-9- Latin America (WOLA);17 10) the Human Rights Department at the Universidad Iberoamericana, Mexico City;18 11) Ernesto Mendieta Jiménez, lawyer and professor on issues of public and private security;19 12) Moisés Moreno Hernández, professor of Criminal Law and Policy;20 13) Amnesty International;21 14) the Director of the International Criminal Law Research Group at the Universidad Santo Tomás;22 15) the Asociación Alto al Secuestro, A.C.,23 and 16) the Federal District Human Rights Commission.24 12. Final written arguments and observations. On December 17, 18 and 20, 2017, the representatives and the State forwarded their final written arguments, together with certain annexes, and the Commission presented its final written observations. 13. Disbursements in application of the Legal Assistance Fund. On January 15, 2018, the report on the disbursements made from the Court’s Legal Assistance Fund in this case with its annexes was forwarded to the State. On January 25, 2018, the State advised that it had no observations to make on the said report. 14. Helpful information and evidence. The parties presented the helpful information and evidence requested by the judges during the public hearing with their final written arguments. In addition, on August 24 and 31, 2018, the acting President of the Court for this case asked the State to present information and another item of helpful evidence. The State presented this on September 12, 2018. to the State’s international obligations in relation to sexual torture and violence against women, and also the insufficiency of the actions taken by the Mexican State in relation to the facts suffered by the eleven victims in this case. 16 The brief, signed by Gastón Chillier as Executive Director, refers to the State's obligation to protect and ensure human rights in the context of social protests, especially to prevent the use of force resulting in acts of sexual torture. The brief, signed by Maureen Meyer as Director for Mexico and Migrant Rights, refers to abuses and repression perpetrated by the Mexican police, incomplete reforms of the police force in Mexico, police internal controls and their effectiveness, and also the deficiencies in the Mexican legal framework in relation to the use of force. 17 The brief, signed by José Luis Caballero Ochoa, as Director of Law at the Universidad Iberoamericana; Juan Carlos Arjona Estévez, Professor of the Master’s program on human rights at the Universidad Iberoamericana; Michelle Guerra, Human Rights Defender, and Ximena Jiménez, law student at the Universidad Iberoamericana, refers to the situation of social protest in Mexico and the State’s position towards this, the participation of women in this context, and torture used as a punishment for participation. 18 The brief refers to the differentiation between the rights, obligations and responsibilities of the agents who use force and those of their superiors, as well as to the circumstances in which force is used. 19 The brief refers to the regulations concerning perpetrators and masterminds of crimes in the laws of Mexico to affirm that, based on criminal law, the attribution of individual criminal responsibility corresponds to the Mexican courts. 20 The brief, signed by Carolina Jiménez as Deputy Director of Research for the Americas, and Ashfaq Khalfan, as Director of the Legal Program, refers to the absolute prohibition of torture and other ill-treatment such as sexual violence, and the obligation of the State to investigate such acts with a gender perspective. 21 The brief refers to the complementary competence of the jurisdiction of the States Parties to the International Criminal Court, the scope of the control of conventionality of that Court, the definition of command responsibility in international criminal law, and its exclusion from the domestic criminal legislations. 22 The brief, signed by María Isabel Miranda Torres de Wallace as President of Alto al Secuestro, A.C., reiterates that, in Mexico, torture, in addition to being a crime, is a violation of human rights. It also analyzes the effectiveness of Mexican practice in relation to investigating and documenting torture, and the rule of exclusion of evidence. 23 The brief, signed by Nashieli Ramírez Hernández as President of the Federal District Human Rights Commission, refers to the situation of social protest in Mexico, the attribution of responsibility through the chain of command, and sexual violence in the context of social conflicts. 24

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