87 297. In the closing written arguments, the representatives requested the Court to order the State to guarantee the separation of individuals under arrest pending trial from those already convicted persons. 298. The Court notes that this request was not presented at the appropriate procedural moment by the representatives, that is to say, in its brief of pleadings and motions. Based on the foregoing, this measure of reparation, which was requested in an untimely manner, shall not be considered by the Tribunal. C. Compensatory damages 1. Pecuniary damage 299. The Tribunal has established in its jurisprudence that pecuniary damage involves “the loss of or detriment to the victims’ income, the expenses incurred as a result of the facts, and the monetary consequences that have a casual nexus with the facts of the case.”315 300. The Commission requested the Court to “equitably determine the amount of compensation for consequential damages and loss of earnings, by virtue of its authority over this matter.” The representatives did not make specific reference to consequential damages. However, they made specific requests as to the claim of loss of earnings. The State declared that, as to the compensatory damages for pecuniary and non-pecuniary damage, it subjects to the decision of the Court regarding the violations for which it has accepted responsibility. 301. Next, the Tribunal shall determine the compensations for pecuniary damage in relation to the violations declared in Chapters VIII-1, 2, and 3 of this Judgment, taking into account the particular circumstances of the case, the evidence furnished by the parties and the arguments. a) Loss of earnings 302. The representatives pointed out that the loss of earnings refers to the loss of economic wages as a consequence of the “interruption, while he was in custody of Panama, of [his] profitable activities […].” Therefore, they mentioned that from 1998 to 2002, Mr. Vélez Loor worked buying and selling clothes, vehicles, and livestock in Quito, Ecuador. According to the representatives, at the time of his detention, he was going to the United States of America in order to make money to promote his business. Considering that the representatives do not have exact figures to calculate the lost earnings of the victim during the ten months of his detention, they requested the Court to take into account these elements and equitably determine the corresponding amount. Moreover, the State did not present any argument regarding the loss of earnings. 303. The determination of the compensation for loss of earnings in the instant case must be calculated based on the period the victim did not work given his deprivation of liberty. In this case, the Court has already proven that Jesus Tranquilino Vélez Loor was deprived of liberty from November 11, 2002, to September 10, 2003, and that said imprisonment constituted a violation of his rights to liberty and personal integrity (supra Chapters VIII-1 and VIII-2). On this occasion, the Tribunal considers that, despite the fact that the representatives pointed out that the victim worked buying and selling clothes, vehicles, and livestock in Quito, Ecuador, the Tribunal does not have sufficient evidence to determine which work activities the victim was engaged in 315 Case of Bámaca Velásquez v. Guatemala. Reparations and Costs. Judgment of February 22, 2002. Series C No. 91, para. 43; Case of Ibsen Cárdenas and Ibsen Peña, supra note 28, para. 260, and Case of Rosendo Cantú et al., supra note 27, para. 270.