5 [Group Torture Never Again]; Criméia Alice Schmidt de Almeida (Commission of the Next of Kin of the Politically Deceased and Disappeared Persons of the Institute of Studies on State Violence); Viviana Krsticevic, Beatriz Affonso, Helena Rocha, and Mr. Michael Camilleri (CEJIL). 4. On October 31, 2009, the State presented a brief wherein it filed three preliminary objections, responded to the application, and made observations to the brief of pleadings and motions (hereinafter “response to the application”). The State requested the Court to consider the preliminary objections founded, and as a consequence, to: a) recognize the lack of jurisdiction ratione temporis to examine the alleged violations which occurred prior to Brazil’s recognition of the contentious jurisdiction of the Court; b) declare it lacks jurisdiction because of the failure to exhaust domestic remedies, and c) immediately archive the present case given that the representatives do not have a legal interest in the proceedings. Alternatively, in regard to the merits, Brazil requested the Court to recognize “all the measures taken in the domestic forum” and “to declare as inadmissible the requests of the [Commission and representatives] given that within the country a solution is unfolding, compatible with its peculiarities, for the definitive consolidation of national reconciliation.” The State assigned Mr. Hildebrando Tadeu Nascimento Valadares as Agent and Mrs. Márcia Maria Adorno Calvalcanti Ramos, Camila Serrano Giunchetti, Cristina Timponi Cambiaghi, and Bartira Meira Ramos Nagado and Mr. Sérgio Ramos de Matos Brito and Mr. Bruno Correia Cardoso, as Deputy Agents. 5. Pursuant to Article 38(4) of the Court Rules of Procedure, on January 11th and 15th, 2010, the Commission and representatives, respectively, presented their arguments on the preliminary objections filed by the State. II PROCEEDINGS BEFORE THE COURT 6. The Commission’s application was notified to the State and the representatives on May 18, 2009.5 During the proceedings before this Court, in addition to the presentation of the main briefs (supra paras. 1 to 5), and others sent by the parties, in an order of March 30, 2010, the President of the Court (hereinafter, “the President”) required, by way of declarations rendered before a public notary (hereinafter, also “affidavit”), the statements and expert reports of: a) 26 alleged victims; one of them offered by the Commission, the other offered both by the Commission and representatives, and the others offered solely by the representatives; b) four witnesses; two proposed by the representatives and two by the State, and c) five expert witnesses; one offered by the Commission, two by the representatives, and two by the State,6 of which the parties were able to present their observations. Moreover, the President summoned the Commission, the representatives, and the State to a public hearing to listen to the testimonies of: a) three alleged victims; one offered jointly by the Commission and the 5 Before, on March 13, 2009, the State was informed that it could designate an ad hoc judge for the present case. The Commission presented a brief entitled, “Position of the Inter-American Commission on Human Rights on the role of the Ad hoc judge.” On June 12, 2009, Brazil designated Mr. Roberto de Figueiredo Caldas as judge Ad hoc, whom on June 24, 2009, accepted the charge. 6 Cf. Case of Gomes Lund et al. (“Guerrilha do Araguaia”) v. Brazil. Summons to a Public Hearing. Order of the President of the Inter-American Court of Human Rights on March 30, 2010, Operative Paragraph 1.