II PROCEEDINGS BEFORE THE COURT 5. Notification to the State and to the representatives. The submission of the case was notified to the State and to the representatives of the alleged victims4 on June 17, 2021. 6. Briefs with pleadings, motions and evidence. The inter-American public defenders presented their brief with pleadings, motions and evidence (hereinafter “pleadings and motions brief”) on August 14, 2021. In this brief, they agreed with the contents of the Merits Report, adding a request that the State be declared responsible for violating the right to the presumption of innocence and the right of defense of their clients and asking for additional measures of reparation to those requested by the Commission. Representative Carlos Eduardo Gómez Rojas presented his pleadings and motions brief on August 15, 2021. He was also in substantial agreement with the contents of the Merits Report and asked for additional measures of reparation to those requested by the Commission. Nevertheless, he did not ask the Court to declare the violation of either the Convention of Belém do Pará or the Inter-American Convention to Prevent and Punish Torture. He added the alleged violation of the right to protection of the family recognized in Article 17(1) of the American Convention. Representatives Jemio Mendoza and Machicao Hidalgo5 presented their pleadings and motions brief on August 16, 2021. As in the case of the other representatives, they agreed with the contents of the Merits Report and requested specific measures of reparation for their clients. They added the alleged violation of the right to health established in Article 26 of the American Convention. 7. Answering brief with preliminary objections.6 On December 16, 2021, the State submitted to the Court its brief answering the submission of the case by the Commission, and with its observations on the pleadings and motions briefs (hereinafter “answering brief”). In this brief, the State filed two preliminary objections. In addition, it rejected the alleged violations and the admissibility of the measures of reparations requested. 8. Observations on the preliminary objections. On February 23, 2022, the inter-American public defenders presented their observations on the preliminary objections. On February 24 and 28, 2022, representative Jemio Mendoza and the Commission, respectively, presented their observations on the preliminary objections. Representative Gómez Rojas did not present observations. 4 In the instant case, the alleged victims are represented by three different representatives: Carlos Eduardo Gómez Rojas represents Norma Lupe Alarcón de Valencia, Carlos Álvaro Taboada Valencia, Claudio Tito Centeno Valencia, Claudia Mariela Valencia Alarcón de Centeno, Gabriel Blas Valencia Alarcón, Alexis Eduardo Valencia Alarcón, Blas Valencia Campos and Mauricio Marcelo Valenzuela Valencia. Hugo Efraín Jemio Mendoza and Fabiola Machicao Hidalgo represent Patricia Catalina Gallardo Ardúz and María Fernanda Peña Gallardo. Inter-American public defenders who, originally represented Víctor Manuel Boggiano Bruzzón, Victoria Gutiérrez Aguilar de Lulleman, Oswaldo Lulleman Antezana, Jenny Paola Lulleman Gutiérrez de Zaconeta, Raúl Oswaldo Lulleman Gutiérrez, and Luis Fernando Lulleman Gutiérrez. Subsequently, in a communication of June 9, 2021, on the instructions of the then President of the Court, the defenders were asked to assume the defense of the alleged victims who it had not been possible to contact at that time, namely: Edwin Rodríguez Alarcón, Genaro Ahuacho Luna, Alfredo Bazán y Rosas, Freddy Cáceres Castro, Carlos Enrique Castro Ramírez; Carlos Eladio Cruz Añez; Julia Mamanu Mamani; Elacio Peña Córdoba; F.E.P.M.; Edwin Rodríguez Alarcón and Mercedes Valencia Chuquimia. - Although a joint representation had originally been announced, the subsequent briefs were only presented and signed by Hugo Efraín Jemio Mendoza. 5 6 The State appointed Wilfredo David Chávez Serrano, Attorney General; Patricia Guzmán Meneses, Deputy Attorney General for the State’s Legal Defense and its Legal Representative; Jhanneth del Rosio Bustillos Bustillos, Director General for the Defense of Human Rights and the Environment, and Ximena Miriam Fajardo Navarro, Head of the Unit for Cases at the Merits Stage and the Human Rights Committee, as its agents 5