B. State 10. Bolivia argues that the acts of sexual violence against Brisa De Angulo are not attributable to the State, as they were not carried out, organized, directed, consented to, or permitted by the State or by any of its agents. It likewise notes that the facts were not foreseeable by the State, as they took place within the privacy of a family home, where the reach of the State is limited by respect for the right to privacy. 11. It also argues that the authorities, officials, staff, agents, and institutions of the Bolivian State performed in compliance with the obligation to refrain from any action or practice of violence against women, and rejected the claim that Brisa was re-victimized by the judicial system. It states that during the criminal process, the rights and guarantees of both parties were respected, due process was provided, and measures were taken to respect human rights. It adds that the forensic medical and psychological exams and the collection of statements from the alleged victim and potential witnesses were carried out with proper respect for the rights of Brisa De Angulo, and that the steps taken were necessary for and pertinent to investigating the incident and context. 12. Likewise, Bolivia argues that it acted with due diligence to prevent, investigate and impose penalties for violence against women and did not fail to provide protection. It explains that it has taken all appropriate measures, including legislative measures, to amend or repeal existing laws and regulations or to modify legal or customary practices that sustain the persistence and tolerance of violence against women. The State also rejects the accusation of an unjustified delay, arguing that it has put in place the domestic legislation and administrative provisions necessary to prevent, punish, and eradicate violence against women. It notes that the State did not have an opportunity to implement measures to prevent the attacker from harassing, intimidating, threatening, harming, or endangering the life or integrity of the victim, her family, or their property, as these facts were not communicated to the police or to any other State authority. The State also argues that it has established fair and effective legal procedures to protect women who have been subjected to violence which include, among other things, protective measures, a timely hearing, and effective access to such procedures. Lastly, Bolivia says it has the necessary legal mechanisms to ensure that women subjected to violence have effective access to restitution, reparations or other just and effective measures of compensation. III. ESTABLISHED FACTS A. Information on Brisa Liliana De Angulo and the facts between 2001 and 2002 13. Brisa Liliana De Angulo was born in Baltimore, the United States, on September 14, 1985. 3 She was the third of five siblings and grew up in a family formed by her parents, two Colombian professionals who worked in social assistance. Brisa's father was in charge of the Bolivian office of MAP International (MAP), a Christian organization that provides medical care to low income people. Because her parents worked in rural areas, Brisa and her siblings got their education through distance learning in the US education system. In September 2001, Brisa turned 16 and was living in Chilimarca, Cochabamba, Bolivia, with her parents and two younger sisters. In addition to studying, Brisa did social and educational work with children and older persons in programs related to MAP. Her two older brothers—with whom Brisa had a very close relationship—had moved to the United States to continue studying. On August 21, 2001, a Colombian cousin, Eduardo Gutiérrez Angulo, 26 years old, came to live with the family. He had been studying veterinary medicine and was to intern in one of the MAP programs in Chilimarca. According to Brisa's account and to a social report attached to the case file, Eduardo quickly filled the space of affection and trust that had been left open by the two older brothers in the family when they left for the United States.4 Certification of Vital Record. State of Maryland. State File Number: 1985-41571. Document attached to the comments on the merits of Bolivia, May 11, 2018, Annex 5 – evidence provided by the Office of the Public Prosecutor, pages 1-4. 4 Social report by Judith Romero C. Defensa de Niños y Niñas Internacional, Bolivia office, August 21, 2008. Document attached to the comments on the merits of Bolivia, May 11, 2018, Annex 5 – evidence provided by the Office of the Public Prosecutor, pages 58-59; Statement of Brisa Liliana De Angulo, December 9, 2011, document attached to the petition before the IACHR of January 20, 2012, Annex 1, pgs. 1-2; Statement from young Brisa de Angulo Losada, August 1, 2002. Document attached to the comments on the merits of Bolivia, May 11, 2018, Annex 1 – Criminal proceedings, page 6. 3 3