of donations," 62 and iii) that they did not find the donation request to PDVSA by the Civil Association, as only the project proposal was found. 63 3.2. Investigative phase 47. On September 8, 2003, an order was issued to proceed with the start of the investigative phase, documented in the Case File No. 22/001/2003, which began in the framework of the reviews conducted by the Department of Industry Oversight. The record shows, inter alia, that: i) on May 14, 1998, Mr. López Mendoza had accepted “the Declaration on Conflict of Interests with the Board of Directors of [PDVSA], wherein he stated he was not the Principal Director, nor substitute nor employee, nor had he taken on executive, director, or administrative positions in any other institution, company, or commercial, industrial, or financial firm” 64 and ii) at the time of the donation, Mr. López Mendoza “was an active employee in PDVSA and formed part of the Board of Directors of the mentioned association.” 65 For this reason, the Department of Industry Oversight concluded that “sufficient elements existed to create an administrative file of the case, and it ordered, among other aspects, that legal notice be provided to those persons who were responsible for an action, event, or omission […] and to incorporate the documentary evidence provided by the interested parties into the case file.” 66 48. On September 12, 2003, 67 legal notice was provided to Mr. López Mendoza of said order to initiate, wherein he was informed that the Comptroller “is carrying out an investigation on the contributions made by […] PDVSA for donations and grants during the years 1998, 1999, 2000, and 2001,” and a period was set in which to gather the evidence deemed necessary for his defense. 68 Finally, he was informed that “he would be informed of the results of the investigation […], in the corresponding Report on Results, which would remain in Case File No. 22/001/2003.” 69 49. On October 31, 2003, Mr. López Mendoza presented a brief in relation to the investigated facts, wherein he argued “that the fiscal oversight body did not comply with its obligation to inform him ‘in a specific and clear manner on the facts of the charges 62 Act of the officials of the Comptroller General of the Republic adjoined to the General Office of Decentralized Administrative Oversight, in the Office of Industry Oversight, supra note 61, folio 7754. 63 In the action, it was stated that the citizens mentioned therein had ten (10) working days to expose, in writing, and before the Comptroller General of the Republic, their observations regarding that mentioned. Act of the officials of the Comptroller General of the Republic adjoined to the General Office of Decentralized Administrative Oversight, in the Office of Industry Oversight, supra note 61, folio 7755. 64 Order to proceed of the Office of Industry Oversight of September 8, 2003, Case file No. 22/001/2003 (Case file of annexes to the answer to the application, tome XIX, annex A, folio 7455). 65 Order to proceed of the Office of Industry Oversight of September 8, 2003, supra note 64, folio 7456. 66 Cf. Order to proceed of the Office of Industry Oversight of September 8, 2003, supra note 64, folio 7456. 67 Cf. Official letter No. 06-02-780 of the Office of Industry Oversight of September 12, 2003 (Case file of annexes to the application, tome I, annex 5, folios 252 to 256). 68 Cf. Official letter No. 06-02-780 of the Office of Industry Oversight of September 12, 2003, supra note 67, folios 252 to 255. 69 Official letter No. 06-02-780 of the Office of Industry Oversight of September 12, 2003, supra note 67, folio 256. 22