22 8(2) of the American Convention. *** 79. The Commission requested the Court to rule that Mr. Suárez-Rosero's incommunicado detention for 36 days violated Articles 8(2)(c), 8(2)(d) and 8(2)(e) of the American Convention, inasmuch as it prevented him from exercising his right to consult an attorney. The Commission further pointed out that at other times during the proceeding, Mr. Suárez-Rosero was unable to communicate freely with his lawyer, which also violated the guarantee laid down in Article 8(2)(d). 80. Ecuador did not contest those arguments in its answer to the petition. 81. In the brief containing its final arguments, the Commission once more raised the matter of incommunicado detention, maintaining that the exchange of a few scribbled notes does not allow a detained person to communicate with the outside world, to seek legal counsel, or to invoke legal guarantees. 82. Article 8(2)(c), (d) and (e) of the American Convention establishes minimum guarantees to which every person is entitled, with full equality, [a]dequate time and means for the preparation of his defense; [t]he right of the accused to defend himself personally or to be assisted by legal counsel of his own choosing, and to communicate freely and privately with his counsel; [and] the inalienable right to be assisted by counsel provided by the state, paid or not as the domestic law provides, if the accused does not defend himself personally or engage his own counsel within the time period established by law [.] 83. Owing to his having been kept incommunicado for 36 days of his detention, Mr. Suárez-Rosero was denied adequate opportunity to prepare his defense, since he did not have the legal assistance of a public defender and, once he was able to obtain legal counsel of his own choosing, he was unable to communicate with him freely and privately. Hence, the Court considers that Ecuador violated Article 8(2)(c), 8(2)(d) and 8(2)(e) of the American Convention. XIII Violation of Article 5(2) 84. The Commission requested the Court to find that the incommunicado detention to which Mr. Suárez-Rosero was subjected for 36 days violated Article 5(2) of the American Convention, in that his isolation constituted cruel, inhuman and degrading treatment. 85. Ecuador did not contest that argument in its answer to the application. 86. In its closing arguments, the Commission again raised this matter, claiming that communication through a third party did not enable Mr. Suárez-Rosero's family to ascertain his physical, mental or emotional state. 87. In its closing arguments, Ecuador maintained that Mr. Suárez-Rosero received adequate medical treatment during his incarceration, "as attested to by the official medical records included in the docket".