Belgrade, January 1998

1.1 The amendments to the Constitution of the SR Bosnia- Herzegovina were adopted in summer 1990(1). The amendment LXIX, item 7, banned (inter alia) forming of political organizations and performing activities aimed at threatening the territorial integrity of the SFRY. This was in compliance with the Constitution of the SFRY.(2)

1.2 Despite this constitutional ban, the B/H Muslims, along with the Croats, were engaged in political and military preparations for forcible secession of the B/H from the SFRY.

The Muslim Party of the Democratic Action (SDA) formed the Patriotic League as its military wing. The forming of the Patriotic League, which was an illegal military organization, started in April 1991. According to his own statement (in the "Oslobodjenje" of September 4, 1992), Munib Bisić, the then assistant minister of defense of the B/H, in association with Sulejman Vranja and some other Muslims, created the Guidelines on Organization and Action in the Field, mostly relying on the SDA members. In May 1991, the organization was named the Patriotic League. Among its founders and organizers were Sefer Halilović (later to become the Chief of General Staff of the B/H Army) and Rusmi Mahmutćehajić, the "political and ideological designer" of the SDA.

According to Alija Izetbegović's statement in the "Ljiljan" journal of Dec. 14, 1994, in June 1991, in the eve of the war in Slovenia and Croatia, the SDA organized a large gathering of "responsible people", which resulted in the founding of the National Defense Council, to manage the operations of the Patriotic League.(3)

Dr. Safet Halilović, in the capacity of Chairman of the SDA Municipal Board in Sarajevo, in his statement for the "Ljiljan" of June 15, 1994, said: "The SDA created the Patriotic League and other formations which served as the core of the future army of the state. All things considered, the role of president Alija Izetbegović and his closest associates was decisive in all stages -- from organization to armament, securing the international support and assistance"...

In Sefer Halilović's book "The Cunning Strategy", it is said that in October 1991 the Patriotic League formed the regional military headquarters for the Sarajevo region, municipal military headquarters, as well as area, maneuver, special, terrorist and anti-terrorist units, branch units, and logistic bases. (5)

1.3 The Patriotic League Political Headquarters was led by Omer Behmen and Ejup Ganić, and the Military Headquarters by Sefer Halilović. They were closely connected with Alija Izetbegović and other high officials of the SDA.

In early summer 1991, the Patriotic League organized secret armament of the Muslims in the Mostar and Herzegovina region, in coordination with an illegal military organization in Čitluk, encompassing a group of Croats from Herzegovina. By autumn 1991, the whole of the B/H was included in armament, with the arms pouring in through various channels, mostly from Croatia.

For Muslims from certain towns in the B/H the Patriotic League secretly organized training in the Croatian Ministry of the Interior and in the towns of Kumrovec, Lučko and Rakitje. As of autumn 1991, the Patriotic League started recruiting the Muslim officers having deserted from the JNA. From April to September 1991, three or four groups of 15 to 20 young men were sent to Libya for terrorist training.

The Patriotic League had a crisis headquarters which created a pattern of headquarters in regions and municipalities, with instructions on the composition, resources, communications and basic activities. The pattern and instructions were adapted for underground activity. In parallel with that, special units of the Patriotic League were formed.

The military structure of the Patriotic League included various units: the "Green Berets" (led by Emin Švrakić), the "mujaheer" volunteer units, rear services, special, medical and other specialized units, the "Bosnia" military organization (led by Kerim Lučarević), and other.

The leaders and members of the Patriotic League, when joining the organization, had to take "oath to the Muslim people". Among the Patriotic League's commanding officers and soldiers in charge of the military tasks in the field were some notorious pre-war criminals, including Jusuf-Juka Prazina, Ramiz Delalić and others.

The Patriotic League achieved a high level of military organization. According to Sefer Halilović's statement to the "Naši Dani" journal of Sept. 25, 1992, when the war broke out, the Patriotic League had 9 regional and 103 municipal headquarters and 98.000 soldiers (the Republic of B/H had a total of 109 municipalities).

Additional proof of the existence and activity of the Patriotic League and its military formations before the outbreak of the war in the B/H can be found in the fact that upon the armistice, when it came to solving the status of the Armed Force soldiers, among the issues raised was that of the "participation in the defense of the country before the state of war was declared".(6)

1.4 In May and June 1991 in Sarajevo, a unit of "Green Berets", at the time still dressed in civilian clothes, were practicing to handle weapons, in the cinema hall of the Bistrik cultural center (Dragice Pravice street). The training was organized in secrecy, in evening hours, and no strangers were allowed in the hall. (7)

1.5 According to the statement that Munib Bisić, one of the Patriotic League founders, gave to the "Oslobodjenje" journal of Sept. 14, 1992, the Patriotic League urged that the war in the B/H should start parallel with the development of war operations in Croatia.(8) They also urged that the bridges on the Drina river should be torn down, but this was not allowed due to "political" reasons, since "Bosnia was not ready for the war, from the military, political or psychological point of view." In early 1992, the Patriotic League "came up with a plan to block communications and the barracks in order to prevent the JNA's strategic operation of taking up combat positions", but the "political factor" denied the green light for the realization of this plan, "seeking to avoid conflict with the JNA". In conclusion, Bisić stated that "Izetbegović's option" was wiser.

The above facts clearly indicate that the Patriotic League, an illegal organization at that point, made plans for unconstitutional and forcible secession of the B/H from the SFRY, and that the B/H Muslim and Croat political leadership was involved in its implementation, including Alija Izetbegović, President of the Muslim Party of the Democratic Action and the then President of the Presidency of the B/H. Izetbegović was only wiser in choosing the timing and methods for breaking up the SFRY. (9)

1.6 The Hasana Brkića Street, one of the largest in Sarajevo, has recently been renamed into the Street of the Patriotic League. (10)

2.0 Even before the outbreak of the war, the Muslim and Croatian representatives in the government in Sarajevo and illegal military organizations took coordinated actions aimed atforcible unconstitutional secession from the SFRY. They jointly started committing crimes against Serbs, who stood in the way of the achievement of their political goals. It has already been stated that the Muslim SDA, as the ruling party, created the Patriotic League as an illegal military organization, and that among its founders was Munib Bisić, the then assistant minister of defense of the B/H. It has also been said that Alija Izetbegović himself confirmed his involvement in organizing the Patriotic League.

2.1 Although the Ministry of the Interior of the B/H (MUP) formally was a single state agency, its activities were subordinated to the interests of the Muslim-Croatian faction. The position of the Minister of the Interior was given to Alija Delimustafić, a former police officer expelled from the force on the grounds of some murky dealings. (11) He and his brothers started a company named "Cenex", dealing in spirit and coffee smuggling, illegal exchange dealings, while illegal import of arms went through this company. As debt collectors for the "Cenex" company, Delimustafić used two criminals - Jusuf Prazina, a convict released from serving the full sentence, and Ismet Bajramović. Delimustafić gave significant donations to the SDA and for that reason, when Izetbegović took power, he appointed him as minister of the interior.

The deputy minister of the interior, Vitomir Žepić, a Serb, had no influence whatsoever on the MUP operations, especially as the under-secretary in charge of state security was S. Škipina. (12)

The head of Security Center in Sarajevo was Bakir Alispahić, a close associate of Alija Izetbegović.

Munir Alibabić was head of the state security in the Sarajevo Security Center, Mirsad Srebreniković was the assistant minister of the interior, Jusuf Pušina was the assistant minister in charge of law enforcement (after Delimustafić, he was appointed as minister of the interior), while Abdo Habib was the assistant minister in charge the police force. (13)

2.2. Before the start of the war, Hilmo Selimović, who had direct contacts with Alija Izetbegović, was appointed head of the Personnel Department of the B/H Ministry of the Interior.

Selimović embarked on urgent dismissals from the MUP of the Serb officers and with no previous procedure appointed SDA members to the leading positions.(14)

2.3 Towards the end of 1991 and at the beginning of 1992, while the position of the Minister of the Interior was held by Alija Delimustafić, there was a ban on any operations aimed at discovering and reporting of criminal activities involving the SDA and the HDZ.

During the second half of 1991, a private business in Sarajevo, under the guise of collecting payments for automobiles, conned citizens out of DEM 6 million and gave this money to the SDA for the purchase of arms in Slovenia. For this criminal activity no criminal charges were brought before the competent prosecutor's office, and as a result, the police operative work was stopped.

Munib Alibabić as well, as head of the State Security Police, halted the police activities directed at discovering criminal dealings for the benefit of the SDA, especially those related to illegal procurement of arms. Some involved in arms smuggling were caught and arrested, but were immediately released. (15)

2.4 Considerably before the international recognition of the B/H, the "Green Beret" soldiers took over the securing of the highest state agencies in the B/H: the Assembly, the Presidency, the Government, the Ministry of the Interior, as well as the Radio and Television and other media buildings in Sarajevo.

At the beginning of January 1992, under the guise of providing security, the "Green Beret" soldiers occupied the premises of the RTV Sarajevo (till then, security had been provided by the MUP). They searched people, made lists of unwanted Serbs and maltreated them.

In this way, the RTV Sarajevo became an instrument of Muslim propaganda in the preparations for forcible secession from the SFRY and creation an independent state, in keeping with the policy of the SDA.

Zdravko Šipka, the RTV head of security, tried to confront this. In spring 1992, he was liquidated by the "Green Berets".

At the time, Sarajevo was flooded with people in "green beret" uniforms, as well as with civilians -- Muslims and, to a lesser extent, Croats, who were publicly carrying arms. They were stopping vehicles, asked people for IDs, and searched them.

The majority of the "Green Berets" were pre-war criminals. Some had been released from serving the sentence immediately before the war.

In March 1992, Esad Osmanbegović, warden of the Central Prison in Sarajevo, released 69 Muslim prisoners and supplied them with guns from the Prison's warehouse. (16)

2.5 At the meeting of the Military Area Staff and members of the Presidency of the B/H, held on January 20, 1992 in Sarajevo, the Command representative informed the Presidency members of the forming of the military area and pointed out the obligation of the military to defend the state of SFRY, emphasizing that the JNA refused to accept violence and that the future of the country should be decided by the politicians.

This position caused violent reaction by the Croat and Muslim members of the Presidency. Alija Izetbegović said that he did not recognize Yugoslavia, since "it did not exist any more". (This happened much before the referendum on the secession of the B/H from the SFRY, of February 29 and March 01, 1992, and the international recognition of the B/H of April 6, 1992.)(17)

2.6 On March 1 1992, on the day of the referendum on the so- called "independent and sovereign" B/H (to which only B/H Muslims and Croats turned out), the first assassination of a Sarajevo Serb was committed, by the illegal Muslim military formation, the "Green Berets".

On that day, Nikola Gardović was marrying off his son Milan. When the wedding guests, after the church ceremony, headed for a restaurant close to the City Hall in downtown Sarajevo to have lunch, they were attacked by armed Muslims who tried to seize their flag, which was folded around the mast. One of the attackers fired four shots at Radenko Mitrović, the priest, while Ramiz Delalić, nicknamed "Ćelo", a pre-war criminal, one of the leaders of the "Green Berets", shot Nikola Gardović who soon passed away. One of the attackers said to the present Serbs: "We shall kill you all."

Some of the Serbs ran after Delalić and other attackers, but a uniformed policeman with an automatic rifle stopped them, instead of taking measures to arrest the perpetrator of the crime.

Although this event aroused great disquiet among the Sarajevo Serbs, none of the attackers was arrested in order to be brought to justice, while Gardović's killer Delalić, later to become a military commander in the B/H Army, boasted about this murder in front of the cameras of TV Sarajevo.

The above stated facts clearly indicate that this was a premeditated criminal act aimed at intimidating the Serbs, in the preparations for the forcible unconstitutional secession of the B/H from the SFRY.

2.7 According to reliable evidence received from witnesses, the plan was to slaughter the Sarajevo Serbs in the night between March 3 and 4 1992.

When Alija Izetbegović was told by the representatives of the JNA command in Sarajevo that the Command was informed of the plan, on the same night Izetbegović, Karadžić and General Kukanjac addressed the public via television, inviting them to maintain peace and order.

2.8 In the night between April 4 and 5 1992, about midnight, Mustafa Fejzić, encrypting officer in the MUP communications center, circulated a special dispatch to the public security centers in Sarajevo, by order of Avdo Habib, assistant minister of the interior.

Immediately after the dispatch had been circulated, a murder took place in the Sarajevo Novo police station. The victim was Pero Petrović, a Serb, policemen of the Koševo police station, who just happened to be there (he brought in a juvenile delinquent caught in a theft).

In the course of the same night about 150 "Green Berets" were handed out arms and uniforms in the local emergency station. (20)

2.9 The organization behind the Muslim actions and their preparations for the attack on Serbs are also proved by the fact that on April 6, 1992, in front of the MUP B/H building in Boriše Kovačevića street in Sarajevo, arms were publicly handed out to Muslims, upon presentation of their identity cards (proving their Muslim identity).

On that day, the Ministry of the Interior's IDs were also changed. The Muslim employees had already been given badges with their names. The Serb employees were denied access to the building by the "Green Berets".

The "Green Berets" acted similarly in other intuitions as well: on April 12, 1992, the "Green Berets" caught a Serb -- a high official of the Assembly of the B/H, while he was leaving his office; they disarmed him, blindfolded him and took him to a prison where they kept him for four days. On April 17, 1992, the door of the office of the vice prime minister, Miodrag Simović, a Serb, was drilled with bullets, while the files in the office were scattered and some of them were taken away. (21)

2.10 On April 15, 1992, a directive was dispatched to all municipal and district Territorial Army headquarters on behalf of the Presidency of the B/H, directing them to attack the JNA and military installations. For Alija Izetbegović, the directive was signed by the Territorial Army Commander, Hasan Efendić. The directive, among other things, says: "Immediately seize the military warehouses, arms and ammunition, as well as besiege the barracks, take them and capture the JNA soldiers on the territory of the B/H."

At the session of the Presidency of the B/H of April 17, 1992, the JNA representative requested an explanation of the directive, but he received no reply, although nobody denied that the directive existed.

This clearly indicates that the Muslim-Croat leadership in the B/H did not seek a peaceful solution for the withdrawal of the JNA troops from the B/H.

Instead of seeking a peaceful solution, the members of the Muslim-Croat military formations kept attacking the JNA units and installations, as well as those parts of Sarajevo that were predominantly populated with Serbs. On April 22, 1992, a unit of "Green Berets" carried out an armed assault at Ilidža and at the JNA military headquarters in Sarajevo.(22)

2.11. On 26 April 1992 a meeting was held in Skoplje where the representatives of Yugoslavia, Branko Kostić and general Adžić reached an agreement with Alija Izetbegović on peaceful withdrawal of YPA from B/H. 23

2.12 On 2 May 1992 at the meeting in Lisboa, Alija Izetbegović signed an Agreement on future state order of B/H, the so-called Cutiliero Plan, but once he returned to Sarajevo he abandoned it and adhered to the war option.

On 2 May 1992 there were intensive attacks on YPA facilities in Sarajevo, namely: the YPA Centre, buildings of the Area Command and the following barracks: "Maršal Tito", "Viktor Bubanj" and "Jusuf -onlić".

On 3 May 1992, through mediation of the representatives of the international community (general McKezie and Colom Doyle) an agreement was reached on peaceful withdrawal from Sarajevo of military personnel from the Second Army Area, but despite the guarantees received from the representatives of the international community, Muslim-Croat side broke their promise and their military units intercepted an YPA column in the Dobrovoljačka Street. They disarmed and killed members of the YPA.

The commanders of the military units that conducted the attack were Ejup Ganić, Ismet Bajramović, Jovan Divjak, Hasan Efendić, Fikret Muslimović, Zoran +egar and Jusuf Prazina, who had a special role in it. 24

3.0. At the outbreak of war Muslims and Croats from Sarajevo were prepared for the war and the forthcoming mass crimes against Serbs: police forces were almost completely cleared from the members of the Serb nationality (especially from those at high posts), while illegal military forces within the Patriotic League ("green berets" etc.) were strengthened. There also existed armed forces within the Territorial Defense and police reserve force which committed mass crimes against Serbs since the outbreak of war.

These armed forces and groups were mostly headed by pre-war criminals. All parts of Sarajevo under Muslim-Croat command were actually governed by the mentioned military forces and armed groups which set up camps where Serbs were killed and exposed to all kinds of physical and mental torturing and humiliation. Serbs were killed and tortured while being forced to dig ditches and tunnels and at other places, especially at the foot of the Trebević mountain.

The most prominent commanders of the Muslim military forces and groups in Sarajevo were: Jusuf Prazina, nicknamed "Juka", Ismet Bajramović, nicknamed "Ćelo", Mušan Topalović, nicknamed "Caco", Samir Kahfedžić, called "Kruško", Ismet Hadžić, Ramiz Delalić, nicknamed "Ćelo 2" and others.

According to some evidence 25), there were 52 army and police headquarters in Sarajevo, with camps in which a lot of Serbs were .PA

killed. Around 7 000 Serbs are estimated to have been killed in Sarajevo.

It is, however, worth noticing that the B/H Presidency brought a decision on "subordination" of the reserve forces of Ministry of the Interior (MUP) to the General Staff of B/H armed forces and that this decision was published in the "Official Gazette of RB/H", no. 8/92. Thus, we cannot talk of the existence of "uncontrolled groups" since all armed forces both in Sarajevo and the entire territory controlled by Muslims and Croats were under command of the B/H Army.

3.1. Jusuf Prazina, a notorious criminal from Sarajevo, set up a unit of "green berets"at the beginning of war which, under his command, took part in the attack on the YPA facilities and a column during the withdrawal of YPA members from Sarajevo on 2 and 3 May 1992. In the Dobrovoljačka Street, the agreement on peaceful passage of the column was broken and atrocities committed against the members of the YPA.

In 1992, Jusuf Prazina's unit numbered around 2 300 armed men and had 35 bases with camps in the town, among which "Stela" at Otoka, on the premises of the railway-industry school, and the school for the mentally retarded, in "Dragica Pravica" kindergarten, "Iskrica" kindergarten in the Hasan Brkić Street, in the "Amerikanac" restaurant (near the Central Prison), and in the Faculty of Dentistry, etc.

Prazina controlled the entire Centar Municipality and some other suburbs, too.

In the camps under Jusuf Prazina's control mass killings and other atrocities were committed against Serbs. Only Senad Džananović, nicknamed "Glavoguz" /an asshole/, commander of the "Stela" camp, killed around 60 Serbs.

Jusuf Prazina's General Headquarters were at the beginning situated on the premises of "Iskrica" kindergarten, in the Hasan Brkić Street while the military unit of Adnan Solaković, a pre-war criminal and assistant to Jusuf Prazina was on the premises of the Faculty of Dentistry. It was a mujaheden unit.

Nervin Uzunović, nicknamed "Šok", committed the largest number of crimes in "Iskrica" kindergarten.

Fikret Bahtić, nicknamed "Fića", former football player of "Železničar", who was under Jusuf Prazina's command, held the premises of Hrasno and his headquarters were situated in the school for mentally retarded children.

Jusuf Prazina's deputy was Samir Kahfedžić, nicknamed "Kruško" 26 and his unit controlled prisons situated at the "Borsalino" restaurant at the Zavnobih Square, at a supermarket storehouse by the restaurant and at the "Novi Grad" restaurant.

At the end of July or beginning of August 1992 Prazina was appointed a member of General Staff of B/H armed forces. The Act on Appointment was signed by Jerko Doko - defense minister, Sefer Halilović - Chief of General Staff and Jusuf Pušina - minister of the interior of B/H (all put their signatures on the left side of the Act) and Alija Izetbegović (his signature is on the right side of the Act).

After the appointment Prazina got two offices in the building of B/H Presidency where he stayed with his body guards.

Davor Matić was also a member of Prazina's formations. On 22 April 1992 he and his HOS (Croatian Defense Forces) unit captured and killed 8 members of the YPA who were in a personnel carrier which broke down on the way to the airport.

3.2. Ismet Bajramović , nicknamed "Ćelo" (born 26 April 1996 in Sarajevo); was in late eighties sentenced to several years of imprisonment for rape, stealth and robberies. He served his sentence in the Zenica Pentitentiary where he provoked disorder, beat other prisoners, insulted Penitentiary's staff and tried to organize a riot. Before the outbreak of war, he was pardoned by Alija Izetbegović and set at liberty. Alija Delimustafić, minister of the interior, whose body guard he became later on, personally requested his pardon.

Bajramović was engaged in military activities immediately after the referendum on the secession of B/H and as early as 3 March 1992 he distributed weapons among Muslims in the Livanjska Street.

By April 1992 Bajramović had set up his own armed group, made up mostly of criminals, idlers and drug addicts, which grew into a military unit. His headquarters were situated on the premises of "Mladen Stojanović" students dormitory, near the Central Prison. Parts of the municipalities of Centar and Novo Sarajevo - Koševsko Brdo, Ciglana and a part of Velešići were under his control.

Within Barjamović's unit there was the so - called "flying battalion", made up of the most extreme Muslims.

The following men were on Bajramović's headquarters: Fahrudin Alic, nicknamed "Pukovnik" /colonel/ (took part in arresting and torturing a large number of Serbs, and in raping the arrested Serb women), Slavko Erceg (a notorious criminal), Fahrija Kahrim ( a lawyer, Bajramović's adviser), Asko Omerbašić (used to work in MUP) and Dževad Topić (Bajramović's deputy, now in Zagreb as a military attache at B/H Embassy).

At the end of April or beginning of May 1992 Bajramović was appointed head of Military Police for the municipalities of Centar and Novo Sarajevo by official authorities, and on 3 May 1992 - he was appointed head of the so-called Military Prison at the fifth floor of the Central Prison.

Captured Serbs were tortured and killed in the Central Prison ( at least 17 killed Serbs were identified).

A large number of crimes against Serbs were committed in a camp on the premises of former military barracks "Viktor Bubanj". This camp where at least 64 Serbs were killed or disappeared from, was under Ismet Bajramović's control.

When Bajramović was seriously wounded in a showdown between Muslims, Alija Izetbegović issued an order for him to be taken abroad by helicopter for medical treatment. 28, 29

3.3 Mušan Topalović, nicknamed "Caco", controlled the left bank of the Miljacka at the territory of the Municipality of Stari Grad from the beginning of war.

He later became commander of the Tenth Mountain Brigade of the B/H Army.30

Members of Topalović's unit committed mass killings of Serbs - civilians at places called Bistrički Potok, Popov Gaj and Kazani at the Trebevići hill-sides. Victims' bodies were usually thrown into pits.

After the break-up of Jusuf Prazina's unit, some commanders of that unit joined Mušan Topalović's unit. Topalović was very close to general Sefer Halilović, chief of the General Staff of the B/H Army.

During 1992 Halilović often visited Topalović's headquarters.

Mass crimes of Dušan Topalović's unit committed against Serbs were obvious and well-known and Muslim-Croat military and civil authorities in Sarajevo were aware of them.

Instead of being prosecuted, he was killed as an undesirable witness. 31

3.4. Ramiz Delalić, nicknamed "Ćelo 2", one of the commanders of the illegal military formation of "green berets", commenced crimes against Serbs in Sarajevo by killing Nikola Gardović on 1 March 1992 - before the outbreak of war which was the day of the referendum for the secession of B/H from SFRY.32

He was for a while commander of the Ninth Mountain Brigade of the B/H Army.

Members of Delalić's military unit committed a number of crimes against Serbs - civilians in Sarajevo. They also participated in the killing of Serbs at a place below Trebevići together with the members of Mušan Topalović's unit.

In October 1993 Delalić was removed from his office, but he was not even formally prosecuted for the crimes against Serbs. 33, 34

3.5. In the territory of the "Ivan Krnelj" local community a command of the Sixth Muslim Brigade was placed whose commander was Adem Alijagić, and his deputy was Fahrudin Fazlić and assistants - Ante Marjanović and Enver Zornić.

This brigade is responsible for numerous killings of civilian Serbs.

Thus, in the house of Gavra Ćeranić in 24 Varaždinska Street three Serbs -civilians were killed (Sreten Nikolić, Jagoda Janković and Jovan Popović) and their bodies burned. 35

3.6. In the "Razigrani dani" kindergarten a command of the Civil Defense was situated led by Muhamed Poplata, former policeman. This Civil Defense was turned into a Muslim military - police formation of "green berets" which controlled local community of "Koševo II" all the way to the Ciglana suburb.

Members of this unit searched Serbs' flats and arrested them. Huskić Albin, nicknamed "Kinez" /a Chinese/ was commander of this unit whose headquarters were at the Faculty of Physical Education (DIF) where arrested Serbs were taken for the first "interrogation" and were beaten, as well as selected for further "procedure". 30

3.7. Ismet Hadžić, known as religious fanatic, former worker of "Energoinvest" enterprise, was in charge of the Dobrinja suburb.

In this suburb a prison was set up at the "Baltazar" restaurant by the members of Dragan Vikić's unit, "green berets" and "the league of veterans".

Serbs killed at "Baltazar" and "Stela" camps were buried in this suburb.

Hadžić was very close to Alija Izetbegović. 37

3.8. Himzo Ćesko, who was a policeman in Sarajevo before the war, had a team of snipers who shot at Serbs - civilians from high buildings in Sarajevo (the Power Utility building, the "Bristol" hotel, skyscrapers, etc.).

Members of Ćesko's team raided Serbs' flats, searched them, maltreated Serbs and robbed them of their property. 38

3.9. Zahir Puška, who was a criminal before the war, had a unit that controlled parts of Sarajevo - Vasin Han and Zečja Glava. This unit committed crimes against Serbs -civilians in Sarajevo. 39

3.10. Fahro Hadžimehmedović, nicknamed "Profesor", after Jusuf Prazina had left, took over the command of the rest of his unit. His headquarters were in the Masarikova Street, in the ZOIL (Persons and Property Insurance Company) "Sarajevo" building. 39

4.0. Muslim-Croat authorities in Sarajevo - with the prevailing Muslim influence - not only tolerated crimes against Serbs - civilians (or captives) in Sarajevo - by depriving them of any protection, but also committed such crimes. Thus:

4.1. A large number of arrested Serbs-civilians were tortured, maltreated, humiliated and murdered at Sarajevo Central Prison. 41

4.2. A special unit of B/H MUP, under Dragan Vikić's command, participated in the killing of Serbs-civilians in mid-May 1992 at the Pofalići suburb in Sarajevo. A hundred or so Serbs were killed - men, women and children and some of them were tortured. 42

4.3. In the police station of Novi Grad Serbs were tortured and killed.

On 4 May 1992 nine captured YPA members were brought to this station and after being abominably tortured they were killed in the night between 4 and 5 of May.

This police station controlled a camp in "Pavle Goranin" primary school in the Prvomajska Street.

The most extreme criminals who tortured Serbs at this station were: Fadil Plivac, nicknamed "Baj-baj" /bye-bye/ who was a criminal before war 43, Dino Dizdar, Džemo Lagundžija and his brother Jusuf as well as Slobodan Rudo.

Crimes against Serbs were committed in other police stations in Sarajevo, too. 44

4.4. In 1992, within the B/H MUP for Sarajevo district there was a unit for special operations and repressive measures against citizens of Serbian nationality - called "Lasta" (a sparrow). Bakir Alispahić, head of Security Service in Sarajevo, was commander of this unit.

A secret group for "low - profile operations" led by Nedžad Ugljan, deputy head of B/H State Security, worked within the State Security Service.

At the beginning of war, there was a Muslim-controlled group called "King", within the State Security Service, with a task to participate in investigations of Serbs suspected of alledged collaboration with the Serb Security Service.

At the beginning of war Kerim Lučarević, nicknamed "Doktor" /doctor/ was head of the Muslim Military Police and later on Ismet Bajramović took that post. At that time Fikret Muslimović was head of the Muslim Army Security Service and was succeded by Jusuf Jašarević. 45

4.5. When in 1993 Nedžad Ugljanik succeded Joza Jozić, under- secretary of the B/H Ministry of the Interior, he set up a snipers group whose task was to shoot at Serbs in the Serbian part of Sarajevo. 46, 47

4.6. After Alija Delimustafić, Jusuf Pušina was appointed B/H minister of the interior.

Pušina allowed criminal activities of armed groups and individuals against Serbs in B/H and by the nature of his post, he was personally involved in crimes against Serbs committed by the members of MUP.

He was carring out Alija Izetbegović's order not to identify and arrest members of criminal groups, police or military troops, who committed crimes against Serbs, i.e. not to investigate the killings of Serbs in that period.

Senad Džanović called "Glavoguz" - a criminal who personally killed some 60 Serbs - was close to Pušina. (48)

5.0 The Muslim-Croat authorities in Sarajevo were aware of crimes committed against Serbs in Sarajevo and other places. The majority of them was committed by themselves, as well as by the Muslim- Croat Army. The authorities left Serbs without any protection and allowed armed groups and formations to go unpunished for killing and torturing Serbs - civilians and prisoners of war.

The involvement in crimes against Serbs reached as far as the very highest authorities of the B/H state.

5.1 All decisions of the Muslim part of the leadership were taken at the meetings of the core leadership of the Party of Democratic Action consisting of: Alija Izetbegović, Ejup Ganić, Haris Silajdžić, Rusmir Mahmutćehajić, Omer Behmen and, occasionally, Irfan Ajanović. Among Croatian leaders, the most extremist and the closest to the Muslim leading group was Stjepan Kljujić. (49)

5.2 In June 1992, Alija Izetbegović released a statement that "the fifth column" had allegedly infiltrated into the city of Sarajevo and gave an order to destroy and exterminate "the fifth column". This encouraged the most intensive prosecution of Serb civilians in Sarajevo, who were detained, abused, tortured and murdered on the excuse of putting "the fifth column" under control. (50)

5.3 Serbs who were brought from detention camps were engaged in forced labour to dig the tunnel under Butmir Airport which was to connect Dobrinja community with Hrasnica and they had to work day and night without rest.

The person in charge of these works was Bakir Izetbegović, Alija Izetbegović's son.

During the digging, some of the Serbs collapsed from tiredness, lack of sleep and hunger and Bakir Izetbegović ordered their

killings because they were, allegedly, sabotaging, and their bodies were buried under Mt. Igman. (51)

5.4 Jusuf Prazina, a pre-war criminal, at the very beginning of the war was in command of the military troops which participated in the interception of the YPA column in Dobrovoljačka Street where they killed members of the YPA who had been guaranteed a free passage by the highest Muslim-Croat authorities in Sarajevo. After that, Prazina continued with the organized killing and torture of Serbs in Sarajevo.

Prazina had an office in the Presidency building and everybody addressed him as general. In the meetings covered by TV, he was usually sitting in the first row.

By the end of 1992 or beginning of 1993, according to the TV Sarajevo report from a press conference, also attended by representatives of the Muslim Army, a reporter Demirović asked why Jusuf Prazina was not in the presidency of the conference when he was practically the commander of the city. Prazina then stood up in the area where reporters were sitting and showed a piece of paper to TV cameras, claiming it was a decision by president Alija Izetbegović appointing him general and commander of Sarajevo. (52)

5.5 On one occasion, sometime in the middle of 1992, in the detention camp at the Zavnobih Square, in number 27, a Serb who was a friend and a protegee of Jusuf Prazina was killed. When Prazina, upon his arrival in the camp, found out about this, he got mad and said that it was not his order, but that all those evils were done according to the orders of Alija Izetbegović and his associates. (53)

5.6 In sommer 1992, Alija Izetbegović visited military troops on the mountain Trebević together with Biserka Turković (later a diplomatic representative of B/H in Zagreb). On the sites beneath this mountain many Serbs - civilians were killed and thrown into pits. The unit of Mušan Topalović - "Caca" was leading in committing these mass crimes.

During this visit, Izetbegović praised Mušan Topalović before TV cameras, and Mrs. Turković was even more generous in her praises.

According to one testimony, Topalović in his capacity of a military commander never did anything without the consent of Alija Izetbegović ("they were connected by the red telephone"). Even the crimes against Serbs - civilians committed by Topalović's unit were commited with the approval of Alija Izetbegović.

Topalović's mass crimes against Serbs were, otherwise, a common knowledge, and Muslim authorities later staged a trial for several members of Topalović's military unit, aiming at creating an .PA

illussion that the authorities kept a distance from the crimes committed, but that will be specifically discussed later on. (54)

5.7 According to one testimony, Izetbegović ordered the Minister of the Interior Jusuf Pušina not to identify and arrest those who committed crimes against Serbs. (55)

5.8 By the end of 1994, a lawyer Fahrija Karkin was tried in Sarajevo for bribery, drugs trafficking and some other criminal offences and he submitted to the court a document signed by Alija Izetbegović. In that document he - Karkin was asked to find out how many Serbs should be arrested in order to exchange them for Haris Jasenković, a close relative of Izetbegović's wife, who was in the Serb prison in Foča. They made the exchange. In the trial, Karkin proposed Izetbegović as a witness, but the court refused. (56)

5.9 A large number of detention camps for Serbs in Sarajevo (57) and other places under Muslim and Croat control were used for torturing, ill-treating, starving and killing of Serbs - civilians. They were organized by the Muslim-Croat authorities and Army and the authorities were aware of the crimes committed in those camps. Some of these camps were visited by Alija Izetbegović and he knew what was the situation in them. For three or four times, he landed on the helipad adjacent to the camp-silo in Tarčin, made by Serb detainees, and which was known as one of the most brutal camps. This camp was under direct control of 109th mountain brigade of so called B/H Army. In this camp 23 Serbs were killed, starved to death, died of serious bodily injuries or were killed at forced labour. (58)

6.0 An important role in the preparations of Muslims and Croats for the secession of B/H from SFRY and the subsequent civil war, was played by the media in Sarajevo, predominantly under Muslim control, which satanized Serbs and instigated crimes against them. In doing so, lies were the basis of that persistent and unscrupulous propaganda against Serbs.

6.1 In the first part of April 1992 TV Sarajevo reported that there was a massacre of Muslims on the mountain Trebević in the Jarčedol settlement. This was an entirely false piece of news and that was established by the joint commission of the B/H Ministry of the Interior and represenatatives of the YPA. TV Sarajevo had to announce that the news was false, and in the broadcast on the investigation into that news, also a statement of a Muslim (standing beside the Minster of the Interior) could be heard saying that he would kill the general Kukanjac's family in Sarajevo. (59)

6.2 Ramiz Delalić, called "Ćelo", one of the commanders of the "Green Berets" and later a commander of the Ninth mountain brigade of the B/H Army, appeared in TV programmes, publicly boasting himself about participating in the murder of Nikola Gardović on 1 March 1992. This undeniable criminal who participated also in the mass killings of Serbs - civilians on the site Kazani beneath Trebević, appeared in a TV show on TV Sarajevo together with Jusuf Pušina, the Minister of the Interior of so called B/H, to whom he expressed a certain level of intimacy by hugging him. (60)

6.3 Mustafa Memija, a TV Sarajevo reporter, often appeared before TV cameras, with an automatic rifle in his hand, and the announcer of news broadcast Hadžifejzović overtly instigated crimes against Serbs. (61)

7.0 The Islamic religious community took part in pursuing political goals of Muslims in B/H, as well as in crimes against the Serbian people, pursuant to the positions taken in Alija Izetbegović's "Islamic Declaration".

7.1 The meshihat of the Islamic community in B/H - Sarajevo sent out a dramatically worded written appeal (62) to all imams in the territory of meshihat, calling all Muslims to go to a referendum and vote for independent and sovereign Bosnia and Herzegovina "as your future and the future of your religion."

In the closing of the appel, it says: "If we fail this exam, history will not give us an opportunity to take a makeup exam for quite some time." (63)

7.2 Copies of the pocket-size handbook titled "Islamic advice and instructions" were distributed to Muslim soldiers, the publication of which was sponsored by: the Organization of Islamic foundations (vakyfs) for humanitarian aid to B/H, Islamic reif for B/H and the

Muslim charitable society "Merhamet" from Sarajevo. As it says in the prologue of this booklet, the "Advice" was written by Ahmet Izudin El Bejanunja ("he is a famous Syrian alim belonging to an arrey of those who exerted great influence on the group of contemporary Syrian missioners - alims who are regarded as rejuvenators of today's Arab-Islamic society").

This religious handbook contains messages to commanders and fighters, Muslim worshippers:

"He who fails to send a combatant to fight ... shall be cursed by Allah with some disaster. It is also left to the military command to decide whether it is more useful and in the interest of the common cause to release, exchange or liquidate a captured enemy. A believer is not allowed to keep an enemy as POW as long as he has not won the victory on the Earth. It is forbidden to kill women, children and clergymen who neither participate in war nor, directly or indirectly, assist the enemey (their own people...)".

The above messages imply that it is not allowed to keep prisoners of war and that their killing is at discretion of a military command which should be guided by the interests of "the common cause", as well as that not even women, children or clergymen are spared from killing if they in any way help the enemy - their own people (what else could be expected from persons belonging to a nation than to help their own nation?).

The given "advice" constitute direct instigation of Muslim soldiers to kill Serbs, and it is even more dangerous because it comes from the religion and releases Muslims from the fear of God and remorse. (64)

7.3 Reis-ul-ulema effendi Cerić often appeared in the Muslim media, visiting military troops and talking that muslims were waging a jihad (the holy war). (65)

7.4 When the Muslim-Croat authorities in Sarajevo tried to at least formally distance themselves form mass killings of Serbs in Sarajevo (especially those on the site Kazani beneath Trebević), they were holding Ramiz Delalić, a perpetrator of many crimes against Serbs in Sarajevo, in detention for a while, at the end of 1993 and early 1994. Delalić enjoyed privileges in prison and used to say that he was on "Allah's path". To detaineed Muslims, killers from the Topalović's unit, he used to say that they did not commit crime by killing Serbs and that they could not be guilty of that.

This is completely in the spirit of the thesis about jihad (the holy war) and in accordance with the messages form the mentioned

handbook "Islamic advice and instructions" as well as from Izetbegović's "Islamic Declaration". (66)

8.0 The Muslim Army, police, armed groups and individuals were all commiting mass crimes against Serbs in Sarajevo. The killings of unprotected Serbs - civilians were so overt and in order to create an illusion that they were only excesses of individuals and that the Muslim-Croat authorities in Sarajevo were not behind them, the trials have been staged, which deserved that name only by form and which did not aim at the real punishment of perpetrators of genocidal crimes against Serbs.

8.1 Thus, in 1994, five Muslims were tried before the Higher Court in Sarajevo for killing six members of the Ristović family on 8 July 1992, who were found at home at lunch. Two of them (Admir Adilović and Ismet Ćutuk) were acquitted, one (Mirsad Hodžić) was sentenced with security measure of compulsory psychiatric treatment, and the remaining two (Osman Hodžić and Meho Ibišević) were subjected to separate proceedings, since they were allegedly on the run. (67)

Sefer Halilović in his book "The Shrewd Strategy" (68) speaks about the killing of the family Ristović and says:

"The very same day, I personally informed President Izetbegović in detail about the Ristović case. First verbally, and then in writting, and after that all other members of the Presidency,who then continued to pressurize minister Pušina to take action, since it was not within the jurisdiction of the Army.

Seven months later, on 20 January 1993, to be precise, Bakir Alispahić, head of the Public Security Service in Sarajevo, lays criminal charges against five persons.

The investigation revealed that the murderers of the Ristović family were all members of B/H MUP, more specifically, of the public security station Marin dvor." (69)

8.2 On the sites Bistrički potok and Kazani, beneath the Trebević mountain in Sarajevo, mass killings of Serbs - civilians were commited and their bodies were thrown in pits. The bodies were also partially burned by setting on fire old car tyres thrown over them. These crimes were commited mostly by members of military troops (10th mountaineous brigade of the First Corps of so called B/H Army) under the command of Mušan Topalović - "Caco". The "elite company" of this unit commited the largest number of crimes.

Fourteen soldiers of the above mentioned military unit were tried for these crimes before the District Military Tribunal in Sarajevo (the verdict was passed on 23 December 1994). Although Serbs - civilians were mass killed on the mentioned sites (70), forensic experts (71) exhumated the remains of only 29 massacred bodies, 8 of which were identified. The exhumation, led by the investigative judge of the Military Tribunal Šerbet Nihad, was suddenly interrupted following the order of the Presidency of B/H, according to the witness 449/97-2 who was well informed of this matter, because he held a high post in Sarajevo during the war.

They were not indicted either of genocide or of war crimes, but of murders commited in a brutal and cruel manner. And the court even found that those were not murders commited in a brutal and cruel manner, despite the findings of experts according to which the bodies of the victims were massacred. The following verdict was passed: (72)

Zijo (father's name Jusuf) Kubat, Refik (Mehmed) Čolak, Esad (Bešlija) Tucaković i Mevludin (Salko) Selak were each sentenced to 6 years of imprisonment for murder (the least serious form of the felony), Omer (Meho) Tendžo i Asif (Began) Alibašić - each to 4 years 4 months of imprisonment for assisting in murder and failing to report a felony or a perpetrator, Senad (Redžep) Hasić, Samir (Mustafa) Seferović, Sabahudin (Remzija) Žiga, Samir (Muhamed) Ljubović, Esad (Nusret) Raonić i Senad (Fadil) Haračić - each to 10 months of imprisonment for failing to report a felony, Armin (Sead) Hodžić - to 5 years 8 months for murder (co- perpetrator) and failing to report a felony and Sead (Hamdija) .PA

Kadić - to 4 years imprisonment for murder (co-perpetrator). Samir Seferović and Sabahudin Žiga were acquitted of the murder charge.(73)

While the relatives of some of the murdered Serbs, present in the court room, expressed their dissapproval with the verdict, accused Samir Seferović approached the President of the court council, Muhamed Podrug and, in order to show his gratitude, shook hands with him and than with other members of the council.

The above stated conclusion is additionally confirmed by the fact that even such mild sentences were not served till the end. After only a year, almost all of the sentenced, who were still in prison, were released. The decision on their release was taken by Alija Izetbegović just befor the New Year 1996. (74)

Apart from formal - symbolic trials against some direct participants in mass killings of Serbs in Sarajevo, other more reliable form of destroying evidence of the involvement of the state of so called B/H in these crimes was the liquidation of the commanders of military troops which commited these crimes. They were first encouraged to commit crimes against Serbs and then, upon the completion of their assignment, as unpleasant witnesses - liquidated.

Jusuf Prazina left Sarajevo at the end of October 1992, on order of Alija Izetbegović (the order was transmitted to him by Rusmir Mahmutćehajić, Vice Prime Minister of the Government of so called B/H), and was killed later on in Belgium.

In October 1992, civilian police surrounded the building in which were Mušan Topalović and his headquarters and after an armed clash in which several policemen were killed, Topalović surrendered and soon afterwards was killed. He spoke to Alija Izetbegović before he was killed.

Samir Kahfegžić was killed by Muslims on the mountain Igman.

Mišo Davorin, also a participant in crimes against Serbs, was killed in Sarajevo.(75)

Footnotes:

1) Official Journal of the SR B/H, no. 21, of July 31 1990

2) Evidence: Committee file no. 121/97

3) Alija Izetbegović was elected head of the Council, while Ejup Ganić, Rusmir Mahmutćehajić, Haris Silajdžić, Muhamed Čengić, Salem Šabić and Sulejman Ugljanin were elected members.

4) Sarajevo, 1997, p. 65

5) Evidence: 308/96, 407/96, 198/97, 479/97

6) Evidence: 308/96, 407/96, 198/97 and the "Slobodna Bosna" journal

7) Evidence: 175/97-3

8) Back in April 1991, he attended the formation of the Patriotic League for the Tuzla region in the village of Memići, outside Kalesija.

9) Evidence: 308/96

10) Evidence: 30/97-1

11) According to the Law on the State Administration of the B/H, this position required 5 years of work experience and a university degree, which Delimustafić did not have.

12) Who immediately started to create lists of the Serbs to be arrested and organize bugging of both private and service telephones of all the Serbs in high positions.

13) Evidence: 162/96-4, 407/96, 374/97

14) Evidence: 162/96-4

15) Evidence: 162/96-4

16) Evidence: 407/96

17) Evidence: 174/97-1

18) Evidence: 386/96-19, 390/96, 478/96-20, 478/96-27

19) Evidence: 174/97-1

20) Evidence: 162/96-1

21) Evidence: 407/96

22) Evidence: 174/97-1, 198/97

23) Evidence: 96/97

24) Evidence: 281/96-1, 665/95, 196/95, 174/97-1, 243/97-1

25) Evidence 162/96-5

26) In the night between 25 and 26 June 1992 when Kahvedžić was celebrating his birthday at the "Borsalino" cafe, beneath which was a notorious camp for Serbs, Jusuf Pušina, one of the highest B/H MUP officials at the time, who soon after became Minister of the Interior of B/H, also came to that party; other notorious Sarajevo criminals who ruled the town, were also present there - Senad Džananović, Gadžo Adnan, nicknamed "Kimun" etc. The beaten up witness 162/96-6, who was kept in the "Borsalino" camp, was brought before them.

27) Evidence: 162/96-2, 162/96-3, 196/95, 341/96-1, 600/96-2, 649/96, 162/97, 374/97, 449/97-2, 806/95-2

28)"When I once happened to be near Ismet Bajramović I heard Muhamed Kruševljaković, mayor of Sarajevo, call him on a portable radio station (motorola) and told him to come at once to a meeting at Alija Izetbegović's" (witness 872/95-1).

29) Evidence: 162/96-2, 162/96-3, 391/96-4, 478/96-2, 478/96-27, 516/96-3, 600/96-2, 374/97, 872/95-1, 420/96, 421/96

30)In one TV show Alija Izetbegović called him son (evidence 806/95-3)

31) Evidence: 162/96-3, 162/96-10, 514/96-33, 478/96-27, 440/97-2, 806/95-3

32) Before the war, between 1984-1991 he was convicted five times, the last time he was sentenced to one year in prison, in Belgrade in 1991 for robbery of a minor. A request for the enforcement of this sentence was returned from Sarajevo in 1991 with a police report stating that Delalić was "unknown".

33)He lives in Sarajevo now and owns one of the most eminent cafes there.

34) Evidence: 334/96-5, 390/965, 478/96-27

35) Evidence: 649/96-36,

36) Evidence: 600/96-2

37) Evidence: 162/96-3, 649/96

38) Evidence: 408/96-44

39) Evidence: 162/96-9

40) Evidence: 162/96-3

41) Evidence: 806/95-7, 806/95-10, 806/95-11, 872/95-3, 750/95

42) Evidence: 799/95-11, 806/95-7, 10, 12, 13

43) Plivac, born in 1945, was 6 times since 1965, sentenced to the total of 19 years and 10 months in prison without the right to parole. The sixth time he was sentenced to 15 years in prison by the High Court of Sarajevo on 4 April 1990 for murder for gain committed on 18 August 1987 (he strangled the victim with a tie before taking away his money) only to be released from the Foča Penitentiary on 12 April 1992 by the decree signed by B/H minister of judicature.

44) Evidence: 649/96, 243/95-2, 281/96-9

45) Evidence: 162/96-2,

46) Evidence: "Dragan and Boris Šošić, the Croats, were particularly active as snipers".

47) Evidence: 806/95-2

48) Evidence: 162/96-3, 162/96-4

49) Evidence: 174/97-1

50) Evidence: 649/96

51) Evidence: 649/96

52) Evidence: 162/96-5, 281/96-1

53) Evidence: 660/95-1

54) Evidence: 281/96-1, 334/96-5, 198/97

55) Evidence: 162/92-4

56) Evidence: 649/96

57) According to the documentation of the Committee on Collecting Data on Crimes Commited against Humanity and International Law, there were at least 104 detention camps for Serbs in Sarajevo.

58) Evidence: 109/96, 385/96-3, 385/96-2, 407/96

59) Evidence: 174/97-1

60) Evidence: 478/96-27

61) Evidence: 281/96-1

62) number 428/92 of 19 February 1992

63) Evidence: 279/95-22

64) Evidence: 82/95-1

65) Evidence: 281/96-1

66) Evidence: 334/96-4, 66/96-16

67) The verdict of the Higher Court in Sarajevo K.19/93 of 11 June 1994

68) Sarajevo, 1997, page 111

69) Evidence: 591/96-2, 594/96-41, 479/97

70) According to Munir Alibabić, head of the Public Security Service, only 200 - 300 Serbs were killed (evidence 108/97-7).

71) According to one of the experts in this case one of the papers of the Military Tribunal contains data on 887 killed Serbs (evidence 872/95-2)

72) The verdict of the Military Tribunal in Sarajevo K.189/94 of 23 December 1994.

73) One of the lawyers in this case publicly speaks about that: "Was this trial consistent to the principle of legality? I will give my free judgement: No, it was not! The very qualification in the indictment, and especially in the verdict - liquidation of a certain number of civilians whose bodies were found in the pit called Kazani was obviously inadequate... The majority of the accused was tried for the criminal offence of failing to report a perpetrator of a felony, and not for the criminal offence of war crime against civilians, what seemed rather peculiar to me even then. I realized that the reasons for that were political... Many of them admitted their active participation, and the indictment and the verdicts were for the "failing to report a perpetrator of a felony" or for common murder... Therefore, the verdict can not be placed in a framework of a legal trial." (evidence: 108/97-7).

74) Evidence: 281/96-9, 344/96-3, 649/96, 449/97-2

75) Evidence: 162/96-3, 162/96-5, 514/96-33, 449/97-2