AFFIDAVIT: Gregory S. Schnabel

I the undersigned Gregory S. Schnabel, U.S.A. Passport #027051903. Born April,26,1974, give my statement under oath for the advocate Raji Sourani about the death or homicide of Rachel Corrie on the 16th day of March, 2003.

I arrived in Israel on February the 12th 2003. Shortly after my arrival I made my way to Rafah, Gaza Strip. There I became affiliated with the International Solidarity Movement (I.S.M.) and I began working as a volunteer with this organization. I have now been working with this organization for more than one month.

On March 16, 2003 at approximately 2:00 P.M. I was with Rachel Corrie and Richard Purssell at a municipal water well in the Tel al Sultan district of Rafah. We received a call from some other members of the I.S.M. group. They informed us that there were two bulldozers and one tank operating in the Hi Salam district. These bulldozers were reported to be threatening the homes of Palestinian families.

Rachel, Richard, and I made our way by taxi to Hi Salam. Upon arrival at approximately 3:00 P.M. We saw the two bulldozers and one tank tearing up the ground. Both Rachel and Richard were wearing orange florescent jackets. Rachel was carrying a megaphone which she was using to communicate with the soldiers inside the vehicles. Richard and I unfurled a banner with the words “International Solidarity Movement” printed clearly on it.

Rachel, Richard, and I then saw the five others members of I.S.M. (Alice, Joe, William, Tom, and Nick) who were already on the scene. They were positioned near a house which a bulldozer was advancing towards. Rachel announced clearly through the megaphone that we were international human rights observers, that we opposed the destruction of family homes in Rafah and that our embassies had been informed of our presence there.

Rachel, Richard, and I stood approximately 15 meters away from the others. We observed as the bulldozer approached Alice, Joe, William, Tom, and Nick. They stood between the bulldozer and the house. The bulldozer came dangerously close to them physically pushing them back. However, it did pull back before crushing them.

This process was repeated several times. Members of our group placed themselves in front of houses, trees, foundations and other things which the bulldozers sought to destroy. This continued for almost three hours (approximately 2:30-5:30 P.M.)

Throughout this time period members of the group followed the bulldozers as they went back and forth. We stood in their path or sat in their path when they advanced in ward towards homes or structures.

We continually spoke with the soldiers via a megaphone. The soldiers occasionally but very rarely shouted back at us, either insults, commands to leave, or Hebrew phrases which we could not understand.

At approximately 3:30 there were some warning shots fired by the tank. They were machine gun shots fired at the ground several meters away from us. This occurred very early in the conflict and no shots were fired afterwards.

At approximately 4:00 P.M. The tank released a canister of what I believed to be tear gas. I did not personally smell the gas, however it was a windy day and the smoke did not come in my direction.

At approximately 4:15 P.M. William Hewitt sat in the path of a bulldozer as it advanced inwards. The bulldozer knocked him backwards and began to bury him between sand and razor wire. The razor wire ripped into his clothing. The bulldozer reversed at the last possible second. If it had advanced any further will would have been seriously injured.

At approximately 4:45 P.M. one bulldozer attacked and destroyed a garden shed and some of the wall surrounding an olive grove. I.S.M. activists prevented this by standing on the wall.

At approximately 5:00 P.M. Rachel Corrie was standing in front of the house of Doctor Samir Masri. I was standing on the partially demolished wall of the olive grove between 15 and 20 meters away. Alice and William were standing on the wall also. The remaining members of the group were spread out around the area.

The bulldozer approached Rachel from a distance of 10 to 15 meters away. Rachel was clearly visible and was still wearing her orange florescent jacket. As the bulldozer advanced Rachel signaled to the bulldozer driver by waving her arms. She was standing in a wide open area. There were no rocks, walls, trees or obstructions of any kind. The house of Dr. Samir was approximately 5-10 meters behind her.

The tank was positioned approximately 20-25 meters away. I believe that from its position it had a clear view of what was happening.

As the bulldozer continued to advance Rachel bent her knees slightly in a semi-crouching position. She was still easily visible to the driver as he approached from a distance of 2-3 meters.

As the bulldozer came extremely close to Rachel it began to push the dirt from underneath her feet and around her ankles. She stood up and struggled to stay on top of the dirt. She climbed upwards to a point where again she was visible to the driver. Rachel was unable to maintain her position on the pile of dirt and she was pushed backwards.

The driver of the bulldozer had clear sight of Rachel until the machine he was driving knocked her over. He clearly had complete control of the machine as he had demonstrated before his ability to maneuver and stop the machine with pinpoint accuracy

She fell on her side and attempted to pull herself away.

The bulldozer continued to advance and her legs became buried. I then witnessed the blade of the bulldozer passing over her legs. I screamed and heard the others screaming as well. The bulldozer continued with the blade down, driving over her entire body from feet to head. The bulldozer continued even further until Rachel was directly underneath the center of the bulldozer. The bulldozer paused for a moment. It then reversed and drove back over her with its blade still down.

After the bulldozer pushed Rachel over the driver continued to advance for a minimum of five meters more. During this time there was no place where Rachel could possibly have been except for underneath the bulldozer. For this reason I believe that this was clearly an intentional action by the bulldozer driver.

This incident occurred within plain sight of the tank, the other bulldozer driver, the seven international members of I.S.M., and Dr. Samir Masri who owned the home Rachel was in front of.

I ran to Rachel’s side and saw that she was severely injured. She spoke only the words “I broke my back” It was clear to me that her condition was very serious. After speaking those few word she was unable to even tell us her name. She had a laceration of her upper lip, blood in her mouth and she was showing signs of internal bleeding.

Alice and I administered what first aid we could and helped Rachel to remain calm as the ambulance was on its way. She was unable to speak but she did grip my hand when I asked her to. I asked her to breath with me and she was able to follow as I said “Breathe in, breathe out, breathe in, breathe out.”

She was still breathing when the ambulance arrived. She was taken to hospital and died within fifteen minutes of arriving there.

I observed the serial numbers of the bulldozers as “949623” and “949645”. I observed Joe taking photographs of these as well.

This statement was given before me, Lawyer Raji Sourani in my office in the Palestinian Centre for Human Rights, and in my presence on the 19th of March 2003, by Nicholas James Porter Durie. After I had given him legal warning to tell the truth, he signed his statement in the full capacity of his free and independent will.

Lawyer signature:

Raji Sourani

AFFIDAVIT: Thomas Edward Dale

I, the undersigned, Thomas Edward Dale, British Citizen (passport #;103540901), born 17/08/1984, am giving this statement under oath to the lawyer Raji Sourani, about the homicide of the late Rachel Corrie. I give this statement on 22nd March 2003, having been given legal warning and choice.

I have been in Rafah since early February working with the International Solidarity Movement (ISM)

On March 16 2003 at 14:46, while sitting in the ISM office in Rafah, I received a text message from Alice. It said that she was near the house of Abu Ahmed, our mutual friend and that there was 1 tank and 2 bulldozers working and that it would be good for more people to come.

I estimate that I arrived at the place about 20 minutes later. This was close to the border between the ‘Hi Salam’ and ‘Brazil’ areas of Rafah, close to the border with Egypt. All 7 other members of the group were already present.

For approximately the next 2 hours the group observed and occasionally peacefully obstructed the bulldozers by sitting or standing in front of them. In each event where I was in front of a bulldozer, its crew managed to stop just before injuring me, while still completing their mission. During this time I spoke on the telephone to an official from the British consulate who told me that he would inform the IDF of our presence. At the end of this period the group was distributed around or on structures close to Dr. Samir’s house, a few hundred metres east of where I originally saw the machines. We were trying to protect them from the bulldozers. At the time the incident happened: I was standing on the south-east corner of a pile of rubble which used to be a house. Greg was close to me. The light was good and there were no obstructions between me and Rachel, nor between her and the driver. There were no gaseous obstructions to vision. Rachel was wearing the orange ‘high visibility’ jacket which she had been wearing all day. I was holding the megaphone. Rachel had been using it all day until a few minutes before hand, when I had come from where I was standing, go the megaphone and went back to my position. It those few minutes I continued to shout the phrases which had been used by Rachel at appropriate points throughout the past few hours. Including: ‘You are endangering the life of an American Citizen.’ Rachel was standing close to Doctor Samir’s house as a bulldozer turned towards it from some 40 metres away. There was another bulldozer directly to the west of Rachel, it was stationary and I believe it had a profile view of the situation.

Rachel walked a few metres forward from where she was standing and took a kneeling/crouching position on the ground. At the time she did this, the bulldozer was facing toward her maybe 15-20 metres away. I was around 15 metres away from her. It advanced slowly toward her. Its scoop was dug slightly into the ground causing it to build up a mound of earth in front of it as it went. The site where Rachel was, was entirely level. It was totally clear to me that the Bulldozer crew could see Rachel and were aware of exactly where she was. Moreover, their experience must have taught them that we were not able to be agile on the soft ground. As the mound of earth reached Rachel she was clearly in danger of being overwhelmed if she maintained her squatting position. She stood up. She was forced by the bulldozer’s continued approach to clamber on to the mound of earth. When she did this her head was mostly over the level of the bulldozer blade. I felt that the crew’s continued progress after this moment (rather than backing up slightly then starting forward again as they had done before) demonstrated an aggressive intent. As the bulldozer continued, she started to fall down and into the pile of earth, her lower legs out of site. Seeing the danger she was in if the bulldozer crew continued, I started to shout at the driver to stop as loud as I could and waved for him to go back. I believe it was clear that I was totally hysterical at this point, as was everyone around me. I pointed to Rachel and motioned that the driver should stop. The reaction of myself and those around me was unprecedented during our interaction with the bulldozers in all the time I had spent in Rafah.

Nevertheless, the bulldozer crew continued to go forward. It had not averted its course the whole time. Rachel seemed to be trapped, lying down on her side. She turned to look up, but as the earth covered her she was face down. The bulldozer continued, pushing her under its blade and continuing until the point she was at was directly beneath the bulldozer cockpit. The bulldozer waited for a few seconds before reversing. As I recall this was not normal in the behavior of the bulldozers and seemed to me to indicate deliberation on the part of the crew. When it did so it did not lift its blade. I started to run toward her throwing away the megaphone. I then turned toward Dr, Samir’s house to call an ambulance but found that he had already done so when I arrived. I ran back, picking up the megaphone, and told the tank (which had moved closer) what had happened and that medical personnel were on their way. The ambulance arrived a few minutes later. I helped carry the stretcher into the ambulance, then accompanied it to the hospital in Rafah.

I, the undersigned, Thomas Edward Dale, British Citizen (passport #;103540901), born 17/08/1984, am giving this statement under oath to the lawyer Raji Sourani, about the homicide of the late Rachel Corrie. I give this statement on 22nd March 2003, having been given legal warning and choice.

Signature:

Thomas Edward Dale

This statement was given before me, lawyer Raji Sourani in my office in the Palestinian Centre for Human Rights, in my presence on 22nd March 2003, by Thomas Edward Dale. After I had given him legal warning to tell the truth he signed his statement in the full capacity of his free and independent will.

Lawyer signature:

Raji Sourani

AFFIDAVIT: Richard, J.A. Purssell

I, the undersigned, Richard, J.A. Purssell, U.K citizen Passport No. 025831942 d.o.b 12/10/1971 give my statement under oath to the lawyer Raji Sourani after having been given legal warning and choice:

I am here in the occupied territories of Palestine as a volunteer with the International Solidarity Movement (ISM). I arrived in Israel on 05/03/03 and made my way to Rafah on 10/03/03.

On the morning of 16/03/03 myself, Rachel Corrie and a U.S. activist named Greg were acting as human shields at one of the wells in Tel El Sultan area of Rafah.. At about 2:30 we received a call from other ISM activists in the Hi es Salaam area that they had spotted military (IDF) bulldozers. We went in a taxi to the area and arrived ten minutes later. As we arrived in the area we heard the machines working. Greg and I unfurled a banner which said INTERNATIONAL SOLIDARITY MOVEMENT and Rachel announced over the megaphone that we were internationals and asked the soldiers not to shoot. We came around a hedge of cacti and I saw two bulldozers and a tank stationary approximately 20 metres away Once again Rachel announced that we were internationals but received no spoken response from either the bulldozer drivers or the tank crew. At this point we saw the other five ISM activists.

As the bulldozers began to move towards a semi built structure on our left hand side we began to obstruct their work by physically standing or sitting in the way. At one point the bulldozers retreated and the tank fired a few warning shots at the ground in front of it and released some smoke. This happened within the first half an hour of our presence there. After that no shots were fired for the rest of the day.

For the next two hours we all acted to try and obstruct the work of the bulldozers. We stood in front of them and in buildings it seemed they might be trying to destroy. Throughout this time there would be someone on the megaphone announcing that we were internationals. Some of us including Rachel were wearing orange fluorescent jackets with reflective strips similar to those worn by construction workers for high visibility. There seemed to be no discernable pattern to what the bulldozers were doing. They ranged up and down the kilometre long strip, sometimes working together, sometimes not. On more than one occasion the drivers gestured to us, waving, pointing or sounding their horns. They were clearly aware of our presence. The bulldozers destroyed some semi-built (semi-destroyed) buildings, a water butt, knocked down some walls and ploughed up a lot of ground. At some times they acted with regard to our safety, at other times recklessly. It was clear to me however, from my experience in the construction industry that they were in full control of their machines.

oeApproximately one hour before the incident which killed Rachel Corrie , an American activist called Will (now known to me as Will Hewitt) was knocked down by a pile of earth in front of one of the bulldozers and semi-buried between rubble and a mass of barbed wire. On this occasion the bulldozer stopped and reversed so we were able to free Will.

At approximately 4:30 the bulldozers moved to the end of the strip where they had been operating and began to attack a semi-demolished building and a walled olive grove. The bulldozers backed down from destroying the walls of the olive grove when activists placed themselves on the walls. The drivers of the bulldozers are enclosed in their cabins .One of the bulldozers, which was marked 94 in white on the olive green bodywork in large numerals on its rear and 949623 in smaller numerals on its side began some activity to the left of the semi-demolished building (left and right as if one were standing in Palestine and looking at Egypt). It began leveling the ground by pushing earth around. At this point I was standing with Rachel between the semi-demolished building and Dr. Samirs house (this house is clearly marked with graffiti in English saying ‘we live here’ and ‘please stop shooting’). By this time Rachel had given the megaphone to another activist. The bulldozer 94 backed up some way (about 50 metres) and Rachel walked forward until she was about 20 metres in front of me. The bulldozer turned to face towards Dr. Samirs house. As it moved forward Rachel knelt briefly in its path. The bulldozer was moving at no more than five or six miles an hour. As it advanced its blade was placed in the ground and earth piled up in front of it. As the bulldozer reached the place where Rachel was standing, she began as many of us did on the day to climb the pile of earth. She reached the top and at this point she must have been clearly visible to the driver, especially as she was still wearing the high visibility jacket. She turned and faced in my direction and began to come back down the pile. The bulldozer continued to move forward at the same speed. As her feet hit the ground I saw a panicked expression on her face and began to move forward shouting and gesturing to the driver to stop. Something happened at this point to push Rachel forward onto her face. The pile of earth engulfed her and she was hidden from my view. By now all the other activists were running forward shouting and gesturing. However the bulldozer still moved forward. To my mind the driver must have been aware that Rachel was still in the bulldozers path. As the vehicle was moving so slowly I see no reason why it could not have stopped immediately if the diver were in any doubt as to where Rachel was. I noticed that the blade of the bulldozer was still down. The bulldozer moved forward until its main section was totally over the place where Rachel had been standing. It paused and then backed over her and continued reversing until it was about twenty metres away. I saw Rachel again at this point lying on her back in a twisted position. She had blood coming from her mouth and nose. I moved aside to let other activists with first aid training take steps. I ran to Dr. Samirs house to get him to telephone an ambulance.

He did this and we returned together to where Rachel was lying. Leaving Rachel in the hands of more expert medical people I moved towards the bulldozer in an effort to take a photograph of its serial number. As I did this the tank came over to near where Rachel was lying and paused before reversing back to the border strip. The bulldozer moved off as I got towards it and all three machines collected together at the border strip. As I turned around from this, I saw that the ambulance crew had arrived and were putting a neck brace on Rachel. They transported her out of the area. I followed in a taxi and about five minutes after arriving at the hospital learned she was dead.

I wish to say the incident resulting in her death took place on open ground twenty metres in front of me in clear light. I had a totally unobstructed view. I also wish to state that my actions and those of the other ISM activists were totally non-violent.

I the undersigned Richard Purssell gave this statement concerning the death of Rachel Corrie under oath

Richard J.A Purssell

This statement was given before me, Lawyer Raji Sourani in my office in the Palestinian Centre for Human Rights, and in my presence on 19 March 2003, by Richard, J.A. Purssell. After I had given him legal warning to tell the truth, he signed his statement in the full capacity of his free and independent will.

Raji Sourani