CAS 2021/A/7854 WADA v.

ONAD and Ms Patricia Carolina Caballero de Zubizarreta

APPEAL BRIEF

to the Court of Arbitration for Sport

Avenue de Beaumont 2, 1012 Lausanne, Switzerland

World Anti-Doping Agency, Stock Exchange Tower, 800 Victoria Square, Suite 1700, P.O. Box
120, Montreal, Quebec, H4Z 1B7, Canada
represented by Messrs Ross Wenzel and Anton Sotir, attorneys-at-law at Kellerhals Carrard
(“Appellant” or “WADA”)

versus

Organización Nacional Antidopaje Paraguay (ONAD), Avda. Eusebio Ayala km 4 ½ y R.I. 6

Boquerón, Asunción, Paraguay
represented by Mr Gerardo Luis Acosta Pérez, attorney-at-law at P&A – Grupo Consultor
(“First Respondent” or “ONAD”)

and

Ms Patricia Carolina Caballero de Zubizarreta, Centurión Miranda 360, Asunción, Paraguay

(“Second Respondent” or the “Athlete”)

in respect of the decision rendered by the Disciplinary Committee of the ONAD on

15 February 2021 in the matter of Patricia Carolina Caballero de Zubizarreta
(the “Appealed Decision”) (Exhibit 1)

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Table of contents
I. Facts ...................................................................................................................... 3
II. Procedural issues ..................................................................................................... 3
Applicable rules ................................................................................................. 3
Time limit to file the Appeal Brief ......................................................................... 4
III. Substantive submissions ........................................................................................... 4
Anti-Doping Rule Violation................................................................................... 4
Determining the sanction .................................................................................... 4
B.1. Intentional violation ....................................................................................... 4
B.2. Establishment of the origin.............................................................................. 6
(i) The Athlete’s explanation ....................................................................... 6
(ii) Applicable jurisprudence ......................................................................... 6
(iii) Position of WADA ................................................................................... 7
B.3. Disqualification of Results ............................................................................... 9
IV. Witness evidence ..................................................................................................... 9
V. Requests for relief .................................................................................................. 10

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I. Facts

1. Ms Patricia Carolina Caballero de Zubizarreta, a Paraguayan national, is a beach volleyball

player.

2. On 5 February 2020, the Athlete underwent an out-of-competition doping control (Exhibit

5).

3. The analysis of the A sample revealed the presence of the following substances of exogenous
origin (Exhibits 6 and 7):

androsterone;

testosterone and its metabolites;

etiocholanone; and

5αAdiol and 5βAdiol.

4. All of the above substances are anabolic androgenic steroids prohibited at all times under
S1.1 (Anabolic Androgenic Steroids (AAS)) of the 2020 Prohibited List (Exhibit 8).

5. The analysis of the B sample confirmed the exogenous origin of the substances (Exhibits 9
and 10).

6. On 24 July 2020, ONAD notified the Athlete of the positive finding and provisionally
suspended her (Exhibits 11 and 12).

7. On 15 February 2021, the Disciplinary Committee of the ONAD rendered a decision, whereby
the Athlete was found to have No Fault or Negligence, such that no period of ineligibility was
imposed (Exhibit 1).

8. Following a case file request on 4 March 2021 in respect of the Appealed Decision (Exhibit
2), WADA received the complete case file from the ONAD on 18 March 2021 (Exhibit 3).

9. WADA filed a Statement of Appeal against the Appealed Decision on 8 April 2021.

10. The Athlete has already been sanctioned by the Fédération Internationale de Volleyball
(FIVB) with a two-year period of ineligibility with respect to a sample provided in-competition
on 2 July 2013 that tested positive for a non-specified stimulant (cocaine). 1

II. Procedural issues

Applicable rules

11. The Appealed Decision was made in application of the ONAD Anti-Doping Rules (“ONAD
ADR”) (Exhibit 4).

12. The ONAD ADR are therefore applicable to the present appeal.

1
For details, please see the award in CAS 2013/A/3431 Patricia Carolina Caballero v. Fédération Internationale de
Volleyball (FIVB) (Exhibit 13).

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Time limit to file the Appeal Brief

13. On 13 April 2021, WADA requested an extension of its time limit to file the appeal brief until
10 May 2021. This extension was granted by the CAS on 16 April 2021.

14. This Appeal Brief is therefore filed within the relevant time limit.

III. Substantive submissions

Anti-Doping Rule Violation

15. Pursuant to art. 2.1 ONAD ADR, it is each athlete’s personal duty to ensure that no Prohibited
Substance enters his or her body. Athletes are responsible for any Prohibited Substance or
its Metabolites or Markers found to be present in their Sample. The presence of a Prohibited
Substance or its Metabolites or Markers constitutes an anti-doping rule violation (“ADRV”).

16. The Athlete underwent an Out-of-Competition doping control on 5 February 2020. The
analysis of the sample revealed the presence of androsterone, testosterone and its
metabolites, etiocholanone, 5αAdiol and 5βAdiol, all of exogenous origin (Exhibits 6 and 7).

17. All of the above substances are anabolic androgenic steroids prohibited at all times under
S1.1 (Anabolic Androgenic Steroids (AAS)) of the 2020 Prohibited List (Exhibit 8).

18. Indeed, the Athlete does not challenge the fact of the anti-doping rule violation, which was
confirmed by the Appealed Decision (Exhibit 1).

19. In light of the above, the Athlete has committed an anti-doping rule violation under art. 2.1
ONAD ADR.

Determining the sanction

B.1. Intentional violation

20. According to art. 10.2.1.1 ONAD ADR, the period of ineligibility shall be four years where the
ADRV does not involve a specified substance, unless the athlete can establish that the ADRV
was not intentional.

21. Furthermore, art. 10.9.1.1 ONAD ADR establishes that for an athlete’s second anti-doping
rule violation, the period of ineligibility shall be the greater of twice the period of ineligibility
otherwise applicable to the second anti-doping rule violation treated as if it were a first
violation, in casu eight (8) years.

22. Art. 10.2.3 ONAD ADR sets out that the term intentional “requires that the Athlete or other
Person engaged in conduct which he or she knew constituted an anti-doping rule violation
or knew that there was a significant risk that the conduct might constitute or result in an
anti-doping rule violation and manifestly disregarded that risk.”

23. As the athlete bears the burden of establishing that the violation was not intentional (within
the above meaning), a whole series of CAS cases have held that it follows that he/she must
necessarily establish how the substance entered his/her body (see, for example, (i) CAS
2017/A/5248 WADA v. Africa Zone V RADO & ADAK & Eliud Musumba Ayiro, para. 55; (ii)
CAS 2017/A/5295 WADA v. ADAK & Athletics Kenya & Sally Chelagat Kipyego, para. 105;
(iii) CAS 2017/A/5335 WADA v. Mohammad Yaseen Alhasan, para. 137; (iv) CAS

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2017/A/5392 FINA v. Georgia Anti-Doping Agency & Eastern Europe RADO & Irakli
Bolkvadze, para. 63; and (v) CAS 2018/A/5570 Denislav Dimitrov Ivanov v. IJF, para. 51). 2

24. Indeed, the situation has been eloquently summarised by CAS arbitrator Yves Fortier in a
Canadian decision in which he was sitting as Sole Arbitrator for the Sport Dispute Resolution
Centre of Canada in the matter of Taylor Findlay. In that case, the Athlete claimed that the
clenbuterol entered her system from the consumption of contaminated horse meat in a
restaurant. On the basis of the evidence before him, Mr. Fortier found that this explanation
was “highly improbable”. He held, in the following terms, that a failure to explain the concrete
origin of the prohibited substance necessarily meant that the athlete could not prove a lack
of intention (Exhibit 14):

“77. It appears to me that logically, I cannot fathom nor rule on the intention of
an athlete without having initially been provided with evidence as to how she
had ingested the product which, she says, contained the Clenbuterol. With
respect for the contrary view, I fail to see how I can determine whether or not
an athlete intended to cheat if I do not know how the substance entered her
body.”

25. Notwithstanding the above, WADA is aware of a number of CAS awards which have found
that in “extremely rare” cases, an athlete might be able to demonstrate a lack of intent even
where he/she cannot establish the origin of the prohibited substance. 3 The Villanueva award
refers to the “narrowest of corridors” 4 in order to stress just how rare it will be for an athlete
to be able to rebut the presumption of intentionality without establishing the origin of the
prohibited substance. The panel in 2016/A/4919 WADA v. WSF & Iqbal went so far as to hold
that “in all but the rarest cases the issue is academic”. 5

26. WADA accepts in principle that such exceptional cases may exist. However, WADA agrees
with the CAS case law cited above that the circumstances would have to be truly
exceptional. 6

27. In CAS 2018/A/5584 Adrian Zielinski v. Polish Anti-Doping Agency, for example, the CAS
held that “an athlete, in order to meet such burden of proving lack of intent without
establishing source, cannot merely rely on protestations of innocence, lack of a demonstrable
sporting incentive to dope, diligent attempts to discover the origin of the prohibited
substance or the athlete’s clean record.” 7

2
See also CAS 2016/A/4377 WADA v. IWF & Alvarez, para. 51; CAS 2016/A/4662 WADA v. Caribbean RADO &
Greaves, para. 36; CAS 2016/A/4563 WADA v. EgyNADO & ElSalam, para. 50; CAS 2016/A/4626 WADA v. Indian
NADA & Meghali; 2016/A/4845 Fabien Whitfield v. FIVB. See also UK National Anti-Doping Panel decisions in:
UKAD vs. Graham case (SR/0000120259), UKAD vs. Williams (SR/0000120251) and UKAD vs. Songhurst
(SR/0000120248).
3
See CAS 2016/A/4534 Villanueva v. FINA; CAS 2016/A/4676 Ademi v. UEFA; CAS 2016/A/4919 WADA v. WSF &
Iqbal.
4
CAS 2016/A/4534 Villanueva v. FINA, para. 37.
5
CAS 2016/A/4919 WADA v. WSF & Iqbal, para. 66.
6
The following example might, for instance, be sufficiently exceptional for intentional to be excluded without origin
being established: An athlete is tested twice in a matter of hours. Whereas the first test is negative, the second
one contains such a minute concentration of the prohibited substance that intentional ingestion can be ruled out
on the basis of scientific evidence. On such an extraordinary set of facts, a panel might potentially be satisfied
that the positive finding could only have resulted from a contaminated product and that the violation is therefore
not intentional (see e.g. the factual nexus of CAS 2011/A/2384 UCI v. Contador & RFEC; CAS 2011/A/2386 WADA
v. Contador & RFEC).
7
CAS 2018/A/5584 Adrian Zielinski v. Polish Anti-Doping Agency, para. 140.

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28. By way of further example, the Sole Arbitrator in CAS 2017/O/5218 IAAF v. RUSAF & Vasiliy
Kopeykin held as follows:

“The Sole Arbitrator follows the reasoning of the CAS cases 4676 and 4534, but
accepting that an athlete, in order to meet such burden of proving lack of intent
without establishing source cannot merely rely on protestations of innocence,
lack of a demonstrable sporting incentive to dope, diligent attempts to discover
the origin of the prohibited substance or the athlete’s clean record. Supporting
lack of intent without establishing the origin of the prohibited substance requires
truly exceptional circumstances.” 8

29. In this case and for the reasons set out below, the Athlete has not established the origin of
the androsterone, testosterone and its metabolites, etiocholanone, 5αAdiol and 5βAdiol in
her system. WADA submits that the academic debate (regarding whether there may be
limited circumstances in which intention may be rebutted without origin being established)
is moot as there are clearly no exceptional circumstances on the facts of this case.

B.2. Establishment of the origin

(i) The Athlete’s explanation

30. During the proceedings before the Disciplinary Committee of the ONAD, the Athlete denied
having intentionally used any prohibited substance. According to the Athlete, the AAF was
due to the pathological condition that she has, viz. non-classical congenital adrenal
hyperplasia, which led to the high level of testosterone.

31. In support of her argument before the Disciplinary Committee, the Athlete presented various
medical and laboratory reports (Exhibits 17-21), and called Dr. Nadia Paiva, as a witness,
who explained the origin of the pathology and its consequences on the Athlete’s body.

32. On this basis, the Disciplinary Committee of the ONAD confirmed that the Athlete “has
provided her cooperation, has sufficiently accredited the pathology, the non-intentional
ingestion and the absence of significant negligence since the prohibited substance detected
- testosterone - has been generated by the athlete's own body as a consequence of a
hormonal disorder disease” (Exhibit 1). Therefore, the period of ineligibility was eliminated
as per art. 10.4 ONAD ADR, i.e. because the Athlete had established that she bears No Fault
or Negligence.

(ii) Applicable jurisprudence

33. The Athlete is required to prove the origin of the prohibited substance on the “balance of
probability”. This burden lies solely on the Athlete; indeed, WADA, or any other Anti-Doping
Organisation, does not have the burden “to hypothesise, still less prove” an alternative
source. 9

8
CAS 2017/O/5218 IAAF v. RUSAF & Vasiliy Kopeykin, para. 166.
9
See e.g. CAS 2012/A/2759 Rybka v. UEFA, paras. 11.31-11.32 (“It was not for UEFA – the Panel emphasise – to
hypothesise, still less prove, their own version of events” as to how the prohibited substance got into the athlete’s
system);
CAS 2014/A/3615 WADA v. Daiders & FIM, para. 52 (“The Panel rejects a proposed interpretation of the rules
which would seek to impose the burden on the person charging to explain the source of the substance detected
in the system of the person charged”);
USADA v. Meeker, AAA Panel decision dated 12 November 2013, para. 7.7 (“Respondent alone bears the burden
of showing an explanation that is more likely than not for how the Prohibited Substances entered his system. If

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34. The balance of probability standard entails that the Athlete has the burden of convincing the
Panel that the occurrence of the circumstances on which the athlete relies is more probable
than their non-occurrence. 10

35. As set out by the panel in CAS 2014/A/3820 WADA v. Damar Robinson & JADCO case: “In
order to establish the origin of a Prohibited Substance by the required balance of probability,
an athlete must provide actual evidence as opposed to mere speculation” (emphasis added
by the panel). 11

36. Moreover, in the case of CAS 2010/A/2230 International Wheelchair Basketball Federation
v. UKAD and Simon Gibbs, the Sole Arbitrator expressed the athlete’s burden in the following
terms:

“To permit an athlete to establish how a substance came to be present in his

body by little more than a denial that he took it would undermine the objectives
of the Code and Rules. Spiking and contamination – two prevalent explanations
volunteered by athletes for such presence – do and can occur; but it is too easy
to assert either; more must sensibly be required by way of proof, given the
nature of the athlete’s basic personal duty to ensure that no prohibited
substances enter his body.” 12

37. The Panel in CAS 2014/A/3615 WADA v. Daiders & FIM considered that:

“The person charged cannot discharge that burden [of proof] merely by showing
that he made reasonable efforts to establish the source, but that they were
without success. The resolution of the issue which arises at this first stage does
not relate to the presence or absence of fault or negligence, or, if it is present,
its degree. Such matters are relevant only to the second stage. The resolution
of the issue which arises at the first stage depends upon the answer to a simple
question: has the person charged established what the source is? Mere assertion
as to what the source is, without supporting evidence, will be insufficient.” 13

(emphasis added)

(iii) Position of WADA

38. WADA submits that the alleged pathology simply cannot explain the exogenous origin of
testosterone and all its metabolites (androsterone, etiocholanolone, 5α- and 5β-
androstanediol) in the Athlete’s sample. This is confirmed by the report of Prof. Ayotte
(Exhibit 22).

39. In order to detect the misuse of endogenous anabolic steroids, WADA-accredited laboratories
use methods that allow differentiation between endogenous steroids (i.e. produced by the
athlete’s body) and their synthetic copies (i.e. of exogenous origin). Gas chromatography
combustion isotope ratio mass spectrometry (GC-C-IRMS) is capable of measuring the

he fails to do so he has not met the requirement for relief under WADA Code 10.5.1 and 10.5.2. Claimant is not
required to put forward its own speculative theory, and its failure to do so does not compel the acceptance of
Respondent's theory”).
10
See, e.g. CAS 2008/A/1515 WADA v. Swiss Olympic & Daubney, para. 116.
11
CAS 2014/A/3820 WADA v. Damar Robinson & JADCO, para. 80.
12
CAS 2010/A/2230 International Wheelchair Basketball Federation v. UK Anti-Doping and Simon Gibbs, para.
11.12.
13
CAS 2014/A/3615 WADA v. Daiders & FIM, para. 56.

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carbon isotope ratio of urinary steroids and this allows differentiation between endogenous
and exogenous origin. 14

40. Therefore, even if a medical condition (including hyperandrogenism and suprarenal

hyperplasia congenital non classic), might hypothetically have an impact on the level of
testosterone produced by the body (i.e. endogenously), that would not even being to explain
the presence of exogenous steroids in the Athlete’s sample.

41. The analysis of the Athlete’s sample established the presence of testosterone and its
metabolites of exogenous origin. 15 According to Prof. Ayotte “the IRMS values are clearly
showing that in [the Athlete’s sample], testosterone and its metabolites were not produced
by the athlete’s body” (emphasis added). This excludes per se a scenario that the AAF may
be caused by any pathology of the Athlete.

42. Furthermore, the analysis of the Athlete’s steroid profile related to the Sample showed values
that well exceeded the Athlete’s own normal steroid values, which had previously been stable
(Exhibit 16). According to Prof. Ayotte, this further confirms that the abnormal values in the
Athlete’s sample are not compatible with any medical condition.

43. The Athlete has therefore not established the origin of the synthetic origin of the steroids in
her sample. Indeed, she has not put forward any explanation that might be capable of
explaining how they entered her system.

44. On a separate note, WADA recalls that the panel in CAS 2013/A/3431 Patricia Carolina
Caballero v. FIVB when confirming the first ADRV of the Athlete (she tested positive for a
non-specified stimulant (cocaine) during an in-competition period) concluded that the
Athlete’s “behavior was at best significantly negligent and at worst simply reckless” (Exhibit
13). 16 The panel also questioned the credibility of the Athlete:

In para. 71 of the award, the panel referred to “one of the various contradictions in
which the [Athlete] incurred in her statement given during the hearing, when she
mentioned that the pain on her stomach she felt on the day she consumed the coca-
candies, was due to eating fatty food, in circumstances that in the statement of appeal
expresses that such sickness was due to eating spicy food, which is obviously
different.”

In para 76, the panel “consider[ed] important to highlight that during the hearing, the
statements presented by the [Athlete] and her witness Mr. Costa, presented new facts,
which directly contradicted several of the factual elements presented by the [Athlete]
herself previously during the procedure. […] most shocking to the Panel was the
[Athlete’s] revelation of the following facts, which were new and contradicted what
was said up to this point by the [Athlete]:

- She suffered for chronic gastritis since she was 23 years old;

- That given the chronic condition of her disease she had a permanent
prescription;

14
https://pubmed.ncbi.nlm.nih.gov/25503937/
15
WADA also notes that the analysis conducted by the Barcelona WADA-accredited laboratory were confirmed by
the second opinion on IRMS performed by the Rome WADA-accredited laboratory (see p. 143, LDP for Sample A,
Exhibit 7).
16
CAS 2013/A/3431 Patricia Carolina Caballero v. FIVB, para. 75.

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- That before the match she had to play during the World Championships,
she felt stomach pains related to her gastritis and that is why she decided
to eat the coca candies, 6 in total, one after the other, instead of using the
medication she had been prescribed;

- When asked why she ate 6 candies at once, she stated that it was because
she liked them.”

In para. 77, the panel noted that it “cannot fail to mention how striking it was to learn
only in the hearing that the [Athlete] suffered from a chronic stomach disease and that
she had to take permanent medication, since these facts were never mentioned during
the disciplinary proceedings before the FIVB nor during the arbitral procedure before
the CAS.”

In para. 80 the panel concluded as follows: “In sum, not only the arguments that were
expounded in her written submissions were not proven at any moment by the
[Athlete], even though she had the opportunity to do so, but her statements in the
hearing (as well as those by Mr. Costa) actually subtracted verisimilitude to her
position, as it exposed contradictions and weakened her case.”

45. In view of the CAS case law regarding the strict nature of the duty on athletes to establish
the origin of the prohibited substance in their system, it is clear that the Athlete has
manifestly not satisfied her burden. 17 For the reasons set out above, therefore, the violation
must be deemed to be intentional and attract an eight-year period of ineligibility.

46. WADA reserves the right to make further submissions, adduce further evidence and to call
further witnesses/experts depending on the Athlete’s answer.

B.3. Disqualification of Results

47. Pursuant to Article 10.10 ONAD ADR, any results obtained by the Athlete from the date of
the sample collection (i.e. 5 February 2020) shall be disqualified, with all resulting
consequences, including the forfeiture of any medals, titles, awards, points, prize and
appearance money.

IV. Witness evidence

48. WADA calls the following person(s) to testify as expert(s)/witness(es) either in person or by
video/telephone conference:

Prof. Dr. Christiane Ayotte, Director of the Laboratory in the INRS Centre Armand-
Frappier Santé Biotechnologie: Prof. Ayotte will testify with respect to her Expert
Report at Exhibit 22 as well as any matters arising therefrom or related thereto.

49. WADA reserves the right to call additional witnesses/experts and/or to expand the scope of
testimony of the above expert depending on the further submissions of the Athlete and
ONAD.

*****

17
As the Athlete has failed to establish the origin of the prohibited substance, the provision on Contaminated
Products and more generally all provisions requiring a finding of No Significant Fault or Negligence are not
applicable either (see Definition of No Significant Fault or Negligence).

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V. Requests for relief

50. WADA respectfully requests the Sole Arbitrator to rule as follows:

1. The Appeal of WADA is admissible.

2. The decision dated 15 February 2021 rendered by the Disciplinary Committee of the
ONAD in the matter of Patricia Carolina Caballero de Zubizarreta is set aside.

3. Patricia Carolina Caballero de Zubizarreta is found to have committed an anti-doping

rule violation.

4. Patricia Carolina Caballero de Zubizarreta is sanctioned with an eight-year period of

ineligibility starting on the date on which the CAS award enters into force. Any period
of provisional suspension effectively served by Patricia Carolina Caballero de
Zubizarreta before the entry into force of the CAS award shall be credited against the
total period of ineligibility to be served.

5. All competitive results obtained by Patricia Carolina Caballero de Zubizarreta from and
including 5 February 2020 until the date on which the CAS award enters into force are
disqualified, with all resulting consequences (including forfeiture of medals, points and
prizes).

6. The arbitration costs shall be borne by the ONAD or, in the alternative, by the
Respondents jointly and severally.

7. WADA is granted a significant contribution to its legal and other costs.

Lausanne, 10 May 2021

For the World Anti-Doping Agency:

Ross Wenzel Anton Sotir

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List of Exhibits
to the Appeal Brief filed by WADA

Exhibit Description

1. Decision of the Disciplinary Committee of the ONAD dated 15 February 2021

2. Case file request from WADA to the ONAD dated 4 March 2021

3. Correspondence between WADA and the ONAD

4. 2021 ONAD ADR

5. Doping control form of 5 February 2020

6. Test report for Sample A

7. Laboratory Documentation Package for Sample A

8. WADA 2020 Prohibited List

9. Test report for Sample B

10. Laboratory Documentation Package for Sample B

11. Letter to the Athlete dated 24 July 2020 about the AAF

12. Letter to the Athlete dated 24 July 2020 about the provisional suspension

CAS award in CAS 2013/A/3431 Patricia Carolina Caballero v. Fédération Internationale

13.
de Volleyball (FIVB)

14. Decision of the SDRCC in respect of Taylor Findlay dated 13 March 2017

15. Chain of custody form of 5 February 2020

16. Laboratory results from ADAMS of other samples of the Athlete

17. Minutes of the hearing held on 22 December 2020

18. Written explanations provided by the Athlete dated 13 January 2021

19. Minutes from the hearing held on 29 January 2021

Transcript of the testimony of Dr Nadia Judith Paiva Gimenez, doctor of the National
20.
Olympic Committee of Paraguay

21. Supporting documents provided by the Athlete during the proceedings before the ONAD

22. Expert opinion of Prof. Dr. Christiane Ayotte dated 9 May 2021

Lausanne, 10 May 2021