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					                            UNITED STATES DEPARTMENT OF JUSTICE
                          EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
                              OFFICE OF THE IMMIGRATION JUDGE
                                    BALTIMORE, MARYLAND


__________________________________________
IN THE MATTER OF                           )                                                 IN REMOVAL PROCEEDINGS
                                           )
                                           )
      “PEREZ”, “JUAN”
                                           )                                                 CASE A# XX-XXX-XXX
                                           )
RESPONDENT                                 )
__________________________________________)


                                                                     INDEX

EXHIBIT                                                                                                                          PAGE NO.

                                             PERSONAL DOCUMENTATION

   A. Declaration of “Perez”, “Juan”, Respondent ............................................. ............1

   B. Birth Certificate of “Perez”, “Juan”,, with certified English translation ...........7

   C. Northwestern High School Identification Card for “Perez”, “Juan”, .................
      .........................................................................................................................................9

   D. Salvadoran School Identification Card for “Perez”, “Juan”,, with certified English
      Translation ....................................................................................................................10

   E. Affidavit of Respondent’s Mother .............................................................................11

   F. Copy of Salvadoran Passport, U.S. B1/B2 Visa, and I-94 Card for Respondent’s
      Mother............................................................................................................................15

   G. Affidavit of Respondent’s Brother ............................................................................17

   H. Copy of Driver’s License, Social Security Card, Expired Lawful Permanent
      Resident Card, Salvadoran Passport, and Valid I-551 Passport Stamp of
      Respondent’s Brother ..................................................................................................19

   I. Curriculum Vitae and Psychological Evaluation of “Perez”, “Juan”, prepared by
      Licensed Psychologist Roxana Wolfe, RN, PsyD ....................................................23



                                                                          i
                  COUNTRY CONDITIONS DOCUMENTATION

                                       Child Abuse

J. U.S. Department of State, El Salvador: Country Report on Human Rights Practices,
   2004 (February 2005), http://www.state.gov/g/drl/rls/hrrpt/2004/41760.htm. ...26

   Throughout the year, the abuse of children and child labor continued to be a problem, as
    did discrimination and violence against women.
   Although domestic violence was a widespread and serious problem, incidents of domestic
    violence were underreported. The reasons for underreporting include societal and
    cultural pressures against the victims, fear of reprisal, poor response to victims by the
    authorities, and the belief that cases were unlikely to be resolved.
   Despite efforts by the government, children continued to be victims of physical and
    sexual abuse, abandonment, exploitation and neglect.
   Child labor remained a problem in El Salvador, despite the Constitutional prohibition
    against the employment of children under 14. Many Salvadorans consider child labor to
    be an essential component of family income, and not a human rights violation. As a
    result, orphans and children from poor families frequently work for their own or their
    family‘s survival. Children in these circumstances often do not complete schooling.

K. U.S. Department of State, El Salvador: Country Report on Human Rights Practices,
   2003 (February 2004), http://www.state.gov/g/drl/rls/hrrpt/2003/27897.htm. ...42

   Child labor was a problem in rural areas. In these areas, approximately 60 percent of
    children worked in the informal sector in micro-agricultural and non-agricultural family
    enterprises, for which they did not receive monetary compensation.
   More than 75,000 children between the ages of 5 and 13 worked, as did almost 147,000
    minors between the ages of 14 and 17.
   Child labor was more common in rural areas (15.7 percent) than in urban areas (7.7
    percent).
   Working children only completed an average of 5.6 years of school, in comparison to
    their non-working counterparts who completed on average 8 years of schooling.
   23.3 percent of families indicated that their children could not attend school for economic
    reasons. In rural areas, primary school attendance was oversubscribed by almost 14
    percent, as older children attended classes below their grade level. In these areas, seven
    percent of children attended school in grades six through eight.
   Children also continued to suffer from physical and sexual abuse, abandonment,
    exploitation, and neglect.




                                             ii
L. Canada: Immigration and Refugee Board, Country of Origin Research: El Salvador,
   April 5, 2004, http://www.irb-
   cisr.gc.ca/en/research/ndp/ref/?action=view&doc=slv42339e...............................66

   In February 2004, the United Nations Special Rapporteur on Violence Against Women
    declared that impunity for the perpetrators of domestic violence is a serious problem in El
    Salvador. Of those episodes of domestic violence that were reported, only one percent of
    complaints registered between 1980 and 2000 resulted in the conviction and sentencing
    of the perpetrator.
   Progress in the area of domestic violence has been slow, especially considering the size
    of the problem. Also, there has been a lack of education campaigns and initiatives to
    raise awareness about domestic violence issues.
   Services for domestic violence victims are inadequate.
   The legal system and law enforcement personnel routinely fail to protect victims and
    there is a high level of impunity.

M. Committee on the Rights of the Child, Concluding Observations of the Committee on
   the Rights of the Child, El Salvador, U.N. Doc. CRC/C/15/Add.232 (June 30, 2004),
   http://www1.umn.edu/humanrts/crc/elsalvador2004.html. ..................................69

   In its report, the Committee on the Rights of the Child expressed deep concern about the
    disproportionately high number of children who are victims of crimes, violence and
    homicides.
   The Committee notes that Salvadoran society is still characterized by high levels of
    violence against minors and it remains concerned about the persistent large-scale of abuse
    and violence within the family, as well as the prevalence of corporal punishment.
   Additionally, the Committee commented on the persistent gaps in the coverage and
    quality of education between urban and rural areas, as well as the high drop-out rates,
    especially among rural children. Only 40 percent of students attend high school.
   Child labor is widespread in El Salvador.

N. Latin American and the Caribbean Committee for the Defense of Women Rights
   (CLADEM El Salvador), Shadow Report on the Convention of Children’s Rights:
   Executive Summary, (Alma Benitez Molina & Aida Ruth Macall eds.), http://www.
   cladem.org/english/regional/monitoreo_convenios/ninezelsalreseji.asp. .............83

   The situation for children in El Salvador is still dramatic. The national government lacks
    a real interest in improving the quality of life and the mental and physical development of
    children.
   Poor children suffer discrimination, especially those in rural communities.
   The Anti-Gang Law, approved in October 2003, was enacted to prosecute crimes
    committed by organized gangs, but is indiscriminately applied to children and youth.
   Domestic Violence forms a part of Salvadoran society and directly impacts the
    development of children and adolescents. Moreover, physical punishment, in the form of
    slaps, hits, burns, sexual aggression, etc. is prevalent among families of lower incomes
    and lower levels of education.


                                            iii
O. Latin American and the Caribbean Committee for the Defense of Women Rights
   (CLADEM El Salvador), Shadow Report on the Convention of Children’s Rights,
   (Alma Benitez Molina & Aida Ruth Macall eds.), http://
   www.cladem.org/english/regional/monitoreo_convenios/ninezelsali.asp. ..........88

   Poor children in El Salvador suffer discrimination. There is inequality in every sense.
    There is inequality between rural and urban areas, between the rich and the poor, and
    between boys and girls.
   Poor children lack everything and, especially in rural areas, they must drop-out of school
    to help support their families.
   The incidence of domestic violence is very high in all sectors; however physical abuse is
    most common in households with low incomes and low levels of schooling.
   Between 2001-2003, there were 4,457 complaints of child abuse, 45% of which
    correspond to boys.
   A survey of physically abused children found that their parents used the following
    punishments: ―slaps 52.59%; kicks 24.15%; pinching 27.82%; pushes 38.55%; burns
    8.32%; with any object 72.54%.‖
   In high-income households, emotional abuse is more prevalent than physical abuse.
    Emotional abuse 82.5%, negligence 52.5%; physical abuse 17.5% and sexual abuse
    6.25%. In low-income houses, physical abuse is the most prevalent. Physical abuse
    87.12%, emotional 81.22%, negligence 68.87%; sexual abuse 22%.
   The Salvadoran society is extremely patriarchal and the men of the family have absolute
    rights.
   In the lower layers of society, vices such as the use of alcohol facilitate child abuse and
    sexual violence by fathers or male relatives.
   El Salvador also suffers from a proliferation of violent gangs that are often comprised of
    teenagers. Because of the misguided attention of both the government and the media
    toward the gang problem, children have become stigmatized as ―underage offenders.‖
    This has lead to the emergence of illegal armed groups that act like Death Squads and
    eliminate boys. The Salvadoran society and the government tolerates these groups, and
    in some cases may even support them.

P. Child Rights Information Network, 2 June 2005 Update: Latin America Regional
   Consultation on Violence Against Children, (UNICEF June 2005),
   http://www.crin.org/violence/search/closeup.asp?infoID=5650. ..........................119

   According to the Independent Expert for the Secretary-General‘s Study on Violence
    Against Children, ―[t]he home is the most dangerous place for children. There are no
    democratic freedoms in the home.‖
   In Latin and Central America, crime rates have soared. The homicide rate is now higher
    than during the war years of the 1980s and many of the new victims are children and
    youth.
   Many of the perpetrators are also youth. In the region, 60 percent of all homicides are
    committed by 10-29 year olds.



                                             iv
    There are a number of social, cultural and family-based factors that influence whether a
     youth becomes involved in a gang. These factors include a lack of positive role models
     within the family, urban growth, a lack of educational and economic opportunities, drugs,
     weak community organizations, a culture of violence, the impact of the conflict, and
     indifference to inequality and marginality.

Q. Child Rights Information Network, Latin America: Families and Institutions are the
   Main Sites of Violence against Children and Young People, (UNICEF June 2005)
   .........................................................................................................................................125

    Latin America is one of the most violent regions in the world and children are the main
     victims.
    In Latin America, families and State institutions are the main sites of violence against
     children and youth, as they maintain authoritarian values that rely on violence for
     implementation.
    ―Violence in the home unfolds in the private sphere which is dominated by deep-rooted
     machista and authoritarian practices.‖
    Most often, violence against children occurs behind closed doors and is perpetrated by
     adults that the children know and trust, such as parents, relatives and friends. Children
     typically suffer silently because they are too afraid to speak out or because they fear they
     will be punished if they do.

R. Caroline Moser & Ailsa Winton, Violence in the Central American Region: Towards
   an Integrated Framework for Violence Reduction, Executive Summary (Overseas
   Development Institute 2002). ......................................................................................127

    Especially in poor communities, violence permeates daily life.
    The overall reported figures of violence are only a conservative estimate of actual
     violence levels. In the case of domestic and sexual violence, only a small percentage of
     victims report their experiences. Often this is because an inefficient police force and
     judicial system discourages people from reporting incidences of violence.
    Despite its widespread nature, child abuse is mostly treated as a private family matter,
     and thus the widespread fear among children is largely invisible.
    Violence within the home causes young people to leave their homes and puts them at risk
     of street violence.
    Delinquents and gangs have highly visible profiles across the region, particularly in El
     Salvador, and governments face tremendous pressure to reduce the violence associated
     with these groups. As a result, although only a small portion of crimes are caused by
     youths under age 18, these crimes receive disproportionate media attention.

S. National Clearinghouse on Child Abuse and Neglect Information, Definitions of
   Child Abuse and Neglect, (Administration for Children & Families 2005),
   http://nccanch.acf.hhs.gov/general/legal/statutes/define.cfm. ..............................140

    The Child Abuse Prevention and Treatment Act (CAPTA) defines child abuse and
     neglect as: ―Any recent act or failure to act on the part of a parent or caretaker, which


                                                                    v
     results in death, serious physical or emotional harm, sexual abuse or exploitation, or an
     act or failure to act which presents an imminent risk of serious harm.‖
    Physical abuse is typically defined as any ―nonaccidental physical injury to the child.‖ It
     can include striking, kicking, burning, or biting the child.
    Emotional abuse is often defined as ―injury to the psychological capacity or emotional
     stability of the child.‖ It often appears as an observable or substantial change in
     behavior, or as anxiety, depression, withdrawal, or aggressive behavior.

T. National Clearinghouse on Child Abuse and Neglect Information, Long-Term
   Consequences of Child Abuse and Neglect, (Administration for Children & Families
   July 2005), http://nccanch.acf.hhs.gov/pubs/factsheets/long_term_consequences.cfm.
   .........................................................................................................................................145

    Not all abused and neglected children experience long-term effects. Outcomes of
     individual cases vary widely and depend on a child‘s ability to cope.
    The immediate physical effects of abuse can be relatively minor (bruises or cuts) or
     severe. In some cases, however, the pain and suffering they cause the child can be long-
     term. For example, the immediate feelings of isolation, fear, and an inability to trust can
     translate into lifelong consequences including low self-esteem, depression, and
     relationship difficulties.
    Victims of child abuse may suffer poor mental and emotional health, they may have
     cognitive and social difficulties, and they may have particular difficulty during
     adolescence.

U. Marti Tamm Loring, Emotional Abuse, Chap. 1, Epilogue, (Lexington Books 1994).
   .........................................................................................................................................151

    ―Emotional abuse is an ongoing process in which one individual systematically
     diminishes the inner-self of another.‖
    ―The most salient identifying characteristic of emotional abuse is its patterned aspect.‖ It
     is the continuous effort to demean and control that constitutes emotional abuse.
    Victims of emotional abuse report feeling empty, confused, and terrorized.
    Frequently, victims suffer from physical difficulties, such as headaches, stomachaches,
     and upper respiratory illnesses, which are metaphors for the pain of the emotional abuse.
    ―Because of their natural dependence on the nurturing adult, children cannot escape
     abuse and are highly vulnerable to anxious attachment, which binds them closely to their
     abusive parents.‖
    Emotionally abusive parents tend to convey a consistently negative self-image to their
     children, labeling them ―dumb‖ or ―wicked.‖
    Many emotionally needy children repeatedly try to please their emotionally abusive
     parents, while others withdraw in anger and frustration.
    Those children who internalize the abuse often become depressed, suicidal, and
     withdrawn. They typically have low self-esteem and suffer from guilt and remorse,
     depression, loneliness, rejection, and resignation.




                                                                    vi
V. Fact Sheet: Emotional Abuse, (Prevent Abuse America). ......................................169

    ―Emotional child abuse is maltreatment which results in impaired psychological growth
     and development. It involves words, actions, and indifference. Abusers constantly
     reject, ignore, belittle, dominate, and criticize the victims. This form of abuse may occur
     with or without physical abuse, but there is often overlap.‖
    Examples of emotional child abuse may include verbal abuse and excessive demands on
     a child‘s performance.
    Children who suffer from emotional abuse are often extremely loyal to the parent. They
     are afraid that they will be punished if they report abuse, or they may even think that such
     abuse is a normal way of life.
    Emotionally abused children tend to engage in inappropriate behavior that is immature or
     more mature for their age. They may be constantly withdrawn and sad, they may have
     poor relationships with peers, and lack self-confidence, and they may be unable to react
     with emotion or to develop an emotional bond with others.
    The effects of emotional abuse in children can be serious and long-term. Throughout
     their lives, these children may suffer depression, estrangement, anxiety, low self-esteem,
     or inappropriate or troubled relationships. ―As teenagers, they find it difficult to trust,
     participate in and achieve happiness in interpersonal relationships, and resolve the
     complex feelings left over from their childhoods.‖

W. Emotional Abuse, (National Exchange Club Foundation),
   http://www.preventchildabuse.com/emotion.htm. .................................................172

    ―Emotional abuse is . . . . the systematic tearing down of another human being.‖
    Emotional abuse is evidenced by a pattern of behavior. This behavior can seriously
     interfere with a child‘s healthy development.
    ―Children who are constantly shamed, humiliated, terrorized or rejected suffer at least as
     much, if not more, than if they had been physically assaulted.‖
    This type of abuse leaves hidden scars. ―Insecurity, poor self-esteem, destructive
     behavior, angry acts, withdrawal, poor development of basic skills, alcohol or drug abuse,
     suicide, and difficulty forming relationships.‖

X. Fact Sheet: Domestic Violence and its Impact on Children, (Children’s Defense Fund
   June 2003),
   http://www.childrensdefense.org/childwelfare/domesticviolence/factsheet.aspx.
   .........................................................................................................................................174

    ―The emotional toll on children who witness threats or violence against others can be
     substantial, especially when those involved are familiar to the child and the violence
     takes place in the hom [sic] – a place where victims should feel safe. Children who do
     not get help can be harmed when they witness domestic violence.‖
    Children who witness domestic violence frequently suffer physical, sexual, or emotional
     abuse themselves.
    ―Both child maltreatment and domestic violence occur in an estimated 30 to 60 percent of
     families where there is some form of family violence.‖


                                                                   vii
    In the United States, according to a national survey, over 50% of men who frequently
     assaulted their wives also frequently abused their children. The more frequent the
     violence against the woman, the more frequent the abuse against the child.
    ―Children who witness violence at home are at risk of suffering from numerous
     emotional and behavioral disturbances as diverse as withdrawal, hypervigilance,
     nightmares, self blame, developmental regression, and post traumatic stress disorder.‖
    ―Children who witness domestic violence also experience symptoms such as anxiety,
     aggression, temperamental problems, depression, less empathy, and low self-esteem.‖
    ―Children who witness domestic violence may display the following symptoms: sleep
     disorders, headaches, stomach aches, diarrhea, ulcers, asthma, enuresis, and depression.
     Such complaints are often identified as reactions to stress.‖

Y. National Clearinghouse on Child Abuse and Neglect Information, Substance Abuse
   and Child Maltreatment, (Administration for Children & Families 2003),
   http://nccanch.acf.hhs.gov/pubs/factsheets/subabuse_childmal.cfm. .................178

    ―Children of substance abusing parents are more likely to experience abuse . . . than
     children in non-substance abusing households.‖
    ―Between one-third and two-thirds of child maltreatment cases involve substance abuse.‖
    ―Maltreated children of substance abusing parents are more likely to have poorer
     physical, intellectual, social, and emotional outcomes and are at great risk of developing
     substance abuse problems themselves.‖

Z. Fact Sheet: The Relationship Between Parental Alcohol or Other Drug Problems and
   Child Maltreatment, (Prevent Child Abuse America). ............................................184

    About 40% of confirmed child maltreatment cases involve the use of alcohol or drugs.
     Additionally, alcohol and other drug problems are factors in a majority of cases of
     emotional abuse.
    Children in these homes suffer from a variety of physical, mental and emotional health
     problems. Specifically, they experience depression, anxiety, and low self-esteem. At
     home they are surrounded by an atmosphere of stress and family conflict.


                                                          Gang Violence

AA.               Scott Wallace, You Must Go Home Again, Harper’s Magazine 47 (Aug. 1,
      2000).
...............................................................................................................................................187
 El Salvador is the most violent country in the Western Hemisphere. It has a murder rate
      that is 40% higher than that of Colombia and its 60,000+ homicides in 1998 matched it‘s
      annual body count at the height of the civil war in 1983.
 ―Officials estimate that there are more than 20,000 full-fledged gang members in San
      Salvador alone-four times the number of guerrillas that three successive Republican
      administrations spent hundreds of millions of dollars trying to vanquish.‖



                                                                    viii
   ―In 1998, INS deportations to El Salvador topped 5,300, and Salvadoran church officials
    estimate that 16% of the deportados arrive with what they call ―grave antecedents‖ for
    criminal behavior – the rough equivalent of dumping 1,300 violent felons onto the streets
    of Chicago each year.‖
   ―…on top of the explosive conditions of gross social inequality, abusive authority, and
    widespread corruption that predated the civil war, El Salvador has become a refuge for
    powerful criminal syndicates who use the maras as a convenient smoke screen to deflect
    attention from their activities.‖
   National police officers are, ―poorly trained, underfunded, and lacking in the most
    rudimentary investigative know-how.‖
   Former guerillas account for 20% of the officer corps. The detective division ensures,
    ―both an enduring cover-up of atrocities and a whole new genre of collaboration between
    state intelligence and the criminal underworld.‖
   In the mid-1990s, Congress increased the number of criminal offenses that could result in
    expulsion, producing a surge of deportations to El Salvador. Speaking little Spanish and
    with few hopes of finding gainful employment, the deportees quickly found themselves
    immersed in a culture of drugs and gangs just like the one they left behind in the U.S.
   Resurgent death squads have claimed credit for a number of executions of gang leaders.
    Their rhetoric bears a remarkable resemblance in its patriotic discourse to the rhetoric
    that accompanied the right wing death squad slayings during the civil war.
   Plans to create ample educational, recreational and employment opportunities for teens
    have largely evaporated. ―Youngsters have been left to fend for themselves in a new
    world without signposts, where local traditions are rapidly succumbing to an entire
    zeitgeist of imported food, music, and fashion.‖
   Those gang members deported from the United States, ―brought with them their
    organization—and the same dress and manner of speaking that kids here had seen in the
    movies. They attracted attention of kids who were hanging out, looking for someone
    they could look up to.‖

BB.      Jeff Chang, Deporting to Death? A Los Angeles gang-peace organizer faces an
   immigration ruling that his supporters say could be a death sentence, Mother Jones
   (February 15, 2002)…………………………………………………………….…199

   Alex Sanchez, former gang member and current peace activist, is the program director for
    Homies Unidos, a Los Angeles and San Salvador based youth organization that works to
    calm the violence between warring gangs.
   Sanchez‘s supporters say deportation would be tantamount to a death sentence.
   ―Since 1999, . . . five members of the group have been deported to El Salvador—and all
    five have been murdered.‖
   No one has been convicted of any of the killings but Sanchez and his supporters believe
    that either street gangs or right wing militias are culpable.
   ―As the Salvadoran gangs compete in a bloody battle for numbers, power, and prestige,
    Homies Unidos‘ peace organizing stands in the way, says Sanchez.‖
   ―The right wing vigilantes, on the other hand, view all former gang members as a
    criminal element that needs to be eradicated.‖



                                            ix
   ―‘Former death squad members are involved in a ‗social cleansing‘ program,‖ targeting
    such people as ―alleged criminals, prostitutes, street children, and transvestites.‘‖

CC.     Juanita Darling, El Salvador’s War Legacy: Teen Violence, L.A. Times
  (August 9, 1999)………………………………………………………………………203

   In this tiny nation of 5.6 million people a wave of post-war violence has reached stunning
    proportions: 2,192 people were killed in the last six months of last year alone. ―That
    compares with 426 people in all of 1998 in Los Angeles, a city of 3.7 million.‖
   ―During the 12-year civil war that ended in 1992, many children were orphaned or
    abandoned. Some were spies or soldiers for the guerrillas or the army. Others…grew up
    in an atmosphere of stress and violence, especially prevalent in cities such as San Miguel
    that were at the edge of war zones.‖
   ―Now they are teenagers and society is paying for the neglect.‖
   ―‘As long as gang members were killing each other, the police just ignored it,.‖

DD.           Jorge Beltran, Victim Who Did Not Want to Join ‘MS’: Gang Member
  Captured Accused of Homicide, El Diario de Hoy (April 30, 2003) ………………206

   Guadron is accused of killing Jose Otoniel Alfaro, 23 years old, of 49 stab wounds,
    apparently because the youth did not want to be a part of the Mara Salvatrucha (MS), the
    gang to which Guadron belongs.
   Otoniel was a friend of local MS gang members, but went to live in a neighborhood
    controlled by a rival gang. That is why he was killed.
   Otoniel never wanted to join MS, despite repeated invitations to make ―the jump,‖ the
    ritual (generally a beating) by which one becomes a gang member.

EE.        Radio Netherlands, Youth Gangs, July 12, 1998, updated November 1999,
   http://rnw.nl/humanrights/html/gangs/html………………………………………210

   Young people turn to gangs seeking the respect, solidarity, and support, which they lack
    in their family, community, work or school.
   80% of gang members are males. The average age of a gang member is 18, while the
    youngest members are 11 and the oldest are 26.
   Hundreds of gang members are killed or wounded every year.
   70% of young people join one of El Salvador‘s two main gangs.
   70% of gang members admit that they take drugs, with marijuana being the most popular,
    followed by cocaine. Many gang members combine the two.

FF. Jorge Beltrán, Another Witness is Killed: They are at the mercy of gangs, El Diario de
    Hoy (February 18, 2004)…………………………………………………………...211

   Cruz was going to testify against two Salvatruchan gang members and had been
    threatened by telephone not to testify. The authorities were aware of the intimidation.
   Principal witnesses in crimes committed by gang members are assassinated by gang
    members interested in interfering with the judicial proceedings.


                                             x
   Cruz died of various gun shot wounds in his back.
   Cruz appears to have notified the authorities in charge of the proceedings about the
    threats, but they did not protect him.
   The authorities happily tell witnesses to testify, but do not protect them, even in serious
    cases.

GG.          Abbey Alvarenga, Witness Who Testified Against Gang Member is
  Gunned Down, El Diario de Hoy (February 5, 2004) ……………………………215

   ―One of the witnesses in the assassination of the child Melvin Daniel was shot dead
    yesterday by unknown individuals who intercepted him and gunned him down on the
    street.‖

HH.           Ruth DeGolia, El Salvador’s Teens Fighting Gang Violence, The Plain
  Dealer (December 16, 1998) ………………………………………………………221

   ―Paz described how she had tried to persuade her friends to leave the gangs and join in
    activities at Generation 21,‖ a youth center founded by teens to combat gangs and
    violence.
   ―Paz struggled to hold back tears as she told us of death threats she received from rival
    gang members. The threats forced one of her closest friends into hiding several months
    earlier.‖
   ―Tears streamed down Paz‘s cheeks as she acknowledged that her friend was probably
    already dead.‖

II. Donna DeCesare, The Children of War: Street Gangs in El Salvador, NACLA Report
    on the Americas (July/August 1998)…………………………………………….224

   ―According to the Pan American Health Organization, El Salvador‘s per capita homicide
    rate of 150 per 100,000 is the highest in the hemisphere, surpassing even Colombia.‖
   Violence is greater now than during the 1980s, ―when civil war grabbed international
    headlines and hundreds of thousands of peasant refugees escaping mayhem and economic
    collapse sought sanctuary in the crowded slums of Los Angeles.‖
   ―Rodrigo Avila, director of the National Civilian Police, admits that deported U.S. gang
    members are only one factor in the violent crime wave. He also blames crime rings,
    increased drug trafficking, an abundance of arms left over from the war, and disgruntled
    former soldiers who have become bandits.‖
   Salvadoran authorities rarely investigate the criminal violence of vigilantes acting against
    youth gang members.
   ―Several Salvadoran newspapers have published poll results in which nearly half of
    respondents support the ‗social cleansing‘ activities of the death squads that target those
    perceived as criminals.‖
   Nearly half the country‘s population is under 18 and three quarters of children live in
    poverty.
   800,000 adolescents between the ages of 13 and 18 comprise 14% of the total population.
    Only 40% attend school and 29% work. ―How the remaining 31%, roughly 249,000


                                             xi
    youths, occupy their time is unknown. But youth gang membership is growing at an
    alarming pace and some studies suggest that as many as 30,000 youths may belong to
    street gangs nationwide.‖
   Nearly all gang members have experienced some kind of deep trauma. ―Fellowship born
    of shared suffering and a lust for vengeance are attractions of gang life and, to a large
    degree, hallmarks of the adolescent‘s emotional world.‖
   The antiquated judicial system is rife with corruption. 77% of those incarcerated are un-
    convicted prisoners awaiting trial. ―Bribes buy murderers instant freedom while innocent
    indigents languish in unsanitary and overcrowded cells for up to two years before their
    cases are heard and dismissed.‖

JJ. Serge F. Kovaleski, Violence Targets Salvadoran Police; Civilian Force Created at
    End of Country’s Civil War Suffers Mounting Losses, The Washington Post (June 10,
    1999)………………………………………………………………………………..234

   ―Six years after a new national police force emerged from the ruins of El Salvador‘s long
    civil war, its members are being killed and wounded at one of the highest rates of any law
    enforcement agency in the world.‖
   Salvadorans question the adequacy of the 18,000-member National Civilian Police –
    drawn from the ranks of former guerrillas and soldiers as well as civilians, which is
    woefully short of resources.
   Between 18 and 21 people die by violence every day in El Salvador.
   ―…these gangs are not really fighting for anything—they just kill, like machines.‖
   Police recruits receive only the most cursory screening prior to admission to the force and
    they receive brief training.
   ―Critics add that the force has failed to put together a comprehensive anti-crime strategy
    and suffers from institutional weaknesses, such as inadequate supervision.‖

KK.     United States Immigration and Naturalization Service, El Salvador: Hardship
  Considerations – January 2000………………………………………………………236

   El Salvador is the most densely populated country in Latin America, with about 5.8
    million people living in an area roughly the size of Massachusetts.
   The US State Department reported that approximately 52% of the population lived below
    the poverty line in 1997.
   700,000 families—3.5 million of the country‘s 5.8 million—lived on $1 a day or less.
   According to the US Department of State, the minimum wage was insufficient to provide
    a decent standard of living for a worker and family.
   ―In 1997, the office of the Procurador de Derechos Humanos (PPDH), El Salvador‘s
    official human rights ombudsmen, estimated that 270,000 children under the age of
    fifteen worked, mostly as street vendors in the informal economy, and noted that besides
    losing their opportunity for education, these children frequently fell victim to sexual
    abuse and were exploited as prostitutes.‖
   Since the end of the civil war in 1992, El Salvador has experienced an unprecedented
    wave of violent crime. It has surpassed Colombia as the country with the highest



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    homicide rate in Latin America and is just behind South Africa as the global leader in
    murders per capita.
   Heavily armed criminal gang members total as many as 12,000 compared with the
    approximately 10,000 guerrillas who fought in the civil war.
   The country remains inundated with hundreds of thousands of illegal and legal arms,
    many of them high caliber automatic weapons left over from the civil war.
   Since the mid-1990s, more Salvadorans die annually due to violence than during the war.
   Warfare between youth gangs adds to the overall insecurity. There are between 10,000
    and 30,000 mostly teenage gang members in the country.

LL.       U.S. Department of Justice, Immigration and Naturalization Service
   Guidelines for Children’s Asylum Claims (December 10, 1998)…………………251

   ―Trauma can be suffered by any applicant, regardless of age, and may have a significant
    impact on the ability to present testimony. Symptoms of trauma can include depression,
    indecisiveness, indifference, poor concentration, long pauses before answering, as well as
    avoidance or disassociation. Some children may appear numb or show emotional
    passivity when recounting past events of mistreatment. Other children may give matter-
    of-fact recitations of serious instances of mistreatment. Trauma may also cause memory
    loss or distortion, and may cause applicants to block certain experiences from their minds
    in order not to relive their horror by the retelling. Inappropriate laughter can also be a
    sign of trauma or embarrassment. These symptoms can be mistaken as indicators of
    fabrication or insincereity.‖
   ―Although the same definition of a refugee applies to all individuals regardless of their
    age, in the examination of the factual elements of a the claim of an unaccompanied child,
    particular regard should be given to circumstances such as the child‘s stage of
    development, his/her possibly limited knowledge of conditions in the country of origin,
    and their significance to the legal concept of refugee status, as well as his/her special
    vulnerability.‖
   ―The harm a child fears or has suffered, however, may be relatively less than that of an
    adult and still qualify as persecution.‖




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