3 a) At the beginning of the 1970s, José María Cantos was the owner of an important business group in the province of Santiago del Estero in Argentina (hereinafter “the Province” or “Santiago del Estero”), composed of the firms Citrícola del Norte, Canroz S.A., José María Cantos S.R.L., Rumbo S.A., José María Cantos S.A., Miguel Ángel Cantos S.A. and Marta Inés S.A. Mr. Cantos was also the principal shareholder of Radiodifusora Santiago del Estero S.A.C. and of the Nuevo Banco de Santiago del Estero, and owned rural and urban properties in the province. b) In March 1972, the Revenue Department of the Province conducted a series of searches of the administrative offices of the businesses owned by Mr. Cantos, based on a purported violation of the Stamp Act.2 In these searches, all the accounting documentation, company books and records, vouchers and receipts attesting to payments made by those companies to third parties and suppliers, as well as numerous shares and securities were seized, without being inventoried. c) The firms began to incur financial losses as a result of the searches and seizures, as they were unable to operate without their business records and papers and had no way of mounting a defense against legal actions brought by third parties demanding payment of bills that had already been settled. d) To defend his interests, Mr. Cantos began a series of legal actions. The first was in March 1972, when he filed a criminal complaint against the Director General of Revenue of the Province. Two months later he filed a petition seeking amparo relief, which was denied. On September 10, 1973, in preparation for the lawsuit, he filed an administrative claim with the federally appointed de facto Governor [interventor federal] of the Province, seeking acknowledgment of the damages and losses caused by the searches conducted by Revenue Department officials and their withholding of the business documents. The losses were estimated at 40,029,070.00 pesos (forty million twenty-nine thousand and seventy pesos) under Act 18,188.3 This claim was expanded on May 23, 1974, when the losses were estimated at 90,214,669.10 pesos (ninety million two hundred and fourteen thousand six hundred and sixty-nine pesos and ten cents) under Act 18,188. In view of the lack of response, on June 6, 1974, and April 26, 1976, Mr. Cantos requested “fast-track” settlement of the administrative claim. e) Because of the lawsuits he had filed, Mr. Cantos was subjected to “systematic persecution and harassment by State agents.” For example, Mr. Cantos was detained and held incommunicado more than 30 times by police agents. His sons, minors at the time, were detained on several occasions and police agents were even posted outside his house on a permanent basis to impede anyone from entering or leaving. According to the records of the Police Force of the Province of Santiago del Estero, from 1972 to 1985, 17 different cases were filed against José María Cantos for the crimes of fraud, embezzlement and forgery. The defendant was acquitted in every case. 2 The Stamp Act relates to registration and stamp taxes. 3 The Act of April 15, 1969, states that 100 pesos is equal to one “Act 18,188 peso.”