EXPERT REPORT OF DR. EVERARD MEADE July 12, 2016 1. Counsel for has asked me to offer expert testimony to assist the Court in evaluating his claim for asylum. I respectfully submit this report, and any corresponding testimony at the hearing, in order to: (1) provide background regarding the events in question and the areas of Mexico in which they occurred; (2) explain the country conditions in Mexico, both in the present and in the period extending back to 2006; (3) offer my opinion on the consistency of the declaration of Mr. with the conditions in Mexico at the relevant times and in the relevant places; and (4) discuss the likelihood that Mr. would be harmed if returned to Mexico. 2. As the Director of the Trans-Border Institute at the University of San Diego, I monitor the conditions in Mexico on a continual basis. As a historian of Mexico and Central America focused on the relationships between violence, memory, and the law, I have tracked patterns of violence and their relationship to the criminal justice system since at least 1998. See attached (curriculum vitae). I have testified before Immigration Courts across the country in conjunction with removal proceedings and asylum applications. 3. Before preparing this report, I reviewed and consulted a number of academic, journalistic, and government sources (from Mexico and the United States), many of which are cited herein. As discussed herein, I conducted certain independent research using resources that I customarily consult when researching country conditions in Mexico and the impact of the latest developments in drug trafficking, organized crime, and law enforcement operations on basic human rights conditions, in particular. This report is also based on my own ongoing research in Mexico. Page 043 4. For the reasons discussed herein, I conclude that Mr. description of events is consistent with country conditions in Mexico at the relevant times and places. 5. For the reasons discussed herein, I also conclude that Mr. , his wife, and son would face extreme danger if returned to Mexico. In light of the current conditions in Mexico and his account of events to date, I believe he and his family would very likely face kidnapping, torture, and/or murder if he were returned to Mexico. 6. For the reasons discussed herein, I further conclude that Mr. and his family members could not safely relocate to Michoacán or anywhere else in Mexico. In light of the current conditions in Mexico and his account of events to date, I believe that they would very likely be identified and targeted for extortion, kidnapping, torture and/or murder if he were to attempt to settle in Jalisco or anywhere else in Mexico. A. Beyond the body count – The violence of the current drug war in Mexico (since 2006) has caused a much greater negative impact on Mexican society than the homicide rate alone might suggest, especially in Mr. home state of Michoacán (on the border with Jalisco) during the period from 2013 to the present. 7. Most accounts of the present “drug war” in Mexico begin in 2006, especially those that explore its impact on ordinary civilians. At the national level, the homicide rate declined by nearly half from the early-1990s to 2007, to levels lower than most American cities.1 This decline was part of a relatively steady downward march dating all the way back to the 1930s, and one which avoided the marked escalation in homicides across the United States and urban Latin America from the early 1960s through the early 1980s.2 By this indicator, 1 Kimberly Heinle, Octavio Rodríguez Ferreira, and David A. Shirk, “Drug Violence in Mexico: Data and Analysis Through 2013” (Justice in Mexico Project, University of San Diego, April 2014), stable URL: http://justiceinmexico.files.wordpress.com/2014/04/140415-dvm-2014-releasered1.pdf 2 Pablo Piccato, “El significado político del homicidio en México en el siglo XX,” Cuicuilco, Vol. 15, No. 43, 56-78; David Shirk and Alejandra Ríos Cázares, “Introduction: Reforming the Administration of Justice in Mexico,” Reforming the Administration of Justice in Mexico, Wayne Cornelius and David Shirk, eds (South Bend: The University of Notre Dame Press/Center for U.S.-Mexican Studies, 2007), 1-49; Fernando Escalante Gonzalbo, “Homicidios 2008-2009 La muerte tiene permiso,” Nexos, 1 enero 2011. Stable URL: http://www.nexos.com.mx/?p=14089 Page 044 Mexico was one of the safest and most stable countries in the Western hemisphere for most of the twentieth century. 8. Beginning in late 2006, the change was dramatic. President Felipe Calderón (2006-2012) initiated major anti-drug operations across the country – including the deployment of 45,000 troops and partial military occupations of the states of Michoacán and Baja California. Calderón deployed 4,000 troops to Michoacán (the president’s home state), who destroyed more than 2,000 marijuana plots the first week. By 2009, there were 7,000 soldiers and other federal forces deployed in the state; 10 mayors and 20 other local officials had been arrested for ties to drug traffickers; and a naval blockade closed all of Michoacán’s Pacific ports. The homicide rate shot up, with increases year-over-year of 58% in 2008, 41% in 2009, 30% in 2010, and 5% in 2011. Homicide declined in 2013 and 2014, but increased by 9% in 2015 to 14.2 per 100k, and the rate still remains near historic highs. 9. Exactly how many of these murders are directly attributable to the illicit drug trade and organized crime is a matter of some contention. Rigorous studies from government agencies, academic researchers, and news organizations estimate that 40-60% of Mexico’s recent homicides can be attributed to organized crime.3 The breadth of the definition of an “organized-crime-related homicide” – whether it attempts to capture only murders directly attributable to their members or business interests, or all those facilitated by the environment they create – accounts for most of the variation. There’s little substantive variation in the data, and there’s little disagreement that killings related to organized crime account for the lion’s share of the dramatic increase in homicides since 2007. A wave of murder rolled over Mexico by historical standards, and much of it was related to organized crime. 3 Heinle, Rodríguez, and Shirk, 18-21. Page 045 10. By comparison to other places in the world, the body count alone does not amount to a “war” that has touched nearly every aspect of Mexican society, nor does it justify the intense media coverage that the most spectacular acts of violence and the most infamous gangsters have generated. Despite the dramatic rise since 2007, Mexico’s overall homicide rate remains slightly lower than the regional average for Latin America. For the entirety of the present “drug war,” homicide rates in neighboring Guatemala and El Salvador have remained more than twice as high as in Mexico and in Honduras it has been four times worse.4 Mexico’s homicide rate is also considerably lower than that of other large middle- income countries in Latin America, including Colombia, Brazil, and Venezuela.5 11. On the other hand, in particular cities and regions within Mexico, the homicide rate is high by any standard. One of the most striking features of the explosion of homicides after 2007 was their geographic spread from a small number of regional hotspots across the country. In border towns like Tijuana, Nuevo Laredo, and Ciudad Juárez, or regional organized crime hubs like Culiacán and Acapulco, intense violence began at least a couple of years earlier, complicating any simple association with the “war” on drug cartels declared by the Calderón administration, but validating the broader association between a series of conflicts involving organized crime and a dramatic rise in murder. This general trend repeated itself in micro as the conflict spread and the murder rate shot up in previously peaceful areas. 12. According to the non-governmental organization Semáforo Delictivo [The Crime Traffic Light] (which has contracts with government agencies across Mexico to monitor crime data), Mr. home state of Michoacán has the 6th highest murder rate in Mexico 4 According the Global Study of Homicide compiled by the United Nations Office on Drugs and Crime (2014), the homicide rate in Mexico was 21.5 per 100k in 2012. In 2012, the average rate for South America and Central America in was 25.7, and for Central America alone was 34.3. For the period 2006-2012, the period of the “drug war,” the homicide rate in El Salvador averaged 59.9, Guatemala 43.1, and Honduras 69.9 per 100k. 5 In 2012, the homicide rate in Mexico was 21.5, Brazil 25.2, Colombia 30.8, Venezuela 53.7 per 100k inhabitants. http://www.unodc.org/gsh/en/data.html Page 046 (19.8 per 100k population), and more than double the national rate of targeted assassinations (11.3 per 100k vs. 6.7 per 100k). By way of comparison, in 2014 Michoacán had more than twice as many targeted assassinations per capita as the state of Illinois had murders (5.3 per 100k). In 2014, the states with the largest number of organized-crime homicides in Mexico were Chihuahua (1,143), Guerrero (1,075), Sinaloa (747), Michoacán (594), and Jalisco (518).6 13. More recent data indicates that conditions have worsened in Michoacán since 2014. In the first 3 months of 2016, there were 231 executions carried out by organized crime in Michoacán, second only to the state of Guerrero.7 14. Organized crime controls much of the violence in the region where Mr.