41. During the 1990s, the different actors involved in the conflict perpetrated violence against journalists in response to their "criticism, allegations, or for reporting on sensitive issues, especially violence related to drug trafficking." 40 An element of the violence against journalism that is unique to Colombia—highlighted in the aforementioned judgment handed down in the case of Carvajal Carvajal et al. v. Colombia—was precisely the variety of actors involved in perpetrating this violence. 41 This array of actors was described by Ms. Bedoya during the public hearing held in this case, in which she stated as follows: At the time of the facts between 1999 and 2000, Colombia was already in one of its worst crises due to the context of the armed conflict that it was facing. We had a well-strengthened FARC guerrilla group that had practically laid siege to cities; we had paramilitary groups, unfortunately strengthened by the protection of some State agents and that had won much territory in many parts of the country. And we also had a very significant amount of drug trafficking, which fed these two organizational structures. In the midst of this came the convergence of many aspects of criminality that were sustained by these armed structures. 42 42. In this regard, the witness Jorge Cardona agreed with Ms. Bedoya’s statement and indicated that the time of the facts was “a very complex moment,” since “the polarization that the country was experiencing coincided with the failed peace process between the FARC and the Pastrana government and paramilitarism’s transformation into a nationwide war machine.” 43 Along with this, the cooperation taking place between this array of actors at the time of the facts in this case should be highlighted, as it took the form of a kind of collusion or joint actions between paramilitary units and State agents. 44 43. Additionally, and in accordance with what this Court has found previously, this context also included a “widespread context of impunity” with respect to the murders of journalists. 45 Regarding impunity for attacks on journalists, this Court has already recognized that "The Colombian justice system has encountered considerable difficulty investigating the perpetrators of acts of aggression 40 Cf. Observations on the merits by the State of Colombia, April 5, 2016 (evidence file, folio 3290). 41 Cf. Case of Carvajal Carvajal et al. v. Colombia, supra, para. 29. Cf. Statement from Jineth Bedoya Lima given at the public hearing held on March 15, 22, and 23, 2021 within the framework of the 140th regular sessions. 42 43 Cf. Sworn statement given by Jorge Enrique Cardona Álzate before the Office of the Attorney General of the Nation, November 1, 2011 (evidence file, folio 25). See also statement by Jorge Enrique Cardona Álzate given during the public hearing held on March 15, 22, and 23 within the framework of the 140th regular sessions. Cf. 251st Prosecutor's Office Assigned to the Criminal Judges of the Specialized Circuit, assessment of the merits of the preliminary investigation, file 1, of June 12, 2018, Chapter 9.1.4. “Links to the penitentiary and prison authorities,” where it is highlighted that “another factor that could allow for the formation and durability of this [criminal structure within the prison] was the actions to permit, facilitate, cooperate, and/or participate by some public servants, who, due to the roles they played and the jobs they held, used their power to ensure or facilitate the commission of criminal acts or help conceal them, and gain from them personally as a result of the significant sums paid periodically in exchange for guaranteeing their contribution to criminal offenses.” Of note were irregularities such as “giving warning of searches or operations to be carried out in the prison,” facilitation of "entry of weapons [...], ammunition and explosives," “failure to conduct internal investigations,” receipt of “regular monetary payments,” etc. (evidence file, folios 23122 and 23123). Additionally, by way of illustration, see public and well-known incidents like the statement of former paramilitary commander Salvatore Mancuso before the Truth Commission on August 4, 2021, in which Mr. Mancuso indicated the following: “I stopped being Salvatore Mancuso and the next day I became Santander Lozada, one of my aliases [...]. This is a step that gradually confirms these political and military phenomena, and one begins to make pacts, agreements, agreements with the institutions themselves. It was agreed to assign brigade, division, and battalion commanders, as well as police and DAS commanders—and even prosecutors—who were sympathetic to the cause of self-defense so that we could confront the enemy of the Colombian nation together.” Cf. Hearing before the Truth Commission, of August 4, 2021, minute 1:05:05, available at: https://www.youtube.com/watch?v=th2RL40S0pU. See also, “Los lazos entre paramilitares y Ejército copan el encuentro de Mancuso y Timochenko,” EFE, article dated August 4, 2021, available at: https://www.efe.com/efe/america/politica/los-lazosentre-paramilitares-y-ejercito -copan-the-meeting-of-mancuso-timochenko / 20000035-4602092 44 45 Cf. Case of Carvajal Carvajal et al. v. Colombia, supra, para. 170. 15