104 e) she requests “that the prolonged solitary confinement to which the prisoners were submitted be acknowledged as torture due to its extent, […] conditions, and the specific purpose of its application;” “Isolated confinement from the world and total control of the human being: its total institutionalization for its slow destruction” f) the regimen of absolute solitary confinement wanted to achieve complete control of the inmate’s environment, with two additional objectives: inflict mental suffering on the inmate due to lack of contact with their next of kin, and restrict the support and communication with the outside world. Lack of communication with the next of kin was also used to control the inmates’ will; g) the confinement of the prisoner to a 24-hour immobilization, as well as deprivation of light and exercise were a severe way to inflict human suffering. There was a specific order to keep them inactive, “they could only eat, defecate, and sleep;” h) according to a study “methods such as sensorial deprivation, isolation, sleep deprivation, forced nakedness, cultural and sexual humiliation, the use of military trained dogs to instigate fear, simulated killings, and threats of violence or death of detainees or their loved ones are forms of psychological torture;” “The use of forced nakedness, the use of dogs without muzzles against detainees” i) dogs without muzzles were used to intimidate and degrade helpless prisoners, in violation of Article 5 of the Convention and of the Manual of the United Nations in its Protocol of Istanbul; j) the nakedness to which the prisoners were submitted, accompanied by “brutal and sadistic beatings, and the exposure [to the] cold or the night for long hours” constituted severe suffering; “Electroshocks, phalanx, and blunt beatings on sensible parts of the body as a form of torture” k) the prisoners and the injured who survived the massacre were stripped of their clothes and beaten with irons, sticks, and electroshocks on the head, back, soles, ankles, lungs, spinal cord, ribs, hips, hands, liver, and kidneys. The aforementioned caused severe physical damage in the survivors, and in some cases made it impossible for them to walk for several days. She requests that these beatings be acknowledged by the Court as a form of torture, in breach of Article 5 of the American Convention; “Punishment Cells: The hole” l) the torture of the survivors included the use of a special punishment cell called “the hole”. This cell was made of metal; it measured approximately 1.70x2 mts., with a 10x10 cm. window, filled with water, rats, without water, and with a nauseating smell. The inmates secluded in the cell had to remain standing all day and night due to lack of space. There, the director of the