3 Naturalization issued a decision that had the effect of stripping Mr. Ivcher of the rights and privileges inherent in Peruvian citizenship; i) As a result of a petition of amparo filed by the Winter brothers, Mr. Percy Escobar, provisional Criminal Judge appointed to the Special Public-Law Court, ordered suspension of Mr. Ivcher’s rights as majority shareholder in the Company and his appointment as Director and President. He also ordered that a Special Shareholders Assembly be called to elect a new board of directors. He prohibited transfer of Mr. Ivcher’s assets and gave the Winter brothers tentative control of the Company; j) The challenges brought by Mr. Ivcher starting in July 1997 seeking to have the decision that had revoked his citizenship vacated and its consequences suspended did not prosper; k) On September 19, 1997, Judge Percy Escobar, assisted by Peruvian police, handed over management of the Company to the Winter brothers and refused to allow the journalists who worked on the “Contrapunto” program to enter the premises; and l) Mr. Ivcher’s voter registration was shown as nullified on the voter role for the elections held in Peru on October 12, 1998. III PROCEEDINGS WITH THE COMMISSION 3. On June 9, 1997, Peruvian Congressman Javier Diez Canseco advised the Comission that Mr. Ivcher might possibly loss his Peruvian citizenship. On July 16, 1997, the Dean of the Lima Bar Association, Mr. Vladimir Paz de la Barra, filed a complaint with the Commission alleging that the Peru had revoked Mr. Ivcher’s Peruvian citizenship. 4. The Commission formally opened the case on July 18, 1997, and requested information from the State in regard thereto. 5. On August 26, 1997, Mr. Ivcher requested a hearing with the Commission; as of this request, the Commission regarded him as the principal petitioner and victim of the alleged violations. 6. Peru replied to the Commission on September 12, 1997, and requested that the petition be declared inadmissible. 7. On October 9, 1997, during the Commission’s 97th session, a hearing was held concerning the petition’s admissibility. 8. On February 26, 1998, during the Commission’s 98th session, a second hearing was held on the instant case’s admissibility. 9. By note of May 29, 1998, the Commission placed itself at the disposition of the parties to attempt a friendly settlement, and asked that they reply within 30 days. Following an extension granted at the State’s request, on July 31, 1998, the

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