EXHIBIT A - JOHN DOE I

AFFIDAVIT IN SUPPORT OF ACTION

John Doe I, being duly sworn, deposes and says:

1. I am a citizen of the United States, and I currently reside (address redacted), on Maslakh Street (known as “the street of butchers”), in the Ein Misbah neighborhood of Ramallah, in the occupied West Bank of Palestine.

2. I submit the herein affidavit in support of the above-entitled cause.

3. The sources of your affiant’s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

4. On Friday, 29 March 2002, at approximately 4:30 in the morning, my late daughter, Jill Doe I, age twenty-two, was brutally shot dead by a large group of soldiers of the Israeli Defense Forces, as she held her nine-month old baby in her arms while sitting in her car. My daughter was a United States citizen, born (date of birth redacted) at George Washington Hospital in Washington, D.C. Her social security number is (number redacted). Her U.S. passport number is (number and issue date redacted).

5. As set forth more fully in the affidavit of her husband, Charles Doe II, who himself was critically wounded in the same attack, my daughter was murdered by military forces during the earliest stages of the Israeli invasion of Ramallah. My daughter, her husband and her child lived on the other side of the same block where I live, and when the invasion began, they drove the short distance by car to my home in order to seek refuge with the rest of our family. Although this event occurred in early morning hours and it was raining lightly, the soldiers were close enough to the car to discern clearly that my daughter and her family were not armed, nor were they combatants of any kind. Jill Doe I and Charles Doe II were dressed in ordinary street clothes, without anything unusual about their dress, and my daughter held her baby in her arms. Only fifty meters from my door, soldiers stopped their car, and without warning or questioning of any kind whatsoever, opened fire with machine guns at a distance of approximately five meters (a little more than five yards). The only guns discharged in the immediate vicinity of the place where my daughter was murdered were those carried by the soldiers of the IDF; there was no fire in that immediate area prior to this encounter, nor was there any return fire after the soldiers finished discharging their weapons. Jill Doe I suffered multiple bullet wounds to her head; Charles Doe II was struck by two bullets in his head, two in the shoulder and neck area, and one in the leg; the baby was miraculously unhurt. After the soldiers moved on, my son-in-law went around to the other side of the car to help his wife, but she died almost immediately. He carried their son, Baby Doe I, to within ten meters of our house, when he collapsed unconscious in the street. During this time my family and I could hear gunfire in our street, and throughout our neighborhood. We also heard the baby crying but could not get to Charles Doe II and Baby Doe I because the Israeli soldiers were shooting indiscriminately in nearby areas. When there was a pause in the shooting, my wife Jill Doe XIX ran out to get the baby and bring her to my house; my neighbors from across the street ran out and took my son-in-law to safety in the lobby of their building. A few minutes later, I ran across the street to join them with first aid materials. Among the neighbors who came to help my son at that time was a pediatrician from my block whom I know as Dr. Mohammed.

6. At that time, my family called an ambulance, but because of the Israeli military actions, it did not reach the scene until some thirty minutes later. The Red Crescent ambulance crew took the body of my daughter from the car and drove away. During this time, my neighbors and I gave first aid to Charles Doe II, with cotton bandages, paper towels and water, while gunfire and explosions could be heard from surrounding neighborhoods. An ambulance was called, but would not arrive for another two hours. During this time, Charles Doe II was alternately unconscious, or awake and in great pain, deliriously crying out his wife’s name, before falling back into shock, then losing consciousness again. His bullet wounds were clearly visible; the two wounds in his shoulder and neck were each approximately one inch in diameter and bleeding steadily. His head wounds were difficult to do anything for, and we were not sure how many bullets had struck him there. At approximately 7 a.m., the Red Crescent returned and took Charles Doe II to the Arab Care Hospital, where he would spend three days in the intensive care unit under the care of Drs. Wahel Hamouri and Shaupye Harb, before being sent home in my care due to lack of space. During all this time, my family and I were unable to leave our homes due to a twenty-four hour curfew on the streets of the city, in which anyone found out of doors could be shot by the Israeli army. My daughter’s car remains in the road at approximately where the killing occurred, though it has been pushed three meters to one side by IDF trucks to keep the way open.

7. On the Thursday following the attack, the same hospital telephoned to inform me that my daughter had been brought there, dead on arrival. They further informed me at that time that during a break in curfew, hospital personnel had buried her in a mass grave in the parking lot, along with twenty-four men and two other women. The hospital explained that their electrical service was failing because the IDF had destroyed the utility infrastructure during the early hours of the invasion, and it was not possible to keep the morgue refrigerated. Because the hallways and stairwells had become triage areas for the many wounded victims of that morning, the hospital was unable to store cadavers anywhere inside. I have not seen my daughter since the day before the invasion, and my family has not been able to perform the religious rites of mourning and burial which are the custom for practicing Muslims.

8. Since the day my daughter was murdered by the Israeli army, the city I live in has been under military siege by the Israeli Defense Forces. Curfew is sporadically lifted for a few hours at a time on select days, with little prior warning, during which time city residents are able to move around and purchase food or supplies. My family and I have been shuttered in our apartment for two weeks as of this writing, including: my wife, my wounded son-in-law, and his infant son; my son Omar, age nineteen, born in Washington, D.C. and currently a student in business accounting at Bir Zeit University; my daughter Sana, born in Arlington, VA, age sixteen and a high school senior; my daughter Taqua, a fifteen year old high school student, born in Jerusalem; my daughter Sugoud, a high school student, age thirteen and born in Ramallah; and my ten year old son Othman, who was born in Ramallah and attends the fifth grade. None of the children have attended school since December, after a series of Israeli attacks in Ramallah made it too unsafe.

9. I was born (date of birth redacted) in the village of Sa’ir, in the Hebron area, in the final years of the British Mandate. I left school in the sixth grade, in 1956, when I went to work at various unskilled jobs. I left Palestine in 1965, at which time I was a subject of the Hashemite Kingdom of Jordan, and emigrated to South America, residing variously in Ecuador, Colombia and Peru. I sold clothing door-to-door in that region, until 1968, when I moved to the island of Puerto Rico to live with my cousins there. I lived there until 1978, when I moved to Arlington, Virginia, where I worked in restaurants. In 1980, I became a partner with another cousin in a Waffle Shop restaurant franchise on Mount Vernon Ave. in Alexandria, VA, which I co-operated until 1983, when I bought another restaurant, (name redacted), on L’Enfant Plaza in Washington, D.C. I operated this restaurant with my brothers Mahmoud and Ibrahim until 1987, when I sold my stake to them, who still operate the restaurant today. At that time I bought a pizza restaurant, (name redacted), on Connecticut Ave. in the District with a third brother, Farhat. I bought a house on George Mason Drive in Arlington, where I lived with my family from 1986 until approximately 1989. In 1987, I bought an ownership stake in an apartment building in Ramallah, in the occupied West Bank. I applied for residency in the occupied West Bank from the Israeli civil authority, and was granted that status in 1989. From 1987 until 1996 I maintained an address in Ramallah center city, near the post office. In 1996, I bought the apartment house where I currently reside, and moved there. Since then, I have worked full time as the superintendent and manager of my two buildings, which have approximately ten apartments, plus the two apartments where my extended family lives. My annual income from my apartment building is normally approximately $15,000. But since the beginning of the current intifada in September, 2000, my earnings have steadily dwindled to less than half that due to the constant closures and military incursions by Israel during this time, which make it impossible for many of my tenants to keep their jobs or pay their rent. Like many Palestinians living under occupation, I have tried to accommodate them according to their ability to pay, given the extraordinary circumstances we all live under here.

10. I was first married at the age of sixteen, to (name redacted), in 1960. This union produced two daughters, (name redacted), born in 1961, and a housewife with six children in Virginia; and (name redacted), born in 1962, and a housewife with five children in Bet Sahour, in the West Bank. I was divorced in 1965, and re-married in 1968 to (name redacted), in Puerto Rico. This union produced one daughter, (name redacted), born in 1969, who now lives near Rio Piedras in Puerto Rico. In 1977 on a trip to the West Bank, I met and married my wife Jill Doe XIX, with whom I have nine children. My wife was born in El Bireh (referred to, with Ramallah, as the other of the “twin cities”) in 1957. In addition to the children who live with me today, as set forth in ¶ 7 above, I have three other daughters by my wife Jill Doe XIX who all live in the United States. Mariam, born in 1978 in Puerto Rico, is a housewife in Chicago; Sahar, born in 1979 in Maryland, is a housewife in Philadelphia; and Samar, born in D.C. in 1980, lives in Brooklyn. In all, I have twelve children, and fifteen grandchildren.

11. I became a United States citizen in 1973. My social security number, (name and number redacted). My U.S. passport number is (number and expiration date redacted). My Virginia driver’s license # is (number redacted).

12. I have never been arrested, detained, or charged with any crime whatsoever by any government anywhere.

13. At the present time, no civil authority exists where I reside, as the government of the Palestinian Authority, its ministries and police services, has been completely suppressed. To the best of my knowledge, there is no governing Israeli military police authority in Ramallah to which I might make any official complaint, as the city is still under siege and is an active military combat zone. Moreover, it would be absolutely futile for me to bring any claim in any Israeli court seeking justice for my daughter’s loss. Palestinians have little or no standing in Israeli civil courts for the Israeli government’s activities in the Occupied Territories. Although several treaties and charters of international law apply to my status in the Occupied Territories, I am not recognized by Israeli courts and there are no meaningful remedies or relief that I can seek through Israeli courts. Despite my American citizenship, I am unable to leave the military zone, either to travel to Jerusalem or anywhere else in the West Bank; nor may I travel in Israel. I am a second-class citizen under Israeli control; I cannot vote in their elections nor exercise any franchise that gives me representation.

14. During this time, no one from the American Consulate or Embassy has contacted me. Although my attorney attempted to secure assistance for my family and me through the consular officials in East Jerusalem, the officials there rebuked these overtures on technical grounds. 15. Since the vicious and wanton killing of Jill Doe I, I have been afflicted by terrible emotional suffering. I see her face constantly, and I remember when she was a baby in America, and when our family was happier. My wife cries nearly every hour, and my daughters are terrorized. On the two occasions that curfew has been lifted in the past ten days, they have been too frightened and anxious to venture out of the house for more than a few minutes at a time: the continuing presence of IDF snipers on many nearby rooftops, as well as their tanks and sandbagged positions, fills my daughters with mortal dread. At times, my daughters are listless and non-responsive, sunk in depression. My ten year old son, Othman, is especially affected by the killing of his older sister, and is now consumed with rage against the Israelis.

16. My family, in the nearly twelve years since our return to Palestine, has never been politically active.

17. Jill Doe I and her husband were not political, but were simply regular working people living their lives under the ongoing occupation. Most recently, she finished high school in Ramallah in 1999, and attended two years of college at the Palestine Education Center, where she studied accounting. Three months ago, she was hired for a permanent position by the Palestinian Authority as an accountant and secretary in the Education Ministry. This job included further educational opportunities, and the possibility of promotion. Her salary was approximately $350 per month, which represents average entry-level salaries for young people in the West Bank. But because of the Israeli military siege on the Presidential compound and surrounding government buildings beginning in December of last year, my daughter had not been paid any of her wages by her embattled employer for her tenure up to the time of her death. She remains on the payrolls of the Palestinian Authority and is due all back wages.

18. During the twelve years that I have resided in Ramallah, the Israeli government, through its army and its occupation administration, has exercised de facto control over the economy of the West Bank and the lives of ordinary Palestinians here. Nearly every aspect of economic life, including licensing, permitting, importing and exporting, freedom of movement, registration of vehicles, land use regulations, and taxation has been, to varying degrees, controlled by the occupation forces and used in a manner intended to punish, manipulate or exploit the local population. At times throughout this period, conflicts between Palestinians and the Israeli occupational authority in Ramallah have resulted in military action by the IDF, police action, or Israeli judicial sanction against Palestinians, in many of these areas. These responses have included land seizure, denial of permits and licenses, withholding of identity cards or stripping of status, denial of rights to travel, and so forth. I personally know many neighbors and friends who have been subjected to unjust and capricious treatment by the occupation authority.

19. In the nineteen months since the beginning of the current troubles, the Israeli Defense Forces have been responsible for many killings without cause in the Ramallah area and throughout the West Bank. During this time I have heard from friends and neighbors, and have seen news reports nearly every day, of killings by soldiers of unarmed civilians. In the past two weeks since the full-scale invasion of the West Bank, widespread news reports from sources around the world as well as in Palestine have reported accounts of hundreds of deaths of civilian noncombatants by the IDF, with many hundreds more wounded. Additionally, reports are now surfacing in all media outlets of mass killings of civilians in the West Bank cities of Jinin and Nablus. Conditions in Ramallah at this time are devastation: buildings are collapsed from missile and tank strikes, roads are torn up, sewer and water services have been destroyed in many neighborhoods, electricity services are day-to-day, food stores are scarce in the shops and the traditional market is not allowed to operate. Worst of all, we are unable to leave our house but for short breaks in the round-the-clock curfew— usually only three or four hours in duration—that occur with no fixed schedule every four days or so.

20. To the best of my knowledge, my daughter Jill Doe I and her husband and baby posed no threat whatsoever to the soldiers who killed her on that terrible morning. They were ordered to stop their car, they complied with the order and awaited further instructions. No effort was made by the soldiers whatsoever to identify them or question them in the few seconds that elapsed between Charles Doe II turning off the car motor and the barrage of bullets that killed Jill Doe I and wounded her husband. Since the murder, no IDF authority in the West Bank has made any statement whatsoever about my daughter’s murder, nor given any indication of any kind why the soldiers fired with overwhelming force with intent to kill on civilians they made no attempt to identify.

21. Because my grandson Baby Doe I is by operation of U.S. law a citizen, and inasmuch as his father is not a citizen, while I am, it is my intent to file in the appropriate state and federal courts an application to be appointed surrogate for the child and trustee for his estate. These applications will be made with the support of the child’s father and will not be done for purposes of establishing me as legal guardian or custodian of the child in any venue, but rather as his legal representative during the course of proceedings in the United States.

22. As recently as this past week, on Thursday 10 April, a detachment of IDF soldiers with tanks and armored personnel carriers came to my block and stopped at my building. First they removed all the men and boys in the building and lined them up in the street; eventually, one tenant was detained and taken away. Then they searched each apartment, including my own. One of my tenants is a children’s daycare center on the ground floor, which was closed because of the troubles. I did not have the key to open the center, but the soldiers insisted that I did. They took me out to the street, where in full view of their commander, they pointed guns at me and threatened me. I informed that I was an American citizen, and showed them my passport. They took my passport and showed it around, cursing at me, and brandishing weapons at me. A neighbor fluent in Hebrew, who at that time was corralled with all the other men from the building, said later that the soldiers were told by the commander to take my passport and “stick it up his [rear].” After some more menacing, the soldiers took a sledgehammer and knocked down the daycare center door, then ransacked it. They took me back to my apartment, returned my passport, and brandished weapons in front of my wife and children, all of whom were crying and upset. They noted where I live and said they would return. My wife and I did not sleep for two nights in a row, as every troop movement we heard outside our home filled us with dread and uncertainty.

23. For this reason, I have a great fear of extra-judicial retaliation from the IDF if I pursue a legal action against them in the United States. As I reside in the military zone controlled by the Israelis, and as there is no supervening, neutral police authority that might protect me, in practice anything could happen to me or my family at their hands. Consequently, I herein ask that my specific identity in the early stages of this litigation be accorded privileged status; and that it be limited solely to the attorneys in this case; and that they be instructed not to share my specific identity with governmental officials of Israel and/or the United States.

Dated: ___________________________
on this ___ day of______, 2002
_____________________________________________
JOHN DOE I

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AFFIDAVIT IN SUPPORT OF ACTION

John Doe XIV, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me and my son in this matter. His office is located at 351 Broadway Suite 300, New York, NY 10013.

2. I am a citizen of the United States. Currently I reside part of the time at (address redacted), Bronx NY, and part of the time in the Deir-Debwan area of Ramallah, Palestine.

3. I submit the herein affidavit in support of the above entitled cause. I am the father of Baby Doe II, a seventeen year old, as such I bring this action on his behalf.

4. The source’s of your affiant’s information and belief are: first hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I have six sons and six daughters, all of whom were born in the United States. One of my sons, Baby Doe II was born on (date of birth redacted) at Jacobi Hospital in New York City. He is a United States citizen.

6. I have a farm in the Deir-Debwan section of Ramallah. On Saturday, April 20, 2002, my son Baby Doe II was at the farm from approximately 6:00 or 6:30 pm until 8:00 pm. He was with a friend, Charles Doe XXV. They were feeding chickens on my land. During the time that he was at the farm neither he nor his friend heard any gunfire in the area. At approximately 8:00 pm they got into a van my son was using and drove on the road from Deir-Debwan to Rammon. He had been driving for approximately ten minutes and was passing an area where there are several trees.

7. At that time he heard faint shouting from a short distance away, alongside the road, but could not hear what the people were shouting. He then saw numerous IDF soldiers in the area. He did not speed up or attempt to flee. There was at that time no reason for him to think the soldiers were calling him. Shortly thereafter several soldiers fired at the van. He was shot once. The bullet entered from his back and passed through into his stomach area. In addition his friend Charles Doe XXV was shot twice in the shoulder. The van he was driving had approximately twenty bullet holes.

8. Though wounded he was able to drive to the house of my brother, Charles Doe XXVI. At that time both my son and his friend were bleeding severely. My brother then took them to the local doctor. His wound, however, was too serious for the local doctor to attend to and so he called an ambulance. It is my understanding that the ambulance was delayed for almost an hour while IDF soldiers searched it and other vehicles. The ambulance was finally allowed to proceed but several soldiers came along inside the ambulance to the doctor’s office where my son was waiting.

9. When the ambulance arrived the soldiers further delayed my son’s evacuation by entering the doctor’s office, pointing their weapons, and demanding that all of the people at the doctor’s office first raise their hands, then lay on the ground. The soldiers interfered with the doctor, and in spite of his protests, made him stop attending my son while they questioned him and searched the doctor’s offices. The soldiers then insisted on reviewing each person’s identification and determining that none of the people were armed.

10. Only after this further delay of almost another hour was my son permitted to go to the hospital in Ramallah, though IDF checkpoints along the way stopped the ambulance repeatedly. By that time my son had been laying, wounded, for two hours. At one checkpoint outside Ramallah, both my son and his friend were removed from the ambulance, stripped naked by IDF soldiers, and left on the ground for an additional two and a half hours. With al the delays and stops, it took seven hours from when he was shot to when he arrived at the hospital in Ramallah, a trip that would ordinarily take ten to fifteen minutes, were it not for Israeli closures and interference.

11. My son stayed at the hospital for three weeks. He was treated for the bullet wound to his stomach. My understanding is that the entry wound was through the lower right part of his back, and theat the bullet tumbled through his abdomen, piercing his liver, colon and intestines. While I do not know fro certain, the bullet has been described to me as what would be called a “dum-dum” bullet, and it flattened out and fragmented inside his body. Surgery lasted four hours. As a result of his wound, doctors were unable to save his gall-bladder, and he currently wears a colostomy bag for excreting solid wastes through a two inch diameter hole in his abdomen. Doctors removed fifteen centimeters from his large and small intestines.

12. He has terrible pain in his abdomen in general and digestion is painful. His appetite is reduced and he suffers from extreme fatigue. He is only able to sleep on his back, and he passes each night badly. He can neither work nor study and is listless and distracted all the time. Since being released from the hospital he has attempted to work but has been unable to. If he stands for any length of time he becomes dizzy and had, on at least one occasion, fallen over. In addition, with only moderate exertion the wound has reopened causing him great pain. I do not know why his wound can not be closed so that this does not happen anymore.

13. Neither my son nor his friend had done anything hostile toward the troops. Neither of them were armed in any sense. Neither of them had thrown rocks or any other thing at the soldiers. Neither of them had called to the soldiers or made any gesture toward them. My son had been feeding the chickens, and in the area for at least two hours prior to the appearance of the IDF. During that time no one on or near my land had done any of the above described actions toward any IDF force. My son has never been arrested, detained, or charged with any crime by any government anywhere.

14. Three days before my son was shot he had taken 4,000 chicks on contract to raise them for a chicken company, with feed costs and supplies. This was the third time he had entered into such a pact with the chicken company. Typically, such an arrangement can earn $4,000.00 minus expenses, for bringing the birds to market in approximately forty-five days. After he was shot, no one dared go near the farm again and as a result the chicks all died. He presently owes the chicken company approximately $2,500.00.

15. At the present time no civil authority exists in the Deir-Debwan section of Ramallah, as the government of the Palestinian Authority, its ministries and police services, has been completely suppressed. To the best of my knowledge, there is no governing Israeli military police authority in Ramallah to which I might make any official complaint, as the city is still under siege and is an active military combat zone. Moreover, it would be completely useless for me to bring any claim in any Israeli court seeking justice for my injuries. Palestinians have little or no standing in Israeli civil courts for the Israeli government’s activities in the occupied territories. Although several treaties and charters of international law apply to my status in the occupied territories, I am not recognized by Israeli courts and there are no meaningful remedies or relief the I can seek through Israeli courts. In fact, when he departed from Israel in late June, 2002, to come to the United States, he was told by security personnel at Ben Gurion Airport in tel Aviv not to return to Israel ever again.

16. In addition, any travel in the area of Deir-Debwan requires frequent contact with IDF forces, and other officials of the Israeli government. Given his experience, and given how quickly and with no reason whatsoever he was shot by the IDF, these encounters are now almost intolerable, filling him with dread and panic.

17. Because my family lives in the occupied territories, and in as much as the Israeli Defense force and Shin Bet, the State security force, routinely and regularly invade our communities, my family lives in a constant fear of being singled out by these forces as retaliation for these complaints and this law suit. Accordingly, I ask for an order of this court permitting my identity, my son’s and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well founded fear that military and security forces of Israel will harm me, my family and our property in retaliation for this suit.
Sworn to before me on this day of , 2002, in .
JOHN DOE XIV

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AFFIDAVIT IN SUPPORT OF ACTION

Jane Doe I, being duly sworn, deposes and says:

1. I have retained the law office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a citizen of the United States. My social security number is (number redacted).

3. I submit the herein affidavit in support of the above-entitled cause.

4. The sources of your affiant’s information and belief are: first hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I have resided in the United States since 1993. My current address is (address redacted) Birmingham, Alabama 35216. I have lived at this address since 1997.

6. Many of my relatives live in the Old City part of Bethlehem. Among them are my aunt Jill Doe II and my cousin Baby Doe V. It is my intention to seek appointment as executrix for the estate of my deceased aunt and cousin.

7. On April 2, 2002 the Israeli army began its invasion of Bethlehem. At approximately 8:00 am forces of the Israeli Defense Force were firing numerous weapons in and near the street where my family lives. Several soldiers came to the door of their home and apparently demanded entry to the house. A neighbor informed them that only an old woman and her children lived there. The soldiers were not satisfied, and unable to open the door, they set off an explosion, I believe using dynamite. The explosion damaged but did not open the door.

8. It is my understanding that my family members did not know what the soldiers wanted of them. Terrified by the massive military presence and demolitions assault, everyone was taking cover in a room on the first floor. The soldiers, having failed to blow the door open, began firing at the house, the windows, and the partially damaged door. This firing was without warning and the only apparent purpose was to kill everyone inside.

9. Assuming that was their purpose they were partially successful. My aunt Jill Doe II was shot at least once in the head and died soon after. My understanding, from conversations with family members that were there, is that at least one bullet entered her brain. There was massive bleeding from her head. I believe this to be the cause of death. In addition my cousin Baby Doe V was also shot at least once in the head. Again, it is my understanding, based on conversations with family members that were there, that at least one bullet entered his brain also. As with my aunt I believe this to be the cause of death.

10. I have made inquiries of several family members that were there at the time and soon thereafter. I am unaware of any accusation relating to any family member of having committed or being wanted for any action criminal or otherwise. Nor has there ever been any suggestion that they or any other family member was associated with any political organization that has been involved in any illegal act. No explanation or comment has ever been given to me as to the reason for killing my family members. No explanation or reason has ever been given to me for why the forces wished to gain entry into my family’s house. There was no firing from within the house either at the time the soldiers murdered my aunt and cousin, nor at any other time.

11. My aunt was born in Bethlehem and lived there her entire life. She completed her high school education there. She married and had six children, one of whom died in July of 1976. She is survived by four children: (names redacted). Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this law suit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: __________________________
on this _____ day of____________,2002
_____________________________________________
JANE DOE I

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AFFIDAVIT IN SUPPORT OF ACTION

John Doe XVI, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a United States citizen. I submit the herein affidavit in support of the aboveentitled cause, which I am filing on behalf of my deceased son, Baby Doe IV (Passport #(number redacted), who was also a United State citizen, and for whom I intend to secure designation as the executor of his estate in the near future.

3. The sources of your affiant=s information and belief are: first hand knowledge and observation, and discussions with witnesses to the events complained of herein.

4. I was born on (date redacted), 1958 in Beit Ur, a town near the city of Ramallah, Palestine. I lived there until 1974 when my father, my brothers and sisters moved to the United States. We lived first in Maine for two years and then in Belleglade, Florida. In 1976 I began working in my father=s grocery. I worked with him for four or five years. I met my wife, Nadia, in the U.S., and we married in 1983 in Jerusalem. We had five children, Baby Doe IV, Mahammed, Samah, Wayel and Abdel. Approximately two dozen of my relatives are American citizens and reside all over the United States.

5. My eldest son Baby Doe IV was born in Jerusalem on June 21, 1984. A few months after he was born my wife and I returned with him to Belleglade, Florida. We lived there for six years. We returned in 1990 and presently live in the Shuffat camp near Jerusalem. The camp is not overseen by the Palestinian Authority, but is administered instead by Israel itself. The camp is less than two square miles in size, with more than 20,000 persons living there. Most homes have electricity and indoor plumbing.

6. From first to ninth grade Baby Doe IV went to the Shuffat camp school; for tenth and eleventh grade he attended the Rasha Dia school in Jerusalem and was a good student. People always said that he was good with people, always happy. He never got into trouble of any kind, and for his age he seemed very serious and religious. People in the community often commented on how my son had a great future before him, and I felt proud.

7. Friday, December 8, 2000 was during Ramadan, the holy month of fasting and prayer, and the most important time of the year in the Muslim religion. On that day, as on every Friday for years, Baby Doe IV was going to the Mosque in Jerusalem. At that time there was a demonstration against the Israeli occupation of the Palestinian land. Baby Doe IV had no great political convictions. He was devoted only to Islam. While he was on his way to the mosque there was a problem at the demonstration. Israeli soldiers began firing indiscriminately into the crowd and at any other people in the vicinity.

8. Baby Doe IV was shot once in the head. He lay there bleeding until an ambulance arrived immediately and took him in. The Israeli soldiers, however, would not allow the ambulance to go to the hospital. They made the ambulance, with Baby Doe IV in it, sit for forty minutes and during the delay he bled to death. Once the ambulance arrived at the hospital, he was pronounced dead on arrival.

9. I have never received an explanation for the wanton killing of my son. Nor could I ever imagine an explanation that might help me understand how the soldiers could have so little value for human life as to shoot into a crowd of people. Baby Doe IV was always a good boy, and no one had ever accused him of doing anything illegal or misbehaving in any way.

10. My family has not been the same since Baby Doe IV died. We used to always eat together, as a happy family, and his absence now fills all of us, especially his siblings, with a deep sorrow we cannot understand. The children are traumatized, they don=t speak much anymore, and they are doing poorly in school since Baby Doe IV=s death. My next-eldest son, Mohammed, is sixteen, and fears he will not live to adulthood, and is deeply troubled.

11. Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the state security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces as retaliation for my complaints and this lawsuit. Accordingly, I ask for an order of this court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family and our property in retaliation for this suit.

Dated: _____________________
on this ___ day of______,2002
_________________________________________
JOHN DOE XVI
Sworn to before me on this ______ day
of ______2002, in____________________.
___________________________________
NOTARY

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AFFIDAVIT IN SUPPORT OF ACTION

JOHN DOE IV, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a citizen of the United States.

3. I submit the herein affidavit in support of the above-entitled cause.

4. The sources of your affiant=s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I was born in El Bireh on March 25, 1958. I attended high school in Palestine. I attended the City College of New York starting in 1978 and received a B.S. in 1982. I was then accepted to Howard University for Medicine and graduated in 1986. I did my residency at King=s County University Hospital from 1986-1990. From then until July 2000 I worked there and taught at the medical school specializing in pediatrics, internal medicine and emergency medicine.

6. I returned to Ramallah in July 2000. The Israeli army began the invasion of Ramallah in late March 2002. For the next several weeks the city was occupied by Israeli military forces. As a consequence the Israeli army was able to, and did in fact, severely curtail and at times prohibit all people from entering the street except during brief, unannounced periods when they would lift the curfew. During periods when the curfew was imposed, even emergency vehicles were prohibited to move.

7. On or about April 10, 2002 I was attending to patients at the hospital (name redacted) where I am director of emergency medicine. Shortly before dinner time I received a phone call from my brother, Ali, stating that my father, John Doe III, was suffering from a headache, and chest pain. My brother indicated that he had slurred speech and could not move his left hand. Based on these indications and my familiarity with my father=s medical history I was able to diagnose that in all probability he was suffering from the onset of stroke.

8. My father lives in the Al Sharafa section of Ramallah. It is only a few miles from the hospital. Immediate medical attention is indicated in such a situation. Indeed, at an early stage, introducing a blood thinner can often avert, and will certainly mitigate the damage from stroke. I immediately called for the ambulance service, the Red Crescent, to go and attend to my father. Alternatively, that an ambulance be sent to his home to bring him to the hospital. In order to secure the medical attention essential to my father=s health. I was told that the Israeli military forces would not allow any people or vehicles, even emergency vehicles to be on the street at that time. I was told that any people or vehicles on the street would be shot. I was not permitted to see my father for two days. Nor were any other medical personnel permitted to see him for two days.

9. By the time I was permitted to see my father he had undergone a stroke. When I came to him he was unable to control his bladder. He was unable to move his left side and he did not recognize me. Since that time he has been under my care and has shown some signs of improvement. However, he still suffers from slurred speech, has obvious impairment in his motor skills, typical of stroke victims. He also suffers from obvious short term memory problems. This also is typical of people that have suffered from stroke.

10. Based on my training and expertise as outlined in paragraph 5 above, I am able to say to a reasonable degree of medical certainty that had my father been treated promptly or even within a reasonably appropriate period of time, the stroke may have been averted and that in any event, the effects would have been less pronounced if at all.

11. There was no obvious military engagement in and around the hospital where I work at the time that I was trying to have my father brought there and during the entire day. It is my understanding that at the time my father first complained of the symptoms described above there was no military action in the area around his house. There was certainly no firing at or from his house at that time or any time for that matter.

12. On 8 April of this year, at least six soldiers came to the house at one o=clock in the morning, while I was attending at the hospital. My wife and six daughters were home alone. My daughters range in age from fifteen years to two years old. The soldiers demanded entry, ordered all the family into the kitchen and then searched the house. After approximately half and hour, they left without giving any indication of why they had come.

13. More recently, my wife and children were at home in Ramallah, on 24 June 2002. A full-scale re-invasion of the city had occurred approximately 48 hours before, and all Ramallah was and remains as of this writing under a shoot-on-sight curfew. I was attending the emergency room at the hospital when 50-60 IDF soldiers surrounded my house. Eight soldiers came to the door, demanded entry, and ordered my wife and children to wait on the verandah under armed guard, while they searched the entire house and my medical clinic downstairs. My clinic advertises itself with a large sign that reads (name and practice redacted).

14. The soldiers opened all my drawers and closets, and then they searched all my computers, both personal and business, in the house and in the office and clinic, systematically opening all my computer files. They also searched my daughter=s computer, and damaged the hard drive, rendering it inoperable. After approximately forty-five minutes, they left to search my neighbor=s house.

15. During this incident, my wife and children were terrified, and the children were especially traumatized after six months of near-constant siege to have IDF soldiers standing over them with weapons brandished. My absence during this tense moment led my wife and children to fear the worst for me, as the soldiers seemed intent on finding something in our house. No explanation was offered by any commanding officer for why they had come. I have no idea why the IDF has decided to focus on my medical practice and my home, subjecting it to searches with some frequency, and I fear I am being singled out because of the success of my practice and because I am an American.

16. I have no affiliation with any political party that is prohibited or that has ever been involved in any illegal conduct.

17. Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this law suit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: __________________________
on this _____ day of____________, 2002
_____________________________________________
JOHN DOE IV

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AFFIDAVIT IN SUPPORT OF ACTION

JOHN DOE III, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a United States citizen.

3. I submit the herein affidavit in support of the above entitled cause.

4. The sources of your affiant=s information and belief are: first hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I was born in El Bireh, Palestine in 1931. I completed prep school there and helped my parents working in the fields of their land. Later I did stone work, making statuary for homes and other buildings.

6. In 1969 I moved to the United States where I became naturalized in 1971. For the first few years I lived in Ohio and later moved to New York State. During the time that I lived in the United States I worked in and later owned several grocery stores. I returned to El Bireh in 1982.

7. On or about April 10 there was a curfew imposed by the invading Israeli forces that had been in effect for at least several days. On or about April 10, shortly before dinner, I experienced a headache and chest pain. Family members that were with me could detect a certain slurring of speech although I had not been drinking alcohol. I was also unable to move my left hand. My son John Doe IV is a doctor at (redacted) hospital. His education and expertise are contained in his affidavit. (Submitted herewith). My family contacted John Doe IV at the hospital where he was able to determine from these symptoms and my medical history that I was beginning to suffer a stroke.

8. My son indicated that it was essential that I get to the hospital immediately. However, the invading Israeli forces prevented any ambulance from coming to my house. The same forces would not allow any of my family to take me to the hospital. Despite the obvious emergency, no medical personnel were permitted to see me until two days after the onset of these symptoms. I have been informed by my son that when he was finally able to see me I could not hold my urine, I could not stand or move my left side. I could not recognize my own children.

9. It is my understanding that I suffered a stroke. It is also my understanding that had there been prompt treatment there would have been a reasonable likelihood of preventing the stroke or minimizing its effects. It is my understanding that prompt treatment in such situations typically means a matter of hours, not days. It is my understanding I currently have recurrent short term memory difficulties. It manifests itself in ways such that I frequently can not recall where I have left my keys, what room I am in, or what I was doing only a moment before. I am also frequently disoriented as to where I am and I have difficulty recalling people who may have visited me the day before. Moreover, I have some difficulty walking and my speech is sometimes slurred.

10. The decision to refuse me essential medical attention is a mystery to me. I have never been so much as accused of committing any act of violence. Nor have I participated in any political organization that has been accused of any wrongdoing. Moreover, at the time that I was beginning to suffer from the stroke and through that day there was no fighting in the area of my home. Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this law suit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: __________________________
on this _____ day of____________,2002
_____________________________________________
JOHN DOE III

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AFFIDAVIT IN SUPPORT OF ACTION

John Doe XV, being duly sworn, deposes and says:

I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

1. I am a resident alien of the United States.

2. I submit the herein affidavit in support of the above-entitled cause.

3. The sources of your affiant=s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

4. From September 1984 to September 1986 I attended the University of Washington and resided in Seattle, Washington.

5. Although I frequently return to Washington State, in 1986 I moved to my current residence on Omar Bin Abdel Aziz Street in Tulkarm, West Bank, Palestine. My family owns the apartment building in which I live, along with twenty-two other U.S. Citizens, Resident Aliens and immediate relatives, seventeen of whom are children under the age of fourteen. The building has five stories and an interior front door that is located in a shared and gated walkway that separates our building from that of our neighbors. Next to our interior front door, there is another door to a backyard where we keep chickens and pigeons. My two brothers Charles Doe XXII and Charles Doe XXIII, both are U.S. citizens, reside here as well. In addition to my brothers, several of my nieces and nephews live here, as does my son Baby Doe III. My son was born in Tulkarm on August 31, 1991.

6. On May 25th, 2002 at approximately 1:30 pm, my brothers Charles Doe XXII, Charles Doe XXIII, and along with my cousin Mohammed were working in the courtyard. My brothers asked my son to get them some coffee or tea. There had been no gunfire in the area of our home during the day. There had certainly not been any firing from our home. At the time that my son exited the door of the backyard to enter into the building, which is a few feet away, at least three tanks of the Israeli army were coming up the street passing by our building. A soldier in one of the tanks was positioned atop the turret of the tank. He was not more than fifty meters from my son. My son was clearly visible to the soldier. It was obvious that he was not armed. It was also obvious that he was not firing and that no one in the area was firing any guns. For reasons known only to him, the soldier began firing at my son. My son was obviously shot in the leg. I could see that he was bleeding profusely, on the ground and unable to move, screaming for me to help and crying. I ran to my son, who lay in the exposed area of the walkway. I could see the soldier. I saw the soldier look at me and he opened fire again, firing at both of us. I fell on my son, and I thought I had been shot, so I lay on my son hoping in that way to protect him from any more wounds.

7. The soldier continued firing into our immediate vicinity. The wall nearest us became pitted all over from gunshots. Numerous bullets hit the ground very near to where we were. The soldier also fired into the area where my brothers had come to help my son and me. Words can not describe the terror I felt for the safety of my ten-year old son and for myself. I had wanted only to move him to safety and was initially entirely unable to move; but eventually, I realized I was not wounded but had simply sprained my ankle running to my son. Yet my own injury and the firing of the soldier made movement impossible.

8. Finally, after several minutes I was able to drag him to safety with the help of my brothers. It was obvious that my son had lost a considerable amount of blood. He was clearly unable to walk and he was traumatized. My brothers and I were shouting at our wives, and at our neighbors to call up for an ambulance. There was an ambulance less than one minute away, but it reached us only half an hour later because the tanks were still present down the road. It was my understanding that all emergency services were being intermittently delayed in the area by the Israeli forces.

9. It was clear that my son needed to be operated on immediately. Because of the lack of personnel and equipment at the local hospital, we asked to transfer the boy to a hospital specializing in bone treatment. There is one in the nearby town called Nablus, but it was too dangerous to travel on any road. We then called the U.S. Consulate to arrange to send the boy to an Israeli hospital. Two days later the Israeli District Liaison office agreed to permit the boy to be transferred to an Israeli hospital on the condition that we provide an affidavit stating that we have to pay for the entire charges. Meanwhile, my child=s leg was tied to a rope connected to a heavy sandbag that kept his leg straight while he awaited the transfer to take place. 10. My son is currently hospitalized at Nazareth Hospital in Israel, where he underwent three medical operations to his leg. Because of the travel restrictions and the long curfews imposed by the Israeli government on all Palestinians, whether citizens of the United States or not, as well as the comprehensive closures that limit our movement, I am often not permitted, nor are any of my brothers permitted, to visit him. He is a ten-year-old boy who was shot by a tank, traumatized, and alone in a strange town without a companion. He does not speak Hebrew. Under any decent person=s view a hospitalized ten-year old should have as many family visits as possible.

11. It was my understanding from conversations with my son=s doctors that my son suffered at least one bullet wound in which the bullet entered his thigh from one side through the other. In passing through his body, it broke his bone and caused partial, or total, nerve damage, which renders him unable to walk. The doctors at this time are unable to determine whether his disability is permanent.

12. As with the vast majority of United States Citizens, no member of my family has ever been convicted of a crime. Like most Americans no one in my family has ever even been accused of having committed any crime of violence. My son Baby Doe III is ten years old. He has never hurt anyone in his life. It is impossible that the soldier had even the slightest fear that Baby Doe III presented a danger to him or to anyone else, ever. Nor has the soldier that shot him or any other soldier indicated any reason for shooting my son. Indeed, after wounding my son and shooting at me, no member of the Israeli forces made any effort to detain or question my son or any member of my family. They simply fired at us as if for sport, then they moved on.

13. Indeed, only the day before they shot my son, on May 24th, 2002, members of the Israeli army came to our house and reviewed the identification card of each of the people that live in our building. The identification card of any person living in this area is a nine-digit number. All military units are able to check this number to determine if the bearer is wanted for any reason. The soldiers did in fact make such a check of every member of my household and they were able to determine that no one in our household was wanted by the Israeli government for any reason.

14. On or about May 30th I made a formal complaint as to the shooting of my son to the local police force and the District Coordinating Office. My family has informed the United States State Department, Consulate and Embassy. In fact we have complained several times seeking protection. The United States representatives have stated that they cannot control the Israeli Army. Since I made my local complaints, the Israeli forces have fired at my family=s building on at least two occasions, during occupations of Tulkarm. These firings are clearly retaliation for my complaint, in that there is never any apparent object to their firing, except to shoot up our apartment building, and the fact that the houses of our neighbors to either side are never hit at the time of these shootings.

15. forces have also caused terrible damage to the business owned by my brothers and me. My three brothers and I have been doing business as (name redacted). Our business was very successful. We are suppliers of wheat flower, seeds, animal-feed and basic foodstuffs, responsible for more than fifty percent of the town=s needs. Apart from the injury to my son and the obvious damage to our home, the Israeli We have seven stores for this purpose. Over the course of several weeks, sometime in either November or December of 2000, four of our stores, which are located in the southern part of town on a main highway connecting to the cities and villages of the Triangle area, were shot at and shelled by Israeli tank fire. In addition, the Israeli army declared the area a closed military zone, a term which is often used to warn civilians not to come near. To this date, we are still unable to reach the stores. Furthermore, a tank sideswiped one of our delivery trucks, rendering it unusable.

16. According to our accounting firm, an estimate for losses caused by the destruction of our stores and the 75% disability of our business caused by the Israeli army could exceed $1,500,000 US in net profit. I am not now able to say at this time when, or if, we will be able to restore our business.

17. Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this lawsuit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: Tulkarm, West Bank, Palestine
on this _____ day of____________,2002
_____________________________________________
JOHN DOE XV

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AFFIDAVIT IN SUPPORT OF ACTION

Jane Doe II, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a citizen of the United States. I currently reside at (address redacted) Greenville, South Carolina 29609. I have resided at this address since 1994. My date of birth is (date redacted). My social security number is (number redacted). I married my husband, Charles Doe III, also a United States citizen, in June of 1981. He served with the United States army until he retired with an honorable discharge after more than fifteen years of service.

3. I submit the herein affidavit in support of the above-entitled cause.

4. The sources of your affiant’s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I was born and raised in a house in Nablus, Palestine. The house was situated on the outskirts of the old city, between the old city and the new city. Two of my sisters, Jill Doe III and Jill Doe IV were also raised in that house. Both continued to live there with my nephew, Charles Doe I, and my niece, Jill Doe V until April 3, 2002.

6. On April 3 Israeli forces began the invasion of Nablus. There was no warning given of the invasion. Residents were not directed to leave. Indeed, all residents were prevented from leaving the city. On April 3 a rocket fired by Israeli military forces, either an F-16 or an Apache helicopter, destroyed the house where I was raised. The rocket apparently entered the third story and caused the house to collapse. Both my sisters and my niece and nephew were in the house at the time. Medical services, ambulances, doctors, paramedics were not allowed to attend to people injured by the military action. As such I am unable to say at this time whether my sisters were killed upon impact, as a result of the house collapsing, or whether, buried under the rubble, they suffocated or died from injuries sustained but for which no medical personnel could attend.

7. I can say that both sisters died on April 3 as a direct result of the rocket attack. My niece was fortunate. Her spine was crushed. She has had to undergo operations to replace the fourth and seventh vertebrae, which were destroyed. She is currently immobilized, and she can not move her neck. She is 26 years old, and is currently being treated at Allmadeenah medical center, a hospital in Jordan.

8. My nephew, age 23, was also fortunate, in that he was not killed with his mother and his aunt. His face was burned and he suffered injuries to his body. He is being treated at the hospital in Nablus. He is currently unable to see clearly with one eye. The doctors are hopeful that one day he will regain his eyesight.

9. There is not now, nor has there ever been, any accusation that any member of my family has committed any crime. There is not now, nor has there ever been, any accusation that our house was used for any military, terrorist, or any other criminal purpose.

10. I first learned of the deaths of my sisters and the destruction of our home while watching television on April 3. The reporter showed the area that the Israeli forces had fired on and then the reporter stated my sisters’ names as among those that were dead. I screamed, I cried, I hoped that they had made a mistake. Through numerous long-distance telephone conversations with family members I was able to verify the statements made above.

11. Like myself, both my sisters as well as my niece and nephew were born in Nablus. For my part I stayed until I was eighteen, when I left to attend the University of Baghdad, College of Economics and Business, where I received my bachelor’s degree. My sisters remained there: Jill Doe III, born February 1959 went to the college at Nablus where she received an Associate’s degree in General Management. Jill Doe IV, born August, 1953, both loved to be with our family and in the home we had lived in since we were children.

12. When this happened my niece, Jill Doe V, just twenty five years old, was in her first year at Al Najah University where she was studying English. Now she is unable to move, and still has no feeling in her hands and legs. My nephew Charles Doe I is just twenty two years old, had finished high school in Nablus, and was unsure if he wanted to attend college. Now he is in the hospital, his face burned and vision in his eye uncertain.

13. I think of my sisters several times a day. It still seems impossible that this has happened, and I can not comprehend how the Israeli forces could do this thing. My sisters were a threat to no one. They have never injured anyone and killing them was senseless in every sense of the word. It is my intention to seek appointment as executrix of their estate. Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this law suit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: __________________________
on this _____ day of____________,2002
_____________________________________________
JANE DOE II

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AFFIDAVIT IN SUPPORT OF ACTION

John Doe XII, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a United States citizen and have been since 1968. My social security number is (number redacted). My passport number is (number redacted). More than forty of my family members are also United States citizens.

3. I submit the herein affidavit in support of the above-entitled cause.

4. The sources of your affiant’s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I was born on (date redacted), 1941 in the Al- Bireh section of Ramallah, Palestine. I lived there and went to school there until 1960. In 1965 I went to the United States in Youngstown Ohio, where I met and married my wife, Amineh. I became a United States citizen in 1968. We remained in Youngstown until 1993, and we still own a house there, although I currently reside part of the year on Al-Mobadeen Street in the Al- Bireh section of Ramallah.

6. While in Youngstown, I worked and later bought, owned and ran several grocery stores. Amineh and I raised our family there. We have five daughters: Heba, who currently lives in Salem Ohio; Rana, who currently resides in Fairfax, Virginia; Janan, who currently resides in Twinsburg, Ohio; Haya, who lives in the house I still own in Youngstown; and Jill Doe XXXIV, who lives in the Al-Bireh section of Ramallah.

7. Through hard work we were able to save enough money that in 1976 we bought land on Al Mobadeen Street in the Al-Bireh section of Ramallah. In 1976 we had a two-story apartment building constructed there. In 1993 my wife and I moved into the building, and in 1998 we had two stories added to the building. There are at least thirty families in this section that are United States citizens.

8. In July 2001 my daughter Jill Doe XXXIV lived here with her was her husband Charles Doe XXXXI and their five children: Baby Doe XXXII and Baby Doe XXXIII, both daughters; and Baby Doe XXXIV, Baby Doe XXXV and Baby Doe XXXVI, all boys. The children at that time ranged in age from eleven to three. Her family, along with my wife and I, were living on the second floor. Tenants in the building included a woman who was in her sixties and her teenaged daughter.

9. In July 2001, two Apache helicopters of the Israeli Defense Force hovered outside my building on opposite sides and fired at least two rockets into the fourth story. The rocket fire killed a guest of the tenant in the fourth floor apartment. The rocket fire destroyed the interior walls of the third and fourth floor, the doors, and windows. The rockets also damaged an exterior gas line for the building and thereby caused a fire to break out. Luckily, neighbors in the area were able to put out the fire before the entire building was burned up.

10. My daughter and her children were in the apartment on the second floor at the time of the fire. It is a miracle that none of them was killed or severely injured. There was substantial damage to the apartment including: shrapnel entered into the apartments and damaged walls; some of the doors were blown off their hinges; all of the windows were destroyed. It is difficult to describe the horror my grandchildren experienced at this event. They were screaming and yelling and obviously terrified.

11. The sixty year old woman who is my tenant was hit with shrapnel, and her daughter suffered a broken arm.

12. This happened nearly one year ago. The trauma of my grandchildren is still manifest. They are all frequently prey to the most terrifying nightmares, often of soldiers suddenly appearing and firing at them. They also suffer from a chronic need to go to the bathroom. This happens several times during the day in which they have to use the bathroom immediately. They have been to the doctor several times to treat this but it is his diagnosis that there is no physiological explanation for this. He believes it is directly related to their trauma.

13. There are literally more than 1000 holes throughout the building from shrapnel from the rocket fire. All windows in the building were destroyed, the sewer line was destroyed as was the water line. The repairs that I have made, largely superficial so far, have already cost me approximately fifty thousand dollars ($50,000.00). In addition, many of the units are not yet habitable and I estimate that I have lost somewhere between thirty-five and fifty thousand dollars ($35,000.00 - 50,000.00) in rental income.

14. I am the owner of the building. This is a matter of both public record and common knowledge. I have resided here since 1993. I am a responsible landlord. I am always available and responsive to any and all complaints and inquiries. I can assert that I have never been approached by any authority, Palestinian or Israeli, concerning any resident of my building or any of their guests. No one has ever approached me about any wanted person ever having been to my building. I would, of course, have been responsive to any such concerns. As such I am entirely unable to say why Israeli forces fired at my building without warning or investigation. I am incapable of saying what they intended by this action or even if they intended to kill the guest who was there. I can however say that there are many entirely obvious alternatives to destroying two floors of my building, traumatizing children that they had to know were present. In fact it was merely fortuitous that my grandchildren were not playing outside at the time. If they were they surely would have been killed by either the shrapnel or the rubble that fell immediately to the ground. 15. In addition to the damage done by the Israeli rocket fire, Israeli bulldozers have knocked down the wall around the house on two occasions. When I have complained of this the soldiers have laughed at me. 16. I have also made complaints to the United States consulate about the damage done by the rocket fire and have been told that there is nothing that they can do. 17. Because I live in the occupied territories, and in as much as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in constant fear of being singled out by these forces as retaliation for my complaints and this lawsuit. Accordingly, I ask for an order of this court permitting my identity and, where appropriate, the identity of others referred to in my affidavit, to remain under seal for as long as possible. In the alternative, I ask for an order of this court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family and our property in retaliation for this suit.

Dated: __________________________
on this _____ day of____________,2002
_____________________________________________
JOHN DOE XII

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AFFIDAVIT IN SUPPORT OF ACTION

JOHN DOE V, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a citizen of the United States of America.

3. I submit the herein affidavit in support of the above-entitled cause.

4. The sources of your affiant=s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I currently reside at (address redacted), Winnemucca Nevada, 89445. I have resided here since 1990. Before that I lived in California from 1972 to 1990. My social security number is (redacted). I was born on (date redacted), 1950 in Deir Debwan, Palestine, which is a town approximately seven miles north east of Ramallah. It is my understanding that perhaps as many as 80% of the population of Deir Debwan are United States citizens. My wife Fouzieh and three children live there now. My children=s names are Omar age 17, Jhadah age 14, and my only daughter, Entisare who is 12 years old.

6. On January 30, 2000 I flew into the Ben-Gurion airport in Tel Aviv. While my luggage was being checked the Israeli security officer asked if I had any electronic equipment. Thinking that he was referring to computers, radios or recorders, I said that I did not. He opened my bag and, finding a Nintendo game that I had brought for my nephew, he accused me of lying. He also insisted that I would have to pay two hundred dollars ($200.00) as a duty. I explained that I was not lying, but that I had not thought the game was the type of equipment he was concerned about. I also stated that the game had only cost fifty dollars ($50.00) at WalMart, and that such an unreasonable duty was absurd. He slapped me in the face, causing a red mark and intense pain. Dozens of other American travelers were watching this event, and the humiliation I felt was acute.

7. Soon after, I went to the United States consulate in East Jerusalem to complain of such treatment of a United States citizen. The person I spoke with there said that there was nothing they could do about it and stated that if I did not like it, I don=t have to travel in this part of the world.

8. On May 5, 2002, my fifty-second birthday, I was traveling from Jerusalem to Ramallah. I was wearing an American flag lapel when I arrived at the Kalendia checkpoint. It is located about ten miles from Jerusalem, near the old Jerusalem airport. I got to the checkpoint at approximately 11:30 am. I presented my American passport to the Israeli soldiers guarding the checkpoint. At least one of the soldiers pointed a gun at my head and another shoved me. I stated that they had no reason to treat me like this. I stated that I am an American citizen, I am not a terrorist, and that I was here as a tourist. The soldier that had pushed me stated AI am an Israeli guard and I can do anything I want. If you don=t like it you can go back to the United States.@ He then pushed me to the ground and kicked me twice: once in my back, once in the back of my head. His blows knocked the breath out of me, and caused me to black out momentarily, as my vision went blurry and I could not see. Afterward, my head throbbed for hours with pain, and my back was bruised, tender and in so much pain I could not move normally. Walking and sitting were extremely painful.

9. The soldier then ordered me to sit on a rock next to the checkpoint. It was hot. When I had been pushed to the ground my suit was torn and dirtied. I felt that I looked like a bum. After sitting there for no apparent reason for approximately one hour, I got up and asked if I could speak with his supervisor. He hit me on the right side of my face with his rifle butt. He ordered me to go back and sit on the rock. I did so. At approximately 2:00 pm there was a change of soldiers. The one that had hit me and kicked me, and the one that had pointed his gun at my head and struck me with the rifle butt both left. Another soldier, who had just come there reviewed my passport and said I could continue on my way. I complained to him of the treatment I had just been subjected to and he said that each checkpoint is different and each soldier is.

10. I promptly went to a doctor in Ramallah. He could see a large bruise on my face and was able to determine that I had damage to my right eardrum and a 50% loss of hearing in that ear. He could also see a bruise on my back from being kicked, and correctly stated that it would hurt for a few days. He gave me a pain killer.

11. I have never so much as been accused of having committed any crime. I have never caused any injury to another person. I am not affiliated with any organization that conducts violence against any one. I am like the vast majority of Americans in this regard.

12. Because I go to the occupied territories, and my wife and children live there, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this lawsuit. I have a reasonable and substantial fear that my ability to travel there will be hampered or even prohibited should my name be revealed. Accordingly, I ask for an order of this court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well founded-fear that military and security forces of Israel will harm me, my family and our property in retaliation for this suit.

Dated: __________________________
on this _____ day of____________, 2002
_____________________________________________
JOHN DOE V

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AFFIDAVIT IN SUPPORT OF ACTION

JOHN DOE XIII, being duly sworn, deposes and says:

1. I am a citizen of the United States, and I currently reside on Othman bin Affan St., Sheik Jarrah, East Jerusalem, in the occupied West Bank of Palestine.

2. I submit the herein affidavit in support of the above-titled cause.

3. The sources of your affiant=s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

4. On the morning of Friday, 30 March 2002, soldiers of the Israeli Defense Forces attacked the city of Ramallah and its environs. My business, (name redacted), a tire distribution company, (location redacted in part), in the Bitonia Industrial Zone in Ramallah, was completely destroyed by an Apache helicopter rocket attack sometime just after noon on Saturday, 31 March 2002. My only remaining employee at the time of the attack, Charles Doe VII, lives less than 100 feet from my business, and that morning he called on his mobile phone to inform me that a helicopter attack on the Industrial Park was in progress, and that my company had been hit. Charles Doe VII said at that time that he watched the entire premises burning out of control, that he could see fire and thick black smoke, and that no one was attempting to fight the blaze, as all emergency services were interrupted or destroyed by the IDF operations. In subsequent telephone conversations with Charles Doe VII that day and in the days following, I was informed that he had inspected the premises, and that all my inventory had burned, my offices were destroyed with everything in them, and that much of the rubber was still burning days later.

5. My business has no strategic military function whatsoever, nor did it pose any threat to the IDF. Neither my business nor myself has ever had any connection of any kind with the Palestinian Authority and its operations, or with any paramilitary or political organizations whatsoever. Charles Doe VII states that no weapons were discharged in the moments before the attack from the area of my business, nor was there any return fire directed at IDF operations from the area of my business during or after the attack. Other businesses in the Industrial Park were also destroyed that day, as numerous people in the Palestinian business community have informed me. The devastation has been widespread and apparently deliberate. I can only conclude that this destruction is simply the latest in a long series of acts by the government of Israel in their campaign of economic warfare against the residents of the West Bank.

6. I opened my business in May of 2000, with an initial investment of $300,000US, which I raised principally from my savings in the United States, augmented by some funds from my brother Mohammed, who maintains a silent partnership interest in the business. In its first six months of operation, my business grossed approximately $100,000US per month, selling as many as 3,000 tires each month; from this, my company earned approximately $75,000US in net receipts during this period, and was steadily building accounts throughout the West Bank. By the start of the current intifada, or uprising, and the Israeli military incursions into the West Bank, I had assembled major accounts with semi-annual standing orders with tire shops in Jenin worth $50,000; in Nablus worth $100,000; accounts in Qalquiya worth $60,000; and accounts in Bethlehem worth $20,000. During the early stages of the disturbances, my company was still able to do some business, though orders began to flag within months as IDF forces took control of the movement of goods and traffic on the roads connecting the major cities of the West Bank. Other tire shops outside Ramallah that depended on my distribution were shut down by the IDF, or placed in zones off-limits by the military. When Ramallah was closed by the Israeli military in April 2001, and became a restricted military zone, my company lost all ability to conduct business entirely, save for the occasional single tire sold to a Ramallah resident. Revenue began to disappear as the Palestinian communities under closure experienced a constriction of the general economy, which rippled through all sectors of trade among Palestinians. Since April of last year, my company has not sold a single tire outside of the Ramallah military zone as a direct result of IDF closure. During the early stages of this period, I continued to try to fill deliveries, but every time I loaded my trucks with hundreds of tires and sent them out, they were detained at military checkpoints, unloaded and searched, then turned back with their load. Often my drivers would have spent an entire day at a checkpoint before being turned back. Eventually the accounts in other cities began to disappear, as the entire Palestinian economy shrank as a result of closure. All the roads are controlled by the IDF with machine-gun positions, tanks and armored vehicles with heavy weapons. It is not possible to make deliveries anywhere under their control; for example, as of this writing, I have not visited Jenin in two years because Palestinians are not allowed to travel there. At the time of the attack, my monthly gross receipts had dwindled to less than $1,000, or barely enough to cover transport, electricity and phones. I was forced to lay off all my remaining employees in December.

7. A Palestinian importing company in Gaza is my principal supplier. They currently hold approximately $100,000US in debt owed by my company against the nearly $150,000US in stock-on-hand I kept at the company=s warehouseCapproximately 3,000 tires, or a month=s supply, many of them high-end truck tires which cost as much of $350US each. Upon information and belief, all of this stock is now destroyed. In addition, my offices and warehouse contained approximately $25,000 in office equipment, warehouse equipment and physical plant, all of which is also presumably destroyed in the fire that consumed the buildings. My business has no insurance, because after July 2001, I was no longer able to pay the premiums due to loss of receipts, and the policy lapsed. All my inventory records are kept in file cabinets on the premises of the business, and I have not been able to enter the military zone since the attack, and cannot provide supporting documentation at this time. My business consisted of three rented premises, with two warehouse/stockrooms and one showroom/office. The combined annual rent on the premises was approximately $8,000US.

8. I was born in Talloza, West Bank, on (date of birth redacted) 1963. My U.S. Passport number is (redeacted), issued in Philadelphia, (date partially redacted) 1993. My father, Jameel, was a farmer in the Talloza area, and died in 1992. My mother, Izziah, age eighty-three, lives in the West Bank. My family lived for part of my childhood in the Palestinian refugee camp Al Farah, operated by the United Nations Relief and Works Administration in Palestine. I have eleven siblings, and three of them are U.S. citizens: my brothers Khalid and Walid are independent home improvement contractors in Edgewater, and my sister Mariam, a U.S. citizen, is a housewife with six children in New York. The rest of my siblings live in Jordan or Palestine.

9. I have never been arrested or detained at any time or anywhere.

10. I moved to the United States at age eighteen in 1981, after graduating from high school in Ramallah. I first lived with my brother Khalid, a student who had been in the U.S. already for two years, and we shared an apartment in North Bergen. Upon arrival I began attending Essex County College in Newark, N.J. I graduated from Jersey City College (now New Jersey State College at Jersey City) with a B.S. degree in computer science in 1992. In 1993 I became a naturalized U.S. citizen.

11. After I finished my schooling, I entered a management training program with Hardee=s Corporation, the fast-food franchise company, in Hackensack, N.J. From 1993 to 1995, I managed various Hardee=s, Roy Rogers, and Pudgees franchises in northern New Jersey and New York City. In 1995, I began working as a manager at Café Italiano, a full service restaurant in Englewood Cliffs, N.J., where I was employed until 1999. I then became a manager at Il Villino restaurant in Waldwick, N.J., where I was employed until early 2000, when I decided to move my family to Palestine and start my tire business. From 1987 through 2000, I lived and paid taxes at various addresses in North Bergen and Union City, N.J. During this time, my annual income averaged approximately $27,000.

12. My wife Samar was born in Jerusalem in 1973. We met in 1997 when I was visiting my brother at a center for ex-detainees in Ramallah, and were married in Oct. 1998, in Ramallah. We set up house in New Jersey, and our first daughter, Shadia, was born in Edgewater in 1999 and is a U.S. citizen; our second daughter, Noor, was born in August, 2001, in Jerusalem, and we are in the process of applying for her American citizenship at this time. My wife is a Permanent Resident Alien, (number redacted). Her social security number is (redacted).

13. Since the first attacks on the Ramallah presidential compound in December of last year, I have been unable to do any business at all, I have been unemployed, and with little means of supporting my family except for assistance from my extended family in the West Bank. At the time of the attack, I had been living at Sateh Marhaba, in Al Bireh, Ramallah. But due to my mounting losses, I could no longer afford the rent on my family=s apartment, and I was forced in February of this year to move in with my sister-in-law and her family in the house they rent at my present address in East Jerusalem. At this time, I am unable to re-enter Ramallah, and since the full-scale military invasion on 30 March, I have not seen my business. For the past week, I have tried to enter Ramallah three times at the Kalendiah military checkpoint of the IDF, during the momentary suspension of curfew that occurs sporadically, but Israeli military officials will not recognize my property rights nor my right to pass. At this time, there is no Israeli civil procedure by which I might seek redress for my losses, and to the best of my knowledge, no military tribunal yet exists which would hear my claim, or recognize my right to make such a claim. The Palestinian Authority, the nominal government under which my business operates, has been drastically reducedCif not eliminatedCwith its ministries shelled by tanks and rocket attacks, its president trapped in his compound, and its police forces arrested, killed or dispersed. To my knowledge, there is no legal remedy in Israel for the losses I have suffered as a result of the wanton, systematic and intentional destruction of my property and business at the hands of the IDF.

Dated: __________________________
on this _____ day of____________,2002
_____________________________________________
JOHN DOE XIII

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AFFIDAVIT IN SUPPORT OF ACTION

John Doe X, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a citizen of the United States, and I currently reside on Nablus Street, Alberahl, Ramallah, Palestine. My social security number is (number redacted) and my passport number is (number redacted). I was born on (date redacted), 1953 in Jerusalem.

3. I submit the herein affidavit in support of the above entitled cause.

4. The sources of my information and belief are: first-hand knowledge and observation, and discussion with witnesses to the events complained of herein.

5. I am one of several owners of a supermarket located in the Almasion area of Ramallah and known as (name redacted). The other owners are: (four names redacted) who are all United States citizens, John Doe XI, (four names redacted).

6. The Israeli army invaded Ramallah on March 28, 2002. For the next three days no one was able to enter the store. By March 31 several armored personnel carriers of the Israeli army were stationed outside my store. At least one fired at and knocked into the door of the store thereby knocking open the front doors.

7. As affirmed in paragraph 6 no one had been able to enter the store since March 29. There was no firing from inside the store or in the immediate vicinity of the store. After the tank blew open the front of the store several soldiers entered. Within the store there is a locked door which leads to the basement. The soldiers used an explosive device to break that door. Because I am unfamiliar with explosive devices I am unable to make any statement as to what type of device this was.

8. In any event, contained within the basement are a few computers and a safe. The soldiers destroyed the computers. There is also a safe in the basement that the soldiers attempted to break into. In addition to the damages in the basement the soldiers took or destroyed numerous foodstuffs in the store. Within the supermarket there was a room of various cigarettes. These, like the food, were taken or destroyed.

9. On April 11 five armored personnel carriers, one tank and about thirty soldiers returned to the store, and using an explosive device, blew the safe open and took the money that was inside.

10. Whether due to the force used to gain entry or because of acts by the soldiers once inside, the electrical system for the store was destroyed. No effort, so far as I know, was ever made by the Israeli forces to fix this. As a result, all perishables within the store were ruined.

11. I have never been involved in any political organization that has been accused of criminal activities. I have never been arrested. None of the other partners in the store has ever been arrested so far as I know. There has never been even so much as a suggestion that the supermarket was used for any illegal reason, neither to harbor people accused of anything criminal, nor to store items that would be used for criminal purposes. I have never been informed that the Israeli soldiers recovered anything suggesting criminality. In short there is little to suggest their reasons for this destruction other than for their own desire to take the goods within, to damage the supermarket, to loot our products and steal our money.

12. I lived in the United States for more than twenty years. With the hope raised by the Oslo peace accords I along with two friends decided to move back to Palestine. It was my intention to start businesses in order to help establish a meaningful infrastructure in Palestine. In some degree we had been successful. The supermarket, prior to the invasion employed twenty-five people in good jobs. We were doing retail sales of between six and seven thousand dollars U.S. currency. Our supermarket provided a variety of goods to people in the area.

13. I estimate the damage to the store, the cost of repairs and the replacement of items such as computers as being thirty thousand dollars U.S. ($30,000.00). My estimate as to goods stolen or ruined as twenty five thousand dollars U.S. ($25,000.00). The store was closed due to the invasion for twenty three days. As stated above, retail sales were between six and seven thousand dollars a day. In addition, even by the beginning of June 2002 we have not been able to fully repair the entire store.

14. At the present time no civil authority exists in the Deir-Debwan section of Ramallah, as the government of the Palestinian Authority, its ministries and police services, has been completely suppressed. To the best of my knowledge, there is no governing Israeli military police authority in Ramallah to which I might make any official complaint, as the city is still under siege and is an active military combat zone. Moreover, it would be completely futile for me to bring any claim in any Israeli court seeking justice for my injuries. Palestinians have little or no standing in Israeli civil courts for the Israeli government=s activities in the occupied territories. Although several treaties and charters of international law apply to my status in the occupied territories, I am not recognized by Israeli courts and there are no meaningful remedies or relief the I can seek through Israeli courts.

15. Because I live in the Occupied territories, and inasmuch as the Israeli military and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this law suit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: __________________________
on this ___ day of______,2002
_____________________________________________
JOHN DOE X

AFFIDAVIT IN SUPPORT OF ACTION

JOHN DOE XI, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am one of several owners of the supermarket, (redacted), described in the affidavit of John Doe X, and I live behind the supermarket. (See affidavit of John Doe X for further details of the other owners and form of ownership).

3. I submit the herein affidavit in support of the above entitled cause.

4. The sources of your affiant=s information and belief are: first hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. As to the events described in the affidavit of John Doe X regarding the incident of March 31, 2002 I was able to personally observe that there was no one inside the store from the time when the curfew was imposed; that Israeli forces used an armored personal carrier to knock open the front door to the store, and thereby ruined the glass in the front as well as the door frame; and that numerous soldiers entered the store and set off explosives to open the door to the basement. In addition, the soldiers set off explosive charges to gain entrance to the accountant=s office and a special storage room where we stored expensive items including perfumes, cigarettes and some food stuffs.

6. When the curfew was lifted temporarily on 11 April at 1:00pm, I immediately entered the supermarket and walked around inspecting the damage. I was able to see that all our perishables were ruined; that much of our dry-goods and foodstuffs were either torn open and dumped out, crushed, or missing; that all the cartons of cigarettes and perfumes were missing; that the office in the basement had been trashed, and our computers were broken; and that our safe which had been blown open and was completely looted with all our money taken.

7. It must be emphasized that until the curfew was lifted no one was allowed to enter the store. Once the curfew was lifted many of the people that live in the area came to the store for essential food. Obviously, I was not able to clean up the damage done to the store before the curfew was lifted.

8. On April 13 I was at the store cleaning up the damage caused. This included taking out the few perishables that were still in the store but which had rotted as a result of the destruction of the electrical service to the store. It also included removing a variety of potentially dangerous rubble, i.e broken glass, strips of metal and broken wood. A store employee was helping me with the cleaning and had gone outside. I was then informed that Israeli soldiers were questioning my employee as to what he was doing.

9. I went out to discuss the matter with the soldiers. I saw that there were three jeeps and nearly a dozen soldiers. I explained that I was cleaning up the damage done to the store by the Israeli forces. I stated that there was no need for them to worry. The soldier that was apparently in charge became obviously angry at my statement and said, to the effect, that he had to worry.

10. The soldier and at least one other then began shouting and pushed me into the store. I did not resist in any manner. Once inside the store the soldier apparently in charge hit me in the face with the butt of his rifle. As a result of this action I suffered a black eye, and intense swelling and pain which I treated with ice. I experienced a headache, and sharp pain and soreness in my face for more than a week afterward.

11. Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this law suit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: ___________________________
on this ___ day of______,2002
_____________________________________________
JOHN DOE XI

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AFFIDAVIT IN SUPPORT OF ACTION

John Doe VIII, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a citizen of the United States and have been since 1985, my social security number is (number redacted), my passport number is (number redacted). I was born on (date redacted), 1958 in Jerusalem. I currently reside in a suburb of Jerusalem, Beit Hanina, Alshkary district. I also have my own law office on the second floor of the (address redacted) in Ramallah, Palestine.

3. The source of your affiant’s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

4. From 1983 to 1993 I resided in the United States. The addresses where I resided were: (three addresses redacted) all of which are in Chicago. During that time I attended courses at Northeastern University and worked at my cousin’s supermarket.

5. Since leaving Chicago I have resided first, in the Satehmarhaba area of Ramallah, Palestine until late 1997, and at my current address in Beit Hanina.

6. I have been injured in a substantial regard, to either my person or my family members or my property, by Israeli forces on at least three occasions.

7. In September of 1997 I resided with my family at El Beira in the Satehmarhaba area of Ramallah. I resided there with my wife, Jill Doe XXVIII. At that time we had two children, Baby Doe XXX, who was then two years old, and Baby Doe XXXI, who was then one year old.

8. Somewhere between five and ten soldiers of the Israeli Defense Forces, armed with M-16s, came to our home and demanded that my family and I come out into the hallway of the building. The soldiers appeared nervous. There was no reason given for this demand and when I merely asked why they were ordering us to do this, at least one soldier became angry. I was holding my daughter Baby Doe XXX in my arms at the time. Despite that, the soldier pushed me and struck me in my shoulder. I fell to the ground as a result of his blows, and just managed to keep the baby from any injury. None of the soldiers would tell me why they were making this demand but after being hit and knocked to the ground, I complied with all their orders. The soldier had hit me in front of my entire family and they were terrified, and they accordingly complied. My injuries required medical attention. None of us were accused then or any time later of having done anything criminal, threatening or wrong. Moreover, I have never been affiliated with any political organization or accused of any wrongdoing.

9. Several soldiers then occupied our apartment. My family and I were not permitted to leave the hallway area. During the course of the night we could hear firing coming from our apartment. We were not permitted to go back into our own home even to get milk or juice for my daughters. In fact later in the evening, at around 11:00pm I asked one of the soldiers if I could get milk for my children and he roughly pushed me away. We were also not permitted to go elsewhere for juice.

10. The following day, a friend of mine, having heard of the situation came and spoke with the soldiers. My friend was a United Nations representative and only through his efforts were we even permitted to leave the hallway area and stay with friends. The soldiers themselves refused to vacate our home. They stayed there for four or five days. It is my understanding that throughout that time they continued to fire guns from our home.

11. The soldiers ruined our apartment and many of our possessions. I was never offered or given compensation of any kind for my personal injuries, for the use of our home, or the possessions ruined. I reported this incident to the United States Embassy. A woman took all my information, and viewed photographs I had and my medical records. She seemed sympathetic to me and my family’s suffering, but I have never heard from them since. I also have never received an explanation for why my family was mistreated this way or why our home was taken over.

12. In February 2002 I owned a 1995 Chrysler Neon. I parked it in the parking lot behind what was the Uncle Sam restaurant in Ramallah. Several other cars were parked there as well. Israeli forces using rocket fire, apparently firing at a nearby building, hit and destroyed my car. Its value was worth several thousand dollars in United States currency. Other than the Israeli forces firing, I heard no other gun shots in the area at that time.

13. Finally, during the Israeli incursion in April of 2002, all of Ramallah was closed for most of the month. As stated in paragraph 2 of this affidavit, I have a law office in (address redacted) in Ramallah. My practice is drafting and reviewing commercial contracts for businesses and advise them in their work related to the Palestinian Trade and Commercial Ministry. Given that I live in Jerusalem I was unable to go to my office during the incursion.

14. In addition, during the incursion Israeli soldiers entered my office and destroyed all of the furnishings necessary to the ordinary operation of a law office. They include but are not limited to a computer, a printer, and a copy machine. In addition personal items were destroyed, my case files were thrown about the room and there was considerable damage to the walls and doors of the office. Although I did not see the soldiers entering or breaking these items, I have spoken with Charles Doe XXXIX, a janitor for the building and Charles Doe XXXX, an attorney with offices below mine and each saw the Israeli forces enter my office. They heard loud crashing noises, and saw the IDF leave sometime later; both also say that no other persons entered my offices before or after the visit by the IDF. Some time later I saw the results of their actions in my office and the extent of the damage as described above.

15. I have never been informed as to the reason for entering my office. I have never been informed of the reason for destroying my office. The Israeli forces knew or should have known that the type of practice I have would not have contained any information or evidence of wrongdoing by anyone.

16. I estimate that the damage to my office, the doors, printer, computer and other furnishings costs seven thousand dollars ($7,000.00) United States currency. I estimate that prior to the incursion I was earning two thousand five hundred dollars ($2,500.00) United States currency per month. I was unable to use my office for the entire month of April and most of May.

17. The cumulative effect of these damages is pervasive. My two children, Baby Doe XXX and Baby Doe XXXI were there when the soldiers took over our apartment in September of 1997. My children saw the soldiers hit me. The effects on them are still manifest. Baby Doe XXX, then age three, has shown since then a marked fear of Israeli men, anyone speaking Hebrew, or persons in uniform. With near constant IDF activity in the past year, she is in a near-constant emotional state of panic, remembering the day her father was holding her and was struck and humiliated by the soldiers. Even now she has nightmares, and upon waking is obviously distraught and asks if the soldiers are coming. Both my children worry at the appearance of any Israeli forces and are reluctant to go outside.

18. As can easily be imagined, entering my law office, destroying all of the necessary equipment, rooting around in my case files, and throwing them about the office, has, as a necessary consequence, severely hindered my ability to effectively represent my clients. Moreover, given the type of practice I have, and given also that there has never been so much as the suggestion that my practice involves anything or anyone harmful to the Israeli people or government, it is hard to imagine any basis for this wanton destruction other than for its own sake.

19. At the present time no civil authority exists in the Dearbwn section of Ramallah, as the government of the Palestinian Authority, its ministries and police services, has been completely suppressed. To the best of my knowledge, there is no governing Israeli military police authority in Ramallah to which I might make any official complaint, as the city is still under siege and is an active military combat zone. Moreover, it would be completely futile for me to bring any claim in any Israeli court seeking justice for my injuries. Palestinians have little or no standing in Israeli civil courts for the Israeli government’s activities in the occupied territories. Although several treaties and charters of international law apply to my status in the occupied territories, I am not recognized by Israeli courts and there are no meaningful remedies or relief the I can seek through Israeli courts.

20. Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this law suit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: _________________________
on this ___ day of______,2002
_____________________________________________

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AFFIDAVIT IN SUPPORT OF ACTION

John Doe IX, being duly sworn, deposes and says:

1. I have retained the law office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a citizen of the United States, and I currently reside at (number redacted) Post Office Street, post office box (number redacted), Ramallah Palestine.

3. I submit the herein affidavit in support of the above-entitled action.

4. The sources of your affiant=s information and belief are: first hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I was born in Bogota, Colombia on (date redacted), 1952. My social security number is (number redacted). My passport number is (number redacted).

6. I graduated from high school in the United States. I attended college at Loop College in Chicago and completed my college education at the University of Illinois where I received a Bachelor of Science degree in Biology.

7. I have been living in Palestine since 1998. I live with my wife, Nina and five children: (names redacted: ranging in age from three months to nine years). My wife and all my children are also United States citizens.

8. I own a jewelry store on (name redacted) Street in Ramallah. During the Israeli incursion the Israeli forces shelled this area frequently, although there was no other fighting, and no shooting by Palestinian people. As a result of the shelling sometime between April 3 and April 7 the store windows of the jewelry store were destroyed. In addition, I had a restored 1976 Peugeot parked outside. Sometime between April 14 and April 21 it was side swiped by an armored personal carrier and a few days later several infantry soldiers forced open the doors and trunk and took personal items from inside. In addition they smashed the radio, the windshield and side windows.

9. Several buildings near where I live were targeted by Israeli forces during the incursion. For instance, the Municipality City Hall, which is the offices for the civil administration of the area, is approximately twenty yards up Post Office Street at Municipality Street. The Chamber of Commerce Building, which is an organization of private businesses, formed to promote business in the Ramallah area, is some fifty yards from my home. Also fifty yards away is a Jordanian bank that was destroyed.

10. Through the month of April, during the invasion, there were several occasions when there was intense Israeli military action outside my home. These actions would occur at any time and were of varying duration. At times, tank fire would last for several hours. At other times .50-caliber machine gun fire would strafe buildings on my block. Routinely Israeli forces used explosive devices to open entries into or to destroy nearby buildings. Finally, on at least one entire day two or three helicopters hovered over our home launching rocket fire continuously for the entire day. These actions would occur even though there was no resistance from the people

11. The emotional damage of these combined actions can hardly be estimated. It is an understatement to say that all of my children have been deeply impacted by this. All are jumpy, nervous and irritable. All suffer from nightmares of soldiers. They play games in which they imagine that they are soldiers shooting at each other. They use Lego building blocks to construct buildings and then using sounds imitating helicopters, saying Ahere comes an Apache.@ Then they knock the Lego building down. Many nights now (child’s name redacted) wakes up screaming. When I ask her what she is dreaming she says that she does not know. My five year old, (name redacted) now wets the bed with some frequency. Their trauma can also be seen in their reactions to otherwise ordinary events. For instance, on June 5, 2002 there was a truck up the street. People were loading gravel and rocks on it. Inexplicably, my son, (name redacted) ran to me yelling AThey=re shooting. They=re shooting.@ it took several minutes before I could calm him down. Prior to April of 2002 my children did not have these types of anxiety, trauma and fear.

12. I estimate the monetary damage as follows. All amounts are in U.S. dollars. Store damage two thousand eight hundred dollars ($2,800.00). Prior to the incursion I estimate retail sales at two hundred fifty dollars per day ($250.00) Car: two thousand five hundred dollars ($2,500.00).

13. At the present time no civil authority exists in Ramallah, as the government of the Palestinian Authority, its ministries and police services, has been completely suppressed. To the best of my knowledge, there is no governing Israeli military police authority in Ramallah to which I might make any official complaint, as the city is still under siege and is an active military combat zone. Moreover, it would be completely futile for me to bring any claim in any Israeli court seeking justice for my injuries. Palestinians have little or no standing in Israeli civil courts for the Israeli government=s activities in the occupied territories. Although several treaties and charters of international law apply to my status in the occupied territories, I am not recognized by Israeli courts and there are no meaningful remedies or relief the I can seek through Israeli courts.

Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this law suit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: _________________________
on this ___ day of______,2002
_____________________________________________
JOHN DOE IX

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AFFIDAVIT IN SUPPORT OF ACTION

John Doe II, being duly sworn, deposes and says:

1. I have retained the law office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a citizen of the United States and reside in Patterson N.J. In addition, I have a valid Jordanian passport and have had one since 1972.

3. I submit the herein affidavit in support of the above-entitled cause.

4. The sources of your affiant=s information and belief are: first hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I, along with several family members, all of whom are United States citizens, own fifty dunums (or about fifteen acres) of land in Deirnitham, Palestine. This land has been owned by my ancestors for approximately 1,600 years. Even before the creation of the state of Israel, under the British Mandate we received a declaration reflecting my family=s ownership of this land.

6. In the late 1970s the Israeli government began construction of the Halamish settlement. At that time Arabs from Deirnitham village were farming there, and using the open space for recreation. The settlement was constructed just to the boundary of my family=s land. Apprehensive at the actions of the incoming settlers, and at the construction of the settlement itself I wrote the American Consulate, the State Department, the Secretary of State and then President James Carter. I was given assurances at that time that the settlement would not take my land.

7. In 1995 or 1996 the fence around the settlement was moved onto my family=s land and expanded the Halamish settlement, taking at least four and perhaps as many as eight dunums of our land. (There are almost four dunums to the acre.) This land was taken without any form of notice. It was taken without any form of compensation, and in no way with any permission. I sought the return of our land in two ways: first, I lodged a formal complaint with the Committee for the Defense of Land, which led to an Israeli attorney being appointed to represent me in this matter. I have called this attorney on numerous occasions and have never been informed what if any action has been taken in this matter.

8. Secondly, I made a complaint to the Israeli police. I went there on at least six occasions. I supplied them with copies of the deed to the land that clearly showed my family=s ownership. Each time I have gone I have been told a different story. On at least one occasion I invited the officer in charge to come with me and I would show him the land that had been taken. The officer declined the invitation.

9. During this time I was the Head of (name of organization redacted) and was able to make informal inquiries and requests of my government. I also formally notified the United States government of this illegal taking. Despite my efforts no action has been taken in this matter. Instead, men and woman that can not possibly make any claim of legitimate occupation continue to use and enjoy the use of my family=s land.

10. In 1996 I was standing on the part of my land which the settlement had not taken. I was looking at the fence constructed which took the part of my land as described in paragraph 7. At that time an Israeli settler came to within twenty meters of me. He was standing on my land that had been taken. He yelled at me in Hebrew. I do not know Hebrew and said so in English. In English he said Aif you don=t move I am going to shoot you. This is my land.@ at that point he raised a gun and pointed it at me. I had no gun. I looked around to see if there was a place for me to run for safety. The land there is very flat. My car was not far away so I walked over to it and made a phone call on my cell phone. I called the American Embassy, and yelled loud enough so that the settler could hear that I am an American citizen and that I was making a complaint to the embassy. The settler yelled something at me that I did not hear or understand. He then threw a stone at me and very nearly hit me.

11. On another occasion I was with my then-five year old son, Baby Doe VI, also an American citizen, and a niece and nephew. We were walking on our land. An Israeli security officer of the settlement, obviously armed, came to the area and yelled at me, ordering us to leave. The children were obviously frightened, it was clearly not an appropriate time to debate with him. We left the area. I cannot emphasize enough that both of these events occurred when I was standing on my own landCproperty owned by my family for more than one thousand six hundred years. Each time I was threatened by people who have no legal right to be there, who were standing on land that they took from my family, and that they threatened me with imminent deathCa very credible threat, in that they possessed guns, and it is well-known in this area that settlers are prone to violence against Palestinians. Although I have formally complained of these events, no action has ever been taken that I am aware of.

12. In late May of 2001, I was in my house with my then-nine year old son and other relatives. It was near sunset. We could hear a commotion, and we could see fires outside the window. I could see that between 15 and 20 settlers were near our house, on my land. They were setting fire to our trees and other parts of our property, and throwing things. But then they started shooting guns at the house. I could hear bullets ripping into our home. I could see that the settlers were surrounding the house, and they were breaking my windows, with stones, sticks, rifle butts and gunfire. As this horror was developing I called the United States Embassy and after a series of calls at least six cars of Israeli soldiers came and made the settlers go away. I have never heard of any prosecution being attempted or initiated against the people that did this. I have never been offered or received any kind of compensation for this. I did bring this matter up with the attorney that was assigned to represent me as indicated in paragraph 7.

13. As of June 13, 2002 settlers from the Halamish settlement began bulldozing my family=s land. I spoke with witnesses there on June 30th who told me that the settlers are presently constructing two parallel roads across my land, adjacent to the expanded settlement.

14. I can not overstate the trauma to my son, now ten years old. Baby Doe VI had been a straight-A student. In the Palestinian education system a student must achieve scores of between 95 and 100% in order to be called straight- A. His grades have now dropped markedly. He used to be interested in television shows like Bugs Bunny. He now is interested only in news. He can tell me at any time which cities are under curfew, what cities are suffering a new incursion. This is the kind of knowledge one expects and sees in adults in Palestine. It is immeasurably sad for a ten year old to be driven to seek such knowledge. He frequently suffers from nightmares. I have, until recently, had to have him stay here in New Jersey.

15. In addition to the land described above I own land along the main road from Ramallah to Abud. I grow olive trees on this land and it is a tract that is next to a tract owned by my cousin. He also grows olive trees. On October 2, 2000 and on two subsequent occasions over the next few weeks, Israeli settlers entered onto my land and destroyed many of the olive trees, in preparation for another expansion they are presently carrying out. Between my land and my cousin=s they destroyed 108 trees. Olive trees can typically live and bear fruit for up to three hundred years, and it takes a full generation, about thirty years or so, before juvenile trees become useful and bear enough fruit.

16. Several weeks after this destruction I was picking olives from the trees that weren=t destroyed. I placed the ladder against a branch and climbed up. I did not know at the time that the branch had been partially sawed through, and as I climbed up, the branch broke and I fell to the ground, badly twisting my arm and leg. I was unable to continue harvesting for two weeks.

17. In March of 2002 I was driving my car. I was halted by armed settlers. They had three cars, two of which appeared to be of a military kind. They were armed with rifles or machine guns. I was unable to determine which settlement they were from. They demanded my identification. I gave them my United States passport. They had me sit in my car while they had a conversation with each other. At least one of the settlers, who seemed to have a hump on his back, approached me and showed me a knife that was approximately 40cm long. He stated that if he saw me again he would slash my tires. After about an hour they ordered me to move my car several feet forward. I complied and they made me wait another hour, to no apparent purpose. After another hour they had me proceed to an Israeli check post. Eventually I was permitted to proceed.

18. On April 2, 2002, I was driving westbound on the Deirnitham-Aboud road, going to Aboud for a funeral. My cousin, an American doctor, was accompanying me. Without warning or cause, we were fired on by Israeli soldiers. Bullets struck the road around our car.

19. I have never so much as been accused of a crime. No one has ever suggested that I have been involved in any act of violence against another person or their property.

20. I came to the United States in 1977 and attended Montclair State College where I received a M.A. I marrried in 1982 and naturalized. Later I attended CUNY and received a Ph.D. in Urban Studies. I am currently employed at (name redacted) University in Nablus, Palestine where I teach Urban Geography.

21. Because I live in the occupied territories, and inasmuch as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of being singled out by these forces in retaliation for my complaints and this law suit. Accordingly, I ask for an order of this Court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this Court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family or our property in retaliation for this suit.

Dated: __________________________
on this _____ day of____________,2002
__________________________________________
JOHN DOE II

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AFFIDAVIT IN SUPPORT OF ACTION

John Doe VII, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013. 2. I am a United States citizen.

3. I submit the herein affidavit in support of the above-entitled cause.

4. The sources of your affiant=s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I was born on June 10, 1955 in the town of Maithalun, near the city of Jenin, Palestine. I finished high school there.

6. I came to the United States in 1978. I attended the American Islamic College in Chicago and graduated with a B.A. in Islamic and Arabic studies in 1988. I am currently employed as the office manager of the (name of employer redacted) of Illinois.

7. My wife, Anadel, is also a United States citizen.

8. The fist time I visited Mathalun after coming to the United States was in 1993. On that visit there were no problems.

9. On March 18, 1999 my wife and I went to Mecca to perform the pilgrimage. On April 5 of that year we went to Jordan and visited with my brother, Riad, and my sisters, Muhadia, Lutlufia and Huda. We visited with them until April 26.

10. On April 26, intending to visit my mother, Sada, and father Mohammed, in Maithalun, we went to the crossing point of Allenby Bridge. We arrived there at approximately 8:00am. I went to the Israeli checkpoint because I have an American passport. My wife was not yet a United States citizen so she went to a separate checkpoint.

11. The Israeli authorities detained me at the border. They never told me a reason for this. I was held there in handcuffs for fourteen hours in a detention room and the officers would not tell me what had happened to my wife. At one point when I asked what was happening to her, one of the officers said AAre you sure she is your wife. Maybe she is 80% your wife.@ I believe he intended to insult me in the gravest manner by this remark.

12. After fourteen hours they took me, in handcuffs, to the Jalameh prison near the city of Haifa. I was shocked. I was thrown into a small, filthy and smelly cell. It was four feet by eight feet. The overhead lights were extremely bright and on twentyfour hours a day. The blankets were very dirty and smelly. The toilet in one corner of the cell was very dirty and smelly. The fan on the ceiling was noisy. Sleeping under those conditions was impossible.

13. I was not able to receive word of my wife until the second day I was held. On that day Mr. Todd Haskell, the American Counsel in Tel Aviv visited me. He was able to tell me that my wife was fine. I thought that finally this nightmare would end, that he would take me to my family. He said, however, that this was a matter between me and the Israeli government and that he could not get involved. He gave me a magazine and left.

14. I was continuously subjected to the most outrageous torture. The food was foul. I was given meat that looked like it was rancid. I was given boiled eggs at times. I tried to eat one boiled egg once and became ill. I did not eat any more eggs. Instead I ate only bread and tomatoes.

15. I was subjected to interrogation every day for several hours each day. Most times I would be interrogated for a few hours, returned to my cell for only a few minutes only to be brought back for further interrogation. They knew a great deal about my life and so it was incomprehensible to me that they were insisting that I was involved in illegal activities. I had never been accused of any wrongdoing ever.

16. Despite this I was repeatedly questioned as to what machine guns I was trained on. I have never even touched a bullet or any kind of gun. They demanded to know what bombs I had learned to make and I told them that I knew nothing of any kind of bomb. They insisted that I had given money to terrorist groups and I have no idea, even to this day, what they were talking about. Despite my constant denials, and despite my pointing out that I am an American citizen, the officers persisted in these lengthy sessions.

17. A few days after I was first held I was taken to the interrogation room. There was a chair there. I was handcuffed behind my back, through the seat. My feet were then tied and the chair itself was tied to the ground. It made movement impossible. At that time a small and putrid hood was placed over my head. The hood was made of a material like khaki. Between the stench and the material it was very hard to breathe through. At the same time music was played at an intolerably high volume overhead. I was kept in this position for at least three hours. I have learned that this treatment is called AShabah.@

18. On another occasion I was interrogated by a man that identified himself to me as Mizrahi. He was like a tough-guy. He shouted at me almost all of the time. At one point I stated to him that I am an American citizen. He stated to me that AYour mother is shit. Your father is shit. America is shit.@

19. When I was not being interrogated and subjected to these tortures I was kept in the small cell. The cells were always horrid. They were most often lice ridden, always small and always dirty. The blankets were always dirty, and they too were lice ridden. The worst cell was no larger than three feet by seven feet. As with the other cells a bright light blazed overhead. The dimensions of the cell made it seem very much like a grave.

20. Whenever I was brought to the interrogation room I was handcuffed and had either the hood placed over my head or dark glasses so that I could not see where I was going. I was often woken at odd hours. Sometimes this was to take me to the interrogation room. Sometimes this was just to wake me up.

21. After many days the officers stopped questioning me. Instead I had to stay in the cell for entire days on end.

22. At one point, after a few weeks, I was feeling severe pain in my back. I asked guards several times to take me to see a doctor. Each time they said Alater, later.@ Finally after repeated requests they took me to a doctor. He wrote what I took to be a prescription. It was in Hebrew and he handed it to the guard. Whatever the note was I never received any medicine.

23. During the first few weeks that I was held my family hired an attorney. His name is Mr. Faris Abu Hassan. He was able to visit me twice in the prison although we never appeared in a court.

24. My family was never permitted to see me.

25. In late May I was taken to a place called AMe ebaar@ (the waiting place). There I was held with approximately ten other men. None of us knew what would happen with any of us. Some were taken to regular jail. Some were released. Some waited months.

26. On June 1, 1999 a guard called my name. He ordered me to get ready immediately. He told me I was going to Jerusalem. I thought they were taking me to the Supreme Court in Jerusalem so that my lawyer could convince a judge to release me. I was taken by truck from the prison to Jerusalem. I was chained to another prisoner in the truck.

27. I was wrong about being taken to court. Instead they took me to the Moscobiya prison in Jerusalem. When I got there I was forced to strip naked and they searched me. I was not told what was to be done with me and I spent the night there.

28. On June 2 a guard told me that I was to be expelled back to the Allenby Bridge. I was again taken in the back of a truck, my foot chained to another prisoner=s and driven to the Allenby Bridge. There the Israeli authorities handed my American and Jordanian passports to the Jordanian bus driver, and told him to give them to the Jordanian authorities.

29. Shortly after I was released I went to the United States Embassy in Jordan with my American passport. The officer there did not pay much attention. He said AWe know about it and we can=t do anything about it.@

30. In total, I was held for thirty six days. I was never charged with any crime or offense by the Israeli authorities. I have never been accused of any crime by anyone, nor have I ever participated in any organization that has committed any crimes.

31. My parents still live in Maithalun. I am unable to even imagine trying to visit them. When we talk on the phone they cry and I cry. This is not only where my family lives. It is the place where I was born and raised. This has removed me from the structure of my family. My sister, Awina, who was living in the West Bank, has passed away since I went through this. I was never able to see her again.

32. I still experience a real sense of fear from this outrageous event. In addition, I have chronic pain in my knees. They were swollen from my being detained, in part due to the conditions, in part due to the minimal nutrition. The pain in my knees is an on going discomfort to me.

33. Because my family lives in the occupied territories, and in as much as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of their being singled out by these forces as retaliation for my complaints and this law suit. Accordingly, I ask for an order of this court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well founded fear that military and security forces of Israel will harm me, my family and our property in retaliation for this suit.

Dated: _________________________,
this ____ day of ______, 2002.
__________________________________
JOHN DOE VII
Sworn to before me on this ______ day
of ______2002, in_________________.
_______________________________,
NOTARY.

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AFFIDAVIT IN SUPPORT OF ACTION

JOHN DOE VI, being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a citizen of the United States.

3. I submit the herein affidavit in support of the above-entitled cause.

4. The sources of your affiant=s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I was born on October 1, 1971 in the town of Silwad which is near the city of Ramallah in Palestine. Many of my family members still live in or near Silwad. They include my father, also an American citizen and several aunts, uncles, cousins, nieces and nephews. I currently live in Orlando, Florida.

6. In 1989, I moved to Florida and lived with my brother Charles Doe V in Miami Beach. My brother had a restaurant, (name redacted), in Miami Beach, which served American food. I worked first as a dishwasher and later became a general manager.

7. I married and had a son in 1991. My son=s name is Baby Doe VII. I became naturalized in 1994.

8. In early 1998 my brother and I went into business together and opened a pizzeria, (name redacted) in Miami.

9. The business I had opened with my brother was doing reasonably well by October of 1998 and I decided to visit my family in Silwad. I flew to Ben Gurion airport in Tel Aviv on or around 15 October 1998. By that time I had visited Silwad three times before and had never had any problems whatsoever. As in times past, I was able to go to Silwad and visit with my family without incident. I visited with them for between 12 and 14 days. There were no incidents or problems during that time. I did not do anything improper or illegal while I was there.

10. On October 28 I went to visit with my sister Jill Doe VI who lives in Amman, Jordan. I went there via the Sheik Hussein/Allenby Crossing border post, where I paid my exit taxes and fees, and presented my United States passport. I was told to wait, which I did. All of the officials in the area who told me to wait were Israeli police or soldiers. I was made to wait for two hours without explanation. After approximately two hours, two officers escorted me to a room and searched all my luggage and reviewed all my papers. They left me in that room for another two hours.

11. I became very hungry and called out to tell them so, and to learn why I was being held. A woman officer came in, I believe her name tag indicated that her name was Smith, she seemed to be in charge, she stated to me that I was under arrest. I said Ayeah, right.@ I thought she was joking, and she stated that she was serious and that I was actually under arrest. I asked her what the charge was, and she said that I was a member of a terrorist organization. I was incredulous and asked how this could be. She would not provide me with any information from which I could understand this accusation. She would not say what organization, what I was supposed to have done with any organization, nor when I was supposed to have done anything.

12. At that point at least two officers pointed guns at me. I stated to them that I am a United States citizen and asked to call my embassy or consulate. She said that I could not. I asked if I could at least call my family. She said that I could not. Instead, one of the officers put papers in front of me and said that I should sign them. They were in Hebrew. I am unable to read Hebrew. I asked what these papers were. They told me that it just says that I am under arrest. I refused to sign the papers. The officers then spoke to each other in Hebrew and then took the papers away.

13. Some of the officers left the room and I was left there for awhile. I did not understand what was going on and became increasingly alarmed. I could not imagine how I could be thought to have ever done anything wrong. I had been held for several hours at that time and I began to worry that they were going to kidnap me. I saw some tourists passing by, I could see that they were Italians and I spoke to them in Spanish. I said to them, AMy name is John Doe VI. Remember my face.@

14. Officers then came in and shackled my legs, and handcuffed me. They put me in a jeep and had me hold my luggage. They had their guns pointed at me. They drove me to a jail, which I believe was in the city of Jericho.

15. When they took me to this jail I again asked if I could call the United States Embassy or Consulate or if I could call my family. The officers laughed at me. They then put me in a small, dirty cell where I was held for about two hours. 16. After two hours the officers came in and again shackled my legs, and this time blindfolded me. I was taken out to a small car and I could sense that we were traveling at a high rate of speed. The radio in the car was blasting, playing Rock and Roll music. They drove me for about two hours. At times during this trip I again stated that I am a United States citizen and asked to call my embassy or consulate. These requests were refused.

17. Finally, the car ride stopped and my blindfold was removed. I asked where we were and they answered that we were in Jerusalem. In my mind I kept thinking this was all a horrible mistake and it will all be cleared up soon. I kept thinking that if only I could call the embassy everything would be straightened out. They took me inside of a jail where they videotaped me. I objected to this. An officer that spoke Arabic said to me that this was the problem of the Shin Bet. He said AYou just have to do what you are told. You are now in the Makobiya Prison.@ I had heard of this prison as a place where people were tortured. I became very worried at this point.

18. I was taken to a holding room where a guard ordered me to strip. I took off my clothes, down to my underwear. He demanded that I take that off. I said he would have to kill me first. He said Aokay.@ I was then shackled again. He placed a hood on my head. The hood was rank. The smell was very strong and it was very foul. I suspected the odor was of vomit and urine. The officer was able to grip the hood and pull me around by it. Between the foul odor and being pulled around this way, the experience was deeply humiliating. After jerking me around for several minutes he removed the hood and I could see other prisoners that I later learned were being held for non-political offenses.

19. I was taken to a doctor. He asked if I had any medical problems. I told him that I have chronic ear pain from an injury while working. I explained that I need a special pillow which I always take with me when I travel in order to sleep. The doctor and the officer laughed at me. One of them said, AWhat do you think? You are at the Sheraton?@

20. The officer then placed the hood back on my head and led me to another room. There was a chair in this room. I had to sit in the chair. The officer took one of my hands, behind my back, and placed my hand through the slats in the chair. He took my other hand and, behind my back, placed it over the back of the chair. He then cuffed my hands in this position very tightly. He then shackled my legs together and anchored then to a hook in the floor. This made any movement impossible. The hood made breathing difficult and offensive. In the first place the fabric of the hood impedes breathing and then the wretched odor made breathing ever so difficult. I have been informed that the manner in which I was bound is referred to in Arabic as Ashabeh.@ I understand the Israeli=s call it AModerated Physical Pressure@.

21. I was forced to remain in this position for three days. The only relief was that at one time during the three days I was taken to a bathroom.

22. During the first day that I was held in this position a man came in and removed the hood from my head. I saw that there was a desk with a computer in the room. The man introduced himself as Shouki. Based on conversations I have had since then, I believe that his real name is Cohen and that he has worked in the prison for twenty years.

23. Whatever his name, I asked him what I was doing there. He said ANo. You are going to tell us what you are doing here.@ I told him that I had done nothing to merit being here and asked that I be permitted to make a call. He refused my request and asked me if I had heard about a law called AEmergency Law.@ I told him that I had read about it in the newspaper. He told me that I should know that my being an American citizen meant nothing. He said: AWe can do anything we want with you.@ He then held up my passport and said AThis passport doesn=t mean anything to us. We are America. You are going to die in here.@ I asked him what he wanted from me. He stated that he wanted information about fund raising at my restaurant. The only thing I could think of was that when I was a manager at (name redacted), around 1996 or 1997, I agreed to help an African-American Muslim group to raise funds to build a mosque.

24. He then asked about a contribution I had made to a charitable organization, which permitted me to sponsor a disabled child overseas. I made the contribution and considered it my responsibility to help children, and so I provided $25.00 a month to help the child. As arranged, the child and I exchanged letters. I told him that I have no reason to believe that my contributions were ever used for anything other than to aid the child. He asked me several questions about the organization, like how was I contacted by them. I told him they had sent a fund raising letter to me. He asked if I knew the president of the organization, and I told him that I did not.

25. He also asked me many questions about whether I belonged to a terrorist organization, and he asked if I was hiding anything. I told him that I did not belong to any terrorist organization and that I was not hiding anything. I also told him that my life is an open book. At the end of his questioning he said that if I would not talk, the next day he would get someone who would make me talk. 26. Before he left the room the man put the foul hood back on my head and turned the air conditioner on at full blast. In only a short while, not even an hour, with the air conditioner on full, unable to move at all I felt like I was in a snowstorm with almost no clothes.

27. I cannot adequately describe how terrifying, how constantly painful over my whole body this was. I was held in this position for three days. Once in awhile a person would come in and ask who I was. After three days I felt I was losing my mind. I began screaming from the bottom of my lungs. I was finally released from the chair but kept in the room, the air conditioner still blasting at full. My hands were so badly swollen it was like they were balloons. I had no feeling in my hands and knew that I had not had any feeling in them for a long time. I was afraid that I might totally lose the use of my hands.

28. Food was brought to me in the form of a plastic bag that contained one tomato, one cooked egg, and four slices of bread. I was not given anything to drink.

29. The fourth day of my captivity another interrogator came to the room. He asked me Awhat are you doing here.@ I asked him what I was doing there. I was then taken to a cell. It was approximately six feet by six feet. There was a dirty mattress on the floor and a hole in the floor in the corner for a toilet. I was given some water.

30. The next day I was taken to another room. It seemed to be a kind of courtroom. A woman was there who seemed to be a judge. No one identified themselves to me or announced any official proceedings. I told her how I had been detained. I told her that I was a United States citizen. She spoke through a translator and said that I would be held 15 days. I asked her why but she did not answer. There was no attorney there for me.

31. I was brought back to the cell and a few hours later taken to a room with two people from the United States consulate. One was named Abdel Noor and the other I only was told Majed. They told me that they had been notified that day of my detention. I explained my situation. They commented that they could see the effects of the torture I had been through. I assumed they would take me out of there but they said they could not. I asked them to get the torture to stop or take me to another facility. They told me that if I signed a Aprivacy waiver@ they could visit me. My heart was breaking, and I was angry. I said to them that AMy government can=t help even though there are no charges against me?@ They replied that there was nothing they could do. It was only during that conversation that I was able to determine what day it was.

32. I was taken back to the cell and held in isolation for the next ten days. There were no windows in the room. I was fed for the next ten days the same way I had been before. A plastic bag with bread, vegetable and an egg. It was from these bags that I could mark the passage of time. The bags were bags used for bread. They had the ingredients printed on them and I read over and over and over again the ingredients in the bread.

33. After ten days in isolation a guard came and said that I was free to go. That was a lie though, told just to torment me. Instead, I had a visit by a woman from the Red Cross. I think her name was Mary Lourdes. She said that she did not understand what was happening to me.

34. It is difficult for me to describe how terrifying this isolation was. The portions of food were small. There was only just enough room to stand. The walls were dirty. The overhead light was on for 24 hours a day. There was an air vent in the ceiling. It had 249 holes in it.

35. After fifteen days in isolation I was once again taken to the interrogation room. A man who said his name was Ahed was there. I later learned that he was a Shin Bet agent for the area around Silwad. He showed me an aerial view photograph of Silwad. I showed him where my house is. He asked me questions about other people that live in the area. I explained that I don=t know them since I have not lived there for ten years. He said that I look like my brother. He said that he knew my brother. I said, AThen you know I am okay.@

36. I am somewhat uncertain about the passage of time at this point. Some days later I was interrogated by a man who said that his name was Uri. He had a paper and a pen. He asked me questions about people I did not know.

37. Some days later a Palestinian lawyer came and told me that he had done an appeal for me, and that the appeal might help me. For the trip to the appeal hearing, my legs were tightly shackled. I was forced to run to the truck that would take me. The shackles cut into my legs. In the truck the hood was placed on my head again, and I was shackled in the back of the truck to a pipe. They then drove fast, with sharp turns. Shackled and hooded, I was thrown about wildly, the chains hurt my legs, and my head knocked against the van.

38. I was taken to a court at Betil. My family was there and when they saw me they started crying. At this hearing, the prosecutor said they had secret evidence. They showed something to the judge. The judge looked at it and I was taken back to the cell.

39. I had not been given any food that day. I began talking to myself. I thought I was going crazy. I yelled. I begged for water. They finally put some water in a bucket at my cell, but no cup. I used one of the bread bags to dunk in the water to drink from that.

40. While in jail, I would give me four cigarettes a day. It was almost like they wanted me to still want to smoke, but wouldn=t give me as much as I would normally smoke.

41. By this time I was seriously ill. I had a fever, had lost considerable weight, and had serious trouble standing, I also had a tightness in my chest. A guard came and gave me some cough medicine. I was glad to have something to drink.

42. My sense is that on the 23rd day that I was held the man called Uri and two other men interrogated me. Later, two policemen came in with papers and a picture they had taken of me a few weeks before. Uri held up the papers and told me it was my file and Athe order.@ It was written in Hebrew. He told me to sign it. I told him that I couldn=t read it and would not sign. They insisted. They said that I would have to go to jail for three months. I knew that I could not bear three months of this but I refused to sign the papers.

43. I was taken to a cell with other prisoners. A Palestinian guy told me that I would next meet the APrince of Jail@. I did meet the man called the APrince of Jail.@ He implied that he was a leader of other prisoners. He said that he could move freely in the prisons because the Israelis were afraid of him since he could call for a hunger strike. He stated that he believed that I was an informer of Shin Bet, sent here to spy on the other prisoners. He said that I better tell him who I was, and show that I am not a Shin Bet informer, and that if I didn=t they would kill me. I was appalled. ImagineCtortured by the Israelis, ignored by the United States, and killed by other Palestinians. The man had an odd watch. I was staring at it and he pulled his sleeve over the watch. He requested my name. He wanted to know if I was with Hamas, or if I was with Jihad. I told him I was not. He said he did not believe me. Other prisoners said that if I did not tell what they wanted to know, they would kill me. Eventually I wrote down my name, the pizzeria I work at in Florida. The man called the APrince@ was not satisfied and said that I would pay for that.

44. I have since learned that these men worked with the Israelis and were trying to get me to say that I do things I do not do.

45. Later that day a guard came and put the hood on me and tugged me by the hood down a hallway. We came to some steps that I obviously could not see. I stumbled down them, injuring my leg, and seriously cutting my arm. I felt that my arm was maybe broken. The guard cursed me and took me to a room. There was a loudspeaker in the room. He put it on at full blast right in my face, playing the same song over and over for hours. It was the Paul Simon song AYou Can Call Me Al.@ The guard said that most of the prisoners would not understand the song but that I would. At first I was shackled in a small chair, to a pipe behind me, and with the air conditioner on.

46. After a few hours I was taken to the interrogation room. I was shouting about the pain I was in, that I needed to see a doctor. A man there asked what was the matter. I told him my elbow was broken. He came over and pressed it. It sent a shooting pain up my arm. He asked if that hurt. I said that it did, and he said Agood.@ 47. A day or two later I was taken back to the interrogation room and placed again in the position with my hands cuffed behind my back and my legs shackled and anchored to the floor. Uri was there and he said ANow we=ve got you.@ He had the paper that I had written my name on and what I did at the pizzeria in Florida. He told me that he could give me life for this. I told him that he was disgusting. I told him that he was a coward, that they were all cowards to do this to me, and I told him that they could only do with me what God wants. I told him I had nothing to hide. He came over to me and said, AIf you aren=t going to confess, I will still go home, sleep with my wife, and come back tomorrow and you will confess.@ I was given no food that day.

48. I spent two days in the chair. This was the lowest point for me. I could only think of my son Baby Doe VII. Thinking of him. Thinking of how desperately I wanted to see him again: thinking of how he needed me, and how I needed to see him, was the only way I was able to survive.

49. On, I believe the twenty-sixth day of my being held I was taken to the woman judge again. She was wearing a military uniform. I begged her to release me. I told her I was dying, that I was fevered, that I had little to eat. She looked at me and said that I had to stay 15 more days.

50. For the next few days I was held in various cells with other prisoners. I could see how badly they had been tortured. One looked like he would have to lose his leg from being kicked in the shin repeatedly over several days. Another made noises like an animal. I did not hear him speak any language. In some cells I was able to hear men screaming. I assumed they were being tortured. One day I was placed in a cell alone that was filled with roaches. They were all over they place. I became ill.

51. I had one more interrogation with Uri. I told him that I knew that I would die in there and that I would meet him on Judgement Day.

52. Three or four days before I was released the two men from the United States consulate visited again. I was upset that they had done nothing for me. I was upset that they were never at the court when I had to go. I told them that they might as well come back in a few days and pick up my dead body. They wrote that down and left.

53. On the fortieth day a guard came. He put the hood on my head. He led me down a hall and took the hood off. I saw my suitcases. He said AYou can go. You better not cause us any trouble.@ I requested my passport and my money, which they gave me though they wrote in my passport that I need a Palestinian travel document to travel. Remembering how they tormented me by making me think I could leave and then saying no I suspected this was all a trick. It was not though. A cab came and took me to my family in Silwad.

54. We were all overjoyed to see each other. My family cried. I cried.

55. I could not walk well. The first night I could not sleep for fear that they were just playing a trick on me and would come and take me back. I stayed with my family a few days. Then I called the United States consulate to ask what this travel requirement was they put in my American passport. He told me that I better comply with what they required. I asked how that could be, when I have a United States passport. He said AYou have to listen to the Israelis.@

56. That restriction meant that I could not leave for another month or month and a half. I finally got back home in late January, 1999.

57. When I went there I weighed 182 lbs. When I returned I weighed 140 lbs. My hands finally seem to be fine though it took awhile for the swelling to go down. I now have chronic, sometimes disabling back pain from this, where I never had a back problem before. I suffer from depression, especially when I talk about this; it takes at least a week before I can recover. I have stomach problems. I feel bloated even though I have only eaten a little. My stomach also feels like it is burning. I have chest pains and a sense of being congested much of the time. I have also lost much of my hair.

58. I was never charged with anything. I was never convicted of anything. I never did anything. I have contacted numerous United States officials about this horror. I have never been given any explanation as why I was tortured this way. I have never been compensated in any way.

59. It is now impossible for me to visit my family members that live in Silwad. The land my parents owned has been left to my brothers and me. In fact, the house was specifically left to me. It is impossible for me to go there, though. I could not ever run the risk that I would be taken for no reason and subjected to the disgusting conditions, the torture and the grinding humiliation I was subjected to. 60. Because family members of mine live in the occupied territories, and in as much as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of their being singled out by these forces in retaliation for my complaints and this lawsuit. Accordingly, I ask for an order of this court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my neighborhood I have a well-founded fear that military and security forces of Israel will harm me, my family and our property in retaliation for this suit.

Dated: __________________________
on this _____ day of____________, 2002
_____________________________________________
DOE VI

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AFFIDAVIT IN SUPPORT OF ACTION

Jerri Bird, being duly sworn, deposes and says:

1. I am the President and founder of Partners for Peace, a non-governmental organization based in Washington, D.C. I am also an author and have published numerous articles on the role of women in the Muslim world and on the Palestinian-Israeli conflict.

2. I reside at_________________________________________________.

3. I submit this affidavit in support of the above-titled cause.

4. The sources of your affiant’s information are first-hand knowledge, observation, academic research, and interviews I personally conducted with officials of the U.S. and Israeli governments, and detainees and their families.

5. I am married to retired Foreign Service Officer Eugene Bird. I have lived in Jordan, Israel, Lebanon, Egypt and Saudi Arabia. In addition, I have traveled extensively throughout all the Arab world with the exception of Iraq and Sudan.

6. The mission of Partners for Peace is to educate the public about the issues in the Israeli-Palestinian conflict, with particular emphasis on developing productive relationships with the professional media.

7. For more than thirty years, Israel has repeatedly detained, tortured and incarcerated Americans of Arab origin, without suffering any sanctions or even a single public reprimand from Washington. A State Department spokesman confirmed on 2 April of this year that Israel was holding at least eighteen American citizens on “security” charges, and that the State Department has “no way of knowing for certain the numbers of American citizens who may have been detained for short periods and released.”

8. It is the legal obligation of every host government to notify the local diplomatic mission within 48 hours of the detention of a foreign national.

9. The Department of State publishes each year human rights reports on the countries of the world. For many years now, these reports have documented Israel’s violations of the human rights of Palestinians, documenting countless house demolitions, land confiscations, arbitrary arrests, and widespread torture. Many human rights organizations in Israel, the Occupied Territories and around the world corroborate these findings with their own research.

10. It is well documented that Palestinian detainees are routinely denied access to counsel, and are not permitted family visits. In addition, they are frequently subjected to interrogations that employ torture to extract forced confessions. They are then often “tried” before a single military officer by means of a hearing in a court established in a West Bank settlement. This disturbing process applies as well to many Americans of Arab origin who have been detained by the Israeli military.

11. I first became aware of the detention and torture of American detainees by Israel in 1998, when the case of Hashem Mufleh was brought to my attention. Mr. Mufleh, then eighteen years old and born in Albuquerque, New Mexico, had just finished high school in the West Bank and was returning to start college in Albuquerque, traveling with his mother and brother. He was seized at the airport by Israeli police, and subsequently jailed for more than a year. During this time, he was repeatedly tortured. My organization publicized Mr. Mufleh’s case throughout the U.S., and as a result, a dozen more cases were referred to me over the next few years. Partners for Peace has documented these cases of Americans tortured by Israel, and has investigated torture practices employed over the period of the Occupation in general. I know both John Doe VI and John Doe VII, two Americans whom I understand to be Plaintiffs in the above-titled cause of action, and whom I believe from my organization’s investigations to have been tortured detainees.

12. Typically, interrogations are conducted by officers of the General Security Service. Methods employed include overt beatings and “shabah,” or general practices of humiliation and dehumanization. Typically, a detainee subjected to “shabah” is handcuffed with their feet chained, forced to sit in a tilted, small chair tied to the ground, leaving them totally unable to move, while seated in an unnatural and painful position. They are then hooded with a filthy, small bag of a rough, thick fabric that is very hard to breathe through. Many detainees have reported that the bag was foul with urine or vomit. A prisoner may be left in this state while very loud music blasts overhead, for days at a time. Detainees are denied the use of a toilet for long periods. Some of the interrogation practices used by the security services involve psychological methods. For example, detainees are deprived of sleep for days at a time, kept in cells with bright overhead lighting and loud music; they are routinely threatened with death or the death or harming of their family members if they do not sign prepared confessions; they are stripped naked.

13. American detainees are routinely denied access to U.S. Consulate or Embassy officials, as well as to legal counsel, for long periods of time. For example, Jamil Sarsour, 51, an American citizen from Wisconsin, was arrested at Ben-Gurion airport in October 1998, and held 101 days before consular officials were permitted to visit him, during which time he was tortured. His own wife did not see him until another two weeks after that, and his attorney did not first see him in custody until Mr. Sarsour had been held for almost six months. Amjad Ahmad Farah Kur'an, a 21-year-old American from Ohio who was attending Bir Zeit University in Ramallah, was arrested in June, 1998, and held for two years without charges. He was tortured for a week after his arrest before any consular official was permitted to see him. He signed a confession during his torture that he now recants; this confession was the basis of his conviction, for which he is now serving a 52-month sentence in the Megiddo tent prison. Mr. Ku’ran has had only two family visits in two years, and his father was made to clean the prison camp toilets before being permitted to see his son.

14. It is my experience that few Arab-Americans are willing to go public with the details of their torture in Israeli prisons once they gain release and return to America, fearing that they will be targeted by the FBI as so many Arab-Americans have been, or reviled by their fellow citizens as possible security risks. Fear of U.S. reprisal has only increased in the aftermath of Sept. 11. In addition, some detainees, upon release from Israeli prisons, have been threatened by security agents with harm to themselves or their families if they speak out about what has happened to them.

15. Over the past three years, Partners for Peace has repeatedly raised the issues of Israeli torture and abuse of American detainees with congressional offices, the Department of State and the White House. Congressional offices are largely totally unresponsive. From State, we have received boilerplate replies that express regret but are not responsive to our requests for action. President Clinton responded in 1999 with the usual acknowledgment of "an obligation to protect all American citizens, regardless of where they may happen to be," and an assurance that this problem has been raised in the human rights report. He also said that Secretary of State Madeleine Albright had raised the issue at the highest levels, including then-Prime Minister Ehud Barak, whose response was that Israel had "no intention to humiliate or to intimidate any Arab citizens, be they Israelis, Americans or from other countries." Note that this is not a direct reply to the charge of torture.

16. My work during the past four years and the evidence I have compiled suggests that these cases are only tip of the iceberg. All these young men—and, in some cases, women—are extremely proud to be American and have been deeply offended by the official U.S. attitude in the face of their trauma. As John Doe VI has said, "I cannot believe that my government was powerless to take action on my behalf. Is it because I have an Arabic name?"

17. It is my belief that the origin of the unwritten policy permitting these abuses—commonly called the "special relationship"—cannot be pinpointed. But after the Israeli occupation of the West Bank and Gaza in 1967 following the Six Days War, there was a subtle but clear shift in U.S. policy, particularly with regard to the reporting from the consulate general in Jerusalem. That post has had a unique independent status since official U.S. policy deems Jerusalem an international city, not the capital of Israel. Initially, this status provided the basis for offering a different voice to Washington, one that reflected American officials' unique opportunity to observe both sides of the conflict on a day-to-day basis. But by the end of the first decade of occupation, Israeli sensitivities were already increasingly reflected.

18. My research into State Department records indicates that this new pattern was "codified" in the handling of a series of reports of Israeli torture, including the torture of two American teenagers as reported in an airgram (Jerusalem A-19, dated Oct. 9, 1978), filed by junior officer Alexandra Johnson in 1978. The brothers, Gamil Khalid, 15, and Gamal Khalid, 16, were subjected to beatings and thrown to the ground. In a written statement Gamil Khalid reported as follows: "They took me to a room and said to me, 'Sign this paper, and if not we will do to you like we did to Munzer [another detainee] and hit you in the eye and swell it up like his. We will bring border police and beat you in front of your father with a stick on any part of your body, and put the stick into your rear.' So I agreed."

19. The boys were eventually given several hearings (usually called a military court but devoid of any of the usual rules of evidence), and the "trials" were attended by two American consular officers. As Ms. Johnson's airgram reports: "One of the two was present at every session of the trial. It is the opinion of both of these consular officers that the Israeli military authorities made no real effort to investigate the charges of mistreatment. Indeed, both the military judge and the prosecutor made it clear throughout the trial that they considered the questions of mistreatment and coercion to be irrelevant and trivial. They also made it clear from the start that the trial's result was preordained."

20. According to the airgram, the consular section of the consulate general had sent over 40 reports on Israeli mistreatment of Palestinian political prisoners in Jerusalem and the West Bank to the State Department. In two later cables (Jerusalem 1500 and 3239, sent on June 3, 1978, and Nov. 30, 1978, respectively), Ms. Johnson detailed the treatment of Arab prisoners on the West Bank. She received commendatory letters from Arthur Houghton, an aide to then-Secretary of State Cyrus Vance; Pat Derian, Assistant Secretary of the Bureau of Human Rights and Humanitarian Affairs, and Deputy Secretary of State Warren Christopher, but was denied tenure in 1979 and left the Foreign Service. (I have been unable to locate her.) The report dated Nov. 30, 1978, was approved by both the consul general and his deputy, with the following note appended: "The post fully understands Israel's legitimate concern over security on the West Bank and accepts the premise that a military occupation regime may necessarily supercede the basic civil and human rights which are expected in a free democratic state living in a state of peace."

21. The institutionalization of torture practices by the Israeli government has been thoroughly documented by many international human rights groups. In my extensive research of the subject, I have learned that not only have the practices become standardized, but the Israeli government at the highest levels essentially approves of the methods used. B'Tselem (the Israeli Information Center for Human Rights in the Occupied Territories) reports the following: "Since 1987, the General Security Service (GSS) interrogators have tortured thousands of detainees, intentionally inflicting severe pain and suffering. The torture was neither extraordinary nor limited to 'ticking bombs.' Quite the opposite: torture was a bureaucratic routine; there was standard equipment for inflicting torture, and careful recording of the times the pain and suffering were inflicted. Even the state's response in petitions against torture repeated, paragraph after paragraph, the routine justification for what were supposedly extraordinary acts. Supervision of the GSS did not succeed in preventing torture in Israel from becoming routine, systematic and institutionalized."

22. A report by the Public Committee Against Torture in Israel defines the issue this way: "Israel's 32-year occupation of the West Bank and Gaza has given rise to patterns of legal proceedings that undermine the rule of law and the democratic values of the state of Israel. According to the latest official estimate, during the Intifada period alone (1987-1993), 30,000 Palestinians were interrogated by the GSS. Those mass arrests led to illegal interrogation, which usually included submitting the detainees to physical and mental pressure and torture and which, from the start, contradicted the Israeli Penal Code and the Israeli Basic Law of Freedom and Dignity. Moreover, this behavior has continued to take place with total disregard to the fact that in August 1991, Israel ratified the United Nations Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, which prohibits and denounces actions deliberately causing "suffering or severe pain."

23. According to Miftah (an Arab NGO headed by Hanan Ashrawi), since 1967the Israelis have carried out over 600,000 arrests or detentions. Both Miftah and B'Tselem concur that between 90 and 94 percent of those arrestees have been tortured. Even if we halve that number, that still means that some 270,000 individuals have been tortured. Or to put it another way: if that proportion were applied to the U.S. population, it would mean that more than 25 million cases of torture had occurred in the past 35 years.

24. There is clear evidence that the United States government has known for at least 24 years that Israel uses torture during interrogations of Palestinians and that the practice was widespread. Furthermore, the U.S. had evidence that American children were also subjected to this abuse. Yet, over more than two decades, no effective action has been taken by the United States to halt this practice. Furthermore, the United States took great care to avoid any public admission that Americans had been tortured.

25. Based on my research, it is my opinion that the “special relationship” offers the United States the opportunity to have enormous influence on the state of Israel. In addition to giving enormous amounts of aid to Israel, the U.S. has provided military resources that have helped make it the fourth most powerful fighting force in the world. Yet rather than using this special relationship in a constructive way, U.S. policy has become "Israel, right or wrong." Even when the lives of American citizens are at stake the U.S. does not intervene effectively to safeguard them. How can this disregard for our citizens be justified? This is not a question of guilt or innocence of the individual detained. The issue is torture.

26. As a concerned American, I believe that we share Israel's guilt in the commission of human rights abuses over a long period of time because we have allowed our friend to commit them. We are enablers. For the sake of our future and our national honor, and for the sake of peace, our "special relationship" must change.

Dated: __________________________
on this _____ day of____________,2002
_____________________________________________
JERRI BIRD
Sworn to before me on this ______ day
of ______2002, in_________________.
_______________________________
NOTARY

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AFFIDAVIT IN SUPPORT OF ACTION

JOHN DOE XVII being duly sworn, deposes and says:

1. I have retained the Law Office of Stanley L. Cohen to represent me in this action. His office is located at 351 Broadway, Suite 300, New York, NY 10013.

2. I am a resident alien of the United States and expect to obtain citizenship status in the near future.

3. I submit the herein affidavit in support of the above-titled cause.

4. The sources of your affiant=s information and belief are: first-hand knowledge and observation, and discussions with witnesses to the events complained of herein.

5. I was born in Alhwodat Camp, Jordan on (date redacted), 1961. I have resided in the United States since 1989.

6. On September 16, 1982 I was in the Sabra camp in Lebanon, and had been there for a short time prior. During the days that I was there before September 16, I did not see any resident in the camp with any sort of weaponry. Similarly, on September 16 and in the ensuing days, I did not see any resident of the camp with any kind of weapon.

7. On September 16 I was staying with my cousin on the second story of a building a few blocks from the stadium where the children would play soccer. There was a candy store on the first floor of the building that was operated by the landlord Charles Doe VI. With me on the second story were three of my cousins and a fifteen year old boy. In the afternoon, at approximately 4:00pm, I heard shooting from a helicopter. I looked out and could see that the helicopter, coming from the direction of the stadium, was shooting in the direction of the building we were in. Approximately five minutes later either a rocket, a missile or both tore into the building. I do not know how many rockets or missiles hit the building. I can not say if the firing was from the helicopter I had seen or some other, or if the firing was from the ground or some combination of these possibilities.

8. I saw that the fifteen-year old, who had been standing near the window, had his head torn off. One of my cousins had the bulk of his stomach ripped open, another cousin suffered severe wounds to his arms, hands and legs. I was also wounded in my arms legs and feet, suffering, I later learned, eight distinct shrapnel wounds.

9. I and my cousin that had suffered the wound to his stomach, jumped out of the window to the street below. The situation was pandemonium. I could see that soldiers of Haddad=s men as well as others that I believed to be Israeli who were coming up the street firing guns in every direction. Residents of the camp were running in order to avoid being shot by the heavily armed forces. I saw that even in the first few minutes many of the residents were killed there on the street. I knew many of the people that lived there and saw them being killed. I could also see that the soldiers were firing into homes and other structures. I could see some people being shot and killed inside the structures and was later able to see that many people were killed while inside their homes.

10. That night I went to the sanitation area, basically a garbage dump, and with three other men was able to hide there. Wounded and terribly hungry I ate some bread that I found among the garbage there.

11. From my position I was able to see many soldiers, both of Haddad=s men and those I think may have been Israeli passing in the street. I could see that they were continuing to fire their weapons in such a way as to spray large areas with bullet rounds. In more than one instance I saw soldiers find a person wounded on the street but not dead, and the soldier would shoot the defenseless person.

12. The next day I saw the most horrific scenes. There were many people lying dead in the street. Many of them were women, old men and children as were the vast majority of the people that had been living in the camp. I could see that several of the dead women were pregnant. I also saw that somewhere around 95% of the structures, homes and stores were demolished or so badly damaged that they could not be used.

13. Eventually I was able to get to the hospital at Albamaof where I was treated for my wounds for three weeks. It took several months for me to recover fully from my wounds.

14. My observation that some of the soldiers were Israeli is based on their wearing the star insignia of Israeli soldiers and that I was able to hear them speaking in Hebrew. I am familiar with, though by no means fluent in Hebrew from having lived in Jerusalem from when I was one year old until I was six.

15. The entire time that I was in the camp I did not see or hear any resistence whatsoever from the refugees. Nor did I see any fighters from the PLO or any other Palestinian group in the camp. I did not see any weapons laying around the camp or in the hands of or at the side of any of the victims. Moreover, among all of the dead people I saw on the streets I did not see the bodies of any soldiers belonging to Haddad or anyone else among them.

16. Because have family in and hope to travel to the Occupied Territories, and in as much as the Israeli Defense Force and Shin Bet, the State security force, routinely and regularly invade our communities, I live in a constant fear of that my family or I will be being singled out by these forces as retaliation for my complaints and this law suit. Accordingly, I ask for an order of this court permitting my identity and, where appropriate, the identity of others referred to in my affidavit to remain under seal for as long as possible. In the alternative, I ask for an order of this court instructing counsel for the defendant to refrain from providing my identity and the identity of others referred to herein until and unless absolutely necessary. Given the events described in this affidavit and the frequency of Israeli forays into my family=s neighborhood I have a well founded fear that military and security forces of Israel will harm me, my family and our property in retaliation for this suit.

Dated: __________________________
on this _____ day of____________,2002
_____________________________________________
JOHN DOE XVII

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