3. Based on the foregoing, the Inter-American Commission asked the Court to declare the State responsible for the violation of the rights recognized in the following articles of the American Convention: 4 (Right to Life), 5 (Right to Personal Integrity), 7 (Right to Personal Liberty), 8 (Right to Judicial Guarantees), 11 (Right to privacy and family life), 19 (Rights of the Child), 21 (Right to Property), 22 (Freedom of Movement and Residence), and 25 (Right to Judicial Protection), in relation to the general obligation to respect and guarantee human rights established in Article 1(1) of the Convention, to the detriment of the members of the Barrios family indicated in the annex to the Merits Report.5 In addition, the Inter-American Commission asked the Court to order the State to provide specific measures of reparation. 4. The submission of the case to the Court by the Commission was notified to the representatives and to the State on October 21, 2010. On December 25, 2010, the Justice and Peace Commission, CEJIL, and the Committee of Next of Kin of Victims of the Events of February-March 1989 (hereinafter “COFAVIC”), the organizations representing the alleged victims (hereinafter “the representatives”), submitted their brief with pleadings, motions, and evidence (hereinafter “pleadings and motions brief”) in the terms of Articles 25 and 40 of the Rules of Procedure. The representatives agreed, in general, with the violations alleged by the Inter-American Commission and added the alleged violation of the following articles of the American Convention: (a) 17 (Rights of the Family), to the detriment of all the members of the Barrios family; (b) 8, 13 and 25 (in their alleged dimension of the right to the truth), to the detriment of all the members of the Barrios family and of Venezuelan society; (c) 63(2) in relation to the failure to comply with the measures of protection in situations of extreme gravity and urgency, and (d) 44 owing to the alleged violation of the right to petition, to the detriment of the four alleged victims who were executed and who were beneficiaries of protective measures at the time of their death; all in relation to Article 1(1) of this instrument. In addition, they argued the alleged violation of Articles 6 and 8 of the Inter-American Convention to Prevent and Punish Torture (hereinafter also “the Convention against Torture”), to the detriment of two members of the Barrios family. Lastly, they asked the Court to order the State to adopt different measures of reparation and to pay the procedural costs and expenses, and indicated that the alleged victims wished to accede to the Victims’ Legal Assistance Fund of the Inter-American Court of Human Rights (hereinafter “Legal Assistance Fund”). 5. On March 24, 2011, the State submitted its brief answering the application and with observations on the pleadings and motions brief (hereinafter “answering brief”).6 In this 5 The members of the Barrios family included in the annex to Report on Merits 11/10 are: Justina Barrios; Pablo Julián Solórzano Barrios; Beneraiz De La Rosa; Paul David Solórzano Barrios; Danilo David Solórzano De La Rosa; Eloisa Barrios; Beatriz Adriana Cabrera Barrios; Víctor Daniel Cabrera Barrios; Natali April Cabrera; Vicsady Daniela Cabrera; Luilmari Carolina Guzmán Barrios; Luiseidys Yulianny Guzmán Barrios; Elbira Barrios; Darelbis Carolina Barrios; Oscar José Barrios; Michael José Barrios Espinosa; Dinosca Alexandra Barrios Espinosa; Elvis Sarais Colorado Barrios; Larelvis del Carmen Escobar Colorado; Cirilo Antonio Colorado Barrios; Lorena del Valle Pugliese Barrios; Maritza Barrios; Rigoberto Barrios; Wilmer José Flores Barrios; Génesis Andreina Navarro Barrios; Víctor Tomás Navarro Barrios; Heilin Alejandra Navarro Barrios; Néstor Caudi Barrios; Caudelys Mayerlin Barrios; Benito Antonio Barrios; Dalila Ordalys Ortuño; Jorge Antonio Barrios Ortuño; Jorge José Barrios Rodríguez; Nairelyn Del Valle Barrios Rodríguez; Carlos Alberto Ortuño; Enyarismar Dalila Ortuño Espinosa; Brígida Oneyda Barrios; Marcos Antonio Díaz Barrios; Sandra Marivi Betancourt Barrios; Juner José Betancourt Barrios; Wilker Felipe Pimentel Barrios; Inés Josefina Barrios; Daniela Yotselín Ortiz Barrios; Edison Alexander Ortiz Barrios; Jhojan Ramón Perozo Barrios; Luis Alberto Barrios; Orismar Carolina Alzul García; Ronis David Barrios Alzul; Roniel Alberto Barrios Alzul; Luis Alberto Alzul; Lilia Ysabel Solórzano Barrios; Yorgelis Elisabeth Pérez Solórzano; Javier Enrique Pérez Solórzano; Lilian Gabriela Pérez Solórzano; Luis Gabriel Pérez Solórzano; Narciso Antonio Barrios; Junclis Esmil Rangel Terán; Annarys Alexandra Barrios Rangel; Benito Antonio Barrios Rangel; Luisa del Carmen Barrios; Gustavo Ravelo; Lusiany Nazareth Ravelo Barrios; Juan José Barrios; Orianny Nazareth Pelae and Oriana Nazareth Pelae. 6 In this brief, the State filed a preliminary objection that it referred to as “lack of impartiality” of some of the judges and of the Secretary of the Court. In this regard, the Acting President of the Inter-American Court, Judge Alberto Pérez Pérez, issued an order dated April 14, 2011, in which he decided, inter alia, that the alleged 6

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