15 h. Statement by Mr. Pablo Balmaceda-Rodríguez, expert witness He prepared a report on the medical and sanitary conditions of the members of the Sawhoyamaxa Indigenous Community during the first quarter of 2003, which was updated during the first half of January 2006, his last visit having taken place on January 7, 2006. The expert witness report is limited to the "Santa Elisa" village of the community, located 376 kilometers down the highway running from Pozo Colorado to Concepción. For the medical study, a group was drawn by lot from the 157 inhabitants of the Community present that day and various laboratory studies were conducted on them, commensurate with the number of members in the test group. Based on these studies, it could be inferred that 22.22% of the inhabitants of this community are anemic, and 16.66% are in the lowest normal values. Moreover, it was also found that 50% of the population examined suffers from parasite infection. Afterwards they made a round of the village, to find that the inhabitants lacked drinking water. The most reliable source of drinking water is the rainwater they gather, but it is very scarce because of inadequate storing facilities. Thus, the small earth dams located inside the fenced lands claimed by the Sawhoyamaxa Indigenous Community for their own are their main source of water, so its members are forced to break into the premises in hiding to get water for their personal use and hygiene. The water is exposed to contact with wild animals and other animals bred on the estate, and it receives the debris flushed by the rain. In November 2002, the members of the Community received a 5,000-liter fiberglass reservoir, which the tank trucks from the Centro Nacional de Emergencia [National Emergency Center] supplied with water drawn from some small earth dam or other, that is to say nondrinking water. In January 2003, they received another high-capacity fiberglass tank. One of the tanks is now broken and the other one is not used because water has not been supplied for several months. The 24 huts comprising the Community are very precarious. They are made from karanda’y, a palm leaf they use to build the walls and roof of these dwellings because it abounds in the area. The dwellings are so precarious that when it rains they get flooded, including the overcrowded rooms. Owing to the characteristics of the soil in Chaco, water is not easily absorbed by the earth, so “all that water gathers without draining.” To this, it should be added that only a few families have managed to build precarious latrines. To relieve nature, they have to cross the fences surrounding the property, and do their business in plain view of the other members of the Community. When it rains, the stagnant water covers the floor of the huts with the excrement that has been spread behind the fencing. It is needless to point out the immense risk this poses for health. In his last visit on January 7, 2006, he could verify the deterioriation of the dwellings compared to previous visits. The room they use as a school is leaning and about to collapse. To determine the probable causes of the deaths that have ocurred in this Community, the next of kin of the deceased persons were interviewed. Seldom are these deaths recorded in any public registry. In many of the cases of the deceased members of the Community did not receive previous medical care, and those who got to the hospital were not assisted, either because their next of kin could not buy the medicines prescribed or because the

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