23 113. On June 28, 2001, Edith Alexandra Orellana made a statement. She stated that she confirmed her initial statement and subsequent extension. She indicated the reasons why she considered that Mr. HS’s blood was not given to TGGL and detailed the procedures used at the Red Cross Blood Bank.134 114. On June 29, 2001, Pablo Arturo Monsalve issued an affidavit in the name of the Red Cross which said the following: “on June 22, 1998, two red blood concentrates (CGRs) were sent for [TGGL], whose codes matched numbers 43095 and 43097 sent at 18:00 hours by Mrs. Mariana Ramírez, and two plasma concentrates (CPq), whose codes matched numbers 43146 and 43142 sent at 21:49 hours by Miss. Bertha Regalado.”135 115. On July 5, 2001, Claudio Arias gave preliminary investigation evidence indicating that the Red Cross “has been subjected to a systematic smear campaign.” As regards the salient questions on aspects of the present case, he pointed out that his role was administrative and that he lacked specific knowledge. He made reference in general terms to the procedures followed and the available evidence. 136 116. On July 11, 2001, the expert witnesses Peralvo and Vivar responded to the questions sent on June 27, 2001.137 The answers given, so far as it is relevant, can be summarized in the following points: - - - - The general modes of transmission and their frequency according to Johns Hopkins Hospital are: sexual transmission, 71%; injectable drug use, 27%; transfusions, 1%; and prenatal transmission, 1%. Less frequent modes of transmission occur due to occupational exposure. The mode of transmission in children has particular characteristics: born to a parent with AIDS, 80%; blood transfusions, 11%; hemophiliacs who received factor VIII or IX, 6%; and incomplete information, 3%. Modes of transmission that may occur (shared toothbrushes, hair salons, etc.) are theoretically possible routes, but the incidence is so low that global statistics are not kept. According to the statistics, the experts confirm that “the human immunodeficiency virus can be passed to children from transmission by an infected mother or by contaminated blood products (...) other possible routes of infection have an insignificant or zero role.” According to the trial findings, TGGL’s mother is not an HIV carrier and consequently the infection was not antenatal. Their previous experts’ report specifies that the results of the University of Louvain indicate that the genetically identical virus affected the two individuals. They explained the significance of these findings in the following terms: “the dissimilarity of two viruses is proportional to the time elapsed from when the two viruses separated from a common host. The closer the epidemiological link between the two individuals infected with HIV, the more similar will be the viruses of those individuals. This experimental confirmation is a basic concept of HIV molecular epidemiology, allowing us to understand the epidemiological relationships on the basis of viral genetic data.” producing AIDS?; 13 – Did the girl TGGL have a negative HIV test prior to her transfusion to confirm irrefutably that the infection was caused by the blood originating from the Red Cross? (...)?”. 133 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Order of June 28, 2001. Folio 160. 134 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Edith Orellana June 28, 2001. Folio 162. 135 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Certificate of the Red Cross of June 29, 2001. Folio 164. 136 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Statement of Claudio Arias of July 5, 2001. Folios 166 – 168. 137 Annex 2. Court File. Second Criminal Court of Cuenca. Incorporated into Annex 1, Court File. Civil Action No. 323 05. Superior Court of Justice of Cuenca. First Chamber. Response of the Expert Witnesses Peralvo and Vivar of the July xx, 2001. Folios 176 185.