Italia” (hereinafter “the Italian Association” or “the Association”). 78 Pablo Carlos Mémoli (hereinafter “Pablo Mémoli”), Carlos Mémoli’s son, is a journalist and a lawyer, and Managing Director of La Libertad, a newspaper founded in 1945, published twice a month in San Andrés de Giles, a town 100 kilometers from Buenos Aires. 79 65. In 1984, the Municipality of San Andrés de Giles leased the Italian Association a plot of land in the Municipal Cemetery for “the construction of burial niches [so that it could], offer them to its members, by instalment payments.” 80 The Italian Association offered these burial niches to its members, built in the so-called “Italian Vault,” “under sales contracts.” 81 66. In 1989, the Italian Association began to offer an Italian language course. Clotilde Romanello, wife of the Vice President of the Italian Association (Humberto Romanello), was appointed course Director, and her son, Sergio Romanello, was appointed Assistant Director and teacher. 82 67. According to Carlos Mémoli, his wife, Daisy Sulich de Mémoli, offered her services to participate “in an honorary capacity” as a teaching assistant. Following “constant obstacles” or requests for explanations that went unanswered about the “family privileges” granted to Mr. Romanello, it was suggested that Mrs. Mémoli take part in a public competition to see who the most qualified candidate was. 83 According to Carlos Mémoli, Daisy Sulich came forward and presented her diplomas and curriculum vitae, while Mr. Romanello’s son and wife did not do 78 Cf. Certification of membership payment issued by the Italian Association (file of proceedings before the Commission, folio 840), and decision of June 6, 1990, of the Criminal Judge of the province of Buenos Aires (file of annexes to the Merits Report, annex 4, folio 218). Under the provisions of article 2 of Law No. 20,321, mutual associations are associations that are “freely constituted, not-for-profit, by persons inspired by solidarity, in order to offer each other mutual assistance in the event of future risks or to contribute to their material and spiritual wellbeing, by regular contributions” (file of annexes to the State’s final written arguments, annex II, folio 3772). According to information provided by Carlos Mémoli in a radio program broadcast on May 10, 1990, he had “been a member of the Italian Association for around one year.” Cf. Transcript of program broadcast by Radio Vall on May 10, 1990, included in the case file of the criminal proceedings (file of annexes to the State’s final written arguments, annex III, folio 3923). 79 Cf. Pleadings and motions brief (merits file, folio 85), brief with final arguments of the representatives (merits file, folio 700); La Libertad newspaper dated September 3, 2004 (file of proceedings before the Commission, folio 1377), and 2004 Santa Clara de Asks Award (file of proceedings before the Commission, folio 1374). The State specified that San Andrés de Giles is 110 kilometers from Buenos Aires. Cf. Brief with final arguments of the State (merits file, folio 833). 80 Judgment of the Second Appellate Chamber for Criminal and Correctional Matters of the Judicial Department of Mercedes, Province of Buenos Aires, of December 28, 1995, case No. 55,964 (file of annexes to the Merits Report, annex 2, folios 80 and 81). See also: Ordinance No. 114 of December 17, 1984, of the Town Council of San Andrés de Giles (file of annexes to the State’s final written arguments, annex III, folio 3864), and Ordinance No. 147/88, Official gazette for the period January-December 1988 of the Town Council of San Andrés de Giles (file of proceedings before the Commission, folios 876 and 877). 81 Judgment of the Second Appellate Chamber for Criminal and Correctional Matters of the Judicial Department of Mercedes, Province of Buenos Aires, of December 28, 1995, case No. 55,964 (file of annexes to the Merits Report, annex 2, folio 81). 82 Cf. Communiqué (solicitada) entitled “Autoritarismo e irregularidades de una Comisión Directiva” [Authoritarianism and irregularities of a Management Committee], published by Carlos Mémoli in the newspaper La Libertad on April 14, 1990 (file of annexes to the State’s final written arguments, annex III, folio 3881); transcript of the program broadcast by Radio Vall on May 10, 1990, included in the case file of the criminal proceeding (file of annexes to the State’s final written arguments, annex III, folio 3923), and brief of lawsuit for defamation against Messrs. Mémoli (file of annexes to the State’s final written arguments, annex III, folio 4152). According to the Diccionario de la Real Academia Española a “solicitada” is an article or news item that a private individual is interested in seeing published and that, at his request, is incorporated into the newspaper against payment. 83 Cf. Communiqué (solicitada) entitled “Autoritarismo e irregularidades de una Comisión Directiva” published by Carlos Mémoli in the newspaper La Libertad on April 14, 1990 (file of annexes to the State’s final written arguments, annex III, folio 3881). 25