(from www.mallat.com, website of the plaintiffs' counsel)

Plaintiffs, survivors of Sabra and Shatila.

In annex to the present charges, the plaintiffs submit a statement of their personal suffering. The originals are in Arabic; each statement has been translated into French [and now English]. These statements are very telling and convincing:

1. Samiha Abbas Hijazi:

On the Thursday, there was shelling when the Israelis came, then it got worse so we went down into the shelter. (…) We learnt on the Friday that there had been a massacre. I went to my neighbours' house. I saw our neighbour Mustapha Al Habarat; he was injured and lying in a bath of his own blood. His wife and children were dead. We took him to the Gaza hospital and then we fled. When things had calmed down, I came back and searched for my daughter and my husband for four days. I spent four days looked for them through all the dead bodies. I found Zeinab dead, her face burnt. Her husband had been cut in two and had no head. I took them and buried them.

Madame Abbas Hijazi lost her daughter, her son-in-law, her daughter's godmother and other loved ones.

2. Abdel Nasser Alameh:

On the night of the carnage, we were at home and we heard that there was a massacre at Shatila. (…) We kept watch on the road all night, taking turns to sleep a few hours, until daybreak when some people managed to escape. I thought my brother had gone ahead of us to West Beirut. We waited for him but he didn't come. In fact my brother was one of the ones they took away, and we never even found his body.

Mr Alameh lost his brother, who was 19 years old.

3. Wadha Hassan Al Sabeq:

We were at home on Friday 17 September; the neighbours came and they started to say: Israel has come in, go to the Israelis, they are taking papers and stamping them. We went out to see the Israelis. When we got there, the tanks and the Israeli soldiers were there, but we were surprised to see that they had Lebanese forces with them. They took the men and left us women and children together. When they took the children and all the men from me, they said to us, "Go to the Sports Centre," and they took us there. They left us there until 7pm, then they told us, "Go to Fakhani and don't go back to your house," then they started firing shells and bullets at us.

On one side there were some men who had been arrested; they took them and we have never found out what happened to them. To this day we know nothing about what happened to them; they just disappeared.

Mrs Al Sabeq lost two sons (aged 16 and 19), a brother and about 15 other relatives.

4. Mahmoud Younis:

I was 11 years old. It was night and we could hear shelling and gunfire. (…) We took refuge in the bedroom and stayed there. As soon as they arrived, they went straight to the living room, and they tore down the photos from the walls, including the one of my brother who was killed in "Black September." They ransacked the living room, cursing and swearing. After having looked for us without finding us, they went up to the roof and stayed there all night long. We spent that night in terror in our hiding place, listening to the shooting and people screaming, while Israel fired flares to light the sky until sunrise.

The next morning they started saying, "give yourself up and your life will be spared." My nephew was 18 months old. He was hungry and we were far from the kitchen. My sister wanted him to quieten down, and she put her hand over his mouth for fear that they would hear. Her husband decided that we would have to give ourselves up, adding that each person's fate was anyway preordained by God. The women went out first, my brothers, my father, my brother-in-law and other members of the family followed. My brother was ill. As soon as they heard our voices, they shot in our direction and came straight back inside the house. They asked us where we had been the day before when they had come in and not found anyone there. Then they ordered the women and children to go out. My brother-in-law started kissing his little girl as if he were saying goodbye. An armed man came towards my niece, tied a rope around her neck and threatened to strangle her if her father didn't let go of her. He let go of her and gave her to me. They wanted to take me too but my mother told them I was a girl. They made my mother and the women walk to the Sports Centre. While I was walking I saw my aunt's husband, Abu Nayef, killed near our house with blows of an axe to his head. The dead bodies were disfigured. While I was carrying my niece, I bumped into a dead body that had been hit with an axe and I fell over. They knew then that I was a boy, and one of them put me up against the wall; he wanted to fire a bullet into my head. My mother begged him and kissed his feet so that he would let me go. He pushed her away. When he did that, he heard the clinking of some money she had hidden next to her chest. He asked her what that meant. She replied that he could have all the money he wanted but he had to let me stay with her. In this way we carried on our way and we arrived at the Sports Centre. The Israeli bulldozers were busy digging large trenches. We were told that we all had to get in because they wanted to bury us all alive. My mother started begging him again, and then she asked for a mouthful of water before dying.

At the Sports Centre, I saw the Israeli military, as well as tanks, bulldozers and artillery, all Israeli. We also saw groups of Phalangists with the Israelis.

The Sports Centre was packed with women and children. We stayed there until sunset. An Israeli came then and he said, "Everyone go to the Cola region, whoever comes back to the camp will die." We left, as they fired shots in our direction.

Mr Younis lost his father, three brothers, his maternal uncle, his maternal cousin, two paternal cousins and other members of his family.

5. Fadia Ali Al Doukhi:

When the shelling started and we knew that Israel had surrounded the camp, my father told us to escape. We asked him to come with us, but he refused because he wanted to protect the house. We escaped, leaving him in the house. Later, we found out that a massacre had taken place. We found out that my father was dead and we saw his picture in the newspaper. His foot had been cut off. Our neighbour in the house where my father had sheltered told us how they killed him.

Mrs Al Doukhi, who was 11 years old at the time, lost her father.

6. Amina Hasan Mohsen:

We were at home the Thursday when the shelling started. I didn't know what was going on outside. When the shelling intensified, I tried to go out to save myself and the children. When we went out, the dead bodies were spread out over the street. My children were afraid. An Israeli told us to go out. Then we saw someone speaking Lebanese. When we went out under cover of the Israelis, they started shouting at us. At that moment I counted my children and I saw that Samir was missing; when he saw the dead people on the ground he got scared and ran away. At that moment I didn't have the presence of mind to go looking for him because the whole area was full of Israeli and Lebanese troops. We escaped, and when the massacre was over I looked for Samir, but the corpses were so mutilated I couldn't recognise him among them.

Mrs Mohsen lost her 16-year-old son.

7. Sana Mahmoud Sersawi:

We lived in the Said area of Sabra, and when the shelling started we sought refuge at my parents' house in Shatila. This happened on the Wednesday. At about midnight, some women who came from the western quarter said that there was killing. We escaped once again, towards the interior of the camp. Then, when daybreak came, we hid ourselves in the shelter of the rest home. I was pregnant at the time, and I had two daughters who were still taking milk. We stayed in the rest home for two days, until Saturday. We didn't have any more milk. My husband went out to get some for the girls. That night was so long, and the Israelis were firing flares to illuminate the sky. It was like this when my husband went to Sabra. The Israelis had come as far as the Gaza hospital. After that, I went out to look for him, and my sister went to look for her husband. We arrived at the entrance to Shatila. There, they had put the men on one side and the women on the other side. I started looking among all the men. I saw him, and I said to him, "You know, these are Phalangists." He replied, "What happened at Tel al Zaater will happen to us." The armed men ordered us to walk in front, and the men behind. We walked like this until we arrived at the communal grave. There, the bulldozer had started digging. Among us was a man who was wearing a white nurse's shirt; they called him and filled him with bullets in front of everyone. The women started screaming. The Israelis posted in front of the Kuwait embassy and in front of the Rihab station requested through loudspeakers that we be delivered to them.

That's how we found ourselves in their hands. They took us to the Sports Centre, and the men were supposed to walk behind us. But they took the men's shirts off and started blindfolding them with them. In that way, at the Sports Centre, the Israelis submitted the young people to an interrogation, and the Phalangists delivered 200 people to them. And that's how neither my husband nor my sister's husband ever came back.

Mrs Sersawi lost her 30-year-old husband and her brother-in-law.

8. Nadima Yousef Said Nasser:

It was the Thursday. Suddenly the street was deserted. My mother went to the neighbours' house, and the shelling started. About 10 families were gathered at the neighbours' house. A little while later, a woman came in from the Irsan quarter. She shouted, "They've killed Hassan's wife!" She was carrying her children and shouting that it was a massacre. I picked up one of my twin daughters, she was a year old, and I went to my husband and said, "They say that there's a massacre." He replied, "Don't be silly." I took one of my daughters and gave him the other one, but the shelling got stronger and we went back to the neighbours in the shelter. The shelter was full of women, men and children; a woman from Tel Al Zaater was crying, saying, "This is what happened at Tel Al Zaater."

A little later, I went out of the shelter, and I saw armed men who were putting the men against the walls. I saw a neighbour; they tore open her stomach. Some women came out of the house opposite and started waving her scarf around, saying, "We must give ourselves up." Suddenly I heard my sister shouting, "They've cut his throat!" I thought that my parents had been killed. I rushed to see them, carrying my daughter. They killed my sister's husband in front of me. I went up, I saw them shooting at the men. They killed them all. I fled. My other daughter stayed with her father. The armed men left, taking the men out of the shelter. My husband was among them. On entering the camp a Lebanese woman came; she had seen my husband holding my daughter. She saw how my husband was killed by a Phalangist, with the blow of an axe to his head. My daughter was covered in blood. The man gave her to the Lebanese woman, who came back to the camp and gave her to some relatives of mine. I fled to Gaza hospital. When they entered the hospital, I escaped a second time.

Mrs Said Nasser lost her husband, her father-in-law, three of her husband's nephews and five other relatives.

9. Mouna Ali Hussein:

I was in my house in Horch, I was 4 months pregnant and I had an 8-month-old son. We lived peacefully. We heard the Israeli aeroplanes flying intensively overhead, their noise got louder and then the shooting started. I took my son and I said to my husband, "I want to go to my parents' house in the Western quarter." We went, and when we were there, the shooting increased. We stayed with neighbours who had a ground floor house with two floors. When the shelling got worse, we stayed inside. It was six o'clock. We closed the door and stayed inside. There were only women and children there, except for my husband and a young man. We heard people shouting outside, and the armed men said, "Don't shoot, use the axe. If they hear shooting they will escape. A bomb exploded near the house, and everyone started screaming. They heard us, and started shooting at us. The young man was killed while he was trying to put the candle out. We shouted even louder when he was killed in front of us. They carried on shooting, and when they heard us they threw a bomb at us. A woman was injured, and so was my mother. The bedroom became a river of blood. The soldiers started shouting at us, "Come out! If you don't come out we will dynamite the house!" They insulted us. My mother opened the door, saying that she would sacrifice herself. She saw ten armed men. She said to one of them, "Don't kill us." He replied, "Everyone out, get in a line." One after the other we went out. I stayed with my husband and with my other son, and then we went out. They said to my husband, "Come here, you." My husband was carrying our son, so he gave him to me. The armed man said to him, "Get back." My husband thought he wanted his ID card. As he was backing away, they machine-gunned him down in front of me. He didn't say a word; he fell. I waited for my turn. They insulted me. I followed my mother and my sister to the orphanage, and we fled. The children lived alone, their father didn't have any brothers or close relatives. They had no one at their side. Other orphans will find an uncle, but my children have only me. God help us. My son, even at his age, really needs a father to help him, someone he can talk to about his problems. When you're an only child, what a huge empty space that would leave.

Mrs Ali Hussein lost her husband and her brother-in-law.

10. Shaker Abdel Ghani Natat:

It was Saturday 18 September and we were at home when I went to check the car outside. That's when I saw some soldiers; I thought they were from the Lebanese army. They demanded to search the house; the family was asleep so I woke them up and we all went outside. They took us towards Shatila camp. As we were walking, we passed people who had been killed and corpses and I realised then that there was a massacre. They drove us to the Rihab station; they wanted to take us to the Kuwait embassy. That's when the cars stopped and loaded up with youths, nothing but youths, including my son.

As for us, they delivered us to the Israelis and the Israelis took us to the Sports Centre, where they kept us.

That's how they took some people away, while they left others. My son was put in a car in front of me; I saw them take him, but I have no idea what became of him that day.

Mr Abdel Gahni Natat's son was 22 years old at the time.

11. Su'ad Srour Meri:

On Wednesday, after Bashir Gemayel had been killed, we heard Israeli helicopters flying overhead at a low altitude, and on Wednesday night the Israelis started firing illumination flares, which lit up the camp as though it was day. Some of my friends went down into the shelter. On Thursday evening I went with my brother Maher to see some friends and tell them to come and sleep at our house; on the way the road was full of corpses. I went into the shelter but I didn't find anyone there, so we went back. Suddenly I saw our neighbour, who was injured and had been thrown on the ground. I asked him where our friends were, he replied that they had taken the girls and asked me to help him, but I couldn't rescue him and I went straight back home with my brother. Maher immediately told my father that there was a massacre. I found out from our neighbour that the Phalangists were there. When my father found out, he said that we had to stay inside the house. Our neighbour was also there. We stayed in the house all night long. On Friday morning my brother Bassam and our neighbour climbed up to the roof to see what was happening, but the Phalangists spotted them straight away. A few moments later, around 13 men knocked on the door of our house. My father asked who they were, they said, "Israelis." We got up to see what they wanted; they said, "You're still here," and then they asked my father if he had anything. He said he had some money. They took the money and hit my father. I asked them, "How can you hit an old man?" Then they hit me. They lined us up in the living room and they started discussing whether or not to kill us. Then they lined us up against the wall and shot us. Those who died died; I survived with my mother. My brothers Maher and Ismail were hiding in the bathroom. When they [the soldiers] left the house, I started to call my brothers' names; when one of them replied I knew he wasn't dead. My mother and my sister were able to escape from the house, but I was incapable. A few moments later while I was moving, they [the soldiers] came back, they said to me, "you're still alive?" and shot me again. I pretended to be dead. That night I got up and I stayed until Saturday. I pulled myself along crawling into the middle of the room and I covered the bodies. As I put out my hand to reach for the water jug they shot at me immediately. I only felt a bullet in my hand and the man started swearing. The second man came and he hit me on the head with his gun; I fainted. I stayed like that until Sunday, when our neighbour came and rescued me.

Mrs Al Meri lost her father, three brothers, (aged 11, 6 and 3) and two sisters (18 months and 9 months).

12. Akram Ahmad Hussein:

[The twelfth plaintiff, Mr Akram Ahmad Hussein, was not at Sabra and Shatila at the time of the events, cf. infra, part B3 of this submission.]

13. Bahija Zrein:

We were at home and we got wind of a massacre, but we didn't believe it. In the night, two young men came to our house and told us that there was a massacre in the camp. We then went outside to see what was happening. We saw the Lebanese Forces standing outside; they called us. There were a lot of people and we thought they were Israelis. When we heard their Lebanese accents I ran away, but they followed me and arrested us, young people, both men and women. All this happened at about 5 o'clock in the morning.

They went into the area and took away about 18 young people, while confining us - men, women and children - in the camp. I saw my brothers and some children among the men they took away. While we were walking, we saw people who had been killed with axes. Among them were doctors from Gaza hospital. They lined them up and slaughtered them; then they started shooting at us and killed a large number of people, including 18 of our neighbours' sons. While they were shooting, the whole camp was surrounded by Israeli tanks and all the diggers were Israeli. An Israeli patrol presented itself to us and asked us to go to the Sports Centre. The men went, while we women were taken to the Kuwait embassy.

That's how we saw them loading the young people into the cars. Among those young people was my brother. They blindfolded them and they loaded my brother in the car. That's how he disappeared and I have never seen him again since.

Mrs Zrein's brother was 22 years old at the time of the events.

14. Mohammed Ibrahim Faqih:

That morning, they started shelling around the outside of the camps, including Shatila, and we could hear the sustained shooting. The shelling reached the main roads and we didn't know what the reason for it was. It was incredible. We couldn't even move from one place to another or escape because of the shells and machine-gun fire.

We stayed at home and suddenly a shell hit our neighbours' house. Some of the shrapnel hit my son in the chest and the leg, and we took him to Akka hospital, but they wouldn't admit him because of the large number of injured people already there. We took him to Gaza hospital. My brother and I stayed with him at the hospital, but the shelling of Sabra and Shatila camps intensified. A woman came to tell us that she had seen them coming; I fled but I saw how they entered and took away all the injured and sick people. So I escaped and I came back three hours later. They had taken away many people and the only one left was my injured son. I don't know how many people they took away alive.

Then we took my son to a hospital in Hamra, and the next day I heard that they had come to Sabra and they had taken away the girls. When I came back here I saw my daughter Fatima had been hit with an axe, along with my little girl. I noticed that they had dug a ditch in the ground and they had buried them alive in the ditch. The baby's throat had been slit. I also saw people who had been killed and pregnant women with their stomachs ripped open. About thirty young people had been massacred near our house, without any distinction made as to whether they were Lebanese or Palestinian. They didn't spare anyone; they killed everyone they came across. In the home of our neighbour Ali Salim Fayad, they had killed his wife and children.

My God, what can I say, what can I tell you? They had demolished the shops in Sabra road and dug large ditches where they had buried the victims. I saw about 400 children's corpses. They upturned the earth and buried them. From the twelve members of our neighbour's family, eleven were killed and only one escaped.

Mr Faqih's two daughters were aged 2 and 14 at the time of the events.

15. Mohammed Shawqat Abu Roudeina:

I was at home with my father, my mother and my sister. When the shelling started, we were at the home of my father's uncle. There, the shelling started again, and we went into the bedroom, the men staying in the salon. Then we went to a neighbour's house. There were about 25 or more of us. A little later, we heard the cries of a girl who had been injured in the back. Armed men had stationed themselves in the area. Then we heard shooting, screams and strange voices. Aida, my cousin, went up to the shop and turned on the light. A man slit her throat and they dragged her by her hair. She started screaming "Daddy!" then her voice went dead. Her father wanted to follow her. They killed him immediately. That's how they understood that we were in the house. They came down to the floor above us, where they broke and ransacked everything and we heard them calling out to each other, "George, Tony…" When we heard them breaking everything our voices rose, and that's how they knew that we were on the floor below. One of them came down and saw us. He immediately told the others, and they all came down. My father was sitting on a chair, and as soon as he saw them, he kissed me, put some cologne on me and told my mother to take good care of the children. My father's cousin said to his wife, "the children are your responsibility."

I won't forget. The image of that day is engraved in my memory. They ordered the men to stand against the wall. They made us go out behind them into the road. When I got to the door, I looked up at the red sky, red streaked with flare grenades. Once we arrived at the beginning of the road, we heard the shots aimed at my father and my uncle, as well as some shouting. We walked several metres, flanked by armed men. My cousin saw her father and she started screaming. I saw my father's car, which they had opened and were sitting in. That image is also engraved in my memory, because I asked my mother what they were doing with my father's car but she didn't reply. As we walked along we saw the dead people.

They took us to the Sports Centre, and they placed us there in a room where there was a woman and her children. They brought people there. They took some of them away in cars and killed the others. At that moment, the Israeli tanks were there. Suddenly a mine from the beginning of the Israeli invasion exploded. They ran away, and so did we.

Mr Abu Roudeina lost his father, his pregnant sister, his brother-in-law and three other members of his family.

16. Fadi Abdel Qader Al Sakka:

We had spent the whole of Friday hidden in the house, thinking that the Israelis were going to penetrate the camp.

On Saturday at about midday, while we were still at home, we saw the Israelis arriving at our house. They told us all to come out. I was a little boy of 6 at the time. We came out and they took us to the road to the western side. My father was carrying my little brother; they told him to give the child to my grandmother, who was also with us. They wanted to take away my father and my uncle, so my grandmother asked where they were taking them. Someone told her that they would be back soon. While we were walking, the roads were strewn with dead people and I saw how they were treating people. My father and my uncle never came back after that day when they were taken away.

Mr Al Sakka lost his father and an uncle.

17. Adnan Ali Al Mekdad:

At about 3 pm on Thursday, after the death of Bashir, Sharon made some worrying transfers. There were foreign men surrounding the region. Some people found out about this and fled. My mother saw the armed men, made them some tea and told them she was Lebanese. They told her that they were only after the Palestinians, and that, being Lebanese, she could stay in the area, no-one would bother her, she just had to keep her ID papers with her.

And we were looking for family members, until I saw her hanging from a tree. After that we set about gathering the corpses and burying them.

Mr Adnan Ali Al Mekdad lost his father, his mother and more than forty members of his family.

18. Amal Hussein:

On the Wednesday, Israeli aeroplanes started flying over the area and the shooting and shelling began. My brothers and sisters were scared. Those who were scared went down into the shelter next to our house. That way, one group slept in the shelter and the other group slept in the house. The aeroplanes continued hovering, and there were more and more of them. My three-moth-old nephew, who was with my sister in the shelter, started crying. He wanted to eat. She came out with him and four others, and they all came into the house. As soon as she came in - this was on the Thursday - we heard shouting, it was coming from the women in the shelter, which we could see from our bathroom window. All of a sudden, the armed Phalangists invaded the area. No one could leave the house. All we could hear was babies and women screaming. They started killing people. We stayed in the house; we opened the doors and then went into the bathroom with my little nephew. We had gagged his mouth for fear that they would hear his voice and come to kill us. We stayed in the bathroom; they came in and searched the house, but they didn't find us. We heard the screams and the massacre through the bathroom window. That's how we knew that they had gone into the shelter and taken everyone they found there, including my relatives. On the Saturday, we escaped into the interior of the camp. After that, my mother went back to see my brothers and sisters, but she couldn't recognise them because they were so disfigured. All that we knew was that they had been buried in the mass grave. My father taught the child who survived (my father's nephew) to call him Daddy.

Mrs Amal Hussein lost a brother, two sisters and several other relatives.

19. Noufa Ahmad Al Khatib:

Two days before the massacre, the Isarelis came to our area. They came, took us, lined us up and then let us go. The next day they withdrew and went into a hospital. We fled, and the day after that I learnt that there had been a massacre. Then the next day I was told the story of the massacre. I was in Shatila, I saw the victims, and I started to look for my relatives. I saw my mother, she was dead and I saw her and recognised her. I saw all the victims who died and those who were still against the walls.

Mrs Noufa Ahmad Al Khatib lost her mother, her sister, and several other close family members.

20. Ali Salim Fayad:

We were in the house and we had some people there. There was a car across the way and we went to move it. As we were coming back, there were some armed men in front of the house, that Thursday. They ordered the separation of the men from the women and children. They lined the men against the wall as well as our Palestinian neighbour and his family and they shot them. The women and children were slaughtered in the road. Before shooting, they asked for their identity cards and they kept those. The Phalangists searched the house and the Israelis protected them with their tanks and their flares. When they shot us I was hit in the back, the thigh and the hand. The night was lit up by the flares. I stayed spread out on the ground. Later I called out to someone who was passing and asked him to call an ambulance. A short while later my daughter came and took me to Akka hospital. The next day the Phalangists came to the hospital and asked my son, who was in the room next door, about me. They took away some of the injured Palestinians. I saw them dragging a wounded man out of his bed and hitting him on the head with an axe. He was young, and they killed him.

Mr Ali Salim Fayad lost his wife, his two daughters, his son and his sister-in-law.

21. Ahmad Ali Al Kahtib:

It was between five and six o'clock on Thursday. We were in the area and there was some shooting. A young man from our area was injured. We took him to Gaza hospital. During the time the massacre took place, we tried to go back but the road was closed. I spent three days away from home.

Mr Ahmad Ali Al Khatib lost his father, his mother, four brothers, three sisters and his grandmother.

22. Nazek Abdel Rahman Al Jamal:

My eldest son went to bring the car so we could escape; they came and arrested him at Sabra Square. My second son went to get bread and food, we were at home, and the Israelis and the Phalangists took us away from the house and made us walk in a line to Sabra. While we were walking I saw my eldest son walking in another line and my sisters saw my other son. They made us walk as far as the Kuwait embassy, and when we got there they said, "Women go home." There was an explosion and the people ran, on the way back I saw dead bodies on both sides of the road, women and old people. They had blown up the corpses and the children were dead. I went home and the children weren't there. I spent four days looking for the children; my brother brought my youngest son's dead body; I had already seen my eldest son dead in the pit.

Mrs Nazek Abdel Rahman Al Jamal lost her two sons aged 20 and 22.

Testimonies, survivors of Sabra and Shatila.

In addition to their own statements, the plaintiffs present a series of statements from other survivors of the massacre.

1. Mohammed Raad:

On Wednesday we were at home waiting for the visit. I was at Sabra and the roads were empty. When I arrived at Ali Hender's cafe, I met some young men who called me over and asked if I knew. I said no. They said that the Israelis had entered with the Phalangists and that they were destroying things. I went straight home, got my wife and we went to her brother's house. We said to him, "Abu Suheil, let's get away from here." He replied, "We are Lebanese, they won't bother us." I was with another relative and I said to him, "Leave your children and go." He called me a coward. My wife and I started walking until we reached the airport bridge, and from there I saw the Israelis surrounding the area. An Israeli soldier shouted at me. The Israelis started asking me where I had come from and where I was going; then they said to my wife and to another woman passing by to stay where they were before ordering me to follow them and wait by the mountain. But I was directly behind Harat Horeik and we escaped to Ghobeireh.

On Saturday we went back to see my relatives. What can I say; people were on their backs, black. I found my brother-in-law dead, he had been hit on the head with an axe; we found thirty other members of the family dead.

2. Jamila Mohammed Khalife:

On the Thursday at about 4 o'clock pm, they were at Al Horch, and we knew that there was a massacre, but we also knew that the Israelis were in the Sports centre; but we were asked not to do anything.

A short while later, the shelling intensified but we thought that things would quieten down soon. We went to seek shelter at our neighbours' house. While looking towards the Sports Centre, we saw hundreds of armed elements descending to it in just a few moments; they appeared in front of the house inside which were many people. We started shouting that the Israelis had attacked us. When they reached the house they started insulting us, blaspheming, and then our neighbours' son shut the door in their faces and we fled through another door to hide in the shelter, which was full of people.

The Israelis and the Phalangists came back a short while later with a loudspeaker, through which they asked us to give ourselves up, promising that our lives would be spared if we came out of the shelter. We waved a white flag, but when we came out of the shelter my father said that our lives would not be spared and that they were going to kill us. I told him not to be scared and to come with us. They dragged us all along; women, children and men; my father tried to escape and they killed him in front of my mother and my little sister. They made us all walk; our injured neighbour was with us, carrying her intestines and haemorrhaging. She and I escaped to the interior of Shatila camp, and from there we sought refuge in Gaza hospital. When they arrived near Gaza hospital, we ran away once again.

When the massacre was over, we went back and saw the corpses of the dead, including our neighbours' son Samir, murdered. And under the corpses, they had placed bombs as booby-traps.

3. Shahira Abu Roudeina:

On Thursday 15 September, after sunset, the Israeli air force carried out some raids on us. We lived in the western part of the camp, and when the shelling started drawing nearer, we - my husband, my children and I - went to my parents' home at the entrance of the camp, to see where they wanted to go. But we all stayed at my parents' house until 7 o'clock pm, at which time, seeing as the shelling kept intensifying, my sister went to see what was happening outside. They immediately shot at her. She shouted, "Daddy!" and didn't come back. Hearing her cry, my father went out. He saw her and said, "Our little girl is dead." Then they shot at him, and he fell. The whole camp was lit up by light flares, and none of us could go outside. We stayed locked in like that until 2 o'clock am. Then we understood that there had been a massacre.

The noise of the killing and the screams accompanied us until dawn. At five in the morning, they came down by the roof, and suddenly we saw them on the stairs in front of the door of the bedroom where we were. About fifteen armed men stationed themselves at the windows, and four of them came in. The children screamed and cried, and we women joined our screams to theirs. They put the men against the wall - my husband, my paternal cousin and my brother - and they pumped them full of bullets in front of us. They made us come out and lined us up in our turn against the wall, wanting to pump bullets into us as well, but then they started arguing about who would be the first to shoot. Then they took us to the Sports Centre and took us into a room full of men, women and children. While guarding that room, they were also sharpening their axes and preparing their guns. It was Friday, at about five in the morning. At midday, they brought back the young men and the women from the rest house, as well as some people from the Kuwait embassy. In the middle of the Sports Centre there were mines dating from the beginning of the Israeli invasion. One of the mines exploded. People fled, and we were among them. What can I say? When we were at the Sports Centre, the Israelis were securing the protection of the Phalangists, and Israeli tanks were stationed there. Also, it was the Israelis who shouted into the loudspeakers, "Give yourselves up and your lives will be spared."

4. Hamad Mohammed Shamas:

On Wednesday, when the Israeli army arrived at the Sports Centre with its tanks, and when we found out that the Israelis were there, I went with a friend to ask them what was going on.

They asked me if I was a terrorist, I said no. Then they said to us, stay at home, there's nothing happening. I went home. It was the 15th of September.

On Thursday 16 September, I was talking to Abu Merhef and Abu Nabil when suddenly we heard the sound of bombs falling on the houses, and the screams of injured people. We ran to help the wounded, and to drive them the Akka and Gaza hospitals. Afterwards, I suggested to my father that he go down into the shelter. The shelling kept intensifying, and we went down into the shelter. The children were thirsty. I went to get some water and blankets. My brother had been away from the house for 15 days because of his job. He came, and stood with us at the door to the shelter. Suddenly, we saw some Israelis and some Phalangists coming towards us, swearing and cursing. They told us to come out. We did. They placed us against the wall and pointed at Abu Merhef; he had 500 pounds in his pocket. Abu Merhef told them to take 250 pounds and to leave him with 250 pounds for the children. When they heard that, they immediately shot at the men. I was hit and I pretended to be dead. Three or four others fell on top of me. They were dead - it was Abu Hassan Al Bourgi, Kassem Al Bourgi, Abu Nabil and Ali Mehanna. I remember that Ali Mehanna survived his injuries for at least an hour; when he regained consciousness he started calling for help and asking if there was anyone still alive. I said, "I am," and he said, "who?" I said, "Hamad." He said, "Please Hamad, I am injured in the stomach and in the hand. Say hello to my mother, my sister, so-and-so, and tell them Ali sends his love." I said, "How do you know that I'm going to live? Is there anyone else alive near you?" He was sitting up and I was still lying down. A little while later they came back and said to Ali, "Are you still calling?" They insulted him and hit him on the head. But he got up again and he said to them, "Is that how you treat us, you sons of bitches?" because he thought they weren't supposed to attack Lebanese. They then resumed their task, 5 or 6 times. They shot to make sure that everyone was dead. They pointed the gun at my thigh and fired. In that way, they had come back to make sure everyone was dead. At about five in the morning, I tried to get up from where I was. There was a wall next to me. I moved along the road and I heard the sound of the tanks. I went to hide in the home of Osman Houhou, which had been destroyed. Suddenly I heard an Israeli on a microphone saying, "Give up your weapons, you will have your lives spared and those of your family."

I tried to climb up the slope in order to give myself up like they said. When I was almost there, I looked and I saw them placing the men on one side and the women on the other. Then I saw them shooting them. That's the reason why I went back to hide in the house I had left a little while earlier. I stayed there until the evening. They were sitting around a table drinking alcohol, there was only a wall separating me from them. The wall was cracked; I could see what was happening. They were saying to each other, "don't leave anything that moves."

In that way I remained sleeping in the house until 10 o'clock on Sunday morning. I lost hope and I couldn't handle any more, I decided to go out even if it meant being killed. I tried to go back to our house, but I found it destroyed. I couldn't walk because of all the dead people strewn over the road. And every time my hand touched one of them, I found their flesh between my fingers.

I saw Um Bashir who had been killed with her seven children. It was as if she was sleeping with her seven children around her. I went back home and sat down with the dead. The Makdad girl came to call for help, and that's how they took me to the hospital.

5. Milaneh Boutros:

We were at home that Thursday. There was shelling, and we went into the shelter. The place was packed with men, women and children.

A little later, someone from, I believe, Rashidiya camp came to take his family. Mohammed Shamas' brother also came and suggested that he leave. But Mohammed refused and we stayed in the shelter. I picked up my 2-year-old daughter and went out. I saw armed men and Israeli soldiers calling people.

I went out first, thinking that they were there to protect us. I said to one of them, "You're here to protect us." He said, "Shut up!" and started insulting and swearing. "Shut up! Are you pretending to be Lebanese now?" I told him that I was from Zghorta and that my mother was Lebanese. He took us away. I was carrying one of my daughters, another one was holding my hand, and the other children were clinging to my clothes. We stepped over the corpses. The area was light as day because of the illumination flares. When we got to the Kuwait embassy, they took Ali, my husband's nephew, and they loaded us into trucks. We headed towards Dora and then Bickfayya. There, a woman stood on a balcony and said, "you're bringing me women; I want men." With us was a small boy of 13, Ali Zayyoun, who was cowering in a corner of the bus. As soon as they saw him, they took him and killed him. Then they took us to Ouzai. The next day they asked us to go back to our houses. Israeli patrols and Phalangist blockades were everywhere. The ground was littered with corpses. At the door of the shelter I saw my husband, my son and other murdered people. Another corpse had been thrown on top of my son, who had been killed by an axe to his head.

6. Najib Abdel Rahman Al Khatib:

Before entering our house, the Israelis started firing flares to light the sky. When the shelling got nearer, my father took us into the shelter until the shelling calmed down a little.

We went to Akka hospital, where we slept one night. But at about 5 in the morning, they penetrated the hospital and we fled again. On the Saturday, I came back to the house to pick up some things. I saw only dead bodies on the ground, and I saw the Israelis and the Phalangists passing by. I went back again and I entered directly into the garden of our house; that's when I saw my dead father. I went to the house and I saw a basin. It was full of people's heads. I fled.

The plaintiffs also present the testimonies of survivors gathered by journalists, and the accounts of eyewitnesses, notably:

7. Ellen SIEGEL, US nationality, nurse in Beirut in 1982, currently lives in Washington DC (USA).

8. Robert FISK, nationality British, journalist, one of the first journalists to visit the camps after the massacre.

9. Nabil AHMED, survivor, currently lives in Washington DC.

10. Jean GENET, nationality French, poet and playwright, visited the camps immediately after the massacre.

11. Dr Swee CHAL ANG, nationality Singaporean, doctor in Gaza hospital, Sabra, at the time of the massacre.

12. Dr Per MIEHLUMSHAGEN, nationality Norwegian, idem.

13. Dr Ben ALOFS, nationality Dutch, currently lives in Great Britain, nurse in the Gaza hospital, Sabra, at the time of the massacre.

14. Dr David GREY, nationality British, currently lives in Great Britain, doctor in Gaza hospital, Sabra, at the time of the massacre (Dr Grey was one of the three doctors who returned to the hospital after the initial evacuation and with an official 'laissez-passer' from the Israeli army.

B3: Other plaintiffs:

12. Akram Ahmad Hussein:

Mr Hussein was in Tripoli at the time of the events. He lost his entire family: his mother, five brothers (aged 17, 13, 12, 11 and 11) and two sisters (aged 10 and 9).