statement, the person investigated must have been informed officially of the facts he or she is accused of, and not only infer them from the questions that are asked. 306 This Court also notes that this State obligation acquires greater relevant when the accused is subject to deprivation of liberty as in the instant case. 307 The Court has considered that the strict observance of Article 8(2)(b) is essential for the effective exercise of the right to defend oneself. 308 200. In the instant case, according to the documentation in the case file, Ms. J.’s defense counsel was only able to know the facts for which she was investigated, the evidence gathered by the State and the legal definition given to these facts on April 28, 1992, when the prosecutor filed the criminal complaint against her, which occurred after Ms. J. had given her first statement (supra para. 198). 201. Therefore, the Court concludes that, by failing to notify Ms. J. formally of the reasons for her detention and the facts that she was accused of until April 28, 1992, when the criminal complaint was filed against her, the State violated the rights embodied in Articles 7(4) and 8(2)(b) of the American Convention, in relation to Article 1(1) thereof, to the detriment of Ms. J. b. The limitations J. had to converse with her lawyer (alleged violation of paragraphs (c) and (d) of Article 8(2) of the Convention) 202. This Court notes that Ms. J. was assisted by her lawyer during her police statement and 309 and also that her during the different declarations that were part of her preliminary statement, lawyer was able to file briefs in the proceedings and request that certain measures be taken. 310 Nevertheless, Ms. J. indicated that she was unable to meet with her lawyer more than three times for between 15 and 25 minutes during the fourteen months that she remained subject to preventive detention and always under strict State supervision. The Court notes that the State did not deny this; rather, to the contrary, Peru justified this restriction by “the confidential nature of the proceedings.” 203. Although it is true that article 12(f) of Decree 25,475 was not in force at the time of Ms. J.’s detention, 311 the Court takes note of what the CVR indicated, to the effect that the said norm “ended up by consolidating a situation of de facto incommunicado of all those detained for the crime 306 Cf. Case of Fermín Ramírez v. Guatemala. Merits, reparations and costs. Judgment of June 20, 2005. Series C No. 126, paras. 67 and 68, and Case of Barreto Leiva v. Venezuela, supra, para. 31. 307 Cf. Case of Palamara Iribarne v. Chile, supra, para. 225. 308 Cf. Case of Tibi v. Ecuador, supra, para. 187, and Case of Barreto Leiva v. Venezuela, supra, para. 28. 309 Cf. Statement of Ms. J. of April 21, 1992 (file of annexes to the answering brief, annex 31, folios 3668 to 3671); preliminary statement of June 10, 1992, before the Tenth Investigating Court of Lima (file of annexes to the answering brief, annex 41, folios 3697 to 3701); preliminary statement of June 15, 1992, before the Tenth Investigating Court of Lima (file of annexes to the answering brief, annex 42, folios 3703 to 3709); preliminary statement of June 19, 1992, before the Tenth Investigating Court of Lima (file of annexes to the State’s brief of June 24, 2013, annex 17, folios 4740 to 4745), and preliminary statement of August 3, 1992, before the Tenth Investigating Court of Lima (file of annexes to the State’s brief of June 24, 2013, annex 18, folios 4745 to 4747). 310 Cf. Brief dated June 26, 1992, in which J.’s defense counsel requested evidence and asks the Third Criminal Court of Lima to send notes asking the different institutions to forward evidence to the proceedings; brief dated July 30, 1992, in which J.’s defense counsel asked the Third Criminal Court of Lima to send notes to institutions asking them to forward documents that prove that the journalists who J. assisted had the pertinent permits; brief dated August 11, 1992, in which J.’s defense counsel requested that the records of personal and home search in the case file be eliminated; brief with conclusions of J.’s representatives dated June 3, 1993; brief dated December 15, 1992, in which J.’s defense counsel contested the conclusions of the graphological expertise; brief dated February 18, 1993, in which J. proposes an expert witness for the purposes of the contesting the graphological expertise; brief dated February 18, 1993, in which J. requests a photographic expertise, and brief dated March 10, 1993, in which J. asks the court to notify the expert witness proposed for the graphology expertise of the questions that he should answer (file of annexes to the State’s brief of June 24, 2013, annex 26, folios 4840 to 4852). Similarly, see the record of the hearing of June 2, 1993, which reveals that one of the expert witnesses proposed by J. was not summoned by the court owing to lack of time (file of annexes to the State’s brief of June 24, 2013, annex 20, folio 4759). 311 Cf. Decree-Law No. 25,475 of May 5, 1992, Article 12(f) (file of annexes to the answering brief, annex 7, folio 3261). 61