Mr. Judge:
Osvaldo Barros on behalf of the Association of Former Detainees Disappeared (AEDD), Liliana Lucia Maze empowered Corsiglia Mura, Juan Manuel Miranda, Hector Pedro Pardo José Julián Martínez Haidar, Haidar Marco Enrique Martinez and representing the Legal Defense Foundation Research and Argentina (Fidel), Luciano González Etkin, representing the Legal Action Committee (CAJ) and Laura Villaflor, Enrique Mario Fukman, Maria Celeste Hazan, Andrea Bello, Carlos Lordkipanidse and Lydia Frank, plaintiffs in the case, with the sponsorship of the undersigned counsel, timely home keeping up on Corrientes Avenue 1785 2nd. "C" in the cause 14.217/03, to say VS:
I. - OBJECT
To watch the instructional time to this cause, we come to apply are available on an urgent expansion of the investigations to defendants in the case for the victims and crimes that are listed according to the findings of fact and law set forth below.
II. - BASICS this part
complainant has maintained, since the reopening of the same cases against members of the civil-military dictatorship that the trials of the genocide should be made in a joint framework, given the obvious feature of a massive, planning and interrelatedness of the serious crimes in them are discussed. Also express the legal necessity of trial of heinous crimes against humanity committed in our country during the years 1976/1983 according to a criterion to combine in a single process for all the events in the same clandestine detention center, to obey it the repressive mechanisms of the circuit established by the different state forces.
The principles of judicial economy and impose substantive legal truth, in the same way, adopting these criteria for a thorough and efficient investigation of the terrible events that would otherwise inevitably be lost in the incoherence of many independent events in succession causes and only a few facts at every opportunity.
This temperament is also inevitable in order to avoid repetition of conditions by the witnesses who are forced to appear again and again before the bar of the courts to endlessly relive their suffering, deposited on them the burden of foundation giving to judgments, rather than it fall on the organs of State has not provided basic measures such as the opening of "suppression files."
arguments against commonly held and based on the enormous practice developed in the five years since it was voted to annul the laws of Due Obedience and Punto Final, say that means a real and great delay of justice to continue raising oral stage fragments, more or less large, of this case, it involves almost endless succession of oral trials in which they investigate the same facts with regard to these defendants.
As stated in the file in the School of Naval Mechanics functioned as clandestine detention, torture and extermination, as part of the genocidal plan established in the country. Within this framework, committed thousands of crimes against humanity, that this instruction were dividing and bringing to trial "by parts" in an arbitrary cut of facts and accused.
In order to put an end to this situation, we have performed a thorough analysis of the accused present and the facts against them, why victims and for what crimes are being tried, being necessary to clarify once again that this study was done as far as we can because the victims do not have the relevant files yes account the state in its various branches.
As stated repeatedly, is of interest in the lawsuit that all the repressors acting on the ESMA to be judged by each and every one of those who passed through it (in the corresponding period) and that the probe and the process is timely for all crimes committed against each of the direct victims of the genocide in Argentina.
III .- PROVIDE EVIDENCE
We report the outcome of the investigation conducted by the Association of Former Detainees and Disappeared based on the analysis and cross-linking of information arising from the evidence before the Court of survivors of the School Navy Mechanics and relatives of people seen alive in the concentration camp or killed by the Task Force.
For ease of exposition and requests for, is attached a double-entry table. In the second column thereof lists all the victims who were abducted in the School of Naval Mechanics, according to the evidence before the Court so far and ordered by date of entry into the CCD. The third column shows the number that is assigned to each victim in the fiscal requirements, the blank cells in that column indicates that these people are not mentioned in this request and that no accused for crimes committed against them. In the fourth column indicates the date of entry into the CCD and the fifth, the current status of the victim, according to the following codes: L = Freed, D = Missing, A = killed, DA = Missing and later murdered? = Is unknown destination, NC-D = Baby born in captivity is still missing, NC-R = Baby born in captivity returned, NC-L = Baby born in captivity released, R = Child withheld or hidden and then restored.
In the first row of the columns below show the oppressors so far are processed at some stage of this case or related causes. Each column for each defendant is divided into two, the first (P) refers to the crime of unlawful deprivation of liberty and the second (T), the tormented. In each cell of these two columns indicates whether the repressor is prosecuted or not for the crime committed against the victim for the row where is the cell. If the cell is blank, it is not processed, it contains a character is defined and the section of the case in which it is processed is marked with the following codes:
Cause / Processing Reference
Donda D AT
Testimonials Acts of the Holy Cross Church
Walsh S W 1976 1
Acts Acts 1977/1978 2
Acts 1978 3
hereinafter Cavallo C
Olivera and other O
Real B
If the Court of Appeals ruled without merit the prosecution, the code section is followed by the letter F.
Moreover, the period of performance, and therefore of accountability, each repressor is highlighted with blue background while cells for crimes committed outside that period has gray background.
In short, all cells in the box with blue background and are in no way indicate missing prosecutions. Each points to a crime committed against a victim by the repressor has not been processed when it should be.
ACTION REQUESTED IV .-
so our request is composed of different parts, all essential to get minimal access to justice and equality before the law for hundreds of victims who went through the School of Naval Mechanics. Under this request:
1) The investigation has expanded to all defendants on charges of illegal deprivation of liberty and / or torment, as the case, committed against the victims by those who have already been investigated , according to the attached table. Here the "selection" of crimes carried out by VS becomes downright inexplicable. Where a genocide is charged with torture with respect to a victim but not for unlawful deprivation of liberty an elementary question arises: how was supposed to be in this position of subjection to torture in the ESMA? Or vice versa, it charged for unlawful deprivation of liberty of a particular victim on the ESMA without considering the same conditions of detention (secrecy, lack of food, clothing, etc.) And use of torture.
Therefore, without prejudice to the crimes for which defendants are on trial in order to each fact-that is, some cases for the crime of torture and others, the illegal deprivation of liberty, "this lawsuit considers that every case they had to be called to testify unsworn and processed by both figures, it has been shown finishing forms that characterized the lives of the captives in the clandestine detention center that would work in the field of school Navy Mechanics. Beyond the obvious loss of freedom of movement that involves such a state of detention, detainees involved for the deprivation of any connection to the outside, the suppression of identity and complete waste of time and space references in the midst of conditions of extreme physical and psychological abuse.
2) The investigation has expanded to every one of the repressors listed in the table for unlawful deprivation of liberty and torture of all the victims for which none of them was even investigated, which, as noted, are those in which the column 3 is not entered the case number. Here we should mention that there is a striking position of inequality before the law for the victim and notorious impunity for each of these genocides. So much so that we could make an example of the accused Ricardo Miguel Cavallo is accused in the English State by more than 239 victims in Argentina, a country where the crimes in question.
is, although hard to understand how justice criteria Argentina has made this "selection", we note that there are over a hundred victims for which none of the defendants in the case has been investigated in the five years since this statement.
For each and every one of these people who were our companions in captivity, we request that you immediately available on call to provide sworn statements.
And specifically in relation to the repressor Ricardo Cavallo, provided the urgent extension of investigation and prosecution in Argentina or give effect to the justice of the English State to receive a sentence in that country for those facts which are already charged.
3) Since that in the course of this instruction has been issued for lack of merit crimes in the table are marked with the initials FM, we ask that each of these cases have appropriate means to supplement their investigation and and obtain the evidence needed, and the intervening fiscal transfer to the Court to also suggest the measures necessary to reverse this situation (or failing to report to the parties what measures are being taken in this regard) still should be mentioned that have spent 30 years or more of the events in question and any delay in this connection automatically becomes smooth impunity and level.
4) It investigates all the picture-repressors depending on the period of performance and the date on which the victim was in the ESMA, for the aggravated murder of: Arcuschin, Luis Carlos, Areta, Jorge Ignacio, Awad, Angela; Ballestrino Careaga, Esther; Girondo Bogliolo, Maria Mercedes, Buono, Azucena Victorine, Cervino, Marcelo; Chiappolini, Carlos Alberto, De Gregorio, Oscar Ruben; Dulon Monti, Ana Catalina; Duquet, Leonie, Ferrari, Ariel Adrián ; Jauregui, Monica Edith, Lennie, Maria Cristina; Maggio, Horacio Domingo Mallea, Alberto Alejo, Marín, Francisco Eduardo, Mendez, Jorge; Mendez, Orlando Rene, Perera, Fernando; Ponce de Bianco, Mary Portas, Osvaldo; Roque, John Julius, Stefano, Roberto; Villaflor Devincenti, Azucena; Walsh, Rodolfo; Zavala Rodriguez, Miguel Angel. is proven that all of them, marked with (*) in the table, were kidnapped in the ESMA and were subsequently killed, however, none of the repressors has been prosecuted for that crime.
5) For victims Lestrem Díaz, Guillermo Raúl; Grigera, Gustavo Alberto, Salgado, José María; Reinhold, Marcelo Carlos, Perez, Liliana Carmen Villaflor, Hannibal Raimundo Villar, Julio Jorge; indicated by (* *) in the table is proved that they were all kidnapped in the ESMA and were subsequently killed. But it has only been prosecuted for his aggravated murder a few of those responsible. Accordingly, we ask that you inquire for that offense to all other repressors to their respective performance by period and date on which the victim was in the ESMA.
6) Regarding those killed outside the ESMA by the Task Force: Leaden, Alfredo; Kelly, Alfredo; Duffau, Pedro Barbeito, Salvador and Barletta, Joseph (cases n º s 40-44), July 4 1976; Cacabelos Salcedo, Hope and Salcedo, Edgardo (cases n ° s 50 and 51), the July 12, 1976; The Ganame, Zulema; Adjiman, Jorge; Gacche of Adjiman, Estela; Adjiman, Leonardo and Schjaer, Soledad (cases n ° s y78 73,74,75,77 or 607), on 6 September 1976 and Dios Castro, Ricardo Aníbal and Krauthmer, Mariano Hector (n º s 135 cases y136), the November 15, 1976, some repressors were processed, however, the Court of Appeals ruled without merit for such crimes. We request that each of these cases have appropriate means to complement the investigation of them and so obtain the evidence needed, and the intervening fiscal transfer to the Court to also suggest the measures it considers necessary to reverse this situation (Or failing to report to the parties what measures are being taken in this regard).
It is proved that Lieutenant Junior Jorge Alberto Devoto was kidnapped on March 21, 1977 Liberty Building, headquarters of the Commander in Chief of the Navy, and then thrown into the sea.
Similarly, the evidence before the Court show that John Alexander Barry and his wife Susana Mata were killed by the Task Force of the ESMA in the Oriental Republic of Uruguay on 1 December 1977.
also the record indicates that during 1978 were killed by the Task Force of the ESMA: Miguel Francisco Villarreal (case number 454) in July, Fernando Menendez (case number 502 or 513) in late November, Daniel Vázquez (case number 500) and Elena Holmberg Lanusse (case number 514) in December.
However, there are only prosecuted for the murders of Menéndez and Holmberg and only five in each case no one has been charged with the murder of Barry, Mata, Devoto, Villarreal and Vazquez. We ask for the investigation of those crimes of all repressors identified in the table to their respective performance by period and date of occurrence of each event.
7) has also not been taken into account in the investigations of crimes committed against Wanda Joseph Fragale of Antigua, Adriana Gatti and Carlos Slepoy, all kidnapped, illegally detained in ESMA during March 1976-in the days before the coup, and later released. We ask that you inquire for the crimes committed against these victims at all repressors identified in the table to put according to their performance period.
8) We ask that free trade to the Secretariat of National Human Rights to provide all information that they already have to prove that the following persons were kidnapped in the School of Naval Mechanics: Aravena, Roberto (file No. 1680); Badillo, Jorge Luis (file n ° 3655), Baroque, Graciela Mabel (file No. 6256); Benítez, José Ramón (file No. 986); Berti, Carlos Guillermo (file n ° 4022), Bettini, Antonio Bautista (file n ° 6425), Boitano, Miguel Angel (file n ° 8210), Caballero Eduardo Luis (Chair) (file n ° 3641), Caballero, Wenceslao Eduardo (file n º 73 ) Cañueto de Zavala Rodríguez, Olga (file n ° 6890), Colombo, Alvaro (Tanito) (file no 3458); Cuello del Rio, Margarita (file n ° 1013), of Ponce, Blanca (page 26 Annex II Never Again Number of actor 10603), Del Rio, Carlos Alberto (file n ° 1012), Di Rosa, Claudio (Paul) (file no 3614); Esplugas, Enrique Lorenzo (Rodi) (file No. 530); Fantino, Raul Bernardo (file No. 4258); Faraoni, Patricia (file n ° 5304), Fernández Oscar Alejandro (file No. 544); Gamonet, Roberto (file No. 410), Garcia Vazquez, Juan Carlos (file n ° 2138), García, Juan Carlos (p. 71 Appendix II Never Again, no actor 10199) Gonzalez, Martin (p. 76 Annex II Never Again, no actor 10246); Gualdoni, Juan Carlos (file No. 3618); Lertora, Roberto Fernando (Moni) (file no 5731) ; Lopez Stenfer, Maria Cristina (Drink) (file No. 113), Lugones Aguero, Mercedes (file No. 883); Puiggros, Sergio (Federico) (file No. 658) and Rivera, Ernesto (File N ° 923 or 587). Identical
order made in respect of the Argentine Forensic Anthropology Team about the following: Braguinsky, Liliana Beatriz (Lucia); Calero, Cristina; Casanova, Norberto; Coronel, Roberto Joaquín (Jack); Eiras, Maria Luisa; Guerci, Eduardo ; Jasminoy, Joseph (North Juanita) and Lenzi (Diver).
and where to verify this assumption, investigates crimes committed against these victims to all the repressors identified in the table to their respective performance by period and date of occurrence of each event.
9) also taking into account the records of the proceedings, the many testimonials they have given the victims, we ask also have expanded the investigations to each of the repressors accused in the table attached for the crimes they have never been charged despite emerging from the account given in the statements of fact before the Court.
These offenses are:
a) Tormentos babies born in captivity.
The attached table identifies 15 children born during the captivity of their mothers who were later released or proper identity and recovered many years later. These people were also subjected to torture by applying electric shocks, beatings, physical abuse and in general all kind of "duress" not only on the body of their mothers, but specifically about themselves in the period in which they were illegally deprived of freedom and are entitled to "have his case impartially examined by competent authorities of the state", in the terms of Articles 8 and 9 of the Declaration on the Protection of All Persons from Torture and Other Cruel, Inhuman or Degrading 12 º to the Convention against Torture and Other Cruel, Inhuman or Degrading and 12 American Convention to Prevent and Punish Torture.
The very undignified living conditions suffered by mothers and by them during the period of illegal deprivation of liberty, also involved the nature of torture and integrate, where appropriate, the subject of this request. Clearly, in this sense that the environment in which to spend their mothers had been pregnant, give birth and nurse affects and significantly disrupts both the psyche and the physical development of children involved.
In order to clarify these psychosomatic effects, documents and reports accompany the Freedom Chair of Health and Human Rights, Faculty of Medicine, University of Buenos Aires and specialized technical personnel in the field. It
investigate this offense to all those identified in the attached table have been played in the CCD during the period he was born a child who has been released to his mother, returned to his family, or has subsequently recovered his identity (which is indicated in column 5 with the code NC-NC-L or R), repeated in as many opportunities as cases have occurred in that period.
b) child abduction or concealment.
is proven in the School of Naval Mechanics ran a clandestine maternity where women gave birth in conditions of detention were missing in the same CCD as well as they moved to this effect from other circuits captive repressive for example in the area west of Buenos Aires or Mar del Plata.
It should be noted that the appropriation of babies and concealment of identity is a feature of the systematic extermination developed in Argentina and that this feature is repeated in the various genocides that have taken place in the world, hence the Convention to the Convention on the Prevention and Punishment of the Crime of Genocide includes the practice as constitutive of the crime of genocide.
The systematic planning and child abduction and full consciousness of what it was that plan as part of the genocide that was unfolding in the country is shown the fact that the plan of silence and concealment of these young people spread and continues to this day.
is why in each case referred to should include checks for crimes listed in art. CP 146, 139 inc 2 and related provisions of the Criminal Code and Art. 2 of the Convention on the Prevention and Punishment of the Crime of Genocide.
investigate this crime is for all defendants identified in the attached table have been played in the CCD during the period he was born or a child was kidnapped (which is given in the fifth column with the code NC-R or R ) reiterated on many opportunities as children were born or have been abducted in that period.
c) Attempt to abortion. The torments suffered by pregnant women spread their effects into margins even more cruel and complex. Indeed, in addition to the torture of the mother and torture in the person of your child by direct and indirect effects of such floggings, should be removed because reasonably-that did not escape the author's musings (mediate or direct) that such torments might imply, and in fact, an attempt involving abortion.
This offense is punishable in the text of Article 85 paragraph 1 of the CP, by providing that: "Whoever causes an abortion shall be punished: 1 with imprisonment or imprisonment of 3 to 10 years if they act without her consent. This penalty may be increased to 15 years if the act is followed by the death of the woman; ".
In this sense, is not immune to the most elementary observation that those who practice torture (or whoever is responsible for the commission as organized mechanism of a general strategy of extermination) on a woman during pregnancy, consent explicitly the probability of producing some an abortion on the unborn child. There is no point, ultimately, a possible argument that seeks to rely on lack of intent to kill, since the possibility of death occurring in the unborn becomes predictable. Anyone that performs an action of torture on a pregnant woman can not help but represent the real risk of abortion there is a direct consequence of the aim pursued (torture of the mother).
Moreover, already referred to inhumane conditions of detention (established themselves as machinery of torture) imply, each day, a degrading punishment on the person of the mother and the personality of those who today are victims of these tortures suffered when they were in gestation.
investigate this crime is for all those identified in the attached table have been played in the CCD during the period in which a woman has been kidnapped pregnant (as which is indicated in column 2 opposite the name), repeated in as many opportunities as pregnant women have been abducted in that period.
d) Submission to slave labor.
During the kidnapping in inhumane conditions of detention, some prisoners were forced to perform tasks in conditions of slavery. Such conduct by which we conduct constitutes criminal accusation of crime reduction to servitude established in the art. CP 140. It should be noted that because 13 were convicted of the crime and the Admirals Lambruschini Massera.
investigate this crime is for all the repressors identified in the attached table that played in the CCD during the period who were abducted in the following: Actis Goretta, Nilda Naomi Acuna, Gustavo Pablo; Barreiro, Roberto; Barros, Osvaldo Arturo; Basterra, Victor Melchor, Bello, Marcela Andrea; Burgos, Norma Susana; Calveiro Campiglia, Pilar Castillo Andres Ramon, Clemnte, Adriana; Coquet, Ricardo Hector Cozzi, Norma Cristina, Cubas, Lisandro Raul, Daleo, Graciela Beatriz; Dri, Jaime Feliciano, Firpo, Alejandro; Fukman, Mario Enrique; Firpo Garcia Alonso, Blanca García , Carlos Alberto; Gardella of Carnelutti, Liliana Naomi, Gasparini, Juan Alberto; Gladstein, Lazaro Jaime; Gras, Martin Thomas, Jara de Cabezas, Thelma Dorothy; Larralde, Maria Amalia; Lecumberry, Osmar Alberto; Leiracha de Barros, Susana Beatriz; Lewin, Myriam; Lordkipanidse, Charles Gregory; Malharro of Muñoz, Ana Maria, Marcus, Ruth Adriana; Martí, Ana Maria; Mili from Pirlo, Mary Alice; Minho, José Orlando; Muñoz, Carlos; Orazio, Nilda Haydee; Oviedo, Daniel Oscar; Paredes, Maria Rosa; Pastoriza, Lila Victoria, Pellegrino, Liliana Marcela; Piccini, Héctor Eduardo; Quiroga, Rosario Evangeline; Ramirez, Roberto; Solarz of Osatinsky, Sara; Strazzeri, Angel; Testa, Ana Isabel; Tokar Di Tirri, Beatriz Elisa; Vieyra, Lydia and Cristina Villani, Mario Cesar; reiterated on many occasions as mentioned have been kidnapped victims in that period.
e) Genocide.
Points made not only allow us to state the nature of crimes against humanity for crimes committed by state terrorism, but that lead us to the irrefutable conclusion that in our country's military dictatorship committed genocide.
Indeed, the Convention on the Prevention and Punishment of the Crime of Genocide states that "genocide means any of the following acts committed with intent to destroy, in whole or in part, a national, ethnical, racial or religious group as such:
a) Killing members of the group;
b) Causing serious bodily or mental harm to members of the group;
c) Deliberately inflicting on the group conditions of life calculated to bring about its physical destruction in whole or in part;
d ) imposing measures intended to prevent births within the group;
e) Forcibly transferring children of the group to another group. "
As we stated earlier, the systematic plan of forced disappearance of persons deployed by the military dictatorship headed against a segment of the population, against a particular national group, as defined by the state as "subversion" or "subversive."
In this regard, it is essential at this point to recall the arguments made at the ruling handed down on September 19, 2006, for the Oral Court No. 1 of La Plata, in the case No. 2251/06 "Etchecolatz, Miguel Osvaldo s / illegal deprivation freedom, use of torture and homicide. "
It recognized the importance of "letting raised ethical and legal need to recognize that in Argentina there was a genocide."
At the request expressed by us, the Court embodies the historical and legal concept of genocide. In this regard said
"I understand that this demand is only partially satisfied with the sentence to which the Court reached unanimously considered once the facts reproached the accused. Were taken into account for this based on those criminal types who were investigated, prosecuted, convicted and eventually required Etchecolatz. Such reasoning is ultimately one that fits more easily with the principle of consistency without compromising the legal structure of the fault .... "
words, in their own fault, and lays the foundation for the proposition that through this letter we introduce: the need to investigate the genocide in advance about the purpose and intent to destroy in whole or in part, a "national group" as a not violate the procedural principle of congruence future trial to be substantiated.
then continued the Court:
"... imposes an affirmative answer, there is no impediment to the categorization of genocide for the events in our country in the period in question, beyond the legal definition in this case has been given those facts for the purpose of imposing the conviction and sentence. "
"... In Argentina the military junta imposed in March 1976 with the coup, a regime of terror based on the calculated and systematic removal from the State over several years, and disguised under the name of war against subversion, of thousands of people (in the Cause and the disappearance accredited consist of more than ten thousand) in a violent manner. The purpose of this action is to achieve systematic introduction of a new order in Germany as Hitler claimed that did not fit in certain classes of people those that did not fit the established cliché of nationality, Western and Western Christian morality (...) Based This approach was developed around a plan for "culling" or sectors of the population members of the Argentine people, so it can be argued that the selection was not as much as real people, because they disappeared or killed thousands of them without any sense political or ideological, as its integration into specific groups, sectors or groups of Argentina, (National Party) who in his inconceivable criminal dynamics, considered contrary to the process. Indeed, selection for the physical elimination by segments of the population is distributed as follows, according to data collected in the CONADEP report (National Commission on missing persons: Never Again): 30.2% Student Workers 21 % Employees 17.9% 5.7% Self-Teachers and other professionals 5% 10.7% 3.8% Housewives Journalists and Artists Actors 1.6% 1.3% 0.3% Personal Religious Forces subordinate Security 2.5%. The objective of this selection, arbitrary as to individuals, was perfectly calculated if it is related to what was the purpose of so-called "National Reorganization Process" based on the disappearance was "necessarily" determined "amount" of people located in those areas that may hamper the ideal configuration of the new nation Argentina were "enemies of the soul Argentina", thus called the General Luciano Benjamin Menendez, accused in this Cause, which, by altering the balance should be eliminated. "
"As to whether what happened in our country should be framed within the concept of" national group " according to the wording that was finally the art. II of the Convention, and anticipated a positive response which otherwise appears obvious error in drafting the informed today (...) is instructive as reflected by the cited author on the subject (referred to sociologist Daniel Feierstein). " .. characterization of 'national group' is perfectly valid to discuss the events in Argentina, since the perpetrators are out to destroy a particular section of social relations in a state to produce a change substantial enough to alter the life of the whole. Given the inclusion of the term `in whole or in part 'on definition of the 1948 Convention, it is clear that the Argentine national team has been destroyed 'in part' and part substantial enough to alter the social relations within the nation itself (...) The annihilation in Argentina is not is spontaneous, not coincidentally, is not irrational: it is the systematic destruction of a 'substantial part' of the Argentine national team, aiming to transform itself, to redefine their way of life, social relationships, destiny, your future ".
After making progress in this argument, the Court concluded:
"said everything appears indisputable that we are not as anticipated before a mere succession of crimes, but to something significantly higher than corresponding term `genocide '."
Indeed, it has understood the judge Jorge Parache of the province of Tucumán, as correctly stated: "That going to solve the question, understand this sentencing, in the sense that Mr. Attorney, who assists reason to the Complaint by stating that the conduct displayed by the security forces against hundreds of people held in our country in the period between 1976 and 1983, falls within the international crime of genocide, understood as " denial of the right of existence of entire human groups ...". "... It made to expand the complaint for the offense to the people involved in this case as well as those related causes, debiéndose proceed with the enlargement of the investigations as it considered."
Undoubtedly we are dealing with constituent acts of genocide carried out with intent to destroy, in whole or in part, a national group, ie in the presence of killing members of that group defined as "subversion", causing serious physical and mental integrity of members of the same, inflicting on the group conditions of life calculated to bring about its physical destruction in whole or in part, transfer by force children of the group to another group.
understand is why so-and-ask the repressors identified in the attached table should be referred to expansion of inquiry in relation to criminal responsibility, as appropriate, for the crime of unlawful deprivation of liberty, torture, subjection to slave labor, attempted murder, manslaughter, attempted abortion and juvenile detention and concealment, all constituting crimes against humanity and also the crime of genocide.
10) In a general way, in both reaches each of the particular requests made, we ask that each of the defendants timely they are prosecuted in their quality of co-authors criminally responsible for each of the crimes charged and described, being sufficiently demonstrated that there was a criminal division of the work under a common plan.
V. PRISON POLICY AND EFFECTIVE
the foregoing as to the nature of the crimes against humanity addressed here, we believe that all the repressors listed in SCHEDULE should be detained in a common jail without any privileges, especially when those conditions privilege were those that led to the murder of Héctor Febres.
collides against the most elementary sense of justice that the detention Institute home or other benefits, can be applied to those who are criminally responsible for crimes against humanity, with the seriousness that implies genocide as maximum grade of such crimes. Precisely these crimes are the ones that are inalienable for the State to continue his pursuit beyond the years. The arrest actually ends up being a way to violate this rule of applicability, the highest rank in the national legal framework, it allows the greatest criminals of the country's history are in their luxurious homes peacefully and raping many of them own prison come home as reflecting two separate media (VS issue that can not be ignored) or leading to today there are more than 50 fugitives in these cases.
VI. REQUEST
For all request:
is urgently have the means applied;
VS Provide
under which JUSTICE WILL
