68. Lastly, the State affirmed that the representatives had indicated their “express waiver of representing [Andrea Alezy] in this case.” 69. The representatives and the Commission indicated that the “preliminary issue” presented by the State was, to the contrary, a question relating to the merits of the case that concerned the assessment of the evidence. Nevertheless, the representatives and, to a lesser extent, the Commission, referred to some aspects of the State’s arguments. 70. Regarding the Medina family, the representatives asserted that the difference in name between Lilia Jean Pierre and Lilia Pérez is due to the fact that Haitians living in the Dominican Republic tend to “latinize” their names. 71. In relation to Willian Medina Ferreras, both the representatives and the Commission indicated that the photographs and video on which the State based its arguments (infra paras. 127 and 128) are not admissible, because their presentation was time-barred. The representatives also asserted that the principle of estoppel is applicable, because the State, during the processing of the case before the Commission and in its answering brief, had indicated that the presumed victim is Willian Medina Ferreras. In addition, the representatives, in their written arguments, indicated that Willian Medina Ferreras was being investigated on the basis of his statements before the Court; that is, in violation of Article 53 of the Rules of Procedure. 54 However, it then stated that, “the State opened the new investigation on September 26, 2013, in other words 12 days before this hearing was held before the Court.” They also recalled that the State had “accepted” that “Willia[n] Medina Ferreras, Awilda Medina [and] Luis Ney Medina […] are Dominican citizens.” 55 72. Regarding the person identified as “Juan Fils-Aimé” in the Merits report, the representatives clarified that she is, in fact, “Juana Fils-Aimé.” Nevertheless, they indicated that “based on the statement of Janise Midi […] before the Court, [they] consider that [Juana Fils-Aimé] should not be considered a victim […], because she was not living with the Fils-Aimé family at the time of their expulsion.” 73. They also stated that they had lost contact with Andrea Alezy and that they would not present arguments with regard to her. 74. As for the person identified as “Ana Virginia Nolasco” in the Merits report, the representatives explained that “her correct name in her mother tongue, Creole, is Ana Virgil Nolasco, and her latinized name […] is Ana Virginia Nolasco.” 75. They also indicated, regarding the State’s objection to “María Esthel Matos Medina,” that “Mrs. [Matos] Medina [is] the person with whom Rafaelito has ties of affection and, therefore, it was she whose ‘right to physical and moral integrity’ was affected ‘owing to suffering […] as a result of […] the violations perpetrated […].” Thus, it is irrelevant that she does not appear as his mother in the birth records.” 76. The representatives also forwarded the Haitian identity documents of Bersson Gelin and Jeanty Fils-Aimé that it had at that time. They repeated that Bersson Gelin was born 54 In addition, in their brief of April 10, 2014, they “advised the Court that the State ha[d] filed a criminal complaint against Mr. Medina Ferreras on March 4, 2014,” and that “Willia[n] Medina Ferreras ha[d] forwarded [them] the notification of the institution of an action to annul his birth certificate, considering that the data provided was false.” A copy of this was forwarded to the Court. 55 Cf. Report of the Dominican Government of July 6, 2012, on the measures adopted to comply with the Commission’s recommendations (file before the Commission, fs. 2165 to 2170). 25