2
had stopped several times in front of the home of Mr. Suriel Núñez and his
family;”
c) “Since the incident, Mr. Suriel Núñez has received several calls to his mobile
telephone but nobody answers on the other end of the line and, in this context,
it causes him great anxiety and uncertainty as regards his vulnerability”;
d) “Mr. Suriel Núñez’s current physical condition is stable; however, the threat
suffered […] has caused him great tension, anxiety, and fear in view of the
possibility that a new threat to him may arise,” and
e) “In view of the threats and harassment, as well as the accident suffered by Mr.
Suriel Núñez, he and his wife decided to change their place of residence.”
3.
The representatives’
measures, including:
arguments
to
justify
their
request
for
provisional
a) “The harassment and threats suffered by Mario José Martin Suriel Núñez
constitute a situation of extreme gravity and urgency, due to the certain and
imminent risk of irreparable damage to his life and personal integrity, owing to
his participation in the [instant] case […], which is currently being heard by the
Court.” According to Article 63(2) of the American Convention this situation
“merits the adoption by the Inter-American Court of the provisional measures
necessary to avoid irreparable damage to the witness Mario José Martin Suriel
Núñez”;
b) Mr. Suriel Núñez is a founding member of the civil society organization
Comisión de la Verdad [Truth Commission], created by a group of Dominican
citizens who, following the alleged forced disappearance of Mr. Gonzalez
Medina, organized themselves in order “to demand justice”;
c) “The Comisión de la Verdad, together with the CEJIL and the lawyer Tomas
Castro Monegro, have taken numerous measures at both the domestic and the
international level in order to discover the whereabouts of Narciso Gonzalez, to
obtain an investigation into the circumstances of his disappearance, and to
bring those responsible to justice.” The measures taken by Mr. Suriel Núñez
include investigations and the gathering of evidence to discover the
whereabouts of Mr. Gonzalez Medina and the filing of complaints with the police
and the courts. “Mr. Suriel Núñez has been one of the main spokespersons for
the Comisión de la Verdad, preparing and publishing press releases, offering
interviews to the press, the television and radio, and even requesting meetings
with senior State officials”;
d) “Over the last 17 years, the family of Narciso Gonzalez, the members of the
Comisión de la Verdad and the lawyer Tomas Castro Monegro have been
victims of harassment and threats, and have been followed.” On November 8,
1996, the Inter-American Commission asked the Dominican Republic to
implement precautionary measures to guarantee the life and personal integrity
of “Virgilio Almánzar, Tomas Castro and Luz Altagracia Ramirez de Gonzalez, as
well as other witnesses in the case, due to the threats and harassment to which
they were subject after the case had been brought before the inter-American
system;”
e) When testifying before the Court during the public hearing on June 28, 2011,
Mr. Suriel Núñez stated that he had been threatened in the past, and that the
Police had been informed of these threats, but had not investigated them;
f) Mr. Suriel Núñez has participated in the international proceedings in the case of
Gonzalez Medina et al. both as the representative of the Comisión de la Verdad
and as a witness of the facts. Mr. Suriel Núñez testified both before the InterAmerican Commission and at the public hearing held before the Court on June
28, 2011. His last statement contains “aspects” that are “sensitive” and
fundamental for determining the State’s international responsibility, “which
could also be considered a threat by people linked to the forced disappearance