2 Court in the instant case on November 24, 20061 (hereinafter “the Judgment”), based on Article 67 of the Convention, as follows: 1. 2. 3. 4. 5. 6. 7. [The reason why] the Court’s decision does not state the (objective) reasons provided for in Article 66(1) of the American Convention. [The reason why] the Court failed to strictly apply Article 63(1) of the American Convention […] [The reason why] the Court’s Judgment deviated from previous decisions rendered by the Court in […] similar cases in which it ordered the employee’s reinstatement, settlement of back pay, moral damages, costs and other [compensatory items …] [The reason why] the Judgment fails to specifically order that the State repeal Decree Law No. 25640 and Resolution No. 1239-A-92-CACL, which prevented and still prevent us from filing an Action for Amparo or an Administrative Recourse, respectively, in order to bring them in line with the American Convention, as requested in the petition the Commission filed with the Court. How, in the Court’s view, we will be given access to a simple, prompt and effective administrative or judicial recourse to defend our violated rights considering that, as of the date hereof, the periods therefor prescribed by domestic laws have already elapsed. The Court belie[ves] that, for the benefit of 257 employees, the State of Peru will amend its Code of Constitutional Procedure, its Code of Civil Procedure, its Law on general Administrative Procedures and other related legislation that concerns the instant case just to give us access to a simple, prompt and effective recourse[.] Are the Judges really unaware that, in accordance with the Court’s case-law, the Action for Amparo is the only simple, prompt and effective recourse? Lastly, regarding operative paragraph No. 4 of the [J]udgment appealed by way of the request for interpretation, we request clarification on the following specific aspects: a) For instance, said operative paragraph begins by stating that the State is under a duty to guarantee our access to a simple, prompt and effective recourse, for which purpose it is required to set up an independent, impartial body. In this respect, we are concerned about who will guarantee our access to such recourse: [t]he [S]tate of Peru or the Body (Commission) to be set up by the State as ordered in said Judgment. b) Furthermore, we seek to learn what compensation we will be entitled to in the event that it (the Commission) should find that we were illegally and arbitrarily dismissed[.] 2. On May 11, 2007, in accordance with Article 59(2) of the Rules of Procedure and further to the Court’s instructions, the Secretariat of the Court (hereinafter “the Secretariat”) transmitted a copy of the request for interpretation to the victims’ representatives’ common intervenors, the Inter-American Commission on Human Rights (hereinafter “the Commission” or “the Inter-American Commission”) and the State of Peru (hereinafter “the State” or “Peru”), advising them that they had a non-postponable deadline up to August 1, 2007 to submit such written arguments as they may deem appropriate. Furthermore, the State was thereby reminded that, pursuant to Article 59(4) of the Rules of Procedure, “[the] request for interpretation shall not suspend the effect of the judgment.” The common intervenors did not file a brief in that regard. 3. On July 31, 2007, the State submitted its written arguments, the relevant portion of which stated as follows: a) the Judgments rendered in Case of Baena-Ricardo et al. v. Panama, Constitutional Court and Acevedo-Jaramillo et al. (SITRAMUN) differ from the instant 1 Cf. Case of the Dismissed Congressional Employees (Aguado Alfaro et al.) V. Peru. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 24, 2006. Series C No. 158.