against the backdrop of the documented frequency with which so-called immigration
consultants defraud immigrants in comparable situations. See Anne E. Langford, What’s
in a Name?: Notarios in the United States and the Exploitation of a Vulnerable Latino
Immigrant Population, 7 Harv. Latino L. Rev. 115 (2004); see also Barroso v. Gonzales,
— F.3d —, No. 03-72552, 2005 WL 3079103, at *1 (9th Cir. Nov. 18, 2005) (“Although
[the preparer] told [the applicant] that he was an attorney, he was not; instead he was a
‘notarial,’ or an immigration consultant. These people, also called ‘notarios,’ are
notorious . . . for preying on the immigrant community.”). Asylum applications prepared
by these illicit preparers are frequently sloppy, inaccurate, and riddled with omissions.
See Langford, supra, at 124-25. Once discovered, attempts by the unwitting applicant to
correct the errors frequently compound the problem by producing “inconsistencies” that
undermine the applicant’s credibility in the eyes of the IJ, who is unlikely to appreciate
the difficulties the applicant faces. This Court has acknowledged these difficulties
It can not be overstated that [c]aution is required [in making credibility
determinations] because of the numerous factors that might make it difficult
for an alien to articulate his/her circumstances with the degree of
consistency one might expect from someone who is neither burdened with
the language difficulties, nor haunted by the traumatic memories, that may
hamper communication between a government agent and a petitioner.
Dia v. Ashcroft, 353 F.3d 228, 278 (3d Cir. 2003) (McKee, J., concurring in part,
dissenting in part); see also Butt v. Gonzalez, — F.3d —, No. 03-4360, 2005 WL
3116631, at *5 n.10 (3d Cir. Nov. 23, 2005).