24. As for the modus operandi, the IACHR has identified that, in some instances, deaths are staged as confrontations or armed engagements during routine procedures, in the course of carrying out either arrest warrant or search warrant operations. In these cases, the victim is killed at the site of the operation and under the pretext of an armed confrontation of a criminal with the police forces.3 In other cases, the executions take place once the victims have been illegally and/or arbitrarily detained and are under state custody. In other circumstances, after illegal raids are conducted by hooded or unidentified individuals, the victims are murdered by them.4 25. Based on information documented by Venezuelan civil society organizations, the Commission also has established that this phenomenon more commonly affects the “more humble sectors,” in the context of preventive operations or plans aimed at the detection, detention and retention of citizens for allegedly criminal conduct. Thus, “[…] the alleged persons involved are arrested and without taking the appropriate measures for in fraganti commission of crimes. Or while they are being arrested, they are brutally apprehended, by beating […] and in many instances, [they are] shot at point blank range in the presence of witnesses, brought to the police unit wounded, they appear dead later in an abandoned site or are admitted to a hospital or medical facility with no vital signs.”5 26. Other elements have also been identified as part of said modus operandi such as: threats against and murder of eye witnesses to the crimes, who because of this situation “generally are not part of the investigation into the crimes that the Ministry of Public Prosecution is conducting;” “moving of the location of the event” including tampering with or altering evidence, and criminalization of the victims in the eyes of public opinion to justify their deaths “as an effective response given by the authorities after an act of crime has taken place (generally theft or robbery) with the victim being the main perpetrator.”6 Separately, the 2001 Annual Report of the Office of the Ombudsman of the People identified as one of the “common elements favoring impunity” in these cases, “[…] acceptance of the discourse of police confrontation by law enforcement agencies and by the citizenry itself, by virtue of which such acceptance leads to a failure to conduct the respective criminal investigations.”7 27. In the case of the Barrios Family v. Venezuela, the IACHR determined the existence of a broad context of extrajudicial executions by regional police forces in Venezuela with a significant incidence of it in the State of Aragua.8 In the case of the Landaeta Mejías Brothers et al v. Venezuela, the IACHR found that “the problem is structural in nature, resulting from numerous factors, and revealed serious flaws in the institutional design of the police forces, the absence of independent and effective oversight mechanisms, and the acute situation of impunity of this type of case.”9 The Inter-American Court also determined in this case 3 IACHR. Report on the Situation of Human Rights in Venezuela, October 24, 2003, para. 333. Citing: COFAVIC/Venezuela, Democracy and Human Rights, Mid-Year Report: January – August 2002. Also see: Provea, Annual Report N° 14, Caracas, Venezuela; COFAVIC/Parapolice groups in Venezuela, 2005. Pgs. 29 to 33; Human Rights Watch, Annual Reports 1998 and 1999. 4 See: IACHR. Report on the Human Rights Situation in Venezuela. October 24, 2003, paras. 321 – 343. 5 Balance de la Situación de los Derechos Humanos en el Estado Aragua entre julio de 1996 y marzo de 2003 [Taking stock of the Situation of Human Rights in the State of Aragua from July 1996 to March 2003’], authored by the Commission on Human Rights, Justice and Peace of the State of Aragua. Citing: IACHR. Report No. 58/12. Case 12.606. Merits. Landaeta Mejías Brothers. Venezuela. March 21, 2012. 6 See: Annex 1. COFAVIC/Los grupos parapoliciales en Venezuela [Para-police groups in Venezuela’], 2005, pgs. 28-33. Available at: https://issuu.com/ddhhcofavic/docs/grupos_parapoliciales_en_vzla_cofavic 7 Annex 2. Office of Ombudsman of the People of Venezuela. Report: Ajusticiamientos y Desapariciones Forzadas. Anuario [‘Executions and Forced Disappearances. Annual Report’] 2001. Available at http://www.defensoria.gob.ve/lista.asp?sec=1404080002 Citing: IACHR. Report No. 11/10. Case 12.488. Merits. Members of the Barrios Family. Venezuela. March 16, 2010. 8 See: IA Court of HR. Case of Barrios Family v. Venezuela. Merits, Reparations and Costs. Judgment of September 24, 2011. Series C No. 237, para. 38. 9 See: IA Court of HR. Landaeta Mejías Brothers et al v. Venezuela. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 27, 2014. Series C No. 281, para. 47. 5

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