A. About the situation of Luis Eduardo Guachalá Chimbó before his admission to the Julio Endara Psychiatric Hospital 23. Luis Eduardo Guachalá Chimbó was born on February 27, 1980. 3 He was 23 years old at the time of the events. Also, his family was comprised of his mother, Zoila Rosario Chimbó Jarro, his three sisters, Martha, Nancy, and Alexandra, and his brother Ángel. 4 According to a medical report of January 21, 2004, Mr. Guachalá was diagnosed with “mental and behavior disorder due to cerebral dysfunction, epilepsy.” 5 According to the National Directorate of Disabilities, Mr. Guachalá was not registered as “person with disability” in his citizen identification document. 6 24. The information available indicates that the family was in a situation of poverty. Ms. Chimbó expressed that Mr. Guachalá’s father abandoned the family when their children were very young. 7 She also noted that she worked in “the occupation of laundry in people’s houses” during the day, and as a rose peddler during the night. 8 25. Mr. Guachalá completed primary education. 9 His mother stated that he was unable to finish secondary education because he “had illness of epilepsy” that would not allow him to concentrate to study. 10 Ms. Chimbó held that she did not have the financial means to buy text books and school supplies. 11 26. Ms. Guachalá explained that her son began suffering epilepsy attacks from the age of thirteen. 12 She stated that she took her son to various hospitals, where he was given medication to prevent these attacks. 13 Ms. Chimbó held that every so often her son would suffer epileptic attacks and therefore they had to change his medication. 14 She held that because the prescription medication for her son was very expensive that she was sometimes unable to purchase them. 15 She stated that because of this, she would provide her son with homemade remedies based on medicinal herbs. 16 She stated that the lack of a continuous and adequate medical treatment caused the continuation of the attacks he suffered. 17 27. She stated that because of their poverty, her son Luis Guachalá began working as a mason. 18 She stated he earned very little, “only for his daily subsistence and sometimes enough to provide her a little support at home.” 19 Ms. Chimbó expressed that on occasions she was called to inform her that her son had a crisis whilst working, therefore she had to go where he was, “accommodate him with pillows (…) on the ground, for him to sleep through the crisis until he wakes up.” 20 Ms. Guachalá stated that “when he was by himself, he would fall anywhere, sometimes in public transportation vehicles.” 21 B. About the admission of Luis Guachalá to the Julio Endara Psychiatric Hospital in May 2003 Annex 15. Letter of the Office of the Attorney General of the State, March 21, 2016. Annex 9 to the communication of the State of May 20, 2016, p. 15. 4 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. Likewise, see: Communication of the State of 20 May 2016. 5 Annex 1. Medical Report of the Julio Endara Psychiatric Hospital. Annex to the initial petition. 6 Annex 15. Letter of the Ministry of Public Health, 6 May 2016. Annex 10 to the communication of the State of May 20, 2016. 7 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 8 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 9 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 10 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 11 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 12 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 13 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 14 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 15 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 16 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 17 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 18 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 19 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 20 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 21 Annex 6. Affidavit of Zoila Chimbó, 27 September 2005. Annex 3 to the initial petition. 3 4