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082007P.pdf   05/12/2009  Armando Cubillos  v.  Michael B. Mukasey
   U.S. Court of Appeals Case No:  08-2007
   Board of Immigration Appeals   
   [PUBLISHED] [Judge Smith, Author, with Murphy, Circuit Judge, and
   Limbaugh, District Judge]
Petition for Review - Immigration. Two anonymous phone calls and two anonymous letters, without more, over a four-year period, are not sufficiently severe to constitute past persecution under this circuit's precedents; these anonymous threats were also insufficient to establish that petitioner had well-founded fear of future persecution if he returned to Colombia; no error in denying application for withholding of removal; BIA did not exceed its authority when it determined that the record failed to establish persecution.