29 calculations of the State’s expert witness report includes, in general terms: a) b) c) d) e) f) g) h) the reimbursements for the failure to pay the remaining raise to be applied to the salary scales based on the raise of S/. 70.00 that was granted to the unskilled laborer position; the amounts corresponding to the restoration of the reduction in monthly remunerations in effect as of the month of December 1992; the amount for paying non-salary compensation, like incentives and bonuses that come after the restitution of basic remuneration; reimbursement of the part of remunerations deducted from January to November of 1992; interest (D. L 25920) on the amounts referred to in a) + b) + c) + d); reimbursements for ESSALUD plus corresponding interest; determination of the reimbursements for Compensation for Time of Service - CTS plus bank (financial) interest on it, and total amounts that SEDAPAL must reimburse to its personnel holding positions as functionaries and senior management.97 102. The Court finds that the reparation of pecuniary damages demands, in the context of this case, demands the payment of the following: i) a reduction in salaries as of December 1992; ii) retroactive collection of the payments made between January and November 1992, and iii) no increase in salaries as a consequence of the last applicable salary scale adjustment that corresponded to the victims (supra para. 63). The two expert witness reports agree on these three points.98 However, if they agree on the amounts that should be compensated for the decrease in the salaries and the nonincrease, they do not agree on the specific amounts regarding the retroactive payment.99 amounts correspond to the denominated basics regarding the “application of an increase in the remunerations of the unskillsed workers of S/. 70.00” and in regard to the “lowering of salaries” that coincide with specific stements of the expert presented by the State. 97 In addition to the foregoing, the expert of the State included in the calculations of the compensation of the reimbursement of the reductions made until March 1994. Cf. Expert Opinion of Mr. Félix Daniel Aquije Soler, supra note 29, folio 2583. 98 Both expert witness reports presented by the parties agreed that, i) “There is no complaint with regard to the application of the salary scale system in the periods previous to 1992;” ii) the system of salary scales was suspended “between January 10 and October 22,” 1992, by virtue of Law Decree 25.334, “and between November 1 and November 26, 1992, through the application of Law Decree No. 25388 and its modifying statues” Official Letter Nº. 1-2005-MTPE/ATAD of January 7, 2005, supra note 44, folio 1883; iii) the workers did not receive payment according to the base pay in force as of January 1992 and there were improper deductions made from their remunerations between December 1992 and March 1994; iv) “for the workers who were dismissed or resigned, or who had passed away, the calculations have been applied through the date corresponding to their last day of employment” Expert report of Mrs. Lily Isabel Albornoz Castro, supra note 40, folio 1626. This can be observed in the specific analysis of workers who stopped worker prior to the final payment date established by the State. For example, in the case of Jorge Juis Neyra Yáñez, according to the details that could be observed in both expert witness reports: Expert accounting report, in both the expert report presented by the State as in the one of the representative, the respective calculation has as an end date the month of June 1993. Expert report of Mrs. Lily Isabel Albornoz Castro, supra note 40, folio 2136 and Expert Opinion of Mr. Félix Daniel Aquije Soler, supra note 29, folio 2659. On this point it is necessary to clarify that although the salary scales should be taken into account through the date on which the individual stopped working, the interest on this debt is considered by both expert witness reports to have accrued through the date on which the briefs of both parties were submitted. It is assumed that interest will continue to accrue “up until the day the debt is paid.” Expert Opinion of Mr. Félix Daniel Aquije Soler, supra note 29, folio 2585. 99 Among the criteria taken into account in the expert witness report are the following: i) a first base salary corresponding to S/. 70.00 that was not applied in July 1992; ii) a second base salary representing the lowering of the workers’ salaries; iii) the result of applying to each of the basic amounts a 10% for personal remuneration; iv) for each of these base salaries 10% was added for remuneration and 10% for FONAVI; iv) the amount charged retroactively to the victims, and v) the gratifications, vi) the total of all the abovementioned variables is called the “gross total.” Interest, bonuses and non-monetary compensation owned through 1993 are calculated over the “gross total” in the case of the first two base salaries and through February 19, 1994, the date on which the retroactive charges to the workers ceased. To this, the amount is added for “Debt for the Social Security (EsSALUD)” and the “Debt for Compensation for Time of Service,” which in both cases incurs interests. Taking as example the table of legal withdraws and interests presented both in

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