1 108. Most of the Rohingya who escaped the clearance operations now live in “a 2 miserable slum of a million people” in Bangladesh. Time reported in 2019 that “[c]onditions in 3 the [refugee] camps remain abysmal. Most refugees live in small shacks made of bamboo and 4 tarpaulin sheets, so tightly packed together that they can hear their neighbors talking, having sex, 5 and disciplining their children or, sometimes, wives. In the springtime, the huts turn into saunas. 6 In the monsoon season, daily rainfall turns hilly footpaths into waterslides and lifts trash and 7 human waste from open drains to float in stagnant pools.” “[M]urders and other forms of 8 violence occur almost nightly inside the camps and are rarely if ever investigated.” 130 “The 9 Rohingya are …, with no access to meaningful work, entirely dependent on humanitarian aid…. 10 These factors increase vulnerability, in particular for women and girls, to trafficking and other 11 exploitation.”131 According to Steven Corliss of the U.N. refugee agency, UNHCR, “The 12 situation is untenable: environmentally, socially and economically.” 132 13 109. Plaintiff and the Class have been deprived of their property, including their homes 14 and the land they cultivated for generations. In an update to its 2018 Report, the U.N. Mission 15 wrote: 16 The Mission concludes on reasonable grounds that the Government undertook a concerted effort to clear and destroy and then confiscate and build on the lands from which it forcibly displaced hundreds of thousands of Rohingya. The consequences are twofold. This government-led effort subjugates Rohingya to inhumane living conditions as [internally displaced persons] and refugees by denying them access to their land, keeping them uprooted from their homes, depriving them of their to ability to progress in healthy and safe communities and preventing them from engaging in livelihood activities that sustain them as a people. The second consequence of the Government’s four-pronged approach of clearing, destroying, confiscating and building on land is that it is fundamentally altering the demographic landscape of the area by 17 18 19 20 21 22 23 Feliz Solomon, ‘We’re Not Allowed to Dream.’ Rohingya Muslims Exiled to Bangladesh Are Stuck in Limbo Without an End in Sight, TIME (May 23, 2019), https://time.com/longform/rohingya-muslims-exile-bangladesh/. 130 24 25 26 131 UNHRC Report, ¶ 1174, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf. Feliz Solomon, ‘We’re Not Allowed to Dream.’ Rohingya Muslims Exiled to Bangladesh Are Stuck in Limbo Without an End in Sight, TIME (May 23, 2019), https://time.com/longform/rohingya-muslims-exile-bangladesh/. 132 27 28 CLASS ACTION COMPLAINT 43 Case No. __________________