4. Requests of the Commission. – The Commission requested that the Court conclude and declare the international responsibility of the State for the violations contained in its Merits Report and order the State to implement the measures of reparation included in that report. The Court notes, with great concern, that some 14 years had elapsed between the lodging of the initial petition to the Commission and the submission of the case to the Court. II. PROCEEDINGS BEFORE THE COURT 5. Notification to the State and to the representatives. 1 – The submission of the case was notified to the State and to the representatives by communications of August 24, 2021. 6. Brief of pleadings, motions and evidence. – On October 25, 2021, the representatives presented their brief of pleadings, motions and evidence (hereinafter “the pleadings and motions brief”), under the terms of Articles 25 and 40 of the Rules. The representatives agreed with the Commission’s claims, made additions to its arguments and proposed specific reparations. 7. Answering brief. 2 – On January 5, 2022, the State presented its answering brief on the submission of the case and its observations on the pleadings and motions brief, pursuant to the terms of Articles 25 and 41 of the Rules. The State formulated four preliminary objections and refuted the alleged violations and the measures of reparation proposed by the Commission and the representatives. 8. Public hearing. – On May 24, 2022, 3 the President of the Court called the parties and the Commission to a public hearing that was held at its seat in San José, Costa Rica on June 23, 2022, during the Court’s 149th Regular Session. 4 9. Partial acknowledgement of responsibility. – During the public hearing and in its final written arguments (infra para. 11), the State withdrew its preliminary objections on the failure to exhaust domestic remedies, on lis pendens, on international res judicata and on the “lack of a legal issue.” It also partially acknowledged its responsibility. 10. Amici curiae. – The Court received amicus curiae briefs from: 1) the Human Rights Legal Clinic of the Institute of Advanced University Studies U-IIRESODH 5; 2) the Human Rights Commission in 1 The representation of the alleged victim is the Solidarity Network for the Decade Against Impunity. As agents, the State named Martha Delgado Peralta, Under Secretary for Multilateral Affairs and Human Rights; Alejandro Celorio Alcántara, legal advisor; Marcos Moreno Báez, Coordinator of International Human Rights Matters; Cristopher Ballinas Valdés, Director General of Human Rights and Democracy; María Fernanda Pérez Galindo, in charge of the General Department of International Cooperation; Carolina Hernández Nieto, in charge of the Coordination of International Resolutions; Salvador Tinajero Esquivel, Coordinator of International Law; Alfredo Uriel Pérez Manríquez, Director of International Rights IV; Tisbe Cázares Mejía, Director of International Affairs on Human Rights; Lucero de Fátima Hinojosa Romero, Director of International Litigation and Diana Valle Rodríguez, Under Secretary of the Secretariat of Foreign Affairs, Mexico, D. F., Mexico. 2 3 Cf. Tzompaxtle Tecpile et al. v. Mexico. Call to a public hearing. Order of the President of May 24, 2022. Appearing at the public hearing were: a) for the Inter-American Commission: Erick Acuña Pereda and Paula Rangel, advisors of the Commission; b) for the representatives: María Magdalena López Paulino; Ernesto Rodríguez Cabrera; Armando Venegas Martínez; Julián Ruzalta Aguirre; Sandra Salcedo González; Carlos Karim Zazueta Vargas and Ie Tze Rodríguez López, and c) for the State: Roselia Margarita Barajas y Olea, Ambassador of Mexico to Costa Rica; Alejandro Celorio Alcántara, legal advisor; Nancy Desiderio Noyola, Director of Follow-up of the Cases before the Inter-American System; Alfredo Uriel Pérez Manríquez, Director of International Law IV; Diana Elena Ramírez Urbina, Agent of the Public Prosecutor’s Office attached to the UEITA and Braulio Robles Zúñiga, Agent of the Public Prosecutor’s Office attached to the UEITA. 4 5 The brief signed by Víctor Manuel Rodriguez Rescia; Bertha Carolina López Pérez; Rogelio Flores Pantoja; María de los Ángeles Corte Ríos; Silvia Alexandra Esquivel Díaz; Giselle Meza Martell and Martha Elba Dávila Pérez, dealing with: a) the context in Mexico regarding arraigo and its “non-conventionality”; b) the test of proportionality of arraigo as an express restriction in the Mexican Constitution and c) arraigo and international human rights norms. 5