12 60. With regard to the alleged forced displacement of persons, the State argues that it is impossible to assess its responsibility for these events. It indicates that it is essential to prove a causal nexus between the events of the case and the forced displacement so that an international crime arises and consequently the international responsibility of the State and to prove that the alleged victims were forcibly displaced solely by "Operation Genesis". 61. It alleges that between December 1996 and the first part of 1997, various regrettable events occurred which gave rise to different displacements, for different reasons and at different times. It indicates that not every displacement occurring in the region took place between February 24 and 27, 1997, which raises the necessity of individualizing and identifying the alleged victims and the reasons why they were displaced, in order to establish State responsibility. It considers that the burden of this lies with the petitioners. It alleges that if this were not the case, the displaced persons' right to the truth would be ignored, since the conclusion could be made that they were all displaced by the same events, thereby ignoring the various reasons and moments of displacement at that time. 62. The State alleges that the list of victims submitted by the petitioners lacks evidentiary value, in the sense that it contains an informal relationship of names and does not either refer to, or provide individual evidence of, their residence in the Cacarica basin in February 1997, nor of the events that allegedly caused the forced displacement. It alleges that in spite of this, the State is making the relevant checks in order to cross-reference this list with the Single Displaced Population Registry, in order to verify these individuals' status as displaced persons. 63. Regarding internal displacement, it alleges that since mid 1996 the State has undertaken innumerable actions to assist displaced persons from the Urabá area, and thereby guarantee their rights, based on humanitarian principles and without distinction as to either the reasons why they were forcibly displaced or of the effects at the moment of evaluating the State's alleged responsibility. 64. The State alleges that the Social Solidarity Network (today Social Action) assisted and lent support to approximately 3,500 displaced persons of 23 communities in the Cacarica river basin, and undertook the accompanying, facilitation and follow-up to the process of returning the said displaced communities, who had provisionally settled in Turbo, Bahía Cupica and Bocas del Atrato. It indicates that of these 3,500 persons, approximately 2,300 provisionally settled in Turbo and in the district of Bocas del Atrato, around 200 individuals crossed the border with Panama, and the rest travelled to other areas of the country such as the Atlantic Coast and the Valle Department. It indicates that the refugees in Panama were repatriated to Colombia and placed at the "El Cacique" farmstead in Bahía Cupica, Bahía Solano district, in the Pacific Coast of Chocó. 65. It stresses that the displaced were located in the municipal stadium of Turbo and in two humanitarian shelters with the funding of international agencies and the Government. It indicates that the Social Solidarity Network supported the competent entities to fulfill the governmental commitments, to the direct benefit of the original 450 families. It indicates that approximately 216 families have returned to their settlements of Esperanza en Dios and Nueva Vida, in the Cacarica basin. 66. It stresses that Social Action requested the Mayor of Riosucio to promote the fulfillment of the municipality's commitments in the areas of health and education. The request also received support 16 at the ministerial level. It stresses that since November 1999, Social Action has been coordinating 16 The State indicates that the direct humanitarian attention granted by the Social Solidarity Network to these communities in their settlements consisted of foodstuffs for persons and families belonging to the process of return to the Cacarica: from the month of May 1999 the families settled in Cupica and from January 2000 until December 6, 1999 those settled in Turbo, for the amount of $1,243,475,664 including food support during all phases of the return. It indicates that in support of the returned communities in the housing and production projects, foodstuffs were delivered in exchange for work, equivalent to 7,500 rations for three hundred families in Esperanza en Dios and Nueva Vida, for the amount of $24,324.360. It indicates that the site individualized by the community at Turbo Stadium for the school was refurbished with construction materials for the amount of $913,400. It indicates that in 1999 it made available the amount of $5,721,200 for the school's kitchen, educational materials for children and for the classrooms (Cupica-Turbo), for the amount of $10,040.446 and that also kindergartens received the amount of $2,569,556, Continues…

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