CHARGES:

ACCUSED: Zeliko MEAKIC

18.1. Zeljko MEAKIC, intending to destroy, in whole or in part, the Bosnian Muslim and Bosnian Croat people as national, ethnic, or religious groups, was complicit with other persons in the killing of Bosnian Muslims and Bosnian Croats from the opstina Prijedor at the Omarska camp, thereby committing GENOCIDE, a crime recognised by Article 4(a) of the Statute of the Tribunal.

18.2. Zeljko MEAKIC, intending to destroy, in whole or in part, the Bosnian Muslim and Bosnian Croat people as national, ethnic, or religious groups, was complicit with other persons in causing serious bodily or mental harm to Bosnian Muslim and Bosnian Croat people from the opstina Prijedor in Omarska camp, thereby committing GENOCIDE, a crime recognised by Article 4(b) of the Statute of the Tribunal.

18.3. Zeljko MEAKIC, intending to destroy, in whole or in part, the Bosnian Muslim and Bosnian Croat people as national, ethnic, or religious groups, was complicit with other persons in the deliberate infliction of conditions of life on Bosnian Muslim and Bosnian Croat people from the opstina Prijedor at the Omarska camp calculated to bring about their physical destruction in whole or in part, thereby committing GENOCIDE, a crime recognised by Article 4(c) of the Statute of the Tribunal.

19.1. With respect to the allegations in this indictment, Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN knew or had reason to know that persons in positions of subordinate authority to them at Omarska camp were about to commit those acts, or had already committed those acts, and failed to take the necessary and reasonable steps to prevent those acts or to punish the perpetrators after the acts had been committed.

19.2 During the operation of Omarska camp, camp guards and others who were subordinate to Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN regularly and openly killed, raped, tortured, beat, and otherwise subjected prisoners to conditions of constant humiliation, degradation, and fear of death.

ACCUSED: Zeliko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN in their capacity as superiors.

19.3. Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in the wilful killing of Omarska prisoners, including those described in paragraphs hereunder, GRAVE BREACHES OF THE GENEVA CONVENTIONS OF 1949 (hereinafter GRAVE BREACHES) recognised by Articles 2(a) and 7(3) of the Statute of the Tribunal, or;

19.4. Alternatively, Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in the murder of Omarska prisoners, including those described in paragraphs hereunder, VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(3) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

19.5. Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in the murder of Omarska prisoners, including those described in paragraphs hereunder, CRIMES AGAINST HUMANITY recognised by Articles 5(a) and 7(3) of the Statute of the Tribunal

19.6. Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in the torture of Omarska prisoners, GRAVE BREACHES recognised by Articles 2(b) and 7 (3) of the Statute of the Tribunal, or;

19.7. Alternatively, Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in the torture of Omarska prisoners, VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(3) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

19.8. Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in the torture of Omarska prisoners, CRIMES AGAINST HUMANITY recognised by Articles 5(f) and 7(3) of the Statute of the Tribunal

19.9. Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in the rape of Omarska prisoners, including those described in paragraphs hereunder, CRIMES AGAINST HUMANITY recognised by Articles 5(g) and 7(3) of the Statute of the Tribunal.

19.10. Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in wilfully causing great suffering to Omarska prisoners, including those described in paragraphs hereunder, GRAVE BREACHES recognised by Articles 2(c) and 7(3) of the Statute of the Tribunal. or:

19.11. Alternatively, Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in the commission of outrages upon personal dignity, including humiliating and degrading treatment of the Omarska prisoners, VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(3) of the Statute of the Tribunal and Article 3(1)(c) of the Geneva Conventions.

19.12. Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for the acts of their subordinates in the unlawful confinement of civilians, including those listed in paragraphs hereunder, GRAVE BREACHES recognised by Articles 2(g) and 7(3) of the Statute of the Tribunal, or;

19.13. Zeljko MEAKIC, Miroslav KVOCKA, Dragoljub PRCAC, Mladen RADIC, Milojica KOS and Momcilo GRUBAN are criminally responsible for their own acts or omissions and for the acts of their subordinates in the unlawful imprisonment of the prisoners of Omarska, including those listed in paragraphs hereunder, CRIMES AGAINST HUMANITY recognised by Articles 5(e) and 7(3) of the Statute of the Tribunal.

ACCUSED: Zeliko MEAKIC

20.1. Around 20 July 1992, the last remaining pocket of Bosnian Muslims and Bosnian Croats was captured from the area west of Prijedor town known as the Brdo. Many were taken to Omarska camp. When they arrived, Zeljko MEAKIC and camp guards beat them severely with batons and others weapons.

20.2. Zeljko MEAKIC wilfully caused these prisoners great suffering or serious injury to body or health, a GRAVE BREACH recognised by Articles 2(c) and 7(1) of the Statute of the Tribunal. or;

20.3. Alternatively, Zeljko MEAKIC wilfully subjected these prisoners to cruel treatment, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(1) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

20.4. Zeljko MEAKIC committed inhumane acts on the Brdo prisoners, a CRIME AGAINST HUMANITY recognised by Articles 5(i) and 7(1) of the Statute of the Tribunal.

21.1. About 25 June 1992, during an interrogation on the first floor of the administration building, two guards beat Saud BESIC repeatedly with batons and kicked him. Zeljko MEAKIC entered the room, kicked Saud BESIC in the chest and the two guards continued to beat him until he lost consciousness.

21.2. Zeljko MEAKIC subjected Saud BESIC to inhuman treatment, a GRAVE BREACH recognised by Articles 2(b) and 7(1) of the Statute of the Tribunal, or;

21.3. Alternatively, Zeljko MEAKIC inflicted cruel treatment on Saud BESIC, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(1) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

21.4. Zeljko MEAKIC subjected Saud BESIC to inhumane acts, a CRIME AGAINST HUMANITY recognised by Articles 5(i) and 7(1) of the Statute of the Tribunal.

ACCUSED: Mladen RADIC

22.1. During June and July, 1992, Mladen RADIC repeatedly subjected "A" to forcible sexual intercourse. The first occasion was on or about the night of 25 June 1992. Mladen RADIC took "A" to a room downstairs in the administration building, forced her on a table and subjected her to forcible sexual intercourse. Two or three nights later, RADIC again called "A" out of the room where she slept and again subjected her to forcible sexual intercourse. On at least three more occasions during June and July 1992, Mladen RADIC called "A" out of the room in the administration building where she slept and subjected her to forcible sexual intercourse. These crimes are charged separately below:

First Incident

22.2. Around 25 June, 1992, Mladen RADIC wilfully caused "A" great suffering by subjecting her to forcible sexual intercourse, a GRAVE BREACH recognised by Article 2(c) of the Statute of the Tribunal or;

22.3. Alternatively, around 25 June 1992, Mladen RADIC subjected "A" to cruel treatment by forcible sexual intercourse, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Article 3 of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

22.4. Around 25 June 1992, Mladen RADIC raped "A", a CRIME AGAINST HUMANITY recognised by Article 5(g) of the Statute of the Tribunal.

Second Incident

22.5 Around 27 June 1992, Mladen RADIC wilfully caused "A" great suffering by subjecting her to forcible sexual intercourse, a GRAVE BREACH recognised by Article 2(c) of the Statute of the Tribunal, or;

22.6. Alternatively, around 27 June 1992, Mladen RADIC subjected "A" to cruel treatment by forcible sexual intercourse, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Article 3 of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

22.7. Around 27 June, 1992, Mladen RADIC raped "A", a CRIME AGAINST HUMANITY recognised by Article 5(g) of the Statute of the Tribunal.

Third Incident

22.8. During July, 1992, Mladen RADIC wilfully caused "A" great suffering by subjecting her to forcible sexual intercourse, a GRAVE BREACH recognised by Article 2(c) of the Statute of the Tribunal, or;

22.9. Alternatively, during July, 1992, Mladen RADIC subjected "A" to cruel treatment by forcible sexual intercourse, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Article 3 of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

22.10. During July, 1992, Mladen RADIC raped "A", a CRIME AGAINST HUMANITY recognised by Article 5(g) of the Statute of the Tribunal.

Fourth Incident

22.11. During late July, 1992, Mladen RADIC wilfully caused "A" great suffering by subjecting her to forcible sexual intercourse, a GRAVE BREACH recognised by Article 2(c) of the Statute of the Tribunal, or;

22.12. Alternatively, during late July, 1992, Mladen RADIC subjected "A" to cruel treatment by forcible sexual intercourse, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Article 3 of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

22.13. During late July, 1992, Mladen RADIC raped "A", a CRIME AGAINST HUMANITY recognised by Article 5(g) of the Statute of the Tribunal.

Fifth Incident

22.14. During late July, 1992, Mladen RADIC wilfully caused "A" great suffering by subjecting her to forcible sexual intercourse, a GRAVE BREACH recognised by Article 2(c) of the Statute of the Tribunal, or;

22.15. Alternatively, during late July 1992, Mladen RADIC subjected "A" to cruel treatment by forcible sexual intercourse, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Article 3 of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

22.16. During late July, 1992, Mladen RADIC raped "A", a CRIME AGAINST HUMANITY recognised by Article 5(g) of the Statute of the Tribunal.

ACCUSED: Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC.

23.1. In about July 1992, Zoran ZIGIC, Dusan KNEZEVIC and a third unknown person savagely beat Becir MEDUNJANIN on two occasions over a two day period in the "white house." The accused assaulted Becir MEDUNJANIN with a club, a chair, a baton and kicked him. The morning after the second assault Becir MEDUNJANIN died in the room and his body was removed from the camp immediately.

23.2. Zoran ZIGIC and Dusan KNEZEVIC participated in the wilful killing of Becir MEDUNJANIN, a GRAVE BREACH recognised by Article 2(a) and 7(1) of the Statute of the Tribunal, or;

23.3. Alternatively, Zoran ZIGIC and Dusan KNEZEVIC participated in the murder of Becir MEDUNJANIN, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(1) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

23.4. Zoran ZIGIC and Dusan KNEZEVIC participated in the murder of Becir MEDUNJANIN, a CRIME AGAINST HUMANITY recognised by Articles 5(a) and 7(1) of the Statute of the Tribunal.

24.1. On or about 10 June 1992, Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC went to the Omarska camp. ZIGIC, KNEZEVIC, SAPONJA, and JANJIC were not regular guards at the camp, but were allowed into the camp to murder, beat or otherwise physically abuse the prisoners. On that particular day, they called four prisoners at the Omarska camp, Emir BEGANOVIC, Rezak HUKANOVIC, Asef KAPETANOVIC, and Sefik TERZIC into the "white house" and severely beat them. The accused used metal batons and cables, a knife, their fists and kicked the victims with their military-style boots. victim: Emir BEGANOVIC

24.2. Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in wilfully causing serious injury to the body or health of Emir BEGANOVIC, a GRAVE BREACH recognised by Articles 2(c) and 7(1) of the Statute of the Tribunal, or;

24.3. Alternatively, Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in subjecting Emir BEGANOVIC to cruel treatment, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(1) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

24.4. Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in subjecting Emir BEGANOVIC to inhumane acts, a CRIME AGAINST HUMANITY recognised by Articles 5(i) and 7(1) of the Statute of the Tribunal. victim: Rezak HUKANOVIC

24.5. Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in wilfully causing serious injury to the body or health of Rezak HUKANOVIC, a GRAVE BREACH recognised by Articles 2(c) and 7(1) of the Statute of the Tribunal, or;

24.6. Alternatively, Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in subjecting Rezak HUKANOVIC to cruel treatment, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(1) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

24.7. Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in subjecting Rezak HUKANOVIC to inhumane acts, a CRIME AGAINST HUMANITY recognised by Articles 5(i) and 7(1) of the Statute of the Tribunal.

victim: Asef KAPETANOVIC

24.8. Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in wilfully causing serious injury to the body or health of Asef KAPETANOVIC, a GRAVE BREACH recognised by Articles 2(c) and 7(1) of the Statute of the Tribunal, or;

24.9. Alternatively, Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in subjecting Asef KAPETANOVIC to cruel treatment, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(1) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

24.10. Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in subjecting Asef KAPETANOVIC to inhumane acts, a CRIME AGAINST HUMANITY recognised by Articles 5(i) and 7(1) of the Statute of the Tribunal.

victim: Sefik TERZIC

24.11. Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in wilfully causing serious injury to the body or health of Sefik TERZIC, a GRAVE BREACH recognised by Articles 2(c) and 7(1) of the Statute of the Tribunal, or;

24.12. Alternatively, Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in subjecting Sefik TERZIC to cruel treatment, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(1) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

24.13. Zoran ZIGIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Nikica JANJIC participated in subjecting Sefik TERZIC to inhumane acts, a CRIME AGAINST HUMANITY recognised by Articles 5(i) and 7(1) of the Statute of the Tribunal.

ACCUSED: GRUBAN

25.1. Between early June and 3 August 1992, a guard at the Omarska camp with the surname GRUBAN, who was a member of Mladen RADIC's shift, repeatedly forced "F" from the room where she was sleeping, took her to another room on the first floor of the administration building in the Omarska camp and subjected her to forcible sexual intercourse.

25.2. GRUBAN wilfully caused "F" great suffering by subjecting her to forcible sexual intercourse, a GRAVE BREACH recognised by Article 2(c) of the Statute of the Tribunal. or;

25.3. Alternatively, GRUBAN-subjected "F" to cruel treatment by forcible sexual intercourse, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Article 3 of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

25.4. GRUBAN raped "F", a CRIME AGAINST HUMANITY recognised by Article 5(g) of the Statute of the Tribunal.

ACCUSED: Predrag KOSTIC a/kla KOLE

26.1. Between early June and 3 August 1992, Predrag KOSTIC, a guard at the Omarska camp, forced "F" from the room where she was sleeping, took her to another room on the first floor of the administration building in the Omarska camp and subjected her to forcible sexual intercourse.

26.2. Predrag KOSTIC wilfully caused "F" great suffering by subjecting her to forcible sexual intercourse, a GRAVE BREACH recognised by Article 2(c) of the Statute of the Tribunal. or:

26.3. Alternatively, Predrag KOSTIC subjected "F" to cruel treatment by forcible sexual intercourse, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Article 3 of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

26.4. Predrag KOSTIC raped "F", a CRIME AGAINST HUMANITY recognised by Article 5(g) of the Statute of the Tribunal.

ACCUSED: MILUTIN POPOVIC, DRAZENKO PREDOJEVIC, ZELJKO SAVIC and NEDELJKO PASPALJ

27.1 Around 6 July 1992, on the "pista", the victim Rizah HADZALIC, in response to a comment by a guard, used a common polite Bosnian Muslim expression, "Bujrum". The accused Milutin POPOVIC, together with the co-accused Drazenko PREDOJEVIC, Zeljko SAVIC, Nedeljko PASPALJ and a guard known only as "Nedo", went to Rizah HADZALIC and beat him for using this Muslim expression. The four accused and "Nedo" beat Rizah HADZALIC until he fell to the ground in a sitting position. About half an hour later, Rizah HADZALIC died as a result of the beating.

27.2. Milutin POPOVIC, Drazenko PREDOJEVIC, Zeljko SAVIC and Nedeljko PASPALJ participated in the wilful killing of Rizah HADZALIC, a GRAVE BREACH recognised by Article 2(a) and 7(1) of the Statute of the Tribunal, or;

27.3. Alternatively, Milutin POPOVIC, Drazenko PREDOJEVIC, Zeljko SAVIC and Nedeljko PASPALJ participated in the murder of Rizah HADZALIC, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 and 7(1) of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

27.4. Milutin POPOVIC, Drazenko PREDOJEVIC, Zeljko SAVIC and Nedeljko PASPALJ participated in the murder of Rizah HADZALIC, a CRIME AGAINST HUMANITY recognised by Article 5(a) and 7(1) of the Statute of the Tribunal.

ACCUSED: MILAN PAVLIC

28.1. In early June, 1992, a large group of prisoners were confined in the canteen area of the administration building of the Omarska Camp. One night an elderly man, Mehmedalija NASIC, stood up and shouted in apparent protest over the prisoners' confinement. He was, at the time, distressed and possibly mentally disturbed by the conditions that he had been forced to endure. The accused, Milan PAVLIC, a regular guard at Omarska, ordered him to sit down. NASIC did not sit down, and after a few minutes PAVLIC fired his rifle, killing the victim and wounding several other prisoners sitting nearby.

28.2. Milan PAVLIC, wilfully killed Mehmedalija NASIC, a GRAVE BREACH recognised by Article 2(a) of the Statute of the Tribunal, or;

28.3. Alternatively, Milan PAVLIC, murdered Mehmedalija NASIC, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Article 3 of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

28.4. Milan PAVLIC, murdered Mehmedalija NASIC, a CRIME AGAINST HUMANITY recognised by Article 5(a) of the Statute of the Tribunal.

ACCUSED: Zdravko GOVEDARICA

29.1. On or about 17 June 1992, Zdravko GOVEDARICA, a guard in the Omarska camp, with four other guards whose names are not known, took Serif VELIC, a prisoner in the camp, to a room in the Administration Building where they stripped him to his underwear, kicked him in the testicles, repeatedly beat him with a baton and rifle, and kicked him in the ribs, causing him to lapse in and out of consciousness.

29.2. Zdravko GOVEDARICA wilfully subjected Serif VELIC to great suffering, a GRAVE BREACH recognised by Article 2(c) of the Statute of the Tribunal, or;

29.3. Alternatively, Zdravko GOVEDARICA subjected Serif VELIC to cruel treatment, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, recognised by Article 3 of the Statute of the Tribunal and Article 3(1)(a) of the Geneva Conventions.

29.4. Zdravko GOVEDARICA subjected Serif VELIC to inhumane acts, a CRIME AGAINST HUMANITY recognised by Article 5(i) of the Statute of the Tribunal

ACCUSED: MIRKO BABIC

30.1. "F" was taken to the Omarska camp as a prisoner in early June 1992. Sometime between early June and 3 August 1992, "F" was taken to the Separcija building at the entrance to the Omarska camp and placed in a room where MIRKO BABIC subjected "F" to forcible sexual intercourse.

30.2. MIRKO BABIC wilfully caused great suffering to "F" by subjecting her to forcible sexual intercourse, a GRAVE BREACH recognised by Article 2(c) of the Statute of the Tribunal, or;

30.3. Alternatively, MIRKO BABIC subjected "F" to cruel treatment by forcible sexual intercourse, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Article 3 of the Statute of the Tribunal and Article 3 (1) (a) of the Geneva Conventions of 1949.

30.4. MIRKO BABIC raped "F", a CRIME AGAINST HUMANITY recognised by Article 5(g) of the Statute of the Tribunal.

ACCUSED: DUSAN KNEZEVIC

31.1. Around the latter part of June or first part of July 1992, near the building known as the "white house," a group of Serbs from outside the camp, including DUSAN KNEZEVIC, ordered prisoners, whose names are not known, to drink water like animals from puddles on the ground, jumped on their backs and beat them until they were unable to move. As the victims were removed in a wheelbarrow, one of the Serbs discharged the contents of a fire extinguisher into the mouth of one of the victims.

31.2. DUSAN KNEZEVIC participated in wilfully causing a group of Omarska prisoners, whose names are not known, great suffering or serious injury to body or health, a GRAVE BREACH recognised by Articles 2(c) and 7(1) of the Statute of the Tribunal, or;

31.3. Alternatively, DUSAN KNEZEVIC participated in subjecting these unknown Omarska prisoners to cruel treatment, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR recognised by Articles 3 (1) (a) of the Geneva Conventions.

31.4. DUSAN KNEZEVIC participated in subjecting these unknown Omarska prisoners to inhuman acts, a CRIME AGAINST HUMANITY recognised by Articles 5(I) and 7(1) of the Statute of the Tribunal.

Richard J. Goldstone
Prosecutor

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