wall or lie facedown and strip to perform searches,30 and they started to strike them with clubs, pipes, peinillas, and báculas,31 “with whatever they had in their hands.”32 One inmate, named “Santos de Jesús, “was hurt by the Guards and needed an operation because he was ruptured inside.”33 An inmate named Gervacio Echeverría stated, “I wasn’t able to see when they killed the inmates. They put us in positions so we couldn’t see [...] but the officials took them out or hid them and disappeared them to kill them...”34 The inmates specifically reported the violent actions of a National Guard member named Franchi (referred to as “Franchelli” or “Apocalypse.”)35 27. They were unanimous that what happened was not a riot control operation. On that day, they said, “we had been told that the prison would be subject to intervention” following the strike.36 One stated that “[the night before], I talked with my wife and told her that the prison was subject to intervention and they were going to transfer us. In the morning, my wife and the relatives of the other inmates were there” when the Veloz, the Intervention Director, entered the prison, followed by the National Guard, shooting.37 They insisted that there were no problems between the inmates that morning,38 that the prison was calm,39 and that none of the inmates were armed that day.40 They stated that the National Guard members “were in battle dress uniform, they entered firing,”41 and that they did not use riot control equipment or teargas: “they only used bullets.”42 28. News items agree that “before roll call, officials from the National Guard and prisons entered the prison. Witnesses say they were ordered to strip and beaten with peinillas, clubs, pipes, and all manner of objects. The leaders and spokesmen of the protest they led two weeks prior were then picked out.”43 Likewise, “there are worrying accounts according to which more than 50 members of the National Guard, in coordination with the prison guards, attacked the prison population, especially the inmates that led the ‘self-kidnapping’ on October 20 in which they demanded better living conditions and that resulted in the dismissal of the prison director and the commanding officer of the National Guard.”44 29. Several inmates said that on the day of the facts, “Goyo” Bolívar and “El Chileno,” Orlando Olivares, were in the minimum-security area.45 Regarding what happened to “Goyo,” inmates stated that after he was beaten by a guard named “Julio,”46 he was killed by a member of the National Guard with shots to the head; several stated that it was Captain Campos who fired the first two shots at his legs47 and then shot him in the head, and others indicate that National Guard member Franchi also participated.48 The theory of the Public Prosecutor in the case is that Captain Campos killed Goyo.49 Several stated that Goyo “was asking for help,”50 Annex 10, 16, 11, 18, 14. Statements of Alcides Alcazar, Andi Bermúdez, Deivis Romero, Carlos Durán, and Alexander Rodríguez; Annex 13. El Universal, “Versiones encontradas de un cruento episodio” (5/12/2004). Annex to the initial petition. 31 Annex 15. Statement of Luis Enrique Figueira; Annex 10. Statement of Alcides Alcazar; Annex 16. Statement of Andi Bermúdez; Annex 13. El Universal, “Versiones encontradas de un cruento episodio” (5/12/2004). Annex to the initial petition. 32 Annex 16. Statement of Andi Bermúdez; also see Annex 15. Statement of Luis Enrique Figueira; Annex 13. El Universal, “Versiones encontradas de un cruento episodio” (5/12/2004). Annex to the initial petition. 33 Annex 15. Statement of Luis Enrique Figueira. Annex to the initial petition. 34 Brief on the merits from the State, section IV. 35 Annex 14. Statement of Alexander Rodríguez; also see Annex 17. Statement of Arón Palacios; Annex 15. Statement of Luis Enrique Figueira; Annex 9. Decision of the Criminal Court of Appeals of Ciudad Bolivar (3/6/04). Annex to the initial petition. 36 Annex 17. Statement of Arón Palacios; also see Annex 14. Statement of Alexander Rodríguez. Annex to the initial petition. 37 Annex 14. Statement of Alexander Rodríguez. Annex to the initial petition. 38 Annexes 11, 18, 16. Statements of Deivis Romero, Carlos Durán, and Andi Bermúdez. Annex to the initial petition. 39 Annexes 11, 18, 16. Statements of Deivis Romero, Carlos Durán, and Andi Bermúdez. Annex to the initial petition. 40 Annexes 11, 18, 16. Statements of Deivis Romero, Carlos Durán, and Andi Bermúdez. Annex to the initial petition. 41 Annex 16. Statement of Andi Bermúdez. Annex to the initial petition. 42 Annex 15. Statement of Luis Enrique Figueira; also see Annex 10. Statement of Alcides Alcazar. Annex to the initial petition. 43 Annex 8. La Nación, “Nunca imaginamos que lo iban a matar” (12/23/2003). Annex to the initial petition. 44 World Organization Against Torture. Venezuela: Ola de violencia en el Internado Judicial de Ciudad Bolívar dejar 7 muertos (12/1/2003). Available at: http://fidh-omct.org/es/urgent-campaigns/urgent-interventions/venezuela/2003/12/d16608/. 45 Annex 10. Statement of Alcides Alcazar. Annex to the initial petition. 46 Annex 15. Statement of Luis Enrique Figueira; Annex 10. Statement of Alcides Alcazar. Annex to the initial petition. 47 It should be noted that this detail contradicts the results of the autopsy conducted on March 22, 2004, which did not find any injuries on the extremities. See supra para. 28. 48 Annex 15, 10, 16, 11, 18. Statements of Luis Enrique Figueira, Alcides Alcazar, Andi Bermúdez, Deivis Romero and Carlos Durán; Annex 9. Decision of the Criminal Court of Appeals of Ciudad Bolivar (3/6/04). Annex to the initial petition. 49 Annex 9. Decision of the Criminal Court of Appeals of Ciudad Bolivar (3/6/04). Pg. 3. Annex to the initial petition. 50 Annex 11. Statement of Deivis Romero; also see Annex 10. Statement of Alcides Alcazar. Annex to the initial petition. 30 6

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