proceeding, particularly in the context of a criminal complaint in which matters with a [supposed] political content are debated.” 80. The State challenged Mr. Zeitune, arguing that he is “an expert witness by profession,” because “whenever a case is brought against Venezuela in the Inter-American Court of Human Rights related to the independence of the Judiciary in Venezuela, he is proposed by the Commission.” The State pointed out that Mr. Zeitune has rendered an expert opinion in the cases Reverón Trujillo, Chocrón Chocrón and Díaz Peña, in which “he has shown his dissatisfaction with the Venezuelan Judicial System, demonstrating his predisposition against the Venezuelan State.” 81. In accordance with Article 48(3) of the Rules of the Court, Mr. Zeitune was informed of the challenge filed against him by the State (supra Having Seen 26). In his observations (supra Having Seen 27), Mr. Zeitune considered that he “compl [ies] with the requirements of impartiality and [has] no family ties or personal connection with the alleged victim or interest in the particular case.” He affirmed that “there is no link of any kind, personal or professional, with the alleged victim or with any of the members of the Inter-American Commission on Human Rights.” He argued that in previous cases against Venezuela in which he acted as an expert witness “[his] participation was limited to a presentation on international standards related to the cases in question, without any connection to any of the alleged victims.” Mr. Zeitune further indicated that he has “never participated, either at national or international level, in any proceeding related to [Mr.] Brewer Carías.” 82. The President notes that the State did not base its challenge on any of the grounds for disqualification of expert witnesses established in Article 48(1) of the Court’s Rules of Procedure. Furthermore, he reiterates that the Rules do not establish as grounds for disqualification the fact that an expert witness has rendered an expert opinion in previous cases brought before the Court (supra Considering para. 48). Even though it may be argued that this is based on the supposed provisions of Article 48(1) (c) of the Rules, the President recalls that, according to said Article, an expert witness may only be disqualified on the basis of the following two assumptions: that he or she has close ties with the proposing party and, in addition, when the Court considers that this relationship affects his or her impartiality (supra Considering para. 31). 37 In this regard, the State has not demonstrated the alleged close ties or subordinate position of the proposed expert witness with the Inter-American Commission. Moreover, the fact of having rendered an expert opinion in previous cases before the Court does not imply, in any way, the existence of “close ties or being a subordinate of the proposing party.” Indeed, rendering an expert opinion in previous cases before the Court does not imply that the expert witness is subordinate to, or is under the command or dominion of, either the Commission or the representatives, or that a relationship of dependence exists between him and the Commission. 38 Thus, the central element of close ties specified in the regulatory provision does not apply. 83. Based on the foregoing reasons, and pursuant to Article 48(1) of the Rules of the Court, the President dismisses the State’s objection to Mr. José Jonathan Zeitune, proposed as an expert witness by the Inter-American Commission. 37 Supra note 18. 38 Cf. Case of Forneron and Daughter v. Argentina. Order of the President of the Inter-American Court of Human Rights of September 13, 2011, Considering para. 14; Case of Díaz Peña v. Venezuela. Order of the President of the Court of November 2, 2011, Considering para. 23, and Case Néstor José and Luis Uzcategui et al. v. Venezuela Order of the President of the Court of November 3, 2011, Considering para. 23. 24