2 José María Cantos was the owner of an important business group in the province of Santiago del Estero in Argentina. This group comprised the companies Citrícola del Norte, Canroz S.A., José María Cantos S.R.L., Rumbo S.A., José María Cantos S.A., Miguel Ángel Cantos S.A. and Marta Inés S.A. Mr. Canto was also the principal shareholder of Radiodifusora Santiago del Estero S.A.C. and of the Nuevo Banco de Santiago del Estero and owned rural and urban properties in that province. The above-mentioned companies employed over 700 persons. In March 1972, the Revenue Department of the Province, headed at that time by Luis María J. J. Peña, conducted a series of searches in the administrative offices of Mr. Canto’s companies, owing to an alleged violation of the Stamp Act3. During these procedures, all the accounting documentation, company books and records, receipts and supporting documents of payments by those companies to third parties and suppliers, as well as numerous shares and securities were seized, without being inventoried. From then on there were financial losses, because the said companies could not operate, owing to the lack of the company documents and also due to the impossibility of setting up a defense against liens filed by third parties to exact payment of bills that had already been settled. Since March 1972, Mr. Cantos has filed various lawsuits to defend his interests. In this respect, at that time, he filed a criminal complaint against the Director General of Revenue of the Province. Two months later he filed an application for amparo, which was unsuccessful. On September 10, 1973, he filed an administrative claim preparatory to the judicial complaint before the Federal Auditor of the Province, to have the losses caused by the searches and the retention of the business documentation by officials of the Revenue Department of the Province acknowledged. The amount of the losses was estimated at 40,029,070.00 pesos (forty million twenty-nine thousand and seventy pesos) under Act 18,1884. This claim was expanded on May 23, 1974, when the losses were estimated at 90,214,669.10 pesos (ninety million two hundred and fourteen thousand six hundred and sixty-nine pesos and ten cents) under Act 18,188. In view of the lack of response, on June 6, 1974, and April 26, 1976, Mr. Cantos requested “fast-track” settlement of the administrative claim. Apart from the lawsuits he filed, José María Cantos reached an agreement with the Government of the Province of Santiago del Estero on July 15, 1982, by which the latter acknowledged a debt towards a group of his companies, and established a compensatory amount and a date to comply with this obligation. As a result of the lawsuits he had filed, Mr. Canto was subjected to “systematic persecution and harassment by State agents.” For example, Mr. Cantos was detained incommunicado more than 30 times by police agents. His sons, who were minors at the time, were detained on several occasions and police agents were even posted outside his house on a permanent basis to impede anyone from entering or leaving. According to the records of the Police Force of the Province of Santiago del Estero, from 1972 to 1985, 17 different cases were filed against José María 3 The Stamp Act relates to registration and stamp taxes. 4 The Act of April 15, 1969, which states that 100 pesos would be equal to one “peso Act 18,188.”

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