2 2. In the following paragraphs, the Court summarizes the relevant facts in the case, as alleged by the Commission in the application: a) A resolution issued by the President of the Republic of Peru on November 27, 1984, agreed to grant Israeli-born Mr. Baruch Ivcher Bronstein (hereinafter “Mr. Ivcher”) Peruvian citizenship on the condition that he renounce his Israeli citizenship; b) On December 6, 1984, Mr. Ivcher renounced his Israeli citizenship; the following day the Minister of Foreign Affairs issued his Peruvian citizenship papers; c) One must have Peruvian citizenship to own shares in businesses licensed to operate television channels in Peru. In mid 1992, Mr. Ivcher owned 53.95% of the shares in the Compañía Latinoamericana de Radiodifusión S.A. (hereinafter “the Company”), the business that ran Channel 2 television in Peru; the Winter Zuzunaga brothers –Samuel and Mendel- (hereinafter “the Winter brothers”) owned the remaining 46% stake in the company; d) In April 1997, Channel 2’s program “Contrapunto” aired reports of torture committed by members of the Peruvian Army’s Intelligence Service, and of the millions paid to Mr. Vladimiro Montesinos Torres, an Intelligence Service advisor. Because of these exposés, agents from the National Treasury Police Bureau suggested to Mr. Ivcher that he change his editorial stance; e) On May 23, 1997, the National Treasury Police Bureau instituted proceedings against Mr. Ivcher, who did not appear because he was abroad. An arrest warrant was issued for Mr. Ivcher for failure to answer a summons to appear in court. That very day, the Executive issued a supreme decree regulating the Nationality Act and stipulating that naturalized Peruvians could lose their citizenship; f) On June 3, 1997, Mr. Ivcher filed a petition seeking a writ of amparo, given the threat to his citizenship that the recent decree could pose. The writ of amparo was denied on February 20, 1998. Other actions seeking to have the decree in question declared unconstitutional were dismissed; g) In June 1997, by an administrative resolution the Peruvian Government altered the composition of the Constitutional and Social Chamber of Peru’s Supreme Court. Later, that Chamber removed from its bench those judges who specialized in public law and replaced them; h) On July 10, 1997, as Channel 2 was announcing its broadcast of a report on the tapping of the phone lines of opposition candidates, the Director General of the National Police held a press conference where he explained the findings of a report done by the Office of the Director of Immigration and Naturalization to the effect that the file containing the documents required for Mr. Ivcher to receive his citizenship papers had not been located. It also reported that there was no proof that Mr. Ivcher had ever renounced his Israeli citizenship. On July 11, 1997, the Director General of Immigration and

Select target paragraph3