33. Beginning in January 1993 and through to May 1993, HVO forces or their agents, under the direction or control of Dario KORDIC and Tihofil BLASKIC, on the basis of political, racial and religious grounds, unlawfully bombarded the central shopping area of Zenica and systematically attacked hundreds of undefended dwellings or buildings in numerous towns, villages and hamlets in diverse locations in the Lasva Valley area that were owned, and many of which were occupied, by Bosnian Muslim civilians, and were of no military significance at the time of the attack or bombardment, in order to kill, terrorize, or demoralize the Bosnian Muslim population. These incidents resulted in hundreds of Bosnian Muslim civilian casualties in numerous locations including but not limited to:

LOCATION						COMMENCEMENT DATE

Ahmici 16 April 1993, 5:30 a.m. Busovaca January 1993 and 26 April 1993 Gacice 20 April 1993, 5:50 a.m. Kacuni January 1993 Loncari 17 April 1993 Nadioci 16 April 1993, 5:30 a.m. Ocenici 19 April 1993 Pirici 16 April 1993, 6:00 a.m. Putis 16 April 1993 Santici 16 April 1993, 5:30 a.m. Sivrino Selo 16 April 1993 Stari Vitez 16 April 1993, 5:45 a.m. Veceriska/Donja Veceriska 16 April 1993, 5:30 a.m. Vitez 16 April 1993, 5:15 a.m. Zenica 19 April 1993

34. All events described in paragraphs 23-33 were directed against Bosnian Muslim civilians on political, racial and religious grounds. Individually and collectively, these actions were on such a large scale and widespread basis, and implemented in such a systematic fashion, that they have effectively destroyed or removed almost the entire Muslim civilian population from those areas of the Lasva Valley where the HVO and the Bosnian Croat administration has taken control.

COUNTS 1-3

CRIMES AGAINST HUMANITY 35. Dario KORDIC and Tihofil BLASKIC, between 1 May 1992 and 31 May 1993, individually, and in concert with others, planned, instigated, ordered or otherwise aided and abetted in the planning, preparation or execution of the following crimes:

a) persecutions of Bosnian Muslims in the Lasva Valley area of the Republic of Bosnia and Herzegovina, on political, racial and religious grounds,

b) bombardments and attacks which caused the death of over one hundred Bosnian civilians in the Lasva Valley area and the city of Zenica, in the Republic of Bosnia and Herzegovina,

c) inhumane acts against Bosnian civilians in the Lasva Valley area, and civilians in the central shopping district of the city of Zenica, in the Republic of Bosnia and Herzegovina,

and, or in the alternative, knew, or had reason to know, that subordinates were about to do the same, or had done so, and failed to take the necessary and reasonable measures to prevent such acts or to punish the perpetrators thereof.

By these acts and omissions Dario KORDIC and Tihofil BLASKIC committed:

Count 1: a CRIME AGAINST HUMANITY as recognized by Articles 5(h) (persecution on political, racial, and religious grounds), 7(1) and 7(3) of the Statute of the Tribunal (as described in paragraphs 23-24, which are incorporated in full herein);

Count 2: a CRIME AGAINST HUMANITY as recognized by Articles 5(a) (murder), 7(1) and 7(3) of the Statute of the Tribunal (as described in paragraphs 24-25 which are incorporated in full herein);

Count 3: a CRIME AGAINST HUMANITY as recognized by Articles 5(I) (inhumane acts), 7(1) and 7(3) of the Statute of the Tribunal (as described in paragraphs 23,28-34, and all references to the wounding or harming of many Bosnian civilians as set out in paragraphs 24-25, all of which are incorporated in full herein).

COUNTS 4-7

GRAVE BREACHES AND VIOLATION OF THE LAWS OR CUSTOMS OF WAR

WILLFUL KILLING AND WOUNDING OF BOSNIAN MUSLIM CIVILIANS

36. Dario KORDIC, Tihofil BLASKIC and Mario CERKEZ, between 1 January and 31 May 1993, and as described in paragraphs 24-25 of this indictment, both of which are incorporated in full herein, individually, and in concert with others, planned, investigated, ordered or otherwise aided and abetted in the planning, preparation, or execution of the murder of over one hundred civilians and the wounding of many others in the Lasva Valley area and in the city of Zenica, in the Republic of Bosnia and Herzegovina and, or in the alternative, knew, or had reason to know, that subordinates were about to do the same, or had done so, and failed to take the necessary and reasonable measures to prevent such acts or to punish the perpetrators thereof.

By these acts and omissions Dario KORDIC, Tihofil BLASKIC, and Mario CERKEZ committed:

Count 4: a GRAVE BREACH as recognized by Articles 2(a) (willful killing), 7(1) and 7(3) of the Statute of the Tribunal;

Count 5: a GRAVE BREACH as recognized by Articles 2(c) (willfully causing great suffering or serious injury to body or health), 7(1) and 7(3) of the Statute of the Tribunal;

Count 6: a VIOLATION OF THE LAWS OR CUSTOMS OF WAR as recognized by Articles 3(deliberate attack on the civilian population and individual civilians), 7(1) and 7(3) of the Statute of the Tribunal;

Count 7: a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognized by Article 3, 7(1), and 7(3) of the Statute of the Tribunal and Article 3(l)(a)(murder) of the Geneva Conventions of 1949.

COUNTS 8-10

GRAVE BREACHES AND VIOLATION OF THE LAWS OR CUSTOMS OF WAR

UNLAWFUL TREATMENT OF BOSNIAN MUSLIM DETAINEES

37. Dario KORDIC, Tihofil BLASKIC, Mario CERKEZ, Ivan SANTIC, Pero SKOPLJAK and Zlatko ALEKSOVSKI, between 01 January and 31 May 1993, and as otherwise described in paragraphs 23 and 26-31 this indictment, all of which are incorporated in full herein, individually, and in concert with others, planned, instigated, ordered or otherwise aided and abetted in the planning, preparation or execution of the unlawful treatment of Bosnian Muslim detainees in the Lasva Valley area of the Republic of Bosnia and Herzegovina and, or in the alternative, knew, or had reason to know, that subordinates were about to do the same, or had done so, and failed to take the necessary and reasonable measures to prevent such acts or to punish the perpetrators thereof.

By these acts and omissions Dario KORDIC, Tihofil BLASKIC, Mario CERKEZ, Ivan SANTIC, Pero SKOPLJAK and Zlatko ALEKSOVSKI committed:

Count 8: a GRAVE BREACH as recognized by Articles 2(b) (inhuman treatment), 7(1) and 7(3) of the Statute of the Tribunal;

Count 9: a GRAVE BREACH as recognized by Articles 2(c) (willfully causing great suffering or serious injury to body or health), 7(1) and 7(3) of the Statute of the Tribunal;

Count 10: a VIOLATION OF THE LAWS OR CUSTOMS OF WAR (outrages upon the personal dignity) as recognized by Articles 3, 7(1) and 7(3) of the Statute of the Tribunal.

COUNTS 11-13

GRAVE BREACH AND VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR

ATTACKS, BOMBARDMENTS, AND DESTRUCTION OF CIVILIAN PROPERTY

38. Dario KORDIC, Tihofil BLASKIC and Mario CERKEZ, between 1 January and 31 May 1993 and otherwise as described in paragraphs 23-25 and 32-33 of this indictment, all of which are incorporated in full herein, individually, and in concert with others, planned, instigated, ordered or otherwise aided and abetted in the planning, preparation or execution of the unlawful attacking, bombarding and destruction of, Bosnian Muslim dwellings, businesses, buildings, personal property and livestock in the Lasva Valley area of the Republic of Bosnia and Herzegovina, and, or in the alternative, knew, or had reason to know that subordinates were about to do the same, or had done so, and failed to take the necessary and reasonable measures to prevent such acts or to punish the perpetrators thereof.

By these acts and omissions Dario KORDIC, Tihofil BLASKIC and Mario CERKEZ, committed:

Count 11: a GRAVE BREACH as recognized by Articles 2(d) (extensive destruction of property), 7(1) and 7(3) of the Statute of the Tribunal;

Count 12: a VIOLATION OF THE LAWS OR CUSTOMS OF WAR (wanton destruction of dwellings or other installations that are used only by the civilian population, including places of religious worship) as recognized by Articles 3, 7(1) and 7(3) of the Statute of the Tribunal;

Count 13: a VIOLATION OF THE LAWS OR CUSTOMS OF WAR (attacks on dwellings or other installations that are used only by the civilian population, including places of religious worship) as recognized by Articles 3, 7(1) and 7(3) of the Statute of the Tribunal.

November 1995
The Hague, The Netherlands
Richard J. Goldstone, Prosecutor
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