18. On one evening during the middle of July, 1992, a large number of detainees were called out of the rooms separately, by a group of guards and others, and severely beaten in turn. Several men died as a result of those beatings. Among them were: Jasmin IZEJIRI, "Spija" MESIC, and Drago TOKMANOVIC. Among the group of guards and others who took part in the beatings and killings were Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Goran LAJIC, Dusan KNEZEVIC, and Zoran ZIGIC.
Count:
18.1. Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Goran LAJIC and Zoran ZIGIC, did thereby commit a GRAVE BREACH, wilful killing of Jasmin IZEJIRI, recognised by Article 2(a) of the Statute;
Count:
18.2. Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Dusan KNEZEVIC, and Zoran ZIGIC, did thereby commit a GRAVE BREACH, wilful killing of "Spija" MESIC, recognised by Article 2(a) of the Statute;
Count:
18.3. Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Goran LAJIC, Dusan KNEZEVIC, and Zoran ZIGIC did thereby commit a GRAVE BREACH wilful killing of Drago TOKMANOVIC, recognised by Article 2(a) of the Statute;
Count:
18.4. Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Goran LAJIC and Zoran ZIGIC, did thereby commit a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, murder of Jasmin IZEJIRI, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions;
Count:
18.5. Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Dusan KNEZEVIC, and Zoran ZIGIC, did thereby commit a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, murder of "Spija" MESIC, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions;
Count:
18.6. Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Goran LAJIC, Dusan KNEZEVIC, and Zoran ZIGIC did thereby commit a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, murder of Drago TOKMANOVIC, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions;
Count:
18.7. Predrag BAKOVIC, Nenad BANOVIC, Nikica JANJIC, Goran LAJIC and Zoran ZIGIC, did thereby commit a CRIME AGAINST HUMANITY, murder of Jasmin IZEJIRI, recognised by Article 5(a) of the Statute:
Count:
18.8. Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Dusan KNEZEVIC, and Zoran ZIGIC, did thereby commit a CRIME AGAINST HUMANITY, murder of "Spija" MESIC, recognised by Article 5(a) of the Statute;
Count:
18.9. Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Goran LAJIC, Dusan KNEZEVIC, and Zoran ZIGIC did thereby commit a CRIME AGAINST HUMANITY, murder of Drago TOKMANOVIC, recognised by Article 5(a) of the Statute; or
Count:
18.10. alternatively to paragraphs 18.1 to 18.9, Predrag BANOVIC, Nenad BANOVIC, Nikica JANJIC, Goran LAJIC, Dusan KNEZEVIC, and Zoran ZIGIC did thereby commit a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
19. Around the latter part of June, 1992, Predrag BANOVIC, Nikica JANJIC, Dusan KNEZEVIC, Dragan KONDIC, Goran LAJIC, Dragomir SAPONJA, Zoran ZIGIC and others repeatedly called from room 2 a group of detainees including Emsud BAHONJIC. Predrag BANOVIC, JANJIC, KNEZEVIC, KONDIC, LAJIC, ZIGIC and others severely beat Emsud BAHONJIC and the other detainees using their fists and objects. The beatings occurred frequently over a period lasting approximately ten or more days. During this period, KNEZEVIC, ZIGIC and others also forced BAHONJIC to engage in various degrading, humiliating and/or painful acts, such as lying on broken glass, repeatedly jumping from a truck, and engaging in fellatio. BAHONJIC died from injuries received during the beatings.
19.1. By participating in the beatings causing the death of Emsud BAHONJIC, Predrag BANOVIC, Nikica JANJIC, Dusan KNEZEVIC, Dragan KONDIC, Goran LAJIC, Dragomir SAPONJA and Zoran ZIGIC thereby committed:
Count:
19.1.1. a GRAVE BREACH, wilful killing, recognised by Article 2(a) of the Statute:
Count:
19.1.2. a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, murder, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions; and
Count:
19.1.3. a CRIME AGAINST HUMANITY, murder, recognised by Article 5(a) of the Statute; or
Count:
19.1.4. alternatively, a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) and 7 (1) of the Statute.
19.2. By participating in forcing Emsud BAHONJIC to engage in the degrading, humiliating and/or painful acts, Dusan KNEZEVIC and Zoran ZIGIC committed:
Count:
19.2.1. a GRAVE BREACH, great suffering, recognised by Article 2(c) of the Statute;
Count:
19.2.2. a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, cruel treatment, recognised by Article 3 of the Statute and Article 3(1)(a) of the Geneva Conventions; and
Count:
19.2.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
20. Around the latter part of June, 1992, Predrag BANOVIC, Nikica JANJIC, Dusan KNEZEVIC, Dragan KONDIC, Goran LAJIC, Dragomir SAPONJA, Nedjeljko TIMARAC, Zoran ZIGIC and others frequently took from room 2 a group of detainees including a man called "Car" with a last name of JUSUFOVIC or JUSUFAGIC. Predrag BANOVIC, JANJIC, KNEZEVIC, KONDIC, LAJIC, SAPONJA, TIMARAC, ZIGIC, and others severely beat "Car" and the other detainees using their fists and objects. The beatings occurred frequently over a period lasting approximately ten or mole days. During this period KNEZEVIC, ZIGIC, and others also forced "Car" to engage in various humiliating and/or painful acts, such as running while carrying, a heavy machine gun and engaging in fellatio. "Car" died from injuries received during the beatings.
20.1. By participating in the beatings causing the death of ''Car," Predrag BANOVIC, Nikica JANJIC, Dusan KNEZEVIC, Dragan KONDIC, Goran LAJIC, Dragomir SAPONJA, Nedjeljko TIMARAC, and Zoran ZIGIC thereby committed:
Count:
20.1.1. a GRAVE BREACH wilful killing, recognised by Article 2(a) of the Statute;
Count:
20.1.2. a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, murder, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions; and
Count:
20.1.3. a CRIME AGAINST HUMANITY, murder, recognised by Article 5(a) of the Statute; or
Count:
20.1.4. alternatively, a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute;
20.2. By participating in forcing "Car" to engage in humiliating and/or painful acts, Dusan KNEZEVIC and Zoran ZIGIC thereby committed:
Count:
20.2.1. a GRAVE BREACH, great suffering, recognised by Article 2(c) of the Statute:
Count:
20.2.2. a VIOLATION OF THE LAWS OR CUSTOMS OF wAR, cruel treatment, recognised by Article 3 of the Statute and Article 3(1)(a) of the Geneva Conventions; and
Count:
20.2.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
21. Between 1 June 1992 and 5 August 1992, Dusan KNEZEVIC, Dragan KONDIC, Zoran ZIGIC, and others took out, on repeated occasions, Jasmir RAMADANOVIC known as "Sengin." KNEZIVIC, KONDIC, ZIGIC and others accused Jasmir RAMADANOVIC of being a Muslim extremist. They then beat Jasmir RAMADANOVIC severely As a result of the beatings, RAMADANOVIC received a large open wound to his head, his body was severely bruised, and he was unable to eat for approximately ten days. Dusan KNEZEVIC, Dragan KONDIC and Zoran ZIGIC thereby committed:
Count:
21.1. a GRAVE BREACH, torture, recognised by Article 2(b) of the Statute;
Count:
21.2 a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, torture, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions; and
Count:
21.3. a CRIME AGAINST HUMANITY, torture, recognised by Article 5(f) of the Statute.
22. Around the first part of June 1992, Nikica JANJIC, Dusan KNEZEVIC, Dragomir SAPONJA, and Zoran ZIGIC took out Fajzo MUKANOVIC and questioned him. When MUKANOVIC failed to provide the desired information, JANJIC, KNEZEVIC, SAPONJA and ZIGIC cut him across the neck with a knife and brought his wife and child to the camp to witness the assault. Nikica JANJIC, Dusan KNEZIVIC, Dragomir SAPONJA, and Zoran ZIGIC thereby committed:
Count:
22.1. a GRAVE BREACH, torture, recognised by Article 2(b) of the Statute;
Count:
22.2. a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, torture, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions; and
Count:
22.3. a CRIME AGAINST HUMANITY, torture, recognised by Article 5(t) of the Statute.
23. Around 23 June 1992 Dusan KNEZEVIC and Zoran ZIGIC took out from room 3 a group of detainees including Faudin HRUSTIC. KNEZEVIC, ZIGIC and others beat the detainees including Faudin HRUSTIC using objects including batons, iron bars and wooden baseball bats. Dusan KNEZEVIC and Zoran ZIGIC thereby committed:
Count:
23.1. a GRAVE BREACH, great suffering, recognised by Article 2(c) of the Statute:
Count:
23.2. a VIOLATION OF THE LAWS OF CUSTOMS OF WAR, cruel treatment, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions; and
Count:
23.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
24. On one evening during July, 1992, Predrag BANOVIC called for a specific prisoner. When he could not find him, BANOVIC then called for "Cacko," whose name was Fikret AVDIC. BANOVIC and others beat AVDIC using a baseball bat and also kicked AVDIC. AVDIC was put back into room 2 and died early the next morning. Predrag BANOVIC thereby committed:
Count:
24.1. a GRAVE BREACH, wilful killing, recognised by Article 2(a) of the Statute:
Count:
24.2. a VIOLATION OF THE LAWS OF CUSTOMS OF WAR, murder, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions; and
Count:
24.3. a CRIME AGAINST HUMANITY, murder, recognised by Article 5(a) of the Statute of the Tribunal; or
Count:
24.4. alternatively, a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute;
25. Around the latter part of June 1992, Jovo RADOCAJ, a detainee of Serbian origin, who was married to a Muslim woman and believed to be a supporter of the Bosnian Muslim Party of Democratic Action, was taken out at night. Predrag BANOVIC and others then beat him severely for an extended period of time. Jovo RADOCAJ died from his injuries several hours after the beating. Predrag BANOVIC thereby participated in the commission of:
Count:
25.1. a CRIME AGAINST HUMANITY, murder, recognised by Article 5(a) of the Statute; or
Count:
25.2. alternatively, a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
26. Around 30 July 1992, Predrag BANOVIC stopped and demanded money from Mirzet HODZIC while Mirzet HODZIC was attempting to kill a water bottle. After Mirzet HODZIC indicated that he did not have money, Predrag BANOVIC beat Mirzet HODZIC with a baseball bat and stabbed him in [he arm with a knife. Predrag BANOVIC thereby committed:
Count:
26.1. a GRAVE BREACH, great suffering, recognised by Article 2(c) of the Statute;
Count:
26.2. a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, cruel treatment, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions; and
Count:
26.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
27. Around the first part of August 1992, while Mirzet HODZIC was outside room 2, Predrag BANOVIC beat Mirzet HODZIC into unconsciousness by banging his head against the wall and by kicking him with his boots. Predrag BANOVIC thereby committed:
Count:
27.1. a GRAVE BREACH, great suffering or serious injury, recognised by Article 2(c) of the Statute;
Count:
27.2. a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, cruel treatment, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions; and
Count:
27.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
28. Around the latter part of June 1992, Dusan KNEZEVIC took out from room 2 Ilijaz JAKUPOVIC and Zijad JAKUPOVIC. KNEZEVIC and others severely beat Ilijaz JAKUPOVIC and Zijad JAKUPOVIC, using fists, feet, and a baton. Dusan KNEZEVIC thereby committed:
Count:
28.1 a GRAVE BREACH, great suffering or serious injury, recognised by Article 3 of the Statute and by Article (3)(l)(a) of the Geneva Conventions; and
Count:
28.2. a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, cruel treatment, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions: and
Count:
28.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
29. Between 1 June 1992 and 5 August 1992, Dusan KNEZEVIC and others severely beat Uzeir CAUSEVIC using their fists and objects, causing large open wounds on his arms and body. The wounds subsequently became infected and CAUSEVIC became so ill that he could barely move. CAUSEVIC was later taken away in a truck filled with corpses and wounded persons and was never seen again. Dusan KNEZIVIC thereby committed:
Count:
29.1. a GRAVE BREACH, great suffering or serious injury, recognised by Article 2(c) of the Statute;
Count:
29.2. a VIOLATION OF THE LAWS OF CUSTOMS OF WAR, cruel treatment, recognised by Article 3 of the Statute and by Article (3)(l)(a) of the Geneva Conventions; and
Count:
29.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
30. Around 4 June 1992, Senahid CIRKIC was interrogated by three men. When CIRKIC did not provide the answers desired by the interrogators, one of the interrogators told Zoran ZIGIC to take CIRKIC outside and beat him until he talked. ZIGIC then brought CIRKIC outside and beat him, using fists, feet, and a rifle. Zoran ZIGIC thereby committed:
Count:
30.1. a GRAVE BREACH, torture, recognised by Article 2(b) of the Statute;
Count:
30.2. a VIOLATION OF THE LAWS OF CUSTOMS OF WAR, torture, recognised by Article 3 of the Statute and by Article (3)(1 )(a) of the Geneva Conventions; and
Count:
30.3. a CRIME AGAINST HUMANITY, torture, recognised by Article 5(f) of the Statute.
31. Between 14 June and 5 August 1992, Zoran ZIGIC took out Fikret ALIC and several other detainees. ZIGIC then beat Fikret ALIC by hitting him with a pistol and by kicking him in the mouth, knocking out four of his teeth. Zoran ZIGIC thereby committed:
Count:
31.1. a GRAVE BREACH, great suffering or serious injury, recognised by Article 2(c) of the Statute;
Count:
31.2. a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, cruel treatment recognised by Article 3 of the Statute and by Article (3)(l)(a) of the Geneva Conventions; and
Count:
31.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
32. Around 24 June 1992, a group of detainees including Redzep GRABIC were brought to Keraterm camp. Zoran ZIGIC and others beat the new detainees including Redzep GRABIC, as well as selected detainees from room 2, throughout the day and night. ZIGIC and others used their fists, their feet, and truncheons to beat the detainees. Zoran ZIGIC thereby committed:
Count:
32.1. a GRAVE BREACH, great suffering, recognised by Article 2(c) of the Statute;
Count:
32.2. a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, cruel treatment, recognised by Article 3 of the Statute and by Article (3)(1)(a) of [he Geneva Conventions.; and
Count:
32.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Articles 5(i) of the Statute.
GENERAL CHARGE
33. During the operation of Keraterm camp, Predrag BANOVIC, Dusan KNEZEVIC, Dragan KONDIC, Zoran ZIGIC and others participated in the regular and open abuse of detainees. Actions taken by BANOVIC, KNEZEVIC, KONDIC, and ZIGIC include: the beating or assault of numerous individuals including Amir CRLJENKOVIC, a man called "Senadin," a man from Carakovo, Jusuf ARIFAGIC, Adnan BAHONJIC, Suad BAJRIC, and Fikret ALIC; the extortion of money and valuables from detainees; and those set out in Paragraphs 14.3. through 14.5.3. and 16. through 32.3. As a result of the regular and open abuse of select detainees by BANOVIC, KNEZIVIC, KONDIC, ZIGIC and others, detainees at Keraterm camp observing the abuse were subjected to extreme psychological trauma, constant degradation and constant fear of bodily injury and/or death. Predrag BANOVIC, Dusan KNEZEVIC, Dragan KONDIC and Zoran ZIGIC thereby committed:
Count:
33.1. a GRAVE BREACH, great suffering, recognised by Article 2(c) of the Statute;
Count:
33.2. a VIOLATION OF THIS LAWS OR CUSTOMS OF WAR, cruel treatment, recognised by Article 3 of the Statute and by Article (3)(1)(a) of the Geneva Conventions; and
Count:
33.3. a CRIME AGAINST HUMANITY, inhumane acts, recognised by Article 5(i) of the Statute.
/s/Richard J. Goldstone
Prosecutor
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