3. Submission of the case to the Court. – On July 17, 2020, the Commission submitted to the jurisdiction of the Inter-American Court all of the facts and violations of rights contained in Articles 8(1) and 25(1) of the American Convention, in conjunction with the obligations established in Articles 1(1), 19 and 24 thereof and Articles 7(b) and 7(f) of the Inter-American Convention to Prevent, Punish and Eradicate Violence against Women (hereinafter “Convention of Belém do Pará”), and for the violation of the rights established in Articles 5(1) and 11(2) of the American Convention, read in conjunction with the obligations established in Article 1(1) thereof, “in the face of the need to obtain justice for the [alleged] victim.”3 This Court notes that, between the presentation of the initial petition before the Commission and the submission of the case before the Court, more than eight years have passed. 4. Requests of the Inter-American Commission. – The Commission asked the Court to declare the international responsibility of the State for the same violations indicated in its Merits Report. It also asked the Court to order the State to order reparation measures, which are detailed and analyzed in Chapter VIII of this judgment. II PROCEEDINGS BEFORE THE COURT 5. Notification to the State and the representatives. – The Court notified the State and the alleged victims’ representatives (hereinafter “the representatives”) of the submission of the case by the Commission, on September 21, 2020. 6. Brief with pleadings, motions and evidence. – On November 20, 2020, the representatives presented their brief with pleadings, motions and evidence (hereinafter “brief of pleadings and motions”) to the Court, in accordance with Articles 25 and 40 of the Rules of Procedure.4 The representatives substantially agreed with the arguments of the Commission and asked the Court to declare the State’s international responsibility for the violation of the same articles indicated by the Commission, and, additionally, the violation of Articles 25 and 5(2) of the American Convention and Articles 6 and 9 of the Convention of Belém do Pará.6 7. Answering brief. – On February 17, 2021, the State presented to the Court its brief of preliminary objections and response to the submission and Merits Report of the Inter-American Commission and the brief with pleadings, motions and evidence (hereinafter “answering brief”), under the terms of article 41 of the Court’s Rules of Procedure.7 In said brief, the State filed two 3 The Commission appointed, as its delegates to the Court, the then Commissioner Flávia Piovesan and the then Executive Secretary Paulo Abrão. In addition, it appointed as legal advisors Marisol Blanchard Vera, then Deputy Executive Secretary, and Jorge Humberto Meza Flores, current Deputy Executive Secretary. 4 The alleged victim in this case is represented by Elizabeth C. Solander, Diego F. Durán de la Vega, Alyssa M. Johnson, Shayda Vance and Alexander Bedrosyan, of Hughes Hubbard & Reed LLP; Parker Palmer, of A Breeze of Hope Foundation; Rosa Celorio, of International And Comparative Legal Studies at George Washington University Law Center; Bárbara JiménezSantiago, from Equality Now; Shelby R. Quast, of Quast & Associates, LLC; Beth Stephens, Child And Family Advocacy Clinic at Rutgers School Of Law – Camden; Carmen Arispe, from the Una Brisa de Esperanza Center, and Jinky Irusta, from the Women's Legal Office. In their brief of requests and arguments, the representatives requested that the Court declare that Bolivia is responsible for the violation of “[a]rticle 1(2) of the American Convention, which requires States to adopt the laws necessary to give effect to the rights or freedoms referred to in Article 1(1).” Considering the description of the aforementioned provisions of the Convention and the arguments presented by the representatives in this regard, the Court warns that the mention of “Article 1(2) of the American Convention” is a material error and should be read as “Article 2 of the American Convention.” 5 6 However, in their written observations on the preliminary objections, the representatives “withdrew their formal claims for reparation under” Articles 6 and 9 of the Convention of Belém do Pará. 7 The State appointed Alberto Javier Morales Vargas, then State Attorney General, as its representative in the case. On December 22, 2022, the State requested the update of its representatives in the case, appointing Wilfredo Franz David Chávez Serrano as State Attorney General; Patricia Guzmán Meneses, Deputy Attorney for Defense and State Legal Representative, and Jhauneth del Rosio Bustillos Bustillos, Director General for Protection of Human Rights and the Environment. 5