Annex 1 to GEN 93/16

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IXSTI~IUGWQAL PROCttDIftOS A8ALXST YWQOSWfA (

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PILMSCIIOW.

TO 111s Excellency, the President, to the Judges of tbe Intematicmal Court of Justice, the undersigned being duly authorized by the mlfcof Wsnia and Herzegovina:

5: have the hanor to refer r,o the Applicatiun Iostitutiag Proceedings tbat was go1;anitted t;o the Court fry the Republic of Bosnia and Henegovina cm 20 March 1993 against Yugoslavia () on the basis of Article IX of the Genocide Convmtion of 9 December 1948 and the a- Request for the Indication of Provisional Measures of Protection that was also submitted to the Court on that date. In Section N of that Application IaIV. Judgment Regl~ested")Bosllia and Herzegovina reee- ite "...right to teNista, -1-t or amend this Application." Since the Appliazcian was filed, additianal evidence bas canre to the att8nt:Lon of the Agent for Bosnia an8 Herzeghna that he would like l:o dmw to the attention of the Court and hereby mxbit in ~narptrrtof our Application anti Ragzmst for Prawlsicmal Measures of metxion. This aclditional evidence is as f ollm below. 1. The folAawing events are categorize8 chranalogical~y. All cites refer to the same day edition of the &bxs-Y unless othEnwise noted.

2 March 11992 : Bosnia and Henegavfna held a refere&m approving i-epeazdence and sovereignty an kQirch 1. (btftu w,puge 2)

3 March 1992: Rebel Serbian forces begin attacks on the Republic of , d:'~sruptingtravel into an8 out of Bosnia. (U., page 9 ) 'crl 28 wch 1992: Leaders of Bomia and Herzegaviaa appealsd to the to deploy forces in the Republic with the hopes of stcrpping or eluwiqr Serbian attacrks. (Ib., page 4)

7 April t992: The European Community recognized the independence of 3osnia and Herzegovina on April 6. Serbian forces bombarded the historic malim quarter of . (U.,page 3)

8 April 1992 : The United States recognized the indgpendence of Bosnia-Heneguvina on April 7. (U.,page 10)

22 Agril 1992: Serbian gusr:rilla units intensify attacks on Sarajevo. Dnlike other 8hel:Lings to thi~point, there is a possibility that the former Y~igoslav army did not participate. iU., page 10) w MY' 1992

13 my 1992 : The European Camunity and the United States rlartwed their anbassaUor6 f raw . (Id., page 10) 17 May 1992: UN Peacekeeping Forces, originally placed to supervise a ceaoe-fire beroeen Serbia aoB , withdraw from Bosnia to Belgracle and Zagreb dtue to and artillery attacks erupting around them. Only 120 troops remained in Sarajevo to help with food ccmwys an8 to seek a lasting cease-fire in Bosnia (~d-,page mi 21 May 1992: Serbian forces held 5,000 hostages fleeing the war ii. Bosnia until the government 02 Bosnia lifted of the Yugoslav (Serbia and ilcmtemegro: &my barracks. , page 14)

22 May 1992: 5.000 hostages held by Serbian forces were released after the Bosnian government agreed to lift the against Yugoslav (Serbia and Mntenegro) barracks, and to eupply the barracks wlth food and other supplies. t.. page 13) 30 my 1992: Serbian forces mleashed a new attack on Sarajm. the most severe attack on the Bosnian capital to date. (Ld-.Page 1)

31 May 1992: The United Nations Security Council voted 13-0 to impose economic sanctions against the Yugoslav (Serbia and Montenegro) gwemnt in an effort to fame Belgrade to bring peace to Bosnia and Benegaviaa . tU., page 1)

7 June 1992: Serbian forces attacked Sarajevo with the most sustained baubarmt from artillery, mortar and rocket batteries since the of the Bosnian capital began. (U.,Page 16)

11 June 1992: A United Nations convoy was attacked on the outskirts of Sarajevo by Serbian guerrilla forces. The team was heading to Sarajevo in the hopes of opening the airport. (U.. page 6) 20 June 1992: Serbian fighte!rs attacked the nearby auburb of with artillery. tanks and infantry. This attack dimned hopes of opening the airport for airlifts f 01 relief supplies. (LB.,pass 5)

21 June 1992: Statements are i~suedby survivors of a bus of refugees held hostage by Seeroian force6 outside of Sarajwo. Serbian gunmen opened fire an the bus with a bazooka and automatic weapons. As the dead and wour~ded lay in the bus, the attackers tossed hand grenades in the bus. Statements also ismad by survivors of and tomure at the hands of Serbian attackers. (a3., Page 1)

27 me1992: Sarajevo aifWxt truce is shattered rhon' Serbian force8 used tanks and artilleq to actack civilian buildings in an airport suburb. OH Security Council i~suesan ultimatum to Serbian forces to halt attacks and put their heavy guns under the United Nations' control. (u.,page 1)

28 June 1992: Despite an ultiniatm from the UN Security Council, Serbian forces continu& to she1.l Sarajevo with artillezy iire. (Id..page 1) 30 June 1992: UN troops toof;: control of Sarajevo airport an8 relief supplies began to arrive for the first time in 12 weeks. The UN planned to send 850 peace-keeping troops. (U.,page 1)

12 July 1992: Serbian forces attack Bosnian city of Gozarde, a city with a gopuhtian of SO, OOC persons. (U.,page 1) -<. 14 July 1992: Serbian naticmal:~stforce8 cmtinwCq their siege on Sarajevo by dynamiting four gmrer-tranemisaion line8 that aweU tbe city, knocking out electricity to the 400,000 person6 that raarain in the city and idling the gurnps that p&& the residents with running water. (Id.,page 1)

21 July 1992: Due to cantimed Serbian attacks in Sarajwo, an BrC brokered treaty failed and the Sarajwo airport is closed, (S., page 1) w 29 mly 1992: Reports publi8heCl of Serbian forces force thcrusaads of mslims in western Bosnia tc) flee. Refugees described terror tactice and of being forced tci sign away their property. Ud., pas0 4)

3 ~ugust1992 : A bus carrying children frm Bosnia to satety in Germany was actacked by Serbian artillery fire. A 14 -mnth-old buy anB a 3-year-oldgirl were killed. (Xf., page 1)

4 August 1992: Initial reports begin to surface abaut the Serbian concentrat ion ems. Survivors give detailed and consistent accounts of torture, rape and killings of Bosnian prieaners. (U., Page 1)

5 August 1992: h Sarajevo family burying a young girl killed during a Serbian attack, ia attacked by Serbian fire in the Safajevo cemetery. (U.,page 1) w 6 August 1992: Serbian forces pound Sarajevo witb a raa6eive artillery barrage into heavily populated civilian districts. indepexadent and consistent re;>orts f rmL survivors of Setbian concentration camps describe horrific treatment of prieoners; cfmrgarisons to Nazi-style death camps are Bxawn by historians. (Ld., We8 1,8)

8 -gust 1992: mzi-style conditions of Serbian concentration cazqxi are con£inned in part by Elritiah video of earaciated Bosnian prisoners in a Serbian camp. Tnis video is bruadtaet throughout Eurape and the United States. (=I., page li 9 August 1992: Serbian forces surround the northwest corner of Bosnia, cutting off 300,000 Bosnians from food deliveries and e~caperoutes. (Id., page 10)

21 Auguet 1992: Bosnian declare the formation of a new Republic (the Serbian Republic of Bosnia-Herzegovina) from territory seized frtm Bosnia. (International recognition does not follow). (U.,page I).

22 August 1992 : Rad- Kaadzic, leadex of the Serbian forces in Bosnia, pledged to close Serbian pri~oncas@a, return grqperty his amhad 8ei~edby force, and a.llcw relief camoys free access to Sarajwo and other encircled towns. (Later, Karadzic wcruld be shawn to befailed to ateet thwe praaises) . (U.,page 3) 25 August 1992: Fighting in Sarajevo intensified as Serbian fo~ceeshelled the center of the city and hit the HoZibay Inn. The intensity of the attack forced suspension of relief flights. (&I.,page 8)

26 Auguet 1992: A6 peace talk8 convened in Lontkm, Serbian forces continued pormaing Sarajevo with artill- fire, setting afire the city's main library. Serbian forces aleo continued their attack on WBtar, and Serbian planes branbed Navi Travnik. I=. , page 8 )

27 August 1992 : Serbs launch an artillery attack in Sarajevo, striking Nuslim nte=digvzl 9cild.in.g~acd the main libraxy. (U., page 10).

29 August 1992: Semian leader Radwan Kadzic prase8 to &It on 4 major Bosnian cities &ring the London peace talks. Hawever, only hours after the c!onclusion of these talks, Sarajwo was bmbd by fierce mortar an5 artillery barragee. At lea8t 10 pereons were killed, and Sara.jevoes main hospital said it had treated 60 wounded people in a four-hour period. U.,page 5)

29 August 1992 : New reports by laurVj.vors of Serbian ccaceatratiorn camp0 desr=ribe the death and torture Bosnian prisoners face at the bands of their Serbian captors. la.,page 1)

30 August 1992: Bosnia Serb leader Radovan Karadzic announces the lifting of the siege of the Bosnian tom of -rake, but the Bosnian government stated the fighting there continued. (Id g. 18) . 31 August 1992: 15 Bosnians; were killed and about 100 were wounded in a crowded Sarajevo market when an artillery shell launched by Serbian farces exploded in the middle of the market. (Id.,page 6) 1 Seg&ember 1992: A grenade was thrown into a cemetery during a Boanian soldier's funeral, killing me person and wounding three. (U.,page 3)

4 September 1992 : A UN plane awing relief supplies to Sarajevo was shot dawn. Preeident BUS^ of the united States criticized Serbian nm camps, saying that prisoners face malnutrition, starwacian, sexual dbuse, beatings and executions. In., page 1)

9 September 1992: Serbian forces haw returned to the siege of Garadze. Serbian militias untier the ccmrmand of Dusko Kornjaca began the assault which, by E(omjaca0s own estimation, killed 50,OOOmen. (U.,page 1).

9 September 1992: Bosnian forces attempt to breakout of the Serbian stranglehold on Saraj,evo. (This attack would faii to 'break the eiege). (Id., page 10). lrllr 11 September 1992: A report f ran the Bush Adtrainistration states Serbian forces in Bosnia have been shadowing UN relief flights to Sarajevc as cover for air strikes against Bosnians. (U.,page 10) .

13 September 1992: Serbs in areas of Bosnia and Herzegozrfna continued heavy shelling despitie the fact that them weapons were to be turned aver to UN supervifsion. (Xi., page 2).

15 September 1992: Despite the presence of UN observers monitoring Serbian artillery positions in Sarajevo, Serbia forces began 2 new wave of shelling. LZ., gage 3)

23 September 1992: A Bosnian Muslim details an account of how more tham 200 civilians were massacred by Serbian forces after they were to be released from a Serbian concentration caaq? near Travaik; the prisoners were slmt in the head and thrown into a ravine. I=., page 14) V

26 September 1992: me laass killings of 200 8asnians near Tranmlk are ccmfiwed by EC representative, Mrli Owen, and PN envcry. ms Vance. Also canfimd is a new wave of by the Serbians in the tcm of . (U.,page 2)

26 Septanber 1992: United States officials report that as nm.13~as 3,000 Muslim arern, warnen and chilaren were killed in May aad June at Serbian-run concentration camps near the Bosnian town of Brbro. A spoke- for the US State mparrment stated that the repon incluae8 accrsunts of *willful killing, torture of gri~a~zers,abuse of civilians in detention centers, deliberate attacks on non- mtants, wanton devastatiml and destruction of property, and othera including mass, f orcij~le expulsiun and deportatioa of (U.,page I) 27 September 1992: Actacks on Sarajevo intensify to becme the worst week of ehelling since aaril. 925 civilians were struck by sniper fire, 129 of them died. Sarajwo remained without electricity and running water. (Ld-,page 12)

27 September 1992: Bosnian Government declares that 11,000 pereons are *mownm to have died as a result of the Serbian invasion, with another 56,000 m;~sing. Santjm. (U.,page 12).

2 October 1992: Over 500 residents of the city of , a suburb of Sarajevo, ware forced to leave their homes and belongings behind after their zann was ~eizedby Serbian forces. This was coneiderd to be camptallin9 evidence that the Serbs are reneging on their prwnise to entl 'ethnic ~leanshg.~(Id., page 1)

3 October 1992: At least 150 Maslim women and teen-age girls vere in a-ced stages of prggnar~cy after befag wed by Serbian nationalist fighters. They also said that they were imprisoned for months afterward in an actwt to keep thm from having abort$ane. U., page 5)

6 October 1992: Serbian forctee intensified their shelling of Sarajevo again, attacking swe:raa?. high-rise apartment buildings. Several of these buildings were eet on fire cauefng the resideats to thraw their belongings over the balccmies in a effort to save their property. (Id., page 10)

8 October 1992: Serbian at+aclcers unleashed an artillery attack in che t&m of Brasno. Tire Serbs used incendiary shell6 to turn the neighborhood into an iaferacl. 116. , gage 14)

9 October 1992: Sefbiarr farces resumed their offexme in arorthern B~saiaaf tar camelidating their sul3stantiai earlier vrctoriee . IU.,page 32).

LO October 1992: A Serbian nmlxar shell explode8 in a cmzrtyard full of children, 3 were kill=!, 10 were wounded. Sweral of tlre children haCi limbs amputated. (ZB-,page 10)

11 October 1992: Less tbaa 24 ftwus after ttre aJ imposed a ban on military flights, Serbian fightetr planes attacked the BPsnian tmm of Gradacac. At least 19 gersons were kill&. 34 were wounded. Other Bosnian coppas in northern Bosnia near Bscko were also hit. IZ.. page 10)

11 October 1992: Croatians are forced to flee after the Serbs -er the Bo8nian cmof Boaanki Brod. (X., page 1) . 19 October 1992: Sarajevo states that Serbian shelling has aestroyed the city's mly flour mill, causing gotential starvation . for a people whose prisary food is pasta and bread. (U..page 5).

20 Octaer 1992: 2500 Bosniari Muslims were expelled £ran their hama by Serbe near Fstor Vans (U., page 10) .

22 October 1992: Serbs begin a massive shelling project against Sarajevo in the hopes of having that city capirulate witfierut a struggle. Serbian8 by this date are am in occupation of at least two-thirds of the territory of Bosnia. Serbs are receiving logiertical support f rcna Yugoslavia (Serbia and Plaxenegzm) . U., page 1)

25 Octrrber 1992: Smbegin etep~ingup attacks on several strategic mancities. (IB., page 12) .

29 October 1992: wnia euffers ite worst defeat yet at Ehe I of the Serbs, ae the scrategi~~llylocated city of Jajce falls to a Serbian off eneive. A line of: refugees f ram the city excenrla 30 milee. lUd,page 3).

1 Nwember 1992: Thousands of exbusted soldiers and civilians arrive in Tranik, in Bosnia-Herzegmina, after the military Befeat for the Bosnian forces in Jaj ce . !I(?. , psge A4 1 . 3 EJovexber 1992: Ae a result of the Serbian capture of Jajce, 35,000 Muslinrs become refugeee in Vitez. UN officials now estiraate 1.5 million people in. Bosnia have became haareless, not including tlrose trapped by the Serbian siege of their crmnnunitiea. (Ib., Base 3).

6 Nwemlser 1992: United Nat.ion8 declares since October 22, Serbian forces have flown 18-21) unauthorized flights over Bosnia (as prohibited b Security Cormc:il resaluticm) . (U., gage 8) . V 6 Bov6mber 1992 : Fighciag breaks out between SerBs and Muslims near(a) the Sarajetro airport. i\n Arnerican relief plano is hit.

10 Plovember 1992: Boenian Serb leader Badovan Karabs;ic partition of Bosnia along ethnic lines, or threatens to intarnify the fighting. (U.,page 8).

14 November 1992: Bosnian Fctreign Minister, Uris Silajdzic, states 100,000 people, mainly Muslims, have been killed as a result of Serbian aggression. (Xi., page 5 1 . 20 November 1992: French troops protecting a Bosnian relief convoy are attack- by Serbian forces. W. , page &I. 21 November 1992: Serbs begin heavy shelling against the Bosnian town of Travik. Travik is key to the Bosnian defense, as it controls one of tho key access roada into Sarajevo. Reports ere BO~rliz~enf 6000 men to deferid the city. (Id.. page 3).

22 Egovember 1992 : Travik in Bomia under attack by Se*ian forces in an effor, to opes another road to Sarajwo. (U.,page 8).

24 Novamber 1992: Heavy shellhg by Serbian forces in Sarajwo is reported. In addizion, Serbs wep up attack an the Bosnian cicy of havnik. whose =lation is predaminstely Muslim and Croatiao. (U.,page 3).

27 November 1992: Special report published regarding Borislav Herak, a Serbian auxiliary soL3ier facing the death penalty for genocide. During m interview. Hem described crimes against Boenian Muslims cammitted by Serbian forces. (U.,page 1).

29 November 1992: Serfis finally release mv relief CMV~ after preventing it8 entrance into Bosnia for 3 days. (U..page 14).

30 PTov~r1992: Croatian and Serbian forces c&sh in Bosnia and Herzegovina hcrurs before cease fire was scheduled to take glace. (UP., page 31.

1 December 1992: Serbs and Crcats f~~gntpitched battles across ~osnia-Herzegovina,one person is killed in Sarajevo. (Id.. page 8).

2 December 1992: UN halts humanitarian flights to Sarajevo after US military aircraft is hit b2i small arms fire in defiance of supposed cease-fire. (U.,page 7 1 .

2 December 1992 : UN Human Bights Corrnaission in Oenen condemns menian Serbs ae primarily res:ponsfble for atrocities ccmaitted during the invasion of Bosnia. (fa).

6 December 1992: Serbian forces resumed the shelling of the center of Sarajevo and stepped up an armored attack an a nearby suburb. (X.,mge 18).

6 December 1992: m Otee, a 8utm.m 6 miles from Sarajevo, Serbian forces fight Bosnian forces for contrc: of key amroaches to the Saraj em airport. (U!.

7 D~Cmber1992: UN forces arcs preventecl from reaching Otes and giving relief to civilians by Serb&, who have overrtlr most af me^. Serbs sbut do*m Sarajevo' E teiephone, water, aad electriciry W8testr8. (x.,page 61. 9 December 1992: Serbs begin heavy shelling of Sarajevo's historic center. Heavy civilian caswlties were reported. U,, 'page 19).

9 December 1992: Serbs use tmks to seize airport road and block any relief aia to civilians trrrpped insf Cie Sarsjm. Serbs fire un French UN trwps, forcing BT*& ON troop to leave the airport garrison. (Lb.. gage 3).

27 December 1993 : A Serbian tanR gunner was intemiewed, and decribed the nintb nmth of the . He Bescribed how he had hem oraerad to fire on the apartmeat builUing whare his parents lived. Serbian aoldiers confirmed dvilian arw were targeted. page 4).

9 ~anwxy1993: European ammarity investigators esr;imated 20,000 mslim wamea had been raped Qy Serbs as a part of the Berum w irwa8ian of Bosnia. European Camunity leaders cOna6me.d the violence as %y8tematicm. (U., page 1 ) .

20 ~anuaxy1993: The final global human rights report su;fiiaitte8 the Bush ~inistrationstated that Serbian forces 5n Boenia and Henegavina were canducting a cangaaign of "c!meLty, brutality and killingw uari~teasince Nazi tinre. (ILe. , page 8).

24 Jaauary 1993: Jmerican intelligence reports that at leaat 13s of the coecentration caraps established by the Serbs at the outbreak of the war still rmain, despite Serbian prcrmisea to &mt them doam. (Refereace 22 August 1992 and -van Kara&icts mseto shut doMl the cam&&. (a*,page 1).

28 ~an\rary1993: Sarajevo cam, under fresh Serbian -rbrParst, killing at least 10 and waum2ing 70. In aaifition, lmsUm.8 at Trebinj e were termsirad by Sexbian forces. u.,page 6 1 .

7 February 1993 : 4000 &- were forced out of tbix hooPos in the Bosnian town of Trebinje at gun point by Serbs, Wrbian military forces rgp~r&crrlUysettled other Serbia mtfo~al~Is the hatres. (U..page 18).

8 Pebrwry 1993: Serbs renewed their canpaign of -ethnic cloansing* after a UN prog~sa.1was aeliverecl on partitioning Bosnia into prwinces. Bdarefugees were f otced to flee f rcm Cexska, Kameaica, and other besieged Bosnian villages above the Rivet- tm of in eastem Bo(pni. me Serbs continua3 their caapalign of hei3-2~artillery bmbarbeat. (a.a page LO). 17 FebrUaw 1993 : A UN relief convoy destinecl for the besieged city of Cerska was stopped by S~ixbianforces. U., page 8) . 2s February 1993: Noble Peaccs Prize winner Elie Wiesel stated that he had been *betrayedu by the Serbs regarding some prisoners intmi~Clic the concentracicm canp of mjanca. WieseP noted that prismere othieh he had inrehewed were later eiagl& wt anB punish98 Qy tbe Serbian cmmar&rs of the cagaps. (u.,page 19).

26 February 1993: Serbian forces allowed a relief caamy it &ad delayed for 12 day8 to reach Garadze, and isalated Muslim town in eaetern BO-. (U.,page 1).

3 March 1993: Serbian forces began a dawn attack an the Bosnian enclave of Cerska. Most; Bosnicra re~listanceended early &d the artillery shelling. This attack folluwed the pattm of *ethic cleansingu pacticed by the rserbs, The attack began with a viciaus ahelling barrage, and then terror tactics against local Muslim population in order to turn the surviversa into refugesee, (Zd., page 1).

4 March 1993: Serbian forces csntinued the attack on the Bo8nia.n enclave of Cerska. Boenian resistance crumbled and Muslim civilians were shelled W Serbs. (U., page 1) .

5 March 1993: Tne Boarrian enc3.ave at Cerska was defeated by the Serbian attack. Sane 1500 ~1~ were waurxled. mug-fma fled to the Muslim enclave of Srebrenica, Bosnia. (U., page 8) .

7 Marcb 1993: me week-long Bttstructicm by Gerbs of the Bosnian enclave of Csreka was recounted. Tho attack by the Serbs appeared to be in response to the rUrrerican relief air-ap. Cerska wae the f itsr city to receive lmerica.n airdropped food an8 supplies. (ZB., page 31.

13 mrch 1993: Sexbizm sbells b;ilI& 20 muslim wor~enand children in Vitez, Bosnia, when these peuple crowdsa andtwo British armored personae1 carriers in :rhe hopes of gaining eafe pawe aur of zhe city. (Id., page 4).

14 mrcb 1993: Serbian edldier Borislav Berak cezzfes%ed to crimes committed in "ethnic cleansing* qmxations. nrneaA Vojislav Seselj a@ Miro Vukcnric as poiiticisnn axxi commanders wha *playd a major roler' in the -ti-. (Id.,page 10). ir mrch 1993: Bosaiatl forces l~egaaan airlift of the critically ill f rani besieged enclaves in 9rebreaica to hospitals in Tuzia, Bosnia- General Morillon, co~lre;ux3erof the Um ailitary forces in mnia, aaonaaaed a halt of the Eierbian offensive in Srerenica. A Htorlcl Heath Organization pky8:Lcian reported that f ightiag had trapped sane 60,000 people in Srebrenica and that 2000 persons had Uied be to disease, bmger, ant1 exposure. (Ib-, page 10) .

15 arch 1993: Serbian forces mcked by tanks overran the Bosnian city of Kmjwic Polje, pu~hingMuslim civilians into the Bosnian city of SrebrenLca. Thi8 acccmt was confi-d by a UN British major. In addition, thore were reports of Serbian ahelling of the Muslim enclave- (Id., page 3).

19 March 1993: In Cereka, BOB XI^^, Bosnian soldiers confirmed short-wave radio operator acc:owts that after overrunning the village Seakilled eweral civilians. (Id.,pagg 10) .

19 March 1993: Sweal persons BieU azzd several more -8 wounded in the Bosnian city af Srebreal-ca due to Serbim shelling. (U., page 11. 19 March 1993: Serbia forces reneged on an agreenUU2t to all- a UN relief canvoy, aad Serbs launched another intense artillery barrage againsic Sara3wo. (Ld). - 21 March 1993: Serbian plarles were seen basrabing two Muslim vfllages (GlaBavici and Osatica) in violation of zhe re801~tion banning flights wer Bosnia. (;La. , page 6) .

2. The folluwiag statenlent6 and evidence ixplicates the Belgrade government in Yugeslavia (Serbia and Montenegro) as a party to the acts of genocide ccamDlitted by Sebs in the Republic of msnia and Herzegovina. All cites refer to the 8ame day edition of the u11less otherwise mxed.

4 April 1992: Sexbian irrsgulzzr eoldiera backed the Yugoslav Arary attacked Muslim and Cruz~tianforces in Bosanski Brod and Kupres. Diplomats called the attacks a clear attempt to block European Community recognition of Bosnia-Herzegovina's in&pendence. (- page 3)

5 April 1992: Serbian irregular eolaiers an8 the Yugoslav am continued their attack against the Boanian tams of Bosanski Brod an8 Kupree . eresiemt Alija :tzetbegovic was f orceci to aaaounce the nmbilizatian of National Guard anU police reserve unite - w-, Page 3) 7 April 1992 : Sarejevo was a!:tacked heavy automatic weapons fire and grenade c~cplorsionsa:: ter Bosnian President Izetbegovic refueed to rescind a33 order to mobilize ~ationalGuard forces. (Id.,page 3) 8 April 1992: Z?le Serbian-led Yugoslav ArrrTy ordered air strikes on the predclrninaatly Croat tawia of Siraki Brijeg and Citluk in Bosnia and Heczege. U., page 10)

9 April 1992: Serb units appmaching from Serbia itself attack& Visegrad and hrornik. Gun battles also reported in Dsostar, Derventa and Few. Yugoslav anqy warplanes boglbed the tosms of SiroRi grijeg and CPtluk for the second straight Bay. (Lb., page 9

10 Pgril 1992: As Yugoslav Rrmy tanks etood idly by, a Serb- backed guerilla force captured .the 8osnlan taon of Zvornik. (=.,

12 April 1992: The Yugoelav .Rzmy carved at new territory in Bosnia and [email protected] arar), units invaded ths tam of ~ica befors Ban. (Id., page 16)

14 April 1992: At the National. Press Club, Dr. Earis Silajbzic, Foreign Minister of Bosnia and ErenegavJna pleaded for assistance. He atat&:

"Fresh [Serbian] irregular forces are being braught into Bosnia and Berzegovina f rm Serbia, Montenegro and the Croation tawn of Knin on Yugoslavian Peqple's Army truck and helicop~ers.~ (- (- Transcript ID: 821134) .

15 April 1992: In an intentimu on CNN*s uInteznatiaaal 8ouP Dr. mris SilajBzic, the Foreign l4:inister of Bosnia and Herzegovina rmmphaeizef3 that Serbian irregular forces were being bnnqht linzo Bosnia by the Yugoslavian Peq.leesm. Silajdzic also noted later in the intervieno that the Serba were equipped by the Yugoslav amQ.

15 April 1992: Serbian and Yugoslav amy forces bm~ean EC- brokered peace agreement . Sert~ianaa8 army units averran several regions pcrpulated by ltuelim SliW8. rZteee Bosnian tams include Foca, H~~tar,and GozanM. ~IUL-, page 6) 19 April 1992: Serbian guerril.la8 pouaded ceatral Sarajevo with aronar ehells as an mican official arrived with witarian aid for Boania. U., page 1) 20 April 1992: Yugoslav army kmrbardea Flostar. Shells fell far at leaat three hours in heatril:y populated neigfiborhoocls anB Bet fire to 6-1 apztnmnts. (U.,page 3 1

21 April 1992: At a White House Backpraund Briefing, a Semior Aclministratian Official noted that the Yugoslavian national anny was causing problems in Bosnia which made establishing a relationship with Belgraae difficult . f- Transcript ID 821477)

22 April 1992 : Yugoslav axmy jet fighters attacked the Bosnian towns of Siroki Brijeg, Citluk, Grude and Capljina. (myark ~%ws., page lo)

23 19gril 1992: Backed by the Yugoslav w,Serbian forces stepgecl ug their attacks an Sarajevo as well as an other Baraller Bosnian cities. (U.,page 10)

23 April 1992: During an interview on PBS' *MacZ?efl/Lehrer*, united States Assistant Secretary of State tawrance Eagleburger called the canduct of the Serbian govsmnmczt amd the Yugoslavfan National Army as Moutragec~u8Mand blamed them for the deteriorating situaticm fa Bosnia. gagleburger noted that the Yugoslavian National Army and the Serbian irregulars were onore *activea than the other forces in the region. J 30 Pgril 1992: Across Boenia, there was fighting in at least five different towns across the repblic*s nortfiern, eaetern, and southern regions as well as a battle in the canter of Sarajevo. I?reee attacks by Serbian f orcrrs and units of the Yugoslav Arrqy featured artillery, mortar and rifle fire. Yugoslav Arnty units also continued to gour artillery, mortar and rocket fire into the Bosnian town of Mostar. I-., page 13)

3 my 1992: The heaviest attack to date in Sarajevo erugtea when Serbian guerrillas and Yugos1a.v Anrry forces: Bhelled the clwas Muslim quarter with artillery and machine gun fire. The attack began soon after 1 p.m. and cazitinued into the night. fld., page 1)

6 May 1992: Yugoslav Army jete rocketed eweral targets in Sarajevo, and Serbian guerrillil farces continued attacks on the w city. (Id.,page 16)

13 my 1992: In an effort to ward off international sanctions, Yugomlaviet (Serbia and Montenegro) announced that it was relinquishing control mer Yugoslav army units in Bosnia and Hemegovrina. (Zd., Oage 1507) 19 May 1992: In an nws conference, Dr. Baris Silajdric, Foreign Minister of Bosnia-Herzegwina, rstated that the war in Bosnia was not between Serbs, Muslizrte, or , but was instead one of aggression by Yugoslavia (Serbia and Montenegro) againat Bosnia - Herzegovina. (teai-alate Transcript 30: 831298) . 26 may 1992: In a State Department Daily Briefing, Ricbard Boucher stated that the United States did no+ believe the disavawal by the Yugoslavian (Serbia and Montenegro) gwernmaent in Belgrade. Boucher glacM respansibility for the uar in Bosnia on the Yugoslavian army and the Serbian government. (- Transcript ID: 831755).

28 May 1992: The United States Ambasmdor to Yugoslavia (Serbia and Montenegro), larren Zimarman, when interrriewed on N8CSs *%dayu, stated that the United States saw the conflict not as an ethnic was but rather "a8 a war of aggression that's waged by Serbia an8 the Serbian president, Milosevic , against an in&pn&nt republic. a (Lerrri_tsim wanscript ID: 831904) .

3 June 1992: When asked at a State Departmeat Regular Briefing whether the Un1t.B States was "certainw Serbian leadership was in control of irregular Sarbiaa groups inside Bosnia, U.S. State -t Spo)teman Rirrhilrd Ba~czher stated that the ga~armentof Belgrade, rather than withdrawing the Yugoslav anqy turned it over to the extremist Boeaian Serb leaders. lie went on to say: "The reality on the ground in Bosnia is that this is an inliependent state that is being ravaged by Serbian armed forces, both army wits an8 irregulars, which were unleashed by Belgrade. which are inspired, equipped, and continue to be supported by Belgrade. " tm-alam Transcript fD: 840231) . 9 June 1992: Bosnian gavermnent releases transcript of recording of Serbian military leaders, several of whan were officers af the Yugoslav Axmy, in which the cmfka.ndhg general ordered that all of the Bosnian residential districts should be shelled. Pis exact camand was *Burn it all." (-., page 10)

11 Jtxne 1992: Ralph Sohnsan, Ikrguty Secretary of State, during an Senazte Subcamittee Hearing on European Affairs notea:

*Ostensibly, the 1Yugoelavianl &my has withdrawn, but they have remained behind in same cases -- many cases -- with equipment and have remained under the camand of General Vladic. Now he, as far as we can see, is ergpointecl and paid Dy Belgrade. So, whether or not Belgra.de has tactical control war the individual units, as far as we're concerned is really not particularly relevant. The isrue is that Belgxade does have, in our view, enough influence that it can have a material effect on the fighting being done by these irregulars ;ant3 that Belgrade nee88 to be held accountable for. the fact that it set this prOCeS6 in motion. . . we think that Mx. Milosevic does control the Yugoslav -...we believe the evidence ia v=j, very persuasive ..." ~&g,hWxTranscript SD: 840866) . 23 June 1992: Thomas Niles, Assistant Secretary of State, testifying at a House Europe and Middle =st Subcamnittee Hearing, in reegornee to a question from Representative Solan, statedm

*I wmld eay the contimirig shelling of the city of Sarajwo by the Serbian forces.. .are certainly subject to a very heavy inf lumce, if not cantrol , f rcm Belgrade. Nileu also noted tbat he believed the President of Yug06la~ia (Serbia and Ibantenegro) , Slobocbn Milosevic, was Wdeeglyinuolved ia w?mt *e going an in Bosnia-Herz.2egovina." (Wi-elateTranscript ID: 841690) .

26 June 1992: In 8 meeting with Britain's Lord Carrington, Serbian Pre~ident SloboBaa Xilosevic refuesd to recognine the independent Republic of Bosnia and Herzegavina saying that its status must be determined by the leaders of federal Yugaelavia. #Owever, after the independence of four of the old mgoslavia'a w republics wer the last year, only Serbia an8 Montenegro rmain in the federation. .. , page 8)

10 July I992: At a CSCE Con:Eerence, Secretary of State James Baker made reference to large ~uaountsof heavy weaponry which had hen trern~portedinto Bosnia frtmn Serbia for use the Serbian forces in Bosnia. (Leaj-slate fkanscript ID: 850551).

11 mly 1992: Secretary of State James Baker told Milan Panic that the United Statea held the Serbian government in Belgrade respunsible .for the humanitarian nightmarea caueeU by the Serbian invasion of Bosnia. (TbauSfnn gg 1. %ueh Umee Ylrgoelavian to End Ethic Bloodr&e~¶.~)

4 August 1992: 'IPlooaae Nilele, Assietant Secretary of State, testifying at the House Europe and Middle East Subcarmrnittee Hearing told Representativehr that the town of VucoMr was Bestrayed by forces controlled by the government of Serbiaa. Later, Niles mentioned that tihe Serbian forces in Bosnia were "organized. . .ccmhctsd by the :#we-t in Belgrade, the Serbian government, attacking essentially unamed people in mnia- Hercegovinaw. (LWf-~1- Transcript ID: 8601661 .

6 P;ugust 1992: A list of 105 Serbian concentration cawps was made prrblic. 91 of them were in Bosnia and Herzegovina, 1: of them were in Serbia. (- page 1) 9 mgust 1992: ~n an interview during ABC's *This Week With David Brinkley* Brent Scrowcroft, the United States National Security Mvieor, stated that the Serbs had the *monspoly on fieavy armrnin the conflict, and this was due because the arms were handed over to them by the Yugoslav anw. (i&kahU Transcript ID : 8604431 . . 12 August 1992: . , interview with William Taylor, vice- President of Xnternational Security Program at the Center for Strategic and International Studies. "The solutions to [the problems in Borsnial are...in Belgracle where Slobodm Milosevic, the president, and his high military camand reside. They are the ones who either have control of Serbian regular military forces and Serbian mixitia furceo.. .all of whom are coprwitting these atrocities and killing a lot of people in wnia...Thereie one proposition which no one argues anb that is that Milaievic and the high catman8 bo have conrro3 war the Yugoslavian National Axa5y. That's about 30 divi~ia~r6.In our estAruates at CSXS --and we've been tracking for manthe-- there are still sewen remlar divieionn in and aroundi Bosnia. Serbia controls these forces, no questi.on about: it.. .*

11 September 1992: At a State Department Daily Briefing, U.S. Srate Department Spokeeman Richard B~ucher stated that the *Belgrade authorities were cont.inuing to supply arms, anmanition, fuel, spare parts, and a variclty of other things to the Bosnian Serbsu. As such, Boucher Becla.red that Belgrade "bears a ce-in reqmnsibilityrn.

28 September 1992: A report in stated that Serbia is being used a8 a source of military uaapons and troops which are used to fight in mxnia. (- page 5)

18 March 1993: The PPI, reported that Yugoslavia (Serbia and Montenegro) violsced the no-fly zone over Bosnia and conducted a military air etrikos against bc:ieged cities in ogatrsm Eosnia.

The Republic of Bosnia and Hercegovi~hereby respectfully requests the Court to consider this adaitianal evidence during the course of these proceedings anti in support of its request for an Indication of Pro\risional Measures of Drotection. Annex 2 to GEN 93/16

1

SOPPtSM8MTARY SUBlbISSIO!? IS SUPPORT OF

THB ARPLICIL'PIOP OF PHI RIPVB&IC O? 808PIX AJ8D RSRZEUOVEHA

EXSPXPOSCXUQ SOW PROCIEbZltQS AQAXHST YUQOStAVIP (SIRBZA

AND rOlllfm80t0) OH PHE MSXS 01 THE! 1918 G.IFOCXDt

COHVS#TIOS AVP IIO 2x1 SUPPORT 08

ZFS ~BQUBBT FOR AR LROZCAFSOI OF Pwvxsromt ~EMURES OF

PROTgClIOlP.

TO His Excellency, the I?reeident, to the Judges of the International Court of Justice, the undersigned being duly authorized by the Rqublic of Bosnia and Herzegovina: I have the honor to refer to the Application Instituting Proceedings that was submitted to the Court f;ry the Republic of Bosnia and Iierzegwlna an 20 Paarch 1993 against Yugoslavia (Serbia and Montenegro) rm +he basis of Zmicle IX of the Genocide Convention of 9 DecaaUer 1948 and the acccnnpaqdng Request for the Indicaticm of Pruvisio~lMeasures of Protection that was aPeo submitted to the Court an that date. In Section N of tbat PgplicaCi~n(*IV. Judgement BeguesteBu) Bosnia and Herzegovina reserved ite . . .right to revise, supplement or r*rclanA this Application. .. " Since the Applicatiun wae filed, aaditional evidence has cane to the attentim of the Agent for Bowria an8 ~erzeghnathat he vcruld like t3 draw to the atteaion of she Court, aaB hereby mhit in suppxt of our Application ad Repuest for the Indication of Prwiraioaal Measures of Protection. This additional bdence is as follawe below.

I. 8TATPYSStT OF FACTS I. Intormation Coordinator on War Crimes in Former Yugoslavia, a Canadian research group, compiled statements fram a graup of Bosnian Muslim who survived cancentratian camps rua by various Sezbian military and paramilitary forces in Bosnia-Benegovina.

2. In one account, a mslim wcxmn ickncified at3 SN 011 described the atrocities camitted against: her and her family and pmyed for the guniahment of the Serbian forces for theee genocidal acts. a. I accuse them for burning Barn my haae, de~troyingall of our pw,for taking hueband and w father-in- law to a concentration camp and for torturing them. I accuse them for harassing and termrizing qy mother and my sister, threatening f thsrcnl with murder . . . and -1ling them fran the tuwn they lived in and telling them that all that they are doing to my mother and my aister is because they are Muslim and that all the Muslims are to be killed or expelled. b. They should be punish,& far all thorae i~ocentfriends, cousins, neighbors f and1 acquaintances killed and tortured; for all the mothers, sisters {and] wives raped ...; for the parents slaughtered in front of their children; they should not escape justice because of all the suffering, torturing, starvation and terror that they wde my [husbarrd] and my f athes-in-law endure, together with hun8red.s and thousands of other innocent people .... 3. In another statement, a Waslirn woman identified as AD 010, described an attack on her village by Serbian forces IChetnicks) . u a. On the 25 of my the! Chetnicks attame8 our village, which was a Muslim village, and by the 31 of May all the men froan the village brare taken to a cancentration -. Sn the first attack they shelled the village. The people out of fear were fleeing their hcanes. I eaw ~aarry of them fall, their bodies and lintbs flying into the air. Bodies of men, -wainen, children, and all that just becauee they were Muslims. They killed en aasae, pillaged and hrnt our houses, detained wmen, elderly and children and burnt than alive. They took the yaaxq men f ram 20-30 years of age Iandl brought them to a 8chol to torture than . . . . One of my uncles was taken. Ee survived a firing squad. Wo of his brothere and four of his nephews, tzogetber with 170 fricauQn, cclueina, neighbors. Re laid hicling with three w~upbe. He managed to escape becauae the Cbetnicks thought everyone was dead. We took him in a forest after a few days, but he could not go heme, k~mwiag that they would be looking for him since he witnes~eda genocide of 180 Muslims. He's been hiding for two months an8 finally they found him me day and since then we have not heard frm him. b. Ttrey have beea torturing us all in BiLf erent manners. Rrery village had a C!hetnick1s headquarters where they spent most of the the. They would take our f aod, our gold and jewelry. [andl money. They took [my neighbor's] son away and they threatenjed] to kill him unless she firings sane money. She and her hu&and were collecting maaey thrcmgh the village, . . . and finally wbea they brought thta money the Chetnicks let her eon go, but they killed her fiushnd. First they mutilated his body with knives, engraving a cross an his bw, [leaving] him to bleed, and finally killing him only at night. In that nnau, name2 they killecl another of my neighbors, it kept goiag an; and all this for me simple reason: They wanted t.o cleanse everything maslim. c. They raped my neighbor, a 65 year old woman, and then killed her. They killed her husband as well, who was a totally handicapped EL& helpleas person. Wben we got the permission to bu:~them, we found them mutilated. We had to pick up his head and the brain with a sfiovel.

d. A friend of mine was kept in captivity becauee her husband was f igheing on the Bihac front. They were threatening her with killing her aad her three children if her husnand [did] :not come back and give himself up. After they took our tnrsbands away we fcIid3 not hear of them for almost two m~nths. They sent us mesaages from the detention cams letting us know that they were alive. We woaren werc! at the mercy of the Cnetnicks, being ourselves kept in som kina of a detention can^. The whole village was under their occupatiorr and we were let to do only what they decided we could do. We lived in fear becauee mreryciay they could kill samcme, aad we were waiting for the game tw to bagpen to us. (Infomitim Coordinator an War Crimes in Former Yugoslavia, Statement of victim AD 010).

4. In anather account, a ms.Lim civilian idatif ieU a6 004 JF described hie Betention in eweral macentration camps. a. On the 30 May, 1992, ;: was forcibly c3etaineb. in Prijedor SUP at 9 p.m. In SUP, la1 Serb soldier pierced my skull with the gun breech. We were all being mercilessly beaten; Serbs ordereti us to face the wall so that we cannot see wa~beating us- Tnere were abmr one hundred Serb soldierr, in the room ainterrogatingu and beating us. They kept swearing at us saying "You f--- want a republicw '(You f --- want a state," @@Youwant a f - -- Muslim state," and so on. Serb soldiers coming from rhe front were thera and they were really wild, the worst. A Mu~lim,Wmzo (first name) , was shot in the forehead and killed by a Serb soldier the moment we stepped in the SUP building. A Muslim, Nizret TTto when asked for his prof essioa anawere0 that be was a =dhnqgsterWLqterieta) and. a Serb soldier said *Oh, a snipera (snajperista), and shot him in the head dead oa the spot. Curt Vesi:L (58 years) and his sm Sead were beaten to death. All their bonee were broken, Gead*,~ nose was torn apart.

Prom Prijedor SUP we were loaded into a bus, 150 of us cramrmed into the last; third of the bus. Sezb soldiers were driving the burg. Serb soldiers killed 2 or 3 bailslim in the bus. is mnaal roaa to OmarsRa is throu* Kuzarac, but Serbs took us around thlaugk rrm~srousSerb held posts or villa!aes. At every such point, Serb - villagere would enter the bus, Serb wcxnen, chil8ssn, and they would hit us with wooden bars, stab us with knives, they wcruld thrw acid at us. Several people di&, but we were not allowaoU to look. We reached the concentration cawp Omrfika at around 11 p.m. that night. Hhen I was ieaving the bus 1 saw that the bus was full of blood and many &s:lime ~tayedon the floor, most of thm dEtad. c. f was in Omarska extermination cwfrom 30 May 1992 luntil] 6 Aug. 1992. I was beaten there daily for 3 to 4 hours. Going to the toilet meant being practically killed by Serb hordes laolCLer6) . Omarska is a mine an8 thera was a lot of na.teria1 itan the mine lying around -wocxlen beams, cables, iran bats, metal -Rers, etc. Serbs ueed all these materials when beating us. Tkey were hitting me, as vrell as others, in the testicles, using metal hampers, netai bars, kicking with r;he bte. sl, testicles were swollen, the size of large oranges. The aumber of tortures varies, f to~lone lor] two to twenty or more. They would gather around vans, Brink or take drugs, swearing at us : - - - your Wusl1i.m nother, a "F- - - your Turkish (Croatian) mother, " "F-- - yw and your Republicw anB so on. Serb torturers forced us to lie Barn an the floor with our hand8 on the head so that we cannot see who was torturing us. We ware taken outside and underwent the cruelest tortures and beatings fron 8-9 a.m. till 7 p.m. Very oft= Serbs would put metal cans wer our hsrads &ring the severe baatinge so we could not see the torturers. Serb torturers would bat us, Step or jump on us until they tired out. Tbey were Bel-rately aiming their beat-s at our testicles Saying wyou*llnever nuke HuSl3.m children again." 8. When a Serb from a near-by village got killed in the fighting, Serb g\rard!j would let the whole village cume to the camp to vent .their rage, which they would do by atilating and killing us.

e. Every day Serb torturers killed about 70 to 100 Muslims (some Croats as well). There was a building we called a "White Houseu where the Serb torturers perfom the killings. They first killed all the doctors and intellectuals. They wen killed a UN doctor, SaBikuvic Esab, f think he was in Zimbabwe or somewhere else in Africa with the UN.

f. Around 13 May 1992, I was lying among a yard full of corpses; I happened to be near a garbage container, a little bit out of reach. Serb forces kept fir* at the corpses, but sodi~ebmt, due to my position, the shots miaaed me, and I lllaaaged to sneak back into the barracks later.

g. One day I was in the detail loading coqmes into a 7-tan truck. We were throwing corpses in, until the truck was one meter high with 'corpses. I sneakad away frcnn that "joba, f could not cake it. 1 saw Serbs using heavy machinery to excavate! big holes, use trucks to the corpses into the hole, and use trucks and construction machine:= to fill the holes and level the gr-• n. Serb torturers used iron bars to beat &slims (same Croats) to death. Tf~eywould not apare any part of the body, breaking all the banes so that the beaten Muslims begged their torturers for a bullet, to be hot dead. Serb torturers stabMc3 arms with hives. I saw Serb torturer8 etab othe:ca . . ., twisting and turning the knives inside them. I saw how Nuslims were forced to bite each otherae testicles aff, their mouth filled with testicles and blood. rippea blood veseels sticking out of their mouths. Daily Ssrb torturers forced Muolirn prieoners to f --- each other, to petform oral sex on each other, forcing t.hese bestialities especially among family members, between a father and son. i. In a emall room filled with mslims, Serbs would throw tires that were set on fire and Muslims would bnrn a1 ive. We had to lie down on the my,or road, with our heads down. I saw Muslim beside me being shot Bead for mming their heads. While we were lying down Serbs would jump on us in their boots, jump on US from the steps, frm garage rcwfs, breaking people's bones, they would arive cars, even heavy trucks aver us, seriously injuring and to a large extent killing the unfortunates. I would be lying down for 4 -5 hours, being msrcilesaly beaten fry five even tan Serbs at a time. Serbs were executing planned killings. OPaarska extermination camp was a place where Serbs were executing so callea "revenge* killings. Serbs would accuse doctors of choking to death Serb children, profeesors and teazhers of being unfair to Serb students, and killed them immediately for these *crimeaU. I ME lucky co have given an assumed naxne, for Serbs aeked for me by name to kill me (qy Serb neighbor8 could not recognize me, the tortures chang Iedl caapletely nry features). (I learned later that 88232s 8ear-d to f iul me abusing my family, my f srher and my wife in the gcocesel . k. CTPlarska extermination canrp had warscra grieonere as well. Daily Se14 eolaiers wfould take girls and bring 5-6 men per girl, Serb soldiers, prisoners to rape them. Sm8tbms I was among the msn farced to nape the girl[e] - . ... They were raped constantly, na-stop every day. They older wanar, Croats, 60-55 years of age. Ckle nauted Divia, was rapeci by 12 men. There xere rany young girls, arcxmd 16 yeare that were being raped daily . . . ,

Serbs mid torture UEI by extingui~hingtheir cigarettes on our bodies. However that was reserved mostly for mslim women. Serbs would wcringuish their cigarettes on the MwlILIR wcllmenws naked bodies, mxtly airbreaste and vaginas. Serbs would also shwe bottlee (mstly half -liter beer bott3.es) up tne Muslim girls' vaginas . . . . Serbs would stick a bottle inside Muslim woaren9s vagina and thea break them inside them. rn. In Onnrska there was a shop where chsp trucks were being repaired - we callecl it tfie *Red Pmse.* Serb torturer8 killed many prisoners in the Red House, That was the * place &ere I paw the Serbs cur people's nones, ears, limbs. When I was cleaning the roag in the Red House t3-m f lmr was full of human boa pieces, pieces of the skull, fingers, ears, noses. Outei* oa the road, sku21 pieces were scattered lsverywhere . n. On the 25 or 26 June Serbs forced nm to drink 5 Liters of used, dirty motox. oil drained frosn a truok oil filter, with the intart to kill me in a terribly painful manner. o. I witnessed Serb guarcila shoving a fire l#kant bee into a mn* s sphincter (it 1ms a man fran a village Itorarac) , letting the water run :Cull force fran the hydrant, until the man swelled and rhtm died bursting to pieces. g. Serb torturers were constantly robbing Muslim prisoners of their belongings. Many of us prisoners had thoueaak of German Marks with us. Serbs would sell us fooU at sxorbitant prices. Once we paid, Serbs wald came, beat us an8 take the so18 goods back .... Serbs were taking Muslim prisoners' watches, jewelry, ~t first Serbs cut people's fingers to get the rings off of them, later after a period of tarv vat ion, rings would came off easily. Serbs were knocking mslixi prisoners4 teeth to get at the gold f illirtgs .. . . Serbs were rounding ap all non-Serb civilians, wstly Muslims, and brinpiag them to Omarska f ram near-by villages - Carakovo eelo, RamWriaa, Ljeskaua, Ljubija, Ravska. It Beems only one or two frua each village would make it co the extermination canrg OPaar8kii. Carakm selo had 4000 people, they were all roupdlsa UQ, but only one made it to the actemination camp. prm c-ring testimonies of the ~urvivingeyewitnesses, in Prijedor iteelf Serbo slaughtered 22,000 Muslime. Out of a population of 42,000 hardly 2,000 -in@. r. Serb torturers were starving us in Omarska. Far 40 days I was eating only bread. Serbs would ratim bread, me loaf of leas than 1 kg was cut into 47 slices, and me slice was the ration per prisioner with sane dirty water. In order to get to the kitchen I as well as the others had to enare cruel keacings by Serbe. They were also beating us while we were eating. S& torturers allowed us 1 minute to finish the meal. In the extermination cap Oimarska there ma water that was used to flush the ore frm the mine, as 'well as the water used to wash the machinery. We were forced to drink that water to mve. I lost 39 kg in Qlrarska.

8. On 25 May 1992 [a] Re3 Cross visit to the extermination C- -ska wa6 announceC. Serb torturers hid Lxmmdiately 150 Muslim prisoners, thrtw in some beds in the rooms with bed linen, and we were forced to tell tbe Red Cross that we were Muslim fighters, cqgtured just prior to their (Red

Cross @ s) arrival. t. On the 6 Aug 1992, we were driven away by Serb hordes to mjaca concentratior.. camp. There had been wer four thousand Muslims (act Croats) that arrived to Wrska with me. Less than fourteen hundred of us were left to go to Manjaca. They moved us from the exzerminaticm caarp Omarska, as Red r3roas members told us, becauee the world has f mmd out about us, news articles were being published about us. We were driven in the bue. Serb torturers were beating us all the the in the bus, forcing U8 to sing Chcrtnik songs, killing us. They slit throats of swen people right in front of rsy eyes- The trip of about 40 )Em took us 12 hours. The hawould often st=, Serb civilians, soldiers, with long beards and hetnik insignia, women land1 chilclren wauld enter to beat us mercilessly, with stone8 and anything else. Serbs did not give us anything to drink, it was hot an8 aey forced us to swallow a handful of salt. 1 was permiring profusely, and in oraer to survive I drained the permiration frm my sweatshirt into imy] ba?lds and &rank tbat. u. In Manjaca, jber-t (Red Crescent) registered us. The Red Cross took wer food deliveries. However wst of the food was taken away by the Serb pards. We were sugpoeed to receive some fish for breakfast (2-3 pieces) , trut Serbs were giving us me for tvro paple, and even that not always. When the Red Croas truck arrived Serbs first collected, at the entrance to the storage depot, ratians for their am. Later on, men the Red Croae left, Serbs would wheel away most of the fnits and vegetable^ . ms1i.m prisonere vould be checked by Red Cross medical which would prescribe &rugs. w These drugs nevex se3cbed aqy pri~oners, they were all taken by Serb guams for their needs. Tbe only thing we received were pills for srrength, which Red Croas gave us rigtit into our hands.

v. In Manjaca Serb guards forced us to Idol all kinds of manwl labour. We were forced by Serbs to cut wood in the f oreets, dig potzrtoes, cut the grass, load the hay, pick corn, graze sheep, cows, etc . Around one thousand people or more went out, working in the stables, in machine shops, sewing clothe^, making wooden figurines, burts for rifles, and so on.

w. In EQanjaca concentration camp f witneseed Serbs taking 142 C-ts for ial prisoner excbange in Knin. As told to me by one of the Croats, Halupa 26-0, it took thean 5-6 Bays for the tri~but the exchange was not executed, becaurae Serbs d~cleda Serb mjor in =change. In w Knin they were holding chem in a tower. Serbs wmld let ws fandl children . . . ccm and abase thm. They brake bones of . . . most of them. When they rsturnd I watched from the kitchen hm Serbs were beating them severely. (Xnfomation Coordinator on War Crimes in Former Yugoslavia, Statement of rLctjsl 004 JF).

5. In anotther account, a young Muslim female identified as 3K 001. reported the details of her expulsion by Serbian forces.

a. Every clay they enterad houses in which there were dy wowen and children ~~ernaining.They plundered, killed and raped even the 5 vear old girls and old waen. So our own house was a prison camp to us far they could caw in and kill us at any thm of day or night. men they were searching my home we were taken into the Sackyard and nade to stand in a row. They threatened to shoot us if they fouxld weapons in the house. There were no weapons, they plundered the hauee and took tbe gold and told us they would came back again and kill us because we were Muslims .... I and my old mother together with our neighbors joined those geaple. We szayeb in the houees that had been plundered and the mmers of which had been killed or taken to camps. It was horrible. There were about fifty of us in me house, we slept on top of each other, and the odor of the dead bodies, #hi& were in the garages land] in the gardens, was everywhere. They killed the men an8 the warnen had to bury their husband, or son, or father with their rn bands and to ths best of their abilities. There was blood, blood of an innocent son, chila, woman, or man an the walls of the house. We elept there and wait& for our departure, and they were standing 011 guard outside, uinging, drinking, and listening to the Tchernik songs and wen shooting the bees. c. After a few Bays 9 trailers and several buses cane .... On [the way to] Vlasic, 160 men, old and young, were taken f roan tbat f irsl: corntoy that had left before mine, and killed. That information frightened us, so we became upset and started to leave, but they made a circle around us an9 said that we would get what we deeerved, and that was death, death to a11 Muslims or *Bulasw as they were calling us. Thq loaded us onto the trailers and we :.eft, not knowing ourselves whether we ware going to death or to freedan . . . . When we came to Vlasic they gave us three minutee to get off the trailer. We were falling Ba#n like sacks out of the tier and it was hardest: for the old wasen sad children. Hhen we got wt they started to separate girls an6 women. Fortunately I had a scarf on rqy head and my aunt's child in qy am. They set apart about thircy girls. They ~separatdan old mman fram her two Baug'tzterB; she proteftted, criecl, went dooon on her knees and begged, but there? was no mercy, she got a bullet in the head. rtie g:Lrls were taken to an unknown deathation and even roday it is not known. In a line, we started walking toward8 Travnik; the men went a-tely and the Tchetniks were hooting after them, and nsny of them got killed bauee they bad heen at the back of the line. They told us to follm the road an8 we would get to ou:r "balijasU (derogatory word for Muslim), and to tell them they should be grateful that they did not kill us all. The journey was long and stremous; .rsarry old wcaneo were carried in blankets or in wheelbarrows, and acme sons carried their mothers on their backs until finally we reached Travnik, which was hard to believe after so many dead bodies of our Muslims ha8 been left lying on the road anU everywhere where the Tschetnik's foot was set. And the only reason for that all is that we are b1slim.

( Inf orarat ion Coordinator on lfar Crimes in Former YUgoslavia , Statement of victim JX Ool).. 6. In another statement, a concentration camp survivor identified as 603 NA described the conditions of his confinement.

a. On May 27, 1992, ., . Serbian forces kept announcing wer the radio that pecrple must gather at the practice field. Muslhra and Croats started leaving their ha;8s8 and Serb forces forced them to march to the practice field under mortar fire. 1 saw tms of peagle being wounded a8 well as a nunber of civilians being killed .... Frcan there 1 obeemed Serbian Armed Forces [the official forces of the Serbian municipality of Sanski Most1 looting the w marked bees (with white sheets), burning them to the ground af texwards, A large number elderly stayed in their hanes thinking that no harm fwouldl come to them because of their age. However, Serbian ArrPed Porcea weat around killing them . . . . During the abduction and in the confinement, I suffered constant beatings at the hands of the Serbian Anmed Forces and Serb civilians. Serbian Armed Forces and Serb civilians were hitting me with bate, rifle butts, kicking me with bwt~. One Serb, a neighbor that went to the a- school as I, attempted to mumler me. Be put a gun barrel into my muth while another took ray hand, pulled a knife and attenrpted to cut two fing-8 off rqy franc¶ (this is to mimic the popular Serb three finger salute1 , but sumhow they changed their miads . . . . I uas beaten owr the head with chair legs, kicked in the kfcheys, in the back. #y head was so swollen, twice the nonaal size, fram the beatings that azy father, who was w also detained there, could not recognize me.

c. During the canfinemen::, we were given saae drenched oozi fd,one tablespoon per areal, twice a bay, sametimes not even that. Serb guards allowed ua thirty to forty seconds for the (*meal." While trying to get to the meal servera and during the meal, we were constantly beaten . - . . X lost there, in one mth, fifteen kg. a. On 7 July 1992, we were driven away by the Serb hordes to Manjaca concentrcition camp in transport trucks. Serbs pack@ about 1i3O people into a half-ton truck, class& us in with the tent-cloth, whim was held tightly in place with steel cables. On the way Serbs would etap the truck in a sunny spot and wait for the tempexature to rise. People had no choice but to urinate and defecate on thermselv=s and people around them. In the truck f was in, ei~ghteenMuslims died from thirst. After we arrived, we were first severely beaten by Serb hordes, they shaved our heads and then Sems threw us imo stables, where sheep an6 cows bad been kept before. The stable swaxmed writh flies and the conditions were appallingly unsanita.~. Some very prickly and sharp grass uae strewn over the cement floor where we were sieeping. The stable was 40-60 meters long, its sides matie of tin. There were six or more stables in the concentration cmp, all surrounded barbed wire, the ground around them mined with explosives, there were watch towers there with machine-gun positions. Serbs crraaned ahmt 700 people into one stable. We could dy ~leeplying oa the side. While inside, Serbs forced us to ksep uilent, not a sound was allowed to be uttered. In the silence we could hear terrible scream. At first we thought the sounds were caning fraa same animals, but sorrn realized they were carting fran peqgle under extreme tonure. Serb camp guarc% rationed wur water, me glaes of water a day [for1 four people (it wm mrwrterl ) . If me in the group drank the wbole glasa the rest would get nothing. In th4z morning we were fed tea without sugar and with no bread. For dinner we would get exactly three beans in tepid water withaut any egices, selh with breacl, which was a thin slice or half a slice sametimes. We had to eat in the crouching position, holding our had8 dmn. Dishes were uineashed, and often I would see feces sw:idng in my dish. On occasion we were fed meat from dlad animals. Serbs enjoyed forcing pork on hojas (Muslim priests) and other mslims. The starvation was so severe that I know cases of Wslims not having any -1 im-ts for two months.

6. Serbs ainterrogatedu us daily - there would be up to twenty uinterrogator~:Nat a time shautiag at me at the same time and bitt:ing me. The minterragation" was invariably accmpanie:d with physical mistreatment, with eevere beatings. Serb guaras, 8oldier6, civilians, interrogators, moat o:E them drunk or drugged mt of the time, were incessa.ntly humiliating ue verbally, swearing: "F--- your mother," '@F---your Turkish mother and family," *F--- .you and Alia - allusion to Alia Izetbrgwic, tihe democratic president of the IRl epublic of Bosnia and Herzegovina, " RY~f ------Turkish bastards, you want a state, " anu so on. The cmceatration caqp's :?.A. was constantly blaring metnik songs . . . . f . Every bay Serb gUtrd€l would take us out of the stables at 7 a .nt. , forced us !LO sit in the sun holding our heads dm - we had to hold our heads clown all the time - and our hands behind our backs. Serbs forced us to stxy in this position rill 3-4 p.m. Seas - guards, soldiers, civilians - would cam-e and beat ue with bate, pieces of wd, metal bar6, hoaes, wire cables, ianbl would kick us; they would hit UE in the kidneys, across the neck, over the head, across the back. We tiad to look straight dawn at a11 times. Fathers and sons would not knew [of each other although t:hey may have actually been [within a] few meters of each other.

g. mound 10 July 1992, Emir mlalic, a policearaa fram Sanski Moat was being beaten with the intent to kill, the beating being so savage. After he paesed away, I heard Serbs order two casrlp prisoners to hold him. Serbs forced the two to ho3.d the cozpse for two bouts. Then they called a doctor, who declared him dead f run a burst vein 5s the brain. Often Serb civilians were let into the cacentration csllqp including wacaen and children. 'Pbey would wit on us, stone us, beat us with ming tbqy ccsuld lay their w hands on. Saw would wen cut f ingera of If 1 priacmer~' hands leaving only three fingers (Serb salute). Serbe forced us to do all kinds of manual labour, such as agricultural chores, digging potatoes, digging irrigation Uitches, we had to worked as luaber-jacks carrying wood fram the forests on our backe - Serbs forced the prisoners :into the mods in their T-shirts in winter in bitterly zc)ld weather. litbile working in the fields, I eaw Plus1i.m grazing grass from being starved until their ~tozaachsr;welled. (Information Coordinator on War Crimes in Former Yugoslavia, Stat-t of Victim 003 NA] . 7. Although the incidents described abwe alone support the charge of genocide, they are only representative of the accounts by a group of Bosnian I@uelimrefugees in Canada, vict- of the mass , killings, and other tortures that have been cmmittet3 by serbian forces in mia-Hen;ogwina. a. In aCIBitiaa, BUsliw victims are not the only witnesses to the genocida1 acts crrrmitted by the Serbs. In the November 27, 1992 issue of -, Bo:rislav We-, an inpri-etl Serbian soldier de8cribed BEU-S, rapl3s, and other tortures in which he participated or cbaerved. IlUrns, John, "Serb soldier finds killing of inno~cmt6eaoy,* u,Rihiday, Ncweaber 27, 19921 . Herak's story is the f irat account given by a perpetrator to outeiders of how the Serbian nationalist forces have carried our their plan of 'lethnfc cleansinga.

9. With other Serbian soldiers, Herak emptied a 30-bullet ~llagazine at a family he had found in the baoemment of a haare at Ahatovici, a llusliip village. Four children under the age of twelve, two elderly wanen, and four wen were killed. Herak explained that Serbian ccmmandc?rs called the Serbian operation in tfie willage -, or the cleansing of the region, an8 had told the Serbian fighters to leave nobotty alive. (U.1 . we were told that Ahatwici must be a cleansed Serbian territory, tbat it: WELG a strategic place betwean Ilidza and Rajlovac, and tirat all the Huslinrs there nrust be killed. Me were tolci that no one must escape, and that all the houses must be burned, so that if anybody did survive, they would have no where left to return to. It wae an oar, and I simply did what 1 was told.

10. In another incident, Berak used a hunting knife to cut the throats of three captured Wmlim men who were Bosnian soldiers. u.1 1. In early June, Herak watched a Serbian unit called the 'special iwsstigation graupw machine-gunning 120 men, wlomen and children in a field outside Vogosco. Dump trucks were ueed to transport the bodies to scrub land beside a railway yare at Raj lovac, near Sarajevo, where: the bodies were pild in an open pit, BaueeB with gasoline and set afire. (U.1 . 12. In another incident that occurred in July, Herak saw 30 men fram Donja Bioca, a Muelim vi:Llage five kilometers northwest of Vogosca, shot and incinerated in a furnace at a steel plant at Ilijas, a town north of: Vogoelza. He said sane of the men were still alive when they were tbun into the fumace. (U.) . 13. Herak ale0 describeU seeing the bodies of 60 iaduslim men who he said had been used by Serbian forces as a *human shieldg when Bosnian forces were trying in August to drive Serbian forces off hrc Mountain, outside Vogosca. (a.1 .

4. Regarding the use of rape ae a weapan of war, Hexak m@aineQ that he and his cmpanione were encouraged to go to a mtel by Serbian ca~aranders who told them that taping melh wornen was "good for raising the fighter's raoralew. Herak stated that he went to the motel once mew three or Lour days, and tbat althmgh Serbian fightere routinely took tfie #omen they rap8 away and killed then, there were always nore wcmen arriving. u.) .

15. In early Segtwber of 199;!, in &sinski Petr-, a graup of wslim villagem were approached ky uniformed Serbian soldiers. A woman in her thirties gave a statement regarding the incident. he eoldiers toak her to a bciuse. stripped her at knife-point, asked her to say whether her husbana had weapops, threatenkqg that they would kill her if she denied it, and raped her. Tuo cPPn%ge girls were also raged by the soldiers. Two adult males were taken to a nearby forest, bound wi.th chains, beat and burned with cigarettes by the Serbian ooldiers . (Amnesty International, w n Jaouary 21, L993, page 6) .

16. A twenty-seven year old Muslim wmm intehewed by AmneBty International described her abduction by Serbian soldiers, In late July she was taken by unif omed Serbs to a private M1.e in the tom of Kotor. Inside, the officer hit, bit and rqped her, keeping an autamntic weapcm clc~eeat hand thraughoilt. (U.,page 7).

17. On June 17, appraxlmately 1,000 lranen and children were taken away by Serbian forces frm their hme village of BrezOvo Polje by bus. Travelling without food or water, they arrived in the town of Caparde several days later. Xn the course of the journey same #omen and girls were taken by Serbian soldiers fram the heres while they were parked in the village of Ban Brdo for enera1 w nights and were returned with blood staine and torn clothes. tub,page 10). 18. At CaparC the older vomm were sepaxated, reportedly by paramilitaries from the grolap controlled by Zeljko Razllatovic Iconmanly known as ) , an0 were taken by bus to the battle- lines which they then bad to c:ross on foot. The younger women were held for mral nights in a furniture warehouse in the tawn. Serbian soldiere selected and raged 40 of the woaren between the ages of 15 and 30 years. The yczung women rejoined the older mumu four days later after being forced to pass along a mined road. Doctors who received them in :-,he Bosnian Gwemssent-controlled town of Tuzla following their rarlease reportedly said that ima~~of the girls were prepant. (;Sd. 1 . 19. In an interview with a Zagreb doctor a 17 year old Muslim girl fran the village of Kafaloscvici near Teslic stated tbac Serbs in lfaZA (Yugoslav People's AZYSQ-- uniforms took her and other WCXIWf#l 'err to an unkncrm location, apparenrly sane sort of workersq huts, in wOOa8 near the ta. She vae :held there for three mths until relea~edwith twelve other wwen by a local Serb. henty-four vmmen were held in her hut, al.chcxugh she beliwes she saw about 100 wamex~ in total as they were unloaded. She anU other8 were beaten upon arrival and on 1-ater occasions. Twelve wanen, including the infomant , who were held in her roan were raped in the roam in front of the other wmen on multiple occaoiono, ~~~etipllpsby mure than one man at a the. Other *clsa who tried to defend her on one occasin were beaten and one of the perpe+rators told her, *You will bear a Serbian childw. w. ) . 20. In a honpiral in Zagreb, seventeen year old Marian- described her confinement in a detention camg . Po+. month8 .he was raped as pssny as ten times a day by Serbian soldiers after a& imd 24 other wanen were taken from their Bosaian village, Tesanj , to a camg in a nearby forest. During the rapes, a told .her, wNow ym dl1 have Serbian babies for the rest of your llf e. a (Squitieri. Tam, "Weapons in Bosnia: Rape, degradation, * gQB w,August 10, 1992, page 1).

21. ~ccodingta the mesty International Report. *A OOOUOd to the soul, a betveen 50 and 70 civilians, r~ainlySuslims from Boeaxlski Petrmmc, and 22 soldiers captured by Serbian forces after the fall of mien VaM were held in barracks at Xozile. (~mnestyInteznational Report, mBosnia-Herzcrgoviaa - A vound to the soul, Jamarqr, 1993, page 1.0 ) . a. prisoners at lsozile were bela in six roam, each about three four meters in floor area and holding between ten and twenty ihain(%es each. Almost a11 natural light was blockeU out by wooden boards nailed over the wincbm. The prisoners were given three a day, of similar quality to that received by the soldiers guarding them but of smaller quantity. A few of the prisoners bad bedo, sane of the others had pieces of foam rubber, a few centfatetere thick, to sleep on and most had blankets .... On ane occasion a doctor or nurse visited and left same medicine for those sufferiw fram diarrhea. #hat prisoners most feared were the regular beatings which usually occurred at night, often after the soldiers had apparently been drinking heavily. 'The most terrible thing was waitfng for your name to be called out,' recalled. one former primmer. @Thef runt &ur ha8 an 018 lock with a nail. llhmwer we heard the terrible sound of tfiat lock we ka&o soumane wcrulcl be

called out and we feared it mid be us. @ The sielected griscmer was usually taken to another builckzg abaut 15 meters away from whit=fi the other grisrmers could hear screams of pain. Ozre or more guards would kick the prisoner, punch him, and beat him with rooden trundhacme. The victjm wa6 returned to the cyzll usually after a period of between thirty minutes anb two hours, usually exteneively bruised. #hi le some gri8oners appeareQ to have been beaten only mce or not at all, otherr, - especially Mzslhrm ccmeidered to be wealttsy or well educated - were allegedly severely beaten on at least seven or eight occasions. On at least one occasion a prisoner bias ma& to beat another prisoner with a koodePI club. Stme vict%me were repcsrtecUy placed in solitary confinemant after being beaten for anything from one hour to sweral days.

c. One 23 year olc3 Muslim decorator, was arrested on 30 June 1992 and taken ro Kozile after being held far two days at the police station in meanski Petrovac. On one occasion at about midnight, another Muslim prisoner in the aame roan nantec¶ KK, aged about 35, was taken outside and beaten for about half an haur. Twelve guard dog^ started barking as they beat him. In the decorators words: ' It was as ilF the forest were crying. gK was then made to crawl back into the roan on all fours, barking like a dog .. . . His drenched clmhes shrrwoQ that he had been Bunked in the trough of water outside. As the other prisoners were removing his clothes BK was called out again and after about fifteen minutes he was again made to crawl brick an all fours .. . . - d. When aeked whether they could see HK' 6 injuries the next morning, the decorator replied, 'Yes, -use he slept with us in the roam. AT1 his clothes were off ao me - could eee everythinsr. His back was black and blue everywhere. Qne couldn't find a place big eaough to stick in a needle that wasn't brui~ed.*

e. RK had been beaten or kicked over all his body with the exception of his head. After three days he could walk with the assistance of his fellow detainees, but could not walk unaided for at least another tpoo Bays. f . One prisoner, ZR, agc!d about 35, was beaten about the head. Anocher prisanc!r who saw tuo days later said, [ZRI looked as if he had been stung all over by bees. You could not see any white in his eyes - thy were a11 bloodehot. His cheeks were bruised. His lips were badly swollen. g. On 6 August 1992 between 10 and 20 civilian Betainess J were transferred froan Rozile to mica, also described as barracks for workers, about 15 kil~etersfrm Drinic. On 21 August .the remaining civilians in Xozile were released. xamenica camp repomedly held about 70 detainees, mainly Muslims but also same Croats and Serbs. The Serbs were reportedly soldiers who had deeerted frm the front or had committed thefts. All Muslim aa8 Croat grieonera were held in one rcwm abut 10 meters by 15 meters. Basic conditions were better here than at ILozile. Tbe food iniproved an8 a doctor visited three or four times over a three mcmth period. Detainees slept an a thin piece of tarpaulin an8 each prieoner had a blanket. Prisoners worked in the camp constmeting fences, printing aad cleaning the gzmunck. However, it seems tb.t after the civilian population of Bosanski Petrovac negotiated their departure on 24 September, the detainees in Kaxnenica started to be ill- treated. One 23-year old male Wuelixn wae tortured in late September three days after a visit by the International Committee of the Red Cross (ZCRC) . An officer in charge of the guards called him for interrogation and as'ked him what he had told the LCRC delegation. He ansvoc~redthat he had only handed wer a message for a relative, because his interview had then been cut short as he ha8 been called to work and he had not had time to tell them anything more. After the answer he was hit on the back with a truncheon by another guard beeore the officer in charge mmt him back to the slwing roan. Returning to hie roan he was intercepted ky a group of ~ixBezbian prim6 W then beat him with trunchectne for several mimxtes before one of the guards who wa.6 looking on intervened. Fifteen minutes later he was again called from the sleeping roan: 'They took me to the other side of the schwl. There were eight of their [Serbian] guards and prisoners. One drvve me forward with a rifle in my back. I went there and they started to beat me. They hat me for between 35 an8 $0 minutes. They mid to me, Don't cry out or it will be the worst for you. They ale0 questioned me, Did you say fto the ICRCl that Bosanski Petrovac had been evacuated try force?'

i. He was beaten about the shoulders, arms, back. legs and groin with ordinary police truncheons, although one of his tormentors wielded samething which he described as being like a baseball bat or a riot-coatrol baton - in his om words: *oJhe~,it hit yau it was like an electric shock going through the body.' The following is his description of the pain and being returned to the eleeping area: 'At f iret f felt all the blows [during the beating], but when I entered the sleeping area I jurrt wanted to lie &mn. I didn't feel pain, but there was no way I could lift my arms since I couldngt feel them. That night I couldn't sleep. After one or two hours f felt the pain. I could not get up, move or turn, r coulUn't & anything. In the morning after dawn they [his fellow prisoners] took the clothes off my upper body. When I was undressed my amlookd as if tbay had been inflated with a prnqp for car tires.'

j. The victim stated that he could not stand for four or five days and that he had serious pains for a whole month. He still canglained of pain in his groin and right am in fate November,

. , pages 16-13). 22. These accounts detail actG that clearly constitute genocide. The Serbians targeted meuber~ of a distinct group, i.e. Bosnian Muslims, killed, caused aeriuuu bodily and mental ham to nmmbers of that gm,anB deliberately inflicted on that grwp coeditions of life calculated to bring ubout its physical destruction in whole or in part. The fact that these acte occurred during var- the does not ehield the Serbians Froan prosecution. There is no excuse for tbeee atrocities. m3 Serbians are guilty of gmide.

The Rqpublic of Boenia and Heraegcrviru hereby respectfully requests that the Cart consider this additiorrsl evidence during the courme of these proceedinge and in suppoa of ite Rspuest for an InBicaticm of Prwieional Metrsuree of Protectloo.

Reepectfully suIt;mitteA,

7 / w: Y / //;;--. LI Fraacis A. Boyle, Professor of fnternati-l & and Agent for the Republic of Boenia and Herzegovina

ERHRLTEII U0t1 C.I.J.

GEN 93/16 Le 22 mars 1993 h.5+c~a~kJJ3-3-q3

Rowelle affaire : Bosnie-Herzb~ovinec. Youposlavie (Serbie et Montk6nro)

Dombes su~~lbentairesbasbes sur des faits di~osbesau Greffe par la Bosnie-Herzinovine

Le Greffier a l'honneur d'informer MM. les Membres de la Cour que ce matin (22 mars 1993), l'agent de la Bosnie-Herzdgovine a ddposi au Greffe les textes originaux anglais de deux documents, intitulis tous deux "Eliments supplkmentaires i~ l'appui de la requ6te introductive d'instance contre la Yougoslavie (Serbie et Montkndgro) sur la base de la convention de 1948 sur le gknocide et i l'appui de sa demande en indication de mesures conservatoires de protection". / Le premier de ces documents (annexe 1) contient un tableau chronologique de "Faits pricis se rapportant au comportement de l'ex-Yougoslavie", et le second (annexe 2) prgsente des "Faits prdcis /' lids 1 des actes de gdnocide", comprenant des citations de dbclarations faites par des victimes et des tdmoins. L'agent a expliquk qu'il avait kt4 prCvu de faire figurer ces documents dans la requGte ou dans la demande en indication de mesures conservatoires, mais que cela n'avait pu Stre fait faute de temps.

Des copies sont cornmuniqu6es 1 la Partie adverse.

La traduction fran~aisede ces deux documents sera fournie aux membres de la Cour aussitbt que possible. Annex 1 to GEN 93/16

1

80PRtICMSSTABY SOBldISBIOl ZlP SVOPOST OF

TH. APPtrCAPZObl OF TIIS RSOtlgLTC OF SOSIIA ASD HtRt.BOVXBTA

XlQSTITUTIIIIG L%QA& PROCS1EDZfl08 ABALXST YU00StAttIA (SERBIA

AWD ILO~WIUEt61OH PEB BAS18 OF TEE 1948 0mCI08

COSVS3U9IO~AlOP I10 THlC SOPPORT OF

ITS mu-4 POR AH IIlbXCILTrOIO OP PBOVISSOIUL PILASUSS8 OF PllOftC'PXOM.

To His Excellency, the Praident, to the we6of the Xnternaticmal Court of Justice, the undexsigne8 being duly authorized the mlicof Bosnia and Herzegovina: I have tehanor to refer zo the Pgplicatiun Znstituting Proceedings that was guf;anitted t;o the Court by the Republic of Bosnia and Henegovina cm 20 Paarch 1993 against Yugoslavia (Serbia an8 Montenegro) on the basis of Article ZX of the Genocide Convention of 9 December 1948 and the a- Request for the Indication of Provi8ianal Measures of Protection that was a180 mbnhtted to the Cmrt on tbat date. In Section XV of that Applicatim i4'IV, Juclgenent Rq~ested~)Bosnia and Wenegavina reeervd its ". ..right to revista, supplement or amend this Application." Since the Jgapliaztion was filed, additional evidence -6 caw to the attent:Lon of the Agent for Bosnia an8 Heneguvina that he would like t:o draw to the attention of the Caurt; and hereby eubpnit in supptxt of uur Applicatian and Reqaest for Provisional Measures of Protection. Thfs aaaitional wiBence is as f 011- below.

I. STATE= OF FACTS 1. The following events are categorized chronologically. All cites refer to the same day edition of the W-- unless otharwise noted.

2 mrch 1992: Bosnia and ~energatiaaheld a referendm apprwing i-ece and sovereignty MEkrch 1. (&Ww -, pgge 2)

3 March 1992: Rebel Serbian forces begin attacks an the Relic of Bosnia and Berzegwina, d:~sruptfng travel into and out of Bosnia. (Id., page 9 1 I 28 aaarch 1992: Leaders of Bomia an6 aerzegaviaa appealed to the United Nations to deploy peacek.eaping forces in the Republic with the hopes of stopping or slcx&lgr Serbian attacks. (U.,page 4 1

7 April 1992: The European Cmmunity recognized the independence of Bosnia and Herzegovina on April 6. Serbian forces bombarded the historic Pluslim quarter of Sarajevo. (U.,page 3 1

8 April 1992: The United States recognized the indepmdence of Bosnia-Herzegovina on April 7. (U.,page 10)

22 Agril 1992: Serbian guer:tilla units inteneify attacks on Sarajevo. Unlike other she1:lings to this point, there is a possibility that the former Yugoslav army did not participate. ifd., page 10)

13 )day 1992: The European Cumnmity and the United States renrwed their tmbaseatbrs f ram Belgrade. (U.,page 10

17 May 1992: Peacekeeping Forces, originally placed to supervice a cease-fire between Serbia anB Croatia, withdraw f mm Bosnia to Bergraw and Zagreb due to mortar and ahill- attacks erupting around them. Only 1;:O troops rearainecl in Sarajevo to help with food cunv9ys and to seek a lasting cease-fire in Wnia (U.,page 10) 21 May 1992: Serbian forces held 5,000 hostages fleeing the war in Bosnia until the goverrrment of Bosnia lifted blockades of the Yugoslav (Serbia a~8Montenegro:, Army barracks. I=. , page 14)

22 my 1992: 5,000 hostages held by Serbian forces were released after the Bosnian government agreed to lift the blockade against Yugoslav (Serbia an8 Msmtenegrc)) Army barracks, and to apply the barracks with food and other supplies. (Id.,page 13)

30 my 1992 : Serbian forces unleashed a new attack on Sarajevo, the most severe attack on the Bosnian capital to date* (Id-,Page 1)

31 Hay 1992: The Uaited Nations Security Council voted 13-0 to impose economic sanctions against the Yugoslav (Serbia and Montenegro) gwerxzment in an effort to force Belgrade to bring peace to Bosnia and Herzegovina. tLd. , page 1)

7 June 1992: Serbian forces attacked Sarajevo with the most sustained baubardment from artillery, mortar and rocket batteries since the siege of the Bosnian capital began. (Id., Page 16)

11 June 1992: A United Nations convoy was attacked on the outskirts of Sarajwo by Serbim guerrilla forces. me team was heading to Sarajwo in the hapes of opening the airport. (U., Page 6)

20 June 1992: Serbian fighters attacked the nearby suburb of Dobrinja with artillery, tanks and infantry. 'Phis attack dimmed hopes of opening the airport for airlifts for relief supplies. (U.,Rase 5)

21 June 1992: Statements arE issued by survivors of a bus of refugees held hostage by Semian forces outside of Sarajevo. Serbian gunmen opened fire aa the bus with a baaoaka aad autaaatic weapons. As the dead and warurded lay in the bus, the attackere tossed hand grenades in the bus. Statement. also issued by survivors of rage and torture at the hands of Serbian attackers, ru., page 1)

27 me1992 : Sarajevo airport truce is shattered when' ~erbian force8 used tanka and artillexy to attack civilian buildings in an airport suburb. UN Security Council issues an ultimatum to Serbian forces to halt attacks and put their heavy guns under the united Natioas cuntrol . (19., page 1)

28 June 1992: Despite an ultioiatm from the UM Security Council, Serbian forces continued to 8hel.l Sarajaro with artillery fire. (Id..page 1) 30 June 1992: UN troops too): control of Sarajevo airport and relief supplies began to arrive for the first time in 12 weeks. The UN planna to send 850 peace-keeping troops. (m., page 1)

12 July 1992: Serbian forces attack Baanian city of Gozarde, a cfty wlth a gapulatiun of 50,OOC persans. (S.,page 1) 14 July 1992: Serbian natianalkst Eorces continued their siege on Saraj enro by -tin9 four power - transmission line8 that eer~ga the city, knocking out electricity to the 400,000 persons that reaiain in the city and idling tile punps that prcrvide the reeiaeats with running water. (Id., page 1)

21 Jbly 1992: Due to coartinued Serbian attacks in Sarajmm, an EC brokered treaty failed and the sarajwo airport is closed, (U., Page 1) * 29 July 1992: R%gorts publieheti of Serbian forces force thausan& of Muslims in western Bosnia tct flee. Refugees described terror tactics ant3 of being forced tc~sign away their property. (U., Page 4)

3 August 1992 : A fxls carrying children frcan ~osniato ~8fety in Germany wae attacked by Serbian artillery fire. A 14 -month-old bcry arid a 3-year-old gkrl were killed. ILB., page 1)

4 August 1992: Initial reports begh to mrface about the Serbian concentrat ion ems. Survivors give detailed and consist at accounts of torrule, rape and killings of Bosnian prisoners. (U., page 1)

5 August 1992: h Sarajevo fanily burylng a ymg girl killed during a Serbian attack, is atracked by Serbian sniper fire in the ~arajkcemetery. I=-.page 11

6 August 1992: Serbian forces pound Sarajevo witb a massive attillery barrage into heavily populated civilian dirstriets. Nmy lndepadent an8 consiertent re;mrts f rm, survivors of Serbian concentrat am camps describe f~orrific treatment of prieooers ; ccmqpariaons to @azica.t;yledeath camps are Brawn by histoqians. (U.,pages 1,8)

8 August 1992: mzi-etyle condirions of Serbian concentration camps are confirmed in part by E~ritiahvideo of emaciated Bosnian prisoners -in a Serbian caatp. Tnis video is broadcast throughat Europe anb the Unit& States. (XI., page 11 9 Wgust 1992: Serbian forces surround the northvest corner of Bosnia, cutting off 300,000 Bosnians from food deliveries and escape routes. (fd., page 10)

21 August 1992: Bosnian Serbs declare the formation of a new Republic t the Serbian RepubLic of Bosnia-Herzegovina) from territory seized frcrm Bosnia. (International recognition does not follow). (U.,page I).

22 August 1992 : Radm Kaadzic, leader of the Serbian forces in Bosnka, gledgd to close Serbian prison camps, reurn graperty his anny bat3 aeieed by force, an6 a.llaw relief cooooys free access to Sarajevo and other encircled t;awns. (Later, Karadzic wmld be &OWXI to have failed to meet these praniees). (Ld.. page 3)

25 August 1992: Fighting in Sarajevo intensified as Serbian forces shelled the canter of the city and hit the . The intensity of the attack f orc& suspension of relief flights. (U.,page 81

26 August 1992: As peace talu convened in LwBan, Serbian forces cantimed pounding Sarajevo witin artillery fire, setting afire the city's main library. Serbian forces aleo continued their attack an Mostar, and Smian planes bcmbed Nwi Travnik . (u., page 8 )

27 August 1992: Serb8 launch an artillery attack in Sarajew, striking Yasl*, medigvzl ?xild.ing~acr! the main librzry. (U., page 10) - 29 Aitgust 1992: Semian Leader ~adoMnFadzic prdsed tc halt siege@ on 4 major Bosnian cities during the Londcm peace talks. However, only hours after the c:onclusion of these talks, Sarajevo -8 bazibe6 by fierce mortar an% artillery barrages. At least 10 pereons were killed, and Sara.jevols wain hospital said it had treated 60 woundeU people in a %our-hour period. U.,page 5)

29 August 1992: New reports survivors of Serbian cmceazration c;lnm0 dewxibe the death and torture Bosnian prisoners face at the t?surds of their Serbian captors. 'a., page 1)

30 August 1992: Bosnian Serb leader Radovan Karadzic annmces the lifting of the siege of the Bosnian town of Guracbe, but the Bosnian government stated the fighting there continued. (ILd p. 181 . 31 Auguet 1992: 15 Bosnians were killed and about 100 were wounded in a crowded Sarajevo market when an artillery ehell launched by Serbian forces exploded in the ariddle of the market. (U.,page 6) 1 S~teznber1992: A grenade unts thrawn into a cemetety during a Baenian 80lCUer'~funeral, killing one person and wounding three. (U.,page 31

4 September 1992 : A UN plane ccirrying relief supplies to Sarajevo was shot down. President Bush of the UniteB States criticized Serbian run camps, saying that prisoners face malnutrition, stamation, sexual Wee, beatings an8 executions. (Z.,page 1)

9 September 1992: Serbian forces have returned to the siege of Garadze. Serbian militias untlfer the camand of Dusk0 Kornjaca began the assault which, by Kornjaca's awn estimation, killed 50,000 men. (U.,page 1) . 9 September 1992: Boszim forces azrempt to breakout of the Serbian stranglehold on Sarajevo. (This attack would fail to -break the eiege). (Id., page lo). 1 11 September 1992: A regom f ram the Sush At&ninistration state8 Serbian forces fa Bosnia have been abdarping relief flights to Saraj evc as cover for air strikes against; Bosnians. (U.,page 10).

13 September 1992: Serbs in areas of Bosnia and Ilenegazrina continued heavy shelling bespits the fact that theee weapons were to be turn& ooer to UN supervision. (Xi., page 2).

15 September 1992: Despite the presence of UN observers mcmitoring Serbian artillery positions in Sarajevo, S-ian farces Segza iz new wave of shelling. (IU., page 3)

23 September 1992: A Bosnian Muslim detail^ an account of hau more than 200 civiliane were maseacrsd by Serbian forces after they vere to be released fran a Serbian concentration caqp near Travnik; the prisoners were shot in the head and thrawn into a ravine. I=. , page 14) I

26 September 1992: -6s killings of 200 Bosnian8 near Travnik are conf imed by EC representative. LorU Owen, anB PPT exrvcry. Ws vance . Also confinned is a new wave of ethnic cleansing by the Serbians in the tcrwn of Banj a Lika . (U., page 2)

26 September 1992: United Statea officials report that a8 asany as 3,000 Muslim m, wanen and children were killed in May anc2 June at Serbian-run concentration camps near the Ebosaian towa of Brdro. A spokesman for the US Stare Department stated that the report inclu&XI accouats of "wf llful killing, torture of pri8oaers. abuse of civilians in detention centers, delibarate attacks on non- combatants, -ton d6vaatatior.i and destructicrn of property, and others including mass, f orci;~leexpulsipn and deport~tion of ~i~l~-~(u.,page I) 27 Septeaber 1992: Attacks OTL Sarajevo intensify to became the woret week of shelling since April. 925 civilians were struck by sniper fire, 129 of them died. Sarajevo remained without electricity and running water. (U.,page 12 1

27 Septder 1992: Bosnian Govenuaent declares that 11,000 pereons are wlaownm to have died as a reeult of the Serbian imasicm, with another 56,000 m;ssing. Sarajwo. (a.,page 121 .

2 October 1992: Over 500 residents of the city of Grbavica, a suburb of Sarajevo, were forced to leave their homes and belongings behind after their zuwn ma ~eizedtry Serbian forces. This was considered to be conpelling evidence that th Serbs are reneging on airHise to enil "ethnic clrurrrirzg. (Id., Page 1)

3 October 1992: M least lSO Maslim women and teen-age girls wee in advanced etageis of pregnancy after being raged by Serbian nationaliet fighters. They also said that they were imprieoned for nroaChs afterroard in an attmt to keep them from having abortion^. U., page 5) 6 October 1992: Serbian forcres intensified their shelling of Saraj wo again, attacking seve:--a3 high - rise apartment bui ldimgs . Several of these builtfings were Bet on fire cauefng the resi-ts to thrw their belongings over the balconies in a effort to save thefr property. IZB. , page 10)

8 October 1992: Serbian attaclrers unleashed an artillery attack in the town of Erasno. The Se:-s used incendiary shells to turn the neighborhod into an inf enw. Ifb. , page 141

9 Octaber f992: Sefbian forces resumed their offense in Northern B~sz~&af cer cmeelidating their Wtantial earlier victories. IU.,page 321.

10 October 1992: A Serbian mtxar shell exploded in a courtyard full of children. 3 were kill&!, 10 were wcmndeB. Sweral of the children hrrd iimb azap~~cateB.(Zd., page LO)

11 October 1992: Less t- 24 t~cwsafter the UN imposed a ban on military flightg, Serbian f ightclr p-es attacked the Bouwua of Gradacac. At least 19 persons were killed, 34 were PIMuaded. Other Bosnian coreas in northern Bosnia near Bscko were also hit. (A¶..page 10)

12 October 1992: Croatians are forced to flee after the Serbs ccmquer the Bosnian tm of Boaanki BroB. (LB. , page 1) . 19 October 1992: Sarajevo states that Serbian shelling has aestroyed the city's only flour mill, causing potential starvation for a people whose primary food is pasta and bread. (Id.. page s).

20 October 1992: 2500 Bosnian Muslims were expelled frm their meby Seenear Protor Vans, (U., page 10) .

22 October 1992: Serbs begin a massive shelling project against Sarajevo in the hopes of having that city capitulate without a struggle. Serbians by this date are now in occupation of at least two-thirds of tbe territory of Bosnia. Serbs are receiving logietical mpgmrt fram Yugoslavia (Serbia and ~t~).(U., page 1) . 25 October 1992: Serbs begin stepping up attacks On several strategic Bosnian cities. (U.,page 12) .

29 October 1992: tSoBa1.a euf f ers its worst defeat yet at the hand6 I of the Serbs, as the 8trategic&:llylocated city of Jajce falls to a Serbian offensive. A line of' refugees frcxi the city extends 30 miles. {Ib.,page 3).

1 November 1992: Thwsands of exhausted solbers and civilian8 arrive in Travnik, in Bosnia-Herzegovina, after the military Befeat for the Bosnian farces iri Jaj ce . !=., page 14 ! . 3 November 1992: As a result of the Serbian capture of Jajce, 35,000 ffuslinrs become refugees in Vitez. UN officials now estimate L.5 million people in. Bosnia have became hageLess, not insluCLing those trapped by the Serbian siege of their cammitiea. iU., page 3).

6 Hwemhr 1992: United Nat.ion8 declares since October 22, Serbian forces have flcmn 18-21] unauthorized flights over Bosnia (as gmited by Semxrity Counc:il resalutimr) . (U., page 8) . *

6 Bovember 1992: Fighting breaks out between SerZl8 ~RC¶ bh~slims near'a) the Sarajevo airport. An American relief plane is hit. 10 Waveanber 1992: Boenian Ser~leader Radovan Karadzic dmaa& partitioa of Bosnia along ethnic lines, or threatens to intensify the fighting. (fs., pge 8).

IG November 1992 : Bosnian Fcireign Minister, Haris SilajClzic, states 100,000 people, mainly Muslims, have been killed as a result of Serbian aggression. (LB., page 5 f .

20 November 1992: French troops protecting a Bosnian relief convoy are attacked by Serbian forces. u.,page 1 f . 21 November 1992: Serbs begin heavy sheliing against the Bosnian town of Travik. Travik is key to the Bosnian defense, as it control6 one of the key access roads into Sarajevo. Reports are Bosnia senc 6000 men to clefexid the city. (U..page 31 .

22 lJoverriber 1992 : Travik in Bot:nia under attack by Sez%ian forces in an effort to open another road to Sarajwo. (U.,page 8).

24 Nwer1992: Heavy shellirlg by Serbian forces in Sarajwo is reported. In abUition, Serbs step up attack on the Bosnian city of Travnik, vbose population is predominately ~uslirnand Croatian. (&I.,page 3).

27 November 1992: Special report published regarding Borislav IIerak, a Serbian auxiliary solt9ier facing the death penalty for genocide. During an intemieor, Beak described crimes against Emsnian Mu8li.s~cawnittea by Serbian forces. (u,,page 1).

29 November 1992: Serb6 finally release UN relief copvoy af cer preventing its entrance into Bosnia for 3 days. (U.,page 14).

30 November 1992: Croatian and Serbian forces clarsh in Bosnia and Herzegovina hours before cease fire was scheduled to take glace. iU., page 31.

1 December 1992: Serbs and Crcmts fou~ntpitched battles across ~osnia-)fenegovina,one person is killeb in Sarajevo. (U.,page 81 .

2 December 1992: ON halts humanitarian flights to Sarajevo after US military aircraft is hit b2i small arms fire in defiance of sugposal cease-fire. [U.,page 7).

2 Dectmber 1992: UN Human Rights Coxmission in Oeneva condemns Bo6nian Seas a8 primarily res:ponsible for atrocities camitted during the invasion of Bosnia. (Xi).

6 December 1992: Serbian forces resumed the shslling of the center of Sarajevo and stepped up an armored attack on a nearby mburG. (Xd., Bage 181

6 D8ceuber 1992: In M~s,a au2- 6 miles fzm Sarajevo, S%rbFan forces fight Bosnian forces for contrc: of key approaches to the sanjem airpa--. tu! .

7 December 1992: UtP' forces are Prevented f ran reaching Otes and giving relief to civilians by Serbs, who have overaz most sf Ores. Serbs shut dam Sarajevo's telephone, water, aaB electziciry w8tw. (U.,page 6). 9 December 1992: Serbs begin heavy shelling of Sarajevo's historic center. Heavy civilian caswlties were reported. U., Page 19) . 9 ~ecember1992: Serbs uee tuka to seize airport rozrd and block any relief aiB to civilians cn~ppedinside Sarajevo. Serbs fire cxt French UN troope, forcing Br+& ON troops to leave the airport garrison. (U.,page 3).

27 December 1993: A Serbian tank gunner was intervjcewed, and decribeff the ninth lnwnth of tho sfege of Garajew. He described how be bad been ordered to fire on the apartrsant builCUng ubre his parent8 lived. Serbian aoldiers camff rnred ciYilian are- were targeted. (Id., page 4).

9 Jaauaxy 1993: mrupean Coesrnurrity imestigators estimated 20,000 Muslim worsen had beem raped b:y Serbs as a part of the Serbian * imrasion of Bosnia. European Cormaunity leaezs cond- the violem~eas asystaaaticu. (U.,page 1) .

20 January 1993: The final global human rights report aubmlttecl By the gush A&tinistrarion stated that Serbian forces fa mia and trenegovina were con&cting a campaign of "cruelty, brutality and killLngw unri~tetisince Hazl times. (fe., page 8).

24 January 1993: Aaerican intelligence reports that at least 135 of the coecentration camps e!stablished by the Serbs at the outbreak of tbe war atill remain, despite Serbian prcwism to shut them down. (Reference 22 August 1992 and -&van Karadzic's pru;an,ise to shr dcRan the camps). (U.,page 1).

28 ~amaary1993: Sarajevo camo under fresh Serbian bcmbx&nent, killing at leaet 10 and wouadiag 70. In aWtion, Musliars at Trebinj e were terrorized by Serbian forces . U. , pap 6 .

7 February 1993: 4000 were forced out of thiafx hoaros in the Boeaian tawn of Tre-binje at gun point by Serb~. Serbian military forces reportedly settle8 other Serbia natiorral~in ths h-. (U.,pw 181.

8 ~ebrwry1993: Serbs renewed their emf- of *ethnic c1ezmsixzgm after a Uf? proposa.1 was delivered on partitiming Bosnia into pminces. Bus- refusees were forced to flee fxrrm Cereka, Kamenica, and ather kmsieged Basaim villages abcrPe the nrina Rivex town of Zvomik in eastern Boa. The Serbs comrlnue~their caapaagn of heavy artillery banbarthxwimt. (XI., page LO). 17 February 1993: A UN relief convoy destined for rhe besieged city of Cerska was mapped by S~lxfcrianforces. (Id. , page 8) .

2s February 1993: Noble Peacct Prize winner Elie Wiesel stateti that he had baen "betrayedH by the Serbs regarding same prisoners intemiewe8 ic the concentracicm caqp of Manja~ca. Wieeel noted that prisonere Prkrich he had intt:rvieweb we- later siagled out and punish@ by tbe Serbian caman&:rs of t'ne (U,,page 19) . 26 February 1993: Serbian forc:es allowed a relief coa~oyit bad &elayeel for 12 day8 to reach Gorake, and isolated Maaslim town in eaetern BO&. (a¶.,page 1).

3 March 1993: Serbian force8 fmgan a dawn attack on the Bosnian enclave of Cerska. Mast Boearitra resistance ended early amid the artillery shelling. This attack followed the pactem of uetbic cleansingM practiced by the Serbs. The attack began with a vicious shelling barrage, aa8 then terror tactics against local MusLim paplation in order to turn the survivors into refugees. (Id.,page 1).

4 March 1993: Serbian forces csntiwec3 Che attack on the BoSPian enclave of Cerska. Bosnian resistance crumbled and EQualixn civilians were shelled by Serbs. (U.,page 1).

S March 1993: The Bosnian enclave at Cerska was defeated by the Serbian attack. Saw 1500 PrPu8lJ~nswere wmmt3ed. Refugees fled to the Muslim enclave of Srabrenica, Emmia. (s., page 8 ) .

7 Match 1993: The week-lolog dastzuctiun by Serbs of the Bosnian enclave of Csrska IQB recauated. The attack by ti38 Serbs appeared to be in responee to the Ounericm relief air&-. Cerska wae the first city to receive lmerica.n airdropped food and supplies. (XI.,page 3).

13 &arch1993: Serbian shells killel 20 mslh woaasr, anB children in Vftez, Bosnia, when these peuple crowded arouad two British arntored persoanel carriers in :he hapes of gaining mfe passage QUI~ of the city. (a.,page 4).

14 March 1993: Serbian ealdier Barislav Rerak rvxrfe~sdto crimes ~tteUin "ethnic cleansingm aperataons. Hezak nazeed Vajislav Seaelj and Miro Vukavic as poli-tic- and commnders wha *played a major role4' in the qmzatlaazs. 1U.,page 10).

14 March 1993 : Bosnian forces kegan an airlift af the critically 211 f r-I beeieged enclaves in Srebreaica to hospitals in Tuzia, Bosnia- General Morillon, c~~~xof the Um dlatary forces in Bosnia. a halt of tn% Serbian off enaive in Srebrenica. A vJorlc? Heath Organization phys:Lcian reported that fighcag bad trapped sane 60,000 people in Srebrenica and that 2000 p8rSOn6 had Uied be to Bisease, hunger, mi exposure. [Id., page 10) .

15 March 2993: Serbian forces backed by tanks averran the ~osnian city of Ronjwic Polje, pushing Muslim civilfans into the Boenian city of Srebrenica. This acccmt wae confinned by a UN British major. In addition, there were reports of GerhiaP slaelliag of the Nluslim enclave. (Id., page 3) . 19 Laarch 1993: In Cereka, ~osnia,Bosnian soldiers cornfiraDed short -nave radio operator acc:owts that after overrunning the village Gemkilled eweral civilians. {Xi., page 10) . 19 March i993: Several persons died and several more were wounded in the Bosnian city of Srebrenl.ca due to Serbian shelling. (Ld., page 1). 19 Xarch 1993: Serbia forces reneged on an agrtanerzt ta allow a UN relief cunvoy, aad Serbs launched another intense artillery barrage against Sarajwo. (=I. .J

21 March 1993: Serbian plarlee were eeen being two Muslim villages (Gla60vici and Osatica) in violation of the resolution banning flights wer Boeaia . (;U., page 6 ) .

2. The falluwing statealents arnd evidence isaplicates the Belgrade guvexmment in Y~gcsl~avia(Serbia and Wantenegra) as a party to the acts of genocide cdtteb by Serbs in the wlfc of Bosnia and irerrcegovina. AT1 cites refer to the r3ame day edition of the racmP21ulless otherwise noted.

4 April 1992: Serbim irregular soldiers backed by cbe Yuganlav ~uqattacked Muslim and Croatian forces in Bosanaki Brod and Kupres. Piploosats called the attacks a clear attempt to block European Coanmuaity recognition of Bosnia-Herzegovina s in-ce. (- psge 3)

5 April 1992: Sefbian irrwlar ~olaiersand the Yugtaelav army coatinued their attack against the Bosnian towns of Bmianski Broa aa8 Kupres. PreeiBent Alija :tzetbegovLc was forced to ~Ouzlce the Irrobilization of National Guard an8 police resenre units. m-, Page 3) 7 April 1992 : Sarejevo was alttacked by heavy aut~d~aticweapons fire and grenade mcplosions a::ter Bosnian President Izetbegwic refused to rescind an order to mobilize National Guard forces. (U.,page 3)

8 April 1992: The Serbian-led Yugoslav AZZRY ordered air strikes on the predominantly Croat tme of Siroki Brijeg and Citluk in Bosnia and Iferzegavina. W. , page 10)

9 April 1392: Serb auzits agpmaching fram Serbia iteelf attacked Viaegrad and Zvornik. Gun battles also reported in Wostar, Derventa and Foca. Yugoslav arogy warplanes baaabed the toprns of Sircrki Brijeg and Citluk for the second ~traightBay. (M., page 9)

10 AgirSl 1992: As YU~OS~~VArmy tanks stood ialy by, a Serb- backed guerilla force captured .the! Bosnian town of Zvornik. (=., Page 54) 12 April 1992: The Yugoelav .- carved art new territory in Bosnia and Herzegovina. The amfunits invaded rbe town of Mdrica before awn. (Id., page 16)

14 April 1992: At the National Press Club, Ilr. mris Silajdzic, Foreign Minister of Bmia and E1erzegmin.a pleaded for assistance. Re stated: "Fresh [Serbian] irregular forces are being bruught into Boenia and Werzegwina from Serbia, Mopten~~and the Croation tam of Knin on Yugoslavian Peq?leVs Amy truck and he1i~optes-s.~ (- (- Traxlscript ZD: 821134) .

IS April 1992: In an intentiew on CNN's uXnternaticmal BmrY Dr. Aaris SilajBzic, the Foreign Minister of Bosnia and Lierzmna resrPghasizeB that Semian irregular forces were being knxmglu ia+o Bosnia by the Yugoslavian Peaple'6 Array. Silajdzic also notea later in the interview that the Serbs were equipped by the Yugoslav ZmQf.

15 April 1992: Serbian and Yugoelav arnry forces bm~ean EC- brokered pace agreement . Serbian an8 army units overran sweral regions populated by bturlim Sli~vB. These Eosnian t-a include Fmx, -tar, and QotarBs. /Nerru__-, page 6)

19 April 1992 : Serbian guerril.las pounded central Sarajewo with mortar ahells as arz American official arrived with humanitarian aid for Bosnia. UB., page 1)

20 Agrii 1992: Yugoslav fm&arde8 Wostar. sheLis fell for ett leaat three hours in h@auil:ypopulated neigfiborboode aaB set fire to 6-1 aprmwszt~. (u.,page 3)

21 Pgrif 1992: At a White Haise Background Briefing, a Senior AcBninisttatian Official nared that the Yugoslavia~national army was cauaing problems in Bosnia which made establishing a = relationship with Belgraae difficult . (- Transcript ID 821477)

22 April 1992: Yugoslav army jet fighters attacked the Bosnian towns of Siroki Brijeg, Citluk, Grude an8 Capljina. (&-a 2iaes-, page 10) 23 mri1 1992: Backed by the Yugoslav w,Serbian forces stepped up their attacks on Sa;rajevo as well as on other maller Bognian cities. (U.,page 10)

23 April 1992: During an interview on PBS* *#acHefl/Lehrerm, United States Assistant secretary of State Lawrence Eagleburger called the conduct af the Serbian government apd the Yugoslavia National Army as *outrageclusS and blamed them for the deteriorating sftuation in Bomia. Ihgleburger noted that the Yugoalavian National Arcny and the Serbian irregulars were anoze *activea than the other forces in the regian. rl 30 April 1992: Across Bosnia, there was fighting in at lea~tfive different towns across the republic's northern, eastern, and southern regions as well as a battle in the center of Sarajevo. Those attacks by Serbian force!^ glld units of the Yugoslav Arrqy featured artillery, mortar and rifle fire. Yugoslav Arnty units also continued to puur artillery, mortar and rocket fire into the Bosnian town of Mostar . (- T+mes., page 131

3 May 1992: The heaviest attack to date in Sarajevo erUgt@ when Serbian guerrillas and Yugos1a.v Army forces shelled the city's Muslim quarter with artillery and machine gun fire. The attacJc began soon after 1 p.m. and cantinu& into the night. (m., page 1)

6 May 1992: Yugoslav Army jete rocketed several targets in Sarajevo, and Serbian guerrillis forces continued attacks on the d city. (Id., page 16)

13 May 1992: In an effort to mrd off internatfoaal sanctio~s, Yugoslavia (Serbia and Montenegro) announced that it was relinquishing contror over Yugoslav army units in Bmia and He.rzegov;ina. (Z$. , page 1507

19 May 1992: fn an nws Conferace, Dr. Saris Silaj&ic, Foreign Minister of Bosnia-Herzegovina, stated that the war in Bo8nia was not between Serbs, Muslims, or: Croats, but was inatead me of aggrcssim by YugoaZavia (Serbia and Montenegro) againat Boenia - Herzegovina. (Lecri-B3ate ~8cCfpt3D: 831298).

26 May A992: In a State Department Daily Briefing, Richara Boucher stated that the United States did nut baliwe the disavowal by the Yugoslavian (Serbia and Montenegro) gavernrnent in Belgrade, Boucher placed respaasibilfty for the war in Bosnia on the Yugoslavian anay and the Serbian government. {- Transcript ID: 831755).

28 May 1992: The United States irmbassador to Yugoslavia (Serbia and Montenegro) , Warren Ximtrrman, when intemiewed on M3CSs *'Todayu, stated that the UniteB States saw the ccrllflict not as an ethnic wa8 but rather "ae a umr of aggression that's waged by Serbia and the Serbian president, Milosevic, against an inagpeaaeat rGgUblic." Transcript ID: 831904) .

3 June 1992: Whm asked at a State Oeparrmeat Regular Briefing wherher the Unitm States was "certaina Sezbian leadership wa~in control of irregular Serbian groups inside Bosnia, U.S. State Dapartnsnt Spokeman Rfchard Baxher stated that the gov-t of Belgrade, rather than withdrawing the Yugoslav aqy tuTOBa it uver to the axtranist Bosaian Serb lcladere. He went on to say: *The reality on the ground in Bosnia is that this is an independent state that is be in!^ ravaged by Serbian anaed forces, both army ulcs ancl irregulars, which were unleashed by BelgraBe. which are inspired, equipped, and continue to be supported by Belgrade. " t- t- TraPBcrigt ID: 840231).

9 June 1992: Bosnian govermRent releases transcript of recording of Serbian military leabers, several of whm were officers of the Yugoslav limy, in which the casraaanaing general ordered that all of the Bosnian residential di~triztsshould be shelled. Bis exact camand was %urn it all." (pm,Ynrk.,page 101

11. lrune 1992: Ralph Solmsan, Drguty Secretary of State, during an Sernate Subccrasnittee Haring on European Affairs notea: "Ostensibly, the fYugoslavian1 Axnry has been withdrawn, but chey have remained behind in .some cases -- many caees -- with equipwent and have reanainea untkr the comand of General Vladic. Now he, as far as we can see, is ~lgpointec5and paid by Belgrade.

So, whether or not Belgra.de kas tactical control wer the individual units, aa far as we're concerned is really not particularly relevant. The issue is that Belgrade does have, in our view, enough influence that it can have a material effect on the fighting being done by these irregulars and that Belgrade needs to be held accmmtable for the fact that it set this pZaCeS6 in motion. . . we think that Mr. Milosevfc does control the Yugoslav r97emy.. .we believe the evidence ia vwj, very persuasive.. ." tU&.&aLa Transcript XD: 840866) . 23 June 1992: Thcmas Niles, Assistant Secretary of State, testifying at a House Europe and Middle -st Subcanmittee Rgarbg, in reegonee to a guestian f ram Representative Solan, statedn

"I would say the continuicg shelling of the city of Sarrajwo by the Serbian forces.. .are certainly subject to a very heavy influence, if not cantrol, f rcm Belgrade. " Niles also noted that he believed the President of Yugoslavia (Serbia and ~t~egro), SloboCbn Milosevic, vas Weeply involved in *t e going axi in Bosnia-Etearzegcnriaa. (- (- Transcript ID: 841690) . 26 June 1992: Zn a meeting with Britain's Lord Carrington, Serbian Pre~idernt Sloboaan Nlloaevic refused to recognine the independeat Republic of Bomiii and Herzegovina saying that its status must be determined by tihe leaders of federal YugoelavLa. However, after the independence of four of the old Yugoalavia'a * republics aver the last year, only Serbia and Moeztenegro -in in the federation. -.., page 8)

10 July 1992 : At a CSCE Conference, Secretary of State Saares Baker raade reference to large zuncsunts of heavy weaponry which had hen transported into Bosnia frum Serbia for uae 'try the Serbian forces in Bosnia. (LePj-slate TFranscript ID: 850551).

11 July 1992: Secretary of State Jamas Baker tola Milan Panic that the Unitecl Statee held the Serbian government in Belgrade responsible "for the humanitarian nightmarem caueed by che Serbian invasion of Bosnia. (aEt~m gg 1. a~~hurges Yugoslav- to &ad Ethnic Bloodrhe~3.~)

4 August 1992: Thwaae Mile~s, Assistant Secretary of State, testifying at the House Europe and Middle East Subcamittee Hearing told Representativehr that the town of VuCaMr was Bestrayed by forces "caatroll.ed by the government of Serbiaw. Later, Niles mentioned that tihe Serbian forces in Bosnia were uorganized.. .cop~ctsdby the c,gwemment in Belgrade, the Serbian government, attacking essentially unarmed people in Bosnia - Reroegwiaa", (- Tramscript ID: 860166) .

6 JUJUS~ 1992: A list of 105 Serbian conce~tzatiancamps was made public. 94 of them were in Bosnia and fierzega-ins, 21 of them were in Serbia. (&w page 1) 9 August 1992: On an interview during ABC'B This Week With David Brinkley* Brent Scrwcrof t , the United States National Security Mvisor, stated that the Serbs had the *monopoly on heavy ammin the conflict, and this was due because the arms were handed wer to them by the Yugoslav arrw. (w- R- Tran6cript ID: 860443 1 . . 12 August 1992: . , interview with William Taylor, vice-President of Internatianal Security Program6 at the Center for Strategic and Inter~atioaalStudies. "The solutions to [the prcrblem in Bosnia1 are. . .in Belgraae where SlolDoban ~iloeevic,the president, and his high military command reside, They are the ones who either have control of Serbian regular military forces and Serbian militia forcuo...all of whom are ccawitting these atrocities and killing a lot of people in wnia.. .Thereis one proposition which no one argues and that is that !4ilor~evicand the high cmmand Bo have control wer the Yugo~llavianNational Axmy. That's about 30 divisions. In our estimate8 at CSIS --and we've been tracking for mcanths-- there are still seven regular divieionis in and around Bosnia. Serbia controls these f arceta, no quest~.oaabout it. . .*

11 Septenber 1992: At a State Department Daily Briefing, U.S. Srat e Department Spokeeman Richard Boucher ~tated that the "Belgrade authorities were cant-inuing to supply arms, amrmunition, fuel, spare parts, and a varis!ty of other things to tne Bosnian Serbsu. As such, Boucher Becla.red that Belgrade "bears a certain responsibility".

28 Saptember 1992: A report in Tfie Ye stat88 that Serbia is being used as a source of military weapons and troops which are used to fight in Bami.a. (- page 5)

18 March 1993: The reported that Yugoslavia (Serbia and Montenegro) violated the no-fly zone over Bosnia and conducted a military air strikes against besieged cities in -tern Bosnia.

The Republic of Bosnia and Hercegovina hereby reepectfully reguests the Corurt to consider this additional &Bence during the course of these proceedings anti in supgort of its request for an Indication of Provisional Measures of motecticm. Annex 2 to GEN 93/16

1

SOPPLZMBHTAIY 6VBlbISS101P X1J SUPPORT OF

THB ZLPPLICATIOP OI TSS RlCPUBtIC OF BOSPXA AglD BSRZtUOVIIOA

f X84IPtlPTUQ LEU PROCIBDXlfGS AQAIITST YVQOBtAVXI (SERBIA

ABD IOFPm811t0) OH PHE B&SIS 01 TRI l948 aIIIOCIXI8

COHl?S#TfOZ ASID XI THE SUPPORT OF

I48 ?OR AR XRPfCATIOl? O? PELOVISZO1AL rtlin-8 OF PROTZCPIOB.

TO His Excellency, the t?resident, to the Judges of the International Court of Justice, the undersigned being duly authorized the Reipublic of Bosnia and Herzegovina: I have the honor to refer to the Application Instituting Proceedings that was submittea to the Court kay the Republic of Bosnia and Hertsgwina an 20 March 1993 against Yugoslavia (Serbia and Montenegro) rm the basis of Article IX of the Genocide Convention of 9 Decmber 1948 and the acc~~ngBequest for the Inclication of PraPisional Measures of Protection that waa also mbmitted to the Court on that date. In Section Zv csf that DliWion ("lt'. Judgemnt Reguest&'') Bosnia and Henegwina reserved its *. ..right to revise, supplement or aimnd this Application. .. Since tfie Application was filed, additional evidence has tau@ to the attentim of the Agent for mania ad HemzegQVina that he vould like -t;~draw to zhe attenticm of the Coun, an8 hereby mlmit in sugp~rtof our Application and RBquest for the Iaaication of Prcnrisic~nalMeasures of Protection. This additional mddence i~ as follows below.

I...

I. 8TATUEltT OF FACTS I. Inforanation Coordinator on War Crimes in Forraer Yugoslavia, a Canadian research group, compiled statements from a group of &ormian Muslfras who survived cancentration camps ruri by various Serbian military and paramilitary forces in Bosnia-Ifenegovina.

2. In one acccruat, a Muslim wcmm identif idas SN 011 bescribed the atrocities cdtted against her and her fatrrily and ptayed for the guni-t: of the Serbian forces for theae genocidal acts.

a. I accuse thew for burning clown my haobe, destroying all of our property, for t:&ing my ~U~EUIUand lpqy father-in- law to a ccmceatratien clw, and for tonurim than. r accuse them for haraseing &d terrorizing ngr -&her and my sieter, threatening [them] with murder . . . and &pelling them fmm the tm they lived in and telling them that all that they are doing to my mother and my sister is because they are Muslim and that all the Muslims are to be killed or expelled. b. They should be punish.ed for all those innocent friends, cousins, neighbors land3 acquaintances killed and torture8; for all the mothers, sisters (and] wives raped . . .; for the parents slaughtered in front of their children; tfmy should not escape justice because of all the suffering, torturing, starvar-ion and terror that they made my [husband] and my father-in-law endure, together with hun&sds and thousands of other innocent people . . ..

3. In another statement, a Muslim w~manidentified as AD 010, bacribed an attack cm her village try Serbian forces (Chetnicks). w a. On the 25 of May the Chetnicks attacked our village, which was a Mua1i.m village, and by the 31 of May all the man frarm the village were taken to a cancentration m. In the first attack they shelled the village. The people out of fear were f leehg their homes. I saw raany of them fall, their bodiee and limbs flying into the air. Bodies of nen, wanen, children, and all that just becauee they were Muslims. They killed en masae, pillaged and burnt our houses, det;ained warnen, elderly and children and burnt them alive. They took the yauag men from 20-30 year8 of age land1 brought thest to a school to torture than .... One of my uncles was taken. He survived a firing squad. TWO of his brothers and four of his neghw8, t:ogether with 170 fricanAn, caueina, neighbors. Be laid hicbg with three wcrun8s. He managed to escape because the Chetnicks thought everyone was bead. We took him in a forest after a few days, but he could not go home, knowing chat they would be looking for him since he witnessed a genocide of 180 Muslims. He's been hiding for two months an8 finally they found him one bay and eince than we have aot heard fram him.

b. Th8y have been tortu:ring us a11 in BiEferent manners. Every *illage had a Clhetnick' s headquarters where they spent -8t of the time. They would take our fwd, our gold and jewelry, [and] money. They took [my neighbor's] son away and they threatenredl to kill him unless she brings sane money. She an8 her husband were collecting money thrcnrgh the village, . . . and fixally when they brcnrght the maDey the Cnetnicks let her scm go, but they killed her husband. First tbey mutilated his boay with knives, engraving a cross on his body, fleaving] hlm to bleed, and finally killing him only at night. In that samg lzIBrmer they killed another of my neighbors, it kept go:;ng on; and all this for ane e-le reason: 'Ptrw wanted t.o cleanse evexything mlim. c. Ttrq raped my neighbor, a 65 year old woman, and then killed her. They killed her husband as well, who was a totally handicapped iind helpless person. When we got the permission to bu:~them, we fauna them mutilated. We had to pick up his head and he brain with a slumel.

d. A friend of mine was kept ic captivity because her hushand was fighting on the Bihac front. They were threatening her with Rilllng her and her three children if her husnand [did] not come back and give himself up. After they took our tnrsbancis away we f&dl not hear of them for almost two m~nths. They sent us msaagea £ram the detention camps letting us know that they were alive. Me warnen wercb at the mercy of the Cfietnicks, being ourselves kept in some kind of a detention camp. The whole village was under their occupation and we were let to do only what t.hey decided we could do. We lived in fear because mryckxy thy could kill saneme, anb we were waiting for the same tbng to happen to us.

(Lnfonitation Coordinator an War Crimes in Fmer Yugmlavia, Statement of victim AD 010).

4. In anather account, a ms.Lim civilian identified ae 004 JF described hie detention in sweral ccmcentratiop camps. a. On the 30 May, 1992, ;: was forcibly detained in Prije-r SUP at 9 p.m. In SUP, la1 Serb soldier pierced my skull with the gun breech. We were all being mercilessly beaten; Sorbs ordereri us to face the wall so that we csrnnot see vrho was beating us. There were about one hundred Serb soldierr, in the room ainterrogatingw and beating us. They kept swearing at us saying "You f - - - @ want a republic" *You f --- want a state, nYou want a f - -- Muslim state.* and so on. Serb soldiers coming from the front were thera and they were really wild, the worst. A Muslim. Hamzo (first name), wae shot in the forehead and killed by a Serb soldier the moment we stepped in the SUP building. A mslim, Nizret Tno men asked for his profession answered that he was a -duerqgstera (Ben(psterista) and a Serb soldier said "(31, a snipera (snajperfsta) , and shot him in the head dead oa the spot. Curt Veai:! (58 years) and his sun Sead were beaten to death. All their bone8 were broken, 8ead8s nwe was torn apart.

From Prijedor SUP we were loaded into a bus, 150 of us cramad into the last; third of the bus. Serf3 soldiers were brkving the burs. Serb soldiers killed 2 or 3 Muslims in the bus. A ~mmalroad to QDareka is through Kozarac, but Serbs took us around througk mnnmroufi Serb held posts or villa!aes. At every such point, Serb - villagere would enter the bus, Serb women, chil-, and they wcjuld hit us wit11 wooden bars, stab us with knives, they would throw acitt at us. Several people did, but we were not a110w~sd to look. We reached the concentration cam^ Oxmrska at around 11 p.m. thac night. When I was leaving tk.e bus I saw that the bus was full of blood and many kbs:lims stayed on the f icror, most of them dsad. c. I wa6 in Wrska externination cam from 30 May 1992 [~2lfill6 AU~.1992. I wag beaten there daily for 3 to 4 hours. Going to the toilet meant being practically killecl by Serb hordea (solcliers). Omarska is a mine and there was a lot of material fran the mlne lying arPuad -PePodan bema, cables, iron bars, meal suggarters, etc. Serbs used all rhe~entatetials when beating us. lhey were hitting me, as well as others, in the testicles, using Dotal hampers, ntetai bars, kicking with the boot.. .crrr My testicles were ewc)llen, the size of large oranges. The rumber of tortures varies, f ram one [or) two to twenty or more. They mid gather around vans, drink or take drugs, wearing at us : "F - - - your Wu~1i.mmother, * nF- - - your Turkish (Croatian) mother, '* tr F - - - you an8 your RepublicR anU so on. Serb torturers forced us to lie Oan on the floor with our hands rm the heat3 so tbat we cannot Bee who WELS torturing us. We were taken outside and undemt the cruelest tor+uros and beatings from 8-9 a.m. till 7 p.m. Very often Seas would put metal cans war our h~adads during the awere beating6 so w could not see the tanurers. Serb tmurerc mu16 beat US, step or jump on us until they tired cntt . They were deliberately aiming their beatiags at our testicles 8aying *I-* 11 never awke Muslim children again. " 8. When a Serb from a near-by village got killed in the fighting, Serb guards would let the whole village cane to the camp to vent *:heir rage, which they would do by mtilating and killing us.

e. Gvery Bay Serb torturere killed about 70 to 100 Muelims (some Croats as well). There was a building we called a "White HouseM where the Serb torturers perforwd the killings. They first killed all the doctors and intellectuals. They wen killed a UN doctor, Sadikovic Emb, I think he was in Zimbabwe or somewhere else in Africa with the UN.

f. Around 13 Way 1992, I was lying among a yard full of corpses; I happened to be near a garbage container, a little bit cut: of reach. Serb forces kept firing at the corpses, but sonebart, due to my position, the shots missed me, and I -ged to sneak back into the barracks later. g. One day I was in the detail loading corpses into a 7-ton rruck. We were thruwing corpses in, until the truck was one meter high with ,zorgses. I aneakad away fraw that "jobR, 1 could not take it. 1 saw Serbs using heavy machinery to excavate! big hoies, use trucks to dusp the corpses into the hole, and use clump trucks and construction machine:^ to fill the holes and level the graund . n. Serb torturers used iron bars to beat kslims (same Croats) to death. They would not spare any part of the body, breaking all the banes so that the beaten ~elims begged their torturers for a bullet, to be shot dead. Serb torturers stabbcrd nty anns with hives. I = Serb torturer8 stab othe:ra . . , twisting and turning the laives inside them. 1 saw how BWslims were forced to bite each otherle testicles off, their mouth filled with testicles and blood, ripped blood veeeele sticking out of their mouths. ainily Serf, torturers forced Muslim prisoners to f - - - each other, to perforre, oral sex on each other, forcing t.hese bestialities especially amcmg family membar~,betwe= a father and son. i. In a small roam filled with Muslims, Serbs woulc¶ throw tires that were set on fire and Muslims would burn alive. we had to lie down on the runway, or road, with mr heads tiawn. f saw Muslims beside me being shot dead for mm?ing their h6ads. While we were lying down Serbs wwld jump on us in their b~ot~,jm on UB fram the st-6, from garage rcwfs, breaking peopleis bones, they would &rive cars, evsn heavy trucks aver us, seriously injuring an8 to a large extent killing the unformnates . I would be lying down for 4 -5 hour6. being marcilesely a beaten fry five wen tsn Serbs at a tiate. Serbs were executing planned killings. Quarska extermination camp was a place where Serbs were executing so callee "revengea killings. Serbs would accuse doctors of choking to deatn Serb children, professors and teazhers of being unfair to Serb students, and killed them inmediately for these acrimesa. f was luce to have given an assumed name, for Serbs asked for me by name to kill me (qy Serb neighbors could not rcacognize me, the tortures cbangIedl completely my features) . (I learned later that Sexbs searched to fina me abusing my family, my father 8nU my wife in the process) . k. Oimrska exterraination camp had wcsmn prisoners as well. Daily Sezb eoldiers wrould take girls and bring 5-6 ~nen per girl, Serb soldiers, prisoners to rape them. w Sametimes I was dun~gthe mezt forced to rage the girl[s] ..-. They were raped constantly, noa-stop every day. They raped older women, -oats, 60-65 years of age. me aaated Divis, was wpecl by 12 men. There were many yvunc~ girls, around LO yeare that were being zapec3 daily . . . .

seibs would torture UEI by extinguir~hingtheir cigarettes on our bodies. However that was reserved mostly for Muslim women. Serbs wml8 extinguish their cigarettes on the Mzsl* women's naked bodies, mostly their breasts and =ginas. Serbs would also shwe bottles (~gb~stfy half - liter beer bott3.e~)up tne Muslim girls ' vaginas . . . . Serbs waul0 stick a bottle inside Muslim #owen's vagina and then break them imide them. m. In Qnarslca there was a shog where dump trucks were being repaired - we calleB it the *Red Bou~e.~Serb torturers killed many prisoners in the Red Bmse. That was the glace where I saw the Serbe cut geal;lleas noses, ears, J limbs. When I was cl.Paning the roaa in the Red House the flour was full of human boUy pieces, piecera of the skull, fingers, ears, noses. Outside cm the road, skull pieces were scattered everywhere. n. On the 25 or 26 June Serbs forced me to &rink 5 liters of uee8, dirty cnatoz- oil drained from a truak oil filter, with the intent. to kill me in a terribly painful ~8~. o. 1 witnessed Serb guarcl~osnwing a fire mt hoe into a nanta sphincter (it was a man f raa a village JCorcarac) , letting the water run :full force frm the -, until the man swelled and thcm died bursting to pieces. g. Serb torturers were constantly robbing Muslim prisoners of their belongings. Many of us prisoners had thousan& of Geman Marks with us. Serbs would sell us food at exorbitant prices. once we paid, Serbs would cane, beat us and take the sold goods back .... Serbs were taking Muslim prisoners' watches, jewelry, At first Serbs cut peuple's fingers to get the rings off of them, la~er after a period of tarva vat ion, rings would came off easily. Serbs were knocking mslim prisoners' teeth to get at the gold fillirrgs .. . . g. Serbs were rounding tlp all non-Serb civilians, nwstly Muslhs, and bringing them to Omarska frcm near-by villages - Carakwo eelo, Sambarim, Lje~kava,Ljubija, Raveka. It tiseems mrly one or two f ran each village would raake it co the extermination camp OPaareka. Carakovo selo had 4000 people, they were all ruznded up, but only one made it to the extermination canp. -can ccmparing testimonies of the wrviving eyewitnesses, in Prij-r iteelf Serbe slaughtered 22,000 Muslims. Out of a population of 42,000 hardly 2,000 nsmineB. r. Serb torturers were starving us in Qnarska- For 40 days I was eating only bread. Serbs wauld ratim bread, one loaf of leas than 1 kg was cut into 47 slices, an8 me slice was the ration per prisoner with sane dirty water. In order to get to the kitchen I as well as the others had to endure cruel Iceacings by Serbs. They were also beatlng us while we were eating. Setorturers allowed us 1 minute to fini~llthe meal. In the extermination amp (3marska there waa water that was used to flush the ore fram the mine, as well as the water used to wash the machinery. We were forced to drink that water to muYive. I lpst 39 k~-in am-. s. On 25 May 1992 [a] Re3 Cross visit to the extermination camp amarea wa6 announc&.. Serb torturers hid -ately 150 Muslim prisoners, thrtw in scrrae beds in the roams with bed linen, an8 we were forced to tell the Red Croes that we were WUs1Im fighters, cqgturecl juet prior to their (Red Cross * s) arrival. t. On the 6 Aug 1992, we were driven away by Sezb fiord88 to Manjaca concentratior.. camp. There had been aver four thousand Muslims {anti Croats) that anivd to mrska with me. Less than fourteen hundred of us were left to go to Manjaca. They mwed us from the extermination caaap Cmarska, as Red c3roas members told us, becauee the world has f aunU out about us, nws articles were being published about us. We were driven in the bus. Serb torturers were beating us all the the in the bus, forcing us to sing Chsrtnik songs, killing us. 931- slit ttzroats of swen peog:le right in front of my eyes- me trip of about 40 )an took us 12 hours. The bus would 1 often stop, Serb civilians, soldiers, hetniks with long beards and hetnik insignia, women [and] children would enter to beat us mercilessly, with atanes and anything else. Serbs Bid not give us anything to &rink, it was hot an8 they forced us to swallow a handful of salt. I was perergiring profusely, and in order to survive I drained the perspiration from my sweatshirt into [my] hand8 and rtianfc that. u. In Manjaca, kerhamet; (Red Crescent) registered us. The Red Cross took over food deliveries. However wst of the food vars taken riway isy the Serb guards. We were supposed to receive some fish for breakfast (2-3 pieces) , but Serbs were giving us one for tw~o-re, and wen that not always. When the Red Croas truck arrived Serbs first collected, at the entrance to the storage depot, ratiaas for their am. Later on, when the Red cross left, Serbs would wbeel away most of the fxuita and vegetables. !&slim prisoners wuuld be checked by Red Cross medical staff which would prescribe &rugs. w These drugs never rssched any prisoners, they were all taken by Serb guards for their needs. The only thing we received were pills for strength, which Red Cross gave us right into our hands.

v. In Manjaca Serb guards forced us to Idol all kinds of manual labour. We were forced by Serbs to cur wood in the forests, dig potzttoer;, cut the grass, load the hay, pick corn, graze sheep, cows, etc. Azcuxl one thousand geo~leor more went out, working in the stables, in machine shops, sewinc] clothes, making wooden figurines, burts for rifles, and so on. u. In Manjaca concentration camp I witnessed Serbs taking 142 Croats for [a] prisoner exchange in Knin. As told to nte by one of the Croats, Halupa Zdenko, it took them 5-6 days for the trig but the exchange was not executed, because Serbs Uemancled a Serb major in =change. In J Knin tbey were holding chem in a tcpwer. Sedwould lat dogs [awl children ... cute and abuse them. They broke bones of . . . most of them. When they returned I watches fmthe kitchen haw Serbs were beating them severely. /Infomation Coorclixaator on llar Crimes in Former Yugoslavia, Stat-t af 004 JF) .

5. In another account, a yotmg Muslim female identified as JK 001 reported the ailsof her expulsion by Serbian forces.

a. Every day they enterl& houses in which there were only w-n and children remaining. They plundered, killed and raped even the 5 year old girls an8 old w9aten. So out: own house was a prison camp to us for they could came in and kill us at any time of day or night. Wben they were searching my home we were taken into the backyard and made to stand in a row. They threatmed to shoot us if they found weapons in the houee. There were no weapons, they plundered the hauee and took the gold and told us they would come back again and kill us because we were Muslims .... b. I an8 my old atother together with our neighbors joined those people. We szayed in the houses that had been plundered and the cntners of which had besn killed or taken to camps. It was horrible. There were about fifty of us in me hcruse, we slept on tqp of each other, and the odor of the? dead bodies, which were in the garages land] in the gardens, was evewhere. They killed the men an8 the wa~~enhad to bury their tplnh;md, or son, or father with their hands and to the best of their abilities. There was blood, blood of an innocent son, child, wcmaan, or man on the walls of tne houae. We slept there and waited for our departure, an8 they were standing 0x1 guard outside, singing, drinking, and listening to the Tchetnik songe and wen shooting the houses. c. After a feu Bays 9 trailers and several buses came . . . . On [the way to] Vla~sic, 160 men, 018 and young, were taken f rm tbat f irsr: convoy that had Pef t kmf ore mine, and killed. ?hat :information frightened us, so we became upset and started to leave, but they made a circle around us an5 said tha? we would get what we deeerved, and that uas death, death to a11 mslims or aBulasw as they were calling us. They loaded us onto the trailers aad we :.eft, not knowing ourselves whetsher we were going to death or to freedan . . . . When we came to Vlasic they gave us three minutes to pet off the trailer. We were falling down like sacks wt of the trailer and it was hardest for the old waraen and children. When we got out they started to separate girls and women. Fortunately 1 had a scarf on my hear3 and my aunt4s child in my am. They set apart about thirty girls. They ~segaratedan old waman frcm her two daughters; she proterrted, crieb, went down cm her knees and begged, but there was no mercy. she got a -let in the head. The g;Lrls were taken to an unknown deathation and even roday it is not Rnown. In a line, we atarte8 walking towards Travnik; the men went 6-teiy and the Tchetniks were shooting after thclm, and raury of them got killed because they had been at the back of the line. They told us to follow the road and we would get to u "balijasH (derogatory word for Nuslim), and to reli them they should be grateful that they did not kill us all. The journey was lang and strenuous; many old waanen were carried in blankets or in wfaslbarrcsws, and scme sons carried their mothers on their backs until firally we reached Travnik, which was hard to believe after so many dead bodies of our Muslims had been left lying on the road ant3 everywhere where the Tschetaik's foot was set. And the only reason for that all is that: we are P&ui;lim. (Information Coordinator on War Crimes in Fonner Yugoslavia, Statement of victim JK Ool).. 6. In another atatemeat, a concentration camp survivor identified as 003 NA described the caditions of his confinement. a. OnMax 27, 1992, ... Serbia forces kept announcing over the radio that pecrple nust gather at the practice field. #hrslirrrs and Croats started leaviog their h-8 and Serb forces forced them to mrch to the practice field under mortar fire. f saw tuns of peagle being wouaded as well ae a number of civilians being killed ..,. Frm there I ~b~emerdSerbian Armdad Forces [the official forces of the Serbian municipality of Sanski Most] looting the marked hauses (with white eheets) , burning them to the ground af terwarde. A large number elderly stayed in their banes thinking that no harm fwrruldl came to tnew because of their age. Hmever, Serbian Anned Porcea weat araund killing them . . . . b. During the abduction and in the confinearsnr, 1 suffered constant beatings at the hands of the Serbian med Forces and Serb civilians. Serbian Armed Forcee and Serb civilians were titting me with bate, rifle butts, kicking me with boot^. One Serb, a neighbor chat went to the same school as I, attempted to murder me. He put a gun barrel into my mouth while another took my hand, pulled a knife and attempted to cut two fingers off my ham3 (tnis is to mimic the popular Serb three finger salute) , but aumebw they changed their minds . . . . I was beaten mr the head with chair legs, kicked in the kidneys, in the back. My head was so mollen, twice the normal size, from the beatings that my father, who was also Betain& there, could not recognize me.

c. During the canfinanen:: we were given 8- drenched oozi food, one tablespoon per meal, twice a day, sometiam not even that. Serb guards allowed us thirty to forty secds for the %teal." Wle trying to get to the meal servera and during the mcial, we were constantly beaten . . . . I loot there, in one math, fifteen kg.

d. On 7 July 1992, we were driven away by the Serb hordes to Manjaw concentrz~tion camp in transport trucks, Serbs packeil about 1130 people into a half -ton truck, clased us in with the tent-cloth, which was held tightly in place with steel cables. On the way Serbs would stop the truck in a eunny spot and wait for the temperature to rise. People had no choice but to urinate and defecate on theaasel and people araund them. In the truck 1 was in, eighteen Muslims died from thirst. After we arrived, we were first severely beaten by Serb hordes, they shaved our heads and then Serbs threw us into stables, where sheep and caws had been kept before. The stable swarmed with flies and the conclitions were appallingly unsanita.ry. Same very prickly and sharp grass was strewn over the cement floor where we were sieeping. The stable was 40-60 meters long, its aides made of tin. There were six or mare stables in the concentration c-, all surrounded by barbed wire, the ground armd them mined with explcrsives, there were watch towere there udth machine-gun positions. Serbs aammd about 700 people into cine stable. We could my sleep lying on the side. While inside, Serbs forced us to keep uilent , not a sound was allowed to be uttered. In the silence we cmld hear terrible scream. At first we thought the soup& were coming fran 8ome animals, but som realized they were coming f ran peqgle under extreme torture. Serb camp guar& rationed our mtw, ane glaes of water a day [for] four people (it waa ammerl). If one in the group drank the whale glass the re6t would get nothing. In the morning we were fed tea without augar and ~5thno bread. For dinner we would get sxactly three beans in tepid water without any spices, selh with bread, which was a thin slice or half a slice smeriines. We had to eat in the crouching position, holding our heads down. Dishes were -shed, an8 often I would see feces sw:idng in my dish. On occasion we were f s8 meat from dead animals. Serbs enjoyed forcing pork on hojaa (Muslim priests) and other mslims. The starvation was so severe that I know cases of Wslinls not having any bowel ~hwemaatsfor two mmths. s. Serbs minterrogated* us daily - there would be up to twenty 4*interrogator~:uat a time shautiag at me at the same time an8 hittying me. The minterragation" was invariably accwpanie!d with Physical mistreatment, with awere beatings. Serb guaras, soldiers, civilians, interrogators, met o:E them drunk or drumed mpet of the time, were incessa.ntly humiliating us verbally, swearing: "I?--- your mother," "I?--- your Turkish mother and family," *F--- 'you and Alia - allusion to Alia Izetbrgwic, the democratic president of the [Rl epublic of Bosnia and Herr egovina, " "You f ------Turkish bastards, you want a state, anu 80 on. The cmceatration camp's :?.A. was constantly blaring Cfietnilr songs . . . . f. Every day Serb guard€! would take us out of the stables at 7 a.m. , forced us to sit in the sun hiding our heads Baan - we had to hold our heads tlm all the time - and our hands bshinci our backs. Serbs forced us to stay in this position till 3-4 p.m. Serbs - guards, soldiers,

- -- :. 4 I-' - civilians - would care and beat us with bats, pieces of wd, metal bars, hoses, wire cables, [andl would kick us; they would hit UE in the kidneys, across the neck, aver the head, across the back. We had to look straight doMn at all tiaes. Fathers and sons would not knuw [of] each other although they may have actually been [within a] few meters of each other.

g. ~rmd10 July 1992, Encir Mulalic, a polic~~unfrom Sanski Most was being beaten with the intent to kill, the besting being so savage. After he paaaed away, I heart3 Serbs order two prisoners to hold him. Serbs forced the tm to ho3.d the corpse fox two burs. Then they called a doctor, who declared him dead fnxn a buret vein in the brain.

Mten Serb civilians were let into the concentration including wanen and children. Tbw would spit on us, stone us, beat us with anything tbqy could lay their hands an. Saw would even cut fingera of If] prisoners' - hands leaving only three fingers (Serb salute). Serbs forced UB to do all kinds of manual labour, such as agricultural chores, digging potatoes, digging irrigation &itches, we had to worked as lumber-jacks carxying wood from t;be forests on our backe - Serbs forced the priscmers :into the woods in their T-shirts in winter in bitterly zcild weather. while working in the fields, I eaw Muslim; grazing grass f ram being starved until their etamachs twelled. (In£ormation Coordinator Crimes Former Yugoslavia, Statmt of victim 043 NA)

7. Although the incidents described above alone support the charge of genocide, they are only r-reaentative of the accaunts by a group of Bosnian Muslim refugees in Canada, via- of the mass rages, killiags, snd other tortures that bave been axmitt& by Serbian forces in Bosnia-Hen:ogcn?ina. _I 8. In adCUtian, Muslim victims are nat the only witnesses to the genocidal acts camittea by the Serbs. In the November 27, 1992 issue of me-, Bo:rislav Herak, an iqrisoned Serbian wldier described mrdms, -38, and other tortures in which he participated or obrserved. (tjurns, John, "Serb soldier finds killing of innocente easy, * Thr-, Rk&iy, l&mmber 27, 1992). Werak's story is the firet account given by a perpetrator to outeiders of how the Serbian nationalist forces have carried our their plan of *lerhniccleansingu.

9. With other Serbian soldiers, Herak emptied a 30-bullet magazine at a faarily he had found in the baomnent of a haw at Ahatovici, a B4ueli.m village. Four children under the age of twelve, two elderly wanen, and four men were killed. Herak explained that Serbian caawanders called the Serbian operation in the village cl;.sclenie,or the cleansing of the region, and had told the Serbian fighters to leave nob- alive. (u.I.

we were told that Ahatovici must be a cleansed Serbian territory, that it was a strategic place between Ilidza and Rajfovac, and that all the Muslims there must be killed. We were told that no one must escape, and that all the hciuees must be burned, so that if anybody did survive, they wmld have no where left to return ta. It wae an order, and X simply did what I was told.

10. In another incident, fiera); used a hunting knife to cut the throats of three captured melim men who were Bosnian soldiers. cra. 1. 1. In early June, Herak wa.tchec¶ a Serbian unit called the special investigation groupm machine-gunning 12 0 men, rmmen and children in a field cnttsfde Vogoeco. Dump trucks were ueed to transport the bodies to scrub land beside a railway yarcl at Raj lovac, near Sarajevo. wirere: the bodies were piled in an open pit, Bauaed with gasoline and scat afire. (u.1 . 12. In another incident thxt occurred in July, Herak aaw 30 men from Donja Bioca, a Muslim vi:Llage five kilometers northwest of Vogosca, shot and incinerated in a furnace at a steel plant at f lijas, a town north of Vogoaca. He said some of the men were still alive when they were thrown into the furgace. (fi.).

13. Herak aleo describetl seeing the bodies of 60 Ntuslim men who he said had been used by Serbian forces as a #inman shieldm &en Bosnian forces were trying in August to drive Sexbian forces off zuc Mountain, outside Vogosca. (a.1 .

14. Regarding tbe use of rape as a weapon of war, Hedc -labed that he and his c~ionewere encouraged to go to a motel by Serbian ccreaanders who told them that raping Muelim waraen was "goad for raising the f ighter5s morale4@. Herak stated that he went to the motel once every three or four days, and that although Serbian fighters routinely took the #amen they taped away an6 killed thm, there were always raore wanen arriving. u.1.

25. In early September of 1992, in Bosanski Petrovac, a group of Muslim villagers were approached by uniformed Se*lean soldiers. A woeaan in her thirties gave a statenrent regarding the incident. The ~oldierstook her to a hciuee, strippea her at knife-goint, asked her to say whether her husband had weapons, threatening that they would kill her if sbe c3en;~e.dit, and raped her. 'Rsb iyaenage girls were also raged by the soldiers. Two adult males were taken 4 to a nearby forest, bound with chains, beat and burned with cigarettes by the Serbian soldiers. (meaty Internatianal, w - wan n Ja~uary21, 1993, page 6).

16. A twenty-seven year old Muslim w- interviewed ty Amnesty International described her abduction QY Serbian soldiers, In late July ehe was taken & unifomd se6s to a private fwuse in the town of Kotor . Inside, the officer hit, bit and raged her, keeping an autanatic weapon cloee at hand thr~~lghQUt.(u ., page 71. 17. On June 17, approxixnately 1,000 -rroarsn and children were taken away by Serhf an f oxces f rum their bane village of Brezovo Polje by bus. Travelling without food or water, they arrived in the tcmm of Caparde several days later. Xn the course of the journey swme #ranen and gfrle were taken by Serbian soldiers from the buses while they were parked in the village of Ban Brdo for eeveral w night8 and were returnea with blood stains and torn clothes, I=. , page 10).

18. At QparBe the older wanen were separated, reportedly by paramilitaries fron the groug controlled by Zeljko Raznatovic (camonly known as Arkan), an6 were taken by bus to the battle- lines which they then hat3 to c:ross on foot- The younger wanen were held far several night6 in a furniture warehauere in the town. Serbian solcliers selected and :raged 40 of the wonnen between the ages of 15 aad 30 years. The ycrung wman rejobed the older wmmz~ four days later after being fc~rcedto pass along a mined road. Doctors who received thm in ;:he Bosnian Govermssernt-coatrolled town of Tuzla follwring their rrilease reportedly said that of tire girls were pregaant. (Id.) . 19. In an interview with a Zagreb doctor a 17 year old Muslim girl fran the village of Rafoservici near Teslic stated that: Serbs in (Yugoslav People's Army. - -1 uniforms took her an8 other -[en froan the village in late April to an unkmm location, apparently some sort of workers1 huts, in wcWae near the tcmm . She was held there for three months until released with twelve other women by a local Serb. Twenty-four women were held in her hut, althuazgtr she beliwes she saw about 100 weamen in total a8 tbq were ~ploaded. She aaB others were beaten upon arrival and on later occasions. mlve men, including the inforsaant, #fro were held in her roam were raped in the roam in front of the other wmen on multiple occasio~s, soprsetimes by more than one maa at a cbe. Other umen who tried to defencl her on one occasim were beaten an8 one of the pe~etratorstold her, "You will bear a Serbian child". (u.),

20. In a hospital in Zagreb, seventeen year old Marianna described her confinement in a detention camp. Fm olanths she was raped as arany aa ten times a day by Serbian soldiers after she and 24 other wrmen were taken f ram their Bosaian villqge, Tesanj , to a canzg in a nearby forest. During the rapes, a Serbian guard told .her, "Now you dl1 have Serbian babies for the reet of your life." (Squitieri, Tam, mWeapons in Bosnia: Rape, degradation, -, August 10, 1992, page 1) ,

2. ACCO&~~ to the mesty International Report, =A Mnmd to the soul, between 50 and 70 civilians, mainly Bhaslims from Eweanski Petrmc, and 22 soldiers captured by Serbian forces after the fall of Kulen Vakuf were held in barracks at XPnile. (Amnesty fnternational Report, mBosnia-HerzagDVina - A wound to the soul, January, 1993, page 3.0 1 .

a. miuoners at Xozile were held in six rrYrafi, each abut three by four meters in floor area and holding between ten and twenty cletabees each. AfiPOet a11 natural light was blockeU out by wooden boards nailed over the wiaacwc3. The prisoners were given rhnee -1s a day, of similar quality to that received by the soldiers guarding them but of snraller quantity. A few of the prisoners had bedo, sme of the others had pieces of foam nibbex, a few oentheters thick, to sleep oa and most ha8 blankets . . . . On one occasion a doctor ar nurse visited and left sane medicine for those suffering from diarrhea. wbat prisoners most feared were the regular beatings which usually occurred at night, often after the soldiers had apparently been drinking heavily. *The most terrible thing was waiting for your name to be called out, recalleo me f onner priscmsr . 'The f rant door had an old lock with a mail. ofhenever we heard the terrible sound of that lock we knew mrula be called out and we feared it wald be us. The mlectod prisoner was usually taken to another truild5ng about 15 meters away f ram whir* the other griscnrerm cddhear screaars of pain. Otre or more guards would kick the grisoner, punch hi, and beat him with roadan trundheoaa . The victim was returned to the qell u&ly after a period of between thirty minutes an8 two hours, usually exten~ively bruieed. mile sae prisoners appeared to have beexi beaten only once or not at all, athers - especially Mlsliras caneiderd to be wealthy or well educated - were allegealy severely beaten on at least seven or eight occasions. On at least one occasion a prisoner was made to beat mother priaaner wlth a waoden club. rSXaae victhw were rwortedly placed ------s=z :I z: -- u;;-:. --,. -- I-; - : 4 -

in solitary confinemunt after being beatan for anything - from one hour to several days.

c. One 23 year old Mus:Lim decorator, was arrested on 30 June 1992 and taken :o Kozile after being held for two Aaya at the police station in Boeanski Petrmc. On me occasion at about mimight, another mslim prisoner in the mite roan aamed HK, aged abwt 35, was taken outeide and beaten for about half an hour. rvelve guard Bogs started barking a6 they beat him. fn the decorators words: 'It wae as if the forer;t were crying. gK was then made to crawl back into the roosr on all fwrs, barking like a clog .. . . His drenched clothes sbxrwod that he had bgen Bunked iri the trough of water outside. As the other prisoners were rgPMving his clothes BK us called out again and after abaut fifteen mfautes he was again made to crawl &kck on all fours . .. .

d. When asked whether they could see EIKq6 Injuries the next morning, the decorator replied, 'Yes, because he slapt I with us in the roasn. All his clothes were off eo one could see everythins.. Hie back was black and blue everywhere. One couldn't find a place big enough to stick in a needle that wasn't bruised.'

e. RK had been beaten or kicked over all his body with the exception of his head. After three days he could walk with the assistance of his fellow detainees, but could not walk unaided for at least another two days.

f. One prisoner, ZR, agc!ii about 35, was beaten about the head. Another prisoner who saw him two days later said, IZR] looked as if he had been stung all over by bees. Ym could not see any uhite in his eyes - they were all bloodehot. His cheeks were bruised. His lips were badly ewollen. '

g. On 6 August 1992 between LO and 20 civilian cletainees w were transferred £ran Kozile to Kanrenica, also described as barracks for workers, abut 15 kilmeters f ram Drinic. On 21 August .the remaining civilians in Kozile were releaeed. mmenica camp reportatlly held about 70 detainees, mainly Muslins but also sane Croats and Serbs. The Serbs were reportedly soldiers who had berserteb f rm the front or had emitted thefts. All Muslim and Croat prisoners were held in one rcwtn about 10 metera by 15 meters. Basic conditions were better here than at mzile. The food imroved an8 a doctor visited three or four times over a three ntonth period. Detainees slept on a thfn piece of tarpaulin an8 each grieoner had a blanket. Prisoners worked in the camp c~rurtingfences, pzrinting and cleaning the grormds. h. Hawever, it seems that after the civilian population of Bosanski Petrovac negotiated their departure on 24 September, the detainees in Karnenica started to be ill- treated. One 23-year old male Muslim was tortured in late September three days after a visit by the International Camittee of the Red Cross (ICRC). An officer in charge of the guards called him for interrogation and asked him what he had told the ICRC delegation. He anmared that he had only handed wer a message for a relative, because his interview had then been cut short as he ha8 been called to work and he had not had tiate to tell them anything more. After the answer he was hit on the back with a truncheon by another guarCl before the officer in charge seat him back to the slsbeping roan. Returning to his room he was intercepted by a graup of six Serbian primmer6 wbo then beat him with trunchtmns for several minutes before one of the guards who wa.s looking on intervened. Fifteen minutes later he was again called front the sleeping roas: 'They took mr6 to the other side of the scho~l. There were eight of their [Serbian] guards and grieoners. One drove me fomard with a rif 1% in my back. I went there and they started to beat me. They beat me for between 35 and 40 minutes. They eaid to me, Don't cry out or it will be the warst for you. They also questioned me, Did you say fto the ICRC] that wanski Petrwac had been evacuated by farce?' i. He was beaten about the shoulders, arms, back. legs and groin with ordinary police truncheons, although me of his tormentors eelded something which he described as being like a baseball bat or a riot-control baton - in hie awn won%: 'OJhez, it hit yau it was like an electric shock going through the body. The follming is his description of the pain an8 being returned to the sleeping area: 'At first 1 felt all the blws [during the beating], but when I entered the sleeping area 1 just wanted to lie dm. I didn't feel pain, but there was no way I coula lift my amsince I couldnet feel them. That night I couldn't sleep. After one or two OUTS 1 felt the pain. I could not get up, move or turn, I coulUnit bo anything. In the marning after dawn they [his fellow prisoners3 took the clothes off my upper body. When I was undressed my amlooked as if they bd been inflated with a pfmrp for car tires.'

j. The victim stated ttlat he could not stand for four or five days and that he had serious pains for a whole month. He still canglained of pain in his groin and right arm in fare Nuuenber. (U-,pages 10-13). 22. These accounts detail acto that clearly constitute genocide. The Serbians targeted member@ of a distinct group, i.e. Bosnian !duelimo, killed, caumed aeriouu bodily and mental ham to members of that group, and deliberately inflicted on that grazp cooditio~~ of l%iecalculated to bring about its physical dmet~ctionin whole or in part. Tfle fact that these acts occurred durlng war- time does not shield the Serbians fmm prosecution. There is no actruse for tbose atrocitie~.?he Serbians are guilm of gcinocide.

The Republic of Bo~niaarrd Xerseguvi~hereby reepectful3y requests that the Court conoider this additional evidence during the course of these proceeding^ and in mgqmrt of it6 Request for an Indication of Prvlsicmal Meurnre6 of Rotectlcm.

-7 /

By: I/?/-- &- / /,?,,--> . . C/ Francis A. Bwle. Professor of ?nt&rnaticmal raw and Agent for the Republic of Bosnia and Herzegovina