(b) If, for well-founded reasons, reinstatement is not possible, the State shall pay reasonable compensation to the victims or, if applicable, their heirs, taking into account the non-pecuniary harm caused. 2. Pay the victims the salaries, pensions, employment and/or social benefits they failed to receive from the time of their termination up to the date on which their terms would have ended. 3. Publicly acknowledge, with adequate publicity, the violations declared in the present case, in particular, the infringement on the independence of the Judiciary. 4. Adopt measures of non-repetition that ensure the independence of the Judiciary, including the measures necessary so that domestic law and applicable practice abide by clear criteria and ensure guarantees for the appointment, tenure, and removal of judges, in particular, a long enough term in judicial office to ensure their independence and determination of the grounds for impeachment, in accordance with the standards established in the American Convention. d) Notification to the State. The Merits Report was notified to the State on July 28, 2011, granting it two months to provide information on compliance with the recommendations. The Commission accorded the State two extensions of this time limit to comply with the recommendations. e) Submission to the Court. On November 28, 2011, as a result of “the need to obtain justice for the victims, owing to the failure of the State to comply with the recommendations, [and also] of the matters of inter-American public interest that the case represents,” the Commission submitted the case to the Court. The Commission appointed Luz Patricia Mejía, Commissioner at the time, and Santiago A. Cantón, then Executive Secretary of the Commission, as its delegates before the Court, and Elizabeth Abi-Mershed, Deputy Executive Secretary, and Tatiana Gos, lawyer of the Commission’s Executive Secretariat, as its legal advisers. II PROCEEDINGS BEFORE THE COURT 3. Notification to the State and to the representatives. The submission of the case by the Commission was notified to the State and to the representatives on December 19, 2011. 4. Brief with pleadings, motions and evidence. On February 25, 2012, Ramiro Ávila Santamaría and David Cordero Heredia (hereinafter “the representatives”) presented their brief with pleadings, motions and evidence (hereinafter “pleadings and motions brief”) to the Court. The representatives agreed substantially with the Commission’s allegations and asked the Court to declare the international responsibility of the State for the violation of the same articles alleged by the Commission; they also asked that the Court declare the violation of Articles 23 (Right to Participate in Government) and 24 (Right to Equal Protection) of the Convention, in relation to the eight presumed victims. 5. Answering brief. On June 18, 2012, the State submitted to the Court its brief with preliminary objections, an analysis of the recommendations made by the Inter-American Commission, its answer to the submission of the case, and its observations on the brief with pleadings, motions and evidence (hereinafter “answering brief”). In addition, the State appointed Erick Roberts Garcés as its Agent, and Alonso Fonseca and Carlos Espín as Deputy Agents. 6. Observations on the preliminary objections. On August 20 and 30, 2012, the representatives of the presumed victims, and the Commission, respectively, presented their observations on the preliminary objections filed by the State. 5