1 operations” followed in numerous Rohingya villages across northern Rakhine State, with at least 2 54 verified locations.112 3 4 104. The U.N. Mission described the clearance operations in six Rohingya villages in detail.113 The following description of the operation in one of those villages is typical: 5 • “[H]undreds of Tatmadaw soldiers … surrounded [the village]. They were accompanied by a smaller number of ethnic Rakhine from neighbouring villages. The security forces then opened fire, shooting at villagers, including those that were fleeing. Soldiers also dragged people from houses and shot some of them at point blank range. Others were killed by having their throats slit with large knives.”114 • “During the course of the operation, structures in [the village] were burned and destroyed…. Satellite imagery analysis … shows the extent of the destruction…. The entire Rohingya village … was destroyed, while the nearby non-Rohingya village … remains intact.”115 • “Women and girls were also subjected to rape, gang rape, sexual mutilation and sexual humiliation during the ‘clearance operations.’”116 • These “‘clearance operations’ were led by the Tatmadaw…. Individuals from the neighbouring ethnic Rakhine village were recognised as participants and some ethnic Rakhine men assisted the military….”117 6 7 8 9 10 11 12 13 14 15 16 17 105. The UNHRC Report and the Fortify Rights Report contain numerous first-person 18 accounts of atrocities committed against the Rohingya by both Myanmar security forces and by 19 civilians during the August 2017 “Clearance Operations.” For example: • 20 21 “The soldiers killed the male members of my family. They shot at them first and then slit their throats. The courtyard was full of blood. They killed my husband, my father-in-law and my two 22 23 24 112 113 25 26 27 114 115 116 117 28 Id. ¶ 880. Id. ¶¶ 755-879. Id. ¶¶ 782-83. Id. ¶¶ 784, 788. Id. ¶ 790. Id. ¶ 797. CLASS ACTION COMPLAINT 40 Case No. __________________

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