Complaint for of the Estate of MARIE COLVIN, and Extrajudicial Killing, JUSTINE ARAYA-COLVIN, Heir-At-Law and 28 U.S.C
Case 1:16-cv-01423 Document 1 Filed 07/09/16 Page 1 of 33 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CATHLEEN COLVIN, individually and as Civil No. __________________ parent and next friend of minors C.A.C. and L.A.C., heirs-at-law and beneficiaries Complaint For of the estate of MARIE COLVIN, and Extrajudicial Killing, JUSTINE ARAYA-COLVIN, heir-at-law and 28 U.S.C. § 1605A beneficiary of the estate of MARIE COLVIN, c/o Center for Justice & Accountability, One Hallidie Plaza, Suite 406, San Francisco, CA 94102 Plaintiffs, v. SYRIAN ARAB REPUBLIC, c/o Foreign Minister Walid al-Mualem Ministry of Foreign Affairs Kafar Soussa, Damascus, Syria Defendant. COMPLAINT Plaintiffs Cathleen Colvin and Justine Araya-Colvin allege as follows: INTRODUCTION 1. On February 22, 2012, Marie Colvin, an American reporter hailed by many of her peers as the greatest war correspondent of her generation, was assassinated by Syrian government agents as she reported on the suffering of civilians in Homs, Syria—a city beseiged by Syrian military forces. Acting in concert and with premeditation, Syrian officials deliberately killed Marie Colvin by launching a targeted rocket attack against a makeshift broadcast studio in the Baba Amr neighborhood of Case 1:16-cv-01423 Document 1 Filed 07/09/16 Page 2 of 33 Homs where Colvin and other civilian journalists were residing and reporting on the siege. 2. The rocket attack was the object of a conspiracy formed by senior members of the regime of Syrian President Bashar al-Assad (the “Assad regime”) to surveil, target, and ultimately kill civilian journalists in order to silence local and international media as part of its effort to crush political opposition.
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