INTERNATIONAL COURT OF JUSTICE

AFFAIRE RELATIF À

L’APPLICATION DE LA CONVENTION POUR LA PRÉVENTION ET LA RÉPRESSION DU CRIME DE GÉNOCIDE

(CROATIE c. SERBIE)

CASE CONCERNING

APPLICATION OF THE CONVENTION ON THE PREVENTION AND PUNISHMENT OF THE CRIME OF GENOCIDE

( v. )

STIPULATIONS, EVIDENCE, and MEMORANDA

SUBMITTED BY THE REPUBLIC OF CROATIA and THE REPUBLIC OF SERBIA

February 2018

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Honourable Justices,

Welcome to the International Court of Justice at NAMUN 2018. I will be serving as the President of the Court, joined by Deputy President Jerry Qiu and Registrar Marium Nur Vahed.

During the conference, the court will be deliberating on a contentious case (Croatia v. Serbia) and an advisory opinion (Immunities from Criminal Proceedings, based on historic cases Equatorial Guinea v. France and Congo Republic v. France). The first order of business is to read the Background Guide, posted on the NAMUN website, which deals primarily with the principles and procedure of the contentious case. The phases of the trial as they map with the conference schedule will be discussed in more detail at our first committee session.

You will also find an advisory opinion guide, which discusses the Position Paper which is due at the beginning of the conference on February 22. Please read that guide. Your position paper does not have to be particularly elaborate: our basic requirement is that you have at least three questions about the advisory opinion for us to discuss during the first day of the conference. Please let me know if you have trouble finding or using any of these documents.

I anticipate this year’s contentious case will produce a fruitful and engaging simulation. As it deals with relatively recent historical events characterized by deep hostility, I want to specifically remind the participants to withhold their personal perceptions and prejudgment of the case and representatives of the two sides – including the fact that the case concerning Application of the Genocide Convention between Croatia and Serbia was resolved in the actual International Court of Justice on 3 February 2015. The findings from the court at Peace Palace, cases at the International Criminal Tribunal for the former , any other legal mechanism, or, indeed, your existing knowledge of events are not relevant to our simulation.

Following this note are three types of documents described in the Background Guide produced by the advocates for Croatia and Serbia: stipulations, memoranda, and evidence lists. Advocates Mia Durkovic and Mitchell Popen, representing Croatia, and Adrian Ko and Tasfia Karim, representing Serbia, have been hard at work for the past few months preparing these, their witnesses, and arguments. These documents are for your reference. Your knowledge of their contents or the evidence does not need to be complete before the conference.

If you have any questions or concerns, feel free to contact me and my colleagues at [email protected]. I may have forgotten to mention some things so please forgive me and remember to check your email (and spam folder) for any further notes.

Best regards,

Allen Wang President, International Court of Justice NAMUN 2018

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Stipulations

The parties stipulate that:

1. The contentious case, Croatia v. Serbia, was brought to the International Court of Justice on 2 July 1999, where Croatia filed an Application against the Federal Republic of Yugoslavia (FRY), now known as Serbia, “for violating the Convention on the Prevention and Punishment of the Crime of Genocide”.

2. The Socialist Federal Republic of Yugoslavia (SFRY) came to an end on 27 April 1992 and became the Federal Republic of Yugoslavia (FRY).

3. All parties agree to the definition of genocide as outlined in the 1948 Convention on the Prevention and Punishment of the Crime of Genocide.

4. All parties agree that Article IX of the 1948 Convention on the Prevention and Punishment of the Crime of Genocide applies to this case, giving the International Court of Justice jurisdiction to hear disputes relating to the application of the convention, and prosecute responsible States.

5. All parties agree that Croats and are ethnically distinct as demonstrated by independent linguistic, religious, and historical traditions. Both the Applicant and the Respondent recognize that such ethnic differences resulted in tensions which rest at the heart of the dispute ahead of us.

6. The was signed by Croatia, , and the Socialist Federal Republic of Yugoslavia on 7 July 1991 in order to suspend all hostilities surrounding the proposed model of confederation submitted by the Republics of Croatia and Slovenia.

7. All parties agree that the translations used of any aforementioned treaties should be held such that the translations are true, but each state reserves their respective legal interpretations.

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Memorandum of Points and Authorities Submitted by Counsel for Croatia

Statement of Jurisdiction

1. The Republic of Croatia submits this Application, naming the Republic of Croatia (“Croatia”) against the Republic of Serbia (“Serbia”), formerly known as the Federal Republic of Yugoslavia, for violations of the Convention on the Prevention and Punishment of the Crime of Genocide (hereafter referred to as the Genocide Convention). The Court has jurisdiction to preside over the case pursuant to Article 36(1) of the Statute of the International Court of Justice and Article IX of the Genocide Convention.

2. At the time in which Croatia filed the Application, both Croatia and Serbia were parties to the Genocide Convention; the court at the time of the Application also had jurisdiction to preside over matters concerned with responsibility for breaches of the convention.

Statement of Law

1. On 19-21 November 1990, the states of Yugoslavia participated in the Charter of Paris for a New Europe. The meeting outlined terms for peaceful relations among participating States in Europe and reaffirmed the commitment to the Helsinki Final Act. It also established a framework of human rights.

2. On 22 October 1992, Croatia signed the Vienna Convention on Succession of States in Respect to Treaties. In doing so, Croatia agreed that it would be bound by the treaty obligations of the state from which they separated.

3. On 11 December 1948, the Socialist Federal Republic of Yugoslavia signed the Convention on the Prevention and Punishment of the Crime of Genocide (Genocide Convention) and ratified it on 21 December 1950.

a. The Genocide Convention defines genocide as “acts committed with intent to destroy, in whole or in part, a national, ethnical, racial or religious group, as such: killing members of the group; causing serious bodily or mental harm to members of the group; deliberately inflicting on the group conditions of life calculated to bring about its physical destruction in whole or in part ; imposing measures intended to prevent births within the group; [and] forcibly transferring the children of the group to another group.”

4. On 14 May 1954, at The Hague in Netherlands, The Federal Republic of Yugoslavia signed The Hague Convention for the Protection of Cultural Property in the Event of Armed Conflict (hereafter referred to as The Hague Convention).

Statement of Fact

1. An independence referendum was held on 19 August 1990 to determine Croatia’s proposed exit from Yugoslavia. Over 90 percent of the voters voted in favour of the referendum.

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2. In 1991, the separation of Croatia from the Socialist Federal Republic of Yugoslavia spurred four years of wrongful bloodshed and economic destruction.

3. On 7 July 1991, representatives of the Republic of Slovenia, Croatia and the Socialist Federal Republic of Yugoslavia signed the Brioni Agreement, facilitated by the European Community (EC). The agreement demanded a ceasefire, wherein all parties agreed to refrain from any unilateral action. A moratorium of three months on the enactment of a Slovenian declaration of independence was established.

4. On October 8, 1991, Croatian Parliament officially declared independence from Yugoslavia, an act which Serbia and its member of the Yugoslav Presidency did not recognize or accept.

5. The was approved pursuant to UN Security Council Resolution 721 on 11 December 1991. The plan set out to implement a ceasefire in parts of Croatia which were under control of the JNA and Croatian Serbs. The Accord was first signed 23 November 1991, but did not hold, so the second agreement was signed in January 1992 in by all Yugoslav states.

6. Serbian paramilitary groups sought to take over areas along Croatia’s border with Serbia based on the proposed lines drawn of in the SANU Memorandum.

7. The Yugoslav People’s Army (JNA) directly armed and funded the operations of these Serbian paramilitaries.

Argument

1. During the Croatian War of Independence, Serbia – through the JNA and supported paramilitaries – was in breach of article II of the Genocide Convention.

a. Between October 10th-18th, 1991, the JNA shelled, tortured, raped, and up to 70 unarmed and peaceful Croatian civilians in the village of Lovas after it was taken over by Yugoslav/Serbian forces. b. On November 12th, 1991, Martic’s police force, led by the JNA, entered the town of Saborsko where they sought out all remaining Croat civilians. In moving from house to house, they captured and then killed 29 such individuals and placed their bodies in two mass graves. c. On 13th December 1991, the paramilitary group known as The White Eagles, entered the town of Vocin where they systematically tortured, dismembered, burned, and killed dozens of Croatian citizens far beyond the scope collateral damage seen in war times. d. On 20 December 1991, at , the JNA removed over 200 patients – most of whom were ethnic Croats – from the Vukovar Hospital, denied the International Committee of the Red Cross entry to the hospital, beat the aforementioned patients, and subsequently allowed Serbian paramilitary groups to massacre the patients.

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2. Serbia and its associated paramilitaries supported actions which were violations of the laws of war outlined in The Hague Convention and the Geneva Conventions.

a. On 2 October 1991, the JNA’s artillery fire caused damage to a Roman Catholic Church located in Lovas, a village near Vukovar. b. On 12 November 1991, the JNA caused damage to a Roman Catholic Church in the village, Saborsko. c. On 18 November 1991, the JNA tanks shot at a church located in the centre of Skabrnja. d. On 6 December 1991, the JNA wilfully caused destruction to the Old Town of which was to be protected under the Protection of Cultural Property in the Event of Armed Conflict and for its recognition as a UNESCO World Cultural Heritage site. e. On 13 December 1991, the Serbian paramilitary group known as “The White Eagles” used explosives to blow up the historic 750-year-old Roman Catholic Church in Vocin, known as Our Lady of Vocin Catholic Church.

3. Serbia – through the JNA – breached the terms of the Brioni Agreement.

a. Ceasefire was agreed to be implemented immediately and the states of Yugoslavia were to wait three months, however, the JNA continued to shell Dubrovnik - among other cities - with continuous support from the Serbian government.

4. Clear financial, material, and hierarchical ties of rebel paramilitaries to the JNA and the Serbian-led Yugoslav government

a. Through the National Bank of Yugoslavia, small financial institutions in Krajina were taken over allowing operational money to be routinely deposited and made accessible to the rebels in a way that circumvented agreed upon UN treaties such as the Vance plan. This is confirmed in the testimony of Milan Babic, Morten Torkildsen, and General Aleksandar Vasiljevic. b. The Yugoslav government routinely supported rebel activity though numerous weapon and aid supply transfers. Furthermore, this support can be tied back to orders from the highest officials in the Yugoslav government. This support and order structure is verified by General Aleksandar Vasiljevic of the JNA.

Prayer for Relief

1. Croatia requests that the court rule Serbia has breached its obligations under the Convention on the Prevention and Punishment of the Crime of Genocide.

2. Croatia requests that the court order Serbia to atone for their wrongdoings by compensating the state of Croatia and it citizens for the emotional and economic harm their actions have caused.

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Evidence List Republic of Croatia

A1. Testimony of Milan Babic Date: November 18 - December 9, 2002 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/slobodan_milosevic/trans/en/021118IT.htm http://www.icty.org/x/cases/slobodan_milosevic/trans/en/021119IT.htm http://www.icty.org/x/cases/slobodan_milosevic/trans/en/021121ED.htm http://www.icty.org/x/cases/slobodan_milosevic/trans/en/021122IT.htm http://www.icty.org/x/cases/slobodan_milosevic/trans/en/021125ED.htm http://www.icty.org/x/cases/slobodan_milosevic/trans/en/021202ED.htm http://www.icty.org/x/cases/slobodan_milosevic/trans/en/021204IT.htm http://www.icty.org/x/cases/slobodan_milosevic/trans/en/021209IT.htm Relevant points: N/A

A2. Testimony of Vesna Bosanac, Director of Vukovar Hospital from 1991 Date: November 5, 2008 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/seselj/trans/en/081105ED.htm Relevant points: Pages 11401-11412.

A3. Testimony from Jan Allan Schou Date: March 30, 2006 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/mrksic/trans/en/060330IT.htm Relevant points: Pages 6867-6868, 6885-6891.

A4. Chapter 4: “What Happened in Vocin” in Anatomy of Deceit Date: 1996 Author: Jerry Blaskovich http://www.studiacroatica.org/anatomy/anatomy04.htm Relevant points: Chapter 4

A5. Summary of Judgement in the Case (The Prosecutor v. Miodrag Jokic) Date: March 18, 2004 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/miodrag_jokic/tjug/en/040318_Jokic_Miodrag_summary_en.pdf Relevant points: Pages 1-3.

A6. Yugoslavia: Further reports of torture and deliberate and arbitrary killings in war zones (EUR 48/26/91) Date: March 1992 Author: Amnesty International YUGOSLAVIA @Further reports of torture and deliberate and arbitrary … Relevant points: N/A

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A7. United Nations Convention on the Prevention and Punishment of the Crime of Genocide Date: January 12, 1951 Author: United Nations https://treaties.un.org/doc/publication/unts/volume%2078/volume-78-i-1021-english.pdf Relevant points: N/A

A8. Vienna Convention on the Succession of Treaties and its signatories Date: August 22, 1978 Author: United Nations http://legal.un.org/ilc/texts/instruments/english/conventions/3_2_1978.pdf https://treaties.un.org/pages/ViewDetails.aspx?src=TREATY&mtdsg_no=XXIII- 2&chapter=23&clang=_en Relevant points: N/A

A9. Testimony of General Aleksandar Vasiljevic, deputy head of security in the JNA Date: February 6, 2003 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/slobodan_milosevic/trans/en/030206ED.htm Relevant points: Page 15785.

A10. Testimony of Ante Markovic Date: October 23, 2003 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/slobodan_milosevic/trans/en/031023ED.htm Relevant points: Page 28044.

A11. Testimony of Morten Torkildsen Date: May 28, 2013 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/hadzic/trans/en/130528ED.htm Relevant points: Page 4996.

A12. Testimony of Adam Rendulic Date: December 4, 2012 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/hadzic/trans/en/121204IT.htm Relevant points: Page 2105-2107.

A13. Testimony of Goran Stoparic Date: December 14, 2010 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/stanisic_simatovic/trans/en/101214ED.htm Relevant points: Page 10355.

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A14. Testimony of Vlado Vukovic Date: March 28, 2006 Author: International Criminal Tribunal for the former Yugoslavia http://www.icty.org/x/cases/martic/trans/en/060328ED.htm Relevant points: Page 2753.

A15. Brioni Accord for ceasefire and non-aggression Date: July 7, 1991 Author: United Nations https://peacemaker.un.org/sites/peacemaker.un.org/files/HR%20RS%20SI_910707_Brioni%20D eclaration.pdf Relevant Points: N/A

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Memorandum of Points and Authorities Submitted by Counsel for Serbia

Statement of Jurisdiction

1. The Republic of Croatia (hereinafter “Croatia”) has filed an Application against the former Federal Republic of Yugoslavia (hereinafter “FRY”), currently the Republic of Serbia (hereinafter “Serbia”), for alleged violations of the Convention on the Prevention and Punishment of the Crime of Genocide (hereinafter “Genocide Convention”).

2. Croatia invoked Article IX of the Genocide Convention, asking for the resolution of the dispute from the International Court of Justice (hereinafter referred to as the “ICJ”).

Statement of Law

1. On 29 August 1950, the Socialist Federal Republic of Yugoslavia (hereinafter SFRY) ratified the Genocide Convention.

2. On 1 November 2000, the FRY became a member of the United Nations.

3. On 10 June 2001, the FRY became a Contracting Party of the Genocide Convention.

4. The International Criminal Tribunal for the former Yugoslavia (hereinafter ICTY) issued indictments against Croatian generals for crimes against humanity committed against the Serbian population of Croatia – in particular during “”.

5. As of November 2012, the Croatian judiciary itself has convicted 2,380 persons for various crimes committed during Operation Storm.

Statement of Fact

1. The death of the long-term President of the Socialist Federal Republic of Yugoslavia was the catalyst for the conflict between Croatia and the FRY. a. The departure of Tito coincided with the beginning of the demise of communism in Eastern Europe. b. After several decades in which ethnic and cultural diversity were reasonably protected and fostered, nationalism became the new foothold for political leaders in the SFRY, in which ethnically charged hate speech became a common vehicle of political success

A large minority of Serbs resided in Croatia, particularly around the border with , formed the former Republic of Serbian Krajina (hereinafter RSK), which existed between 1991-1995.

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2. On 4 August 1995 to 14 August 1995, Croatia commenced Operation Storm against the RSK. RSK ceased to exist by the end of Operation Storm, after which its territory was reincorporated into Croatia.

3. According to the data of the VeritasDocumentation Center, more than two thousand people were killed or missing in Operation Storm, and 1,192 of them were civilians.

4. After Operation Storm, 200,000 Serbs were forced to leave Croatia.

Arguments

1. Serbia cannot be held responsible for acts or omissions which occurred before 27 April 1992.

a. There was simply no Federal Republic of Yugoslavia and therefore no Serbia before 27 April 1992, thus Serbia cannot be held responsible for any acts or admissions prior to 27 April 1992. b. Any acts referred to by Croatia, on the part of Serbia, stated in the Application that occurred prior to 27 April 1992, are therefore inadmissible. c. Furthermore, the Republic of Serbia became a member of the United Nations on 1 November 2000, as the FRY. d. The FRY became a Contracting Party of the Genocide Convention on 10 June 2001. e. The FRY was never bound by Article IX of the Genocide Convention until 10 June 2001.

2. There was no genocide against Croats. Genocide requires mens rea. There are no grounds to establish the responsibility of the Respondent under the Genocide Convention.

a. While there was armed conflict and casualties between both Croatia and Serbia, Serbia had zero “intent to destroy, in whole or in part, a national, ethnical, racial or religious group as such”. b. There is also no dolus specialis, that is to mean a specific intent, which in order for genocide to be established, must be present in addition to the intent required. c. Submissions made by the Applicant in the present proceedings are unfounded.

3. Genocide under Article II of the Genocide Convention was envisaged as either physical or biological.

a. The travaux préparatoires of the Convention consciously decided to limit the categorization of genocide as either physical or biological. b. Any notion that genocide is defined as anything more is perverting the intentions of the travaux préparatoires.

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4. The actions taken within Croatia’s Operation Storm committed genocide against Serbs residing in Croatia.

a. The Serbian population in Croatia, namely Serbs living in the territory of Krajina (Krajina Serbs) suffered acts of genocide. b. Croatian military leadership prepared for the strike against the Krajina Serbs by conducting preparatory military operations. c. A genocidal plan was envisaged among the top Croatian political and military leadership, indicating dolus specialis.

Prayer for Relief

1. Serbia requests that the Court rule the claims submitted by the Applicant are inadmissible.

2. Serbia requests that the Court rule that Croatia committed acts of genocide and displayed genocidal intent.

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Evidence List Republic of Serbia

RA. Vienna Convention on the Law of Treaties Author(s): United Nations Date: May 23, 1969 http://www.oas.org/legal/english/docs/Vienna%20Convention%20Treaties.htm Relevant Point(s): Article 28 on Non-Retroactivity of Treaties

RB. Ratione Temporis (Definition) Author(s): Aaron X. Fellmeth and Maurice Horwitz Date: 2011 Publisher: Oxford University Press http://www.oxfordreference.com/view/10.1093/acref/9780195369380.001.0001/acref- 9780195369380-e-1795 Relevant Point(s): on non-retroactivity, quoted passage

“Because of the relevant timing or period of time pertaining to the subject under consideration. E.g., Germany contends that the key issue for the purpose of applying Article 27(a) is not the date when this dispute arose, but whether the dispute relates to facts or situations that arose before or after the critical date. Only if these facts or situations took place after the critical date, that is after 1980, would the Court have jurisdiction ratione temporis under Article 27(a). But since, in Germany’s view, this dispute relates to facts and situations that predate 1980, the Court lacks the requisite jurisdiction. Certain Property (Liecht. v. Ger.), 2005 I.C.J. Rep. 6, 20, ¶ 30.”

RC. Fourth Report on the Law of Treaties Author(s): G. G. Fitzmaurice Date: 1959 Publisher: Yearbook of the International Law Commission Vol. II Reference: http://legal.un.org/ilc/documentation/english/a_cn4_120.pdf Relevant Point(s): p. 74, para. 122

RD. Genocide in International Law: The Crimes of Crimes Author(s): William A. Schabas Date: 2000 Publisher: Cambridge University Press Reference: http://www.javeriana.edu.co/blogs/ildiko/files/Genocide-in-International-Law1.pdf Relevant Points: p. 541

RE. The Death of Yugoslavia Author(s): L. Silber and A. Little Date: 1995 Publisher: Penguin; BBC Books, London Reference: 978-0140261684

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Relevant Point(s): p. 86 (Annex 1).

RF. ICTY Indictment in the case Prosecutor v. IT-01-45 Author(s): United Nations Date: 24 Feb 2004 Publisher: International Court of Justice Reference: http://www.icty.org/x/cases/gotovina_old/ind/en/got-ii010608e.htm Relevant point(s): pt. 20, “Deportation/Forced Displacement”

RG. Operation Storm: Croatia’s Triumph, Serbia’s Grief Author(s): Marija Ristic et al. Date: 3 August 2015 Publisher: Balkan Transnational Justice Reference: http://www.balkaninsight.com/en/article/operation-storm-croatia-s-triumph-serbia-s- grief-07-31-2015 Relevant point(s): Story of Anka Bjelivuk (see quote below)

“Anka Bjelivuk was 47 when she and her husband took her daughter and a few belongings and joined a column of Serbs who were fleeing their houses in central Croatia on August 5, 1995, as ’s forces advanced with their heavy artillery. ‘We lived in the Vojnic municipality, [Operation] Storm was already underway…We left the house together, we were on a tractor, my daughter was just a kid back then.’ Bjelivuk recalled. Since that day 20 years ago, Bjelivuk has been a refugee – and since that day, she has never seen her parents, her brother and his pregnant wife again. She only found out later from her neighbours what happened to them. “A rocket hit them, this is how they were killed, somewhere while they were in a column [of refugees], somewhere around Zirovac [a village on the highway tow Bosnia],” she explained. Their bodies have never been found. “I still don’t know even today where they are. And I don’t think I will know until the rest of my life,” she said with a trembling voice.”

“Bjelivuk’s relatives are among the 600 Serbs who went missing during Operation Storm, when Croatian forces regained control of 18 per cent of the republic’s territory that had been held by rebel Croatian Serbs since 1991. The Serb rebels were routed and more than 200,000 people like Bjelivuk fled the country”.

RH. The Situation in the Occupied Territories of Croatia: Report of the Secretary-General Author(s): United Nations General Assembly Date: 20 October 1995 Reference: http://www.un.org/documents/ga/docs/50/plenary/a50-648.htm Relevant Point(s): para. 33

RI. The Situation in the Occupied Territories of Croatia: Report of the Secretary-General Author(s): United Nations General Assembly Date: 20 October 1995 Reference: http://www.un.org/documents/ga/docs/50/plenary/a50-648.htm Relevant Point(s): para. 27

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RJ. Prosecutor v. Gotovina, Cermak and Markac IT-060-90-PT Author(s): The International Criminal Tribunal for the Former Yugoslavia Date: 23 March 2007 Reference: http://www.icty.org/x/cases/gotovina/custom3/en/pros-ptb.pdf Relevant Point(s): para. 23

RK. Croatian Helsinki Committee for Human Rights, Military Operation Storm and its Aftermath Author(s): Zagreb Date: 2001 Reference: https://snv.hr/oluja-u-haagu/media/sg1/sg1-04-vojna-operacija-oluja-en.pdf Relevant Point(s): details about killings at pp. 104-106, number of killed pp. 137 & 166–169, description of events in Sector North pp. 281–283, list of killed pp. 285–286

RL. Report on the Situation of Human Rights in the Former Yugoslavia Author(s): Elisabeth Rehn (Special Rapporteur of the Commission of Human Rights) Date: 7 November 1995 Publisher: United Nations General Assembly Security Council Reference: https://digitallibrary.un.org/record/202407/files/A_50_727_S_1995_933-EN.pdf Relevant Point(s): p. 7, para. 18; see also Report of the Secretary-General submitted pursuant to Security Council Resolution 1009 (1995), 23 August 1995, UN Doc. S/1995/730, para. 6; see also Human Rights Watch Report, Impunity for abuses committed during Operation Storm, and the denial of the right of refugees to return to the Krajina, August 1996, Vol. 8

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