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"Aquino offered evidence that MS-13 subsequently killed his cousin, Vidal, and had previously killed his uncle, both of whom were members of Mara 18. We cannot agree with the Government’s characterization of this evidence as describing nothing more than the “general conditions of upheaval and unrest associated with gang violence.” Govt’s Br. 31 (internal quotation marks omitted). See Crespin-Valladares, 632 F.3d at 126 (rejecting the BIA’s characterization of “the threat of death” as “mere threats and harassment”). ... For the foregoing reasons, we grant Aquino’s petition for review and remand the case to the BIA for proceedings consistent with this opinion." - Aquino Cordova v. Holder, July 18, 2014. [Hats off to Linda Anna Dominguez!]