into alleged actions that may have violated human rights, “the venue in which any relevant evidence should have been presented in a timely manner.” 39. The State deemed it relevant to recount its international obligations in terms of the fight against organized crime, emphasizing that “the criminal gang led by Blas Valencia and others” is an organized crime group. In the words of the State, “the criminal organization led by former police Colonel Blas Valencia can be considered a structured group that has been formed on a premeditated basis for the immediate commission of planned crimes. Added to this situation is the participation of Peruvian citizens who make up the aforementioned organized group, an aspect which, given the seriousness of the participation in and planning of the crimes, gives them the added connotation of a transnational criminal organization.” 40. The Bolivian State informed the Commission about a report by the National Police of Peru, dated January 3, 2002, in which reference is made to the participation of Peruvian citizens in the perpetration of crimes against financial entities in Bolivia. According to the State, it can be inferred from this report that several of the people mentioned in it were the ones who participated in the holdup of PROSEGUR. The State underscored that their actions followed a clearly articulated modus operandi consistent with their entry into the country as tourists and their subsequent immediate departures from Bolivia. 41. As to the alleged theft of jewelry, the State indicated that these are currently being held by the judicial authority so they can be used to indemnify and repair the widows of the deceased. It emphasized that the criminal complaint filed by some of the alleged victims regarding this aspect was rejected by the Second Criminal Trial Judge, a rejection subsequently upheld by the Second Sentencing Court of the city of El Alto, on the grounds that ownership rights had not been established. 42. In terms of admissibility requirements, the State indicated that the petition does not meet the requirements established in Article 46.1 a) and that it cannot be deduced from the petitioner’s account that there were events characterized by any violation of the rights protected in the American Convention. In the words of the State, Bolivia “has made use of its domestic legislation in the framework of respect for all guarantees of the alleged victims’ human rights, there now being a final judgment whose review or annulment does not fall to the IACHR; otherwise this would fall under the fourth-instance doctrine.” In conclusion, the State asked the Commission to declare the petition inadmissible. 43. The State argued that the alleged victims did not comply with the requirement to exhaust all domestic remedies, since at the time the petition was presented to the Commission the judicial authority had yet to issue a decision on the domestic proceedings or on the alleged tortures. In this regard, the State noted that the international human rights system has a function that is collaborative and complementary to that offered by States’ domestic laws. In the view of Bolivia, the filing of a petition without having a judgment of the first instance and without having denounced the alleged acts of torture is evidence of the inadmissibility of the charge. 44. The State also contended that the alleged victims did not file an appeal for extraordinary review of the final judgment, enshrined in Article 421 of the Code of Criminal Procedures. According to the State, this standard clearly establishes that there is no deadline for filing an appeal; on the contrary, the motion can proceed at any time on behalf of the convicted, and could lead to the sentence being overturned and a new trial being held. IV. ANALYSIS OF ADMISSIBILITY 7