[…] it was a high-risk pregnancy and the necessary precautions were not taken. […] The physicians Poggi and Casavilla did not correctly interpret the facts indicated in the medical record. […] We believe that the most important risk factor for Ms. Britez Arce and her fetus was the deplorable quality of the care that she was given […].31 35. According to the expert report of the Catholic University of Córdoba, the medical record showed various omissions.32 The medical record also had another number, an altered number, in addition to which its pages were not all numbered, and various pages provide an incomplete name. This expertise, in addition to highlighting the flaws in the medical record and the care provided to both the fetus and the mother during the pregnancy, as well as negligence in the care provided on June 1, 1992, indicates that the experts Poggi and Casavilla did not correctly interpret the information that was given to them for preparing the expert report and states that “the conclusions reached by the physicians Poggi and Casavilla are unsubstantiated,” and points out that most of the facts appearing in the medical record were interpreted erroneously, and in conclusion they have strayed from what actually happened.33 36. On April 30, 1998, the complaint submitted a request for recusal of the investigating judge Guillermo Carvajal because of the following: i) the judge’s stake in the proceedings, with a bias favoring the defendants; and ii) prejudgment, for his way of assessing the case ahead of the hearings. The complaint noted that, although the inquiry must last only four months, according to Article 507 of the CPP, this case lasted almost five years. It added that although there was “conclusive evidence to indict the defendants Poggi and Casavilla,” they were acquitted on five occasions, with all of the acquittals overturned by the Fourth Chamber of the Criminal Court. It indicated he “ordered” an expertise from the Federation of Associations of Gynecology and Obstetrics (Federación de Asociaciones de Ginecología y Obstetricia―FASGO) “for the sole purpose of obtaining an expertise as a measure to compensate for that of Córdoba,” aimed at ensuring delays to bring into force the statute of limitations. It also stated that he did not respond to the request of the Prosecutor of the Court of First Instance Dr. Crous; to that of the court of second instance Dr. Sáenz; or to that of the same Fourth Chamber for the defendants to be investigated again.34 37. On June 18, 1998, the recusal was ruled inadmissible but Judge Guillermo Carvajal was given the recommendation “to carry out the proceedings with greater speed because, as indicated by the complainant, we would be coming close to barring the case because of the statute of limitations.”35 38. On October 21, 2002, the Court of Appeals upheld the ruling of the court of first instance which had acquitted the physicians Casavilla and Poggi. 36 This was done taking into account the responses of the last expert report in the case, conducted by the Academic Unit of Obstetrics of the Hospital de Clínicas, belonging to the Medical School of the University of Buenos Aires, in which it was said, among other things, that Cristina Britez Arce was not a high-risk patient and had a normal pregnancy and that the care given to her was adequate.37 3. Case 27.985/98, entitled MEDICAL EXAMINERS CORPS s/false witness statement, National Criminal Investigation Court No. 4, Secretariat 11338 39. On April 1, 1998, Mr. Miguel Ángel Avaro, father of Ezequiel Martin Avaro and Vanina Verónica Avaro, filed a criminal complaint against the 31 physicians who conducted the plenary expert report in case 21.375/96 of Expertise provided by the University of Córdoba on March 13, 1998. Annex to the initial petition. The expertise is provided as part of case 21.735 and annex 2.391. 32 Expertise provided by the University of Córdoba on March 13, 1998. Annex to the initial petition. The expertise is provided as part of case 21.735 and annex 2.391. 33 Expertise provided by the University of Córdoba. Annex to the initial petition. 34 Presentation of June 2, 1998 to Dr. Granillo Ocampo, Minister of Justice of the Nation. Annex to the initial petition. Likewise, recusal appeal on May 5, 1998. Annex to the brief of March 30, 2009 from the petitioners. 35 Ruling on the recusal appeal of June 18, 1998. Annex to the brief of March 30, 2009 from the petitioners. 36 Ruling on the appeal. Annex to the briefs of April 4, 2003 from the petitioners. See also statements of the state’s briefs of July 19, 2005 and September 27, 2018. 37 Ruling on the appeal. Annex to the briefs of April 4, 2003 from the petitioners. 38 Being heard by the investigating judge Mariano Osvaldo Berges. 31 8