IV PRELIMINARY OBJECTIONS 13. In its answer brief, the State filed preliminary objections, responded to the submission brief and made observations to the brief of pleadings and motions. With respect to the preliminary objections and related matters, it presented five separate arguments: a) A “preliminary analysis of jurisdiction,” which it did not expressly define as a preliminary objection; b) “Preliminary objection regarding the failure to exhaust domestic remedies”; c) “Preliminary objection regarding the incongruities, contradictions and inconsistencies of the facts that constitute the factual framework established by the Commission […], with respect to the facts alleged in the brief of pleadings [and motions …]”; d) “Preliminary objection regarding the belated submission of the brief containing a.) ‘Clarification of the analysis of the attachments’ to the brief of pleadings, motions and evidence presented by the petitioners; and, b.) Curriculum vitae of the expert witnesses proposed by the petitioners”; e) “Preliminary objection regarding the lack of legal status of the representatives of the presumed victims in this case” or “Preliminary objection regarding the lack of legal status or legitimacy of the petitioners to represent all [the presumed] victims,” and f) Alleged violation of its right to defense: Although the State did not file a preliminary objection per se in this regard, and did not explicitly indicate that it was an argument of that nature, it presented arguments concerning the alleged violation of its right to defense “because [it] did not know from the outset about the arguments claiming supposed additional violations” of Articles 22 and 23 of the Convention. 14. Before responding specifically to each of the State’s arguments (supra para. 13), the Commission pointed out that the arguments presented by the State in subparagraphs c), d) and e) “do not have the character of preliminary objections and do not affect the Court’s jurisdiction.” The representatives did not comment on this point. 15. Having regard to the nature of each of the arguments formulated by the State, the Court will consider these in the pertinent sections of this Judgment. Accordingly, it will only consider as preliminary objections those arguments that have, or that might have the characteristics of such. In other words, those objections of a prior character that seek to prevent the analysis of the merits of a disputed matter, by contesting the admissibility of an application or the Court’s jurisdiction to hear a specific case or of one of its aspects, owing to the person, matter, time or place, provided that these objections are of a preliminary nature. 4 If these arguments cannot be considered without previously analyzing the merits of a case, they cannot be examined by means of a preliminary objection. 5 16. Therefore, in this chapter the Court will only consider the arguments set forth in paragraphs b) and f). The arguments in paragraphs c) and e) will be analyzed in the Chapter on prior considerations. It is important to note, in particular, that the alleged “incongruities, contradictions and inconsistencies in the facts” refer to the factual framework of the case, which should be analyzed in the chapter on merits. 6 The argument set forth in paragraph d) refers to the admissibility of certain evidence, and will therefore be examined in the corresponding section (infra paras. 61 and 64). Finally, since the argument presented in paragraph a) does not specifically question the Court’s jurisdiction to hear this case and, given the terms in which it was presented, it refers to 4 Cf. Case of Las Palmeras v. Colombia. Preliminary Objections. Judgment of February 4, 2000. Series C No. 67, para. 34, and Case of Brewer Carías v. Venezuela. Preliminary Objections. Judgment of May 26, 2014. Series C No. 278, para. 100. 5 Cf. Case of Castañeda Gutman v. Mexico. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 6, 2008. Series C No. 184, para. 39, and Case of the Pacheco Tineo Family v. Bolivia. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 25, 2013. Series C No. 272, para. 15. 6 Cf. Case Mendoza et al. v. Argentina. Preliminary Objections, Merits and Reparations. Judgment of May 14, 2013 Series C No. 260, para. 25, and Case of the Pacheco Tineo Family v. Bolivia, supra, para. 24. 7