Annex1 to GEN93/16
80PltrLMSmARY SOBlSISSIOLB Z19 SVOPO8T O?
TZU APBLZCA'PZOH OF TBR Rwtlgtrc OF SOSHZA WD H~~UBGOVII~A
IXSTI~IUG WQAL PROCttDIftOS A8ALXST YWQOSWfA (SERBIA
AHD LaO#TrCIETIULL OH)THO MIX8 Oh PBE 1988 O%EOCIL)B
COmlmrOl AVD I10THI: SOPrnRT OP
STS BSQO~ST ma aw rmxcMrow OP PBOVISZ~~AL ~CJULS~IC OP
PILMSCIIOW.
TO 111sExcellency, the President, to the Judges of tbe
Intematicmal Court of Justice, the undersigned being duly
authorized by the mlfc of Wsnia and Herzegovina:
5:have the hanor to refer r,othe Applicatiun Iostitutiag
Proceedings tbat was go1;anittet;othe Courtfry the Republic of
Bosnia and Henegovina cm 20 March 1993 against Yugoslavia (Serbia
and Montenegro) on the basis of Article IX of the Genocide
Convmtion of 9 December 1948 and the a- Requestfor the
Indication of Provisiona l easuresof Protection that was also
submittedto the Court on that date. In Section N of that
Application IaIV.Judgment Regl~ested") Bosllia and Herzegovina
reee- ite "...rightto teNista,-1-t or amend this
Application." Since the Appliazcian was filed,additianal
evidence bas canreto the att8nt:Loonf the Agent for Bosnia an8
Herzeghna that he would like l:odmw to the attention of the
Court and hereby mxbit in ~narptrrof our Application antiRagzmst
for Prawlsicmal Measures of metxion. Thisaclditional evidence
is as follm below. 1. The folAawing events are categorize8chranalogical~y.
All cites refer to the same day edition of the &bxs-Y
unless othEnwise noted.
2 March 1199: Bosnia and Henegavfna held a refere&m approving
i-epeazdence and sovereignty an kQirch 1. (btf tu, puge 2)
3 March 1992: Rebel Serbian forces begin attacks on the Republic
of Bosnia and Herzegovina, d:'~srupting travel into an8 out of
Bosnia. (U. , page 9)
'crl
28 wch 1992: Leaders of Bomia and Herzegaviaa appealsd to the
the hopesatofnstcrppingor eluwiqr Serbianfoattacrks.h(Ib.,ppagec4)th
7 April t992: The European Communityrecognized the independence
of 3osnia and Herzegovina on April 6. Serbian forces bombarded
the historic malim quarterof Sarajevo. (U., page 3)
8 April 1992 : The United States recognized the indgpendenceof
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~igoslavarmy did not participate.
iU., page 10)
w
MY' 1992
13 my 1992: The EuropeanCamunity and the United States rlartwed
their anbassaUor6 fraw Belgrade. (Id .page 10)
17 May 1992: UN Peacekeeping Forces, originally placed to
supervise a ceaoe-fireberoeen Serbia aoB Croatia, withdraw from
Bosnia to Belgracleand Zagreb dtue tomortar and artillery attacks
erupting around them. Only 120 troops remainedin 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 blockades of the
Yugoslav (Serbiaand ilcmtemegro:&my barracks. , page 14)
22 May 1992: 5.000 hostages held by Serbianforceswere released
after the Bosnian governmentagreed to lift the blockade 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 economicsanctions 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 siege of the Bosnian capital began. (U., Page 16)
11 June 1992: A United Nations convoy was attacked on the
outskirts of Sarajevo by Serbian guerrillaforces. 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
Dobrinja with artillery.tanks and infantry. This attack dimned
hopes of opening the airport for airlifts f01 relief supplies.
(LB. , ass 5)
21 June 1992: Statements are i~sued by 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 rape and tomure at the hands of Serbian attackers.
(a3.,Page 1)
27 me 1992: Sarajevo aifWxt truce is shattered rhon' Serbian
force8 used tanks and artilleq to actackcivilian buildingsin an
airport suburb. OH Security Council i~sues an 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.lSarajevo with artillezy iire.
(Id.. page 1) 30 June 1992: UN troops toof;: control of Sarajevo airport an8
reliefsupplies 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:~st force8 cmtinwCq their siege on
Sarajevo by dynamitingfour gmrer-tranemisaio line8 that aweU
tbe city, knocking out electricity to the 400,000 person6 that
raarain in the city and idling the gurnpsthat 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 Saraj wo 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 ~ugust 1992 : 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
accountsof torture,rape and killingsof Bosnianprieaners. (U.,
Page 1)
5 August 1992: h Sarajevo family burying a young girl killed
during a Serbian attack, ia attackedby Serbian sniper fire in the
Safajevo cemetery. (U., page 1) w
6 August 1992: Serbian forces pound Sarajevo witb a raa6eive
artillerybarrage into heavily populated civiliandistricts.
indepexadent and consistent re;>orts frmL survivors of Setbian
concentration camps describe horrifictreatment of prieoners;
cfmrgarisons to Nazi-styledeath 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~cape routes. (Id., page 10)
21 Auguet 1992: Bosnian Serbs declare the formation of a new
Republic (the Serbian Republic of Bosnia-Herzegovina) from
territory seized frtm Bosnia. (International recognition doesnot
follow). (U., page I).
22 August 1992 : Rad- Kaadzic, leadex of the Serbian forcesin
Bosnia, pledged to close Serbian pri~on cas@a, return grqperty his
am had 8ei~ed by force, and a.llcw relief camoys free access to
Sarajwo and other encircled towns. (Later, Karadzic wcruld be
shawn to be failed to ateet thwe praaises) . (U., page 3)
25 August 1992: Fighting in Sarajevo intensified as Serbian
fo~cee shelledthe center of the city and hit the HoZibay Inn.
The intensityof the attack forced suspensionof 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 Serbianplanes 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
sieges on 4 major Bosnian cities &ring the London peace talks.
Hawever, only hours after the c!onclusion of these talks, Sarajwo
was bmbd by fiercemortar an5 artillery barragee. At lea8t 10
pereons were killed, and Sara.jevoes main hospital said it had
treated 60 wounded people in a four-hourperiod. U., page 5)
29 August 1992 : New reports by laurVj.vorof Serbian ccaceatratiorn
camp0 desr=ribe the death and torture Bosnian prisonersface 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'sfuneral, killing me person and wounding three.
(U., page 3)
4 September 1992 : A UN plane awing reliefsuppliesto Sarajevo
was shot dawn. Preeident BUS^ of the united States criticized
Serbian nm camps, saying that prisoners face malnutrition,
starwacian,sexualdbuse, beatings and executions. In., page 1)
9 September 1992: Serbian forces haw returned to the siegeof
Garadze. Serbian militias untierthe ccmrmand of Dusko Kornjaca
began the assaultwhich, 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. (Thisattack would faii to
'break the eiege). (Id., page 10). lrllr
11 September 1992: A report f ranthe Bush Adtrainistrationstates
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
monitoringSerbian artillerypositions in Sarajevo, Serbia forces
began 2 new wave of shelling. LZ., gage 3)
23 September 1992: A Bosnian Muslim details an accountof how
more tham 200 civilians were massacred by Serbian forces after
they were to be released from a Serbian concentratio naaq?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 8asniansnear Tranmlk
are ccmfiwed by EC representative, Mrli Owen, and PN envcry.ms
Vance. Also canfimd is a new wave of ethnic cleansing by the
Serbians in the tcm of Banja Luka. (U., page 2)
26 Septanber 1992: United States officials report that as nm.13as
3,000 Muslim arernw,arnenand chilarenwere 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-
othera, includingon mass, forcij~leexpulsiun and deportatioa of, and
(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 Grbavica, a
suburb of Sarajevo, ware forced to leave their homes and
belongingsbehind after their zann was ~eized by 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 afterwardin an actwt to keep thm from having
abort$ane.U., page 5)
6 October 1992: Serbian forctee intensifiedtheir shellingof
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+aclcersunleashedan artillery attack
in che t&m of Brasno. TireSerbs used incendiary shell6 to turn
the neighborhood into an iaferacl. 116., gage 14)
9 October 1992: Sefbiarrfarces resumed their offexme in arorthern
B~saia aftar camelidating their sul3stantiai earlier vrctoriee .
IU., page 32).
LO October 1992: A Serbiannmlxar shell explode8in a cmzrtyard
full of children, 3 were kill=!, 10 were wounded. Sweral of tlre
childrenhaCi limbs amputated. (ZB-, page 10)
militaryerflights, SerbianaafightetrplaneseattackedJ the BPsnianantmm
of Gradacac. At least 19 gersons were kill&. 34 were wounded.
Other Bosnian coppasin northern Bosnia near Bscko were also hit.
IZ.. page 10)
11 October 1992: Croatiansare forced to flee after the Serbs
-er the Bo8nian cm of Boaanki Brod. (X. , page 1) . 19 October 1992: Sarajevo states that Serbian shelling has
aestroyed the city's mly flour mill, causinggotentialstarvation
.for a people whose prisary food is pastaand 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 massiveshellingproject against
Sarajevo in the hopes of having that city capirulate witfieruta
struggle. Serbian8 by this date are am in occupation of at least
two-thirds of the territory of Bosnia. Serbs are receivU.g ,
logiertical support frcnaYugoslavia (Serbia and Plaxenegzm) .
page 1)
25 Octrrber 1992: Sm begin etep~ing up attacks on several
strategic man cities. (IB. ,age 12) .
29 October 1992: wnia euffers ite worstdefeat yet at Ehe
of the Serbs, ae the scrategi~~lly located city of Jajce falls to I
a Serbianoff eneive. A line of:refugees fram 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 Jajce . !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 tlrosetrappedby the Serbiansiegeof 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:ilresaluticm) . (U. , gage 8). V
6 Bov6mber 1992 : Fighciag breaks out between SerBs and Muslims
near the Sarajetro airport. i\n Arnerican relief plano is hit.
(a)
10 Plovember 1992: Boenian Serb leader Badovan Karabs;ic
partition of Bosnia along ethniclines,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 51 .
20 November 1992: French troops protecting a Bosnian relief
convoy are attack- by Serbian forces. W. , page &I. 21 November 1992: Serbs begin heavy shellingagainst the Bosnian
controlsToneikof tho key access roadao into Sarajevo.defense, as it
BO~rliz ~enf 6000 men to deferid the city. Reports ere
(Id.. page 3).
22 Egovember 1992:
in an effor, to opesranother roadito uSarajwo.ack by Se*ian forces
(U., page 8).
24 Novamber 1992:
reported. Heavy shellhg by Serbian forces in Sarajwo is
of havnik. whosedi=lationSerbis predaminstelyk MuslimheandsnCroatiao.
(U., page 3).
27 November 1992:
Herak, a Serbianauxiliarycial soL3ier pfacing the rdeath penaltyislfor
genocide. During m interview. Hem described crimes against
Boenian Muslims cammittedby Serbian forces. (U., page 1).
29 November 1992: Serfisfinally release mv relief CMV~ after
preventing it8 entrance into Bosnia for 3 days. (U.. page 14).
30 PTov~r 1992: Croatian and Serbianforces 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~~gnt pitched battles across
~osnia-Herzegovina ,ne person is killed in Sarajevo. (Id.. page
8).
2 December 1992: UN haltshumanitarianflightsto Sarajevo after
US military aircraft is hit b2i small arms fire in defiance of
supposedcease-fire. (U., page 71.
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 armoredattack 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
Sarajem airport. (U!.
7 D~Cmber 1992: UN forces arcs preventeclfrom 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 civiliancaswlties were reported. U,,
'page 19).
9 December 1992: Serbs use tmks to seize airportroadand block
any relief aia to civilians trrrpped insfCieSarsjm. 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 siegeof Sarajevo. 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 ~anwxy 1993: 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 ~anuaxy 1993: The final global human rights report su;fiiaitte8
the Bush ~inistration stated that Serbian forces 5n Boenia
and Henegavina were canducting a cangaaignof "c!meLty, brutality
and killingwuari~tea since Nazi tinre. (IL e.page 8).
24 Jaauary 1993: Jmerican intelligence reports that at leaat 13s
of the coecentration caraps established by the Serbs at the
themredoam. th(Refereacel 22maAugustes1992 and -vanprcrmiKara&ictst
mse to 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
Trebinje were termsirad by Sexbian forces. u., page 61.
7 February 1993: 4000 &- were forcedout 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.1 was aeliverecl on partitioning
Bosnia into prwinces. Bda refugees were f otced to flee f rcm
Cexska, Kameaica, and other besieged Bosnian villages above the
Drina Rivet- tm of Zvornik 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 stoppedby S~ixbian forces. U. , page 8) .
2s February 1993: Noble PeaccsPrizewinner Elie Wiesel stated
that he had been *betrayeduby the Serbsregarding some prisoners
intmi~Cl ic the concentracicc manp of mjanca. WieseP noted
that prismere othiehhe had inrehewed were later eiagl& wt anB
punish98 Qy tbe Serbiancmmar&rs of the cagaps. (u. ,age 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
enclaveof Cerska. Most; Bosnicra re~listanceended early &d the
artillery shelling. This attack folluwed the pattm of *ethic
cleansingupacticed by the rserbs, The attack began with a
viciaus ahellingbarrage, 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 resistancecrumbled 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-longBttstructicm by Gerbsof the Bosnian
enclave of Csreka was recounted. Tho attack by the Serbs appeared
to be in responseto the rUrrericarelief air-ap. Cerska wae the
fitsr city to receive lmerica.n airdropped food an8 supplies.
(ZB., page 31.
13 mrch 1993: Sexbizm sbells b;ilI& 20 muslim wor~en and children
in Vitez, Bosnia, when these peuple crowdsa and two British
armored personae1 carriers in :rhehopes of gaining eafe pawe
aurof zhe city. (Id., page 4).
14 mrcb 1993: Serbian edldier BorislavBerak cezzfes%edto crimes
committed in "ethnic cleansing*qmxations. nrneaAVojislav
Seselj a@ Miro Vukcnricas poiiticisnn axxi commanders wha *playd
a majorroler' in the -ti-. (Id. ,age 10).
ir mrch 1993: Bosaiatl forces l~egaaan airlift of the critically
ill f rani besiegedenclaves in 9rebreaica to hospitals in Tuzia,
Bosnia- General Morillon, co~lre;ux3eof the Um ailitary forces in
mnia, aaonaaaed a halt of the Eierbianoffensivein Srerenica. A
Htorlcl Heath Organization pky8:Lcian reported that f ightiaghad Uied be stoedisease, pbmger,inant1 exposure.n(Ib-,tpage0 10).ons had
15 arch 1993: Serbian forces mcked by tanks overran the Bosnian
city of Kmjwic Polje, pu~hing Muslimciviliansinto the Bosnian
city of SrebrenLca. Thi8 acccmt was confi-d by a UN British
major. In addition, thore were reportsof Serbianahelling 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 Sea killedeweral civilians. (Id., pagg 10) .
19 March 1993: Sweal persons BieU azzdseveral 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 launchedanother intense artillery -
barrage againsicSara3wo. (Ld).
21 March 1993: Serbian plarles were seen basrabingtwo Muslim
vf llages (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 u11lessotherwise mxed.
Araryiattacked Musliman and Cruz~tian forces baineBosanski Brod andav
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 irregulareolaiers an8 the Yugoslavam
continuedtheir attack against the Boanian tams of Bosanski Brod
an8 Kupree . eresiemt Alija :tzetbegovi was f orcecito aaaounce
the nmbilizatian of National Guard anU policereserveunite - w-,
Page 3)
7 April 1992 : Sarejevo was a!:tacked heavy automatic weapons
fire and grenade c~cplorsions a::er Bosnian President Izetbegovic refueed to rescind a33 order to mobilize ~ationalGuard forces.
(Id., page 3)
8 April 1992: Z?leSerbian-led Yugoslav ArrrTordered air strikes
on the predclrninaatly Croat tawia of Siraki Brijeg and Citluk in
Bosnia and Heczege. U., page 10)
9 April 1992: Serb unitsappmaching 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 CPtlukfor the second straight Bay. (Lb., page
9
10 Pgril 1992: As Yugoslav Rrmy tanks etood idly by, a Serb-
backedguerilla force captured .the 8osnlan taon of Zvornik. (=.,
12 April 1992: The Yugoelav .Rzmycarved at new territoryin
Bosnia and Ban@govina. The 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 frm 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:inisterof Bosnia and Herzegovina
rmmphaeizef3 that Serbian irregular forces were being bnnqht linzo
Bosnia by the Yugoslavian Peq.lees m. Silajdzic alsonoted
later in the intervieno that the Serba were equipped by the
YugoslavamQ.
15 April 1992: Serbian and Yugoslav amy forces bm~e an 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 ehellsas an mican official arrived with witarian
aid for Boania. U., page 1)
20 April 1992: Yugoslav army kmrbardea Flostar. Shellsfell far
at leaat three hoursin heatril:populated neigfiborhoocls anB Bet
fire to 6-1 apztnmnts. (U., page 31
21 April 1992: At a White House Backpraund Briefing, a Semior
Aclministratian Official noted that the Yugoslaviannational annywas causing problems in Bosnia which made establishing a
relationship with Belgraae difficult . f- TranscriptID
821477)
22 April 1992: Yugoslav axmy jet fightersattacked 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
Nationalthe ArmyuctasofMoutragec~u8M and blamed amd tthemugoforvfthe
deteriorating situaticm fa Bosnia. gagleburger noted that the
YugoslavianNational Army and the Serbian irregularswere 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 forcrrs and units of the Yugoslav Arrqy
featuredartillery, 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 guerrillasand Yugos1a.v Anrry forces:Bhelled the clwas
beganm soonrafterit1 p.m.illeryand machine gun fire. The attack
and cazitinued into the night. fld., page
1)
6 May 1992: Yugoslav Army jete rocketed eweral targets in
Sarajevo, and Serbian guerrillil farces continuedattacks 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 Croats, but was instead one of
aggression by Yugoslavia (Serbia and Montenegro) againat Bosnia-
Herzegovina. (teai-ala Trenscript 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 respansibilityfor 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 aggressionthat's waged by
Serbia an8 the Serbian president, Milosevic , against an
in&pn&nt republic . (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 RirrhilrdBa~czher stated that the ga~arment of
Belgrade,rather than withdrawing the Yugoslavanqy turned it over
to the extremist Boeaian Serb leaders. liewent 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 TranscriptfD: 840231).
9 June 1992: Bosniangavermnent releasestranscript of recording
of Serbian military leaders,several of whan were officers af the
Yugoslav Axmy, in which the cmfka.ndhg general orderedthat all of
the Bosnian residentialdistricts should be shelled. Pis exact
camand was *Burn it all." (-., page 10)
11 Jtxne 1992: Ralph Sohnsan, IkrgutySecretary of State, during an
SenazteSubcamittee 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 remainedunder the camand of General Vladic.
Now he, as far as we can see, is ergpointecand paid Dy Belgrade.
So, whether or not Belgra.de has tactical control war the
individual units, as far as we're concernedis really not
particularlyrelevant. The isrue is that Belgxade does have, in
our view, enough influence that it can have a materialeffect on
the fighting being done by these irregulars ;antthat Belgrade
inemotion.e..held accountablefor. the fact that it set this prOCeS6
we think that Mx. Milosevic does control the Yugoslav
-...we believe the evidenceia v=j, very persuasiv .."
~&g,hWx Transcript SD: 840866) . 23 June 1992: Thomas Niles, Assistant Secretary of State,
testifyingat a House Europe and Middle =st Subcamnittee Hearing,
in reegornee toa question from Representative Solan, statedm
*I wmld eay the contimirig shellingof the city of Sarajwo
by the Serbian forces.. .are certainly subject to a very heavy
influmce, if not cantrol, frcm Belgrade.
Nileu also noted tbat he believed the President of Yug06la~ia
(Serbia and Ibantenegro), Slobocbn Milosevic, was Wdeegly inuolved
ia w?mt*e goingan in Bosnia-Herz.2egovina"
(Wi-elate TranscriptID: 841690) .
26 June 1992: In 8 meeting with Britain'sLord Carrington,
Serbian Pre~ident SloboBaa Xilosevic refuesd to recognine the
independentRepublic of Bosnia and Herzegavina saying that its
status must be determined by the leaders of federalYugaelavia.
#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 whichhad
hen trern~ported into Bosnia frtmnSerbia 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 nightmareacaueeU by the Serbian
invasionof Bosnia. (TbauSfnn gg 1. %ueh Umee
Ylrgoelavian to End Ethic Bloodr&e~¶.~)
4 August 1992: 'IPlooaaeNilele, 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 governmentof Serbiaa.
Later, Niles mentioned that tihe Serbian forces in Bosnia were
"organized. . ccmhctsd by the :#we-t in Belgrade, the Serbian
Hercegovinaw.tta(LWfg ~1- essTranscriptnID:d 8601661o.le in mnia-
6 P;ugust1992: A list of 105 Serbian concentration cawps was made
prrblic.
were in Serbia. (-em were in Bopage 1)d Herzegovina, 1: of them 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 armrn in
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 WilliamTaylor,
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 militaryforces and Serbian mixitia furceo.. .all
of whom are coprwitting these atrocities and killing a lot of
peoplein wnia...Thereie one proposition which no one argues anb
that is that Milaievic and the high catman8 bo have conrro3 war
the YugoslavianNational 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
controlsthese 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 areused 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
requeststhe Court to consider this adaitianal evidence during the
Indication ofesPro\risionalMeasuresof suDrotection.ts request for an Annex2 toGEN93/16
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:
Ihave the honor to refer to the ApplicationInstituting
Proceedings that was submittedto the Court f;rthe Republicof
Bosniaand Iierzegwlna an 20 Paarch1993 against Yugoslavia (Serbia
and Montenegro)rm +he basisof Zmicle IX of the Genocide
Convention of 9DecaaUer 1948 and the acccnnpaqdng Requestfor the
Indicaticm of Pruvisio~l Measuresof 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 ...rightto revise, supplement or r*rclathis
Application .." Since the Applicatiun wae filed,aaditional
evidence has cane to the attentim of the Agent for Bowria an8
~erzeghna that he vcruldlike t3 draw to the atteaion of she
Court, aaB hereby mhit in suppxt of our Applicationad Repuest
for the Indication of Prwiraioaal Measuresof Protection. This
additional bdence is as follawe below.
I. 8TATPYSStT OF FACTSI. Intormation Coordinator on War Crimesin Former Yugoslavia, a
Canadian research group, compiled statements fram a graup of
BosnianMuslim who survived cancentratian camps rua by various
Sezbianmilitary and paramilitary forces in Bosnia-Benegovina.
2. In one account, a mslim wcxmn ickncified at3SN 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~troying all
of our pw, for taking hueband and w father-in-
law to a concentration camp and for torturing them. I
accuse them for harassingand termrizing qy mother and
my sister, threatening thsrcnl with murder ... and
themnthat allmthatn they aren doing lto myimother tand 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~ocent friends,
cousins, neighbors f and1 acquaintanceskilled 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, starvationand terror that
they wde my [husbarrd] and my fathes-in- law endure,
together with hun8red.s and thousands of other innocent
people ....
describednanhattacktaonmher,villagelbynSerbianidforcesed as AD 010,
IChetnicks )
a. On the 25 of my the! Chetnicks attame8 our village, u
which was a Muslim village, and by the 31 of May all the
men froan thevillage braretaken to a cancentratio n.
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 childrenand burnt than alive. They took the yaaxq
men fram 20-30 years of age Iandlbrought them to a
8chol to torture than .. ..One of my uncles was taken.
four ofihis nephews,g tzogetberwith 170 fricauQn,hcclueina,
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~ed a genocide of 180 Muslims.
He's been hiding for two months an8 finally they found
him me day and since then we havenot heardfrm him.
b. Ttrey have beea torturing us all in BiLferent manners.
Rrery village had a C!hetnick1s headquarters where they
spent most of the the. They would take our faod,our
gold and jewelry. [andl money. They took [my
neighbor's] son away and they threatenjed] to kill him
unlessshe firings sane money. She and her hu&and were
collecting maaey thrcmgh the village, ... and finally
wbea they brought thtamoney the Chetnickslet 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 finallykillinghim only at
night. In that nnau, name2 they killecl anotherof 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& helpleasperson. Wben we got
the permissionto 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 figheing on the Bihac front. They were
threatening her with killing her aad her three children
if her husnand [did] :not comeback and give himself up.
them forhealmost twor m~nths.dsTheyy sentfus mesaagesarfrom
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.
(Inomitim 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 '(Youf ---want a state," @@Yo uant 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
=dhnqgsterW Lqterieta) essiand. a Serb soldier saidw*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 tornapart.
Prom Prijedor SUP we were loaded into a bus, 150 of us
cramrmed into the last; thirdof 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~srous Serb -
held posts or villa!aes. At every such point, Serb
villagerewould 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
concentratio nawp Omrfika at around 11 p.m. that night.
Hhen I was ieavingthe bus 1 saw that the bus was full
of blood and many &s:lime ~tayed on the floor, most of
thm dEtad.
c. f was in Omarska extermination cw from 30 May 1992
luntil] 6 Aug. 1992. I was beaten there daily for 3 to
4 hours. Going to the toilet meant being practically
therad was Sarlotoof na.teria1eitan. theamine ilyingiaround8
-wocxlenbeams, 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, netaibars, kicking with r;hebte.
testicles were swollen,the size of large oranges. sl,
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.mnother, 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 torturerswould
bat us, Step or jump on us until they tired out. Tbey
were Bel-rately aiming their beat-s at our testicles
Saying wyou*ll never 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
(someCroatsas well). There was a building we calleda
"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 lllaaagedto sneak back into the barracks
later.
One day I was in the detailloading coqmes into a 7-tan
g. 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~ey would not apare any part of the
body, breaking all the banes so that the beatenMuslims
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 eachotherae 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 bestialitiesespeciallyamong
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 besideme 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
injuringivand tora,large hextenttkilling the unfortunates. I would be lying down for 4-5 hours, being msrcilesaly
beaten fryfive 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 changIedl
caapletely nryfeatures). (I learned later that 88232s
8ear-d to f iul me abusing my family, my fsrherand my
wife in the gcocesel .
k. CTPlarskextermination canrphad warscragrieonere 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 farcedto nape the girl[e]
.... They were raped constantly,na-stop every day.
They older wanar, Croats, 60-55 years of age. Ckle
nautedDivia, was rapeci by 12 men. There xere rany young
girls, arcxmd 16 yeare that werebeing rapeddaily ...,
Serbs mid torture UEI by extingui~hing their cigarettes
on our bodies. Serbs wouldthwcringuishsetheir cigarettes
monithe MwlILIRwcllmenwnaked bodies, mxtly air breaste
and vaginas. Serbs would also shwe bottlee (mstly
half-liter beer bott3.es) up tne Muslim girls' vaginas
.... Serbs would stick a bottle inside Muslimwoaren9s
vaginaand thea break them insidethem.
rn. In Onnrska there was a shop where chsp trucks were being
repaired - we callecl it tfie*Red Pmse.* Serb torturer8
killed many prisonersin 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 flmr was full of human boa pieces, pieces of the
pieces weregescattered lsverywhere.ei* oa the road, sku21
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 killme in a terribly painful
manner.
o. I witnessed Serb guarcila shovinga fire l#kant bee into
a mn *s sphincter (it1ms 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 constantlyrobbingMuslimprisoners
of their belongings. Many of us prisoners had thoueaak
of German Marks with us. Serbs would sell us fooU at
sxorbitantprices. 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
aftere'a fperiod ofo tarv vat ion,ringsf wouldthecamelaoff
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 fram 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 ~urviving eyewitnesses, in
Prijedoriteelf Serboslaughtered 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 rationper prisionerwith 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 themine,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
caarpOmarska, as Red r3roasmembers 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 )Emtook us 12 hours. The ha would often st=, Serb civilians,soldiers, Chetniks 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?ldsand &rank tbat.
u. In Manjaca,jber-t (RedCrescent) registered us. The
Red Cross took wer food deliveries. However wst of
sugpoeed wto treceiveawasome fishSefor pbreakfastWe w(2-3
pieces) , trut Serbs were giving us me for tvropaple,
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, Serbswould wheel away most of the
fnits and vegetable^. ms1i.m prisonerevould be checked
by Red Crossmedical staff 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 rigtitinto 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 foreets, 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~cled a Serb mjor in =change. In w
wsin fandlchildrenldi...cccm iand abase thm.erbsTheydbrake
from the kitchenthmf Serbs werenbeatingrthemndseverely.ed
(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.reportedthe 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 standin a row. They threatened to
shoot us if they fouxldweapons 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
becausewe were Muslims ....
I and my old mother together with our neighborsjoined
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 warnenhad to bury their husband,
or son, or father with theirrn 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
theyeweree standinge011aguardioutside,uinging, drinking,nd
and listening to the Tchernik songs and wen shooting
the bees.
c. After a few Bays 9 trailers and severalbuses cane ....
On [the way to] Vlasic, 160 men, old and young, were
taken froantbat firsl: corntoythat had left before mine,
and killed. That informationfrightened 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 rqyhead
and my aunt's child in qy am. They set apart about
thircy girls. They ~separatd an old mman fram her two
Baug'tzterB;she proteftted, criecl,went dooonon her knees
and begged, but there?was no mercy, she got a bullet in
deathation andteven:Lrodaywiteistnotn known.aIn ua 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; .rsarrold wcaneowere carried in blanketsor 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 everywherewhere the
Tschetnik's foot was set. And the only reason for that
all is that we are b1slim.
(Inf oraraion 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 forceskept announcingwer
the radio that pecrplemust gather at the practice field.
Muslhra and Croats started leavingtheir ha;8s8 and Serb
forcesforced them to march to the practice field under
mortar fire. 1 saw tms of peaglebeing wounded a8 well
as a nunber of civilians being killed .... Frcan there1
obeemed Serbian Armed Forces [the official forces of
marked beesmunic(withtwhite osheets),burning1 lthemngto the w
ground aftexwards, 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 civilianswere hitting me with bate, rifle butts,
kicking me with bwt~ . One Serb, a neighbor that went
to the a- school as I, attemptedto 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 azyfather, who was w
also detained there,could not recognize me.
c. Dfd,ng onee tablespoon per areal, gtwice aaaebay,nsametimesi
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 constantlybeaten
.-.. X lost there, in one mth, fifteenkg.
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-tontruck,
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~ghteen Muslims 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.
appallingly unsanita.~ith. fSome verythpricklytiand 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-gunpositions. Serbs
crraanedahmt 700 people into one stable. We could dy
~leep lying 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
sorrnrealized they were carting fran peqgle under extreme
tonure. Serb camp guarc% rationed wurwater, 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 waterwithaut any egices, selh
wsametimes.l, We had toas eatthin theiccrouching aposition,
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~: at a time shautiag at me at the
same time and bitt:ing me. The minterragation" was
invariably accmpanie:d with physicalmistreatment,with
eevere beatings. Serb guaras, 8oldier6, civilians,
interrogators, moat o:Ethem drunk or drugged mt of the
time, were incessa.ntly humiliating ue verbally,
swearing: "F--- your mother," '@F---your Turkishmother
Izetbrgwic,," *tihedemocraticpresident - aofuthen IRlepublic
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 !LOsit in the sun holding our heads
dm - we had to hold our heads clownall 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-eand 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 sonswould not knew [of
each other although t:heymay have actuallybeen [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 casrlprisoners to hold him. Serbs
theyedcalled a doctor,3.whohdeclared him dead frun a burst
vein 5s the brain.
Often Serb civilianswere let into the cacentration
csllqpincluding wacaenand children. 'Pbeywould wit on
us, stoneus, beat us with ming tbqy ccsuld lay their w
hands on. Saw would wen cut f ingera ofIf 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 workedas luaber-jacks
carrying wood fram the forests on our backe - Serbs
forced the prisoners:into the mods in their T-shirtsin
winter in bitterly zc)ld weather. litbileworking in the
fields, I eaw Plus1i.mgrazing 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
byaraegroupenof BosnianheI@uelim refugeesreinnCanada, vict-e accofnthe
mass rapes, 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:rislavWe-, an inpri-etl Serbian
soldier de8cribed BEU-S, rapl3s,and othertortures 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 firat account given by a
perpetrator to outeiders of how the Serbian nationalist forces
have carried our their plan of 'lethnfccleansinga.
9. With other Serbian soldiers, Herak emptied a 30-bullet
~llagazineat a family he had found in the baoemment of a haare at
Ahatovici, a llusliipvillage. 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 leavenobotty alive. (U. 1.
we were told that Ahatwici must be a cleansed Serbian
territory, tbat it:WELGa strategic place betwean Ilidza
and Rajlovac, and tiratall the Huslinrs there nrust be
killed. Me were tolcithat 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 simplydid 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 anotherincident that occurredin 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
stillalive when they were tbun intothe fumace. (U. ).
13. Herak ale0 describeUseeing the bodies of 60 iaduslimmen 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 ..
4. Regardingthe use of rape ae a weapan of war, Hexak m@aineQ
that he and his cmpanione were encouragedto go to a mtel by
Serbian ca~aranders who told them that taping melh wornen was
"good for raising the fighter'sraoralew . 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
woman inlheremthirtiesapgavecha statementorregardingantheolincident.
he eoldiers toak her to a bciuse. strippedher 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
wigarettes by the Serbian ooldiers . (Amnesty International,n
Jaouary 21, L993, page 6) .
16. A twenty-seven year old Muslim wmm intehewed by AmneBty
International described her abductionby Serbian soldiers, In
thetetomlyofheKotor. Inside,unitheomofficerbhit,obitprandtrqped her,n
keepingan autamntic weapcm clc~eeat hand thraughoilt. (U., page
7).
17. On June 17, appraxlmately1,000 lranenand children were taken
away by Serbian forces frm their hme village of BrezOvo Polje by
bus. Travellingwithoutfood or water, they arrived in the town
of Caparde several days later. Xn the courseof the journey same
#omen and girls were taken by Serbian soldiersfram 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
paramilitariesfrom the grolapcontrolled by Zeljko Razllatovic
Iconmanly known as Arkan) , an0 were taken by bus to the battle-
lines which they then bad to c:rosson foot. The younger women
were held for mral nightsin a furniture warehouse in the tawn.
Serbian soldiere selectedand 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.
town of Tuzla following ttheir rarleaseoreportedlyssaid-thatroima~~of
the girls were prepant. (;Sd1.
19. In an interview with a Zagreb doctor a 17 year old Muslim
girl fran the village of Kafaloscvici near Teslicstated tbac Serbs
in lfaZA (YugoslavPeople's AZYSQ--
uniforms took her and other WCXIW f#l 'err
to an unkncrmlocation, apparenrly sane sort of workersq huts,in
wOOa8 near the ta. She vae :held there for three mths until
relea~ed with twelve other wwen by a local Serb. henty-four
vmmen were held in her hut, al.chcxughshe 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 Serbianchildw. w. ).
20. In a honpiral in Zagreb, seventeen year old Marian-
rapediasdpssnycasftenmtimes a dayebyntSerbian soldiersmafter .a& wimd 24 other wanen were takenfrom their Bosaian village, Tesanj , to a
camg in a nearby forest. During the rapes, a Serbian guard told
.her,wNow ym dl1 have Serbianbabies for the rest of your llf e.a
(Squitieri. Tam, "Weapons in Bosnia: Rape, degradation, * gQB
w, August 10, 1992, page 1).
21. ~ccoding ta the mesty International Report. *A OOOUOd to
the soul, a betveen 50 and 70 civilians,r~ainly Suslims from
Boeaxlski Petrmmc, and 22 soldiers captured by Serbian forces
after the fall of mien VaM were held in barracks at Xozile.
(~mnesty Inteznational Report, mBosnia-Herzcrgovia a A vound to
the soul, Jamarqr, 1993, page 1.).
a. prisoners at lsozile were bela in six roam, each about
three four meters in floorarea 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
visitedand left same medicine for those sufferiw fram
diarrhea.
#hat prisonersmost feared were the regular beatings
which usually occurred at night, often after the
most terrible apthing was waitfngdriforngyour name to behe
called out,' recalled. one former primmer. @The frunt
&ur ha8 an 018 lock with a nail. llhmwer we heard the
terrible sound of tfiat lock we ka&o soumane wcrulclbe
called out and we feared it mid be us. @ The sielected
griscmer was usually taken to another builckzg abaut 15
meters away from whit=fthe other grisrmers could hear
screams of pain. Ozreor more guards would kick the
prisoner, punch him, and beat him with rooden
trundhacme. The victjm wa6 returned to the cyzll usually
aftera period of between thirty minutes anb two hours,
usually exteneively bruised. #hile 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 biasma& to beat another prisoner
with a koodePI club. Stme vict%mewere repcsrtecUy placed fromoone hourntonsweral adays. being beaten for anything
c. One 23 year olc3 Muslim decorator, was arrested on 30
June 1992 and taken ro Kozile afterbeing held far two
days at the police station in meanski Petrovac. On one
occasionat about midnight, another Muslim prisoner in
the aame roannantec¶ 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 forestwere crying. gK was
then made to crawl back into the roan on all fours,
barking like a dog .... His drenched clmhes shrrwoQthat
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 aboutfourse....minutes he was
again made to crawl brickan all
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
exceptionof his head. After three days he could walk
with the assistance of his fellow detainees, but could
not walk unaided for at least another tpooBays.
f . One prisoner, ZR, agc!d about 35, was beaten about the
head. Anocherprisanc!r who saw tuo days later said,
[ZRI looked as if he had been stungall 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 froanRozileto mica, also described
as barracks for workers, about 15 kil~eters frm
Drinic. On 21 August .the remaining civilians in Xozile
were released. xamenicacamp repomedly held about 70
Serbs.eesThe mSerbs wereimreportedlyso soldiersoawho 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 cleaningthe gzmunck. However, it seems tb.t after the civilianpopulation of
Bosanski Petrovac negotiated their departure on 24
September, the detaineesin Kaxnenica startedto be ill-
treated. One 23-year old male Wuelixnwae tortured in
late September three days after a visit by the
International Committee of the Red Cross (ZCRC). An
ointerrogationandargas'ked him whatarhe had told the LCRC
delegation. He ansvoc~redthat he had only handed wer a
messagefor a relative,because his interview had then
been cut shortas he ha8 been calledto 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 ~ix Bezbian prim6 W then
beat him with trunchectne for severalmimxtes 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
BosanskiPetrovachad beenevacuated tryforce?'
i. He was beaten about the shoulders, arms, back. legs and
hisintormentorsiwielded samething which, hethdescribed as
being like a baseballbat or a riot-coatrol baton - in
his om words: *oJhe~it hit yau itwas likean electric
shock going through the body.' The following is his
description of the pain and being returned to the
eleeping area: 'At firet f felt all the blows [during
the beating], but when I entered the sleeping area I
jurrtwanted 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 am lookd as if
tbay had been inflated with a prnqpforcar 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 constitutegenocide.
The Serbians targeted meuber~ of a distinct group, i.e. Bosnian
Muslims,killed, caused aeriuuu bodilyand 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 Froanprosecution. There is no
excuse for tbeeeatrocities .3 Serbians are guilty of gmide.
requestse thatbltheoCartBoeconsiderthisadditiorrsl evidenceduringfully
the courme of these proceedinge and in suppoa of ite Rspuest for
an InBicaticm of Prwieional Metrsureeof Protectloo.
Reepectu flly suIt;mitteA,
7 /
w: Y ///;;-LI
Fraacis A. Boyle,
Professor of fnternati-l & and
Agent for the Republic of Boenia and
Herzegovina
ERHRLTEIU0t1C.I. J.
GEN 93/16
Le 22 mars 1993
h.5+c~a~k J3-3-q3
Rowelle affaire :Bosnie-Herzb~ovin c. Youposlavie
(Serbieet Montk6nro)
Dombes su~~lbentaires basbessur desfaitsdi~osbes au Greffe
par la Bosnie-Herzinovine
Le Greffiera l'honneurd'informerMM. les Membres de laCour quece
matin (22mars 1993),l'agentde la Bosnie-Herzdgovin aeddposiau Greffe
les textesoriginauxanglaisde deux documents, intitulistousdeux
"Elimentssupplkmentaire s~l'appuide la requ6teintroductived'instance
contrela Yougoslavie (Serbieet Montkndgro)sur la basede la convention
de 1948sur le gknocideet i l'appuide sa demandeen indicationde
mesures conservatoird es protection".
/ Le premierde ces documents(annexe1) contientun tableau
chronologique de"Faitspricisse rapportant au comportement de
l'ex-Yougoslavie" ,t le second (annexe) prgsentedes "Faitsprdcis
/' lids 1 des actes de gdnocide"comprenantdes citationsde dbclarations
kt4tprCvude fairefigurer ces documents dansla requGteou dans lait
demandeen indicationde mesures conservatoiresmais que celan'avaitpu
Stre fait faute detemps.
Des copies sontcornmuniqu6esla Partieadverse.
La traductionfran~aisede ces deux documents sefraurnieaux
membres dela Cour aussitbqtue possible. Annex 1to GEN93/16
1
80PRtICMSSTABY SOBldISBIOl ZlP SVOPOST OF
TH. APPtrCAPZObl OF TIIS RSOtlgLTC OF SOSIIA ASD HtRt.BOVXBTA
XlQSTITUTIIIIGL%QA&PROCS1EDZfl08 ABALXST YU00StAttIA (SERBIA
AWD ILO~WIUEt61 OH PEB BAS18 OF TEE 1948 0mCI08
COSVS3U9IO~ AlOP I10 THlC SOPPORT OF
ITS mu-4 POR AH IIlbXCILTrOIOOP PBOVISSOIUL PILASUSS8 OF
PllOftC'PXOM.
XnternaticmalExCourtnof,Justice, the undexsigne8being odulye
authorized the mlic of Bosniaand Herzegovina:
I have te hanorto refer zo the PgplicatiunZnstituting
Proceedings that was guf;anittedt;othe Courtby the Republicof
Bosniaand Henegovina cm 20 Paarch 1993 against Yugoslavia (Serbia
an8 Montenegro) on the basis of Article ZX of the Genocide
Conventionof 9 December 1948 and the a- Request for the
Indication of Provi8ianal Measuresof Protection that was a180
mbnhtted to the Cmrt on tbat date. In SectionXV of that
Applicatim i4'IV,Juclgenent Rq~ested~) Bosnia and Wenegavina
reeervd its "...rightto revista, supplementor 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 drawto the attention of the
Caurt;and hereby eubpnitin supptxt of uur Applicatian and Reqaest
for Provisiona l easures of Protection.Thfs aaaitional wiBence
is as f011- below.
I. STATE= OF FACTS 1. The following events are categorizedchronologically.
All cites refer to the same day edition of the W--
unless otharwisenoted.
2 mrch 1992: Bosnia and ~energatiaa held a referendm apprwing
i-ece and sovereignty MEkrch 1. (&Ww -, pgge 2)
3 March 1992: RebelSerbian forces begin attacks an the Relic
of Bosnia and Berzegwina, d:~sruptfng travel into and out of
Bosnia. (Id,. page 9 1
28 aaarch 1992: Leaders of Bomia an6 aerzegaviaa appealed to the I
United Nations to deploy peacek.eaping forces in the Republic with
the hopes of stopping or slcx&lgSrerbianattacks. (U., page 41
7 April 1992: The European Cmmunity recognized the independence
of Bosniaand Herzegovina on April 6. Serbian forces bombarded
the historic Pluslimquarter of Sarajevo. (U., page 31
8 April 1992: The United States recognized the indepmdence of
Bosnia-Herzegovino anApril 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 EuropeanCumnmity and the United States renrwed
their tmbaseatbrs fram Belgrade. (U., page 10
17 May 1992: Peacekeeping Forces, originally placed to
supervice a cease-fire between Serbia anB Croatia,withdraw fmm
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~8 Montenegro Ar,my barracks. I=. , page 14)
22 my 1992: 5,000 hostagesheld by Serbianforces 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)
Serbianforces unleashed a new attack on Sarajevo,
the most9severe 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 Bosniancapital began. (Id., Page 16)
11 June 1992: A United Nations convoy was attacked on the
outskirts of Sarajwo by Serbim guerrillaforces. 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 airliftsfor 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 me 1992 : Sarajevo airport truce is shattered when' ~erbian
force8 used tankaand artillexy to attack civilian buildingsin 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.lSarajaro 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-keepingtroops. (m. ,page 1)
12 July 1992: Serbian forces attack Baanian city of Gozarde, a
cfty wlth a gapulatiunof 50,OOC persans. (S., page 1)
14 July 1992: Serbian natianalkst Eorces continuedtheirsiege on
Saraj enroby -tin9 four power -transmission line8 that eer~ga
the city, knocking out electricity to the 400,000 persons that
with runninghewater. a(Id.,lpage t1)epunps that prcrvide the reeiaeats
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 tctflee. Refugees describedterror
tactics ant3 of being forced tc~ sign away their property. (U. ,
Page 4)
3 August 1992 : A fxls carrying children frcan ~osnia to ~8f ety in
Germany wae attacked by Serbian artillery fire. A 14 -month-old
bcryarid a 3-year-oldgkrl were killed. ILB., page 1)
4 August 1992: Initial reports begh to mrface about the Serbian
concentra on ems. Survivors give detailed and consist at
accounts of torrule, rape and killings of Bosnianprisoners. (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
~arajk cemetery. I=-. page 11
6 August 1992: Serbian forces pound Sarajevo witb a massive
attillery barrage into heavilypopulated civiliandirstriets. Nmy
lndepadent an8 consiertent re;mrts frm, survivorsof Serbian
concentra tm camps describe f~orrif ic treatment of prieooers ;
ccmqpariaons to @azica.t;yle death 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~ritiah video 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 tthe Serbian RepubLic of Bosnia- Herzegovina) from
territory seized frcrmBosnia. (International recognition doesnot
follow). (U., page I).
22 August 1992: Radm Kaadzic, leaderof the Serbian forces in
annykabat3laeieedby force, San6 a.llaw reliefmpcooooysrnfreeapaccesshto
Sarajevo and other encircled t;awns. (Later, Karadzic wmld be
&OWXI to have failedto meet these praniees). (Ld.. page 3)
forcesgusshelledthe cantering iof thearcity and hitnsithe Holiday Inn.an
The intensity of the attack forc& suspension of relief flights.
(U., page 81
26 August 1992: As peace talu convenedin LwBan, Serbian forces
cantimed pounding Sarajevo witinartillery 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 ~adoMn Fadzic 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 woundeUpeople in a %our-hourperiod. 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?surdsof their Serbian captors. 'a. , page 1)
30 August 1992: Bosnian Serb leader Radovan Karadzic annmces
the liftingof the siege of the Bosnian town of Guracbe, but the
Bosnian government stated the fighting there continued. (IL d.
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~teznber 1992: A grenade untsthrawn into a cemetety during a
Baenian 80lCUer'~funeral, killing one person and woundingthree.
(U., page 31
A UN plane ccirryingreliefsuppliesto Sarajevo
4 September 1992 :
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 siegeof
Garadze. Serbian militias untlferthe camand of Dusk0 Kornjaca
began the assault which, by Kornjaca'sawn estimation, killed
50,000 men. (U., page 1).
9 September 1992: Boszim forces azrempt to breakout of the
Serbian stranglehold on Sarajevo. (Thisattack would fail to
-break the eiege). (Id., page lo).
1
11 September 1992: A regom fram 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
continuedheavy 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 iznew 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 exrvcryW.s
vance . Also confinned is a new wave of ethnic cleansing by the
Serbians in the tcrwnof Banja Lika . (U. ,page 2)
26 September 1992: United Statea officialsreport that a8 asany as
3,000 Muslim m, wanen and children were killed in May anc2June
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 "wfllful 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, forci;~le expulsipn 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 civilianswere struck by
sniper fire, 129 of them died. Sarajevo remained without
electricity and running water. (U., page 121
pereons are wlaownm to haveian diednuasntadereeult of thet 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 air Hise to enil"ethnicclrurrrirzg. (Id., Page 1)
3 October 1992: M least lSO Maslim women and teen-agegirlswee
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 shellingof
Saraj wo again, attacking seve:--a3 hig-rise apartment buildimgs .
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: Serbianattaclrers unleashedan artillery attack
in the town of Erasno. The Se:-s used incendiary shells to turn
the neighborhod into an inf enw. Ifb., page 14 1
9 Octaber f992: Sefbian forces resumed their offense in Northern
B~sz~& afcer 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 hrrdiimb azap~~cateB. (Zd.,page LO)
11 October 1992: Less t- 24 t~cws after the UN imposed a ban on
military flightg, Serbian fightclr p-es attacked the Bou wua
of Gradacac. At least 19 personswere killed, 34 were PIMuaded.
Other Bosnian coreas in northern Bosnia near Bscko were also hit.
(A¶..page 10)
ccmquerobthe Bosnian Ctmatiof Boaanki BroB. to flee after the Serbs
(LB . page 1). 19 October 1992: Sarajevo states causing potentialhestarvations
aestroyedthe city's only flour mill,
for a peoplewhose primary food is pastaand bread.
(Id.. page s).
20 October 1992: 2500 Bosnian Muslims were expelled frm their
me by See near ProtorVans, (U. , page 10).
22 October 1992: Serbs begin a massive shellingproject against
Sarajevo in the hopes of having that city capitulate without a
struggle. Serbians by this date arenow in occupation of at least
two-thirds of tbe territory of Bosnia. Serbs are receiving
logietical mpgmrt framYugoslavia (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.aeuff ersits worst defeat yet at the hand6 I
of the Serbs, as the 8trategic&:lly locatedcity of Jajce falls to
a Serbianoffensive. A line of'refugees frcxi the city extends 30
miles. {Ib., page 3).
1 November 1992: Thwsands of exhaustedsolbers and civilian8
arrive in Travnik, in Bosnia-Herzegovina, after the military
Befeat for the Bosnian farces iriJajce. !=. , page 14!.
35,000embffuslinrs become refugees of inheVitez.an UNptofficials now
estimate L.5 million people in. Bosnia have became hageLess, not
insluCLing those trapped by the Serbian siegeof theircammitiea.
iU., page 3).
6 Hwemhr 1992: United Nat.ion8 declares since October 22,
Serbian forces have flcmn 18-21]unauthorized flights over Bosnia
(asgmited by Semxrity Counc:il resalutimr ) (U. , page 8) . *
6 Bovember 1992: Fighting breaks out between SerZl8 ~RC¶ bh~slims
near the Sarajevo airport. An American relief plane is hit.
'a)
10 Waveanber 1992: Boenian Ser~ leader RadovanKaradzic dmaa&
partitioaof Bosniaalong ethniclines, or threatens to intensify
the fighting. (fs., pge 8).
IG November 1992 : Bosnian Fcireign Minister, Haris Silaj Clzic,
states 100,000 people, mainly Muslims, have been killed as a
result of Serbian aggression. (LB . page 5f.
20 November 1992: French troops protecting a Bosnian relief
convoy are attacked by Serbian forces. u., page 1f. 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 thecity. (U.. page 31.
22 lJoverribe1992: Travik in Bot:niaunder attack by Sez%ian forces
in an effort to openanother road to Sarajwo. (U., page 8).
24 Nwer 1992: Heavy shellirlg by Serbian forces in Sarajwo is
reported. In abUition, Serbs step up attack on the Bosnian city
of Travnik, vbose populationis predominately ~uslirn and 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 firewas scheduled to take glace.
iU., page 31.
1 December 1992: Serbs and Crcmts fou~nt pitched 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
sanj em airpa--. tu! .
7 December 1992: UtPforces are Prevented fran reaching Otes and
giving relief to civilians by Serbs, who have overaz most sf
Ores. Serbs shut dam Sarajevo'stelephone, water, aaB electziciry
w8tw. (U., page 6). 9 December 1992: Serbs begin heavy shelling of Sarajevo's
historic center. Heavy civiliancaswlties were reported. U.,
Page 19) .
9 ~ecember 1992: Serbs uee tuka to seize airport rozrd and block
any relief aiB to civilians cn~pped inside Sarajevo. Serbs fire
cxtFrench UN troope, forcing Br+& ON troops to leave the airport
garrison. (U., page 3).
27 December 1993: A Serbian tank gunner was interHe describedd
decribeff the nintordered to fireo songthe apartrsant builCUng ubre
hisw parent8 blived. Serbian aoldiers camff rnredciYilian are- were
targeted. (Id., page 4).
9 Jaauaxy 1993: mrupean Coesrnurriimestigators 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~e as 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 killLngwunri~teti since Hazl times. (fe., page 8).
24 January 1993: Aaericanintelligencereports 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,isto shr dcRan the camps). (U., page 1).
28 ~amaary 1993: Sarajevo camo under fresh Serbianbcmbx&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 forcedout of thiafxhoaros 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 ~ebrwry 1993: Serbs renewed their emf- of *ethnic
c1ezmsixzgm after a Uf? proposa.1 was delivered on partitiming
Cereka,inKamenica,esand ather- kmsiegedeeBasaime fvillageso abcrPethem
nrina Rivex town of Zvomik in eastern Boa. The Serbs
page LO). their caapaagn of heavy artillery banbarthxwimt. (XI., 17 February 1993: A UN relief convoy destined for rhe besieged
city of Cerskawas mapped by S~lxfcriaforces. (Id., page 8).
2s February 1993: Noble Peacct Prize winner Elie Wiesel stateti
that he had baen "betrayedHby the Serbs regarding same prisoners
intemiewe8 ic the concentracicm caqp of Manja~ca. Wieeel noted
that prisonere Prkrichhe had intt:rviewebwe- 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~oy it bad
&elayeel for 12 day8 to reach Gorake, and isolated Maaslimtown in
eaetern BO&. (a¶. ,age 1).
3 March 1993: Serbian force8 fmgan a dawn attack on the Bosnian
enclave of Cerska. Mast Boearitraresistance ended early amid the
artilleryshelling. This attack followed the pactem of uetbic
cleansingM practiced by the Serbs. The attack began with a
vicious shellingbarrage, 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 resistancecrumbled and EQualixn
civilians were shelled by Serbs. (U., page 1).
S March 1993: The Bosnian enclave at Cerska was defeatedby the
Serbianattack. Saw 1500 PrPu8lJ~nwere wmmt3ed. Refugees fled to
the Muslimenclaveof Srabrenica, Emmia. (s. , page 8 ).
7 Match 1993: The week-lolog dastzuctiun by Serbs of the Bosnian
enclaveof Csrska IQB recauated. The attack by ti38 Serbs appeared
first cityestonereceivehelmerica.n airdroppedr&-food and supplies.e
(XI.,page 3).
13 &arch 1993: Serbianshellskillel 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~sd to crimes
~tteU in "ethnic cleansingm aperataons. Hezak nazeedVajislav
Seaeljand 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 ~ ~ ~ x of the Um dlatary forces in
Bosnia. a halt of tn% Serbian off enaivein 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) .
Serbian forcesbacked by tanks averran the ~osnian
15 March 2993:
city of Srebrenica. This pusacccmtMuswae confinnedinby a UNe British
In addition, there were reports of GerhiaP slaelliag of the
Nluslimenclave. (Id . page 3).
19 Laarch 1993: In Cereka, ~osnia,Bosnian soldiers cornfiraDed
short-nave radio operator acc:owts that after overrunning the
village Gem killedeweral civilians. {Xi., page 10).
19 March i993: Several persons died andseveral more were wounded
in the Bosniancity of Srebrenl.ca due to Serbianshelling. (Ld.,
page 1).
19 Xarch 1993: Serbia forces reneged on an agrtanerzt ta allow a
UN relief cunvoy, aad Serbs launchedanother 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 arndevidence 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 racmP21 ulless otherwise noted.
4 April 1992: Serbim irregular soldiers backed by cbe Yuganlav
~uq attacked 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 ~olaiers and the Yugtaelav army
coatinued their attack against the Bosnian towns of Bmianski Broa
aa8 Kupres. PreeiBent Alija :tzetbegovL wcas 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~atic weapons
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-ledYugoslav AZZRYordered 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
SircrkiBrijeg and Citlukfor the second ~traight Bay. (M., page
9)
10 AgirSl 1992: As YU~OS~~V Army tanks stood ialy by, a Serb-
backedguerilla force captured .the B!osnian town of Zvornik. (=. ,
Page 54)
12 April 1992: The Yugoelav .- carved art new territory in
Bosniaand Herzegovina. The amf units invaded rbe town of Mdrica
before awn. (Id.,page 16)
14 April 1992: At the NationalPress Club, Ilr. mris Silajdzic,
Foreign Minister of Bmia and E1erzegmin.a pleaded for assistance.
Re stated:
"Fresh [Serbian] irregularforces 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.
resrPghasizeBzthat tSemianreirregularerforces wereiabeingLknxmglu ia+o
Bosnia by the Yugoslavian Peaple'6 Array. Silajdzic alsonotea
later in the interview that the Serbs were equipped by the
Yugoslav ZmQf.
15 April 1992: Serbian and Yugoelav arnryforces bm~e an EC-
brokeredpace 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
mortarahellsas arz American official arrived with humanitarian
aid for Bosnia. UB., page 1)
20 Agrii 1992: Yugoslav fm&arde8 Wostar. sheLisfell for
ett leaat three hoursin h@auil:y populated 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 fightersattacked 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 interviewon 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
deterioratingsf tuation in Bomia. Ihgleburger noted that the
YugoalavianNational Arcny and the Serbianirregularswere anoze
*activeathan the other forces in the regian. rl
30 April 1992: Across Bosnia, there was fighting in at lea~t five
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!^ gllunits of the Yugoslav Arrqy
featured artillery, mortar and rifle fire. Yugoslav Arntyunits
also continued to puur artillery, mortar and rocket fire into the
Bosnian town ofMostar . (- 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
Muslimquarter with artilleryand machinegun 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 Serbianguerrillis 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
aggrcssimeenby YugoaZaviaim(Serbia:andatMontenegro) againatd Boeniaf-
Herzegovina. (Lecri-B3a t8Cfpt 3D: 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 respaasibilftyfor 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 M3CS s
*'Todayu,stated that the UniteB States saw the ccrllflictnot 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 RfchardBaxher stated that the gov-t of
Belgrade, rather than withdrawingthe Yugoslavaqy tuTOBait uver
to the axtranist Bosaian Serb lcladere. He went on to say:
*The reality on the ground in Bosnia is that this is an
independentstate that is be in!ravaged by Serbian anaedforces,
both army ulcs anclirregulars, which were unleashed by BelgraBe.
which are inspired, equipped, and continue to be supported by
Belgrade .
t- TraPBcrigt ID: 840231).
9 June 1992: Bosnian govermRent releasestranscript of recording
of Serbian military leabers, severalof whm were officers of the
Yugoslav limy, in which the casraaanainggeneral ordered that all of
the Bosnian residentialdi~trizts should 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 Axnryhas been withdrawn, but
chey have remained behind in .some cases -- many caees -- with
equipwentand have reanainea untkr the comand of General Vladic.
Now he, as far as we can see, is ~lgpointec5 anpaid by Belgrade.
So, whether or not Belgra.de kas tactical control wer the
individual units, aa far as we're concerned is really not
particularlyrelevant. The issue is that Belgrade does have, in
our view, enough influence that it can have a materialeffect 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 reegoneeto a guestian fram RepresentativeSolan, statedn
"I would say the continuicgshellingof the city of Sarrajwo
by the Serbian forces.. .are certainly subject to a very heavy
influence, if not cantrol, frcm Belgrade. "
Niles also noted that he believed the President of Yugoslavia
ine*tia engoing~eaxiin Bosnia-Etearzegcnriaa., vas Weeply involved
(- Transcript ID: 841690) .
26 June 1992: Zn a meeting with Britain's Lord Carrington,
Serbian Pre~idernt Sloboaan Nlloaevic refused to recognine the
independeatRepublic of Bomiii and Herzegovinasaying 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 zuncsuntof heavy weaponry whichhad
hen transported into Bosniafrum Serbia for uae 'trthe Serbian
forces in Bosnia. (LePj-slate TFranscriptID: 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
invasionof Bosnia. (a E t ~ m gg 1. a~~h urges
Yugoslav- to &ad EthnicBloodrhe~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 governmentof Serbiaw.
Later, Niles mentioned that tihe Serbian forcesin Bosnia were
uorganized.. .cop~ctsd by 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~tzatian camps 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 duringABC'B This Week With David
Brinkley* Brent Scrwcrof t, the United States National Security
Mvisor, stated that the Serbs had the *monopoly on heavy amm in
the conflict, and this was due because the arms were handed wer
to them by the Yugoslav arrw. (w -R- Tran6cript ID:
8604431.
12 August 1992: . . , interview with WilliamTaylor,
for Strategictandf Inter~atioaalStudies.ity Program6 at the Center
"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
peoplein 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 --andwe'vebeen tracking for mcanths-- thereare
still seven regular divieionis in and around Bosnia. Serbia
controls thesef arceta, no quest~.oaabout it...*
11 Septenber 1992: At a State Department Daily Briefing, U.S.
Srate Department Spokeeman Richard Boucher ~tated that the
fuel,raspareparts,es andeaevaris!tynofngotheruthingsrmto 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 Corurtto consider this additional &Bence during the
Indication tofsProvisionalgMeasuresof sumotecticm.ts request for an Annex2 to GEN93/16
1
SOPPLZMBHTAIY 6VBlbISS101P X1J SUPPORT OF
THB ZLPPLICATIOP OI TSS RlCPUBtIC OF BOSPXA AglD BSRZtUOVIIOA
fX84IPtlPTUQ 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 ApplicationInstituting
Proceedings that was submittea to the Court kay theRepublicof
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~~ng Bequestfor the
Inclication of PraPisional Measuresof Protectionthat 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 tfieApplicationwas 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~rt of our Applicationand RBquest
for the Iaaication of Prcnrisic~naMeasures of Protection. This
additional mddence i~ as follows below.
I...
I. 8TATUEltT OF FACTS I. InforanationCoordinator on War Crimesin ForraerYugoslavia, a
Canadian research group, compiled statements from a group of
&ormian Muslfras who survived cancentration camps ruri by various
Serbianmilitary and paramilitary forces in Bosnia-Ifenegovina.
2. In one acccruat, a Muslim wcmm identif id as SN 011 bescribed
the atrocities cdtted against her and her fatrriland ptayed for
the guni-t: of the Serbianforces for theae genocidalacts.
a. I accuse thew for burning clown my haobe, destroying all
of our property, for t:&ing my ~U~EUIU and lpqfather-in-
accuse themcmfor haraseing&d terrorizingonuringr-&hern.andr
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 innocentfriends,
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-lawendure,
together with hun&sds and thousands of other innocent
people ....
3. In another statement, a Muslim w~man identifiedas AD 010,
bacribed an attackcm her village try Serbian forces (Chetnicks).
a. On the 25 of May the Chetnicks attacked our village, w
which was a Mua1i.m village, and by the 31 of May all the
man frarmthe village were taken to a cancentratio n .
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 childrenand burnt them alive. They took the yauag
men from 20-30 year8 of age land1brought thest to a
Hehsurvivedoraufiringansquad. OnTWO of hisclebrothersakand
four of his neghw8, t:ogetherwith 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 BiEferentmanners.
Every *illage had a Clhetnicks headquarterswhere 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 Cnetnickslet 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 finallykilling him only at
night. In that samg lzIBrmerthey killed another of my
neighbors, it kept go:;ngon; and all this for ane e-le
reason: 'Ptrwwanted t.o cleanse evexything mlim.
c. killedraher. my neighbor, a 65 year old woman, and then
totally handicappediliindhhelplessperson. well, who was a
the permission to bu:~ them, we fauna themWhmutilated.
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 tnrsbancisaway 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.heydecided 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 @
beatingus. 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 comingfrom
worst.ronA Muslim. Hamzoand (first name), rwaelyshot 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 (snajperf sta), 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; thirdof the bus. Serf3soldiers
were brkving the burs. Serb soldiers killed 2 or 3
Muslims in the bus. A ~mmal road to QDareka is through
Kozarac, but Serbs took us around througk mnnmroufi Serb -
held posts or villa!aes. At every such point, Serb
villagerewould enter the bus, Serb women, chil-, and
they wcjuld hit us wit11 wooden bars, stab us with knives,
they would throw acittat 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 ficror, most of
them dsad.
c. I wa6 in Wrska externination cam from 30 May 1992
4~hours.6 AGoing to the I toiletatmeant being practicallyto
killecl by Serb hordea (solcliers. Omarska is a mine and
there was a lot of material fran the mlne lying arPuad
-PePoda nema, cables, iron bars, meal suggarters,etc.
Serbs used all rhe~e ntatetials 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, fram one [or) two to
twenty or more. They mid gather around vans, drink or
take drugs, wearing at us : "F--- your Wu~1i.m mother, *
nF- -- your Turkish (Croatian) mother, '* tF--- you an8
your RepublicR anU so on. Serb torturers forced us to
lie Oan on the floor with our hands rm the heat3so 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~adadsduring the awere beating6 so
w could not see the tanurers. Serb tmurerc mu16
beat US, step or jump on us until they tired cnt. They
were deliberatelyaiming their beatiags at our testicles
8aying *I-* 11 never awke Muslim childrenagain. " 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 *:heirrage, which they would do by
mtilating and killing us.
e. Gvery Bay Serb torturere killed about 70 to 100 Muelims
(someCroats as well). There was a building we calleda
"White HouseM where the Serb torturers perforwd the
killings. They first killed all the doctors and
intellectuals. They wen killed a UN doctor, Sadikovic
Africa with the UN.was in Zimbabwe or somewhere else in
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 firingat 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 intoa 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 ntyanns 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, theirmouth 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.hesebestialitiesespecially 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 besideme being shot dead
for mm?ing their h6ads. Whilewe were lying down Serbs
wwld jump on us in their b~ot~, jm on UB fram the
st-6, from garage rcwfs, breaking peopleisbones, 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 -5hour6. 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 "revengeakillings. 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 abusingmy family,my father 8nU my
wife in the process) .
k. Oimrska exterrainatioc namp had wcsmn prisonersas well.
Daily Sezb eoldiers wrould take girls and bring 5-6 ~nen
per girl, Serb soldiers, prisoners to rape them. w
SametimesI was dun~g the 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 12men. There were many yvunc~
girls, around LO yeare that were being zapec3daily ....
seibswouldtorture UEIby extinguir~hing their 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
vaginaSeand then breakicthem imidee them.de Muslim #owen's
m. In Qnarslcathere was a shog wheredump 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;lleasnoses, 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.
a nanteassphincter g(itcwas aiman fraaira village JCorcarac),
letting the water run :full force frm the -, until
the man swelledand thcm died burstingto pieces. g. ofrtheirtubelongings. coManynof usrprisonersslhad thousan&
of Geman Marks with us. Serbs would sell us food at
exorbitantprices. 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 ionrings would came off
easily. Serbs were knocking mslim prisoners' teeth to
get at the gold fillirrgs ....
g. Serbs were rounding tlp all non-Serbcivilians,nwstly
Muslhs, and bringing them to Omarska frcm near-by
villages - Carakwo eelo, Sambarim, Lje~kava, Ljubija,
Raveka. It tiseemsmrly 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 Serbeslaughtered 22,000 Muslims. Out
of a populationof 42,000 hardly 2,000 nsmineB.
r. Serb torturerswere 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. Se torturers allowed
us 1 minute to fini~ll the 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 scrraebeds 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 fiord88to
Manjaca concentratior..camp. There had been aver four
thousand Muslims {antiCroats) that anivd to mrska
with me. Less than fourteen hundred of us were left to
go to Manjaca. They mwed us from the extermination
caaapCmarska, as Red c3roas members told us, becauee the
published aboutnU us. abWetwere drivenarincthe bus. beSerb
torturers were beating us all the the in the bus,
forcing us to sing Chsrtniksongs, killing us. 931- slit
ttzroatsof 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
hot an8 Sthey forcednousgito swallowthanhandfulriof salt.wasI
was perergiring profusely, and in order to survive I
drained the perspiration from my sweatshirtinto [my]
hand8 and rtianfthat.
u. In Manjaca,kerhamet; (RedCrescent) registered us. The
Red Cross took over food deliveries. However wst of
the food vars taken riwayisy 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
arrivedSerbs 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. !&slimprisonerswuuld be checked
by Red Crossmedical staff which would prescribe &rugs. w
These drugs never rssched any prisoners,they were all
taken by Serb guards for theirneeds. 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;, cutthe grass,load the hay,
pick corn, graze sheep, cows, etc. Azcuxl one thousand
geo~le or 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
Knin tbey were holding chem in a tcpwer. Sed would lat J
dogs [awl children ... cute and abuse them. They broke
bonesof ... most of them. When they returned I watches
fm the 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 ails of her expulsion by Serbianforces.
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
becausewe were Muslims ....
b. I an8 my old atother together with our neighborsjoined
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
innocentson, child, wcmaan,or man on the walls of tne
houae. We slept thereand waited forour departure, an8
they were standing 0x1guard outside, singing, drinking,
and listeningto 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 frm tbat firsr: convoythat had Peft 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 aunt4 s child in my am. They set apart about
thirty girls. They ~segarated an 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 waanenwere 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 ant3everywherewherethe
Tschetaik'sfoot 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 forceskept announcing over
#hrslirrandthCroatsstartedleaviogr attheirph-8ticeandiSerb
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~emerd Serbian ArmdadForces [the official forces of
the Serbianmunicipalityof Sanski Most] looting the
marked hauses (with white eheets) , burning them to the
ground afterwarde. 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
normals,size,thfrom the beatings that somyofather,twwho wase
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 constantlybeaten
.... 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 severelybeaten 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
watchd towere therem udthd machine-gunpositions.there Serbs
sleep lyingouton0the side. iWhile inside,le.Serbs cforcedmyus
to keep uilent , not a sound was allowed to be uttered.
In the silencewe cmld hear terrible scream. At first
we thought the soup& were coming fran 8ome animals, but
som realized they were coming fran 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 ~5th no 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 fs8 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 ~hwemaats for two mmths.
s. Serbs minterrogated*us daily - there would be up to
twenty 4*interrogator~ :tua time shautiag at me at the
same time an8 hittying me. The minterragation" was
invariablyaccwpanie!d with Physical mistreatment, with
awere beatings. Serb guaras, soldiers, civilians,
interrogators, met o:Ethem 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
this hpositionhitillur3-4acp.m. Serbs f-rguards, tosoldiers,
:.4I-' -
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,
doMn at allatiaes.osFathersaand sons hwould notkknuw [of]
each other although they may have actually been [within
a] few meters of each other.
g. ~rmd 10 July 1992, EncirMulalic, a polic~~un from
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.dthe corpse fox two burs. Then
they called a doctor, who declaredhim dead fnxn a buret
vein in the brain.
Mten Serb civilianswere 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'
forced lUBvito dolyallhkindsinofrsmanual labour,). suchras
agricultural chores, digging potatoes, digging
irrigation &itches, we had to worked as lumber- jacks
carxying wood from t;beforests on our backe - Serbs
forced the priscmers :into thewoods in their T-shirtsin
winter in bitterly zcild weather. while working in the
fields, I eaw Muslim; grazing grass f ram being starved
until their etamachstwelled.
(In£ormation Coordinator Crimes Former Yugoslavia,
Statmt of victim 043 NA)
7. Although the incidents described above alone support the
chargeof genocide, they are only r-reaentative of the accaunts
by a group of Bosnian Muslim refugees in Canada, via- of the
bysSerbianforcesliain,Bosnia-Hen:ogcn?ina.that bave been axmitt&
_I
8. In adCUtian, Muslimvictimsare nat the only witnessesto the
genocidal acts camittea by the Serbs. In the November 27, 1992
issue of me-, Bo:rislavHerak, an iqrisoned Serbian
wldier described mrdms, -38, and othertortures 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 carriedour their plan of *lerhnic cleansingu.
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 caawanderscalled the Serbian operation in
the village cl;.sclenie, or the cleansing of the region, and
had told the Serbianfighters to leave nob- alive. (u. I.
we were told that Ahatovicimust 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 simplydid 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-gunnin 120 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
pit, Bauaedeawithrgasoline andescatafire.ie(u.w1r. piled in an open
12. In anotherincident thxt occurred in July, Herak aaw 30 men
from Donja Bioca, a Muslim vi:Llage five kilometers northwestof
Vogosca, shot and incinerated in a furnace at a steel plant at
flijas, a town north of Vogoaca. He said some of the men were
stillalive when they were thrown into the furgace. (fi.).
13. Herak aleo describetl seeingthe bodies of 60 Ntuslimmen 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~ione were encouraged to go to a motel by
Serbian ccreaanders who told them that raping Muelim waraenwas
"goad for raisingthe f ighter5smorale4@. Herak stated that he
went to the motel once everythree or four days, and that although
Serbian fighters routinely took the #amen they taped away an6
killed thm, therewere alwaysraore wanen arriving. u.1.
25. In early September of 1992, in Bosanski Petrovac,a group of
Muslimvillagers were approached by uniformed Se*lean soldiers. A
woeaan in her thirties gave a statenrent regarding the incident.
The ~oldiers took 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. 'Rsbiyaenage 4
girls were also raged by the soldiers. Two adult males were taken
to a nearby forest, bound with chains, beat and burned with
wigarettes by the S-rwann soldiers. (meaty Internatianal,n
Ja~uary 21, 1993, page 6).
International-sdescribedr her abduction- QY iSerbian soldiers,nestIn
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 autanaticweapon cloee at hand thr~~lghQUt. (u .,page
71.
17. On June 17, approxixnately 1,000 -rroarand children were taken
away by Serhfan foxces frum their bane village of Brezovo Polje by
bus. Travellingwithout food or water, they arrived in the tcmm
of Caparde several days later. Xn the courseof 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
Serbian solclierserselectedtandn :raged40tuof theewonnen betweenothe
ages of 15 aad 30 years. The ycrungwman rejobed the older wmmz~
four days later after being fc~rced to pass along a mined road.
Doctors who received thm in ;:heBosnian Govermssernt-coatrolled
town of Tuzla follwring their rrilease reportedly said that of
tiregirls 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, althuazgtrshe beliwes she saw about
100 weamenin total a8 tbq were ~ploaded. She aaB others were
beaten upon arrival and on later occasions. mlve men,
theluroam in frontorsofntthe othere hwmen inonemultipleeroccasio~s,n
soprsetimesby more than one maa at a cbe. Other umen who tried
to defencl her on one occasim were beaten an8 one of the
pe~etrators told her, "You will bear a Serbianchild". (u.),
20. In a hospital in Zagreb, seventeen year old Marianna
described her confinement in a detention camp. Fm olanthsshe was
raped as aranyaa ten times a day by Serbiansoldiers after she and 24 other wrmen were taken fram their Bosaian villqge,Tesanj , to a
canzgin a nearby forest. During the rapes, a Serbian guard told
.her, "Now you dl1 have Serbianbabies for the reet of your life."
(Squitieri,Tam, mWeaponsin Bosnia: Rape, degradation,
-, August 10, 1992, page 1),
the soul,&~~betweenthe50meand 70 Icivilians,al mainly Bhaslimsmdfromo
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.
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
visitedand left sane medicinefor those suffering from
diarrhea.
wbat prisonersmost 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 frant
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
prisonerwas usually taken to another truild5ng about 15
meters away fram whir* the other griscnrerm cdd hear
screaars of pain. Otreor 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
athersed-tespeciallyeMlslirasncaneiderdceto 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. rSXaaevicthw were rwortedly placed - -- --
u;;-:z: -- -s=z :I
---- I:4-
-
in solitary confinemunt after being beatan for anything
from one hourto several days.
c. One 23 year old Mus:Lim decorator,was arrested on 30
Aaya at the police stationin BoeanskiPetrmc.g held fOn meo
occasionat about mimight, anothermslim prisoner in
the mite roan aamedHK, 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,
barkinglikea clog.... His drenched clothes sbxrwo tdhat
he had bgen Bunked iri the trough of water outside. As
the other prisoners were rgPMving his clothes BK us
called out againand after abaut fifteen mfautes he was
again made to crawl&kck on all fours ....
d. When asked whether they could see EIK6 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 thatwasn'tbruised.'
e. RK had been beaten or kicked over all his body with the
exceptionof his head. After three days he could walk
not walke unaidednfor at leasteanotherettwo days.but could
f. One prisoner, ZR, agc!ii about 35, was beaten about the
head. Anotherprisoner 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 civiliancletainees w
were transferred £ran Kozile to Kanrenica, also described
as barracks for workers, abut 15 kilmeters fram
Drinic. On 21 August .theremainingcivilians 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 frm the front or had emitted thefts. All
Muslim and Croat prisoners were held in one rcwtn about
10 metera by 15 meters. Basic conditionswere better
visitedhathree mor four times over iarthree ntonthperiod.r
Detainees slept on a thfn piece of tarpaulin an8 each
grieoner had a blanket. Prisoners worked in the camp
c~rurting fences, pzrinting and cleaningthe grormds. h. Hawever, it seems that after the civilianpopulationof
Bosanski Petrovac negotiated their departure on 24
September, the detaineesin 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
interrogation candgasked himewhatarhe had told them 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 calledto 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 guarClbefore 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 mr6to the other side of the scho~l.
There were eight of their [Serbian] guards and
grieoners. One drove me fomard with a rif1% 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 baseballbat or a riot-control baton - in
hie awn won%: 'OJhez,ithit yau it was likean 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
wast nonway tI coulam.lift my amdn'tsince Iacouldnet tfeel
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 themarningafter dawn
they [his fellow prisoners3 took the clothes off my
upper body. When I was undressed my am looked as if
they bd been inflated with a pfmrpfor car tires.'
j. The victim stated ttlathe 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 distinctgroup, i.e. Bosnian
ofuethat,group, andumdeliberately inflictedanonmthatl grazp cooditio~~
of l%ie calculated to bring about its physical dmet~ction in
whole or in part. Tflefact 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~nia arrd Xerseguvi~ hereby reepectful3y
requests that the Court conoider this additionalevidenceduring
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 Republicof Bosniaand
Herzegovina
Supplementary Submission in support of the Application of the Bosnia and Herzegovina instituting legal proceedings against Yugoslavia (Serbia and Montenegro) on the basis of the 1948 Genocide Convention and in the support of its Request for an Indication of Provisional Measures of Protection