doctor who performs abortions. Furthermore, Zhang has not provided evidence to establish a claim for asylum based on past persecution or a well-founded fear of persecution on account of the letter she wrote to criticize a government official’s misconduct. The circumstances she described are analogous to situations that have been found by the Courts of Appeals to amount to mere harassment and to fall short of economic persecution. See Guan Shan Liao v. U.S. Dep’t of Justice, 293 F.3d 61, 70 (2d Cir.2002) (finding that an applicant who incurred excessive fines, was threatened with detention, was forced to leave his village, and was deprived of government services and his home did not establish past persecution); Barreto-Claro v. U.S. Attorney General, 275 F.3d 1334, 1340 (11th Cir.2001) (<HOLDING>); Nelson v. INS, 232 F.3d 258, 264 (1st
holding in age discrimination case that plaintiffs dismissal did not give rise to an inference of discrimination when job was subsequently offered to an older individual holding that a company policy which forced an employee to choose between losing his job for the exercise of his rights under erisaprotected benefits or keeping his job and forcing him to give up his benefits would be essentially unfair or a quintessential hobsons choice  holding that a prima facie case for discrimination requires the plaintiff to show that 1 he belongs to the protected age group 2 his job performance was satisfactory 3 adverse employment action was taken against him  in 4  circumstances giving rise to an inference of discrimination  holding no connection between nonresident defendants alleged age discrimination against job applicant and its solicitation activities in florida as was required to exercise specific jurisdiction holding that an applicant who suffered employment discrimination lost his job as a taxi driver and was forced to take menial work failed to show persecution