The Ecuadorean State ratified the American Convention on Human Rights on December 28, 1977, and accepted the contentious jurisdiction of the Court on July 24, 1984. The Commission has designated Commission member Rose Marie B. Antoine and the Executive Secretary, Emilio Álvarez Icaza L., as its delegates. In addition, Elizabeth Abi-Mershed, the Assistant Executive Secretary, and Silvia Serrano Guzmán, Fanny Gómez Lugo, and Selene Soto Rodríguez, attorneys of the IACHR Executive Secretariat, will serve as legal advisers. In keeping with Article 35 of the Rules of Procedure of the Inter-American Court, the Commission attaches a copy of report 81/13 on the merits, prepared in observance of Article 50 of the Convention, as well as a copy of the entire file on the case before the Inter-American Commission (Appendix I) and the annexes used in preparing report 81/13 (Annexes). The Ecuadorean State was apprised of the report on the merits through a communication dated December 11, 2013, which gave it a period of two months to report on its compliance with the recommendations. Between that point and now, the Commission granted a series of extensions to the Ecuadorean State. During those extension periods, a dialogue took place between the two parties; the Inter-American Commission participated, attempting mediation to achieve a possible agreement on compliance with the recommendations. Despite this, no agreement was reached between the parties on the scope, content, and manner of implementation of reparations to Mr. Homero Flor Freire. Although public apologies were issued on July 28, 2014, the Commission, considering the disagreement between the parties on the remaining reparations and the consequent lack of full reparations, decided to submit to the jurisdiction of the Court all of the facts and human rights violations described in report 81/13 on the merits, given the need to obtain justice for the victim in this case. The Commission requests the Court, therefore, to conclude and declare that the Ecuadorean State is responsible for the violation of the rights enshrined in Articles 24, 8.1, and 25.1 of the American Convention with respect to Articles 1.1 and 2 of that instrument, to the detriment of Mr. Homero Flor Freire. Accordingly, the Commission requests of the Inter-American Court that the reparatory measures it orders be consistent with the recommendations issued by the IACHR, as follows: 1. Issue full reparations to Mr. Homero Flor Freire, as indicated in the report, in both material and moral terms, including measures to indemnify him for the damage caused. 2. Recognize publicly that Mr. Homero Flor Freire was discharged from the Ecuadorean Ground Forces in a discriminatory manner. 2

Select target paragraph3