139 568. The representatives alleged that a “more exact” calculation of loss of earnings required taking into account a certain type of “annual increment” with regard to the “daily wage” and the “adjusted salary” that the victims received. They also referred to concepts such as an “integration factor” and “progressive wages for subsequent years.” They indicated that all the “factors” that the Court has developed in its jurisprudence and that are related to “weighing the age at the time of death, and the remaining years to complete the average life expectancy in the country in question should be included, as well as an “estimate” of the wages paid for the “type of work carried out by the victims,” and their “professional preparation and opportunities.” They indicated that the Tribunal should not subtract “25% for the personal expenses that the victims could have incurred,” because in the case of Bámaca Velásquez v. Guatemala, “the Court did not subtract this amount.” Lastly, they drew up a formula to calculate the loss of earnings, which they used to estimate the amounts owed to each victim under this heading.545 569. The representatives argued that Esmeralda Herrera worked “as a domestic employee,” received a monthly wage of $3,000.00 (three thousand Mexican pesos) and that, at the time of her death, she was 15 years old. Based on their formula, they calculated that Esmeralda Herrera’s total loss of earnings amounted to $15,520,085.59 (fifteen million five hundred and twenty thousand and eighty-five Mexican pesos with 59/100), which, in their opinion, would equal US$958,029.97 (nine hundred and fiftyeight thousand and twenty-nine United States dollars with 97/100), based on the exchange rate on February 20, 2008. 570. Regarding Claudia Ivette González, the representatives alleged that she worked in a “maquiladora” industry and that, at the time of her death she was 20 years old and earned a monthly salary of $2,000.00 (two thousand Mexican pesos). Based on their formula, they indicated that her loss of earnings amounted to $7,593,561.83 (seven million five hundred and ninety-three thousand five hundred and sixty-one Mexican pesos with 83/100) equaling US$703,107.57 (seven hundred and three thousand one hundred and seven United States dollars with 57/100). 571. In relation to Laura Berenice Ramos, the representatives indicated that, at the time of her disappearance she was 17 years of age, she worked in a restaurant as a cashier and received a monthly salary of $4,600.00 (four thousand six hundred Mexican pesos). Based on their formula, they indicated that her loss of earnings amounted to $20,400,026.75 (twenty million four hundred thousand and twenty-six Mexican pesos with 75/100), equal to US$1,888,891.36 (one million eight hundred and eighty-eight thousand eight hundred and ninety-one United States dollars with 36/100). 572. In their final arguments, the representatives advised that the total United States dollar equivalent for the loss of earnings of Esmeralda Herrera at the rate of exchange on June 12, 2009, was US$772,143.56 (seven hundred and seventy-two thousand one hundred and forty-three United States dollars with 56/100), and that of Mss. González and Ramos, US$566,683.71 (five hundred and sixty-six thousand six hundred and eighty-three United States dollars with 71/100) and US$1,522,390.00 (one million five hundred and twenty-two thousand three hundred and ninety United States dollars), respectively. 573. The State, for its part, reported that Esmeralda Herrera carried out “domestic cleaning” tasks and that, in the State of Chihuahua, the average wage for this type of 545 The representatives exhibited tables calculating the amount of the victims’ loss of earnings, but did not explain how the formula had been developed (case file of attachments to the pleadings and motions brief, volume XXIII, attachment 19, folios 8099 to 8105).