offense of conspiracy to change the Constitution by violent means,” so that, “consequently, the prosecution of these persons” would ensue.” 65 The indictment included: a) A “clear, precise and detailed account of the illegal act attributed to [Mr.] Brewer Carías”; 66 b) The grounds for the accusation, with a list of the evidence used to draw up the charges; c) The applicable legal provision, and d) An “offer of evidence [to the judge].” 62. Regarding the first point, the prosecutor mentioned the following elements that presumably proved Mr. Brewer’s criminal responsibility: a) On “April 10, 2002, at 6 p.m., [Mr.] Brewer Carías [allegedly] met with José Gregorio Vásquez López and Jorge Olavarría, among others, in the latter’s office, […] in order to discuss what would become the ‘Decree constituting a Government of Democratic Transition and National Unity”; b) “During this meeting, a draft decree was [allegedly] submitted to [Mr.] Brewer Carías for discussion […]. […] The draft [was] examined and discussed by [Mr.] Brewer Carías, who [allegedly] underscored the poor quality of the drafting, but never indicated […] that it was not the appropriate procedure […] to change the Constitution”; c) On “April 11, 2002, at 9 a.m., a ceremony was held on a platform set up in front of the PDVSA building, and [Mr.] Brewer Carías was among those present. [He had] momentarily left the march and went [to be interviewed], stating that, once the interview was over, he would rejoin the march”; d) “Letters of resignation and dismissal [had been prepared, […] and documents had been drawn up, and the investigation revealed that [Mr.] Brewer Carías was one of the persons [supposedly] responsible for drafting these legal instruments”; e) On April 11, at Fort Tiuna, Mr. Brewer Carías had “again examined the document that he had discussed two days previously” and had “drafted what would be the letter of resignation of the President of the Republic and [had] given advice on how the new government should proceed; [he had] provided instructions and suggestions on how to implement the said decree”; f) On the morning of April 12, 2002, Mr. Brewer Carías had been interviewed during the program CMT Noticias and, from there, he had driven “to the Miraflores Palace” where he had presumably met with Pedro Carmona, and g) During the evening of April 12, 2002, he alleged “telephoned José Gregorio Vásquez López […] who […] was allegedly in a meeting with Pedro Carmona […], planning the new government’s strategies.” 63. With regard to the second point, the prosecutor had prepared a list of the evidence together with the arguments used to substantiate the charges against Mr. Brewer Carías. 67 65 Indictment of October 21, 2005 (file of annexes to the answering brief, annex 1, exhibit 13, folios 14193 to 14351). 66 Indictment of October 21, 2005 (file of annexes to the answering brief, annex 1, exhibit 13, folios 14196 to 14202). 67 Indictment of October 21, 2005 (file of annexes to the answering brief, annex 1, exhibit 13, folios 14209 to 14274). The indictment includes 31 probative elements in addition to those established in the accusation and, in “Chapter III,” on “grounds for the accusation indicating the evidence that emerges from the investigation against […] Allan Brewer Carías,” describes 54 “probative elements” for the indictment: (A) content of the “Decree constituting a Government of Democratic Transition and National Unity”; (B) two criminal complaints against Allan Brewer Carías filed before the Public Prosecution Service; (C) two briefs filed by Allan Brewer Carías; (D) 19 21