PETITION FOR RELIEF
Chief, Claims Unit
MINUSTAH Log Base, Room No. 25A
Boulevard Toussaint Louverture & Clercine 18Tabarre, Haiti
Cc: Office of the United Nations Secretary-General
1. In October 2010, cholera broke out in the Artibonite region of Haiti. According to Haiti’s Ministère de la Santé Publique et de la Population, the disease has infected over 457,582 people and claimed over 6,477 lives as of October 2011. This request for relief and reparations is filed on behalf of over 5,000 victims of cholera in Haiti, who are the petitioners in this matter
(hereinafter “Petitioners”). The cholera outbreak is directly attributable to the negligence, gross negligence, recklessness and deliberate indifference for the health and lives of Haiti’s citizens by the United Nations (“UN”) and its subsidiary, the United Nations Stabilization Mission in Haiti
2. Numerous studies, including those of the UN itself; the United States-based Centers for Disease Control and Prevention; the Harvard Cholera Group; Dr. Renaud Piarroux, whose report the Haitian and French governments commissioned; the Wellcome Trust Sanger Institute in
Cambridge, England; and the International Vaccine Institute in Seoul, Korea, have documented that the Vibrio cholerae virus was introduced to Haitian waters by MINUSTAH personnel from Nepal.
3. The sickness, death, and ongoing harm from cholera suffered by Haiti’s citizens are a product of the UN’s multiple failures. These failures constitute negligence, gross negligence, recklessness, and deliberate indifference for the lives of Haitians. First, the UN failed to screen troops for cholera infection prior to deployment from Nepal, a country where cholera is endemic
and which had just reported a surge in infections. Second, it failed to maintain its sanitation facilities and waste disposal at the Mirebalais camp in Haiti, allowing contaminated human waste to run into the Meille River, a tributary of the Artibonite River. The Artibonite River is Haiti’s longest and most important river; it is a critical source of water for tens of thousands of Haitians who rely on it for drinking, bathing, washing clothes, and irrigation. Third, it failed to conduct accurate water quality tests in the camp and allowed testing equipment to fall into disrepair,thereby maintaining unsanitary and highly infectious conditions. Fourth, it failed to take
immediate corrective action to properly address the outbreak of disease, a product of the UN’s own failures, willfully delaying investigation and obscuring discovery of the outbreak’s source.