11. Final written arguments and observations. On April 20 and 22, 2022, the State, the representatives, and the Commission submitted their respective final written arguments and final written observations. 12. Observations on the annexes to the final arguments. On May 23, 2022, the State commented on the annexes presented by the representatives. On May 25, 2022, the Commission stated that it did not have comments on the annexes to the parties’ final written arguments, and the representatives presented observations on the annexes to the State's final written arguments. 13. Victims' Legal Assistance Fund. On April 22, 2022, with their final written arguments, the representatives informed the Court that they would not present documentation for expenses to be paid for by the Court's Assistance Fund, as those expenses had not been significant. As such, the Court understands that the representatives have ceased use of said Fund, and it hereby closes the corresponding expense file. 14. The Court deliberated this judgment on June 25, 27, and 30, 2022. III JURISDICTION 15. The Inter-American Court has jurisdiction to hear this case pursuant to Article 62(3) of the American Convention because Brazil has been a State Party to the American Convention since September 25, 1992, and accepted the contentious jurisdiction of this Court on December 10, 1998. IV PRELIMINARY OBJECTIONS 16. In the sub judice case, the State lodged three preliminary objections, which are detailed below. A. Lack of ratione temporis jurisdiction with respect to events that occurred prior to the date of recognition of the Court’s jurisdiction A.1. Arguments of the parties and the Commission 17. The State asked the Court to declare its lack of ratione temporis jurisdiction with respect to alleged human rights violations that occurred or began prior to December 10, 1998. It stated that the Commission submitted to the Court events that occurred between September 25, 1992, 14 and December 10, 1998, and that those events are outside the jurisdiction of the Court. It argued that the Court has jurisdiction to analyze possible violations, in the terms submitted by the Commission, only if the events are proven or deduced to have begun after December 10, 1998, and if the violations constitute specific, discrete denials of justice. Finally, it stated that neither the Commission nor the representatives identified the specific independent events that occurred after December of 1998 that would constitute a violation of the Convention, and that for this reason the case should be dismissed. 18. The Commission emphasized that its submission of the case referred exclusively to events that began or continued after December 10, 1998—primarily the alleged failure to exercise due diligence in the investigation and the factors that it argues led to a denial of justice. It also recalled that the Court has already established that it “can examine acts or facts that have taken place after the date of the said acceptance and that have generated instantaneous and continuing or permanent human rights violations.” 14 Brazil has been a State Party to the American Convention since September 25, 1992. 7

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