Serbian leader Dusko Tadic faces charges of crimes against humanity and grave breaches of the Geneva Conventions, all allegedly committed while he operated death camps in Bosnia.

Annexure "MK 1" To Application for Deferral

DECLARATION

1.1 I, Michael J. Keegan, do solemnly declare the following
statement is true to the best of my knowledge and belief.

1.2 I am an attorney in the Prosecutor's Office of the
International Criminal Tribunal for the Former Yugoslavia. I am
assigned to the Investigation Unit.

1.3 As part of my duties, I am a legal advisor to the
investigation in the Prijedor region, of which the investigation
of Dusan Tadic, also known as Dule Tadic or Dusk Tadic, is a
part.

1.4 In the course of my duties, I am involved in the interview
of witnesses and the review of a large amount of information
that has been collected by the Office of the Prosecutor in
relation to this and other investigations.

1.5 Due to the sensitive nature of the offenses involved and
the necessity for confidentiality in this and other ongoing
investigations in the Prosecutor's office, the statements and
documents I placed in particular reliance upon in preparing this
declaration, are identified by the following codes:

1.5.1. Document identified by Tribunal document number 0400
-5072

1.5.2. Document identified by Tribunal document number 0400
-5080

1.5.3. Document identified by Tribunal document number 0400
-5110

1.5.4. Document identified by Tribunal document number 0400
-5112, 5116-5117, 5120-5122, 5125, 5133, 5135, 5139, 5141, 5147,
5150, 5152.

1.5.5. Document identified by Tribunal document number "Record
6"

1.5.6. Witness statement identified as document 2992/94

1.5.7. German witness statement dated 220294

1.5.8. German witness statement dated 160394

1.5.9. German witness statement dated 070494

1.5.10. German witness statement dated 300694

1.5.11. Netherlands witness statement dated 290984

1.5.12. Netherlands witness statement dated 300894

1.5.13. Norway witness statement coded March 22

1.5.14. Norway witness statement coded March 28

1.5.15. Norway witness statement coded March 40

1.5.16. Norway witness statement coded March 47

1.5.17. Norway witness statement coded March 56

1.5.18. Swedish witness statement dated 150994

1.5.19. Swedish witness statement dated 180994

1.5.20. Swedish witness statement dated 190994

1.5.21. Swedish witness statement dated 240994

1.5.22. Swedish witness statement dated 260994

1.5.23 Switzerland witness statement dated 240394

1.5.24. Switzerland witness statement dated 120793

2. INTRODUCTION

2.1. The case of Dusan TADIC is important to the prosecution of
those persons responsible for committing the serious violations
of international humanitarian law which occurred in the
territory of the former Republic of Yugoslavia since January 1,
1991, and in the Prijedor region of Bosnia-Herzegovina in
particular.

2.2. The criminal acts allegedly committed by Dusan TADIC would
provide a clear illustration of a plan for the widespread and
systematic destructive persecution against the civilian
population of the Prijedor Region (commonly referred to as
"ethnic cleansing"). TADIC himself was a well known person in
the Prijedor community and his actions after the Serbian
takeover of the area stood out even amongst the other atrocities
that were being committed. In light of the fact that TADIC's
activities cross the spectrum of possible offenses within the
jurisdiction of the Tribunal, the issues in the TADIC case are
closely related to, and involve significant factual and legal
questions which have direct implications on, the overall
investigation and prosecution of those persons responsible for
committing the serious violations of international humanitarian
law which occurred in the territory of the former Republic of
Yugoslavia since January 1, 1991, and in the Prijedor region of
Bosnia-Herzegovina in particular.

2.3 To place the alleged actions of Dusan TADIC in proper
context, I will first explain the general background of the
takeover and ethnic cleansing of the Prijedor region and then
set forth TADIC's actions within that framework. The use of
the terms "Muslim" and "Croat" in the following paragraphs refer
to those citizens of Bosnia-Herzegovina who were or are Muslim
or Croatian by heritage, and are used only for ease of
clarification. Depending upon the context in which it is used,
the term "Serb" may refer to either Bosnian citizens of Serbian
descent or when it is unknown whether the individuals were
Bosnian or citizens of Serbia proper.

3. EVENTS LEADING UP TO THE SEIZURE OF POWER AND ETHNIC
CLEANSING IN THE OPSTINA PRIJEDOR.

3.1. I am informed, and verily believe, that the Opstina
Prijedor is a regional "district" in northwest Bosnia. (See
attached map) It is situated between the Opstinas of Banja Luka
(to the east), Bosanska Dubica (to the north), Bosanski Novi (to
the west), and Sanski Most (to the south). Prijedor is also the
name of the largest city in Opstina. After the city of
Prijedor, Ljubija and Kozarac were the two next largest towns or
villages, with the rest of the area comprised of a small number
of villages. The Sana river flows through the region which is
dominated by heavily forested areas, including Kozarac Mountain
which lies to the north of Kozarac.

3.2. The city of Prijedor and the surrounding towns are located
within a corridor that can connect Serbian dominated areas in
the Krajina area west of Prijedor and Serbia proper to the east.
The Krajina is the traditional name for the area of land
extending along the border of and into Croatia and Bosnia
-Herzegovina. This area has been populated by the people of
Serbian descent for generations. The focus of the fighting in
Croatia was over the Serbian claim to the Krajina as an
independent Serbian republic with direct ties to Serbia proper.
The area of the Opstina Prijedor, therefore, had a special
military significance for the Serbians once the conflict in the
territory of the former Yugoslavia Republics of Croatia and
Bosnia-Herzegovina began. Although the opstinas in the wider
region, with the exception of Sanski Most, were Serb dominated,
within Prijedor the population was fairly evenly divided between
Muslims and Serbs with the Muslims having a small majority.
According to the 1991 census, Opstina Prijedor had a total
population of 112,470 people, of whom 44 per cent were Muslims,
42.5 per cent were Serbs, 5.6 per cent Croats, 5.7 per cent
'Yugoslavs' and 2.2 per cent others (Ukranians, Russians, and
Italians). According to the report of the United Nations
Commission of Experts established pursuant to the Security
Council Resolution 780 (1992), by June, 1993, over 43, 000 of
the nearly 50,000 Muslims in the area had left Bosnia or had
been killed.

3.3. In the early 1990's, nationalistic political parties
openly pursued political power for the first time in the area.
The two largest parties were the Muslim dominated Party of
Democratic Action (SDA - Stranka Demokratske Akcije) and the
Serb dominated Serbian Democratic Party (SDS - Srpska
Demokratiska Stranka). In the 1990 elections the Muslim SDA won
the majority of seats in the local Assembly. Despite this fact,
the Serbs still controlled by the majority of key positions in
the local political structure and government. The Muslim
population at first consented to this anomaly in order to
maintain relations. However, in late 1991 and early 1992, as a
response to the rising tensions and increasing Serb demands, the
Muslims began to try to assert their democratic claim to key
positions. The Serbs refused to yield some of the positions and
threatened force if the Muslims attempted to remove them from
office.

3.4 During 1991, some of the significant events that were
occurring outside the Prijedor area, but which foreshadowed the
future in Bosnia-Herzegovina and Prijedor included:

3.4.1. The declaration in January, 1991 by the Socialist
Federal Republic of Yugoslavia (controlled by the Serbian
Republic), calling for the arming of local paramilitary groups
throughout Bosnia-Herzegovina and the Krajina in response to an
arms build up by the Croatian national defense.

3.4.2. In the Spring, 1991, Serbian politicians in the Banja
Luka initiated the proclamation of the Bosanska Krajina
declaring a Serbian autonomous region: "Srpska Autonomna Oblast"
(SAO). A plebiscite was held in the Opstinas in the
northwestern Bosnia-Herzegovina to determine whether or not they
wanted to join the SAO. Only Prijedor and Sanski Most did not
vote to join the SAO,

3.4.3. In the summer of 1991, war broke out in Croatia and
fighting in Slavonia and other parts of Eastern Croatia. The
JNA issued a call up of all soldiers, active and reserve. The
Muslims and the Croats did not honour the call up. The Muslims
in Prijedor complained to the civil authorities in their area
and were told they did not have to honour the call up as the
Army had no authority to call up the reservists and militias.
Only the leadership of the Republics could issue such a
mobilization order. This lack of response by the Muslims and
Croats caused great resentment on the part of the Serbian
population. During the conflict with Croatia many of the JNA
forces were deployed through the Prijedor area. Throughout the
conflict there were a great number of soldiers in the Prijedor
area. At the same time, the Federal government, through the JNA,
began to arm the Serbian population in the area. Serbian
households received weapons that included machine guns,
automatic rifles, grenades, and ammunition.

3.4.4. In the autumn of 1991 the Serbians in Bosnia-Herzegovina
held a plebiscite directed at maintaining the region's ties with
the Serbian part of Yugoslavia. However, the Muslims and Croats
declared the plebiscite unconstitutional. Further, in the
autumn of 1991, the SAO was declared unconstitutional by the
Constitutional Court of Bosnia-Herzegovina.

3.5. As a result of the winding down of the conflict in
Croatia, Serbian attention focused more on Bosnia-Herzegovina.
In January 1992, "Assembly of the Serbian People of Bosnia
-Herzegovina" declared itself to be the duly elected
representative of the Serbian people and created the "Serbian
Republic of Bosnia-Herzegovina". The "Assembly" also declared
that the "Republic" would remain a unit of the Yugoslavian
Federal State. The Serbs maintained that the Muslims and the
Croats had acted unconstitutionally by declaring their
independence from Yugoslavia 1991 and seeking international
recognition of their independent state. In February, just
before the formal referendum on the sovereignty of Bosnia
-Herzegovina required by the European Community as a precondition
of recognition, the Serbs in the area changed the name of their
autonomous region to the Republic of Srpska. On February 29,
1992, the formal referendum was held on the issue of Bosnia
-Herzegovina's sovereignty as an independent state. 69% of the
electorate is reported to have voted, with 99% of those voting
for independence. The Bosnian Serb leadership directed that the
Serbian population was not to participate in the referendum. The
lack of Serbian participation was later used by the Bosnian Serb
leadership to question the constitutionality of the referendum.
The five Muslim members of the election committee from the
Prijedor area were all later detained in Omarska and Keraterm,
the two men were both killed, the three women all survived
detention at Omarska.

3.6. During this same time frame, the Serbs in the Prijedor
began to establish a local government administration that was
parallel to the existing authorities in Prijedor. This included
a pure Serbian police force at nine police stations, with secret
service functions. In addition to this shadow of government,
during the Spring of 1992 "Crisis Committees" was to direct the
activities of local Serb controlled agencies, including police
and military/paramilitary units.

3.7. During the Spring of 1992, tensions were increasing all
over Bosnia-Herzegovina, and in particular in the Prijedor
region. There were many causes for increasing severity of the
situation, but primarily among them were:

3.7.1. The takeover and control of the television transmitter
of the Kozara Mountain by a very small Serbian paramilitary
group. As a consequence, the population in the district could
not receive television programs from Sarajevo or Zagreb any
longer, only from Belgrade and Banja Luka. Those who watched
the broadcasts from Belgrade reported that the television
programs suggested that non-Serbs wanted war and were planning
the extermination of the Serbs.

3.7.2. The recognition of Bosnian independence of April 6,
1992, by the European Community and the United States and the
declaration the next day by the Serbs of the independent Serbian
Republic of Bosnia-Herzegovina.

3.7.3. The order one week later, by the Bosnian Serb government
for mobilization for war.

3.7.4. The erection of roadblocks on all main roads in Opstina
Prijedor.

3.7.5. The direction from the Serbian authorities that all non
-Serbs should turn in their weapons.

3.7.6. The ultimatum issued by Col. Vladimir Arsic, a JNA
brigade commander, that all soldiers returning from the war in
Croatia were to be redeployed around the Prijedor rather than
demobilized as demanded by local authorities. Within in two
weeks, United Nations Military Observers withdrew from Banja
Luka.

3.8. The final events that preceded the takeover by the
Serbians of the Prijedor area were:

3.8.1. The report by Radio Sarajevo on April 29, 1992 that a
forged facsimile was being circulated which purported to be
orders for the Bosnia-Herzegovina Territorial Defense (non-Serb)
to attack the JNA. The Bosnian government strongly decried the
facsimile as a hoax and stated there had been no orders issued.

3.8.2. The acceptance of the Republic of Bosnia-Herzegovina,
with the consent of Belgrade, as a full member of the Conference
on Security and Cooperation in Europe.

3.9. During the day of April 30, 1993 Radio Prijedor broadcast
repeated announcements that non-Serbs should turn in their
weapons. Many non-Serbs were visited by Serbs, identified as
"officials," and "encouraged" to turn in their weapons.
Overnight, the Serbs seized power in Prijedor. The following
morning Serbian flags were flying on all official buildings and
Radio Prijedor broadcast announcements that the Serbs had taken
control of the area and it was then to be called Srpske Opstina
Prijedor. As an immediate consequence of the takeover, all non
-Serbs in official positions, such as police and government
administrators, were dismissed from their jobs. Within days of
the takeover, most non-Serbs were fired or laid off from their
jobs regardless of their stature.

3.10. Immediately after the takeover, communications between
Prijedor and the outside world were cut off. The telephone
system was no longer full operational, the media was completely
Serbian controlled, and travel was curtailed for non-Serbs. A
curfew was introduced to Prijedor city.

3.11. As these measures were implemented, a number of lists
were compiled by the Serbs. As stated above, even before the
takeover, Serbs had started to visit the non-Serbs who were
licensed to hold weapons and demand that they give up their
weapons. This process was intensified after the takeover, and
combined with a campaign where non-Serbian police and local
defense forces were instructed to hand over their weapons. The
names of all those that were believed to have possessed weapons
were placed on a list, regardless of whether they, in fact, had
any weapons or turned them in as instructed. The names of all
those who were fired or laid-off from their jobs in the area
were put on "waiting lists." These various lists were
reportedly later used at the detention camps to identify and
classify people. The non-Serb policemen were also informed that
they had to sign an oath of loyalty to the new Serbian
government, which most refused to do. Later they were among the
first groups to be persecuted and killed.

3.12. As a result of all of this, many of the Muslim villages
in the area erected their own roadblocks on the village
outskirts to protect the villages from the roaming bands of
gunmen. Until the incident at Hambarine, discussed below, were
there no major incidents reported at any of these roadblocks.

3.13. On 4 May 1992, Belgrade ordered the complete withdrawal
of "all JNA personnel within 15 days who were citizens of the
Federal Republic of Yugoslavia." As a result, several high
ranking officers "retired" and took positions in the Bosnian
Serb Army. Following the "withdrawal," the local remnants of
the JNA, with all their JNA armaments and equipment, were
converted into the Army of the Serbian Republic of Bosnia
-Herzegovina. The new army commander was General Ratko Mladic,
who at the time of the takeover was head of JNA Knin Corps. The
JNA Fifth Corps in Banja Luka became the Ist Krajina Corps under
the command of Maj. Gen. Momir Talic. The Ist Krajina Corps had
two divisions: the 30th and the 10th which included the 1st and
2nd Armored Brigades. These two brigades reportedly causes much
of the subsequent destruction in the area. The 43rd Motorized
Brigade was stationed in Prijedor and was actively involved in
the fighting in Hambarine, Kozarac, and Kurevo. Several
paramilitary groups are alleged to have operated in the area,
including Arkanovci, the Marticevci, the Seseljovci, and the
White Eagles.

4. MAJOR MILITARY OPERATIONS IN THE PRIJEDOR AREA:

4.1. HAMBARINE - On 22 May 1992, a car with four Serbs and a
Croat was stopped at a Muslim checkpoint on the edge of
Hambarine. After words were exchanged, one of the Serbs opened
fire and in the ensuing gunfight, two of the men in the car were
killed. Shortly thereafter, Serbian authorities went on the
radio and demanded that Aziz Aliskovic (a former non-Serb
policeman) be turned in for shooting within 24 hours, despite
the fact that there was no evidence that he was involved in the
incident. Almost as soon as the deadline passed, the Serbs
launched a large artillery and tank assault on Hambarine which
lasted for two days followed by rampant pillaging. Much of the
village was destroyed in the shelling and most of the
inhabitants fled to other villages or to the nearby woods. On
23 May 1992, the Serbian authorities arrested Muhamed Ceharic, a
Muslim and the former mayor of Prijedor, and charged him with
arranging the attack on Hambarine. Ceharic was later killed.

4.3. PRIJEDOR CITY - On 23 May 1992, an ultimatum was issued to
the city of Prijedor. On 30 May, a small group (50 to 150) of
poorly armed local Muslims and Croats attempted to reenter the
city to take control of the central part of Prijedor. The Serbs
quickly put down this attempt with tanks and soldiers from the
Banja Luka corps as well as other units. Radio Prijedor
announced that the "attack" was committed by Green Berets
(Muslims) and Croatian HOS troops. The Serbs then used this
action as a pretext to destroy much of Muslim areas of the city.
A subsequent radio announcement claimed that certain areas of
town were in particular danger (Muslim dominated suburbs -
Stari Grad, Skela, Gomjenica, Puharska, Raskovac) and said all
the residents would be evacuated for their safety. Most of
those "evacuated" were taken to Trnopolje, Keraterm, or Omarska.
Later, a commission was formed to decide what to do with all the
damaged buildings. The majority of non-Serb homes and
businesses were destroyed on the basis that they had been too
badly damaged in the fighting. Serbs were compensated for their
property that was destroyed, non-Serbs were not.

4.4. VILLAGES ON THE LEFT BANK OF THE SANA - On 20 July 1992,
most of the non-Serb villages on the left bank of the Sana
suffered the same fate. Here, however, the fighting was done
primarily by infantry, regular army and paramilitary units, and
the shelling and artillery was not used as it had been in
Kozarac. Before the offensive there had been approximately
20,000 non-Serbs in these villages. (Ljubija, Biscani,
Rizvanovici, Tukovi, Sredice, Hegic, Kadarici, Durtovic,
Carakovo, Zekovi). During and subsequent to the attack, the
homes and businesses were plundered and those inhabitants not
killed were sent to camps.

5. THE CAMPS:

5.1. There were three main camps in the Prijedor area:
Omarska, a former mine complex; Keraterm, a former ceramics
factory; and Trnopolje, a complex of several buildings,
including a former school and the grassy fields that separated
and surrounded them. The primary purpose of both Omarska and
Keraterm was to incarcerate any male member of the non-Serb
population of the Prijedor area who was in any way perceived to
be a potential threat. This generally meant all non-Serb males
between the ages of 16 and 60.

5.2. Some non-Serb males who were well known or well connected
to Serbs were allowed to go to Trnopolje with their families and
then were normally sent to the Manjaca camp prior to their
release. The difference in Omarska and Keraterm seems to have
been that Omarska was where those who were considered to be
leaders or prominent citizens in the non-Serb community, or had
actively resisted the Serb takeover, were sent. Many of those
individuals did not survive. Keraterm was where the remaining
male population was held. Throughout the time the camps were
open there was regular communication, cooperation and the
transfer of prisoners among them as prisoners were interrogated
and their "status" determined.

5.3. The violations of international humanitarian law in
Omarska and Keraterm followed a pattern that was strikingly
similar. Prisoners were usually beaten as they disembarked from
the vehicles that transported them to the camp. There are also
reports of people being executed immediately upon arrival. The
prisoners in Moarska and Keraterm were generally denied food or
water for the first 48 to 96 hours and thereafter were given
very little water (usually contaminated) and starvation rations,
consisting of 1/8 of a kilo of bread and a cup of watery soup
per day. Most prisoners were robbed of their valuables and
identification papers either before they arrived at the camp or
immediately upon their arrival. Most were registered by the
camp officials upon their arrival (normally that is when they
were deprived of their possessions), although there were cases
where it was more than a week before some prisoners were
registered. In Omarska and Keraterm, the first interrogation of
a prisoner was normally conducted within the first 96 hours, but
again, there were cases where some prisoners were not
interrogated until they had been in camp for some weeks. It is
reported by the first prisoners in Omarska that there was a team
of Serbian military and police officials from Banja Luka who
stayed at the camp for the first month to train the Omarska camp
staff on how to conduct interrogations and operate the camp.

5.4. According to most prisoners the interrogations were
conducted by members of the Serbian army or police. Many of the
army personnel were reservists who were teachers or policemen.
In one case the interrogator was a film director. During the
interrogation in Omarska and Keraterm, the prisoners were
frequently beaten/tortured by soldiers who were present in the
interrogation room. It appears that some but not all of the
interrogators also participated in the beating/torturing of the
prisoners. The severity of the beating or torture seems to have
been related to the prisoners classification within the camp.
The wealthy, intellectual, and politically active seem to have
been the most severely tortured and many did not survive. The
next class of prisoner were those suspected of armed resistance
against the Serbs or planning the resistance. Within that
group, those people who were not executed or tortured to death
immediately upon capture or arrival at camp, were subjected to
very harsh beatings and torture. The final category of
prisoners were those who, according to the Serbs, "could not be
proven guilty." The severity of their treatment seemed to
depend on whether they stood out for any reason, any of the camp
personnel either had a grudge against the prisoner, or
alternatively, liked the prisoner.

5.5. The beatings/torture, both in the "formal interrogations"
and by the guards throughout the camps, generally involved the
use of blunt instruments (e.g., iron bars, truncheons, table
legs, police batons, rifle butts), with knives also frequently
used. The beatings/torture were intended to either cause death
or inflict permanent and debilitating injury, and not just
pain. Beatings with the blunt instruments were focused on the
joints of the legs, the kidneys, the spine, and the head. The
most common use for knives seem to be to sever tendons in the
knee and ankles or mutilate the major muscles of the legs. On
occasion the joints in the arms were also the target of knife
attacks. There are also many reports of murders committed by
slitting the throats of prisoners. Finally, there are widely
witnessed reports of mass executions in both Keraterm and
Omarska.

5.6. The concentration camp premises were sometimes so packed
with people that no more inmates could be crammed in. At least
on one occasion this allegedly resulted in an entire bus-load of
newly captured people being executed. Some 37 women were
detained in Omarska, while no women were detained in Keraterm
for more than a very short period of time while awaiting
transportation to another camp.

5.7. The women's groups were normally taken to the Trnopolje
camp. Here the regime was better than in Omarska and Keraterm,
nonetheless harassment and malnutrition was a problem for all
the inmates. The raping of women at Trnopolje, usually
involving gang rapes, was a regular occurrence for most of the
time the camp was open. Beatings and other kinds of torture and
even killings also occurred. Some of the detained women were
released after a few days as there was also a lack of space in
Trnopolje camp almost immediately after it opened.

6. TADIC:

6.1. When the actions of Dusan "Dule" TADIC, as described by
the eyewitnesses and set forth below, are considered within the
above-outlined context, they provide an explicit picture of the
final phases of the systematic attack against and destructive
persecution off the non-Serb civilian population in the Prijedor
region.

6.2. Prior to the takeover in Prijedor, Dusan "Dule" TADIC was
known as the owner of a cafe and a part time Karate instructor.
He was an officer in the reserve militia and had served as a
policeman in the Kozarac area. Although he had very good
relations with the Muslim population prior to 1992, at the start
of the tensions in the area he banned Muslims form his cafe.
(In respect of the foregoing [6.2], I relied on the documents
and statements cited in paragraphs 1.5.1; 1.5.2; 1.5.3; 1.5.4;
1.5.5; 1.5.7; 1.5.9; 1.5.10; 1.5.11; 1.5.13; 1.5.15; 1.5.16;
1.5.17; 1.5.18; 1.5.19; 1.5.20; 1.5.21; 1.5.22; 1.5.23; 1.5.24)

6.3. Witnesses have reported that prior to the Serbian
referendum in November, 1991, Dusan TADIC, along with his
father, Ostoja, was among those going to each Serb residence
counting the electorate and ensuring they intended to vote. It
is alleged that strong pressure was utilized to ensure all would
vote. TADIC was also involved in the creation of the death
lists of intellectuals and other prominent Muslims form the
Kozarac area. (In respect of the foregoing [6.3], I relied on
the documents and statements cited in paragraphs 1.5.1; 1.5.2;
1.5.3; 1.5.4; 1.5.5)

6.4. Eyewitness accounts identify TADIC as being
personally involved in the forced removal of Muslims from the
villages in the Prijedor area and the looting and destruction of
Muslim homes. TADIC was observed to be wearing a military
uniform on these occasions and was noticeably in charge of
whatever group was involved with him, whether it be during the
ethnic cleansing of villages or the torture and murder of
prisoners in the camps. During the forced removal and transfer
of non-Serbs from the villages in the Kozarac area, TADIC and
other individuals acting as Serbian soldiers in the attack were
witnessed to have summarily executed several unarmed non-Serbs
(among the victims were two brother) as those individuals were
complying with the Serbian demands to leave their villages and
move toward Prijedor city. (In respect of the foregoing [6.4],
I relied on the documents and statements cited in paragraphs
1.5.1; 1.5.2; 1.5.3; 1.5.4; 1.5.5; 1.5.7; 1.5.10; 1.5.11;
1.5.12; 1.5.18; 1.5.19; 1.5.21; 1.5.22)

6.5. Eyewitness accounts identify TADIC as being personally
involved in and directing the transfer of non-Serbs from the
villages to the camps. He is identified as conducting
interrogations and beatings of prisoners at both military
barracks in Prijedor and in the camps. He was seen on numerous
occasions in the Trnopolje camp and almost daily (or nightly) in
Omarska. (In respect of the foregoing [6.5], I relied on the
documents and statements cited in paragraphs 1.5.1; 1.5.2;
1.5.3; 1.5.4; 1.5.5; 1.5.6; 1.5.7; 1.5.8; 1.5.9; 1.5.10; 1.5.11;
1.5.12; 1.5.19; 1.5.20; 1.5.21)

6.6 At the Trnopolje camp TADIC was witnessed, on more than
one occasion, to have been involved in the raping of Muslim
women. On one occasion in the Summer of 1992, TADIC was
witnessed to have arrived at the Trnopolje area riding on a tank
with a group of Serbian soldiers. TADIC and the soldiers were
then involved in the rape of some Muslim women at a house
outside the camp. On another occasion in the Summer of 1992,
TADIC arrived at the camp in the company of a guard commander at
the Trnopolje camp carrying a list of names of prisoners, whom
TADIC transported to the Omarska camp. (In respect of the
foregoing [6.6], I relied on the documents and statements cited
in paragraphs 1.5.1; 1.5.2; 1.5.3; 1.5.4; 1.5.5; 1.5.6; 1.5.7;
1.5.8)

6.7. It was at the Omarska camp, however, that TADIC's actions
were most serious. Eyewitness accounts place him at the camp on
almost a daily (or nightly) basis during the period the camp was
open, from late May 1992 until mid-August 1992. At the camp he
was normally observed wearing a military uniform. On occasion
he would wear a black mask. However, due to his notoriety,
physical appearance, and his voice, he was well recognized even
on those occasions when he wore a mask. TADIC beat and
tortured prisoners on a daily basis and is personally responsible
for the murder of more than ten prisoners. The final number is
yet to be determined. The beatings/torture were accomplished
using a variety of weapons, including: truncheons, iron bars,
rifle butts, wire cables, and knifes. In addition, many of the
prisoners who survived the initial beating and torture by TADIC
were subsequently taken to the other buildings in the camp and
were never seen again. Among the most widely witnesses events
that TADIC was involved in was the murder of Emir Karabasic,
Jasmin Hrnjic, and Enver Alic. In June, 1992, those prisoners
were brutally beaten and tortured by TADIC and others, using
metal rods, truncheons, and knives, to the point of
unconsciousness. TADIC then forced a fourth prisoner to drink
motor oil from the garage and then bite off the testicles of the
unconscious prisoners. The three died as a result of their
torture. (In respect of the foregoing [6.7], I relied on the
documents and statements cited in paragraphs 1.5.1; 1.5.2;
1.5.3; 1.5.4; 1.5.5; 1.5.9; 1.5.10; 1.5.13; 1.5.14; 1.5.15;
1.5.16; 1.5.17; 1.5.18; 1.5.19; 1.5.21; 1.5.22; 1.5.23; 1.5.24)

6.8. TADIC did not hold a routine position at the camp, but was
brought in and allowed in for the specific purpose of torturing
and killing those non-Serbs perceived to be part of the
leadership or a prominent part of the Muslim or non-Serb
community. His daily presence in the camp involved the beating,
torture and murder of prisoners. He had the authority to direct
the actions of those men who accompanied him and of the known
camp guards. TADIC was also seen in the presence of the camp
commander, giving directions to camp staff on the arrival of new
prisoners. (In respect of the foregoing [6.7], I relied on the
documents and statements cited in paragraphs 1.5.1; 1.5.2;
1.5.3; 1.5.4; 1.5.5; 1.5.9; 1.5.10; 1.5.13; 1.5.14; 1.5.15;
1.5.16; 1.5.17; 1.5.18; 1.5.19; 1.5.21; 1.5.22; 1.5.23; 1.5.24)

This DECLARATION was signed by the said Michael J. Keegan this
11th day of October 1994 in the presence of:

Witness: /s/John H. Ralston

/s/Michael J. Keegan