49 XIV APPLICATION OF ARTICLE 63(1) The Commission’s arguments 114. In its application brief (supra 15), the Commission requested the Court to condemn the State to make integral and appropriate reparations to Manuel Aguirre Roca, Guillermo Rey Terry and Delia Revoredo Marsano, and to this end to “reinstate them in the exercise of their functions” and compensate them for salary and related benefits not received since the date they were dismissed and until their effective reinstatement. It also requested the Court to order Peru to pay for the moral damages and prejudice suffered “in relation to the honor and reputation, life and safety of the [j]ustices.” Furthermore, it requested that the State be condemned to pay the reasonable costs and expenses in which the victims incurred in the different proceedings, in both the domestic sphere and before the inter-American system. 115. In reply to the Court’s request (supra 27), on January 8, 2001, the Commission submitted a brief with its arguments on the expenses and costs in this case and attached the evidentiary documents that, in its opinion, substantiated them. These arguments are summarized below. a. With regard to Delia Revoredo Marsano: i. In order to suppress its “political adversaries”, the Government of Peru had the practice of reviving closed judicial proceedings and manipulating them, and this occurred with two matters concerning Mrs. Revoredo Marsano because of her actions as a Constitutional Court justice relating to the facts of the instant case. Accordingly, and to defend themselves from the “political harassment, through judicial channels” that they were experiencing, she and her husband were obliged to employ lawyers and, later, to abandon Peru, seeking political asylum; and ii. During the asylum, they had expenses that arose from employing people to represent their companies and administer their property in Peru; they employed lawyers in Costa Rica and in the United States to prepare a “political complaint-report”, submitted to the Inter-American Commission in order to file a proceeding for slander in the State of Nevada in the United States; and lastly, they paid for accommodation in Costa Rica and the United States and incurred expenses for air travel to Washington D.C., Nevada and Costa Rica, all of which amounted to US$958,406.62 (nine hundred and fifty-eight thousand four hundred and six United States dollars and sixty-two cents). b. With regard to Manuel Aguirre Roca: i. From April 1997 to November 2000, the period during which he was separated from his functions as a Constitutional Court justice, he incurred expenses for secretarial services and arising from the use of an office where he worked on various domestic proceedings related to the facts of this case and from covering much of the territory of Peru offering talks and presentations, together with Justices Revoredo

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