5 25. There is no dispute as to the fact that Mrs. Mariana Ramírez took the blood sample from Mr. HS on June 22, 199816 and that she herself gave the pints of blood to the family and acquaintances of TGGL; that the platelet concentrates were handed over later that night to two friends of TGGL’s mother,17 by Mrs. Bertha Regalado18; and that on the following day, June 23, 1998, Mrs. Edith Orellana performed tests for the first time – including for HIV – on HS’s blood sample.19 26. There is no controversy surrounding the fact that the transfusions were carried out on June 22, 1998, and continued to be performed on the following day by staff of the Humanitarian Clinic.20 In this regard, Rolando Remigio Patiño, a doctor at the Humanitarian Clinic, stated that the transfusion was performed by the nursing staff and that “total reliance was placed on the blood and platelets sent by the Red Cross.”21 27. TGGL remained at the Humanitarian Clinic until June 29, 1998, when she was discharged.22 B. Facts taking place after the transfusion 28. Regarding what happened after her discharge from the Humanitarian Clinic, TGGL’s mother made several statements. In her own words: Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of TGGL’s brother of November 23, 1998. Folio 305 16 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. TGGL’s mother’s private prosecution of December 22, 1999. Folio 85; and Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of TGGL’s mother of November 15, 1998. Folio 284. 17 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Eulalia Catalina Dávalos Landivar October 29, 1998. Folio 267; and Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Luz Elena Dávalos Landivar of October 29, 1998. Folio 268; Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Bertha Regalado of February 10, 2000. Folio not numbered between 91 and 92; Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Bertha Regalado of July 18, 2001. Folio 188. 18 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Edith Orellana of February 9, 2000. Folio 90; Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Pablo Arturo Monsalve of February 9, 2000. Folio 91; and Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Mariana Ramírez Ramírez of December 14, 1998. Folio 33; Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Bertha Regalado of February 10, 2000. Folio not numbered between 91 and 92; Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Bertha Regalado of July 18, 2001. Folio 188. 19 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Edith Alexandra Orellana of October 19, 1998. Folio 282. 20 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. TGGL’s mother’s private prosecution of December 22, 1999. Folio 85; Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Sandra Elizabeth González of October 23, 1998. Folio 281; Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Sandra Elizabeth González of November 30, 1998. Folio 307; and Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Expert witness report of August 16, 1999, of Drs. Juan Peralvo Roman and Nardo Vivar Idrovo. Folios 67 to 74. 21 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Remigio Rolando Patiño of August 1, 2001. Folio 196. 22 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. TGGL’s medical history between June 22 and 29, 1998. Folio 50. Almost totally illegible.