In this November 7, 1994 indictment, Dragan Nikolic, the Bosnian Serb camp commander of the Susica prison camp, is charged with war crimes including the murder and torture of prisoners.

THE INTERNATIONAL CRIMINAL TRIBUNAL
FOR THE FORMER YUGOSLAVIA

Case No. IT-94-2-I

THE PROSECUTOR OF THE TRIBUNAL

AGAINST

DRAGAN NIKOLIC
ALSO KNOWN AS
"JENKI" NIKOLIC


INDICTMENT

Richard J. Goldstone, Prosecutor of the International Criminal
Tribunal for the Former Yugoslavia ("the Tribunal") pursuant to his
authority under Article 18 of the Statute of the International
Criminal Tribunal for the former Yugoslavia ("The Statute of the
Tribunal"), charges 

Dragan Nikolic, also known as "Jenki" NIKOLIC. ("Dragan NIKOLIC"), 

believed to be from the town of Vlasenica in the Opstina of Vlasenica,
Republic of Bosnia-Herzegovina, within the territory of the former
Yugoslavia, with: 

Grave Breaches, of the Fourth Geneva Convention of 12 August 1949
Relative to the Protection of Civilian Persons in Time of War ("Geneva
Convention") by committing prohibited acts against persons protected
under the provisions of that Convention; 

Violations of the Laws or Customs of War, including those recognized
by Article 3 of the Fourth Geneva Convention of 12 August 1949
Relative to the Protection of Civilian Persons in Time of War ("Geneva
Convention"); 

and

Crimes Against Humanity, being prohibited acts committed in armed
conflict and directed against a civilian population; 

all committed at a place known as the Susica Camp, near the town of
Vlasenica in the Opstina of Vlasenica, Republic of Bosnia-Herzegovina
in the territory of the former Yugoslavia ("Susica Camp"); 

all offences recognized by Articles 2, 3, and 5 of the Statute of the
Tribunal, 

as is more particularly set out in the concise statement of the facts
and recital of the crimes, as follows: 

1.1   From about 13 June 1992 to about 24 June 1992, in Susica Camp,
Dragan NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
wilful killing of Durmo HANDZIC, a person protected by that
Convention, an offence recognized by Article 2(a) of the Statute of
the Tribunal. 

1.2   From about 13 June 1992 to about 24 June 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(a) of the Geneva Convention, by participating during a
period of armed conflict in the murder of Durmo HANDZIC, a person
protected by that Convention, an offence recognized by Article 3 of
the Statute of the Tribunal. 

1.3   From about 13 June 1992 to about 24 June 1992, in Susica Camp,
Dragan NIKOLIC committed a Crime against Humanity by participating in
the murder of Durmo HANDZIC, during a period of armed conflict and as
part of a widespread or systematic attack directed against a civilian
population, an offence recognized by Article 5(a) of the Statute of
the Tribunal. 

2.1   From about 13 June 1992 to about 24 June 1992, in Susica Camp,
Dragan NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
wilful killing of Asim ZILDZIC, a person protected by that Convention,
an offence recognized by Article 2(a) of the Statute of the Tribunal. 

2.2   From about 13 June 1992 to about 24 June 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(a) of the Geneva Convention, by participating during a
period of armed conflict in the murder of Asim ZILDZIC, a person
protected by that Convention, an offence recognized by Article 3 of
the Statute of the Tribunal. 

2.3   From about 13 June 1992 to about 24 June 1992, in Susica Camp,
Dragan NIKOLIC committed a Crime against Humanity by participating in
the murder of Asim ZILDZIC during a period of armed conflict and as
part of a widespread or systematic attack directed against a civilian
population, an offence recognized by Article 5(a) of the Statute of
the Tribunal. 

3.1   From about 3 July 1992 to about 7 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
wilful killing of Mevludin HATUNIC, a person protected by that
Convention, an offence recognized by Article 2(a) of the Statute of
the Tribunal. 

3.2   Alternatively, from about 3 July 1992 to about 7 July 1992, in
Susica Camp, Dragan NIKOLIC committed a Grave Breach of the Geneva
Convention by participating, during a period of armed conflict or
occupation, in the infliction of inhuman treatment, consisting of
serious physical assaults, on Mevludin HATUNIC, a person protected by
that Convention, an offence recognized by Article 2(b) of the Statute
of the Tribunal. 

3.3   From about 3 July 1992 to about 7 July 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(a) of the Geneva Convention, by participating during a
period of armed conflict in the murder of Mevludin HATUNIC, a person
protected by that Convention, an offence recognized by Article 3 of
the Statute of the Tribunal. 

3.4   Alternatively, from about 3 July 1992 to about 7 July 1992, in
Susica Camp, Dragan NIKOLIC violated the Laws or Customs of War,
contrary to Article 3(1)(a) of the Geneva Convention, by participating
during a period of armed conflict in the infliction of cruel
treatment, consisting of serious physical assaults on Mevludin
HATUNIC, a person protected by that Convention, an offence recognized
by Article 3 of the Statute of the Tribunal. 

3.5   From about 3 July 1992 to about 7 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Crime against Humanity by participating in
the murder of Mevludin HATUNIC during a period of armed conflict and
as part of a widespread or systematic attack directed against a
civilian population, an offence recognized by Article 5(a) of the
Statute of the Tribunal. 

3.6   Alternatively, from about 3 July 1992 to about 7 July 1992, in
Susica Camp, Dragan NIKOLIC committed a Crime against Humanity by
participating in inhumane acts, consisting of serious physical
assaults, on Mevludin HATUNIC during a period of armed conflict and as
part of a widespread or systematic  attack directed against a civilian
population, an offence recognized by Article 5(i) of the Statute of
the Tribunal. 

4.1   From about 19 June 1992 to about 26 June 1992, in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, committed a Grave Breach of the
Geneva Convention by participating, during a period of armed conflict
or occupation, in the wilful killing of Rasid FERHATBEGOVIC, a person
protected by that Convention, an offence recognized by Articles 2(a)
and 7(3) of the Statute of the Tribunal. 

4.2   From about 19 June 1992 to about 26 June 1992, in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, violated the Laws or Customs of War,
contrary to Article 3(1)(a) of the Geneva Convention, by participating
during a period of armed conflict in the murder of Rasid
FERHATBEGOVIC, a person protected by that Convention, an offence
recognized by Articles 3 and 7(3) of the Statute of the Tribunal. 

4.3   From about 19 June 1992 to about 26 June 1992 in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, committed a Crime against Humanity by
participating in the murder of Rasid FERHATBEGOVIC during a period of
armed conflict and as part of a widespread or systematic attack
directed against a civilian population, an offence recognized by
Articles 5(a) and 7(3) of the Statute of the Tribunal. 

5.1   From about 19 June 1992 to about 26 June 1992, in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, committed a Grave Breach of the
Geneva Convention by participating, during a period of armed conflict
or occupation, in the wilful killing of Dzevad SARIC, a person
protected by that Convention, an offence recognized by Articles 2(a)
and 7(3) of the Statute of the Tribunal. 

5.2   From about 19 June 1992 to about 26 June 1992, in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, violated the Laws or Customs of War,
contrary to Article 3(1)(a) of the Geneva Convention, by participating
during a period of armed conflict in the murder of Dzevad SARIC, a
person protected by that Convention, an offence recognized by Articles
3 and 7(3) of the Statute of the Tribunal. 

5.3   From about 19 June 1992 to about 26 June 1992 in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, committed a Crime against Humanity by
participating in the murder of Dzevad SARIC during a period of armed
conflict and as part of a widespread or systematic attack directed
against a civilian population, an offence recognized by Articles 5(a)
and 7(3) of the Statute of the Tribunal. 

6.1   From about 19 June 1992 to about 26 June 1992, in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, committed a Grave Breach of the
Geneva Convention by participating, during a period of armed conflict
or occupation, in the wilful killing of Muharem KOLAREVIC, a person
protected by that Convention, an offence recognized by Articles 2(a)
and 7(3) of the Statute of the Tribunal. 

6.2   From about 19 June 1992 to about 26 June 1992, in Susica Camp,
DRAGAN NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, violated the Laws or Customs of War,
contrary to Article 3(1)(a) of the Geneva Convention, by participating
during a period of armed conflict in the murder of Muharem KOLAREVIC,
a person protected by that Convention, an offence recognized by
Articles 3 and 7(3) of the Statute of the Tribunal. 

6.3   From about 19 June 1992 to about 26 June 1992 in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, committed a Crime against Humanity by
participating in the murder of Muharem KOLAREVIC during a period of
armed conflict and as part of a widespread or systematic attack
directed against a civilian population, an offence recognized by
Articles 5(a) and 7(3) of the Statute of the Tribunal 

7.1   From about 19 June 1992 to about 26 June 1992, in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, committed a Grave Breach of the
Geneva Convention by participating, during a period of armed conflict
or occupation, in the wilful killing of a person with the surname
ZEKIC, a person protected by that Convention, an offence recognized by
Articles 2(a) and 7(3) of the Statute of the Tribunal. 

7.2   From about 19 June 1992 to about 26 June 1992, in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, violated the Laws or Customs of War,
contrary to Article 3(1)(a) of the Geneva Convention, by participating
during a period of armed conflict in the murder of a person with the
surname ZEKIC, a person protected by that Convention, an offence
recognized by Articles 3 and 7(3). 

7.3   From about 19 June 1992 to about 26 June 1992 in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, committed a Crime against Humanity by
participating in the murder of a person with the surname ZEKIC during
a period of armed conflict and as part of a widespread or systematic
attack directed against a civilian population, an offence recognized
by Articles 5(a) and 7(3) of the Statute of the Tribunal. 

8.1   On or about 6 July 1992, in Susica Camp, Dragan NIKOLIC
committed a Grave Breach of the Geneva Convention by participating,
during a period of armed conflict or occupation, in the wilful killing
of Ismet DEDIC, a person protected by that Convention, an offence
recognized by Article 2(a) of the Statute of the Tribunal 

8.2   Alternatively, on or about 6 July 1992, in Susica Camp, Dragan
NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
infliction of inhuman treatment, consisting of serious physical
assaults, on Ismet DEDIC, a person protected by that Convention, an
offence recognized by Article 2(b) of the Statute of the Tribunal. 

8.3   On or about 6 July 1992, in Susica Camp, Dragan NIKOLIC violated
the Laws or Customs of War, contrary to Article 3(1)(a) of the Geneva
Convention, by participating during a period of armed conflict in the
murder of Ismet DEDIC, a person protected by that Convention, an
offence recognized by Article 3 of the Statute of the Tribunal. 

8.4   Alternatively, on or about 6 July 1992, in Susica Camp, Dragan
NIKOLIC violated the Laws or Customs of War, contrary to Article
3(1)(a) of the Geneva Convention, by participating during a period of
armed conflict in the infliction of cruel treatment, consisting of
serious physical assaults on Ismet DEDIC, a person protected by that
Convention, an offence recognized by Article 3 of the Statute of the
Tribunal. 

8.5    On or about 6 July 1992, in Susica Camp, Dragan NIKOLIC
committed a Crime against Humanity by participating in the murder of
Ismet DEDIC during a period of armed conflict and as part of a
widespread or systematic attack directed against a civilian
population, an offence recognized by Article 5(a) of the Statute of
the Tribunal. 

8.6    Alternatively, on or about 6 July 1992, in Susica Camp, Dragan
NIKOLIC committed a Crime against Humanity by participating in
inhumane acts, consisting of serious physical assaults, on Ismet DEDIC
during a period of armed conflict and as part of a widespread or
systematic attack directed against a civilian population, an offence
recognized by Article 5(i) of the Statute of the Tribunal. 

9.1    From about 24 June 1992 to about 19 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
infliction of inhuman treatment, consisting of serious physical
assaults, on Galib MUSIC a person protected by that Convention, an
offence recognized by Article 2(b) of the Statute of the Tribunal. 

9.2    From about 24 June 1992 to about 19 July 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(a) of the Geneva Convention, by participating during a
period of armed conflict in the infliction of cruel treatment,
consisting of serious physical assaults on Galib MUSIC, a person
protected by that Convention, an offence recognized by Article 3 of
the Statute of the Tribunal. 

9.3    From about 24 June 1992 to about 19 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Crime against Humanity by participating in
inhumane acts, consisting of serious physical assaults, on Galib MUSIC
during a period of armed conflict and as part of a widespread or
systematic attack directed against a civilian population, an offence
recognized by Article 5(i) of the Statute of the Tribunal 

10.1   From about 1 June 1992 to about 18 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
torture, by use of a bayonet, of Fikret "Cice" ARNAUT, a person
protected by that Convention, an offence recognized by Article 2(b) of
the Statute of the Tribunal. 

10.2   From about 1 June 1992 to about 18 July 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(a) of the Geneva Convention, by participating during a
period of armed conflict in the torture, by use of a bayonet, of
Fikret "Cice" ARNAUT, a person protected by that Convention, an
offence recognized by Article 3 of the Statute of the Tribunal 

10.3 From about 1 June 1992 to about 18 July 1992, in Susica camp,
Dragan NIKOLIC committed a Crime against Humanity by participating in
the torture, by use of a bayonet, of Fikret "Cice" ARNAUT during a
period of armed conflict and as part of a widespread or systematic
attack directed against a civilian population, an offence recognized
by Article 5(f) of the Statute of the Tribunal. 

11.1 From about 1 June 1992 to about 18 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
wilful causing of great suffering, inflicted as a result of serious
physical assaults, to Fikret "Cice" ARNAUT, a person protected by that
Convention, an offence recognized by Article 2 (c) of the Statute of
the Tribunal. 

11.2 From about 1 June 1992 to about 18 July 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(a) of the Geneva Convention, by participating during a
period of armed conflict in the cruel treatment, inflicted as a result
of serious physical assaults, of Fikret "Cice" ARNAUT, a person
protected by that Convention, an offence recognized by Article 3 of
the Statute of the Tribunal. 

11.3 From about 1 June 1992 to about 18 July 1992, in Susica Camp,
Dragan NIKOLlC committed a Crime against Humanity by participating in
inhumane acts, consisting of serious physical assaults, of Fikret
"Cice" ARNAUT during a period of armed conflict and as part of a
widespread or systematic attack directed against a civilian
population, an offence recognized by Article 5(i) of the Statute of
the Tribunal. 

12.1 From about 20 June 1992 to about 30 June 1992, in Susica Camp,
Dragan NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
torture, by use of a bayonet, of Mubin MUSIC, a person protected by
that Convention, an offence recognized by Article 2 (b) of the Statute
of the Tribunal. 

12.2 From about 20 June 1992 to about 30 June 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(a) of the Geneva Convention, by participating during a
period of armed conflict in the torture, by use of a bayonet, of Mubin
MUSIC, a person protected by that Convention, an offence recognized by
Article 3 of the Statute of the Tribunal. 

12.3 From about 13 June 1992 to about 3 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Crime against Humanity by participating in
the torture, by use of a bayonet, of Mubin MUSIC during a period of
armed conflict and as part of a widespread or systematic attack
directed against a civilian population, an offence recognized by
Article 5(f) of the Statute of the Tribunal. 

13.1 From about 13 June 1992 to about 3 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
torture, by use of a pistol, of Suad MAHMUTOVIC, a person protected by
that Convention, an offence recognized by Article 2(b) of the Statute
of the Tribunal. 

13.2 From about 13 June 1992 to about 3 July 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(a) by participating during a period of armed conflict in
the torture, by use of a pistol, of Suad MAHMUTOVIC, a person
protected by that Convention, an offence recognized by Article 3 of
the Statute of the Tribunal. 

13.3 From about 13 June 1992 to about 3 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Crime against Humanity by participating in
the torture, by use of a pistol, of Suad MAHMUTOVIC during a period of
armed conflict and as part of a widespread or systematic attack
directed against a civilian population, an offence recognized by
Article 5(f) of the Statute of the Tribunal. 

14.1 From about 13 June 1992 to about 3 July 1992, in Susica Camp,
Dragan NlKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
causing of serious injury to body or health, occasioned by physical
assaults resulting in disfigurement, of Suad MAHMUTOVIC, a person
protected by that Convention, an offence recognized by Article 2(c) of
the Statute of the Tribunal. 

14.2 From about 13 June 1992 to about 3 July 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(a) of the Geneva Convention, by participating during a
period of armed conflict in the cruel treatment by physical assaults
resulting in disfigurement, of Suad MAHMUTOVIC, a person protected by
that Convention, an offence recognized by Article 3 of the Statute of
the Tribunal. 

14.3 From about 13 June 1992 to about 3 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Crime against Humanity by participating in
inhumane acts, consisting of serious physical assaults resulting in
disfigurement, of Suad MAHMUTOVIC during a period of armed conflict
and as part of a widespread or systematic attack directed against a
civilian population, an offence recognized by Article 5(i) of the
Statute of the Tribunal. 

15.1 On or about 13 June 1992, in Susica Camp, Dragan NIKOLIC
committed a Grave Breach of the Geneva Convention by participating,
during a period of armed conflict or occupation, in wilfully causing
great suffering, inflicted as a result of a serious physical assault,
to Sead AMBESKOVIC, a person protected by that Convention, an offence
recognized by Article 2 (c) of the Statute of the Tribunal. 

15.2 On or about 13 June 1992, in Susica Camp, Dragan NIKOLIC violated
the Laws or Customs of War, contrary to Article 3(1)(a) of the Geneva
Convention, by participating during a period of armed conflict in the
cruel treatment, consisting of a serious physical assault, of Sead
AMBESKOVIC, a person protected by that Convention, an offence
recognized by Article 3 of the Statute of the Tribunal. 

15.3 On or about 13 June 1992, in Susica Camp, Dragan NIKOLIC
committed a Crime against Humanity by participating in inhumane acts,
consisting of a serious physical assault, on Sead AMBESKOVIC during a
period of armed conflict and as part of a widespread or systematic
attack directed against a civilian population, an offence recognized
by Article 5(i) of the Statute of the Tribunal. 

16.1 On or about 14 June 1992, in Susica Camp, Dragan NIKOLIC
committed a Grave Breach of the Geneva Convention by participating,
during a period of armed conflict or occupation, in wilfully causing
great suffering, inflicted as a result of a serious physical assault
causing serious disfigurement, to Sead AMBESKOVIC, a person protected
by that Convention, an offence recognized by Article 2 (c) of the
Statute of the Tribunal. 

16.2 On or about 14 June 1992, in Susica Camp, Dragan NIKOLIC violated
the Laws or Customs of War, contrary to Article 3(1)(a) of the Geneva
Convention, by participating during a period of armed conflict in the
cruel treatment, consisting of a serious physical assault causing
disfigurement, of Sead AMBESKOVIC, a person protected by that
Convention, an offence recognized by Article 3 of the Statute of the
Tribunal. 

16.3 On or about 14 June 1992, in Susica Camp, Dragan NIKOLIC
committed a Crime against Humanity by participating in inhumane acts,
consisting of a serious physical assault causing disfigurement, on
Sead AMBESKOVIC during a period of armed conflict and as part of a
widespread or systematic attack directed against a civilian
population, an offence recognized by Article 5(i) of the Statute of
the Tribunal. 

17.1 On or about 16 June 1992, in Susica Camp, Dragan NIKOLIC
committed a Grave Breach of the Geneva Convention by participating,
during a period of armed conflict or occupation, in wilfully causing
great suffering, inflicted as a result of a serious physical assault,
to Sead AMBESKOVIC, a person protected by that Convention, an offence
recognized by Article 2 (c) of the Statute of the Tribunal. 

17.2 On or about 16 June 1992, in Susica Camp, Dragan NIKOLIC violated
the Laws or Customs of War, contrary to Article 3(1)(a) of the Geneva
Convention, by participating during a period of armed conflict in the
cruel treatment, consisting of a serious physical assault, of Sead
AMBESKOVIC, a person protected by that Convention, an offence
recognized by Article 3 of the Statute of the Tribunal. 

17.3 On or about 16 June 1992, in Susica Camp, Dragan NIKOLIC
committed a Crime against Humanity by participating in inhumane acts,
consisting of a serious physical assault, on Sead AMBESKOVIC during a
period of armed conflict and as part of a widespread or systematic
attack directed against a civilian population, an offence recognized
by Article 5(i) of the Statute of the Tribunal. 

18.1 From about I June 1992 to about 2 July 1992, in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts committed a Grave Breach of the Geneva
Convention by participating, during a period of armed conflict or
occupation, in the infliction of inhuman treatment, consisting of
serious physical assaults, to Redjo CAKISIC, a person protected by
that Convention, an offence recognized by Articles 2(b) and 7(3) of
the Statute of the Tribunal. 

18.2 From about I June 1992 to about 2 July 1992, in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, violated the Laws or Customs of War,
contrary to Article 3(1)(a) of the Geneva Convention, by participating
during a period of armed conflict in the cruel treatment, consisting
of serious physical assaults, of Redjo CAKISIC, a person protected by
that Convention, an offence recognized by Articles 3 and 7(3). 

18.3 From about 1 June 1992 to about 2 July 1992 in Susica Camp,
Dragan NIKOLIC, by being a superior responsible for the acts of a
subordinate and by his own acts, committed a Crime against Humanity by
participating in inhumane acts, consisting of serious physical
assaults, on Redjo CAKISIC during a period of armed conflict and as
part of a widespread or systematic attack directed against a civilian
population, an offence recognized by Articles 5(i) and 7(3) of the
Statute of the Tribunal. 

19.1 From about 24 June 1992 to about 19 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Grave Breach of the Geneva Convention by
participating, during a period of armed conflict or occupation, in the
wilful causing of great suffering, inflicted as a result of a physical
assault, to Hasna CAKISIC, a person protected by that Convention, an
offence recognized by Article 2 (c) of the Statute of the Tribunal. 

19.2 From about 24 June 1992 to about 19 July 1992, in Susica Camp,
Dragan NIKOLIC violated the Laws or Customs of War, contrary to
Article 3(1)(c)of the Geneva Convention, by participating during a
period of armed conflict in inflicting outrages upon the personal
dignity, inflicted as a result of a physical assault, of Hasna
CAKISIC, a person protected by that Convention, an offence recognized
by Article 3 of the Statute of the Tribunal. 

19.3 From about 24 June 1992 to about 19 July 1992, in Susica Camp,
Dragan NIKOLIC committed a Crime against Humanity by participating in
inhumane acts, consisting of a physical assault, to Hasna CAKISIC
during a period of armed conflict and as part of a widespread or
systematic attack directed against a civilian population, an offence
recognized by Article 5(i) of the Statute of the Tribunal. 

20.1 From about 1 June 1992 to about 30 September 1992, in Susica
Camp, Dragan NIKOLIC, by being a superior responsible for the acts of
a subordinate and by his own acts, committed a Grave Breach of the
Geneva Convention by participating, during a period of armed conflict
or occupation, in the unlawful confinement of more than 500 civilians,
the names of most of whom cannot be ascertained but amongst them were
the following: 

Durmo HANDZIC, Asim ZILDZIC, Mevludin HATUNIC, Rasid FERHATBEGOVIC,
DzevadSARIC, Muharem KOLAREVIC, a person with the surname ZEKIC, Ismet
DEDIC, Galib MUSIC, Fikret"Cice" ARNAUT, Mubin MUSIC, Suad MAHMUTOVIC,
Sead AMBESKOVIC, Redjo CAKISIC, and Hasna CAKISIC, 

the said civilians of the Vlasenica Opstinand surrounding areas, being
persons protected by that Convention, an offence recognized by
Articles 2(g) and 7(3) of the Statute of the Tribunal. 

20.2 From about 1 June 1992 to about 30 September 1992, in Susica
Camp, Dragan NIKOLIC, by being a superior responsible for the acts of
a subordinate and by his own acts, committed a Crime against Humanity
by participating during a period of armed conflict in the imprisonment
of more than 500 civilians, the names of most of whom cannot be
ascertained but amongst them were the following: 


Durmo HANDZIC, Asim ZILDZIC, Mevludin HATUNIC, Rasid FERHATBEGOVIC,
Dzevad SARIC, Muharem KOLAREVIC, a person with the surname ZEKIC,
Ismet DEDIC, Galib MUSIC, Fikret "Cice" ARNAUT, Mubin MUSIC, Suad
MAHMUTOVIC, Sead AMBESKOVIC, Redjo CAKISIC, and Hasna CAKISIC, 

the said civilians of the Vlasenica Opstinand surrounding areas, all
during a period of armed conflict and as part of a widespread or
systematic attack directed against a civilian population, an offence
recognized by Articles 5(e) and 7(3) of the Statute of the Tribunal. 

21.1 From about 1 June 1992 to about 30 September 1992, in Susica
Camp, Dragan NIKOLIC, by being a superior responsible for the acts of
a subordinate and by his own acts, committed a Grave Breach of the
Geneva Convention by participating, during a period of armed conflict
or occupation, in the extensive appropriation of property not
justified by military necessity and carried out unlawfully and
wantonly, including but not limited to private property of persons
detained at Susica Camp, the names of most of whom cannot be
ascertained but amongst them were Sead AMBESKOVIC, Mubin MUSIC, Redjo
CAKISIC, and Hasna CAKISIC, an offence recognized by Articles 2(d) and
7(3) of the Statute of the Tribunal. 

21.2 From about 1 June 1992 to about 30 September 1992, in Susica
Camp, Dragan NIKOLIC, by being a superior responsible for the acts of
a subordinate and by his own acts, violated the Laws or Customs of
War, by participating during a period of armed conflict in the plunder
of private property of persons detained at Susica Camp, the names of
most of whom cannot be ascertained but amongst them were Sead
AMBESKOVIC, Mubin MUSIC, Redjo CAKISIC, and Hasna CAKISIC, an offence
recognized by Articles 3(e) and 7(3)of the Statute of the Tribunal. 

22.1 From about 1 June 1992 to about 30 September 1992, in Susica
Camp, Dragan NIKOLIC, by being a superior responsible for the acts of
a subordinate and by his own acts, committed a Grave Breach of the
Geneva Convention by participating, during a period of armed conflict
or occupation, in the unlawful transfer of civilians from Susica Camp
to Batkovic Camp, the names of all of whom cannot be ascertained but
amongst them were Mubin MUSIC, Suad MAHMUTOVIC, Sead AMBESKOVIC, and
Redjo CAKISIC, all being persons protected by that Convention, an
offence recognized by , Article 2(g) and 7(3) of the Statute of the
Tribunal. 

23.1 From about 1 June 1992 to about 30 September 1992, a period of
armed conflict, in Susica Camp, Dragan NIKOLIC, by being a superior
responsible for the acts of a subordinate and by his own acts,
committed a Crime against Humanity by participating in the persecution
on political, racial and/or religious grounds of more than 500
civilians, the names of most of whom cannot be ascertained but amongst
them were the following: 

Durmo HANDZIC, Asim ZILDZIC, Mevludin HATUNIC, Rasid FERHATBEGOVIC,
Dzevad SARIC, Muharem KOLAREVIC, a person with the surname ZEKIC,
Ismet DEDIC, Galib MUSIC, Fikret "Cice" ARNAUT, Mubin MUSIC, Suad
MAHMUTOVIC, Sead AMBESKOVIC, Redjo CAKISIC, and Hasna CAKISIC, 

the said civilians of the Vlasenica Opstinand surrounding areas who
were or believed to be the Muslims or non-Serbs of the region by
maintaining a camp in which the said civilians were incarcerated, all
during a period of armed conflict and as part of a widespread or
systematic attack directed against a civilian population, an offence
recognized by Articles 5(h) and 7(3) of the Statute of the Tribunal. 

24.1 From about 1 June 1992 to about 30 September 1992, in Susica
Camp, Dragan NIKOLIC, by being a superior responsible for the act of a
subordinate and by his own acts, committed a Crime against Humanity by
participating in inhumane acts against more than 500 civilians, the
names of most of whom cannot be ascertained but amongst them were the
following: 

Durmo HANDZIC, Asim ZILDZIC, Mevludin HATUNIC, Rasid FERHATBEGOVIC,
Dzevad SARIC, Muharem KOLAREVIC, a person with the surname ZEKIC,
Ismet DEDIC, Galib MUSIC, Fikret "Cice" ARNAUT, Mubin MUSIC, Suad
MAHMUTOVIC, Sead AMBESKOVIC, Redjo CAKISIC, and Hasna CAKISIC, 

the said civilians of the Vlasenica Opstinand surrounding areas, by
endangering the health and welfare of detainees by providing
inadequate food, endangering the health and welfare of detainees by
providing living conditions failing to meet minimal basic standards,
and by creating an atmosphere where detainees feared for their
personal safety, during a period of armed conflict and as part of a
widespread or systematic attack directed against a civilian
population, an offence recognized by Articles 5(i) and 7(3) of the
Statute of the Tribunal. 


/s/Richard J. Goldstone
Prosecutor