494. The Court reiterates that, in accordance with its case law, 658 costs and expenses form
part of the concept of reparation, because the efforts made by the victims to obtain justice
both at the national and international level involve disbursements that must be compensated
when the international responsibility of the State is declared in a judgment. Likewise, the
Court reiterates that is not sufficient merely to forward probative documents; rather, the
parties are required to include arguments that relate the evidence to the facts that they
represent and, in the case of alleged financial disbursements, clearly specify the items and
their justification. 659 Therefore, the mere forwarding of receipts is not sufficient and the
expense vouchers issued by the representative organizations themselves are not sufficient
proof of the expenses incurred. 660
495. In the instant case, the Court considers that the costs and expenses arising from the
domestic and international proceedings should be proportional to the number of persons
represented and declared as victims in this judgment.
496. First, the Court notes that since the international responsibility of the State has not
been established to the detriment of the petitioners represented by the common interveners
SIPDH, it is not appropriate for this Court to rule on costs and expenses. 661
497. As for the common interveners Factum Consorcio, the Court notes that they proved
costs and expenses for: an airline ticket for travel from Argentina to Costa Rica, on August
12, 2017, at a cost of USD $1,044.43, 662 and professional services during the hearing on
merits and closing arguments of the lawyer Néstor Morera Víquez, for the sum of USD
$5,000.00. 663 They also submitted an invoice for “professional services in the Case of Manfred
Amrhein et al.” from the attorney Adrián Alberto Martínez Blanco, for the sum of USD
$12,000.00. 664 However, this invoice does not indicate the amount would correspond to
professional services provided after the submission of the pleadings and motions brief.
Consequently, the Court considers that the State should pay the sum of USD $ 18,044.43
(eighteen thousand and forty-four United States dollars and forty-three cents) in favor of the
firm Factum Consorcio for costs and expenses incurred in the domestic proceedings and in
the international proceedings before the Inter-American Human Rights System.
F. Reimbursement of expenses to the Victims’ Legal Assistance Fund
498. The Inter-American Defenders requested the support of the Victims’ Legal
Assistance Fund of the Court to cover their participation in the proceedings, both in the
hearing on preliminary objections and in the hearing on the merits. In their pleadings and
motions brief, they requested access to the Legal Assistance Fund “both for the exercise of
the defense in the inter-American proceedings and in relation to all the expenses required for
any activity related thereto. These expenses include the attendance at the hearing before the
Cf. Case of Velásquez Rodríguez v. Honduras. Reparations and costs, supra, para. 42, and Case of the
Xucuru Indigenous People and its members v. Brazil, supra, para. 214.
659
Cf. Case of Chaparro Álvarez and Lapo Íñiguez v. Ecuador, supra, para. 277, and Case of the Xucuru
Indigenous People and its members v. Brazil, supra, para. 215.
660
Cf. Case of Rodríguez Vera et al. (Disappeared of the Palace of Justice) v. Colombia. Preliminary
objections, merits, reparations and costs. Judgment of November 14, 2014. Series C No. 287, para. 607, and
Case of Vereda La Esperanza v. Colombia, supra, para. 314.
661
Cf. Case of Castillo González et al. v. Venezuela. Merits. Judgment of November 27, 2012. Series C No.
256, fourth operative paragraph.
662
Cf. Reservation of airline tickets Argentina-Costa Rica and Costa Rica-Argentina of Adrián Alberto
Martínez Blanco (evidence file, folio 44972).
663
Cf. Invoice for professional services of Néstor Morera Víquez of September 28, 2017 (evidence file, folio
44886).
664
Cf. Invoice for professional services of Adrián Alberto Martínez Blanco, of September 28, 2017 (evidence
file, folio 44975).
658
146
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