6 admit “the so-called additional claims of a group of workers which raised the amount of money claims to unattainable levels and that are inconsistent with labor laws in force.” The State asserted that “the amounts and totals resulting from this last calculation fully comply with all the obligations established in the Judgment of February 2, 2001.” 10. That the representatives of the CEJIL commented that: i) regarding the information requested by the Court, the State furnished very limited and general information. While the State report submitted at the hearing summarized certain criteria used to calculate the amount of approximately 21 million balboas and detailed the amounts owed to each victim according to its calculations, it failed to furnish supporting documents of said totals. Moreover, they pointed out that “regarding the revision of the first payment and the subsequent calculations, including the proposal made at the hearing, it is evident that the State […] has failed to submit criteria which are clear, consistent with and incidental to any sum calculation based on the parameters set out by the Court in the Judgment." ii) regarding the benefits owed by the State, they explained that “[t]he core of the rights prescribed by the Labor Code to which all victims are entitled are unpaid salaries, payment in lieu of vacation, surcharge interest of Article 169, default interest of Article 170, and thirteenth month.” However, the State proposal only provides for unpaid salaries, surcharge interest of Article 169 and default interest of Article 170 of the Labor Code, in disregard of vacation and thirteenth month benefits and the rights prescribed in Law 8, including, but not limited to, assessment right, right to allowances and right to union privileges for workers acting as union leaders. iii) The term for calculating unpaid salaries, under domestic law, should run “from dismissal date to reinstatement date or until the pertinent judgment is executed when indemnification payment for unfair dismissal has been ordered," and if the State has not made any refunds or similar payments, the term to estimate unpaid salaries is not interrupted. They also asserted that in the report the State failed to inform the monthly salary of each worker on which it based the calculation, rendering accuracy verification by the victims impossible. Finally, they stated that “[t]he 10% default interest should be applied to unpaid salaries and further ‘labor rights’ under the laws in force at the date the events took place” so, as the amounts estimated by the State fail to include these items, they do not comply with domestic laws; they also noted that in the report the State failed to submit an updated list of the deceased victims and the payments made and amounts owed to their successors. 11. That the group of victims represented by the Organización de los Trabajadores Víctimas de la Ley 25, in turn, asserted that the State of Panama has followed a procedure which is completely foreign to domestic laws, in violation of its own rules, and that up to date it has not filed a detailed report on the calculations.