1 • “The military took and arrested around 50 people. They brought them to the military camp … and set fire to where they kept them. One was my own brother. There was a small hut, and they put all the people in there and set it on fire.”125 • “As soon as we got on the boat, they shot at us…. Foyezur Rahman was my father. My daughter was Sofia. She was 18. They were both shot in the back. As soon as the military shot them, they stopped moving. We brought their dead bodies here [to Bangladesh] and buried them.”126 • “I saw her taken from the house and raped by military soldiers. It happened outside, beside a house. We watched from inside the house. After they raped her, they killed her…. [O]ne person [raped her], then she was taken to the road, and he cut her neck and cut her breasts off.”127 2 3 4 5 6 7 8 9 106. In December 2017, Médicins Sans Frontières (Doctors Without Borders) (“MSF”) 10 published estimates of Rohingya deaths between August 25 and September 24, 2017—the month 11 after the “clearance operations” began—based on surveys of refugees in Bangladesh. MSF 12 estimated that “8,170 deaths were due to violence …, including 1,247 children under five years 13 of age.… Cause of death by shooting accounted for 69.4% of these deaths; being ‘burned to 14 death at home’ accounted for 8.8%; being beaten to death accounted for 5.0%; sexual violence 15 leading to death for 2.6%; and death by landmine for 1.0%.” 16 107. MSF noted that “the rates of mortality captured here are likely to be 17 underestimates, as the data does not account for those people who have not yet been able to flee 18 Myanmar, or for families who were killed in their entirety.” 128 The U.N. Mission similarly 19 “concluded that the estimated number of more than 10,000 deaths during the August-September 20 2017 ‘clearance operations’ alone is likely to be conservative.” 129 21 22 23 24 125 126 127 25 26 27 28 Id. at 62. Id. at 65. Id. at 69. Rohingya crisis – a summary of findings from six pooled surveys, MÉDICINS SANS FRONTIÈRES (Dec. 9, 2017), https://www.msf.org/myanmarbangladesh-rohingya-crisis-summaryfindings-six-pooled-surveys. 129 UNHRC Report, ¶ 1482, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf. 128 CLASS ACTION COMPLAINT 42 Case No. __________________