3 4. Conduct a serious, diligent, and effective investigation, within a reasonable time, to cast light on the acts of torture described by Mr. Ruano Torres, identify the guilty, and impose the corresponding penalties. 5. Take the applicable administrative, disciplinary, and criminal steps in connection with the actions and omissions of the state agents (police officers, prosecutors, public defenders, and judges of the various courts) whose actions contributed to the violations of José Agapito Ruano Torres’s rights. 6. Take the necessary steps to prevent similar incidents in the future, in compliance with the duty of preventing and guaranteeing the fundamental rights enshrined in the American Convention. Specifically, develop training programs for state officials that include the international provisions established in the Principles on the Effective Investigation and Documentation of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment and the Istanbul Protocol. In addition to the need to obtain justice as a result of the failure to comply with the recommendations of the merits report, the Commission deems that the case raises issues of InterAmerican public order. Specifically, the instant case would be an opportunity for the Court to engage in a novel examination on the right to the presumption of innocence. The Honorable Court is called upon to rule on the minimum investigatory requirements the State must fulfill in order to verify the identity of an individual before moving forward in a criminal proceeding and handing down a conviction against the individual. The case also raises the opportunity to analyze the scope of State responsibility for actions and omissions that may be committed by a public defender of an individual. Inasmuch as these issues have a consequential effect on Inter-American public order, as provided under Article 35.1.f of the Rules of Procedure of the Inter-American Court, the Commission proffers the following expert witness: 1. xxxxxxxxxxxx, who will provide testimony on international standards pertaining to the presumption of innocence and the right of defense. In particular, the expert will address the minimum steps that must be taken in an investigation in order to verify the identity of an individual in a criminal proceeding. The witness will also flesh out the criteria used in other human rights protection systems to differentiate between cases of violations of the presumption of innocence from cases of discrepancy in the assessment of the evidence. The expert will also discuss the right to defense and, specifically, how actions and omissions in the technical defense could entail international responsibility of the State. The expert will apply said standards to the facts of the instant case. Signed in the original Elizabeth Abi-Mershed Secretaria Ejecutiva Adjunta