On behalf of the Respondent State, In the Brief in Reply: “71, Based on the reasons mentioned above, the State of Burkina Faso respectfully prays the Court to: - Rule that the Applicants have not produced or have produced insufficient, documents to justify their status and identity; and have thus not established proof of their close or filial relation to the direct victims who are late Norbert Zongo, Ernest Yembi Zongo, Blaise Ilboudo and Abdoulaye Nikiéma alias Ablassé; Thus, decide that they do not have the status of indirect victims and cannot claim any reparation whatsoever; -Dismiss the request of the Burkinabé Human and Peoples’ Rights Movement (MBDHP) for the payment of the sum of 45,734,705 CFA F, as groundless; -In the alternative, uphold the payment of a symbolic 1 Franc as reparation for moral prejudice; -State that the fees of the Applicants’ consequently throw them out; lawyers are not specific or general damages and Alternatively, -State that the amounts requested as lawyers’ fees are exorbitant and reduce the said amount to a total of 20,000,000 CFA F, which breaks down to 5,000,000 CFA F each per family of the indirect victims; -Lastly, regarding transport and sojourn costs victims and their Counsel at 6,542,500 CFAF, wise appraisal of the Court”. in Arusha, Tanzania, estimated by the indirect the State of Burkina Faso leaves it to the very 18. It is apparent, on the whole, that the Applicants are claiming damages for the prejudice they suffered; reimbursement of the costs and expenses they incurred; and at the same time, asking for measures of satisfaction and guarantees of non-repetition. The Court will now consider these main prayers one after the other. 8 ws. Q Ao 2