also referred to the absence of reliable and valid data on the abusive use of force by State security forces.38 Moreover, in its final written arguments, the State emphasized the decrease in cases of “executions.”39 37. The findings contained in the CONAREPOL report were, in turn, the subject of analysis by the expert witness Liderly José Montero Barrueta, proposed by the State, who among other comments, indicated that CONAREPOL had noted that one of the most common patterns of police action was the “disproportionate, indiscriminate and discretionary [...] use of force, negligence and lack of expertise in the use of firearms, numerous and aberrant methods of torture, threats and harassment, simulated executions, arbitrary arrests, illegal raids, delays in transferring injured persons to medical centers after injuring them, firing shots into the air, altering bullets and using illegal weapons.” Finally, the expert witness stated that in “armed confrontations civilian deaths [were] far more likely to occur than police casualties, which suggests the highly lethal nature of police tactics and the cover-up of executions.”40 38. Finally, despite the differences between the statistics provided by the State bodies41 and by the parties, it is not disputed that since 2004, and more significantly since 2006, the number of complaints of alleged violations of the right to life by police officers has been declining.42 38 Cf. National Commission for Police Reform, Estudios. Características de la Policía Venezolana, page 61; 2003 Annual Report of the Ombudsman’s Office of the Bolivarian Republic of Venezuela, page 66 and 2002 Annual Report of the Ombudsman’s Office of the Bolivarian Republic of Venezuela (attachment 3 to the brief of pleadings, motions and evidence, volume 24, page 7831). 39 Cf. Final arguments of the State (Merits file, volume 5, page 1012) and Ministry of the Interior and Justice, Order No. 124, of April 10, 2006, cited in 2010 Annual Report of the Ombudsman’s Office of the Bolivarian Republic of Venezuela (digital attachment to Brief of final arguments of the State, page 363). 40 Expert opinion rendered by affidavit by Liderly José Montero Barrueta on November 15, 2011 (Evidence file, volume 16, page 5324). 41 Figures from the Scientific, Penal and Criminal Investigations Corps (hereinafter “CICPC”) show that in 2001 alone, there were 1,251 reported deaths due to “resisting authorities”; during the period 2000-2006, 10,428 deaths were reported with an annual average of 1,489, with figures for the years 2002, 2003 and 2004 increasing to 1720, 2305 and 2150 respectively (National Commission for Police Reform, Estudios. Características de la Policía Venezolana, page 69). According to reports of the Ombudsman’s Office cited by the State, between 2000 and 2005, the Office for the Protection of Fundamental Rights of the Attorney General’s Office reported that “from 2000 to 2005, there were 5,520 criminal proceedings for the alleged commission of homicide by public officials in the exercise of their duties or in connection with their position.” 2005 Annual Report of the Ombudsman’s Office of the Bolivarian Republic of Venezuela. Available online at: http://www.defensoria.gob.ve/dp/index.php/publications/reports-anuales. In addition, figures of the Public Prosecutor’s Office indicate that during the period 2000-2006, 5,684 civilians were killed in these circumstances (National Commission for Police Reform, Estudios. Características de la Policía Venezolana, page 70). The State also mentioned that between 2006 and 2010, the Attorney General’s Office reported that 3,521 police officers were prosecuted for crimes committed in the exercise of their duties, and 274 were convicted. Brief of final arguments of the State (Merits file volume 4, Page 1046). As to the Encuesta de Victimization y percepción de seguridad ciudadana (Survey on Victimization and perceptions of citizen security), the CONAREPOL study indicated that “one of the substantial contributions of [this] tool is that it allows us to know the scale of the unreported crimes.” (National Commission for Police Reform, Estudios. Características of the Policía Venezolana, page 30). 42 The figures presented by the State, based on reports of the Ombudsman’s Office, record a total of 2095 complaints for alleged violation of the right to life by police officers during the period 2001-2010. Brief of final arguments of the State (Merits file, volume 4, Page 970), which does not include the total of complaints received by the Public Prosecutor’s Office, according to the representatives. 12

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