Statement Condemning Assassination of Cecilia Monzon
SUMMARY
The New York City Bar Association joins Mexico and Spain in mourning human rights lawyer and activist Cecilia Monzón’s violent and untimely death. The City Bar looks to the Mexican authorities at the local, state, and national levels to bring to justice those responsible for her assassination. And, more generally, the City Bar calls on the Mexican authorities to take all measures necessary to ensure that the country’s human rights lawyers – including women, in particular – are able to fulfill their professional obligations safely and without impediment. The City Bar proudly stands in solidarity with human rights lawyers and other rights defenders in Mexico and elsewhere around the globe, and wholeheartedly supports their vital work seeking a better, more just, more peaceful, and equal world for all.
REPORT
The New York City Bar Association (“City Bar”) condemns the brazen, brutal assassination of human rights lawyer and activist Cecilia Monzón in Puebla, Mexico on May 21, 2022.[1]
CECELIA MONZÓN’S ASSASSINATION
On the morning of May 21, Cecilia Monzón was driving her SUV (sport-utility vehicle) in the municipality of San Pedro Cholula, in the central Mexican state of Puebla.[2] At approximately 9:54 a.m., as Monzón was driving on Camino Real to Momoxpan, at the height of the Periférico Ecológico in Santiago Momoxpan, two men on a motorcycle who had been following her pulled up next to her vehicle.[3] The man on the back of the motorcycle drew a gun, firing multiple times.[4] Monzón was struck three times and was killed instantly.[5] The two assailants fled the scene.[6]
MONZÓN’S TARGETING AS A WOMAN HUMAN RIGHTS DEFENDER
The President of Mexico, Andrés Manuel López Obrador, did not mince words. He labeled Monzón’s assailants “assassins” and “hit men,” and described the shooting as a clear-cut “execution.”[7]
Monzón was a nationally-renowned lawyer and human rights activist. Best known as a champion of women’s rights, she was often referred to as “the women’s lawyer.”[8] Over the years, she represented hundreds of women in a wide array of matters, including divorce, alimony, child custody and support, pensions, gender bias/discrimination, sexual harassment, family- and gender-based violence, and sexual assault and abuse, among others.[9]
As a result of the nature of her work,[10] Monzón was a frequent target of harassment, attempted intimidation, and threats, including death threats. For example, one threat ominously cautioned Monzón to be careful with the brakes on her SUV. Another threat advised her to make arrangements for a babysitter for her four-year-old son, asserting that “soon her absence would be long.”[11] Monzón repeatedly sought precautionary measures of protection, but her requests were denied.[12]
THE RESPONSE TO MONZÓN’S ASSASSINATION
In the women’s community and in human rights circles, the news of Monzón’s assassination was met with frustration and fury.[13] The murder was condemned around the world, from Spain, Norway, and Switzerland to the European Union and the United Nations.[14] In Mexico, hundreds of women rallied, demonstrated, and marched in protest, dressed in white and carrying photos of Monzón[15]; and nearly 2000 women’s rights activists, human rights defenders, politicians, journalists, and women from all walks of life signed a petition demanding justice for her.[16] A viral social media campaign engaged thousands more people, using the hashtags “#JusticiaParaCecelia” and “#CeciliaMonzón.”[17]
Local, state and federal law enforcement authorities launched a joint investigation, and three suspects have now been arrested.[18] However, noting the prevailing climate of impunity, the women’s community has little confidence that justice will be done.[19] In the meantime, Monzon’s young son is under heavy guard.[20]
Regrettably, whether it is viewed as a case of femicide or as a fatal attack on a human rights defender,[21] Monzón’s murder is not an isolated case. Reports indicate that “11 women are murdered daily” in Mexico[22]; and the nation is one of the most dangerous countries in the world for human rights lawyers and other rights defenders (male or female).[23]
PROTECTIONS FOR MONZÓN UNDER INTERNATIONAL LAW
Mexico is a party to the American Convention on Human Rights and is therefore obligated to accord individuals certain fundamental rights enshrined in that instrument.[24] For example, Article 4 of the Convention protects the “[r]ight to [l]ife,” and Article 5 specifies that “[e]very person has the right to have his physical, mental, and moral integrity respected.”[25]
Even more specifically, international law recognizes the unique role that lawyers play in any society. Because lawyers serve as the guardians of justice for all, international law accords lawyers special protections.[26] For example, the U.N. Basic Principles on the Role of Lawyers provide that “[l]awyers shall not be identified with their clients or their clients’ causes as a result of discharging their functions.” In other words, clients’ positions and causes are not to be attributed to their counsel.[27] The U.N. Basic Principles further provide that governments are to “ensure that lawyers are able to perform all of their professional functions without intimidation, hindrance, harassment or improper interference.”[28] In addition, “[w]here the security of lawyers is threatened as a result of discharging their functions,” the U.N. Basic Principles state that lawyers “shall be adequately safeguarded by the authorities.”[29] Monzón was entitled to all of these protections.
RESOLUTION AND CALL TO ACTION
The New York City Bar Association joins Mexico and Spain in mourning Monzón’s violent and untimely death. The City Bar looks to the Mexican authorities at the local, state, and national levels to bring to justice those responsible for her assassination. And, more generally, the City Bar calls on the Mexican authorities to take all measures necessary to ensure that the country’s human rights lawyers – including women, in particular – are able to fulfill their professional obligations safely and without impediment. The City Bar proudly stands in solidarity with human rights lawyers and other rights defenders in Mexico and elsewhere around the globe, and wholeheartedly supports their vital work seeking a better, more just, more peaceful, and equal world for all.
June 2022
Footnotes
[1] More than 150 years old, the New York City Bar is an organization of approximately 24,000 members in New York City and elsewhere throughout the United States, and in more than 50 countries around the globe. Its members include judges, prosecutors, defense counsel, government lawyers, and public interest/non-governmental organization practitioners, as well as legal academics and attorneys representing nearly every major law firm and corporation in the United States. The City Bar has a long and distinguished history of promoting the rule of law and human rights, including the rights of legal professionals to fulfill their professional obligations. The City Bar’s Task Force on the Independence of Lawyers and Judges and its Inter-American Affairs Committee assisted with this Statement, as did the Cyrus R. Vance Center for International Justice.
[2] See Lawyer and activist Cecilia Monzón murdered in Mexico (Today90, May 22, 2022) (“Today90-1”), https://www.today90.com/lawyer-and-activist-cecilia-monzon-murdered-in-mexico-news/; They kill activist Cecilia Monzón in Puebla (Newsbeezer, May 22, 2022) (“Newsbeezer-1”), https://newsbeezer.com/mexicoeng/they-kill-activist-cecilia-monzon-in-puebla/. (All websites cited in this statement were last visited June 14, 2022.)
[3] See Murder of activist Cecilia Monzón “was an execution” by hit men: AMLO (The News 24, May 23, 2022) (“News 24”), https://then24.com/2022/05/23/murder-of-activist-cecilia-monzon-was-an-execution-by-hit-men-amlo/; Puebla Prosecutor’s Office works to clarify the murder of activist Cecilia Monzón (American Post, May 24, 2022) (“Am Post-1”),
https://www.americanpost.news/puebla-prosecutors-office-works-to-clarify-the-murder-of-activist-cecilia-monzon/; Who was Cecilia Monzón? This is how they remember the murdered lawyer (Archyde, May 25, 2022) (“Archyde-1”), https://www.archyde.com/who-was-cecilia-monzon-this-is-how-they-remember-the-murdered-lawyer/; Today90-1, supra n.2; Cecilia Monzón: “There are solid elements” in the investigation into the activist’s murder (Paudal, May 26, 2022) (“Paudal-1”), https://www.paudal.com/2022/05/26/cecilia-monzon-there-are-solid-elements-in-the-investigation-into-the-activists-murder/; Helena Monzon: “Silence killed my sister and is killing women in Mexico” (El Pais/Spam Chronicles, May 27, 2022) (“El Pais-1”),
https://www.spamchronicles.com/helena-monzon-silence-killed-my-sister-and-is-killing-women-in-mexico/.
[4] See Puebla Prosecutor’s Office Confirms That Monzón’s Murder Was Planned; Analyze Crime Videos (Hot Movies News, May 24, 2022) (“Movies News-1”),
https://hotmoviesnews.com/2022/05/24/puebla-prosecutors-office-confirms-that-monzons-murder-was-planned-analyze-crime-videos/.
[5] See Activist and lawyer Cecilia Monzón was shot dead in Puebla (Newsbeezer, May 22, 2022) (“Newsbeezer-2”),
https://newsbeezer.com/mexicoeng/activist-and-lawyer-cecilia-monzon-was-shot-dead-in-puebla/; Cecilia Monzón: They kill the activist and lawyer in Puebla (Paudal, May 22, 2022) (“Paudal-2”), https://www.paudal.com/2022/05/22/cecilia-monzon-they-kill-the-activist-and-lawyer-in-puebla/.
[6] See News 24, supra n.3; El Pais-1, supra n.3.
[7] See Paudal-1, supra n.3; The murder of Cecilia Monzón was an execution, says AMLO; SSPC expects prompt identification of culprits (Canadian News, May 23, 2022) (“Canadian News-1”), https://thecanadian.news/the-murder-of-cecilia-monzon-was-an-execution-says-amlo-sspc-expects-prompt-identification-of-culprits/; see also Government condemns murder of Spanish lawyer and activist Cecilia Monzón in Mexico (The Diplomat in Spain, May 24, 2022) (quoting President of Mexico referring to Monzón‘s assailants as “hired killers”),
https://thediplomatinspain.com/en/?p=279089.
Although Monzón resided and practiced law in Mexico, she was a national of both Mexico and Spain. See Mexico: The Observatory condemns the murder of women’s rights lawyer Cecilia Monzón (Observatoire international des avocats en danger (“OIAD”), May 24, 2022) (“OIAD”), https://protect-lawyers.org/en/item/cecilia-monzon/; Paudal-1, supra n.3; El Pais-1, supra n.3; The UN-DH condemned the murders of Cecilia Monzón and Humberto Valdovinos (Paudal, May 26, 2022) (“Paudal-3”), https://www.paudal.com/2022/05/26/the-un-dh-condemned-the-murders-of-cecilia-monzon-and-humberto-valdovinos/.
Like the President of Mexico, the government of Spain condemned Monzón’s murder. See Official Statement, Murder of Cecilia Monzón (Government of Spain/Ministry of Foreign Affairs, European Union and Cooperation, May 23, 2022) (“Statement of Spain”),
https://www.exteriores.gob.es/en/Comunicacion/Comunicados/Paginas/2022_COMUNICADOS/20220523_COMU036.aspx; see also infra n.14 & accompanying text).
[8] See, e.g., Who was Cecilia Monzón, the lawyer and activist murdered in Puebla? (Latin American News, May 23, 2022) (“Latin American-1”), https://latin-american.news/who-was-cecilia-monzon-the-lawyer-and-activist-murdered-in-puebla/; Today90-1, supra n.2; Paudal-1, supra n.3; Archyde-1, supra n.3.
Monzón was also known for her pro-abortion stance. See Canadian News-1, supra n.7; Lawyer and activist Cecilia Monzón murdered in Mexico (NewsWep, May 22, 2022), https://newswep.com/news/lawyer-and-activist-cecilia-monzon-murdered-in-mexico/; Today90-1, supra n.2.
[9] See The feminist activist Cecilia Monzón is killed in Puebla (Mazatlan Weekly, May 21, 2022),
https://www.mazatlanweekly.com/2022/05/22/the-feminist-activist-and-lawyer-cecilia-monzon-is-killed-in-puebla/; Newsbeezer-2, supra n.5; Paudal-2, supra n.5; Groups demonstrate for the murder of activist Cecilia Monzón in Puebla (Latin American News, May 22, 2022) (“Latin American-2”), https://latin-american.news/groups-demonstrate-for-the-murder-of-activist-cecilia-monzon-in-puebla/; Latin American-1, supra n.8.
Monzón herself was a plaintiff/claimant in several cases which raised gender issues. For example, at the time of her death, Monzón had a claim for alimony pending against Javier Lopez Zavala (the former Secretary of Social Development in the government of Mario Marin Torres (2005-2011) and a former candidate for governor of Puebla), who is the father of her four-year-old son. See Latin American-1, supra n.8; Paudal-1, supra n.3; El Pais-1, supra n.3; AMLO regrets the murder of activist Cecilia Monzón in Puebla (American Post, May 23, 2022) (“Am Post-2”), https://www.americanpost.news/amlo-regrets-the-murder-of-activist-cecilia-monzon-in-puebla/.
Just one day before her assassination, Monzón had visited the prosecutor’s office to voice her consternation that, even though all the necessary paperwork had been filed, there was no progress in deciding her claim. See Latin American-1, supra n.8; News 24, supra n.3; Paudal-1, supra n.3; Am Post-2, supra n.9.
Monzón was politically active as well, and served as a public official. For example, Monzón was a candidate for the Presidency of the municipality of San Pedro for the Green Ecologist Party of Mexico (“PVEM”), and then served as the Director of Social Development for the municipality in the administration of Luis Alberto Arriaga. See OIAD, supra n.7; Latin American-1, supra n.8; Lawyer and activist Cecilia Monzón shot to death in Puebla (El Pais/Mexico, May 22, 2022), https://newsfounded.com/mexicoeng/lawyer-and-activist-cecilia-monzon-shot-to-death-in-puebla/; Lawyer and activist Cecilia Monzón shot to death in Puebla (Archyde, May 22, 2022) (“Archyde-2”), https://www.archyde.com/lawyer-and-activist-cecilia-monzon-shot-to-death-in-puebla/; Newsbeezer-2, supra n.5; Paudal-3, supra n.7; Lawyer and activist Cecilia Monzon shot dead in Puebla (The Rimont/El Pais, May 23, 2022) (“Rimont”), https://minifeednews.com/latest-news/lawyer-and-activist-cecilia-monzon-shot-dead-in-puebla/25093/; Indigenous Woman Released/Activist Killed in Puebla (Mexico Business News, May 23, 2022) (“Business News”), https://mexicobusiness.news/policyandeconomy/news/indigenous-woman-released-activist-killed-puebla.
[10] See generally, e.g., El Pais-1, supra n.3 (noting that Monzón‘s work put her squarely “in the crosshairs of power, machismo and patriarchy”).
[11] See Latin American-1, supra n.8; OIAD, supra n.7; Femicide: Who was Cecilia Monzón, the activist murdered in Puebla? (Paudal, May 23, 2022), https://www.paudal.com/2022/05/23/femicide-who-was-cecilia-monzon-the-activist-murdered-in-puebla/; El Pais-1, supra n.3; Paudal-3, supra n.7; News 24, supra n.3; Defender attorney Cecilia Monzón López assassinated in San Pedro Cholula, Puebla (Mesoamerican Initiative of Women Human Rights Defenders, May 31, 2022) (“WHRD Initiative”),
https://im-defensoras.org/2022/05/whrd-alert-mexico-defender-attorney-cecilia-monzon-lopez-assassinated-in-san-pedro-cholula-puebla/; Business News, supra n.9.
[12] See OIAD, supra n.7; WHRD Initiative, supra n.11; National Citizen Observatory of Femicide Condemns the Murder of Cecilia Monzón (Hot Movies News, May 24, 2022) (“Movies News-2”), https://hotmoviesnews.com/2022/05/24/national-citizen-observatory-of-femicide-condemns-the-murder-of-cecilia-monzon/; Latin American-1, supra n.8; El Pais-1, supra n.3; Archyde-1, supra n.3; News 24, supra n.3; Paudal-3, supra n.7; Rimont, supra n.9.
[13] See, e.g., They kill Cecilia Monzón, lawyer and activist, in Puebla (California18, May 21, 2022) (reporting that “[t]he murder of the activist has generated outrage among politicians and people who knew her”) (“California18”), https://california18.com/they-kill-cecilia-monzon-lawyer-and-activist-in-puebla/4730192022/; Am Post-2, supra n.9 (reporting that “[t]he murder of the activist has generated outrage in the population of Puebla and at the national level, especially among feminist groups”); Government of Puebla condemns murder of activist Cecilia Monzón (Paudal, May 22, 2022) (reporting that news of Monzón’s murder “caused great sorrow and indignation”),
https://www.paudal.com/2022/05/22/government-of-puebla-condemns-murder-of-activist-cecilia-monzon/; Movies News-2, supra n.12 (summarizing list of demands made by the Observatory, a coalition of 42 civil society organizations); Rimont, supra n.9 (stating that “[d]ozens of organizations, feminist activists and human rights platforms have [condemned] the murder, demanding justice and calling on the authorities, [the] Governor . . . and federal executive agencies such as the National Women’s Institute, not to let the crime go unpunished”).
[14] See Statement of Spain, supra n.7; European Union condemns the murder of Cecilia Monzón and asks that the case not go unpunished (Today90, May 25, 2022) (“Today90-2”), https://www.today90.com/european-union-condemns-the-murder-of-cecilia-monzon-and-asks-that-the-case-not-go-unpunished/; Paudal-1, supra n.3; El Pais-1, supra n.3; Paudal-3, supra n.7.
[15] See https://es.entertainmentoverdose.co.uk/lawyer-and-feminist-activist-cecilia-monzon-was-assassinated-in-puebla-el-financiero/; Cecilia Monzón: They march in Puebla to demand justice for the murder of the activist (htnewz, May 22, 2022) (“Htnewz”), https://htnewz.com/cecilia-monzon-they-march-in-puebla-to-demand-justice-for-the-murder-of-the-activist/; Am Post-2, supra n.9; Activist Cecilia Monzón murdered in Puebla state, Mexico (Europe World News, May 22, 2022), https://www.europeworldnews.com/activist-cecilia-monzon-murdered-in-puebla-state-mexico/; Defender attorney Cecilia Monzón López assassinated in San Pedro Cholula, Puebla (Mesoamerican Initiative of Women Human Rights Defenders, May 31, 2022),
https://im-defensoras.org/2022/05/whrd-alert-mexico-defender-attorney-cecilia-monzon-lopez-assassinated-in-san-pedro-cholula-puebla/; Latin American-2, supra n.9 (featuring photo of some demonstrators).
[16] See Movies News-2, supra n.12; Unfolded: More than a thousand women demand justice for Cecilia Monzón (Hot Movies News, May 23, 2022) (quoting list of demands set forth in petition and including a copy of the petition itself), https://hotmoviesnews.com/2022/05/23/unfolded-more-than-a-thousand-women-demand-justice-for-cecilia-monzon/; Htnewz, supra n.15; Archyde-1, supra n.3.
[17] See Puebla Prosecutor’s Office works to clarify the murder of activist Cecilia Monzón (Pledge Times, May 22, 2022), https://pledgetimes.com/puebla-prosecutors-office-works-to-clarify-the-murder-of-activist-cecilia-monzon/; Archyde-1, supra n.3 (including example of tweet using hashtags); Am Post-1, supra n.3.
[18] See, e.g., Without a doubt, the assassins killed her; AMLO on Cecilia Monzón, an activist murdered in Puebla (American Post, May 23, 2022),
https://www.americanpost.news/without-a-doubt-the-assassins-killed-her-amlo-on-cecilia-monzon-an-activist-murdered-in-puebla/; Archyde-1, supra n.3; News 24, supra n.3; Am Post-2, supra n.9; California18, supra n.13; Archyde-2, supra n.9; Am Post-1, supra n.3; Cecilia Monzón, the women’s lawyer, was murdered in Puebla (Poblanerias, June 8, 2022) (reporting, inter alia, that one of the suspects is the father of Monzón’s son), https://www.poblanerias.com/2022/06/cecilia-monzon-was-murdered-in-puebla/.
[19] See, e.g., El Pais-1, supra n.3 (stating that Mexico’s impunity rate is 95% and criticizing “the machismo and inaction permeating the Mexican authorities and judiciary”);
“Femicide nation”: murder of young woman casts spotlight on Mexico’s gender violence crisis (The Guardian, April 26, 2022) (citing the “rampant impunity” vis-à-vis femicides in Mexico, “where more than 90% of crimes go unsolved”; referring to Mexican authorities’ “botched and apathetic response” to the country’s “worsening gender violence crisis”) (“The Guardian”), https://www.theguardian.com/society/2022/apr/26/murder-young-woman-mexico-femicide.
[20] See Local prosecutor will give protection to the son of an activist murdered in Puebla (Canadian News, May 24, 2022), https://thecanadian.news/local-prosecutor-will-give-protection-to-the-son-of-an-activist-murdered-in-puebla/; News 24, supra n.3.
[21] As one civil society organization has observed, Monzón made a particularly large and tempting target, because of the combination of her gender and the fact of her work as a human rights defender – a “double whammy.” See Movies News-2, supra n.12 (referring to Monzón’s “double situation of vulnerability”).
[22] See Movies News-2, supra n.12 (reporting that, in Mexico, “11 women are murdered daily”); El Pais-1, supra n.3 (acknowledging that, in Mexico, there are “more than 10 women murdered a day”); Am Post-2, supra n.9 (stating that, in Mexico, “more than 10 women are murdered every day”); News 24, supra n.3 (reporting that, in Mexico, “more than 10 women are murdered every day”); The Guardian, supra n.19 (quoting source stating that 11 women are killed daily in Mexico; reporting that, in 2021, Mexico recorded 1015 cases of femicide – where a woman is murdered specifically because of her gender; further stating that, in 2021, approximately 3500 women were killed overall).
[23] See Paudal-3, supra n.7 (reporting on Monzón’s murder, as well as the May 23, 2022 murder of Humberto Valdovinos, a Mexican defender of land rights and the rights of Afro-Mexican people, and stating that, in Mexico, 25 human rights defenders and environmental defenders were murdered in 2021 alone – an average of more than two per month); Movies News-2, supra n.12 (stating that, of all the countries in the world, Mexico “occupies one of the first places . . . where human rights defenders are murdered for carrying out their work”); News 24, supra n.3 (reporting that Mexico is “one of the most dangerous countries [in the world] for activists”); Am Post-2, supra n.9 (stating that Mexico is “one of the most dangerous countries for activists”); see also OIAD, supra n.7 (highlighting “the appalling wave of violence against women lawyers in Mexico,” citing in particular the murders of Veronica Guerrero and Patricia Rivera Reyes in March 2022); WHRD Initiative, supra n.11 (emphasizing that Monzón’s murder “comes on top of 4 assassinations of women defenders and journalists [this year, through May 31, 2022] at a national level and forms part of 14 attacks registered [in the first five months of 2022] in the state of Puebla”).
[24] See American Convention on Human Rights (Organization of American States, Nov. 22, 1969), https://www.cidh.oas.org/basicos/english/basic3.american%20convention.htm; Signatories and Ratifications, American Convention on Human Rights, https://www.cidh.oas.org/basicos/english/Basic4.Amer.Conv.Ratif.htm.
[25] See American Convention on Human Rights, supra n.24, Article 4; id., Article 5(1); see also id., Article 8(1) (stating that “[e]very person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal”); id., Article 24 (providing that “[a]ll persons are equal before the law” and are thus “entitled, without discrimination, to equal protection of the law”); see generally OIAD, supra n.7.
Mexico is also bound by the jurisprudence of the Inter-American Court of Human Rights. See generally OIAD, supra n.7; Caso Digna Ochoa y Familiares vs. Mexico, Sentencia de 25 de Noviembre de 2021 (cited in OIAD, supra n.7).
In addition, as a national of Spain, Monzón was entitled to the rights set forth in the European Convention on Human Rights, which is to much the same effect. See Convention for the Protection of Human Rights and Fundamental Freedoms (Council of Europe, Nov. 4, 1950) (“European Convention on Human Rights”), https://www.echr.coe.int/Pages/home.aspx?p=basictexts&c; see generally, e.g., id., Article 2 (“Right to life”); id., Article 3 (“Prohibition of torture”); id., Article 5 (“Right to liberty and security”); id., Article 6 (“Right to a fair trial”); id., Article 14 (“Prohibition of discrimination”); Chart of signatures and ratifications of Treaty 005 (Council of Europe),
https://www.coe.int/en/web/conventions/full-list?module=signatures-by-treaty&treatynum=005.
[26] See generally United Nations Basic Principles on the Role of Lawyers (Sept. 7, 1990), https://www.ohchr.org/en/instruments-mechanisms/instruments/basic-principles-role-lawyers; see also United Nations Basic Principles on the Independence of the Judiciary (Sept. 6, 1985), Principles 2, 4, & 11,
https://www.ohchr.org/en/instruments-mechanisms/instruments/basic-principles-independence-judiciary.
[27] See U.N. Basic Principles on the Role of Lawyers, Principle 18.
[28] See U.N. Basic Principles on the Role of Lawyers, Principle 16; see also Statement of Spain, supra n.7 (calling on Mexican authorities at all levels “to deploy all . . . efforts possible to effectively protect human rights advocates so that they may exercise their work without endangering their lives”);
Archyde-1, supra n.3 (same); Today90-2, supra n.14 (same).
[29] See U.N. Basic Principles on the Role of Lawyers, Principle 17.
