provide information on compliance with the recommendations. Following ten extensions of this time limit, the Commission determined that the State had made no concrete progress in complying with the recommendations. 3. Submission to the Court. On March 4, 2015, the Commission submitted the facts and the human rights violations described in the Merits Report to the jurisdiction of the Court, “in order to obtain justice.”2 Specifically, the Commission submitted to the Court the State’s acts and omission that took place or continued to occur after December 10, 1998, date on which the State accepted the Court’s jurisdiction,3 without prejudice to the possibility that the State accept the Court’s jurisdiction to examine the totality of this case as stipulated in Article 62(2) of the Convention. 4. Requests of the Inter-American Commission. Based on the above, the Inter-American Commission asked the Court to declare the international responsibility of Brazil for the violations described in the Admissibility and Merits Report and to order the State, as measures of reparations, to comply with the recommendations included in that report (supra para. 2). II PROCEEDINGS BEFORE THE COURT 5. Notification to the State and to the representatives. The Commission’s submission of the case was notified to the State and to the representatives on April 14, 2015. 6. Brief with motions, pleadings and evidence. On June 17, 2015, the representatives presented their brief with motions, pleadings and evidence (hereinafter “motions and pleadings brief”), pursuant to Articles 25 and 40 of the Court’s Rules of Procedure.4 7. Answering brief. On September 14, 2015, the State submitted to the Court its brief answering the submission of the case and the motions and pleadings brief and with The Inter-American Commission designated Commissioner Felipe González and Executive Secretary, Emilio Álvarez Icaza L., as delegates and Deputy Executive Secretary, Elizabeth Abi-Mershed, and Silvia Serrano Guzmán, an Executive Secretariat lawyer, as legal advisers. 2 These acts and omissions include: (1) The situation of forced labor and debt bondage, similar to slavery, after December 10, 1998; (2) The acts and omissions that have led to the impunity of all the facts of the case. This impunity continued on the date that the State accepted the jurisdiction of the Court and persists to date, and (3) The disappearance of Iron Canuto da Silva and Luis Ferreira da Cruz, which subsisted following the date on which the State accepted the Court’s jurisdiction. 3 The representatives asked the Court to declare the international responsibility of the State for the following: (1) violation of the obligation to ensure the prohibition of slavery, servitude and trafficking in persons established in Article 6 of the Convention, in relation to the rights to juridical personality, personal integrity, personal liberty and safety, privacy, honor and dignity, and freedom of movement and residence established in Articles 3, 5, 7, 11 and 22 of the Convention, to the detriment of those individuals who were working in Hacienda Brasil Verde following the acceptance of the Court’s contentious jurisdiction. This responsibility is increased owing to the violation of the principle of non-discrimination and the rights of the child established in Articles 1(1) and 19 of this instrument; (2) violation of the rights to judicial protection and judicial guarantees established in Articles 25 and 8, in relation to Article 1(1) of the Convention, of those individuals who were working in Hacienda Brasil Verde following the acceptance of the Court’s contentious jurisdiction; (3) failure to comply with the obligation to ensure the rights to juridical personality, life, personal integrity and liberty of Luis Ferreira da Cruz established in Articles 3, 4, 5 and 7 of the Convention, in relation to Articles 1(1), 8 and 25 of this instrument; (4) violation of the rights to judicial guarantees, judicial protection and personal integrity of the next of kin of Luis Ferreira da Cruz established in Articles 8, 25 and 5 of the Convention, in relation to Article 1(1) of this instrument, and (5) the continuing violation of the rights to judicial guarantees and judicial protection established in Articles 8 and 25 of the Convention, of those who were working in Hacienda Brasil Verde prior to 1998. 4 6