On 30 October 2014, notwithstanding the Court’s decision, the Argentinian investigating judge issued detention orders against 20 of the accused in order to request their extradition to Argentina. However, these orders were not executed in Spain, the authorities arguing that the Spanish Amnesty law prevails. In 2015, the Judge Servini de Cubría sent a second rogatory commission to the local tribunal of Guadalajara in Spain, requesting the exhumation of the corpse of Timoteo Mendieta, a trade unionist who was reportedly imprisoned in the Guadalajara Central Prison and executed in 1939. It also provided for a DNA test of his daughter, Ascensión Mendieta, victim and plaintiff in the case. On 24 November 2015, the Tribunal of Guadalajara authorized the exhumation, which started on 19 January 2016. The exhumation of 22 bodies from a first mass grave found nearby the Guadalajara prison did not allow identifying the remains of Timoteo Mendieta. In June 2017, Judge Servini de Cubría issued an international arrest warrant against Rodolfo Martín Villa for the death of five workers in Vitoria in 1976. However, it was annulled by the Appeals Chamber as unfounded. In July 2017, Judge Servini de Cubría issued a new arrest warrant against Martín Villa for crimes against humanity and murder. Read more about the case Zoom in Establishing the unconditionality of universal jurisdiction In its judgment, the Federal Supreme Court clarified that the universal jurisdiction principle is not one of subsidiary application, concurrent or limited to connections between the facts and the state that intends to judge it. The Federal Supreme Court also judged that the international qualification of a crime against humanity depends exclusively on the verification that a determined illicit act is committed in the context of a generalized or systematic attack against a civilian population. It found that the crimes could occur not only in the spatial-temporal epicenter through which the attack extends, but also in its margins. On 16 March 2016, Women’s link Worldwide, an international women’s organization based in Spain, filed a complaint calling for the investigation into systematic gender-based crimes committed against women during the Franco regime. In August 2016, Judge Servini de Cubría opened an investigation into the death of Spanish poet Federico García Lorca, pursuant to a complaint filed by the Spanish Association for the Recuperation of Historical Memory (Asociación para la Recuperación de la Memoria Histórica). On 9 June 2017, the remains of Timoteo Mendieta were identified in a mass grave uncovered nearby the Guadalajara prison. The archaeological team of the Association for the Recovery of Historical Memory (ARMH) has exhumed 28 other victims of the Franco regime. 14

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