The Shame of Escobilla, Part II
On the Trail of Antonio Suárez: The slaughter of turtles on a beach in Mexico threatened to wipe out a species. Then the man behind it all made a mistake.
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Originally published in Outside‘s November 1982 issue
Very few human beings, I believe, could tour that dump near the slaughterhouse on the beach called Escobilla and remain unmoved. There, rotting reptilian bodies were piled one atop the other, as far as the eye could see. Near the entrance to these acres of death there was a pile of eggs—an entire generation, or so it seemed—
rotting away under a blazing tropical sun.
I saw that dump in October of 1977. I had gone to Mexico expecting to write a pleasant little report on what promised to be an awesome natural phenomenon. On the beach called Escobilla, in the state of Oaxaca, on the Pacific coast not far from the Guatemalan border, some 100,000 turtles were said to come up out of the sea and lay their eggs in the sand. The olive ridley, an 80-pound animal about the size of a manhole cover, had come up onto the beach at Escobilla on nights of the full moon, 100,000 strong, for as long as anyone could remember. These massive arribazónes—
arrivals—happened approximately once a month from midsummer through late fall.
I had been invited to see the arribazón by a man named Juan José de la Vega, the director of a Mexican environmentalist group called the Cosmographic Society. Also invited by De la Vega and on hand for the expected arribazón was a film crew from ABC’s American Sportsman. As it happened, the crew was lucky to get good footage of a single turtle laying her eggs in the sand: There was no arribazón in October of 1977. Politics and greed had gotten in the way, and the dump at Escobilla was the result.
The article I wrote, “The Shame of Escobilla,” was published in the February 1978 issue of Outside. The pleasant little story I had envisioned became a horror of death and despair. Antonio Suárez, the man in charge of the slaughter, felt Outside had judged him “harshly.”
Despite the fact that the situation seemed to me to be hopeless—
no laws were being broken, after all—there wasa mad scramble of activity. I was invited to international conferences, asked to file affidavits, to submit copies of the Outside article to environmental groups in support of lawsuits initiated by them.
In the four years since the publication of that hopeless story, my fileon the turtles of Escobilla has expanded enough to fill an entire drawer, and the story no longer seems quite so hopeless. It is a continuing tale, one of criminal conspiracies, of investigations and counter-investigations, of well-intentioned people working at cross-purposes, of evil—and hints of redemption.
All I ever wanted to do was watch those turtles swim up out of the sea and lay their eggs on the beach. What I actually saw on the beach called Escobilla in October of 1977 lives in my mind like a wound.
In 1977 there was an experiment underway at Escobilla, a deadly experiment involving the survival of an entire species of animal.
In previous years, harvesting of sea turtles during the nesting season had been prohibited, for good reason. In the days that precede the arribazón, female ridleys mass in the ocean, vulnerable, just beyond the breakers. There are thousands of them bobbing in the swells, as far as the eye can see. Sunlight glitters off their shells. At this time they are slow, nearly somnambulant, driven by instinct, and they are easily caught by divers.
The ban on harvesting turtles during the breeding season had been lifted in 1976, and in October of 1977 men were catching the turtles beyond the breakers, slaughtering them faster and more efficiently than ever before. Lifting the ban had been a controversial move. The turtles were listed in the 1975 reptile Red Data Book as endangered: “in danger of extinction and whose survival is unlikely if causal factors keep operating.”
De la Vega had brought this situation to the attention of the media in 1976. The fishing company, PIOSA, and its director general, Antonio Suárez, were sensitive to the criticism. Instead of restoring the prohibition against harvesting, however, Suarez had picked up the lion’s share of the tab for the construction of a laboratory dedicated to the preservation of the olive ridley.
Here’s the way the lab was supposed to work: As the turtles were slaughtered, eggs would be taken from the female’s oviducts. These eggs would be buried in the sand or in styrofoam boxes filled with sand. There they would be protected from predators, such as domestic dogs and coyotes, not to mention those human jackals, the men who poach turtle eggs for profit.
The eggs fetch a good price in the marketplaces of Mexico’s larger cities; ignorant and impotent men believe they are an aphrodisiac. Poachers, catering to that trade, will strip a beach of 100 percent of its eggs, and in consequence, leatherback, green, and olive ridley turtles have all but disappeared from certain unprotected beaches. The poachers are organized and vicious. The new lab at Escobilla was named for Daniel Guevara, a lawman murdered by poachers in the course of his investigation of a major egg-smuggling ring.
Eggs from the slaughtered females would be concentrated in the area around the lab, protected by Mexican marines and PIOSA employees. As hatchlings emerged, they would be collected, put in large tanks, and fed until there were enough of them to be boated out and dumped beyond the breakers.
Protecting the eggs from poachers was a noble-enough idea, but a little reading about set turtles in the most elementary scientific texts indicates that there were several things wrong with the central concept of the lab. No one had any idea what the hatch rate would be from eggs taken out of the slaughtered females, only that it would be a fraction of that from eggs laid naturally. There was also a probability that the hatchlings, in captivity, would become “pen-happy,” that once the swimming frenzy of the first day of birth had passed, they would wallow about indolently where dumped, there to be snapped up by predators or washed back onto the beach by the tide. Finally, whatever mechanism it is that causes ridleys to return to the beach of their birth to lay their eggs might be short-circuited.
There was one other thing wrong with this lab. It was a hoax.
The media was on hand in force for the dedication of the lab that stormy Sunday afternoon in the fall of 1977. There were more than 25,000 hatchlings swimming about in 106 tanks. The governor of the state made a speech, and newsmen got plenty of pictures of the lab’s benefactor, Antonio Suárez, who smiled modestly.
Several days later I returned to the lab. All the tanks were empty. All the hatchlings were gone. The mature turtles in the large tanks—the ones whose mating habits were going to be studied—had been taken to the slaughterhouse, or so said an old man eating his lunch under a tree. He was the only person I could find at the “lab.”
The hatchlings in those tanks on dedication day, I discovered later, had been collected on the beach at Escobilla, and they had hatched from eggs laid there naturally. They had been brought from Escobilla to the lab to deceive the media and the Mexican people.
On the last day of my visit to Escobilla I visited the slaughterhouse dump, the most evil place I have ever seen. “The dump,” I wrote soon afterward, “is located on several low hills just southeast of the slaughterhouse. When the turtles have been slaughtered, the 12 pounds of good meat has been stripped from the bone, and leather has been stripped from the head and chest, the remains are dumped onto these hills like garbage and left to dry in the sun before the bones and shells are ground into fertilizer.
“The stench here—the odor of death—was unholy….Vultures retreated reluctantly as I approached. Here and there I saw flippers stripped of their flesh, their five fingers, like yours and mine, jutting out of black putrescent meat.
“There were eggs there too, where no eggs should be. Mixed with the bowels of their slaughtered mothers, they were heaped into a sprawling pile and covered with maggots. I suspect someone will tell me that PIOSA only chooses the finest eggs to go bad in the sand or in those styrofoam boxes, and that these were rejects. But I saw that pile with my own eyes. There were thousands upon thousands of eggs, all rotting in that evil heap.
“I was, quite literally, sick to my stomach.”
That was the tone of the article: bitter, angry, hopeless. It was full of words like evil, and those words were always used in proximity to the name Antonio Suárez.
In late 1977 things were going very well indeed for Antonio Suárez. His men were killing as many as 700 turtles a day, the governor of Oaxaca had complimented him on his efforts in the field of conservation, and Tecnica Pesquera, the magazine of the Mexican fishing industry, had published a long and laudatory article on the lab. Suárez was selling the turtle leather and making enough money, apparently, to continue the obscene slaughter at Escobilla. Mexican law required him to make use of all parts of a turtle. The shells and bones could be used as fertilizer, but the processed meat was a problem. Olive ridley is not considered a tasty turtle, not in Mexico or Central America. The turtle soup and turtle steaks that are prized come from the green turtle. So Suárez was sitting on a few hundred thousand pounds of meat, which, if not precisely worthless, was not making him any money either.
In December of 1977—according to an indictment later handed down by a Miami grand jury—Antonio Suárez and several others met in a luxury apartment in Mexico City, and there they entered into an illegal conspiracy to dispose of all that cumbersome turtle meat.
A few weeks after the Outside article was published, I received a letter from Dr. Peter Pritchard, vice-president for science and research at the Florida Audubon Society. Dr. Pritchard, having recently returned from a fact-finding mission to Escobilla, wrote: “When I was there in late November, they were still killing 500-700 turtles per day, and every one was a female containing eggs…. The local PIOSA jefe told me that the story behind the opening ceremony of the research facility and the subsequent draining of the tanks was simply that the plumbing system was not ready for dedication day, so they had hand-filled the system just for the ceremony, then emptied it again. They still did not have their plumbing system in operation when I was there, but they were ‘working on it’…. I, like you, was revolted by what I saw….The feds say that they will clamp down and close the season if the turtles show a diminution in numbers. Unfortunately, it may be too late then—the Kemp’s ridley, on the other coast, has shown no recovery even after a decade of full protection…Open season during the breeding time is a sure recipe for disaster.”
“Shame” was reprinted in the IUCN (International Union for Conservation of Nature and Natural Resources) Marine Turtle Newsletter. Dr. Pritchard wrote a commentary, and I quote from him again, not only because his comments are cogent, but because it will later be important to know exactly where he stands. Reflecting on his visit to the slaughterhouse, Pritchard wrote, “I found the sight of the beautiful female ridleys, fresh from the sea, being bashed in with iron bars and deftly eviscerated, one after the other, 500 or more per day, a disgusting and demoralizing sight, and I found the idea of creatures being butchered in this way when they were gathering to lay their eggs totally unacceptable, both emotionally and biologically.”
Pritchard had questioned the director of the Mexican Department of Fisheries, who had, apparently, been quite frank. PIOSA, he said, had been allowed to fish during the breeding season, had been allowed such dangerously high quotas, because it would be logistically difficult and extremely expensive to field a small army of enforcement personnel in remote coastal Oaxaca. It was thought that if Suárez got the quotas he wanted, he would, in turn, see that those eggs laid naturally or buried at the lab would be adequately protected from poachers. Pritchard’s commentary went on to question the concept of the lab itself and mentioned that the Suárez /PIOSA operation constituted the largest butchery of turtles in the world.
In the summer of 1978 ABC aired its American Sportsman segment on the plight of the olive ridley. Producer/director John Wilcox and associate producer Bob Nixon had put together a, powerful and emotional documentary. It was all there on film: the lab with thousands of turtles in the tanks and the media standing around looking suitably impressed, followed by empty tanks only two days later. There was a final shot of the dump, that foul boneyard, and all those eggs, the next generation, rotting away in that maggot-infested heap.
A small groundswell of public support seemed to be building, and the Environmental Defense Fund took good and proper advantage of it. They threatened to sue the United States federal government: The EDF demanded that the olive ridley and two other species of sea turtle be declared a threatened species under the Endangered Species Act. Threat of suit was enough. The olive ridley was declared to be endangered. The effect of the action was to prohibit importation of any of the protected turtles or of products derived from them.
Things started to go bad for Antonio Suárez in the spring of 1979. In California Charles Clark, a Marine Fisheries Service agent, came across a shipment of freezer packages labeled “chunked Tabasco River Turtle.” Clark examined the meat. It was not light-colored, like freshwater turtle. It was dark, beef-red, fibrous: more like sea turtle. Clark notified Charles Fuss, the special agent in charge of law enforcement for the National Marine Fisheries Service in St. Petersburg, Florida. Fuss had been getting similar reports about sea-turtle meat for sale in Florida. But as a result of the federal action taken the previous July, all six species of sea turtle found in the Western Hemisphere had been declared endangered or threatened. Fuss geared up an investigation.
There were 12 agents on Fuss’s investigative team, and it was a rare case of near total cooperation between government agencies: There were people from the Fish and Wildlife Service, from the U.S. Customs Service, from the National Marine Fisheries Service, and from the Wildlife and Marine Resources section of the Justice Department.
The interagency team talked with turtle experts. It was perfectly legal to import Tabasco River turtle (that has since changed), but according to José Toro, a special attorney for the Justice Department, the investigators were looking at nearly 190,000 pounds of it. And there were not enough Tabasco River turtles in all of Mexico to account for that much meat.
One element of the investigative team, working with customs declarations, followed a paper trail to a seafood exporter in Mexico. The man had no knowledge of the shipments pouring into Miami International Airport. Investigators determined that export papers had been stolen from the company’s office, that signatures had been forged in what appeared to be a criminal conspiracy of some proportion.
Meanwhile, Sylvia Braddon, a research chemist with the National Marine Fisheries Service, was working to identify the meat in those packages of “Tabasco River Turtle.” The technique she used is called isoelectric focusing. It involves passing a strong charge of electricity through a small sample of meat for several hours. Eventually the protein “focuses,” forming a microscopic pattern of blue lines, distinct for each species.
In order to identify the species involved, Braddon would have to test the lines developed from the suspect meat against those from the meat of every other freshwater and saltwater turtle in the world. Luckily the investigators had a pretty good idea of what kind of meat they were dealing with: 190,000 pounds seemed to implicate the most prolific turtle butcherer in the world, Antonio Suárez.
Peter Pritchard provided one of the samples of ridley meat used by Braddon. The thin blue lines from Pritchard’s sample matched exactly those fromthe meat in the suspect tins.
So it was ridley meat. The fact that only one man in the world would have that much olive ridley meat to sell doesn’t cut much ice legally. There was still a blizzard of paper and a forest of middlemen between Antonio Suárez and all that illegal meat.
It was a very difficult case, but José Toro had a plan.
I knew nothing about the investigation of Antonio Suárez in the late summer of 1979. The story had pretty much died down as far as I knew; so I was surprised to get a strange and urgent call about Suárez a year and half after the publication of the story.
The man on the phone sounded like a guy who knew his Raymond Chandler and who subscribed to Soldier of Fortune magazine; the kind of guy who might weigh 300 pounds, smoke cigars, and talk out of the side of his mouth. He was calling from Los Angeles, or so he said, and he claimed to represent a group of wealthy southern California conservationists with the money to “provide extraordinary solutions to extraordinary problems.”
“The slaughterhouse,” he said, “it’s located on a pretty remote stretch of beach, isn’t it? You give us the layout, we could be in and out of there in 20 minutes. We’d be in Mexico 10, 12 hours, tops.”
“You’re not…are you suggesting some sort of, uh, paramilitary operation?”
“I’m suggesting that we talk to these bastards in the only language they understand.”
“Well, you know, I’m not really sure that, uh”—this lunatic was talking about bombing Mexico!—”we’d be able to, uh, do much good, uh, that way!”
There was a pause while the man seemed to consider his options. “All right,” he said finally, “you tell me. How do we stop this guy Suárez?”
I wish I could say I pegged him immediately, but it was only after he hung up that it occurred to me that the guy was neither a militant environmentalist nor a flaming nutcase. He sounded more like a very clever professional investigator. “O.K.,” he kept saying, “if that won’t work, how do we get Suárez?”
If indeed the man was an investigator of some sort, then he was pumping me for any nasty information I might have on Suárez. The most prolific turtle butcher in the world must have been a very worried man.
Events slid around the bend and went careening downhill for Suárez in November 1979. Suarez had been meeting with Pritchard—the two men would spend eight hours at a crack, arguing their way through a long lunch—and Pritchard invited him to the United States to speak at the First World Conference for World Sea Turtle Conservation. According to Pritchard, Suárez had initially thought that those who opposed him were obstructionists, sentimentalists who didn’t like killing, vegetarians, hippies. “But,” Pritchard told me, “he was impressed by scientists, by reasonable men with facts at their fingertips.” Pritchard saw the conference as a process of give-and-take, a learning experience for Suárez, who he felt was coming around to a more rational approach.
The Justice Department’s José Toro, unknown to Pritchard, attended the conference for entirely different reasons.
“Mr. Suarez,” Pritchard told me, “was very nervous. He was speaking in the largest room of the United States State Department to 500 of the most knowledgeable sea-turtle experts in the world.”
Worse, members of the World Wildlife Fund had put copies of the Outside article on every seat. Two unidentified men, described to me as “large and probably Mexican,” went from seat to seat, confiscating the reprints. No matter, the WWF people handed out more reprints as the delegates entered the room. They had also arranged showings of the ABC Sportsman segment.
Suárez spoke before an unresponsive and surly crowd. As he stepped off the podium, he was surrounded by federal agents and handed a subpoena. Apparently he panicked. Suárez fled. He flew back to Mexico, leaving his clothes and luggage in his hotel room.
“I knew,” José Toro told me, “that there was a great quantity of olive ridley meat involved, and that seemed to point to Mr. Suárez. We had no legal proof, however, and the subpoena only involved his records. I went into the investigation with an open mind, but when Mr. Suárez fled, we began concentrating on him.”
Toro and other agents took up the paper trail once again. Names on letterheads submitted to United States Customs led to a group of Cuban businessmen in Miami, and inquiries there led to another group of Cubans in Mexico City. There, Toro, who was born in Puerto Rico and of course speaks fluent Spanish, began looking for the man any investigator wants to find: the fellow with a gripe.
On Toro’s list of people he wanted to talk to was a man named Martin Zacarias. It looked to Toro as if Zacarias has once been involved in the conspiracy but had been somehow muscled out of the business. There were three separate meetings in Mexico City, and because Zacarias was no longer involved in the business, Toro felt justified in granting him immunity in exchange for information. On the third meeting, Zacarias produced a sample customs document, written in pencil. It contained the precise wording used in the customs declarations for the illegal meat.
Zacarias said that the sample document had been drawn up during a meeting in Mexico City sometime in December of 1977. At that meeting he and other individuals present had conspired to fraudulently mislabel olive ridley meat and export it to the United States. One of the individuals present was named Antonio Suárez.
Taking this information to the grand jury in Miami, Toro was able to obtain an indictment against Suárez, PIOSA, and five other individuals and corporations. Suárez hired the best lawyers he could find and returned to the United States only after plea negotiations had been completely worked out. On October 28, 1981, Suárez pleaded guilty to all charges and paid a total of $50,000 in fines.
Antonio Suárez eventually quit the turtle-slaughtering business. “No,” Toro told me, “that was not part of the plea negotiations. I think that we denied him the United States market, and perhaps the business is no longer profitable.” Toro, who shares a Latin background with Suárez, thinks there may be something else involved. “Antonio Suárez,” Toro said, “is a very proud man, very concerned with dignity. He is very Latin in that respect. I think it was devastating to his ego to stand before that judge, to be declared guilty, to acknowledge that he engaged in criminal acts. I think for him the worst humiliation came at the arraignment, when they took him downstairs for fingerprinting and mug shots.
“You could,” Toro said, “almost feel sorry for him.”
So the butcher of Escobilla was driven from the beach in humiliation and disgrace. The good guys won, the villain was crushed, and the turtles were saved for all eternity.
That’s the way I’d like to end this report. But the turtles are not yet saved, and Antonio Suárez may not have been a total villain.
According to Dr. Peter Pritchard, “It was easy to see Suárez as evil incarnate, and that is how I saw him at first.” After talking with him for a while, Pritchard saw that Suárez truly believed industrialization was the only way to preserve the turtles: If turtles are were worth more the local people than eggs are worth to poachers, then poaching would stop on the beach.
What Suárez didn’t believe was that harvesting during the nesting season was harmful to the population as a whole. “He was beginning to come around to our point of view,” said Pritchard. “Hard facts, statistics, scientific research impressed him. That is why I invited him to the sea-turtle conference in Washinton.” That is where Suárez was served with the subpoena.
“I knew nothing about that,” Pritchard said. When Suárez fled, Pritchard raced to the airport. He wanted to assure Suárez that he had not betrayed him. “We didn’t talk for some time after that,” Pritchard said. “He did call me when he made the decision to quit the business, though. He was very concerned about what the world thought of him. He didn’t want to be known as the man who was killing off an entire species of animal. I remember I once asked him what he thought about the Outside article. I thought he would scream and yell, call it a pack of lies. Instead he looked very sad. ‘They judged us harshly,’ he said. He was sensitive to that judgment.”
Perhaps the person whose opinion counted most with Suárez was his daughter. “He loves his daughter,” Pritchard said. “He dotes on her. He told me once that if she even told him to quit the business, he would at once, without question. One day he called me. Now I’m sure there are many other reasons for his decision, but he said, ‘Peter, Fernanda asked me to stop killing turtles.'”
Suárez sold his turtle operation to Propemex, a government-owned company that continues to kill the animals at a furious pace. “Suárez,” says Pritchard, “was the strongman, el Chingón, the man in charge. You could reason with him. Now you see bureaucrats who shrug their shoulders and pass you on to other bureaucrats.”
Carlos Nagle, a consultant for the World Wildlife Fund, puts it more bluntly. “If what you really wanted was to save the turtles, then you have to see what happened to Antonio Suárez as a tragedy. He was a typical poacher on his way to becoming a game warden. He is a very intelligent man, and he could see the long-range consequences.”
But Suárez is gone, and the bureaucrats of Propemex are the new butchers on the beach.
The situation, however, is anything but hopeless. Things are not the same in Mexico as they were in 1977. Then, the only conservationists on the beach at Escobilla were Juan José de la Vega and Boris de Swan of the Cosmographic Society. By 1981, during the largest arribazón of the year, more than 150 conservationists hit the beach, like commandos. Aside from Juan José and members of the Cosmographic Society, there were representatives of two other growing environmentalist groups, Amigos del Universo and Bioconservation.
“The marines,” Juan José told me, “made it possible for us to be there. I can’t praise them enough. When the arribazón started, they provided a plane for us. We flew down from Mexico City and got on the beach only a few hours after the first turtles crawled up on the beach.” The conservationists spread out, with people taking stations every 50 yards. They stayed two weeks. “Poachers don’t want the eggs after a week or so,” Juan José said. “They hatch in 40 to 45 days, but hatchlings begin to form inside very quickly. No one would eat an egg with a turtle head in it.”
As the conservationists helped the marines patrol the beach, the navy patrolled the water out beyond the breakers. New Fisheries regulations require all fishing to stop for seven days after the start of an arribazón.
More than 70 reporters covered the operation. The public saw what was happening on television and heard about it on radio. Nine of the most influential newspapers in Mexico ran front-page articles on the plight of the turtles. Two documentary films were produced, and both were eventually shown on television. Juan Ruiz Healy, a popular reporter on Mexico’s 60 Minutes, did a devastating report on poachers and sellers.
People like Juan José see the media in Mexico as major allies. “The public is now aware of the problem,” Juan José told me, “and this is a dramatic change from when you first came to Escobilla.”
Ricardo Mier, of Bioconservation, adds, “It is a paradox, but the ecology movement seems to be growing here, and growing very rapidly, in spite of the current economic crisis. I think this is because we can now clearly see that true value lies in natural resources and not in pesos or dollars.”
As the public becomes more conscious of the slaughter on the beach at Escobilla, more pressure is put on the Department of Fisheries to reinstate the ban on fishing during the breeding season, or, failing that, to lower the quotas allowed Propemex to more reasonable levels.
The current quotas are absurdly high. Here are some numbers; it doesn’t take a marine biologist to analyze them.
1973: Juan José de la Vega sees his first arribazón. More than 100,000 turtles lay their eggs on the beach.
1981: The total number of turtles arriving on the beach for all arribazónes, July through November, is 50,000.
1981: The total number of turtles allowed to be killed, according to quotas set by the Department of Fisheries, is 89,000.
The number of turtles arriving on the beach in 1981 was only a tenth of what it was only a decade ago. And although 50,000 turtles reached the beach in 1981, almost twice that number were killed before they could lay their eggs. And 1981 was the sparest year for arribazónes in recent memory, which probably means that fewer turtles reached the beach than ever before, throughout the whole of time.
Juan José de la Vega says the memory of 1973, when he saw 100,000 turtles lay their eggs on the beach in a single night, is a treasure no one can take from him. He likes to relive it now and again. He stood alone, surrounded by all that…biology, and the moon was full and bright. A gentle breeze was blowing in off the ocean, and the smell of the sea was strong. All around, on all sides, as far as the eye could see on this bright night, there were turtles: turtles coming in out of the ocean, turtles laying their eggs, turtles returning to the mystery of the sea. Juan José had a sensation of a time before man a sense of the fecundity of the sea and land. There was something deep and full expanding inside of him, something other people feel only inside a church.
There is an image that lives inside my memory as well. It is a vision of that slaughterhouse dump, those acres of death. The breeze I recall was heavy with the stench of rot, warm with the weight of decay.
Propemex is still dumping bodies there, and, according to Dr. Pritchard, still dumping eggs. These eggs are said to be too immature to be buried in the sand; either that or too fouled with the mother’s intestines during the slaughtering process.
So these eggs are dumped where the bodies of the mothers are left to rot. But many of the eggs are not fouled; many are not immature. Many of them live, and hatchlings emerge to crawl over the rotting bodies of their slaughtered mothers. They crawl frantically, through the stench of death, toward a sea they will never reach.