4 […T]he Commission requests that the Honorable Court find and declare that 1. The State is responsible for violation of the rights to life, humane treatment, and personal liberty, to the detriment of Alvaro Lobo Pacheco, Gerson Rodríguez, Israel Pundor, Angel Barrera, Antonio Flores Ochoa, Carlos Arturo Riatiga, Victor Ayala, Alirio Chaparro, Huber Pérez, Alvaro Camargo, Rubén Pineda, Gilberto Ortiz, Reinaldo Corso Vargas, Hernán Jáuregui, Juan Bautista, Alberto Gómez, Juan Montero[, Luis Sausa,]1 and Ferney Fernández, protected by Articles 4 and 7 of the American Convention. 2. The State is responsible for violation of the right to mental and moral wellbeing of the next of kin of the victims, set forth in Article 5 of the American Convention. 3. The State is responsible for violation of the right to fair trial and to judicial protection of the victims and their next of kin, protected by Articles 8(1) and 25 of the American Convention, as well as for not fulfilling its obligation to ensure respect for the rights set forth in the Convention, pursuant [to] its Article 1(1). Based on these conclusions, the Commission requests that the Honorable Court order the State to: 1. Conduct a complete, impartial, and effective investigation under regular court jurisdiction to try and punish those responsible for the extrajudicial execution of Alvaro Lobo Pacheco, Gerson Rodríguez, Israel Pundor, Angel Barrera, Antonio Flores Ochoa, Carlos Arturo Riatiga, Victor Ayala, Alirio Chaparro, Huber Pérez, Alvaro Camargo, Rubén Pineda, Gilberto Ortíz, Reinaldo Corso Vargas, Hernán Jáuregui, Juan Bautista, Alberto Gómez, Luis Sauza, Juan Montero, and Ferney Fernández. 2. Take all necessary steps for the next-of-kin of the victims to receive fair and timely reparation and compensation for the violations [...] established. 3. Pay legal costs and expenses incurred by the next-of-kin of the victims in litigating the instant case under domestic jurisdiction as well as before the Commission and the Court, and reasonable fees for their attorneys. 11. Pursuant to Article 22 of the Rules of Procedure, in its application the Commission named Mr. Robert K. Goldman and Mr. Juan E. Méndez as its delegates, and Mrs. Verónica Gómez as advisor. The Commission also appointed Mrs.Viviana Krsticevic and Mrs. Roxanna Althoz, of the Center for Justice and International Law (Centro por la Justicia y el Derecho Internacional, CEJIL), as assistants, and Mr. Gustavo Gallón Giraldo, Mr. Carlos Rodríguez Mejía and Mrs. Luz Marina Monzón, members of the Colombian Commission of Jurists, as representatives of the alleged victims and their next of kin. 12. On March 20, 2001, the Secretariat of the Court (hereinafter “the Secretariat”), after a preliminary examination of the application carried out by the President, gave notice of it and its appendices to the State, and informed the State of the period granted to respond to it and to appoint its representatives for the proceedings. 13. On April 11, 2001 the State named Mrs. Luz Marina Gil García as its agent. 14. On May 16, 2001 the State filed a brief in which it raised a preliminary objection due to “violation of due process by omitting steps taken in good faith to best comply with the aims of the American Convention on Human Rights.” 1 In its March 8, 2001 brief the Commission reported that “Mr. Luis Sauza, who is mentioned in [the] main text of the application [, …] was left out of the petition due to an involuntary administrative error, [for which reason] he is to be included among the 19 victims in the instant case.”