which she was involved. The State argued that “Ms. J. was not compelled to sign the records of the seizure or of the house search” and that “she was able to testify freely, without any type of coercion or censure,” so that “[t]he limited communication [of J. […] with the lawyer of her choice is not a matter that can be attributed to the State.” It also argued that the “restrictions [due to which the presumed victim could only speak to her lawyer under the strict supervision of the authorities], arose from the confidential nature of the proceedings more than from a goal of restricting her right of defense.” It also indicated that the prohibition to question police officials “did not prejudice her in any way, given that she was acquitted”; moreover, “it has not been proved that she sought the presence of the officials who took part in the elaboration of the police attestation and that this was refused.” The State argued that, despite the said restriction, currently, Ms. J.’s defense counsel “has the right to question the witnesses who appear at the preliminary investigation stage and during the oral hearing, as well as to present any witnesses she may deem pertinent” or the possibility that another interpretation of the Constitution is used in her specific case. Regarding the limitations to the filing of remedies and preliminary questions, the State argued that Decree 25,475 “did not establish a prohibition to pose such questions, but determined that they must be decided at the time of the judgment”; also, that “it has not been proved that her defense counsel were prevented from filing any remedy related to her case.” ii. Considerations of the Court 193. In this case, a violation of the right to defend oneself is being alleged on the following grounds: (a) the failure to notify Ms. J. of the investigation opened against her and of the reasons for her detention; (b) the limitations J. had to converse with her lawyer; (c) the legal restrictions that prevented her from offering as witnesses those who intervened in the elaboration of the police attestation; (d) the legal restrictions regarding the means and opportunities to file preliminary questions, and (e) the alleged coercion Ms. J. received while she was detained, presumably to make her plead guilty. The Court will now examine each of these alleged violations. a. Failure to notify Ms. J. of the investigation opened against her and of the reasons for her detention (alleged violation of Articles 8(2)(b) and 7(4) of the Convention) 194. This Court has established that it should be possible to exercise the right to defend oneself as soon as a person is named as a possible perpetrator of, or participant in, an illegal act and only culminates when the proceedings end. 298 Affirming the contrary implies that the convention-based guarantees that protect the right to defend oneself, including Article 8(2)(b), are contingent on the investigation being at a specific procedural stage, leaving open the possibility that, prior to this, the rights of the accused are affected by acts of authority that he is unaware of or that he cannot control or oppose effectively, which is evidently contrary to the Convention. 299 The right to defend oneself obliges the State to treat the individual at all times as a true subject of the proceedings, in the broadest sense of this concept, and not simply as its object. 300 195. Accordingly, Article 8(2)(b) of the Convention is in effect even before an “accusation,” strictly speaking, is formulated. To ensure that the said article can meet its intrinsic objectives, the notification must take place before the accused gives his first statement 301 before any public authority. 302 298 Cf. Case of Barreto Leiva v. Venezuela, supra, para. 29, and Case of López Mendoza v. Venezuela. Merits, reparations and costs. Judgment of September 1, 2011. Series C No. 233, para. 117. 299 Cf. Case of Barreto Leiva v. Venezuela, supra, para. 29. 300 Case of Barreto Leiva v. Venezuela, supra, para. 29 and Case of López Mendoza v. Venezuela, supra, para. 117. 301 Cf. Case of Tibi v. Ecuador, supra, para. 187, and Case of Barreto Leiva v. Venezuela, supra, para. 30. 302 Cf. Case of Barreto Leiva v. Venezuela, supra, para. 30. 59