338. In relation to certain presumed victims regarding whom it was alleged that they were in detention centers, 372 it provided two certifications issued by the General Directorate of Prisons indicating that these persons were not detained in the said prisons at the time of the events. Accordingly, and in view of the supposed lack of evidence of the alleged “retention” of the presumed victims, the State considered it unnecessary to refer to the supposed non-compliance with the guarantees established in Article 7 of the American Convention. 339. The State also rejected all the arguments related to the collective expulsions of Haitian nationals, affirming that it “does not carry out collective or mass deportations of Haitians.” According to the State, in “agreement with the […] version of the Commission […] and the representatives,” “all the presumed victims […] had been questioned by the immigration agents regarding their identity document and none of them showed this, either at the time or subsequently. […] Consequently, the State agents would have investigated the legality of their permanence in the country, so that the deportation process had been individualized. If any of the foreign presumed victims had shown a Haitian passport with a visa, or a work permit authorized by the General Directorate of Immigration, they would not have been deported.” Furthermore, regarding the expulsions of Dominican nationals of Haitian origin or descent, the State asserted that it had “never repatriated a Dominican who had been detained and who, during the verification procedure, had produced documents to prove his condition as a national.” 340. In addition, the State stressed that, after they had supposedly been deported or expelled, the presumed victims returned to the country without any type of impediment, either hidden in a bus that transported migrant workers or crossing the guarded border on foot. According to the State, given the ease with which individuals could enter national territory, it could not be proved reliably with circumstantial situations that the State’s immigration agents had really deported or expelled any of the presumed victims. Regarding a national immigration policy based on racial profiling or skin color, the State rejected the allegations and indicated that it would be ineffective, because the Haitian physiognomy was extremely similar to that of a large part of the Dominican population. 341. The State also argued that, at the time of the events, several effective domestic remedies existed: the application for amparo, the possibility of habeas corpus established by Law No. 5353 of October 22, 1914, and the contentious-administrative proceeding established by Law No. 1494 of August 9, 1947, that would have allowed any of the presumed victims to question the lawfulness of their detention and the decision of the Dominican authorities to deport or expel them. The State indicated that the presumed victims “had the real and effective opportunity to file” the remedies and that there is no evidence in the case file to prove that any of them filed any of the remedies established by the contentious-administrative jurisdiction. Lastly, the State asserted that “there is no evidence in the case file to substantiate the material losses of the [presumed] victims,” or “that, at any time, they had possessed such objects, money or household goods.” 342. Based on the above and “the lack of evidence in the file of this case,” the State asked the Court to declare that it had not violated the rights recognized in Articles 7, 8, 19, 22(1), 22(5) and 22(9) and 25 of the American Convention, in relation to Article 1(1) of this instrument, to the detriment of certain presumed victims. 373 372 The State indicated this in its answering brief in relation to “the supposed detentions” of Willian Medina Ferreras, Lilia Jean Pierre, Awilda Medina, Luis Ney Medina and Carolina Isabel Medina (deceased) were in the prison of Oviedo, Pedernales; Rafaelito Pérez Charles in the prison of San Cristóbal; Jeanty Fils-Aimé (deceased) in the Pedernales prison, and “Bers[s]on Gelin” in the Barahona prison. 373 The State indicated the following, among others: Willian Medina Ferreras, Lilia Jean Pierre, Awilda Medina, Luis Ney Medina, Carolina Isabel Medina, Jeanty Fils-Aimé, Janise Midi, Nené Fils-Aimé, Diane Fils-Aimé, Antonio 110