17 investigations and procedures initiated or conducted by criminal courts in relation to these facts. The foregoing is based on the legal arguments. * * * 60. Moreover, the representatives alleged that the facts mentioned in the instant case “have been reviewed, alleged and proved" in the application, which are known to the parties within the framework of the petition, the precautionary and provisional measures, as well as a series of alleged facts that they qualify as "supervening". These would be directly linked to the facts contained in the application, which occurred before and after the submission thereof, which “must be assessed by the Court [...] as part of the 'context' in which the facts took place [...] or as facts that worsened the alleged violations, [which] are also attributable to the State and that originated its international responsibility”. These incidents “have continued and continue occurring, and even the aggressions and threats have been worse, [therefore they are] ongoing facts […] that qualify within the concept established by the Court to ‘supervening’ facts”. They made reference to the following ��three types of facts”: Those that constitute “per se the object of the case” considering that they have been mentioned in the application; those that would allow explaining, clarifying or dismissing the ones contained in the application and the supervening facts, which occurred after the submission of the application. In the final written arguments, the representatives intend the Court to further assess other facts that occurred after August 2005 and until May 2008, "which have been timely and duly informed to the Court within the framework of the provisional measures". 61. Besides, the representatives referred to a series of incidents, situations and considerations that they intend to include within the factual framework of this case and that they consider are important to demonstrate a “pattern of hostility, threat and aggression against journalists and mass media” and a “State policy or at least, a behavior pattern of the State towards the exercise of liberty of expression”. These alleged facts consist, inter alia, in a series of domestic rules and judicial decisions, namely, inter alia: administrative sanction procedures against television stations, in particular, Globovisión, addressed to partially suspend the broadcasts or even cancel or refuse to renew the concession of the television station; multiple judicial proceedings that tend to sanction the mass media, even take away the signal. The representatives asserted that in the particular case of Globovisión, criminal actions have been instituted against executives and reporters of that company by the Public Prosecutors' Office and they mentioned the alleged existence of a discredit campaign against such television station initiated by State’s mass media. The also mentioned the existence of indirect pressure of the State by not granting the concessions and permits that Globovisión has requested in order to expand its coverage and the irregular dismissals of judges that have rendered rulings in favor of the television station. * * * 62. Moreover, in the briefs and interventions, apart from referring to most of the factual and legal aspects of this case, the State referred to, inter alia, the role that private mass media play in Venezuela that, in the State’s opinion, have turned into “unyielding political opposition to the legitimately elected government"; it has objected to the interpretation the representatives made of some domestic rules and judicial decisions; it has pointed out certain facts and people that participate in “a plan to affect the government and prepare a coup d' état for April 2002 “; and other “rebellion acts of ‘golpistas' officials in Altamira Square, plans for a business and oil strike, the “guarimbas” of 2003 and the referendum to recall the President's mandate of 2004". The State asserts that during the development of

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