-3- members of the Army and paramilitary groups under the so-called “coup de grâce plan.” Furthermore, the Commission affirmed that this execution revealed the situation faced by the members of the UP, the acts of harassment and persecution, and the attempts on their life, as well as the impunity of these acts. In addition, it alleged that the execution of Senator Cepeda “was a conspicuous example of the pattern of violence against UP activists, given his role as the last publicly elected representative” of that party, and constituted a crime against humanity. 3. The Commission asked the Court to declare the State responsible for the violation of the rights to life, personal integrity, judicial guarantees, protection of honor and dignity, freedom of thought and expression, freedom of association, political rights, and judicial protection recognized respectively in Articles 4, 5, 8, 11, 13, 16, 23 and 25 of the American Convention, in relation to Article 1(1) thereof, to the detriment of Manuel Cepeda Vargas. In addition, the Commission alleged that the State was responsible for the violation of the rights to personal integrity, judicial guarantees and judicial protection, established in Articles 5, 11, 8 and 25 of the Convention, to the detriment of the following next of kin of the presumed victim: Iván Cepeda Castro (son), María Cepeda Castro (daughter), Olga Navia Soto (common-law wife, deceased), Claudia Girón Ortiz (daughter-in-law), María Estella Cepeda Vargas, Ruth Cepeda Vargas, Gloria María Cepeda Vargas, Álvaro Cepeda Vargas and Cecilia Cepeda Vargas (deceased) (siblings); and of the right to freedom of movement and residence, recognized in Article 22 of the Convention, in relation to Article 1(1) thereof, to the detriment of Iván Cepeda Castro (son) and María Cepeda Castro (daughter), and their “direct families.” The Commission asked the Court to order the State to take specific measures of reparation. 4. On April 4, 2009, Iván Cepeda Castro and Claudia Girón Ortiz, of the “Manuel Cepeda Vargas” Foundation; Rafael Barrios Mendivil, Alirio Uribe Muñoz, Jomary Ortegón Osorio and Ximena González of the Corporación Colectivo de Abogados “José Alvear Restrepo”, and Viviana Krsticevic, Ariela Peralta, Francisco Quintana and Michael Camilleri of the Center for Justice and International Law (CEJIL), organizations representing the presumed victims (hereinafter “the representatives), submitted a brief with pleadings, motions and evidence to the Court in accordance with Article 24 of the Rules of Procedure. In this brief, they alluded to the facts indicated in the Commission’s application and emphasized, in relation to the context in which they occurred, “the extent of the Colombian State’s responsibility for the murder of the last elected senator of the Patriotic Union, by underscoring the importance of analyzing the pattern of systematic executions under which this one was perpetrated; the scope of the violations of the rights established in the American Convention […], and the effects of these violations on the political party that he led, on the electorate that he represented, and on the communications medium to which he belonged.” The representatives alleged the violation of the same rights as the Commission, presenting their own analysis, and also asked that the State be declared responsible for the violation of Article 44 of the American Convention, because Senator Cepeda was the beneficiary of precautionary measures at the time of his execution, which interrupted “his right to petition” the inter-American system. They also alleged the violation of Article 2 of the Convention, because they considered that the legal framework of the demobilization law for members of paramilitary groups would promote impunity in the instant case. Lastly, the representatives requested various measures of reparation. 5. On July 4, 2009, the State submitted its brief in answer to the application, with observations on the brief with pleadings, motions and evidence, and filed four preliminary objections (infra Chapter III). Furthermore, the State submitted a partial