I. INTRODUCTION OF THE CASE AND PURPOSE OF THE DISPUTE 1. The case submitted to the Court. On March 4, 2015, the Inter-American Commission on Human Rights (hereinafter “the Inter-American Commission” or “the Commission”) submitted to the Court the case of the Hacienda Brasil Verde Workers v. the Federative Republic of Brazil (hereinafter “the State” or “Brazil”). The case relates to a supposed practice of forced labor and debt bondage in Hacienda Brasil Verde, located in the state of Pará. It is alleged that the facts of the case took place in a context in which, each year, tens of thousands of workers were subjected to slave labor. In addition, it is alleged that the workers who were able to escape gave declarations regarding the existence of death threats to those who abandoned the hacienda; the prohibition to leave freely; the absence of salaries or the existence of a paltry wage; their debts to the hacienda, and the lack of decent housing, food and health care. This situation could presumably be attributed to the State because, since 1989, it had been aware of the existence of these practices in general, and specifically in the Hacienda Brasil Verde and, despite this awareness, it had not taken reasonable steps to prevent or to respond to the situation, and had not provided the presumed victims with an effective judicial mechanism to protect their rights, to punish those responsible, and to allow the presumed victims to obtain redress. Lastly, it was alleged that the State was internationally responsible for the disappearance of two adolescents that had been reported to the state authorities on December 21, 1988, allegedly without any effective measures having been taken to discover their whereabouts. 2. Procedure before the Commission. The case was processed before the Inter-American Commission as follows: a) Petition. On November 12, 1998, the Inter-American Commission received the initial petition lodged by the Comissão Pastoral da Terra (hereinafter also “CPT”) and the Center for Justice and International Law (hereinafter “CEJIL”). b) Admissibility and Merits Report. On November 3, 2011, the Commission issued Admissibility and Merits Report No. 169/11 pursuant to Article 50 of the American Convention (hereinafter “Admissibility and Merits Report”), in which it reached a series of conclusions and made several recommendations to the State. i) Conclusions. The Commission concluded that the State was internationally responsible for: a. Violation of the rights recognized in Articles 6, 5, 7, 22, 8 and 25 of the Convention, in relation to Article 1(1) of this instrument, of the Hacienda Brasil Verde Workers found in the inspections carried out in 1993, 1996, 1997 and 2000. b. Violation of the rights recognized in Articles I, II, XIV, VIII and XVIII of the American Declaration of the Rights and Duties of Man (hereinafter “the American Declaration” or “the Declaration”) and, after September 25, 1992, violation of Articles 8 and 25 of the Convention, in relation to Article 1(1) of this instrument, to the detrimen of Iron Canuto da Silva and Luis Ferreira da Cruz, and their next of kin, including José Teodoro da Silva and Miguel Ferreira da Cruz. Also, for violation of Article I of the Declaration and, after September 25, 1992, of Article 5 of the Convention, of the next of kin of Iron Canuto da Silva and Luis Ferreira da Cruz. c. Violation of Articles I, VII and XIV of the Declaration and, after September 25, 1992, of Articles 7, 5, 4, 3 and 19 of the Convention, in relation to Articles 8, 25 and 1(1) of this instrument, to the detriment of Iron Canuto da Silva and Luis Ferreira da Cruz. d. Failure to adopt sufficient and effective measures to ensure, without discrimination, the rights of the workers found during the 1993, 1996, 1997 and 2000 inspections, 4

Select target paragraph3