Venezuela in the context of the 1999 to 2003 armed conflict,” because it has sufficient elements of evidence to assess the context of the instant case. C. Expert evidence offered by the Inter-American Commission and the representatives 9. Both the Inter-American Commission and the representatives offered as evidence the expert opinions of Raúl Cubas and Pedro Berrizbeitia (supra having seen paragraphs 1 and 3). 10. Regarding the expert opinion of Mr. Cubas, both the Commission and the representatives indicated that its purpose was to refer to the situation of violence in the state of Zulia and, in particular, in the municipality of Machiques, owing to the presence of illegal armed groups and the peasant land struggles. In addition, he would provide an opinion on the effects of this context on the work of the human rights defenders in the zone, and on the lines of investigation that could have been followed up in the case. The Commission considered that the said expert opinion would allow the Court to put the facts in context, from the differentiated perspective of a vulnerable group, with the consequent development of standards in this regard, issues that have a relevant effect on interAmerican public order. 11. Regarding the expert opinion of Mr. Berrizbeitia, both the Commission and the representatives indicated that “he will testify on the circumstances that have contributed to impunity in the instant case by analyzing the domestic investigations and their appropriateness in view of the international human rights standards applicable [to the murder of human rights defenders].” The Commission considered that the said expert opinion refers to an issue of inter-American public order to the extent that it offers the Court a differentiated perspective on compliance with the obligation to investigate in the case of human rights defenders. 12. The President recalls that, as established in Article 35(1)(f) of the Rules of Procedure, the “possible appointment of expert witnesses” may be made by the InterAmerican Commission “when the inter-American public order of human rights is affected in a significant manner,” and the purpose and grounds must be adequately substantiated by the Commission. This provision means that the appointment of expert witnesses by the Commission is exceptional, subject to the said requirement, which is not met merely because the evidence that it is proposed to provide is related to an alleged human rights violation. 3 13. The President notes that the expert opinion of Mr. Cubas is limited to the specific context and situation of Venezuela and of the state of Zulia, and to the lines of investigation in this specific case, so that the purpose does not constitute an issue of inter-American public order. With regard to the proposed purpose of the expert opinion of Mr. Berrizbeitia, the President finds that, even though it concerns the acts relating to the impunity in the case and their correspondence to international standards, it is also circumscribed to the facts of the instant case; hence, no implications for inter-American public order can be inferred. 14. Notwithstanding the above, the President finds that, although they are unrelated to inter-American public order, the said expert opinions can provide relevant elements to 3 Cf. Case of Vera Vera et al. v. Ecuador, supra note 3, ninth considering paragraph, and Case of Díaz Peña v. Venezuela. Order of the President of November 2, 2011, twenty-fifth considering paragraph. 4

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