-4- 7. Regarding the obligation of the State to grant a scholarship for post-secondary or university studies to Luis Alberto Cantoral Benavides (operative paragraph six of the Judgment on reparations), the State indicated that “the Ministry of Education has satisfactorily completed the processing and has made the payment” (f.1497), that is to say, “it has completely paid for Mr. Luis Alberto Cantoral Benavides’ university studies […], expenses were paid in a timely manner and in accordance with the estimations that were budgeted for and given to the Ministry of Economy and Finance and previously accepted by the representatives […], in the absence of any debt or any recognition of accruals due to delays in payments […].” 8. The representatives reiterated that “there is a difference of 12,157.20 [Brazilian] [R]eales between the payments made by the State [and] Mr. Cantoral Benavides´ expenses in 2007 and 2008,” because, when payments were agreed, the calculation was based upon an estimation where a 5 % increase in expenses was applied to those years compared to 2004, 2005, and 2006, but this did not correspond to the actual expenses incurred. They indicated, in addition, that in April of 2010, they had a meeting in Lima with the Specialized Prosecutor General’s Office, which promised to coordinate with the Ministry of Education and the National Board of Human Rights to cover the difference between the payments. Also, they acknowledged that “all the payments were made in accordance with the timeframes set between the parties in the Act of Fulfillment of the Judgment [December 28, 2007]” and that the only delayed payment would be the one referred to. Although on various occasions they stated that the payment of the moratory interests generated by the delays were still pending, in their last brief, the representatives stated that as an act of goodwill, Mr. Cantoral Benavides had stated that he had renounced the payment of the moratory interests. Lastly, they requested the Court to continue to monitor compliance regarding this obligation until the execution of all payments has been verified. 9. In response to the representatives’ remarks, the State issued a report from the Ministry of Education of January 15, 2010, which gives details of the actions carried out to comply with this point, in an alternate manner to the steps originally taken to obtain a full academic scholarship in Peru. The report states that, having paid S/.133,641.30 for 2004 through 2006, in November of 2006, studying expenses for 2007 and 2008 were estimated at S/.49,713.14 and S/.52,198.79, so as to be included in the respective annual budgets. Therefore, for the purposes of timely undertaking the respective payments, in January of 2007, Mr. Cantoral Benavides’ representatives were informed of this matter because they had to agree to the processing, approval, and inclusion of the respective budgets. The State asserted that the representatives expressed their full agreement with the amounts. Furthermore, according to the report, the alleged lack of compliance by the Ministry of Education “becomes unfounded, insofar as the amounts paid in 2007 and 2008 were projected, programmed, and considered by the Ministry of Economy and Finance, so as to include payment commitments in the respective years, and especially given that said amounts were considered and fully accepted” by the representatives. The State added that the increased expenditure requested by Mr. Cantoral Benavides could not be acknowledged since said amounts, predicted for 2007 and 2008, were approved and authorized as the limits by said Ministry. Additionally, it stated that, in terms of the allegations that a representative of the Ministry of Education had acknowledged an increased expenditure and that this would be allowed for in the 2008 payment, “no agreement, act, or document exists that supports said statement.” Regarding the acknowledgment of the academic expenses and interests for 2009, it also became inadmissible since the representatives announced that Mr. Cantoral Benavides had finished his studies. 10. To this end, the representatives stated that when signing the Act, the Ministry of Education acknowledged that the 2007 and 2008 amounts were approximations, given that

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