3 In consideration of the foregoing conclusions, the Commission requests to the Court to recommend that the State: 1. Make appropriate amends for the human rights violations established in this report, with fair compensation for the 14-year delay in the judicial proceedings, to the next-of-kin of Zulema Tarazona Arrieta and Norma Pérez Chávez, and to Luis Alberto Bejarano Laura. 2. Strengthen its ability to conduce timely and duly diligent investigations of incidents in which members of the armed forces use lethal force. 3. Take the necessary steps to prevent similar events from occurring in the future, in accordance with the duty of prevention and the obligation of guaranteeing the fundamental rights recognized in the American Convention; in particular, through the implementation of human rights programs in its armed forces training schools. The Commission submits the instant case to the jurisdiction of the Inter-American Court out of the need to obtain justice for the victims. In addition, the IACHR notes that the instant case involves issues of Inter-American public order. Specifically, the case addresses the application of the standards developed in the jurisprudence of the bodies of the Inter-American System on the use of force by security officers and the response that must be given by the States to provide a satisfactory explanation of the facts. Moreover, in terms of justice, the case poses a series of impunity factors, both general and specific, that include the lack of due diligence, the intervention of the military jurisdiction, the validity of an Amnesty Law and excessive delays, of which the elimination of its effects, could have an impact in the case. These factors of impunity are related to the concepts of justice and opportune reparation to which the bodies of the system have given special relevance in the development of its jurisprudence. Inasmuch as these issues significantly affect Inter-American public order, pursuant to Article 35.1 f) of the Rules of Procedure of the Inter-American Court, the Commission proffers the following expert testimony: 1. A person whose name will be informed shortly, who shall testify on the International standards on the use of force, in particular, on the criteria for the necessity, proportionality and precaution, as well as its implications in the analysis of the attribution of the international responsibility of the State when there is an ongoing debate on the accidental character or not of the use of force. The expert will also address the opportune and effective judicial response in these cases. To the extent that it is relevant, the expert will make reference to the facts of the case. The expert’s CV will be included in the Merits Report 77/12. Finally, the petitioners expressed the victims’ interest in the submission of the present case to the Inter-American Court and informed that the following shall be representatives of the victims: Asociación Pro Derechos Humanos (APRODEH) xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxx Signed in the original

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