknowledged in Wilkinson most recently is that every type of question of law is not subject to de novo review, and it is still subject, as Wilkinson said, and as we state in our brief, to a deferential standard.

[00:18:32] Speaker 00:
And that standard goes back to Elias Zacharias, which is still good law, where the inquiry that the court engages in isn't to put itself into the shoes of the agency and do its job over again.

[00:18:46] Speaker 00:
Rather, it's to determine whether the record compels reversal.

[00:18:50] Speaker 00:
And so, you know, regarding the economic persecution, for example, that Mr. Moldakhmetov, I'm sorry, the economic difficulties that Mr. Moldakhmetov

[00:19:01] Speaker 00:
uh... experienced do not rise to the level of persecution uh... we can see that on this record here and we can also see that uh... when we look at this court's case law and just some examples include uh... the court the case hay seven forty nine at third seven ninety two at seven ninety six uh...

[00:19:21] Speaker 00:
This was a farmer.

[00:19:23] Speaker 00:
The petitioner was a farmer.

[00:19:24] Speaker 00:
He was subject to a very large fine, and he could only farm for three months out of the year, but was able to get employment and make some kind of living, you know, with other work the rest of the year.

[00:19:40] Speaker 00:
Another case is Hussein v. Rosen.

[00:19:43] Speaker 00:
985 F 3rd, 634, where, and this again was sort of a combination of, it also involved the burden of proof because while the petitioner's jewelry store and business had been burned down, not enough evidence was submitted regarding exactly what the impact of that was on his livelihood, and he was, and the evidence that there did exist showed that he was able to keep working.

[00:20:07] Speaker 00:
And you juxtapose that with a case where economic persecution was found,

[00:20:13] Speaker 00:
which is Babala 367 F3 1067, where the petitioner was a fisherman who was the subject of incessant threats and violence by Israeli Marines.

[00:20:25] Speaker 00:
And I think that this case certainly falls into the former category of cases.

[00:20:33] Speaker 00:
And then I'll just respond.

[00:20:35] Speaker 00:
I'll use my remaining time to quickly respond.

[00:20:38] Speaker 00:
The IJ here did engage in a cumulative analysis.

[00:20:42] Speaker 00:
He said so explicitly on pages 78 and 80 of the record.

[00:20:48] Speaker 00:
I think that asserting a risk of even discrimination and harassment all over Russia by everyone is casting much too broad a net, you know, that would just, that's just too broad of allegations in order to establish.

[00:21:06] Speaker 00:
the claim.

[00:21:08] Speaker 00:
And the last thing I would say is that the judge did not only decide this case based on the lack of physical harm.

[00:21:15] Speaker 00:
As I've explained, he really did consider each individual incident and then consider them together as he should have.

[00:21:23] Speaker 00:
Thank you, Your Honors.

[00:21:24] Speaker 01:
All right.

[00:21:25] Speaker 01:
Thank you, Counsel.

[00:21:36] Speaker 01:
I would like to point out as a rebuttal that we are not only talking economic hardship.

[00:21:43] Speaker 01:
Economic hardship is just one of the things.

[00:21:45] Speaker 01:
We're taking also how government treats people who are non-Russian ethnically.

[00:21:53] Speaker 01:
We're talking about how they are commenting on them and so forth.

[00:21:57] Speaker 01:
So cumulatively

[00:21:59] Speaker 01:
Even though the judge did say he considered it all together, just saying it is not enough, he has to actually talk about what about altogether, because what we have in his decision, this, not enough, this, not enough, this, not enough, and then I considered everything cumulatively.

[00:22:17] Speaker 01:
It's not enough just to say I did.

[00:22:19] Speaker 01:
You have to actually do it, and he didn't do it.

[00:22:21] Speaker 02:
What are the considerations of cumulative evidence, though, that there is a great deal of discrimination against all kinds of ethnic groups in Russia, migrants, not only in terms of economic deprivation, but even in terms of country conditions.

[00:22:33] Speaker 02:
The track record is not good in Russia with respect to many minorities and many people.

[00:22:38] Speaker 02:
That's really the problem you have here, isn't it?

[00:22:41] Speaker 02:
It's not really just pulled out as to those from Kyrgyzstan or Kazakhstan.

[00:22:45] Speaker 02:
It's pervasive.

[00:22:46] Speaker 02:
It's true as to Armenians, for example, correct?

[00:22:49] Speaker 01:
Not exactly.

[00:22:50] Speaker 01:
If we talk historic perspective why it's happening, then you will be able to see, and the country condition do show it, that it's mainly Central Asians and Caucasus people.

[00:23:00] Speaker 01:
So it's based on appearance.

[00:23:02] Speaker 01:
It's the same as if an American goes to Russia, he's not going to be discriminated against because he's white in appearance and undistinguishable from a Slavic person.

[00:23:12] Speaker 01:
So it's whoever does not look Slavic.

[00:23:14] Speaker 01:
And just so happened that it's either Central Asian

[00:23:17] Speaker 01:
or people from Caucasus areas, Chechens, and so forth.

[00:23:21] Speaker 01:
So there are very specific groups of people in Russia who are being discriminated ethnically against.

[00:23:27] Speaker 01:
So it's very specific.

[00:23:28] Speaker 01:
It's not super broad.

[00:23:30] Speaker 01:
And lastly, we need to look at historic perspective.

[00:23:35] Speaker 01:
So what happened was Central Asia was a Russian colony.

[00:23:38] Speaker 01:
So people of that appearance

[00:23:41] Speaker 01:
They are considered historically as other and less than, because they've been colonized.

[00:23:47] Speaker 01:
They were less educated, less cultured, and so on.

[00:23:50] Speaker 01:
So that's the basis of what we're seeing today happening in Russia, and that's what happens all over Russia, and that's what happens both by the government and by the society.

[00:23:59] Speaker 01:
Sorry, I'm over my time.

[00:24:00] Speaker 01:
Thank you.

[00:24:01] Speaker 01:
No problem.

[00:24:01] Speaker 01:
Thank you very much, Council, to both sides for your argument.

[00:24:05] Speaker 01:
The matter is submitted.