d. non-repetition of the crimes committed in this case, and the acknowledgement of State responsibility for the arbitrary detention, torture and murder of Vladimir Herzog and the suffering of his relatives. Grant adequate reparation for both the pecuniary and the non-pecuniary aspects of the human rights violations. 3. Notification to the State. The Merits Report was notified to the State in a communication dated December 22, 2015, in which the State was granted two months to provide information on compliance with the recommendations. The State reiterated the information presented at the merits stage before the Commission and added some elements related to a proposal for pecuniary compensation. However, the Commission noted that the State did not provide information on re-opening the investigation into this case. 4. Submission to the Court. On April 22, 2016, the Commission submitted the case to the Court in relation to the facts and human rights violations described in the Merits Report, “due to the need to obtain justice,” and because “they involve matters of inter-American public order.” 2 Specifically, the Commission submitted to the Court the State’s acts and omissions that occurred, or continued to occur, after December 10, 1998, the date on which the State accepted the Court’s jurisdiction. 3 5. Requests of the Inter-American Commission. Based on the above, the Inter-American Commission asked this Court to conclude and declare the international responsibility of Brazil for the violations described in the Merits Report that occurred after the State had accepted the jurisdiction of the Court, and to require the State, as measures of reparation, to comply with the recommendations included in the said report (supra para. 2). II. PROCEEDINGS BEFORE THE COURT 6. Notification of the State and the representatives. The case was notified to Brazil and to the representatives of the presumed victims (hereinafter “the representatives”) on June 13, 2016. 7. Brief with motions, pleadings and evidence. On August 16, 2016, the representatives 4 presented their brief with motions, pleadings and evidence. In this brief, they agreed with the Commission’s considerations concerning the provisions that had allegedly been violated and, in addition, alleged violations of the oblgation to ensure the rights to personal integrity and to freedom of expression (Articles 5 and 13 of the Convention), in relation to Articles 1(1), 8 and 25 of this instrument, and Articles 1, 6 and 8 of the ICPPT, to the detriment of Vladimir Herzog, due to the failure to investigate his torture to date. They also alleged the violation of the rights to judicial guarantees and judicial protection recognized in Articles 8 and 25 of the Convention, in relation to Articles 1(1) and 2 of this instrument, of the members of Mr. Herzog’s family. Additionally, they asked the Court to declare the violation of the right to the truth, established 2 The Inter-American Commission appointed Commissioner Francisco Eguiguren, the Executive Secretary at the time, Emilio Álvarez Icaza L. and the Special Rapporteur for Freedom of Expression, Edison Lanza, as delegates, and the Deputy Executive Secretary, Elizabeth Abi-Mershed, and the Executive Secretariat’s lawyers Silvia Serrano Guzmán, Ona Flores and Tatiana Teubner as legal advisers. Subsequently, the Commission appointed Paulo Abrão as Executive Secretary. These acts and omissions included: (1) violations of the American Convention and the Inter-American Convention to Prevent and Punish Torture derived from the action of the State authorities during Proceeding No. 2008.61.81.013434-2, which culminated in the closing of the investigation in January 2009. The reason for this closure was the application of the Amnesty Law, and also of the statute of limitations and res judicata; (2) the action of the State authorities in the context of Public Civil Action No. 2008.61.00.011414-5; (3) the effects on the personal integrity of the family members as a result of the situation of impunity and denial of justice described in the Merits Report. 3 4 The Center for Justice and International Law (CEJIL) represents the presumed victims in this case. 4