I INTRODUCTION OF THE CASE AND CAUSE OF ACTION 1. The case submitted to the Court. On February 22, 2021, the Inter-American Commission on Human Rights (hereinafter “the Inter-American Commission” or “the Commission”) submitted to the jurisdiction of the Court the case of Blas Valencia Campos et al. with regard to the Plurinational State of Bolivia (hereinafter also “the State” or “Bolivia”). The Commission indicated that the case related to the alleged international responsibility of the State for the unlawful raid of the homes of the alleged victims and excessive acts of violence by state agents – including torture, sexual violence, and solitary confinement – during their arrest and subsequent detention. 2. Procedure before the Commission. The procedure before the Commission was as follows: a) Petition. On January 8, 2003, the Commission received a petition lodged by Blas Valencia Campos and another 25 persons1 against the State of Bolivia. b) Admissibility Report. On October 30, 2008, the Commission adopted Admissibility Report No. 84/08, and this was notified to the parties on November 11, 2008. c) Merits Report. On May 4, 2019, the Commission adopted Merits Report No. 54/19 in which it reached a series of conclusions2 and made several recommendations to the State. d) Notification to the State. The Merits Report was notified to the State on July 22, 2019. 3. Submission to the Court. On February 22, 2021, after having granted the State six extensions of the time limit for complying with its recommendations, the Commission3 decided to submit all the facts and human rights violations described in Merits Report No. 54/19 to the jurisdiction of the Inter-American Court taking into account that some of the alleged victims were deprived of liberty and “the need to obtain justice and reparation for the [alleged] victims.” The Court notes with concern that more than 18 years elapsed between the lodging of the original petition before the Commission and the submission of the case to the Court. 4. The Commission’s requests. Based on the foregoing, the Commission asked the Court to declare the international responsibility of the State for the violations indicated in its Merits Report (supra para. 2(c) and footnote 2). The Commission also asked the Court to order the State, as measures of reparation, to comply with the measures included in the said report. 1 Norma Lupe Alarcón de Valencia; Mercedes Valencia Chuquimia; Mauricio Valenzuela Valencia; Álvaro Taboada Valencia; Claudia Valencia Alarcón; Carlos Eladio Cruz Añez; Patricia Catalina Gallardo Ardúz; María Fernanda Peña Gallardo; Freddy Cáceres Castro; Oswaldo Lulleman Antezana; Raúl Oswaldo Lulleman Gutiérrez; Victoria Gutiérrez de Lulleman; Paola Lulleman de Zaconeta; Luis Fernando Lulleman Gutiérrez; Julia Mamanu Mamani; Genaro Ahuacho Luna (also known as Walter Herrera Flores); Carlos Enrique Castro Ramírez; Alfredo Bazán y Rosas (also known as José Miguel Abildo Díaz); Víctor Manuel Boggiano Bruzzón (also known as Juan Ramírez Ortega); Elacio Peña Córdova (also known as Elacio Peña Córdoba); Edwin Rodríguez Alarcón; Gabriel Valencia Alarcón; Alexis Valencia Alarcón; Claudio Valencia, and F.E.P.M. 2 The Commission concluded that the State was responsible for the violation of the rights to personal liberty, private and family life, life, and personal integrity, rights of the child, and to judicial guarantees and judicial protection established in Articles 4, 5, 7, 8, 11, 19 and 25 of the American Convention in relation to the obligations established in Article 1(1) of this instrument, as well as the duty to prevent violence against women established in Article 7 of the Convention of Belém do Pará and Articles 1, 6 and 8 of the Inter-American Convention to Prevent and Punish Torture, in light of the failure to investigate and punish the complaints of torture. The Commission appointed then Commissioner Flavia Piovesan and then Deputy Executive Secretary, Marisol Blanchard Vera, as its delegates before the Court, together with Jorge Humberto Meza Flores and Analía Banfi Vique, experts of the Commission’s Executive Secretariat at the time. 3 4

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