104 representative requested: (i) for loss of or detriment to the earnings of I.V. over the last 15 years of emotional instability and her personal commitment to obtain justice, which resulted in her being unemployed for most of the time and made it impossible for her to obtain permanent, stable, reliable and well-paid employment and to promote her life project, the sum of 308,772 bolivianos, equivalent to US$44,363, and (ii) for health care expenses incurred by I.V., the sum of US$4,500.410 To this end, she asked that the Court take into account as a minimum parameter for “some of the health care expenses” incurred by I.V., the sum of US$1,088, calculated based on certifications from several health care centers, pharmacy invoices, and medical fees, and (iii) for the expenses incurred in the search to obtain justice before diverse administrative entities of the State, the sum of US$862. In conclusion, with regard to the pecuniary damage caused to the victim and established under the three headings described above, the representative requested the sum of US$49,725. However, she also asked that “[i]f the Court […] did not agree with the calculation of the pecuniary damage requested, […] it make a calculation based on the principle of equity, taking into account the amounts mentioned and the parameters suggested.” 351. The representative requested the sum of US$400,000 for all the non-pecuniary damage caused to I.V. and her two daughters, specifying US$300,000 for I.V. and a total of US$100,000 for the two daughters. The representative indicated that, in addition to the psychological harm that the victim experienced owing to the sterilization and judicial discrimination, she had to support and confront social, psycho-social and family consequences as a result of the facts. Among these, the representative underscored: (i) the disintegration of the relationship with her partner; (ii) the abandonment of the care of her daughters owing to the need to advance the judicial proceedings at the national and international levels; (iii) the alteration of her life project because she had to devote her time to the judicial proceedings and psychological therapy, which meant that she was unable to obtain stable, reliable and permanent employment; (iv) the fact that she had to cope with the attempted suicide of her daughter N.V., who was overwhelmed by the circumstances arising from her mother’s situation, and (v) the re-victimization, discrimination and stigmatization over the last 15 years because she had claimed her rights and would not remain silent and passive regarding all that happened. Also, the representative asked that “[i]f the Inter-American Court did not agree with the calculation of the non-pecuniary damage requested, […] it make a calculation based on the principle of equity, taking into account the amounts mentioned.” 352. The State argued, with regard to the pecuniary damage, that the petition indicates that I.V. decided to stop working to devote herself to her family, so it could not be claimed that the State was responsible for the results of that choice. It also argued that it was not coherent to allege that with two diplomas, one in hotel administration and the other in law, “she could only obtain ‘casual work’ that ‘did not last long’ owing to her health complications that, as the State has proved, cannot be attributed to facts that took place in Bolivia, or because she had to devote her time to following up on the criminal proceedings, in the understanding that she had a lawyer and, under no circumstances, had to spend all her time on this.” 353. The State argued that “the sum requested by the representative (US$300,000) as reparation for presumed non-pecuniary harm caused to I.V. is inadmissible, because the bilateral tubal ligation procedure was performed with her consent.” The State argued that it was not responsible for repairing the non-pecuniary harm suffered by I.V., because it was not caused either by its officials, or by indirect actions carried out to the detriment of I.V., so that the ailments and supposed aftereffects that she has at present cannot and should not be attributed to the State. In its final written arguments, the Regarding the health care expenses, the representative presented a report on the minimum expenses incurred by I.V., which indicated that, despite attempts to recover the information lost during the incident, it was not possible to recover all the information required to determine the specific items of expenditure. She therefore asked that the Court consider the other medical services justified in annexes 11, 13, 14 to the Merits Report, the expense report presented, the parameters for medical fees in the department of La Paz, and the expenditure that it had not been possible to justify. 410

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