This is the third and final assignment in this course. Your client has received the Notice of Decision and written reasons from the Refugee Protection Division.

The decision is negative and can be found in its entirety on the "Instructions" tab below.

For this assignment, you will have to prepare a Notice of Appeal and a perfected Appellant's Record challenging the decision. More specifically,you will have to preparethree documents needed to challenge the decision on appeal:

(1)a Notice of Appeal, (2) written statement, and (3) memorandum of argumentin accordance, respectively, with subsection 2(3) and paragraphs 3(3)(d) and 3(3)(g) of theRefugee Appeal Division Rules. Carefully consider the new developments described in the instructions below.

As with the last assignment, this assignment requires you to draw on material you have learned throughout the course on the grounds and procedures for refugee claims in Canada (CLO 2 and 3), as well as to practice your advocacy skills (SVO(3) and(5)).

Instructions Assessment Academic Integrity and Gen AI RPD Decision and New Developments Your client received the written decision on April 16, 2025.

In preparing your client's appeal, you may rely on all exhibits that were provided in Assignment 2. (See Consolidated List of Documents below.)

Consolidated List of Documents RPD, CLMT, MIN in the table below are Document Numbers.

Consolidated List of Documents RPD CLMT MIN Description Comments 1

Basis of Claim narrative

2

Immigration and Refugee Board of Canada, National Documentation Packages - Hungary (September 27, 2024).

3

Claimant's Documentary Evidence

4

Claimant's Country Condition's Evidence (which you submitted in Assignment 2)

In addition to the information from Assignments 1 and 2, you should take into account the following new development/s.

On August 18, 2025, your client informed you that there was an anti-Roma march in his mother's neighbourhood in Hungary. The mother has sent a letter about the event.

New Documents RPD Decision - the panel determines that the claimant is neither a Convention refugee under section 96 of the IRPA nor a person in need of protection under paragraph 97(1)(a) or 97(1)(b) of the IRPA. The panel therefore rejects his claim for refugee protection.

Letter from mother - This letter confirms that on August 18, 2025, there was an anti-Roma protest in our neighbourhood. Our neighbourhood is about 90% Roma.

Submissions You have been instructed to prepare three documents needed to challenge the decision on appeal, as well as the GDipICL Undertaking for Academic Integrity:

a Notice of Appeal a written statement a memorandum of argument in accordance with the RAD Rules Understanding and complying with the specific rules applicable to these submissions is an important part of this assignment. As such, a simple checklist of the requirements is not provided here.

As you put together the assignment, be sure to review the applicable Refugee Appeal Division Rules. You may also find it useful to review the Immigration and Refugee Board's Appellant's Guide, as well as other information on the Board's website. The formatting and all other technicalities of the documents you submit should comply with those rules, as well as any other applicable regulations or policy instruments.

Your submissions must include:

The Notice of Appeal, which can can be found on the IRB website titled "Notice of Appeal Form" The written statement should be a brief, 100- to 150-word document. The contents of the statement are found in Rule 3(3)(d) of the RAD Rules. Be sure to consider whether to seek to admit new evidence under subsection 110(4) or whether to request an oral hearing under subsection 110(6) of the Immigration and Refugee Protection Act. If you are submitting new evidence and/or requesting an oral hearing, you should make submissions in the memorandum on why the RAD should admit new evidence and/or grant an oral hearing. To assist your instructor in grading this assignment, if you decide not to include new evidence or request an oral hearing, please provide your reasoning on a separate page attached to the end of your memo. (In practice, this would not be a part of an Appeal Record.) A persuasive RAD Memo should refer to evidence (new evidence, evidence entered at the RPD hearing, NDP, etc.) as well as case law to support their arguments about why the RPD erred. Target length RAD Rules allow a memorandum up to 30 pages. Your memo for this assignment should be 2800 words. Please include your word count at the end of the memo.

A "grace" range of up to 200 words is permitted. Anything above or below that range will impact your mark for "Written Advocacy and Communication". See the rubric. 201 - 300 words over or under will be considered an "error" and 300+ over or under will be considered a "significant error." Your submission will be assessed based on three main criteria:

Written Advocacy & Communication Skills (33.3%) You will be assessed onpersuasiveness in actively advancing your client's interests, within the bounds of law and professional obligations, including effectively mobilizing evidence and relevant case law. You should demonstrate general proficiency in written communications while presenting submissions which are clear and coherent. You are expected to refer to the evidence and conduct case law research to support your arguments. Legal Research (33.3%) You will be assessed on your ability to find cases that support your argument and to anticipate and address cases that may militate against the result you are seeking. You should use online databases to find additional cases that are current, relevant, and binding. Find and utilize at least three additional cases in your memo. These cases should not be cases covered in class or your readings. The cases must have correct citations in the footnotes of your memorandum along with a live link to the CanLii paragraphs. Application of Foundational Knowledge (33.4%) You will be assessed on yourcompliance with RAD Rules and the statutory framework for appeals to the RAD. You should present sound legal arguments and strategies, based on acomplete and accurate understanding of the relevant case law and statutory or regulatory frameworks.