12 Inter-American Commission attached a written document addressed to them by the ICJP. 21. The Secretariat’s letter of September 16, 2010 whereby, pursuant to the instructions of the President of the Tribunal, it requested that the State present its relevant observations on the Inter-American Commission’s communications of September 13 and 14, 2010 (supra Having Seen 19, 20). 22. The Secretariat’s letter of October 15, 2010 whereby, pursuant to the instructions of the President of the Tribunal, it again requested that the State submit its relevant observations on the Inter-American Commission’s communications of September 13 and 14, 2010 (supra Having Seen 19, 20, 21). 23. The communication of October 4, 2010 whereby the Inter-American Commission presented its observations on the State’s brief of July 30, 2010 (supra Having Seen 17, 18). In this communication, the Commission declared that: a) In the “request for provisional measures the proposed beneficiaries claimed that, despite the precautionary measures through which the State provided cellular and satellite means of communication, late model vehicles, transportation support, and protection schemes complete with armored vehicles for members of the ICJP of Bogotá, the members c[ontinue] to be the target of death and disappearance threats, surveillance[, and] kidnapping[;] their communications [continue to be] intercepted by the [... DAS]; and, there presently exist legal complaints against the members about which the authorities are withholding information.” “This situation has not changed at all in the intervening period following the request for provisional measures”; b) “[T]hrough various communications in the months of May, June, and September 2010, [...] [the Commission] has informed the Tribunal as to specific indications that, despite the precautionary measures and other actions the State has undertaken in this framework, such efforts have shown themselves to be inadequate”; c) “[I]t has reported on various threats received recently by members of the ICJP (especially concerning the teams present in Buenaventura and the department of Cauca)[,] which forced them to suspend work in the area[;] on the threats received by Danilo Ruedo [sic] in Bogotá and the surveillance of members in general, with specific reference to that of the groups located in Caracolí, territory of Curvaradó.” The Commission indicated that “it has likewise reported on alleged ‘intelligence offensives’ of the DAS against the organization, alleged acts of persecution against them, as well as the current situation the members face in carrying out their work, which has forced them to change their way of life owing to the constant risk they face”; d) “[T]he information proffered by the State in relation to its implementation of the security measures demonstrates, in light of the multiplicity of instances upon which the Commission has reported, that the measures have not been sufficient to respond to the situation of real and imminent risk, nor have they been adequate to protect the lives and right to humane treatment of the beneficiaries. The information presented indicates a

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