2023 RLLR 246
Citation: 2023 RLLR 246
Tribunal: Refugee Protection Division
Date of Decision: November 30, 2023
Panel: Joseph Berkovits
Counsel for the Claimant(s): Karina Thompson
Country: Georgia
RPD Number: TC3-23215
Associated RPD Number(s): N/A
ATIP Number: A-2024-01360
ATIP Pages: N/A
DECISION
[1] XXXX XXXX, a citizen of Georgia, (the claimant), claims refugee protection pursuant to section 96 and 97(1) of the Immigration and Refugee Protection Act, (the IRPA).
[2] The names of all third parties have been redacted to their initials for safety and privacy reasons.
DECISION
[3] For the reasons given below, the panel finds that the claimant is a Convention refugee because he has established that he faces a serious possibility of persecution should he return to Georgia on the grounds of his political opinion.
ALLEGATIONS
[4] The claimant alleges that, in summary, that as a result of his support for an opposition political party in Georgia, the United National Movement, (UNM), he faced ongoing threats and violent treatment at the hands of supporters of the governing political party, the Georgian Dream.
Identity
[5] The claimant’s personal identity as a citizen of Georgia has been established by a certified copy of his passport.
[6] The panel therefore finds that the claimant has established his identity, on a balance of probabilities.
Nexus
[7] Given the claimant’s allegations, his claim will be assessed pursuant to section 96 of the IRPA, with the nexus being his political opinion.
Credibility
[8] When a claimant swears or solemnly affirms that certain facts are true, this creates a presumption that they are true, unless there is valid reason to doubt their truthfulness. Hence, as a corollary, there is no general legal requirement for a claimant to corroborate sworn or solemnly affirmed testimony that is uncontradicted and otherwise credible.
[9] In terms of the claimant’s general credibility, and in light of the evidence below, the panel has found him to be a credible witness and the panel therefore accepts what he has alleged in his oral testimony and in his basis of claim form. The panel found his testimony to be credible because there were no major contradictions or omissions that went to the core of his claim, and because his testimony was spontaneous and detailed. Additionally, the panel found his corroborative evidence to be reliable and trustworthy, and as such, the panel assigns it full weight in supporting the claimant’s credibility in relation to his allegations.
[10] In his detailed narrative and in his testimony, the claimant provided a credible account of his support for and activism on behalf of the United National Movement (UNM), an opposition party in Georgia. The claimant testified, credibly, about how he came from a family that was known in his community for its support of the less fortunate by XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. The claimant provided numerous letters of reference which described his charitable work. For example, one member of his community, SS, wrote, “It’s very sad that he is no longer in our village. My whole family misses him very much. I want to thank him because for 4-5 years I have not XXXX XXXX XXXX XXXX. [The claimant] always helped me a lot. My husband is disabled, I have 2 children and we have difficult times….”[1] A neighbour, VM, wrote about how the claimant “is a very good person. His family, his parents and his wife and children are loved by [the] entire village. The whole village knows that [the claimant] is a very kind person. [The claimant] personally helped… my family. We have [been] short of money. I remember one time water fell from the roof of our house and [the claimant] gave me money to replace the roof. He used to send me XXXX XXXX XXXX XXXX XXXX in summer.”[2] Another neighbour also wrote that the claimant “is said to be the first person in the village with his kindness, justice and honesty, and this is true. He helped the entire village population as much as possible.” [3] The local monastery also wrote to confirm the claimant’s charitable donations of XXXX from 2015 through to 2022.[4] The panel acknowledges how in the letters that the claimant provided from his neighbours and community members his support for the UNM is also frequently mentioned, and that this charitable work, which brought the claimant the popularity that it did in his community, also likely made him a more effective advocate for the UNM party.
[11] The claimant testified, credibly, that he first became inspired to become politically active when a Russian politician came to Georgia in XXXX of 2019, at the invitation of the governing Georgian Dream party, and spoke from inside the Georgian parliament in the Russian language, in what the claimant described was widely perceived as an attack on Georgian sovereignty by Russia. The claimant, who was concerned about Russian influence, testified, credibly, about how he viewed the United National Movement as a party that supported ideas embraced by Western countries, which, in his view, was the direction that Georgia should aspire to. The claimant testified about how this speech by the Russian politician spurred him to attend protests in the capital city of Tbilisi, where he witnessed how the police mistreated the protesters, and then, by the XXXX of that year, to officially join the UNM. By the XXXX of 2020, the claimant detailed how he started to campaign upon behalf of the UNM at the parliamentary elections. The claimant testified, credibly, about how he sought to explain the differences between the UNM and the governing Georgian Dream party by travelling throughout his village and in neighbouring villages. One of the claimant’s neighbours, VM, wrote a letter, where she confirms how the claimant “was a member of the ‘United National Movement’ and was very active during the election, meeting the residents of the district and talking to them.”[5] A letter supplied by an UNM official confirms the claimant’s activities on the party’s behalf, as well as the danger that these efforts brought him at the hands of the Georgian Dream supporters.[6]
[12] By XXXX of 2020, the claimant detailed, after having received a number of verbal threats by local government officials as well as threatening phone calls, on his way inside his house, he suffered his first attack by Georgian Dream supporters, an assault that caused him to be hospitalized. The claimant described how his attackers were making demands that he stop his political activities. According to the claimant, his assailants only left because the neighbours came outside to his rescue, with one of them driving him to the hospital. By way of corroboration, a neighbour, SS, wrote how they “heard the sound of screaming. I immediately went out to the street and saw that the [claimant] was being beaten in front of the courtyard door. His wife… was shouting that her husband was being killed and asked for help. I immediately ran to them. When the attackers saw me, they got into the car, I remember it was a Jeep. They cursed [the claimant], calling him an enemy, bastard nationalist. [The claimant’s] wife and I immediately took [the claimant] to [the…] Hospital.”[7] The claimant further detailed how, by XXXX of 2021, while he was volunteering on behalf of the UNM in the local elections that were taking place, his house was covered in graffiti that made disparaging comments about his support of the UNM leadership and which called him a “traitor” to Georgia. The claimant provided photos of this graffiti on his home, together with a translation.[8] The claimant then detailed a visit by Georgian Dream supporters to his home, some two days after his attempt to report the graffiti to the police, in an attempt to persuade him to switch his support to him, and which culminated in threats being made to the claimant when he refused.
[13] Then, by the next month, XXXX of 2021, the claimant described how he was once again attacked by Georgian Dream supporters, with the claimant detailing how he recognized one of his attackers from the previous assault. The claimant then detailed how he nevertheless continued to participate in UNM protest rallies in XXXX, 2021, XXXX, 2022 and in XXXX, 2022. By way of corroboration, the claimant provided two photos of himself present at the very large protest rallies in XXXX of 2022.[9] These were protests, the claimant testified, in response to the imprisonment of the former President of Georgia who had led an UNM government prior to the election of the Georgian Dream. Whereupon in XXXX 2022, the claimant detailed, he was first telephoned with a threat and then, that same day, attacked so severely that he lost consciousness and woke up in the hospital. By way of corroboration, the claimant provided a letter from his neighbour who, by the time he was able to ward off the attackers, found the claimant in an unconscious state and then called an ambulance.[10] In the wake of this latest attack, the claimant described how he made the decision to leave Georgia for his own safety, first making an unsuccessful attempt to hide in the capital city, where he was found by Georgian Dream supporters and threatened. The claimant’s friend with who he stayed wrote a letter to confirm how was living with him during the timeframe that the claimant described.[11]
[14] By way of further corroboration, the claimant also provided hospital reports that detailed the treatment that he required in the wake of attacks in XXXX of 2020, XXXX of 2020 and XXXX of 2021.[12] The claimant’s wife also wrote a letter detailing how she does not “want to see [her] husband beaten like he was in XXXX 2020, XXXX, 2021 and XXXX, 2022. The last time he was beaten in XXXX, he was in such a state when I saw him at the hospital, I became sick. I don’t want to see him in this state again.”[13]
[15] The claimant testified, credibly, that throughout these violent and threatening encounters, the police were of essentially no assistance to him, and that they were openly hostile to him on account of his support for the opposition UNM. The claimant testified, credibly, about how the police, who came to interview him in the hospital in the aftermath of several attacks, demonstrated no real willingness to investigate the crime, and that they were hostile to him when he made inquiries about their progress. As the claimant testified, credibly, it was his impression of the police, in his dealings with them, that they were obviously not interested in helping him because they were there to do the bidding of the governing Georgian Dream party, because they were heavily politicized, and because they knew that he was an UNM supporter. For example, the claimant detailed how he went to the police to make a report about the threatening graffiti on his home, and when he pressed for an investigation, he was ordered to leave the police station. The claimant also testified about how he witnessed the police acting with violence against anti-government protesters during the course of the rallies that he attended in XXXX of 2019 in the wake of the Russian parliamentarian’s visit to Georgia. Even though the panel acknowledges that the claimant was attacked in front of neighbours, the police in the reports that the claimant submitted into evidence, make the determination that there are no witnesses to interview. By way of corroboration, the claimant provided a police report that makes reference to his complaint in the wake of the XXXX, 2020 attack and which concludes by stating the case was “closed” due to lack of evidence and witnesses.[14]
[16] In light of this credible evidence, the panel finds that the claimant has established that he has expressed a political opinion on behalf of the opposition UNM party in his community, and in so doing, has brought himself into the orbit of violent and dangerous supporters of the governing Georgian Dream party, who are his agents of persecution. The panel also finds that these agents of persecution are the beneficiaries of at least some degree of state impunity at the hands of such agents of the state as the police and other government officials.
[17] The panel also finds that the claimant faces a forward-looking possibility of persecution at the hands of these Georgian Dream supporters. As the claimant’s wife wrote in her letter, “I know that if [claimant] returns to Georgia, he will be persecuted and harassed again by the Georgian Dream. [He] is such a kind person that he cannot stand injustice, therefore he will start [to be] active again in the ranks of the United National Movement.” She also stated that “we have no hope for the police. His enemies don’t stop, they keep looking for him, they have already come to me 3 times, the last time was in XXXX 2023, they are looking for him everywhere, they found him earlier in Tbilisi.”[15]
[18] The panel acknowledges that the claimant came to Canada via a route that consisted of brief or relatively brief stays, first for about two weeks in XXXX, where he obtained a visa to XXXX, and then for about three days, whereupon he crossed over to the United States, where, after being detained by border officials, and after a total stay of about one month and one week, he crossed over to Canada, where he has a cousin who resides in the country. At the hearing, the claimant testified, credibly, that it had been his plan to go to Canada, where his cousin had encouraged to claim asylum, because, he was told, he would be safe and be treated fairly. The claimant testified, credibly, that he did not claim asylum in XXXX, because it was his understanding that he would not be eligible for asylum in that country, and because he feared deportation back to Georgia. He further testified, credibly, that he did not claim asylum in XXXX because he knew no one there, and that it was his plan to cross through there to ultimately reach Canada. While the claimant did reside in immigration detention in the United States, which prolonged his stay in that country, he testified, credibly, that he filled in only a few preliminary forms and was not properly interviewed or provided with legal assistance or translation that was sufficient for him to truly understand what his rights were in that country, and as such, he did not file a claim for asylum in that country. The ICAC disclosure also confirms as well as the Freedom of Information request filed by the claimant’s counsel[16] disclose no asylum application in the United States. In light of the claimant’s credible testimony and evidence, the panel finds it reasonable and credible that the claimant did not claim asylum in any of the countries that he passed on through to his ultimate destination of Canada, and as such, the panel finds that the credibility of his subjective fear of persecution is not undermined, nor is the credibility of the core of his allegations.
[19] Given the above credible evidence, the panel believes what the claimant has alleged on a balance of probabilities. In light of this credible evidence, the panel finds that the claimant has established a subjective fear of persecution on the basis of his political opinion.
Objective evidence
[20] The UNM or United National Movement, which was formed in 2001, has been described as a “centre-right and nationalist” party, with a platform that “focuses on economic and government reform, closer ties with the EU and the US, and restoring control over Abkhazia and South Ossetia.”[17] It has been observed that, subsequent to the 2012 parliamentary elections, which resulted in the loss of the UNM party, and the election of the Georgian Dream, “UNM members reported arrests- including the UNM’s general secretary, a former minister of internal affairs, defense minister, and prime minister- due to their political affiliations or activities… [M]any senior members of the UNM including the former Prime Minister and current leader… are ‘either in jail as a result of court judgements or are in preventative detention,’ while others have fled the country following the country’s 2012 parliamentary elections and 2013 presidential elections,” which resulted in the election of the Georgian Dream.[18] According to Human Rights Watch, during the period leading up to the June and July 2014 municipal elections, there have been “multiple allegations of pressure on opposition candidates to withdraw their candidacies, including actual withdrawals in more than a dozen municipalities, disruption of opposition gatherings, and several episodes of violence against candidates’ campaigners.”[19] There are also reports of “dismissals of government employees from local institutions for their alleged association with [the] former ruling party, [the UNM].[20]
[21] According to objective observers, the ruling Georgian Dream party has “repeated the historical pattern in Georgia of transforming the country’s political regime into a hybrid regime in which the governing party controls all branches of the state. The government has adopted the constitution to its own needs and increasingly antagonizes the leading opposition party UNM [United National Movement] as an enemy rather than as a competitor. The government rejected growing criticism from civil society as politically biased. The GD [Georgian Dream] majority did not exercise self-restraint or stick to democratic standards. The state has violently dispersed several demonstrations led by a growing opposition. … To fill its policy void, it launched a polarizing campaign against Mikhael Saakashvili and his UNM representatives in Georgia.” [21]
[22] In light of the objective evidence above, the panel finds that the claimant’s fear of persecution on the grounds of his political opinion, which he has expressed in support of the opposition UNM party, a party that has been subjected to abuses by the governing Georgian Dream party, has been established by the objective evidence. Therefore, the panel finds that the clamant has a well-founded fear of persecution.
State Protection
[23] According to the 2022 United States Department of State Country Report on Human Rights Practices in Georgia, “Significant human rights issues included credible reports of: torture or inhuman, cruel, or degrading treatment; arbitrary arrest or incarcerations; serious problems with the independence of the judiciary, along with investigations and prosecutions widely considered to be politically motivated; arbitrary or unlawful interference with privacy, serious restrictions on freedom of expression and media, including violence and threats of violence against journalists, substantial interference with the freedom of peaceful assembly and freedom of association…. The government took steps to investigate some officials for human rights abuses, but impunity remained a problem.”[22]
[24] In the most recent national parliamentary elections in Georgia, in October 2020 and the second-round runoffs in November of 2020, international observers for the OSCE (Organization for Security and Cooperation in Europe) noted that there were “pervasive allegations of pressure on voters and blurring of the line between the ruling party and the state,” which “reduced public confidence in some aspects of the process. The [OSCE] mission particularly highlighted concerns about ruling party dominance in election commissions. Other problems included widespread reports of intimidation of party supporters and public-sector employees. The OSCE also reported continuing shortcomings in the complaints and appeals process, concluding that ‘the systemic rejection of the majority of complaints on formalistic grounds significantly limited the opportunity to seek legal remedy.”[23] It has been alleged by opposition parties that there were so many missing ballots in certain districts that this was indicative of “widespread ‘carousel voting,’” as well as “voter intimidation, vote buying, violations of ballot secrecy, obstruction of journalists and domestic election observers, and inaccurate and altered vote tabulation at the precinct and district level.”[24]
[25] There has been documentation of violence and “harassment” against UNM members after the 2012 Georgian Dream campaign victories, with numerous incidents including violent “mobs disrupting UNM campaign events… [with] groups of individuals ‘directly linked and organized by’” the Georgian Dream party. These attacks would often result in UNM members being hospitalized. Sources also report that “the authorities failed to prosecute the assailants ‘despite the fact that they were publicly identified.’”[25] While there have been documented incidents of the police providing protection to UNM members from “incidents of violence,” it has also been indicated that the police have “failed to provide protection to UNM members.” For example, during an incident of mob violence impacting upon four UNM rallies, it was documented that the police appeared on the scene after the attacks and failed to intervene to prevent any violence.” There have been other examples documented of the police failing to intervene to stop violence against UNM members, even when they were warned in advance of possible violence, including at large UNM rallies, with police being present, but with the not trying to “diffuse…prevent violence or stop the attacks” upon an UNM office in 2015. [26] On the other hand, peaceful protesters against the government have found themselves unfairly targeted by the authorities and the police. The Public Defender’s Office also expressed concern about reports of arbitrary detentions, noting that “law enforcement officials actively resorted to administrative detention of demonstrators, which in many cases did not meet the requirements of necessity and they took the form of unjustified interference with freedom of assembly.” These arrests took place in the context of the “majority of these protests [being] peaceful….”[27]
[26] Prior to his return to the country, former President of Georgia and United National Movement Leader Mikheil Saakashvili was “tried in absentia and convicted on various charges, including abuse of power…”[28] The Public Defender’s Office has complained that Mr. Saakashvili, who is currently detained in Georgia, has had his health “deteriorated sharply.”[29] The Special Investigation Service or SIS which has been investigating “alleged inhuman treatment” of the former President as well as more generally, had a mandate to “investigate abuse of power by law enforcement officials and to protect personal data,” was abolished in December of 2021, in an expedited vote that was organized by the ruling Georgian Dream party which held all three readings of the bill in less than one week. This vote, took place “consultation with key stakeholders and in the face of strong domestic and international criticism.”[30] For example, the Organization for Security and Cooperation in Europe’s (OSCE) Office for Democracy Institutions and Human Rights “raised concern that the legal changes would affect ‘protection from serious human rights abuses by law enforcement officials, reducing the state’s ability to effectively investigate allegations of torture, ill-treatment and deaths in custody, including through undermining the State Inspector’s Service and the expansion of its mandate to cover a broad range of crimes outside of its originally envisaged purpose.”[31] Two separate agencies were put into the place of the SIS, which, ‘in contrast to the previous mandate to investigate all law enforcement equally,” are not authorised “to investigate certain crimes committed by prosecutors, such as murder and bodily harm,” and the State Inspector, who “had three years remaining in her constitutionally mandated term,” was removed from office.”[32]
[27] In light of this objective evidence, the panel finds should the claimant return to Georgia, given his support of the opposition UNM party, and the state’s treatment of those who oppose its political power, adequate state protection will not be available to him. As such, the panel finds that the claimant has rebutted the presumption of state protection.
Internal Flight Alternative (IFA)
[28] The test to be applied in determining whether there is a viable internal flight alternative (IFA) is two-pronged.[33]
[29] Firstly, the panel must be satisfied, on a balance of probabilities, that there is no risk to life or risk of cruel and unusual treatment or punishment or danger of torture in the proposed internal flight alternative location, or, on a balance of probabilities, there is no serious possibility of persecution in the proposed internal flight alternative location. This prong is known in plain language as the “safety” part of the test.
[30] Secondly, the conditions in the proposed internal flight alternative location must be such that it would not be objectively unreasonable under the circumstances, including those particular to the claimant, for him to seek refuge there. This prong is known in plain language as the “reasonableness” part of the test.
[31] Both of these prongs must be satisfied for a finding that the claimant has a viable internal flight alternative.
[32] Given the claimant’s demonstrated political involvement and his likely well-known efforts in his community on behalf of the UNM, his agents of persecution likely have the motivation to pursue him in the foreseeable future. Having considered the credible evidence given by the claimant, together with the objective evidence of country conditions and state protection, the panel finds that these agents of persecution are, effectively, agents with many of the indices of state power. The panel finds this to be particularly the case because the political opinion that the claimant is expressing is on behalf of a party that is in opposition to the governing political party, and because of the objective evidence, as detailed above, that establishes that the government and its agents, which include the police, have persecuted members of the opposition, and in many ways treats the members of the UNM, as one objective observer commented, as an “enemy rather than as a competitor.”[34] The claimant has also provided credible evidence to establish that the agents of the governing party, the Georgian Dream, are able to operate with, at a minimum, state impunity, and, likely worse, given the lack of interest the police has demonstrated in investigating a series of violent attacks upon the claimant as well as a graffiti attack on his home, as determined above.
[33] Given that the state is likely an agent of persecution, the claimant is left to confront an agent of persecution with the means to locate him throughout the country. The panel also acknowledges that the claimant has already attempted to relocate within the country, moving from his hometown to the capital city, where he testified, credibly, he was threatened again by Georgian Dream supporters. The panel also relies upon objective evidence of the state’s ability to monitor the “combined records of civil status, identity documents, and residential registration in one new entity,” the Civil Registry Agency, or CRA, which “”includes basic information on every Georgian citizen including their name, address, and national ID number,” with the police receiving “periodic updates from this registry “listing persons who have registered a new address in the district.”[35]
[34] Accordingly, the panel finds that test for a viable internal flight alternative fails on the first prong of the test, safety.
[35] Therefore, the panel finds that there is no viable internal flight alternative for the claimant in his particular circumstances throughout Georgia.
CONCLUSION
[36] Based on the totality of the evidence, the panel finds that the claimant will face a serious possibility of persecution pursuant to section 96 of the IRPA, should he return to Georgia.
[37] His claim for protection is therefore accepted.
——— REASONS CONCLUDED ———
[1] Claimant Disclosure, Exhibit 5, Letter from community member, SS, p. 93, (translation).
[2] Claimant Disclosure, Exhibit 5, Letter from Neighbour VM, p. 87, (translation).
[3] Claimant Disclosure, Exhibit 5, Letter from Neighbour NN, p. 75 (translation).
[4] Claimant Disclosure, Exhibit 5, Letter from Monastery, p. 99, (translation).
[5] Claimant Disclosure, Exhibit 5, Letter from Neighbour VM, p. 87, (translation).
[6] Claimant Disclosure, Exhibit 5, UNM party letter of reference, p. 26. (translation).
[7] Claimant Disclosure, Exhibit 5, Letter from Neighbour SS, p. 81, (translation).
[8] Exhibit 9, Claimant Disclosure, photo of graffiti, with translation.
[9] Claimant Disclosure, Exhibit 5, Photos, pp. 55- 56.
[10] Claimant Disclosure, Exhibit 5, Letter from Neighbour NN, p. 75. (translation).
[11] Claimant Disclosure, Exhibit 5, Letter from Friend KG, p. 63 (translation).
[12] Claimant Disclosure, Exhibit 5, Hospital Reports, pp. 39- 54. Also Exhibit 7, Hospital Report with amended translation.
[13] Claimant Disclosure, Exhibit 5, Letter from the Claimant’s Wife, p. 58, (translation).
[14] Claimant Disclosure, Exhibit 5, Police Report, dated XXXX XXXX, 2023, p. 34, (translation).
[15] Claimant Disclosure, Exhibit 5, Letter from the Claimant’s Wife, p. 58, (translation)
[16] ICAC package, Exhibit 4, Claimant Disclosure, Exhibit 8, USA documents obtained by USA FOIA request.
[17] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 4.5, p. 1.
[18] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 4. 5, pp. 6- 7.
[19] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 4.5, p. 8.
[20] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 4.5, p. 12.
[21] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 1.9, p. 3.
[22] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 2.1, p. 5.
[23] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 2.1, pp. 34- 35.
[24] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 2.1, p. 35.
[25] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 4.5, p. 10.
[26] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 4.5, p. 14.
[27] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 2.1, p. 11.
[28] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 2.1, pp. 1- 2.
[29] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 2.1, p. 4.
[30] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 2.1, p. 5.
[31] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 2.1, p. 5.
[32] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 2.1, p. 5.
[33] Rasaratnam v. Canada (Minister of Employment and Immigration), [1992] 1 F.C. 706 (C.A.).
[34] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 1.9, p. 3.
[35] Exhibit 3, National Documentation Package for Georgia, (October 31, 2023), Item 10.1, pp. 4- 5.