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RED VZLA Urgent Request to the OTP-3

REDACTED Page 58 of 190 • Alterations to the "ethnic" composition of populations; • Discriminatory measures, whether administrative or other (banking restrictions, laissez-passer,...); • The scale of the acts of violence perpetrated - in particular, murders and other physical acts of violence, rape, arbitrary imprisonment, deportations and expulsions or the destruction of non-military property, in particular, sacral sites.206 It is submitted that the GoV’s response to the demonstrations since February 2014 clearly amounts to a course of conduct involving the commission of multiple acts directed solely against the civilian population and more specifically those identified as being political dissidents pursuant to a pre-established policy. The available information indicates that this policy was designed at the highest echelons of the state apparatus, including the national security forces, which were colluding with the pro government armed paramilitaries, in order to execute such a plan to attack civilians. The incidents demonstrate an organized effort during and within the context of the demonstrations to identify and target particular individuals perceived as dissidents who would be likely to voice their disagreement or to report about the incidents. Many incidents of a similar nature and following the same pattern of execution by various units of the national security forces and pro government armed paramilitaries coupled with the threats to the perceived dissidents and policies announced by the President himself as well as the involvement of various organs of the state in the implementation of the policy such as the prison services, prosecutors and the judiciary, point to the complex, organized, concerted and coordinated nature of the attacks. The existence of the political objective to prevent, restrict, monitor, punish dissent and cover up the crimes to maintain power, the large scale of the attack across various locations in Venezuela during an extended time frame using significant public resources executing acts of a similar nature and following the same pattern as well as the high number of victims indicates that the attack was both widespread and systematic. The general historical circumstances and the overall political background against which the criminal acts occurred, the general content of the political programme of the PSUV and the inflammatory speeches of its high level members including the President inciting violence and the intensive media propaganda campaign of the state owned media to fuel conflict illustrate the overall objective of the GoV to identify, threaten, persecute, imprison, torture and destroy the civilians perceived as dissidents. 206 ICTY. Prosecutor v. Blaskic. Case No. IT-95-14-T. Judgement. 3 March, 2000. para. 204

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