104. The Court has indicated that notification must be provided before the accused makes his first statement before a public authority.95 The content of the notification “will vary according to the progress of the investigations […] and when the formal and definitive presentation of the charges takes place […] prior to this and at the very least, the person under investigation must know, in as much detail as possible, the facts that are attributed to him.”96 In the instant case, on July 5, 1995, Mr. Grijalva was notified of the order to investigate an alleged crime, and that same day, he rendered his “investigative testimony.” However, this Court considers that the latter did not constitute a breach of Mr. Grijalva’s right of defense, since at that time he was informed of the facts for which he was being investigated. 105. With regard to the failure to notify the defendant of the prosecutor’s report, as alleged by the Commission, based on the evidence, this Court has confirmed that Mr. Grijalva requested its notification. This notification took place on July 23, 1996, after which, on July 31, 1996, he submitted his observations on it. Therefore, the Court does not find any violation in this regard. 106. Based on the foregoing, this Court considers that the State is not responsible for the violation of Articles 8(2)(b) and 8(2)(c) of the American Convention. A.2.2. Right to examine witnesses 107. Article 8(2)(f) of the Convention establishes, as a “minimum guarantee”, “the right of the defense to examine witnesses present in the court and to obtain the appearance, as witnesses, of experts or other persons who may shed light on the facts,” thereby protecting the principles of adversarial and procedural equality. The Court has indicated that, among the prerogatives that must be granted to someone who has been accused is the opportunity to examine witnesses against and in his favor, under the same conditions, for the purpose of exercising his defense.97 108. In the evidence provided during the military criminal proceedings regarding the witnesses ER and RG, who accused Mr. Grijalva of supposed irregularities committed in the performance of his duties in the Captaincy of Puerto Bolívar, it is recorded that they testified on two occasions: a) on April 13, 1994, Mr. ER and Mrs. RG testified in Puerto Bolívar before the military criminal judge of the First Naval Zone and, b) on October 5, 1994, Mr. ER gave his testimony in Huatalco before the military criminal judge of the First Naval Zone and Mrs. RG rendered her testimony in Puerto Bolívar before the same judge. These procedures were carried out without the participation of Mr. Grijalva’s defense. 109. The Court has confirmed that on May 14, 1996, Mr. Grijalva asked the military judge of the First Naval Zone to summon the aforementioned persons to testify. On June 27, 1996, the Military Criminal Court of the First Naval Zone issued an order “requiring the testimonies of […] [ER] and RG (for Monday 01 July 1996 at […] 10H00 and 12H00.” However, the State did not provide evidence that these procedures were Cf. Case of Tibi v. Ecuador. Preliminary objections, merits, reparations and costs. Judgment of September 7, 2004. Series C No. 114, para. 187, and Case of Montesinos Mejía v. Ecuador. Preliminary objections, merits, reparations and costs. Judgment of January 27, 2020. Series C No. 398, para. 190. 96 Case of Barreto Leiva v. Venezuela. Merits, reparations and costs, supra, para. 31, and Case of J v. Peru. Preliminary objection, merits, reparations and costs. Judgment of November 27, 2013. Series C No. 275, para. 199. 97 Cf. Case of Castillo Petruzzi et al. v. Peru. Merits, reparations and costs. Judgment of May 30, 1999. Series C No. 52, para. 154, and Case of Amrhein et al. v. Costa Rica. Preliminary objections, merits, reparations and costs. Judgment of April 25, 2018. Series C, No. 354, para. 449. 95 28