alleged that following the motions and arguments brief, the Human Rights Clinic had
supported several measures taken at the national level and on the border with Haiti, in
order to document evidence for the public hearing and paid the expenses of its team to
attend the public hearing, indicating that the Clinic would forward the vouchers directly to
the Court.
490. The State indicated that “none of the members of the representatives’ team has
specified or argued when they incurred the expenses corresponding to the vouchers
provided, or their relationship to the case.” In the case of CEJIL, the State indicated that
“it had provided at least 116 pages with photocopies of presumed receipts […] many of
which [contain] deletions, [are] unsigned and/or not stamped, and this undermines their
authenticity.” In addition, it indicated that “this representative does not provide a logical,
detailed and illustrative account of the use of the financial resources supposedly disbursed
[…] so that the State has reasonable doubts that all these expenses were associated with
this case” and asked the Court to reject them. Nevertheless, it indicated that, if the Court
denied its request, it considered that the amount requested by CEJIL was “exorbitant” and
therefore asked that the Court “establish, in equity, the amount to be reimbursed for the
expenses that can be proved.”
491. Regarding the Human Rights Clinic, the State indicated that “it has not provided all
the documents that support the expenses it alleges it incurred, such as, for example, for
the supposed international travel,” and “it has not provided a logical, detailed and
illustrative account of the use of the resources,” and asked the Court to reject the amount
requested by the Clinic. In addition, it considered that “it was unheard of that this Clinic
would request recognition of more than double to costs requested by CEJIL, because it has
only taken part in the proceedings since 2001, while the NGO has worked on the case
since 1999.” Consequently, it asked the Court “to “establish, in equity, the amount of the
costs.”
492. Lastly, with regard to the expenses of MUDHA and GARR, the State asked the Court
“to reject them, purely and simply, because they are not supported by any document or
voucher and they had not even provided a detailed and specific account to justify these
disbursements.” In addition, it affirmed that the Court “should not even apply recognition
of costs in equity, because these representatives have not provided a single voucher for
their monetary disbursements.”
493. Regarding future expenses, the State asserted that it reserved the right to make
observations on these when the representatives, jointly or individually, provided vouchers
for expenses incurred with the appropriate explanation of the connection of such expenses
to this case.
494. In its observations on the annexes presented by the representatives with their final
written arguments, the State submitted different “objections” to the documents presented.
In this regard, it indicated: (1) that the documents relating to the hotel reservations,
“whether or not they had been used, could never prove the amount of money that was in
fact paid”; the document relating to the Hotel Francés in Santo Domingo does not mention
who the reservation was made for, and the other reservations refers to a presumed
witness whose expenses were not covered by the Fund, but does not specify which
witness; (2) regarding transportation expenses, there is an invoice for a taxi fare to and
from a meeting with Tahira Vargas on July 10, 2013; the State observed that the
representatives withdrew the opinion of this expert witness and, therefore, it could not
accept the said expense, because the evidence was never provided to the proceedings.
Also CEJIL had never provided an invoice supporting the alleged expense for transport to
Pedernales from July 7 to 9, 2013; therefore, the State did not accept the supposed
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