80 iii. they asserted that the pension afforded to Albertina Viana-Lopes under law No. 13,491 is not sufficient to cover the damage caused. She receives the disability pension previously afforded to Mr. Damião Ximenes-Lopes. c) In relation to pecuniary damage: i. the representatives requested the Court to set, on equitable grounds, the amount of USD 80,000.00 (eighty thousand United States dollars as compensation for the suffering undergone by Mr. Damião Ximenes-Lopes; ii. the representatives further stated that the victim’s death caused Albertina Viana-Lopes, mother of the victim, to suffer depression, and that she is currently suffering emotional distress. The life annuity granted by the State cannot be considered a reparation for her or for the other next of kin of the victim. Therefore, they requested the Court to set, on equitable grounds, the amount of USD 50,000.00 (fifty thousand United States dollars) as the compensation to be paid to her. In addition, they stated that the lady was the direct victim of the abuse and ill treatment suffered by his son, since she witnessed the torture he had been subjected to and she was treated with lack of respect by the director of the Casa de Reposo Guararapes (Guararapes Rest Home). Therefore, they requested the Court to raise the amount of the compensation in USD 25,000.00 (twenty-five thousand United States dollars); iii. the representatives also stated that Mr. Francisco Leopoldino Lopes, Damião Ximenes-Lopes’ father, had suffered depression for a long time and he thinks that justice will never be served in the case of his son. He is currently a regular churchgoer, seeking spiritual comfort. Therefore, they requested the Court to set, on equitable grounds, the amount of USD 50,000.00 (fifty thousand United States dollars), as the compensation to be paid to him; iv. the death of the victim caused Irene Ximenes-Lopes-Miranda, Damião Ximenes-Lopes’ sister, physical and psychological suffering; she lost her job 26 days after the death of his brother and has suffered depression for three years the consequence of which was lack of motivation to work. She suffered mental and emotional exhaustion in the search for justice because of the several meetings and hearings she had to attend with health, judicial and human rights institutions, and she felt “humiliation for begging for justice.” In addition, the death of the victim caused Mr. Cosme Ximenes-Lopes, Damião Ximenes-Lopes’ identical twin, severe distress, as he could suffer the same as his brother went through should he need psychological aid from a health care institution again. He has suffered six years of frustration as a result of the impunity of the perpetrators and constant grief for the loss of his twin brother. Therefore, they requested the Court to set, on equitable grounds, the amount of USD 15,000.00 (fifteen thousand United States dollars), as compensation to be paid to each of them. d) In relation to other means of reparation, they pointed out that: i. they recognize the State’s initiative to improve the conditions of psychiatric care; ii. the complaints of serious human rights violations committed in mental health institutions must be effectively investigated, and all those involved must be held liable and punished; iii. the oversight entities must establish procedures for supervising the operation of health units;

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