Merits Report “given the need to obtain justice and reparation for the [alleged] victims.”2 4. Requests of the Inter-American Commission. Based on the foregoing, the Commission asked the Court to conclude and declare the State’s international responsibility for the violations established in its Merits Report (supra para. 2c) and to order the measures of reparation described and analyzed in Chapter IX of this judgment. The Court notes with concern that, between the presentation of the initial petition before the Commission and the submission of the case before this Court, more than 21 years have elapsed. II PROCEEDINGS BEFORE THE COURT 5. Notification to the State and to the representatives. The submission of the case by the Commission was notified by the Court to the State and to the representatives of the alleged victims3 (hereinafter “the representatives”) on August 14, 2019. 6. Brief of pleadings, motions and evidence. On October 21, 2019, the Gabinete de Assessoria às Organizações Populares (GAJOP) and the Center for Justice and International Law (CEJIL) presented their brief of pleadings, motions and evidence (hereinafter “pleadings and motions brief”) before the Court, pursuant to Articles 25 and 40 of the Court’s Rules of Procedure. The representatives agreed substantially with the arguments of the Commission and requested that the Court declare the violation of Articles 8 and 25 of the Convention, in relation to Articles 1(1) and 2 of the same instrument, and of Article 7 of the Convention of Belém do Pará, to the detriment of M.B.S, S.R.S. and Mt.B.S, mother, father and sister, respectively, of Mrs. Barbosa de Souza. They also alleged that the State violated Article 5 of the Convention, in relation to Article 1(1) of the same instrument, to the detriment of M.B.S, S.R.S. and Mt.B.S. Likewise, they asked the Court to order measures of non-repetition and to require the State to provide adequate reparation to the alleged victims. Through their representatives, the alleged victims also requested access to the Victim’s Legal Assistance Fund of the Inter-American Court (hereinafter “Assistance Fund of the Court” or the “Fund”). 7. Answering brief. On February 17, 2020, the State4 presented before the Court its answering brief to the submission of the case, to the Merits Report of the Inter-American Commission and to the pleadings and motions brief of the representatives (hereinafter The Commission designated Commissioner Antonia Urrejola Noguera and then Executive Secretary Paulo Abrão as its delegates. It also appointed Silvia Serrano Guzmán and Henrique Napoleão Alves, lawyers of the IACHR’s Executive Secretariat, as its legal advisers. 3 The representatives of the alleged victims are the Gabinete de Assessoria às Organizações Populares (GAJOP) and the Center for Justice and International Law (CEJIL). 4 On January 13, 2021, the State submitted to the Inter-American Court an updated list of its designated agents in the present case: Ambassador Antônio Francisco Da Costa and Silva Neto, Brazil’s ambassador in San José and agent of the State; Minister João Lucas Quental Novaes de Almeida, Director of the Department of Human Rights and Citizenship; Minister Marcelo Ramos Araújo, Head of the Human Rights Division; Secretary Ricardo Edgard Rolf Lima Bernhard, Deputy Head of the Human Rights Division; Secretary Daniel Leão Sousa, adviser of the Human Rights Division; Secretary Débora Antônia Lobato Cândido, adviser of the Human Rights Division; Secretary Lucas dos Santos Furquim Ribeiro, Human Rights Unit of the Embassy of Brazil in San Jose; Tony Teixeira de Lima, lawyer of La Unión; Dickson Argenta de Souza, lawyer of La Unión; Taiz Marrão Batista da Costa, lawyer of La Unión; Beatriz Figuereido Campos da Nóbrega, lawyer of La Unión; Andrea Vergara da Silva, lawyer of La Unión; Milton Nunes Toledo Juner, Head of the Special Counsel for International Affairs of the Ministry for Women, the Family and Human Rights (MMFDH); Bruna Nowak, coordinator of International Human Rights Disputes of the Special Counsel for International Affairs of the MMFDH; Aline Albuquerque Sanf Anna de Oliveira, coordinator of International Affairs of the Legal Counsel of the MMFDH; Juliana Mendes Rodrigues, technical adviser of the National Secretariat of Policies for Women of the MMFDH; Daniele de Sousa Alcântara, coordinator of Crime Prevention Policies for Women and Vulnerable Groups of the Ministry of Justice and Public Security (MJSP); Evandro Luiz dos Santos, official of the MJSP, and Joselito de Araújo Sousa, Federal Police Commissioner. 2 -5-