agreement] signed by the State and the petitioners existed under which some undertakings remained pending.” f) Submission to the Court. On July 10, 2019, the Commission submitted to the jurisdiction of the Inter-American Court the facts and human rights violations described in the Merits Report “that occurred or continued to occur after March 9, 1987,” “given the need to obtain justice and reparation.”3 3. Requests of the Inter-American Commission. Based on the above, the Commission asked the Court to declare the international responsibility of the State for the violations indicated in points 2, 4 and 64 of the Merits Report. The Commission also asked the Court to order the State to adopt measures of reparation and these are described and analyzed in Chapter IX of this judgment. The Court notes with concern that, almost fifteen years elapsed between the lodging of the initial petition before the Commission and the submission of the case to the Court. 5 II PROCEEDINGS BEFORE THE COURT 4. Notification to the State and to the representatives. The Court notified the Commission’s submission of the case to the representatives of the alleged victims6 (hereinafter “the representatives”) and to the State on December 19, 2019. 5. Brief with pleadings, motions and evidence. On February 24, 2020, the representatives submitted to the Court their brief with pleadings, motions and evidence (hereinafter “pleadings and motions brief”). The representatives agreed substantially with the Commission’s arguments and asked the Court to declare the international responsibility of the State for the violation of the same articles alleged by the Commission and, additionally, the violation of Articles 11(2), 13, 17 and 19 of the American Convention. Furthermore, through their representatives, the alleged victims requested access to the Victims’ Legal Assistance Fund of the Inter-American Court (hereinafter “the Court’s Legal Assistance Fund” or “the Fund”). 6. Answering brief. On September 7, 2020, the State of Guatemala7 submitted to the Court its brief with a preliminary objection and its answer to the Merits Report of the Inter-American Commission and the pleadings and motions brief of the representatives (hereinafter “the answering brief”). In this brief, the State asked the Court to decide that it did not have jurisdiction to examine the events that gave rise to the instant case and, consequently, to reject the claims made by the The Commission appointed Commissioner and President Esmeralda Arosemena de Troitiño and then Executive Secretary Paulo Abrão as its delegates before the Court. It also appointed Silvia Serrano Guzmán, Executive Secretariat lawyer at the time, and Ania Salinas Cerda, Executive Secretariat lawyer, as legal advisers. 3 These points refer to: (i) the alleged forced disappearance of three persons who were last seen during the events of April 29 and 30, 1982, in the State’s custody; (ii) the alleged forced displacement of the 1,498 survivors of the massacre and their 111 family members, and (iii) the alleged violation of the rights to judicial guarantees and judicial protection of the next of kin of the victims of the massacre, the victims of forced disappearance and their next of kin, and all the surviving victims. According to the Commission, the acts and omissions allegedly correspond to violations of the rights established in Articles 3, 4(1), 5(1), 5(2), 7, 8(1), 22(1) and 25(1) of the American Convention, in relation to Article 1(1) of this instrument, and Article I of the ICFDP. 4 The Court notes that the procedure was suspended for a time because the parties were involved in a friendly settlement procedure (see supra para. 2.b). 5 The organizations that represent the alleged victims are the Asociación Familiares de Detenidos-Desaparecidos de Guatemala (“FAMDEGUA”) and the Center for Justice and International Law (“CEJIL”). 6 The State of Guatemala appointed Jorge Luis Donado Vivar, Ana Luisa Gatica Palacios and Lilian Elizabeth Nájera Reyes as its agents. 7 5