410. The representatives also asserted that the expulsion of the victims constituted abusive and arbitrary interference in the right to privacy of the Medina Ferreras, Fils-Aimé, Sensión, Jean, Gelin and Pérez Charles families. In this regard, they argued that the members of these families had been born in the Dominican Republic or had lived in that country for many years, so that they had close ties with the persons around them and with the different communities in which they lived, and Dominican Republic was the only reality they knew. Their expulsion meant that they were exposed to a new reality, a place with a different culture, in which another language was spoken, and where they had no support network. In addition, the expulsions had a significant impact on their living conditions and, in many cases, even on their health. The representatives alleged that this violation had been particularly severe in the case of the children affected by the expulsion, given their particular situation of vulnerability and the obligation of the State to adopt special measures of protection in their favor, which it failed to comply with. 411. Based on the above, the representatives considered that the State had violated the rights of the family and to family life of the members of the said families who were separated, as well as the right to privacy of all the victims who were expelled in violation of Articles 11(2) and 17 of the American Convention, in relation to Articles 1(1) and 19 of this instrument. 412. For its part, the State denied the facts relating to the expulsions. Regarding the presumed separations, the State indicated that, in a communication of August 21, 2001, the representatives had indicated that: “Berson Gelin has been reunited in Haiti with his youngest son, William, and therefore there is no need to insist on the measures of the Inter-American Court in that regard.” It had also been indicated that Mr. Gelin was currently living in the Dominican Republic. In the case of Rafaelito Pérez Charles, who had alleged a supposed separation from his mother and siblings for five days due to his presumed expulsion, the State understood that this lapse could not be considered an unreasonable time in order to establish that the State had violated the right to protection of the family. Regarding the members of the Medina, Fils-Aimé and Jean Mesidor families, the State emphasized that they had alleged that they were deported together so that there was no violation of the rights of the family owing to the supposed family separation. With regard to the situation of the Sensión Family, the State, in its answering brief, indicated that Antonio Sensión was working in Puerto Plata at the time of the supposed deportation of Ana Virginia Nolasco and her daughters, Ana Lidia Sensión and Reyita Antonia Sensión, so that he was already living apart from his family; moreover, Antonio Sensión became aware of the presumed deportation months after it occurred. In addition, the State indicated that only three years passed from March 25, 1999, until 2002, and that, in March 2002, the State had proceeded to grant safe-conducts, which were renewed in 2010. Consequently, the State indicated that it had not violated the rights recognized in Articles 11 and 17 of the Convention, in relation to Article 1(1) of this instrument, to the detriment of the said presumed victims. B) Considerations of the Court B.1. Family separation (Article 17(1)) 413. The Court observes that some of the arguments of the Commission and of the representatives concerning the presumed violation of the rights of the family, recognized in Article 17 of the American Convention, in relation to the rights of the child, recognized in Article 19 thereof, refer to the impact of the expulsions, for example on the living conditions of the victims who were expelled, and not to obligations related to the rights of the family stricto sensu. Regarding the alleged violations of Article 17 of the Convention, 131

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