was in force;263 (b) the current normative framework, which has fully re-established the punitive claims of the State (Law 18,831 of October 27, 2011) and (c) the impetus given to the judicial cases since the creation of the Office of the Special Prosecutor for Crimes against Humanity (Law 19,550 of October 25, 2017).” Uruguay maintained, referring to current State actions, that it has led a “fight against impunity.”264 242. The State also maintained that, although during the “first phase,” beginning in December 1986, the Expiry Law impeded the prosecution of different types of crimes, this was reversed in the “second phase.” It pointed out that, since the enactment of Law 18,831 in 2011, there are no obstacles to investigating serious violations of human rights committed during the dictatorship. It especially pointed out that “the Expiry Law is no longer an obstacle.”265 Uruguay added that, during the “third phase,” it has “strengthened the institutions involved in clarifying the events, increased their resources and strengthened the human rights training of the operators involved.”266 It underscored the creation of the Office of the Special Prosecutor in 2017267 “with exclusive competence in all criminal cases concerning violations of human rights that occurred during [the dictatorship].”268 It emphasized that that resulted in a “significant strengthening” of the capacity to conduct criminal investigations,269 which resulted in an increase of Regarding the “first phase,” the State mentioned the following actions: (a) the creation, on April 9, 1985, of a Parliamentary Investigative Commission, which investigated events that occurred during the dictatorship, including the disappearances of Mr. Tassino and Mr. González González and presented complaints before the judiciary; (b) the creation, on August 9, 2000, by Presidential Order 858/000, of the Peace Commission to “compile information on forced disappearances during the de facto regime” which in 2003 issued its Final Report that expresses the “firm conviction” of the perpetration of “serious violations of human rights,” such as torture, “unlawful” detentions and forced disappearances; and (c) as a consequence of the prior work, the creation in April 2003 of a Follow-Up Secretariat” of the work of the Commission, which in August 2013, became the “Secretariat of Human Rights for the Recent Past,” having among its functions that of “seeking knowledge on the events and the truth about the forced disappearances, political assassinations and the factual context of the violation of human rights during the dictatorship.” 263 As an element of evidence, the State mentioned that “it was a civil party in criminal proceedings in Italy as part of the “Operation Condor” case, presenting evidence as such.” It pointed out that “that case, as is public knowledge, concluded in Rome on July 9, 2021 with the unappealable sentencing by the Supreme Court of Cassation to perpetual imprisonment of 11 Uruguayan citizens, most of them former members of the military.” It affirmed that “the Italian justice acknowledged the documentary evidence provided by the State of Uruguay.” 264 Uruguay pointed out regarding the possibility of investigating crimes committed during the dictatorship, that the issue of the alleged effects of the Expiry Law is distinct from the functioning of the Rule of Law and of the independence of the judicial bodies” since one can agree or not with certain decisions, but that is not a shortcoming of the State, but rather it is one of the avatars of the Rule of Law.” 265 It informed that, since 2012, it has “trained prosecutors, providing as some examples the “creation by the Ministry of the Interior of a Special-Aid Team of the Ministry of Justice for crimes of State terrorism to collaborate directly with the justice operators of the Judiciary and the forming of a Specialized Human Rights Unit of the Office of the Prosecutor General in 2015.” It also pointed out that the Supreme Court “has implemented human rights modules in courses at the Center of Judicial Studies for aspiring judges, public defenders and prosecutors.” 266 The State mentioned that this was “part of the [State] commitment to comply with the Court’s judgment in the Gelman” case. 267 The State underscored that the Office of the Special Prosecutor has “a direct and permanent relationship” with “the family groups of the victims.” 268 The State emphasized that the creation of the Office of the Special Prosecutor, with national jurisdiction, resulted in “a sole criterion of investigation,” […] ”a sole legal position” and “a specialized technique.” 269 62