undocumented, living in Dominican territory as well as of Dominicans of Haitian descent, documented and undocumented. They assert that more than 20,000 people were repatriated in November 1999, and that the practice continued up until December 14, 2000, with an average of 2000 people deported monthly. They assert that this practice has continued despite the provisional measures adopted by the Inter-American Court. 21. They contend that these actions take place with no prior warning and involve the use of excessive force, including different types of physical intimidation a people are taken from their homes, their families and jobs and in some cases, their children. The acts of violence also have included sexual abuse of women. 22. The petitioners also report that these people are detained by immigration officers and Dominican soldiers and are transported to the Haitian border with no opportunity to prove their legal status or make arrangements prior to being expelled. This practice, they say, has also been used against Dominican citizens who have the means to prove their legal status in Dominican territory. These individuals are deprived of their ability to contest the deportation, contact family members, or obtain legal assistance. The petitioners claim that the alleged victims, as members of these groups, have been targeted by different facets of this State policy. 23. The petitioners add that in several cases, fathers and mothers have been sent to Haiti and forced to leave their small children behind in the Dominican Republic. 24. The petitioners further claim that the information about these practices is consistent with that of several Dominican and international organizations who confirm the existence of this generalized policy since the mid 1990s. Moreover, the Dominican State has failed to comply with its bilateral treaties with Haiti by failing to notify the latter about thousands of people who were simply left at the border. 25. The petitioners also point out that Haitians living in the Dominican Republic are not granted the opportunity to obtain legal residency; they are frequently arrested, put in omnibuses, and sent to Haiti. They assert that this practice has included Haitians who have lived in Dominican territory for more than twenty years. 26. They further claim that those who have had legal access to work and residency are not given the opportunity to prove their status and ultimately are treated as if they were undocumented. 27. The petitioners contend that these policies also affect Dominicans of Haitian descent whom the immigration authorities have mistakenly deported in the same circumstances. Reports from the State itself have alluded to this situation, which has affected third generation Dominicans. 28. The petitioners also contend that many children have been left behind, abandoned on Dominican soil as a result of such practices by the State. Deportees are frequently prevented from taking their minor children with them and parents who have been deported have been prevented from contacting their children or other family members. 29. The petitioners argue that such policies violate the domestic law of the Dominican Republic, whose immigration regulations establish deportation procedures including prior notice, specific grounds, and an opportunity to contest the charges. Moreover, these actions violate a 1997 agreement between the Dominican State and Haiti that was signed in the context of a similar crisis. 30. The petitioners consider that these mass practices at the national level discriminate based on race and origin, and infringe upon the domestic and international rights of these people. B. The State 3

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