and that not all the information that they provided was considered or written down. They further contend that the instances detailed in the Respondent State‟s submission does not discharge it from its obligation to investigate human rights violations because the omission is not material enough to constitute a bar, by the victims, to an effective investigation. 105. The Complainants submit further that, the Respondent State placed too AC HP R much reliance on the formal statements that the Victims made to the PPO and failed to have any regard to the context and circumstances within which the statements were made. The Complainants also attempt to clarify the discrepancies mentioned by the Respondent State in their additional submissions on the Merits:24 i. On the discrepancy concerning the Second Victim‟s omission to mention to the PPO that the wife of Mr. El Deeb led the demonstrations against them and that she was sprayed in the face by an Assailant, the Complainants submit that according to the Second Victim, the PPO did not record all the information provided. The Complainants indicate further that, according to the Second Victim, she spent a lot of time waiting for her statement to be taken by the PPO and that when it was finally taken, they did not make any record of evidence that she submitted; including CDs containing pictures and her torn clothes; 24 See generally, the Complainants‟ additional submissions on the Merits, paras 12 to 16, and the affidavits in the Merits submissions of the Complainants of three of the Victims contained in Annexure E: para 21, Second Victim, Abir Al-„Askari‟, paras 19-25, Third Victim, Shaimaa Abou Al-kheir‟s, & Para 17-19, Iman Taha Kamel, Fourth Victim. 29

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