different arguments, including that “Mr. García Lucero [was] one of the prisoners expelled from Chile during the dictatorship under a decree […] adopted by the regime [that] contains […] the names of those who were expelled.” Subsequently, in their final written arguments, they indicated that the State should have “acted” when, “in 1993 and 2004, it had reasonable grounds to believe that Mr. García Lucero had been tortured.” Thus, they argued that, “in December 1993, don Leopoldo sent an official letter to the Program for the Recognition of those Dismissed from their Employment for Political Reasons in Chile, and together with the required documentation, he attached a letter to the authorities describing in detail his torture and political imprisonment,” and that, on November 23 and 28, 2004, respectively, the State was made aware of the petition lodged by Mr. García Lucero before the Inter-American Commission and the report of the Valech Commission was issued, which indicated that he had been a victim of torture and political imprisonment. 111. They added that “Chile is still not acting with due diligence in the investigation of cases of torture, and this has impaired access to justice in the case of Mr. García Lucero.” Thus, they stated, with regard to the “Public Legal Assistance Service,” that “it is not the appropriate entity” and that “the investigation has been opened by an entity that does not have the knowledge, the experience or the resources required to litigate Mr. García Lucero’s case, which is extremely complex.” Furthermore, they argued that, in Chile, there is no “entity with the capability to open and expedite the investigation of cases of survivors of torture during the dictatorship, as there is for cases of disappearance and extrajudicial execution.” They indicated that they have noted: The following specific violations in the context of the criminal investigation […]; (i) the investigating authority lacks the powers to obtain all the information needed for the investigation, particularly to obtain the information gathered by the Valech Commission; (ii) there has been an unjustified delay in the investigation owing to issues of competence; (iii) the investigation has not been conducted with due diligence because only one possible perpetrator of the torture has been identified; (iv) the […] only possible perpetrator identified has not appeared before the courts because [the authorities] do not have [his] correct address; (v) neither the Public Legal Assistance Service nor the judge of the 34th Criminal Court of Santiago have the required experience to conduct these cases. 112. They added that: The absence of a system for conducting an ‘effective investigation that permits those responsible to be identified, prosecuted and punished, when there is a complaint or a wellfounded reason to believe that an act of torture has been committed’ violates the Convention, […] Articles 8(1), 25(1), in relation to Articles 1(1) and 2 thereof, and Articles 6 and 8 of the Inter-American Convention against Torture. 113. They considered that there should be: Other measures, which should be of a legal nature, to allow justice to function diligently; [… t]he entities of justice […] should have specialized units for elucidating cases of torture [and] the victims should have access to legal representatives with knowledge of torture. 114. In addition, in relation to the “complaint filed,” they stated that it: […] does not give an appropriate legal definition of the facts, by referring to them merely as torture, injuries and threats; also, it does not mention any responsible person, and does not relate the facts to any criminal proceedings underway in Chile for human rights violations in the same criminal context; […] cites […] articles 150 A and B of the Criminal Code that were not applicable at the time of the facts, [and] […] uses provisions of military origin to define the illegal acts as constituting unnecessary violence by applying article 330 of the Code of Military Justice. 37