smuggling.21 In addition, there were murders of asylum seekers on the border area, and some involved individuals protected by precautionary measures.22 The State reinforced security in the area through increased police and military surveillance, 23 establishing a Strategic Command, consisting of five “Theaters of Operations”24 and approximately one hundred border protection posts.25 37. Furthermore, with the entry into force of the Law on Land and Agrarian Development in 2001, agrarian reform began to be implemented in Venezuela, which exacerbated tensions between landowners and ‘campesinos´ (peasant farmers)26 and led to many attacks against campesino leaders27, carried out by “sicarios” or hired killers. A newspaper 21 The expert witness proposed by the State, Antonio Urribarrí, stated that “paramilitarism and the Colombian guerrillas have fought for control of the border and, in the case of Venezuela, this affects four states [,] Zulia, Apure, Táchira and Amazonas” and that “this has brought consequences such as kidnappings, murders, extortion, known there as “immunization”, theft and stealing of vehicles, and contraband of food and gas toward Colombia” (Statement by Antonio Urribarrí rendered before the Court during the public hearing). 22 Precautionary measures were granted by the Commission on March 12, 2001, Cf. IACHR, Precautionary Measures for Colombian Refugees in Venezuela, Manuel de Jesús Pinilla Camacho et al. (File of attachments to the Merits Report, Annex 2, pages 25 a 41) and, according to the representatives , one year and a half after these were granted, Mr. Agustín Rodríguez died on August 11, 2002 (Merits file, brief of pleadings and motions, page 128), and on November 4, 2002 Manuel de Jesús Pinilla, and his son Nelson, who were also protected by the aforementioned precautionary measures, were murdered. According to the representatives, Mr. Pinilla and his son were found with signs of torture and numerous bullet wounds. Furthermore, the representatives referred to the death of Luis Ernesto Castro, who had worked with refugees on the border, Cf. information on the precautionary measures in favor of Jesús Pinilla Camacho and others, November 22, 2002 (File of attachments to the brief of pleadings and motions, Volume II, Annex 70, pages 2076 to 2082), and PROVEA, Derechos humanos y coyuntura, Newsletter No. 104, October 26 - November 8, 2002 (File of attachments to the brief of pleadings and motions, Volume III, Annex 96, pages 2888 to 2902). The Court further notes that in the course of several “interviews” held in the context of the investigation into the attack against Joe Luis Castillo and his relatives there were references to the aforementioned precautionary measures. 23 Cf. Official letter AGEV/000574, of December 13, 2011, issued by Henry de Jesús Rangel Silva, Commander in Chief of Strategic Operations (Attachments to the brief of final arguments of the State, page 3485). 24 According to the State, the Theaters of Operations “are military zones, with personnel trained to carry out special operations, who act in coordination with intelligence bodies of the State, the Attorney General’s Office and the police forces”, Cf. Observations presented by the State to the Commission, a letter dated January 21, 2008 – File of attachments to the Merits Report, Annex 6, pages 70 to 84). Official letter AGEV/000574 dated December 13, 2011, supra, mentions the establishment of “theaters of operations”. 25 In its answer brief the State referred to the establishment of a hundred bases, a fact that was not disputed (Merits file, response brief, page 305). For their part, in their brief of pleadings and motions, the representatives stated that the militarization of the area occurred between 1994 and 1999, following the decree suspending guarantees in the border zone. Cf. Support Network for Justice and Peace of Venezuela, PROVEA and the Association for the Promotion of Social Alternatives "Minga" of Colombia, Informe Global: el derecho a buscar y recibir refugio en la zona fronteriza colombo-venezolana, supra. 26 The expert witness Antonio Urribarrí reported that “there have been cases of campesinos being killed [,] especially because of the land problem.” In relation to this he added that “as a result of [the] new agrarian law in Venezuela there have been conflicts between cattle ranchers and campesino groups” (Statement by Antonio Urribarrí, supra). According to a communiqué issued by PROVEA, from 2002, “there was deep concern at the appearance of organized killings with the resulting increase in murders of peasant leaders […]”. Cf. PROVEA, Derecho a la Tierra, September 27, 2002 (File of attachments to the brief of pleadings and motions, Volume II, Annex 80, page 2163). 27 The State itself noted that, in this context, “[s]ome Venezuelan landowners began to hire Colombian paramilitaries to kill peasant leaders who were demanding compliance with the Land Law.” Cf. Observations submitted by the State to the Commission, in a letter dated January 21, 2008, supra. See also, Statement by Antonio Urribarrí, supra. It should also be noted that PROVEA reported that “[i]n several states in the country there were killings of peasant leaders. Contract murder was the most commonly used method to act against leaders. According to an investigation undertaken by the National Agrarian Coordinator, between January and September 2003, 20 peasant and indigenous leaders were murdered.” PROVEA, Derecho a la tierra, October 2002-September 11