16. With regard to newspaper articles, this Court has considered that they can be assessed when they contain well-known public facts or declarations of State officials, or when they corroborate aspects related to the case.16 The Court decided to admit the documents that are complete or that, at least, allow their source and publication date to be verified, and it will assess them, taking into account the body of evidence, the observations of the State, and the rules of sound judicial discretion. 17. Regarding the procedural occasion for the presentation of documentary evidence, pursuant to Article 57(2) of the Rules of Procedure, in general, it must be presented with the application brief, the pleadings and motions brief, or the answering brief, as applicable. In the case of the representatives, Articles 28(1) and 40(2)(b) of the Rules of Procedure establish that the evidence must be presented with the pleadings and motions brief or, at the latest, within 21 days of the day on which the time granted for submitting this brief expired; and this period cannot be extended. However, in the instant case, the representatives submitted a list of 14 annexes with the pleadings and motions brief, 13 of which were not received by the Court on that occasion, or within the said non-extendible time frame, which expired on January 15, 2011; but rather with a delay of three days, on January 18, 2011.17 The representatives did not refer to the fact that these annexes were submitted after the deadline; they merely justified the time-barred submission of annex 12 corresponding to the sworn statement of Eloísa Barrios concerning the Court’s Legal Assistance Fund. In this regard, the Court considers that the documents submitted by the representatives outside the specified time frame cannot be admitted. Notwithstanding the foregoing, given that the said delay does not correspond to the actions of the alleged victims, in application of Article 58(a) of the Rules of Procedure, the Court admits as evidence in this case the powers of attorney granted by the victims, as well as the identification documents and birth certificates of the members of Barrios family included in annexes 1 and 13 to the pleadings and motions brief. 18. In addition, regarding the documents provided by the Commission, the representatives, and the State following the submission of the case and the transmittal of the pleadings and motions brief and the answering brief, the Court finds it appropriate to recall that Article 57(2) of the Rules of Procedure, which regulates the admission of evidence, establishes: Exceptionally, and having heard the opinion of all those participating in the proceedings, the Court may admit evidence if the party that has offered it adequately explains that the evidence was not presented or offered at the procedural moments established in Articles 35(1), 36(1), 40(2) and 41(1) of these Rules of Procedure due to force majeure or serious impediment. Additionally, the Court may admit evidence that refers to an event which occurred after the procedural moments indicated. 19. On October 18, 2010, the Commission reported, as a supervening fact, “the [alleged] death of Wilmer José Flores Barrios,” forwarding four newspaper articles about this incident. The State advised that “[r]egarding the incident that took place on September 1, 2010, in which […] Wilmer José Flores Barrios was a victim, the Fourteenth Prosecutor ordered that an investigation be launched.” In addition, on January 13, 2011, the Commission advised that, on January 2, 2011, Néstor Caudi Barrios had suffered an attempt on his life that had severely injured him and, on January 14, 2011, it forwarded certain documents “as documentary support that it ha[d] been able to obtain […] concerning that incident.” On 16 Cf. Case of Velásquez Rodríguez, supra note 16, para. 146, and Case of López Mendoza v. Venezuela. Merits, reparations and costs. Judgment of September 1, 2011. Series C No. 233, para. 18. 17 The document received within the time frame was attachment 2, “Para-police Groups in Venezuela, COFAVIC, 2005.” 12

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