3 6. The State’s brief of March 28, 2011, in which it asked the Court to grant “a prudent extension of the time limit [...], taking into account the importance of verifying all the facts alleged by the petitioners with the corresponding government entities,” in order to present its observations and any other pertinent documentation in relation to the Inter-American Commission’s request for provisional measures. In this regard, in the Secretariat’s note of March 30, 2011, and on the instructions of the President of the Court, the State was granted the requested extension until April 7, 2011. 7. The brief of April 7, 2011, and its attachments received on April 8 and 13, 2011, in which, although indicating that “for more than two decades, the Venezuelan prison system has suffered a serious operational crisis, which is manifested by the number of inmates who have died or been injured in violent clashes within the prisons,” the State asked the Court to reject the Inter-American Commission’s request to adopt provisional measures, emphasizing the measures taken by the State “faced with a structural prison problem,” the alleged “disparity between the data provided by the petitioners as grounds for [their] request, and the official data of the agencies with jurisdiction in this matter, such as the National Prison Services Directorate. In particular, the State maintained that: a) The measures adopted included: i. ii. iii. iv. v. vi. The Constitution of the Bolivarian Republic of Venezuela, which establishes protection for and guarantees compliance with the rights of those deprived of liberty, among the constitutional norms on which the Venezuelan prison system is based; The project to Humanize and Modernize the Venezuelan Prison System, which began in 2006 with the goal of reforming the structure of the prison system, based on complying with the fundamental rights of those deprived of liberty, ensuring that inmates and their families are treated decently and respectfully, providing them with values and giving a sense to their life, increasing their self-esteem, and providing them with opportunities that were previously denied; The major transformation of the Directorate General of Custody and Rehabilitation into a decentralized body known as the National Prison Services Directorate (DNSP), with competence in the areas of administrative, financial and budgetary management, enabling it to formulate and execute public policies in accordance with the changes in the prison system, in line with the new legal framework and the humane and progressive concept; The distribution of vehicles, including ambulances, to the DNSP for the transport of small, medium and large loads, to be acquired at the end of the first quarter 2011; The incorporation into the Code of Criminal Procedure of the classification for minimum, medium and maximum security, as well as the parameters to be followed in this procedure, and the professionals responsible for executing it, and The legislative initiatives concerning the prison system, such as the submission of the Code of Criminal Procedure to the National Assembly, which was unanimously approved by the members of the Assembly on April 5, 2011. It is presently being debated by the first Regional Penitentiary Council. b) In 2010, there were 150 detainees for every 100,000 inhabitants of Venezuela; in other words, 43,520 persons deprived of liberty, while it was recorded that 315 persons had died and 998 had been injured, which corresponded to 0.71% and 2.24% of the total prison population, respectively;

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