police, particularly by state and local police forces.29 This was alleged by the Commission30 and the representatives31 and was also acknowledged by the State.32 36. Although the State denied that “the Venezuelan State has a policy in this regard,” it nevertheless recognized that “extrajudicial executions took place in the country.”33 Moreover, the State emphasized the action taken on this matter by the Ombudsman’s Office and the study carried out in 2006 by the National Commission for Police Reform34 (hereinafter “CONAREPOL”), which analyzed the Venezuelan policing model that had made it possible to reform and adapt the police forces to “to the real situation, to the requirements of the Venezuelan people, and in accordance with international human rights standards.”35 This report mentions, inter alia, the use of physical force by police officers, in a context of few oversight mechanisms and a lack of implementation protocols, where the use of force has become a means of affirming their authority.36 Furthermore, the document notes that officers involved in causing death or injuries to civilians are not required to submit reports, and mentions the 37 failure to investigate these cases and the impunity of the perpetrators. The study 29 The Ombudsman’s Report of 2002 states that “some victims are intercepted and murdered in the street; others are shot by agents who burst into their homes without a warrant; others are killed in the course of police operations,” in which “the official version generally offered by the police forces refers to the alleged death of the presumed criminal in a confrontation” and “in some cases claims the existence, real or invested, of a criminal record, as if this fact justifies the execution.” The 2002 Annual Report of the Ombudsman’s Office of the Bolivarian Republic of Venezuela (Evidence file, volume 24, page 7831). Likewise, expert witness Liderly José Montero Barrueta, proposed by the State , stated that according to the investigation of the National Commission for Police Reform, the victims of police abuse were “poor [,] young men aged 15 to 24 years, dark-skinned, with various occupations and living in working class areas.” Expert testimony rendered by Liderly José Montero Barrueta by affidavit on November 15 2011 (Evidence file, volume 16, pages 5323 and 5324). See also 2003 Annual Report of the Ombudsman’s Office of the Bolivarian Republic of Venezuela (Evidence file, appendix 3 to brief of pleadings, motions and evidence in digital format, page 57). 30 Cf. Final arguments of the Commission (Merits file, volume 5, page 1206) and brief submitting the case (Merits file, volume 1, pages 28 to 29). 31 Cf. Brief of pleadings, motions and evidence (Merits file, volume 2, pages 122, 123, 127 and 135). 32 Brief of final arguments of the State (Merits file, volume 5, page 1011). 33 Brief of final arguments of the State (Merits file, volume 5, page 1011). 34 Cf. National Commission for Police Reform, Presentación y Caracterization de los cuerpos de Policía, Estudios. Caracas 2006, and Características de la Policía Venezolana, Caracas 2006, available as of March 1, 2012 at http://www.consejopolicia.gob.ve/index.php/documents/conarepol and available as of September 1, 2012 at http://issuu.com/unesvirtual/docs/report_conarepol/2?mode=a_p; Annual Report 2010 of the Ombudsman’s Office of the Bolivarian Republic of Venezuela (attachment to the brief of final arguments of the State in digital format, pages 363 and 364); Expert testimony rendered by Liderly José Montero Barrueta by affidavit on November 15, 2011 (Evidence file, volume 16, pages 5321 to 5329), and final arguments of the State (Merits file, volume 5, page 892). 35 Cf. Final arguments of the State (Merits file, volume 5, page 892). 36 Cf. National Commission for Police Reform, Estudios. Características de la Policía Venezolana, page 68. The CONAREPOL Study concluded that “the disciplinary regimen encourages impunity both as regards police infractions, and arbitrary action toward the officers themselves, weakening its role of monitoring and regulation of police actions.” National Commission for Police Reform, Estudios. Características de la Policía Venezolana, page 61. Also see 2010 Annual Report of the Ombudsman’s Office of the Bolivarian Republic of Venezuela forwarded by the State together with its final written arguments (attachment to the brief of final arguments of the State in digital format, page 364). 37 Cf. National Commission for Police Reform, Estudios. Características de la Policía Venezolana, page 68. Also see 2010 Annual Report of the Ombudsman’s Office of the Bolivarian Republic of Venezuela forwarded by the State, together with its final written arguments (attachment to the brief of final arguments of the State in digital format, page 364). Expert testimony of Liderly José Montero Barrueta, (Evidence file, volume 16, page 5323). See also, National Commission for Police Reform, Estudios. Características de la the Policía Venezolana, page 99 and subsq. 11