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27 Penn St. Int'l L. Rev. 895 (2008-2009)
Taking Judicial Notice in the Genocide in Rwanda: The Right Choice

handle is hein.journals/psilr27 and id is 901 raw text is: I Comments I Taking Judicial Notice of the Genocide in Rwanda: The Right Choice Rebecca Faulkner* I. INTRODUCTION At the Roman Catholic Church compound in Shangi, Rwanda, bloody handprints remain on the walls as a gruesome reminder of the Hutu massacre of Tutsis that occurred on April 18, 1994.1 In one room, handprints stretch from floor to ceiling, showing how Tutsis stood on one another's shoulders in desperate efforts to reach ceiling crawl spaces and the roof in order to hide from Hutu militiamen.2 Other rooms are bullet- pocked or partially blown apart by hand grenades.3 Although no one knows for sure, it is estimated that as many as 4,000 Tutsis-adults and children alike-were hacked, shot, or beaten to death at the Shangi * Juris Doctor, The Dickinson School of Law of the Pennsylvania State University, 2009; Bachelor of Arts, Wheaton College, Norton, Massachusetts, 2006. Special thanks to my family and friends who supported and encouraged me during the writing process. Thank you also to the PILSR members who took the time to read this Comment and provide thoughtful critique. 1. See Jonathan C. Randal, A Mosaic of Bloody Handprints Recalls 4,000 Tutsis' Last Day of Life, WASH. POST, June 29, 1994, at A 17. 2. See id. 3. See id.

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