On January 3, 2003, journalist Carla Angola was covering an opposition march when government sympathizers assaulted her, insulting her and Globovisión, making obscene gestures at the camera, blocking the camera, and throwing a container full of urine at her. 15. The Petitioners allege that all of these attacks were committed by supporters of the government of President Hugo Chavez, many of them members of so-called "Bolivarian Circles." The Petitioners allege that the "Bolivarian Circles" are political organizations promoted by the President of the Republic to "organize the people" and "defend the revolution." These groups are constituted according to guidelines issued by the Executive, they register with the Miraflores Palace, and receive government funds. Some of these groups are peaceful and are directed at community service, but others are allegedly armed and violent. 16. The Petitioners further allege that all of the foregoing incidents of attacks against Globovisión occurred as a result of the systematic, aggressive, and violent discourse of President Chavez, which began in 2001. They include a chart showing the dates of various such speeches relative to the above-described attacks on Globovisión to demonstrate that the attacks occurred shortly after one of these speeches. The attacks, the petitioners allege, not only have not been investigated by the State, they have been tolerated, justified, and encouraged by the President and some other high governmental officials. 17. The Petitioners state that they have denounced all of the incidents of attacks against the personnel and property of Globovisión before the Office of the Attorney General of the Republic, but that the Attorney General's Office has not taken any steps to carry out a serious investigation of any of these incidents. The Petitioners state that they requested information from the Attorney General's Office regarding the progress of the investigations in a letter dated March 10, 2003 and that they received no response to this letter. The Petitioners state that they have provided the Attorney General's Office with videos and verbal descriptions of the perpetrators of the various attacks, which would make it possible to identify the perpetrators. Nevertheless, they allege that the State has made no efforts to either identify or apprehend these individuals. 18. The Petitioners also applied for protection measures in various tribunals, measures which were granted but never carried out, according to the Petitioners. As a result of the State's alleged disregard for the Petitioners' requests for protection, Globovisión found it necessary to contract a private security firm and to buy security equipment, such as gas masks and bulletproof vests, for its employees. 19. The Petitioners state that in addition to the physical and psychological attacks against the Globovisión employees, the media has been subjected to numerous legal and administrative actions that carry with them the possibility of fines, suspension, or revocation of the media's broadcasting concessions. The Petitioners state that these actions are arbitrary and have been undertaken in an attempt to harass and intimidate them by keeping them under a constant threat of sanctions. 20. With regard to Article 13 of the Convention, the Petitioners argue that the systematic acts of aggression committed against the employees of Globovisión have intimidated the media workers and led them to engage in self censorship, out of fear for their lives and personal integrity, and that this violates their right to freedom of expression. They also argue that the State is directly responsible for these violations because the acts of aggression were committed by "Bolivarian Circles," entities supported by the State and acting on its behalf, or by government supporters acting under incitement by the government. 21. They further argue that the series of judicial and administrative actions taken by the State against Globovisión have produced additional pressure on the station not to report certain stories or points of view out of fear of sanctions ranging from fines to the revocation of their broadcasting concession. The Petitioners maintain that these legal actions have been undertaken in a discriminatory and arbitrary manner and that they therefore violate their right to freedom of expression. 5

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