the border with Haiti by different means and obliged to stay on the Haitian side. According to the representatives, the expulsions occurred in a context of mass collective detentions and expulsions of Haitians and Dominicans of Haitian descent, which affected many thousands of persons and were carried out in groups. They indicated that although some of the victims returned to the Dominican Republic, they did so by their own means and without the assistance of the Dominican authorities. Based on the way in which the expulsions were carried out, and even on the expressions used by the authorities who implemented them, it is evident that the intention was that those concerned would not be able to return to that country. The representatives added that the presumed victims were not given the opportunity to take their possessions with them, and were unable to return to their place of origin for a long time. In other cases, the victims were divested of any possessions they had with them by the authorities who detained them. 334. The representatives also indicated that the procedure established by domestic law was not respected in any of the cases. They argued that “[t]he victims were not informed of the charges against them, and were not given the opportunity to defend themselves. Much less were they given access to a lawyer to assist them in the defense of their rights.” They added that the presumed victims were unable to have recourse to the domestic remedies, because: (a) they were expelled collectively without a court order, so that there was no judicial decision to contest, and the immediate expulsion from Dominican territory prevented them from having access to any remedy, and (b) once expelled, the presumed victims were outside Dominican territory and, therefore, did not have access to an effective remedy. 335. Consequently, the representatives asked the Court to declare the violation of the rights to personal liberty, to judicial guarantees, to freedom of movement and residence and to judicial protection recognized in Articles 7, 8(1), 22(1), 22(5), 22(9) and 25(1), of the American Convention, in relation to Article 1(1), to the detriment of several victims, 371 and Article 19 of this instrument, because the violations are “particularly serious in the case of the victims who were children at the time of the events,” because the State had also failed to comply with its obligation to adopt special measures of protection in their favor. 336. In addition, without linking it to a specific article of the American Convention, the representatives, in their brief of June 17, 2014, stated, in relation to the proceedings relating to the documentation of Willian Medina and the members of his family, that “[t]he State has not proved that it has ensured the right to defense of Mr. Medina Ferreras and his family or that the State authorities have conducted an impartial investigation in the course of which they have proved the responsibility of Mr. Medina Ferreras in the irregularities of which he is accused.” 337. The State, for its part, refuted the “presumed pattern” of the immigration control operations or “sweeps” for the detention and subsequent deportation of Haitians and Dominicans of Haitian origin, and reiterated that the General Directorate of Immigration at the time of the supposed actions and facts applied a procedure consisting of three stages: (a) arrest and identification; (b) investigation and filtering, and (c) verification and confirmation. 371 The representatives indicated, among others, as presumed victims: Willian Medina Ferreras, Lilia Jean Pierre, Awilda Medina, Luis Ney Medina, Carolina Isabel Medina, Jeanty Fils-Aimé, Janise Midi, Nené Fils-Aimé, Diane Fils-Aimé, Antonio Fils-Aimé, Endry Fils-Aimé, Bersson Gelin, Rafaelito Pérez Charles, Victor Jean, Marlene Mesidor, Markenson Jean, Victoria Jean, Miguel Jean and Natalie Jean, as applicable. 109