6 28. Secondly, the petitioners argued that in some cases, identification documents were confiscated and the safe-conducts granted pursuant to the provisional measures ordered by the InterAmerican Court to serve as permits for legal residence or work permits were destroyed, which compounded the alleged victims’ suffering. 29. Thirdly, the petitioners claimed that the alleged victims were subjected to degrading treatment; they were forced to leave their families and live in a country where they knew no one, did not know either the language or the culture, did not have the means necessary to survive, and lived in dire poverty. In the expulsions, no consideration was given to each family’s circumstances, a fact that, according to the petitioners, caused severe emotional harm. They also asserted that the constant threat of possible re-deportation -assuming they were able to return to the Dominican Republic- inflicted permanent psychological damage on the alleged victims. The petitioners underscored the fact that Benito Tide Méndez, William Medina Ferreras, Wilda Medina, Luis Ney Medina, Carolina Isabel Medina, Jeanty Fils-Aime, Nene Fils-Aime, Antonio Fils-Aime, Diane Fils-Aime, Marilobi Fils-Aime, Endry Fils-Aime, Andren Fils-Aime, Juan Fils-Aime, Berson Gelin, Ana Lidia Sensión, Reyita Antonia Sensión, Rafaelito Pérez Charles, Víctor Jean, Miguel Jean, Victoria Jean and Nathalie Jean were born in the Dominican Republic and had lived there their entire life. 30. They further maintained that the expulsions took a heavy toll on the alleged victims’ next of kin left behind in the Dominican Republic, as the separation of the family and the lack of any information as to the whereabouts and circumstances of their deported family member caused severe anguish for the next of kin of Carmen Méndez, Aíta Méndez, Domingo Méndez, Rosa Méndez, José Méndez, Teresita Méndez, William Gelin, Antonio Sensión, María Esther Medina Matos, Jairo Pérez Medina, and Gimena Pérez Medina. 31. As for the obligation to protect the rights of the child, the petitioners make the case that the Dominican government failed to protect the best interests of the deported children by separating them from their families, failing to separate them from adults while in custody, and failing to take special measures to protect them against discrimination, inasmuch as: three children in the Medina family were forced to walk to the prison and spent the night behind bars; Carolina, who was sick with the flu, received no medical attention; the Fils-Aime children were taken from their home and bussed to the border at night, where they were forced to cross into Haitian territory by fording a river; the Sensión daughters did not receive the special treatment they were due as minors; and at time of his first expulsion, Berson Gelin was just 14 years old. 32. As for the right to freedom of movement and residence, the petitioners argued that collective expulsions are strictly prohibited by the Convention and that the alleged victims were denied the possibility of moving freely through and living in the country where they had been born and/or had established their ties of kinship and residence. They pointed out that in the individual and collective expulsions, the right to due process established by law was not observed and the persons being expelled were not permitted to prove their nationality. 33. Specifically, the petitioners claimed that Dominican immigration officials detained the alleged victims and expelled them from the Dominican Republic in less than 24 hours, denying them individual legal proceedings to review the merits of each case in order to determine their immigration status and/or family ties. The Dominican officials and soldiers utterly ignored the alleged victims’ attempts to prove their nationality, which suggests that factors other than “individual considerations” were the basis for the expulsion. 34. As for the right to nationality, the petitioners observed that actions taken by the Dominican authorities had the effect of robbing the alleged victims of their nationality and converting them into stateless persons. They stated that the method of expulsion used by the Dominican Republic allegedly involved arbitrary and indiscriminate destruction of identification documents. The de facto consequence of this practice was to unlawfully deprive the following persons of their Dominican nationality: Mr. Tide Méndez, Mr. Gelin (whose safe-conduct was destroyed), the Medina Ferreras and Fils-Aime families and the daughters of Mr. Sensión, who were denied their rights as Dominican citizens