b) Regarding the situation of Jorge Martínez Meléndez, the Factum Consorcio representatives referred to the alleged mistreatment he received during his incarceration in the CAI San José. c) The Inter-American Defenders alleged that “a structural violation of the law [exists] in the Costa Rican prison system.” In response, the State argued that only the petitioners Rafael Rojas Madrigal and Damas Vega Atencio had alleged violations of fundamental rights from the start of the proceedings due to the prison conditions at the CAI La Reforma, and that each area of physical containment and each petitioner has his own characteristics and circumstances; therefore, the Commission should have established the specific harm caused to each of them, if it existed. Thus, they requested that the Court limit the case only to the alleged non-compliance related to “the conditions of detention at the CAI La Reforma in relation to the alleged victims.” 155. The SIPDH representatives listed the complaints filed by Damas Vega Atencio during his stay at the CAI La Reforma, including six complaints concerning the search carried out on July 20, 2006, the alleged denial of access to health care, problems regarding the food provided to inmates, the complaint filed after the death of the inmate FA in January 2010, and the complaint filed after the alleged victim was transferred to maximum security, as a result of the inmates’ hunger strike in 2008. The representatives alleged that all these facts “complement […] the initial facts contained in the petition of Mr. Damas Vega Atencio, since these events occurred within the framework of the execution of the criminal conviction […] and should be understood as an aggregation of new facts with respect to the initial petition.” They also pointed out that “[t]he recounting of these facts, complaints and grievances proves that Mr. Vega did everything that he could possibly do […] as a person deprived of liberty who expects his access to justice to be channeled through the prison’s administrative authorities […].” 156. In a brief dated March 7, 2017, 192 the Inter-American Defenders alleged that in the Merits Report the Commission established that the problem of overcrowding was general to all the alleged victims, “since it is more than evident that the overcrowding found in all the modules of La Reforma Prison […] generates very serious problems in the quantity and quality of water, among many others […].” They also argued that this report “narrates and describes in detail the conditions faced by all persons deprived of liberty in La Reforma Prison.” 157. In their observations on the preliminary objections, the Factum Consorcio representatives indicated that the State had alleged “without specifying, that there is an extension of the facts in the allegations of Jorge Martínez Meléndez; this is not correct, since all the aspects mentioned are circumstances linked to the factual framework, or are a consequence of it, or are within the factual framework established by the Commission.” They also alleged that Mr. Martínez Meléndez is the only person of those involved who did not serve time in prison at CAI La Reforma. They considered the absence of this fact “a regrettable involuntary omission on the part of the Commission, justified by the change from the individual case file P-1083-06 to the joined case file 12,820.” 192 In a note dated March 21, 2017, the Secretariat confirmed that “the State and the common interveners Factum Consorcio and Inter-American Defenders included arguments in their briefs that do not constitute observations on the annexes presented by the other parties as helpful evidence. Therefore, as per the instructions of the President of the Court, such arguments will not be taken into consideration by the Court.” In that regard, given that in the note of February 10, 2017, the Secretariat asked the State to specify which facts were supposedly outside the factual framework of the case, the arguments of the parties concerning this point should also be admitted in order to ensure the right to adversarial proceedings. 53