The Prosecutor of the International Criminal Tribunal for the former Yugoslavia, pursuant to her authority under Article 18 of the Statute of the International Criminal Tribunal for the former Yugoslavia charges:

With CRIMES AGAINST HUMANITY and VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR as set forth below:

1. Momcilo PERISIC (son of Svetozar PERISIC) was born on 22 May 1944 in Kostunici, in Serbia, in the Socialist Federal Republic of Yugoslavia (SFRY). He joined the Yugoslav People’s Army (JNA) and graduated from the Ground Forces Military Academy in 1966. When the conflict in the former Yugoslavia began Momcilo PERISIC was the commander of the JNA Artillery School Centre in Zadar. In January 1992, Momcilo PERISIC was appointed the commander of the newly established 13^th Corps (Bileca Corps) of the JNA which had a command post in the Mostar region of the SFRY. In May 1992, after it formally withdrew from the territory of the Republic of Bosnia and Herzegovina (BiH) the JNA was renamed the Yugoslav Army (VJ). In June 1992, Momcilo PERISIC was appointed Chief of Staff and Deputy Commander of the 3rd Army based in Nis. He became its Commander in April 1993.

Position and Authority of Accused

2. Momcilo PERISIC became the Chief of General Staff of the VJ on or about 26 August 1993 and held this position until 24 November 1998. He was the most senior officer in the VJ and had overall authority and responsibility for its functioning. Under Yugoslav law he was subordinate only to the President of the Federal Republic of Yugoslavia (FRY) and the FRY Supreme Defence Council (SDC) which was comprised of the President of the FRY, and the presidents of the two constituent republics of Serbia and Montenegro.
3. Momcilo PERISIC’s authority over the VJ included authority over its military and civilian personnel within the policies and limitations set by the SDC. His authority over personnel included the de jure and de facto authority to:

   1. make and implement decisions for the VJ General Staff and all subordinate units;

   2. issue orders, instructions, directives and to ensure implementation of these orders, instructions and directives;

   3. transfer and second VJ personnel to the Army of the Republika Srpska (VRS) and the Army of the Serbian Krajina (SVK) via the 30^th and 40^th Personnel Centres of the VJ General Staff for short temporary assignments or longer indefinite periods.

4. Momcilo PERISIC, within the policies and limits set by the SDC, had the authority to direct the use and disposition of the material assets of the VJ including: ammunition, weapons and weapons systems, fuel, food, medical supplies, medical facilities, education, spare parts, clothing, and military housing.
5. Momcilo PERISIC exercised this military authority through the General Staff of the VJ, the highest professional and staff organ for the preparation and use of the Army in times of peace and war. He sometimes exercised this authority in coordination and consultation with senior members of the VRS and the SVK. In the case of VJ officers seconded to the SVK and the VRS, Momcilo PERISIC delegated or transferred, at least in substantial part, daily operational control of these officers to General Ratko Mladic, Commander of the Main Staff of the VRS; General Milan Celeketic, Commander of the SVK and his successor General Mile Mrksic.
6. Momcilo PERISIC was responsible for ordering, supervising, monitoring and disciplining all personnel and units that comprised the VJ serving within and without the boundaries of the FRY, which included:

1. All VJ personnel that were seconded to the VRS and the SVK, via the 30^th and 40^th Personnel Centre of the VJ General Staff whether or not operational control of the personnel was delegated or transferred to the commanders of these other forces and for whom the VJ continued to remunerate and retain its authority to make final determinations regarding their promotions and termination of service. Despite delegating daily operational control of these officers Momcilo PERISIC still had had the authority and material ability to discipline and punish these officers as described in paragraph 37 of this indictment.
2. All members of the VJ serving in regular units of the VJ who were sent on assignments outside of the FRY or engaged in activities within Yugoslavia in support of the SVK and VRS.
3. All VRS and SVK military personnel who began their military service in these armies but who, after receiving officer training from and commissioning in the VJ were thereafter remunerated and promoted within the VJ and regulated through the 30^th and 40^th Personnel Centres.

7. Momcilo PERISIC had a superior-subordinate relationship with former members of the JNA that joined the newly formed SVK and VRS and who became officers in the 30^th and 40^th Personnel Centres of the VJ General Staff and who the VJ continued to remunerate for their service in the SVK and VRS and retain its authority to make final determinations regarding their promotion and termination of service.

INDIVIDUAL CRIMINAL RESPONSIBILITY

Article 7(1) of the Statute of the Tribunal

8. Momcilo PERISIC is individually criminally responsible for the crimes referred to in Articles 3 and 5 of the Statute of the Tribunal as described in this indictment, in whose planning, preparation, or execution he aided and abetted. During his tenure as Chief of the General Staff of the VJ, Momcilo PERISIC exercised his authority, pursuant to the policies and limitations set by the SDC, to provide substantial military assistance to the VRS which he knew was used, in significant part, in the commission of the crimes described in this indictment.
9. Such assistance included continuing the practice of providing the majority of senior officers in the VRS as well as supplying large quantities of weapons, ammunition, and other logistical materials necessary for the commission of crimes. The provision of this assistance was both substantial and significant and remained largely uninterrupted during the period of time that Momcilo PERISIC was the Chief of the General Staff. Momcilo PERISIC gave this assistance with the knowledge that a significant part of that assistance was being used in the commission of crimes. Such assistance was provided covertly and in contravention of United Nations Security Council Resolutions that were issued, in part, because such assistance was being used in the commission of crimes. Such assistance was provided despite official representations by the FRY government that it was not militarily involved in the conflicts in the Republic of Croatia (Croatia) or BiH. In some instances such assistance consisted of sending regular VJ troops stationed in the FRY into BiH. Momcilo PERISIC provided this assistance through acts performed directly by him and by acts performed by his subordinates. The personnel and logistical assistance provided to the VRS contributed substantially and materially to their capacity to commit crimes

Provision of the Officer Corps of the SVK and the VRS

10. The VJ, under the command of Momcilo PERISIC, continued the policy of the SDC and its individual members to provide and finance the majority of officers comprising the officer corps of the VRS and the SVK. This provision of the officer corps of the VRS and the SVK included the regulation of their service, their remuneration (including post adjustments for combat duty while serving in the VRS and SVK), their benefits, and their promotions.
11. The provision of VJ officers was done secretly to hide the involvement of the VJ and the FRY government in the conflicts in Croatia and BiH in breach of United Nations Security Council Resolutions. In November 1993, Momcilo PERISIC personally established special purpose personnel centres within the General Staff of the VJ to disguise the provision and payment of these officers. These centres were known as the "30^th Personnel Centre" for VJ members serving in the VRS and the "40th Personnel Centre" for VJ members serving in the SVK.
12. The primary function of these special purpose personnel centres was to remunerate and regulate the service of the large number of former JNA officers who served in the armies of the VRS and the SVK as well as the large number of VJ officers who were seconded to the armies of the VRS and the SVK. These centres bore the burden of the administration and regulation of much of the SVK’s and VRS’s military and civilian personnel.
13. The VJ officers that were sent to the SVK and the VRS were selected according to criteria which was, in part, established by Momcilo PERISIC. Many of the officers were selected because they were born in either BiH or Croatia. Some were selected in order to influence the composition and character of those armies. Some who volunteered were permitted to go without resigning from the VJ and continued to be paid as officers in the VJ. Many who were reluctant to go were induced with incentives such as Yugoslav citizenship or coerced with the threat of punitive measures such as forcible early retirement from the VJ. Momcilo PERISIC personally issued orders requiring his subordinates to transfer to the VRS and the SVK.
14. The co-ordination between the VJ and the VRS was so close that the political leaders of the Republika Srpska and General Ratko Mladic could request that particular VJ officers be placed under their operational command or be retired via the 30^th Personnel Centre.
15. VJ officers serving in the SVK and the VRS did so for short-term temporary assignments or long-term indefinite periods. Some officers were required to obtain certification that they had completed their service in units outside Yugoslavia before returning to the VJ. VJ officers serving in the VRS retained their VJ identification cards and were not issued VRS identification documents until after the Dayton Peace Accords in 1995.
16. In some instances, soldiers who began their military service in the VRS and SVK were sent to the FRY to be trained as officers by the VJ. Upon their commissioning they were accepted into the VJ as officers assigned to the 30^th and 40^th Personnel Centres of the VJ General Staff which would henceforth regulate their service, remunerate them and make final determinations on future promotions.
17. In some instances, officers were permitted to return to their original posts in the VJ at their request. At the end of the conflict, Ratko Mladic made arrangements with Momcilo PERISIC for the transfer of many of the senior VRS officers serving under his command via the 30^th Personnel Centre back to regular units in the VJ.

Promotion of Yugoslav Army officers serving in the SVK and the VRS

18. The VJ administered the continued training and promotion of officers serving in the SVK and the VRS. The promotion of these seconded personnel contributed to the morale of the officer corps serving outside the regular VJ and furthered the development of the respective officer corps of the VRS and SVK.
19. Momcilo PERISIC regularly received recommendations for the promotion of VJ officers serving in the SVK and the VRS. In most instances, these recommendations came from senior officers who themselves were members of the 30^th and 40^th Personnel Centres of the VJ General Staff and who had operational control of the seconded VJ officers. On occasion, senior political leaders or political entities within the Republika Srpska and the Republic of Serbian Krajina promoted senior VJ officers serving in their armies. In many cases, these officers were nominally promoted in the SVK and VRS and could be addressed by the higher rank by other members of their force before a final determination was made on their promotion in the VJ. Momcilo PERISIC would make a final determination on these recommendations for all ranks of Lieutenant Colonel and below.
20. In the case of officers being promoted to the rank of General, Yugoslav law required the SDC president to make a determination upon the proposal of the VJ Chief of the General Staff. Momcilo PERISIC would advise the SDC, that he either supported or opposed these recommendations. In most cases, Momcilo PERISIC proposed that these recommendations be adopted by the SDC; in some cases he recommended that certain officers not be promoted or he requested that the decision be postponed to give him time to evaluate the suitability of a particular officer. The SDC, in most cases, adopted Momcilo PERISIC’s proposal and either accepted, rejected or postponed the proposed promotion.
21. This secret process was commonly referred to by members of the VJ, SVK and the VRS as "verification". All matters related to the regulation of their service were decided pursuant to the applicable laws of the VJ. All appeals of such decisions could only be heard in the Supreme Military Court in Belgrade pursuant to Yugoslav military law. The service of most senior officers in the VRS and SVK was regulated in this manner and is described in detail in Schedule E of this indictment. Some of these assigned officers exercised their authority in the commission of crimes as described in this indictment.
22. Two successive Ministers of Defence of the Republika Srpska received their pay and their benefits from the 30^th Personnel Centre of the VJ General Staff. Key members of the VRS Main Staff and all Corps commanders of the VRS received their remuneration from the 30^th Personnel Centre of the VJ General Staff which also regulated their service.
23. Similarly, key members of the SVK Main Staff and other senior officers including its Commander received their pay and their benefits from the 40^th Personnel Centre of the VJ General Staff which also regulated their service.

Provision of Material and Logistical Assistance to the SVK and the VRS

24. During his tenure as Chief of the General Staff of the VJ, Momcilo PERISIC continued to implement the policy of the SDC and its members to provide large quantities of weapons, ammunition, materials and other logistical support necessary for the commission of crimes. The provision of this assistance was both substantial and significant and was given irrespective of whether or not the assistance was to be used in lawful combat or in the commission of crimes. Momcilo PERISIC provided this assistance through acts performed directly by himself and by acts performed by his subordinates.
25. Momcilo PERISIC was personally aware of specific requests made by the SVK and the VRS. In some instances, Momcilo PERISIC responded to direct requests from Ratko Mladic for logistical assistance and arranged meetings between Mladic and other members of the FRY government to discuss his military requirements. Assistance to the VRS and the SVK was so well integrated into the VJ budgetary system that a joint balance sheet was maintained for materials allocated to the VJ, VRS and the SVK.
26. The VJ provided largely uninterrupted material and logistical support including weapons, ammunition and other combat equipment. The VJ provided and maintained an air defence system that was unified and integrated with the VRS. In 1994, Momcilo PERISIC personally proposed the provision of an air defence weapons system to the VRS.
27. The VJ provided and maintained an integrated communications systems allowing senior officers of the three armies to readily communicate with each other. The VJ facilitated the supply of raw materials to weapons and munitions factories in the Republika Srpska and provided testing facilities when necessary. The VJ provided the VRS and the SVK with spare parts for military equipment and the technicians necessary to maintain and repair such military equipment. The VJ performed maintenance on VRS equipment at its own facilities and sent some of its equipment to the RS for maintenance and repairs.
28. The VJ provided large quantities of fuel to the VRS and the SVK for military purposes. The VJ provided medical supplies, treatment, and facilities for wounded and the injured VRS personnel including hospitalisation in VJ military hospitals. The VJ provided education and training to personnel of the VRS and the SVK. The VJ provided foodstuffs for the combat troops of the VRS. The VJ provided military clothing for the combat troops of the VRS and the SVK. The VJ provided assistance to the families of personnel serving in the VRS and the SVK. The VJ paid the salaries of the civilian staff working in the VRS and SVK.

Environment of Impunity

29. Momcilo PERISIC had a professional military obligation to ensure that discipline was maintained by his subordinates who were engaged in combat activities in the VRS and the SVK. He had the legal and professional duty to take all necessary measures to prevent or punish the commission of crimes by his subordinates in the 30^th and 40^th Personnel Centres of the VJ General Staff.
30. As the Chief of the General Staff of the VJ from 26 August 1993 and continuing during the period of this indictment, Momcilo PERISIC was aware that some of his subordinates, serving in the SVK and the VRS, had repeatedly committed violations of international criminal law. During this period, Momcilo PERISIC failed to take any measures to prevent the commission of these crimes, and knowing of their commission, failed to take any measures to punish the perpetrators.
31. Subordinates of Momcilo PERISIC were aware that he did not take measures to prevent and to punish the crimes being committed by some of his subordinates. His consistent and prolonged pattern of failing to prevent, investigate and punish breaches of international criminal law by VJ personnel serving in the SVK and the VRS created an environment of impunity in which his subordinates believed they could commit those crimes without fear of sanction. The creation of this environment of impunity amounted to aiding and abetting by facilitating and encouraging the commission of the crimes alleged in this indictment.

Knowledge

32. During the period relevant to this indictment Momcilo PERISIC had actual knowledge that the personnel and the logistical assistance he provided to the VRS was being used, in significant part, to perpetrate crimes in Sarajevo and Srebrenica including unlawful killings and forcible transfers. He was personally aware of the extreme nationalistic character of many members of the VRS and their propensity to engage in persecutory conduct. Momcilo PERISIC was aware of the VRS’s co-operation with and use of paramilitary forces. Momcilo PERISIC was personally aware of allegations of particular crimes and allegations against specific officers. He was regularly copied on daily situation reports from the VRS and had direct communications with VRS officers including Ratko Mladic.
33. During the time relevant to this indictment the VJ maintained its own intelligence apparatus that was actively engaged in gathering information about what was transpiring in the conflicts in BiH and Croatia. This apparatus provided Momcilo PERISIC with regular timely reports of events. The VJ General Staff also received intelligence reports from VRS intelligence organs. Other factors which served to place Momcilo PERISIC on notice of the crimes that were being committed by VJ personnel or with VJ material and logistical assistance included:

1. Reports from VJ officers sent to the SVK and the VRS.
2. FRY government officials had regular contact with Bosnian Serb leaders
3. During the period relevant to this indictment there were numerous media reports and reports from non-governmental organisations alleging criminal conduct.
4. Beginning in 1994, the ICTY began issuing a series of indictments describing allegations of serious criminal acts committed, in some instances, by personnel assigned to the 30^th and 40^th Personnel Centres of the VJ General Staff.

Article 7(3) of the Statute of the Tribunal

34. Momcilo PERISIC was Chief of the General Staff of the VJ from 26 August 1993 until 24 November 1998 and, subject to the authority of the SDC, exercised effective control over the VJ (de jure and de facto). As such, in his capacity as a superior officer, and pursuant to Article 7(3) of the Statute of the Tribunal, he bears individual criminal responsibility for failing to prevent or punish the unlawful acts of his subordinates in the VJ as described in this Indictment.
35. Momcilo PERISIC’s subordinates, under international law, include those personnel over whom he had a material ability to prevent and punish the commission of crimes. They included, but were not limited to:

1. All VJ personnel that were assigned or seconded to the VRS and the SVK via the 30^th and 40^th Personnel Centres of the VJ General Staff whether or not daily operational control of the personnel was delegated or transferred to the commanders of these other armies and for whom the VJ continued to remunerate and retain its right to make final determinations regarding their promotions and the termination of their service.
2. Former members of the JNA that joined the newly formed SVK and VRS and who became officers in the 30^th and 40^th Personnel Centres of the VJ General Staff and whom the VJ continued to remunerate for their service in the SVK and VRS and retain its authority to make final determinations regarding their promotions and termination of service. Such superior relationship existed because of Momcilo PERISIC’s material ability to prevent or punish their criminal conduct as described in paragraph 37 of this indictment. His material ability to prevent and punish criminal conduct by these officers was parallel and concurrent to the material ability held by the Commanders of the VRS and SVK who had operational control of these officers and who also had a superior-subordinate relationship with these officers.
3. All members of the VJ serving in regular units of the VJ who were sent on assignments outside of the FRY or engaged in activities within the FRY in support of the SVK and VRS.
4. All VRS and SVK military personnel who began their military service in these armies but who, after receiving officer training from and commissioning in the VJ, were thereafter remunerated and promoted within the VJ and regulated by the 30^th and 40^th Personnel Centres.

36. Momcilo PERISIC had an affirmative duty to monitor the activities of his subordinates assigned to serve in the 30^th and 40^th Personnel Centres of the VJ General Staff and investigate allegations of misconduct and criminal acts against them of which he became aware and adopt necessary and effective measures to prevent the commission of the crimes. Despite being aware of allegations of serious crimes being committed by members of the VRS and the SVK, no investigations were conducted at the instance of Momcilo PERISIC to determine if members of the 30^th and 40^th Personnel Centres bore responsibility for these crimes.
37. Momcilo PERISIC as the Chief of the General Staff of the VJ had the authority, the responsibility and the material ability to employ disciplinary mechanisms that were available to him that included, but were not limited to:

1. Initiating investigations by VJ military prosecutors.
2. Denying promotions to, demoting or terminating the service of officers up to the rank of Lieutenant Colonel.
3. Making appropriate recommendations to the SDC for officers holding the rank of General including denial of promotion, demotion, or termination of service.
4. Issuing orders to VJ personnel assigned to the 30^th and 40^th Personnel Centres specifically prohibiting criminal conduct such as attacks on civilians and persecution and affirming their legal and professional obligation to observe international humanitarian law.
5. Implementing non-judicial mechanisms for investigating allegations of criminal conduct including requiring VJ officers serving in the SVK and VRS to appear before the VJ General Staff and the SDC to report and respond to allegations of misconduct.
6. Recalling VJ seconded officers from the SVK and VRS when he became aware they might have engaged in criminal conduct or were likely to be engaged in such conduct in the future.

38. Momcilo PERISIC failed to employ any of the above disciplinary or preventative mechanisms despite having personal knowledge of allegations of criminal behaviour regarding particular events and specific members of the 30^th and 40^th Personnel Centres of the VJ General Staff. He exercised his authority selectively, for example, when subordinates gave VJ supplies to the VRS outside the parameters of his orders; or when officers serving in the SVK lost territory in Western Slavonia to Croatian forces.
39. VJ officers serving in the VRS and RSK were, on some occasions, promoted or retired under favourable conditions in the VJ after allegations of serious misconduct by them became public knowledge. Some of these officers included, but were not limited to:

1. General Milan Celeketic, Commander of the SVK. Six weeks after the shelling of Zagreb, Momcilo PERISIC opposed his promotion to the rank of Lieutenant Colonel General, not because of this crime but because he held him responsible for the loss of Serb-held territories in Western Slavonia.
2. General Ratko Mladic, Commander of the Main Staff of the VRS. He was promoted in the VJ on 24 June 1994 to the rank of Colonel General.
3. General Stanislav Galic, Commander of the Sarajevo Romanija Corps. He was retired from the VJ in 1996.
4. General Dragomir Milosevic, Commander of the Sarajevo Romanija Corps. He was promoted in the VJ in December 1995.
5. General Radislav Krstic, Commander of the Drina Corps. He was promoted in the VJ in December 1995.
6. Colonel Vinko Pandurevic, Commander of the Zvornik Brigade. Pandurevic was extraordinarily promoted in the VJ in December 1995.
7. Lieutenant Colonel Dragan Obrenovic, Deputy Commander of the Chief of Staff of the Zvornik Brigade. Obrenovic was extraordinarily promoted in the VJ in December 1995.

THE CHARGES

SARAJEVO

Counts 1 to 4
Murder, Inhumane Acts and Attacks on Civilians

40. Between August 1993 and November 1995, Momcilo PERISIC aided and abetted the planning, preparation, or execution of a military campaign of artillery and mortar shelling and sniping onto civilian areas of Sarajevo and upon its civilian population, killing and wounding thousands of civilians.
41. In this time period, the commanders of the Sarajevo Romanija Corps of the VRS, General Stanislav Galic (10 September 1992 to 10 August 1994) and General Dragomir Milosevic (10 August 1994 to November 1995) and their superior General Ratko Mladic, continued an extensive shelling and sniping attack on Sarajevo, mostly from positions in the hills surrounding the city.
42. The Sarajevo Romanija Corps conducted a protracted campaign of shelling and sniping upon Sarajevo during which civilians were either specifically targeted or were the subject of reckless fire into areas where civilians were known to have been. Specific instances of shelling are set forth in Schedule A of this indictment. Specific instances of sniping are set forth in Schedule B of this indictment
43. These crimes were, in part, planned, instigated, ordered, committed and aided by members of the 30^th Personnel Centre of the VJ General Staff including but not limited to General Ratko Mladic, Commander of the VRS; General Stanislav Galic, Commander of the Sarajevo Romanija Corps (until August 1994); and General Dragomir Milosevic, Commander of the Sarajevo Romanija Corps (after August 1994). As members of the 30^th Personnel Centre of the VJ these and other officers involved in the crimes received all of their remuneration from the VJ. The ranks they held and which allowed them to hold the positions of authority necessary to plan, instigate, order, commit and otherwise aid and abet the above crimes were verified and regulated by the VJ.
44. General Momcilo PERISIC, aided and abetted crimes which included unlawful killings, inhumane acts and attacks on a civilian population with the knowledge that the assistance he provided would be used in the commission of these crimes. His specific acts of assistance consisted of:

1. Exercising his authority as Chief of the General Staff of the VJ to provide and pay the senior officers responsible for the crimes committed during the siege of Sarajevo.
2. Exercising his authority to provide a substantial amount of the weapons, ammunition and logistical support used by the VRS, which was used, in part, to perpetrate the crimes committed during the siege of Sarajevo.
3. Failing to exercise his authority and responsibility to prevent and punish criminal conduct and uphold military discipline thereby creating an environment of impunity among members of the 30^th Personnel Centre of the VJ General Staff assigned to duties in BiH.
4. Exercising his authority to deploy regular VJ troops in support of the siege of Sarajevo during the "Pancir-2" operation between December 1993 and February 1994.

45. Momcilo PERISIC had reason to know that subordinates of his, including Ratko Mladic, Stanislav Galic, Dragomir Milosevic and other VJ officers serving in the VRS via the 30^th Personnel Centre had participated in the perpetration of crimes in Sarajevo based on the following facts:

1. The crimes involved numerous individual criminal acts that were perpetrated over an extended period of time in the capital of BiH.
2. The crimes received widespread attention from the media, intergovernmental organisations, international negotiators, and non-governmental organisations, many of which based their reports on first-hand accounts of the crimes.
3. The large amount of logistical support that was necessary for the commission of these crimes was provided by the VJ.
4. The VJ had an effective intelligence gathering apparatus that provided Momcilo PERISIC with regular contemporaneous information about what occurred in BiH.

46. Despite these facts, Momcilo PERISIC, failed to initiate an inquiry into what role members of the 30^th Personnel Centre of the VJ General Staff may have played in the commission of these crimes.

By his acts and omissions in relation to the crimes perpetrated in Sarajevo as described in paragraphs 40 – 46 and in Schedules A and B of this indictment, Momcilo PERISIC committed:

Count 1: Murder, a CRIME AGAINST HUMANITY, punishable under Articles 5(a) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 2: Murder, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, as recognised by Common Article 3(1)(a) of the Geneva Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

Count 3: Inhumane acts, a CRIME AGAINST HUMANITY, punishable under Articles 5(i) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 4: Attacks on civilians, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, as recognised by Article 51 (2) of Additional Protocol I and Article 13 (2) of Additional Protocol II to the Geneva Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

47. On 2 May 1995 and 3 May 1995 Milan Martic planned, instigated, ordered, committed or otherwise aided and abetted the planning, preparation, and execution of the shelling of civilian areas in the city of Zagreb and upon its civilian population.
48. On 1 May 1995 the Croatian Army (HV) launched an attack against the SVK in Western Slavonia, commonly referred to as Operation Flash. As a result of the attack the SVK was forced to withdraw from the area of Western Slavonia across the Sava River into the Serbian held part of BiH. In retaliation, Milan Martic, President of the Republic of Serbian Krajina and Supreme Commander of the SVK ordered the shelling of three Croatian cities: Zagreb, Sisak and Karlovac.
49. On 2 May 1995, at approximately 10:25 hours, on the order of Milan Martic, General Celeketic of the SVK ordered his subordinates to fire an Orkan Multiple Barrel Rocket Launcher fitted with "cluster bomb" warheads from the area of Petrova Gora into the central part of Zagreb and the airport (Pleso). These rockets impacted in several locations within the central commercial district of Zagreb, primarily the areas of Stara Vlaska Street, Josip Juraj Strossmayer Square and Krizaniceva Street. During this unlawful attack, at least five civilians were killed and at least 121 six civilians wounded.
50. On 3 May 1995, at approximately 12:10 hours on the orders of Milan Martic, the Orkan Multiple Barrel Rocket Launcher fitted with "cluster bomb" warheads was once again fired from the area of Petrova Gora into the centre of Zagreb. Rockets impacted in the areas of Klaiceva Street, Meduliceva Street, Ilica Street and near the Croatian National Theatre. This unlawful attack caused the death of two civilians and wounded forty-eight others. The names of those civilians that were killed are listed in Schedule C of this indictment.
51. The shelling was not justified by military necessity. The affected locations were either specifically targeted or the result of reckless fire into areas where civilians were known to have been.
52. The crimes described above were, in part, committed and aided and abetted by members of the 40^th Personnel Centre of the VJ including, but not limited to, General Celeketic. As members of the 40^th Personnel Centre of the VJ these and other officers involved in the crimes received all of their remuneration from the VJ. The ranks they held and which allowed them to hold the positions of authority necessary to plan, instigate, order, commit and otherwise aid and abet the above crimes were verified and regulated by the VJ.
53. Momcilo PERISIC had reason to know that subordinates of his, including Milan Celeketic and other VJ officers serving in the SVK via the 40^th Personnel Centre had participated in the perpetration of crimes in Zagreb based on the following facts:

1. The crimes involved a notorious act of shelling civilian areas of Zagreb, the capital of Croatia.
2. The crimes received widespread attention from the media, intergovernmental organisations, international negotiators, and non-governmental organisations, many of which based their reports on first-hand accounts of the crimes.
3. The VJ had an effective intelligence gathering apparatus that provided Momcilo PERISIC with regular contemporaneous information about what occurred in Croatia.

54. Despite these facts, Momcilo PERISIC, failed to initiate an inquiry into what role members of the 40^th Personnel Centre of the VJ may have played in the commission of these crimes.

By his omissions in relation to the crimes perpetrated in Zagreb as described in paragraphs 47 to 54 and in Schedule C of this indictment, Momcilo PERISIC committed:

Count 5: Murder, a CRIME AGAINST HUMANITY, punishable under Articles 5(a) and 7(3) of the Statute of the Tribunal.

Count 6: Murder, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, as recognised by Common Article 3(1)(a) of the Geneva Conventions of 1949, punishable under Articles 3 and 7(3) of the Statute of the Tribunal.

Count 7: Inhumane acts, a CRIME AGAINST HUMANITY, punishable under Articles 5(i) and 7(3) of the Statute of the Tribunal.

Count 8: Attacks on civilians, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, as recognised by Article 51 (2) of Additional Protocol I and Article 13 (2) of Additional Protocol II to the Geneva Conventions of 1949, punishable under Articles 3 and 7(3) of the Statute of the Tribunal.

55. On 8 April 1993 the International Court of Justice issued an order to the Federal Republic of Yugoslavia to take all immediate measures within its power to prevent the commission of the crime of genocide in BiH. On 16 April 1993, the United Nations Security Council issued Resolution 819 which reaffirmed the order of the International Court of Justice as well as the sovereignty, territorial integrity and political independence of the Republic of BiH. In Resolution 819 the Security Council recognising that the continued Bosnian Serb military operations against Srebrenica and in Eastern Bosnia involved unlawful attacks on civilians made several demands. The Security Council demanded that the attacks stop and further that "the Federal Republic of Yugoslavia (Serbia and Montenegro) immediately cease the supply of military arms, equipment and services to the Bosnian Serb paramilitary units in the Republic of Bosnia and Herzegovina."
56. On 8 March 1995, Radovan Karadzic, as the Supreme Commander of the VRS, issued Operational Directive 7, which directed the VRS to eliminate the Muslim enclaves of Srebrenica and Zepa, in furtherance of the "six strategic objectives" of 12 May 1992. On 2 July 1995, the VRS and other Bosnia Serb forces under the command and control of General Ratko Mladic attacked the Srebrenica enclave. The attack on the enclave continued until 11 July 1995, when General Ratko Mladic and the VRS and other Bosnia Serb forces under Mladic’s command and control entered Srebrenica. Momcilo PERISIC knew an attack was planned. Momcilo PERISIC also knew that some members of the VRS would engage in criminal conduct against the Bosnian Muslim civilian population of Srebrenica after its capture; criminal conduct which would include persecution, forcible transfers and killings.
57. Between 12 July and about 20 July 1995, thousands of Bosnian Muslim men were captured by, or surrendered to, Bosnia Serb forces under the command and control of General Ratko Mladic. Over 7,000 Bosnian Muslim prisoners captured in the area around Srebrenica were summarily executed from 13 July to 19 July 1995 and thereafter many were buried in mass graves. From about 1 August 1995 through 1 November 1995, VRS units under the command and control of General Ratko Mladic participated in an organised and comprehensive effort to conceal the killings by reburying, in isolated locations, bodies exhumed from their original mass graves. These killings are summarised in Schedule D of this indictment. From July 1995 onwards, approximately 25,000 Bosnian Muslim civilian women, children and elderly men were forcibly transferred by the VRS from Potocari and other areas surrounding Srebrenica to Kladanj and other non-Serb areas of BiH.
58. The crimes described above were, in part, planned, instigated, ordered, committed and aided by members of the 30^th Personnel Centre of the VJ including, but not limited to: General Ratko Mladic, Commander of the VRS; General Milenko Zivanovic, Commander of the Drina Corps until 20:00 hours on 13 July 1995; General Radislav Krstic, Chief of Staff and Deputy Commander up until 20:00 hours 13 July 1995 and thereafter Commander of the Drina Corps; Colonel Ljubisa Beara, Chief of Security of the VRS Main Staff; Colonel Vujadin Popovic, Assistant Commander for Security of the Drina Corps; Colonel Vidoje Blagojevic, Commander of the Bratunac Brigade; Colonel Vinko Pandurevic Commander of the Zvornik Brigade; Dragan Jokic, Chief of Engineering of Zvornik Brigade; Lieutenant Colonel Dragan Obrenovic, Deputy Commander and Chief of Staff of Zvornik Brigade; and various other individuals and elements of military units including, but not limited to: 10^th Sabotage Detachment, 65^th Protection Regiment, Bratunac Brigade, Zvornik Brigade, Vlasenica Brigade, and 5^th Engineering Battalion. These crimes were committed as part of a joint criminal enterprise involving VRS personnel, members of the Republika Srpska police and some political leaders from both the FRY and the RS.
59. The officers enumerated above, as members of the 30^th Personnel Centre of the VJ General Staff, received all of their remuneration from the VJ. The ranks they held and which allowed them to hold the positions of authority necessary to plan, instigate, order, commit and otherwise aid and abet the above crimes were verified and regulated by the VJ.
60. General Momcilo PERISIC, aided and abetted crimes which included unlawful killings, inhumane acts and forcible transfers with the knowledge that the assistance he provided would be used in the commission of these crimes. His specific acts of assistance consisted of:

1. Exercising his authority as Chief of the General Staff of the VJ to provide and pay the senior officers responsible for the forcible transfers, inhumane treatment and killings at Srebrenica.
2. Exercising his authority to provide a substantial amount of the weapons, ammunition and logistical support used by the VRS, which was used, in part, to perpetrate the crimes described above.
3. Permitting officers from the Uzice Corps of the VJ to assist in the planning and preparation of the takeover of the enclave of Srebrenica.
4. Exercising his authority on or about 13 July 1995 to order approximately 30 VJ officers to report to the VRS Main Staff for assignments in BiH including the Srebrenica area.
5. Exercising his authority to provide covert training to the members of the 10^th Sabotage Detachment in Yugoslavia (December 1994) and in the Republika Srpska (March – April 1995) and whose members directly participated in many of the killings.
6. Exercising his authority to secure the border between Serbia and Bosnia in the area of Srebrenica to prevent Srebrenica Muslims from escaping into Serbia and to return those who had crossed the border.
7. Failing to exercise his authority and responsibility to prevent and punish criminal conduct and uphold military discipline thereby creating an environment of impunity among members of the 30^th Personnel Centre of the VJ assigned to duties in BiH.

61. Momcilo PERISIC had reason to know that his subordinates, including Ratko Mladic, Radislav Krstic, Milenko Zivanovic, Ljubisa Beara, Vujadin Popovic, Vidoje Blagojevic, Vinko Pandurevic, Dragan Jokic, Dragan Obrenovic, and other VJ officers serving in the VRS via the 30^th Personnel Centre of the VJ General Staff participated in the perpetration of crimes in Srebrenica based on the following facts:

1. The crimes resulted in the murder of over 7,000 men and boys, the forcible transfer of approximately 25,000 people and was the most notorious crime committed during the conflicts in the former Yugoslavia.
2. The crimes were committed in areas that were adjacent to the border with the FRY.
3. The crimes were committed after the take-over of Srebrenica, an enclave designated a "safe area" by the United Nations Security Council on 16 April 1993.
4. The crimes received widespread attention from the media, intergovernmental organisations, international negotiators, and non-governmental organisations.
5. Momcilo PERISIC had prior knowledge of the VRS’s propensity to commit crimes in furtherance of the "six strategic objectives."
6. The VJ had an effective intelligence gathering apparatus that provided Momcilo PERISIC with regular contemporaneous information about what occurred in BiH.

62. Despite these facts, Momcilo PERISIC, failed to initiate an inquiry into what role members of the 30^th Personnel Centre of the VJ may have played in the commission of these crimes.

By his acts and omissions in relation to the crimes involving forcible transfers and killings perpetrated in Srebrenica as described in paragraphs 55 to 62 and in Schedule D of this indictment, Momcilo PERISIC committed

Count 9: Murder, a CRIME AGAINST HUMANITY, punishable under Articles 5(a) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 10: Murder, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, as recognized by Common Article 3(1)(a) of the Geneva Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

Count 11: Inhumane acts, a CRIME AGAINST HUMANITY, punishable under Articles 5(i) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 12: Persecutions on political, racial or religious grounds, a CRIME AGAINST HUMANITY, including Murder, Cruel and Inhumane Treatment and Forcible Transfer, punishable under Articles 5(h) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 13: Extermination, a CRIME AGAINST HUMANITY, punishable under Articles 5(b) and 7(1) and 7(3) of the Statute of the Tribunal.

63. During 1990 and 1991 increasing nationalism and ethnic tension were marked by political, police and military leaders taking definitive steps that would result in the disintegration of the Social Federal Republic of Yugoslavia and the separation of four of its six constituent republics. This disintegration involved a series of armed conflicts extending for a period of nine years.
64. Conflict in Croatia erupted and intensified throughout the spring of 1991. In March 1992 armed conflict commenced in BiH. At all times relevant to this indictment, a state of armed conflict existed in Croatia and BiH.
65. The European Community formally recognised the sovereignty of Croatia on 15 January 1992 and the sovereignty of BiH on 7 April 1992. The United States formally recognised the sovereignty of Croatia and BiH on 7 April 1992. On 27 April 1992 the republics of Serbia and Montenegro proclaimed a new Federal Republic of Yugoslavia and declared itself the Successor State of the Socialist Federal Republic of Yugoslavia. On 22 May 1992 Croatia and BiH became members of the United Nations.
66. All acts and omissions alleged in this indictment occurred on the territory of the former Yugoslavia.
67. At all times relevant to this indictment the Accused, Momcilo PERISIC and other personnel of the VJ, VRS and SVK were required to abide by the laws and customs governing the conduct of armed conflicts, including the Geneva Conventions of 1949 and the Additional Protocols thereto. All acts and omissions charged in this indictment were committed against persons protected under the Geneva Conventions.
68. All acts and omissions charged in this indictment as Crimes against Humanity were part of a widespread and systematic attack directed against the Croat, Bosnian Muslim, Bosnian Croat and other non-Serb civilian populations within areas of Croatia and BiH.

________________________
Carla Del Ponte
Prosecutor

Dated this 22^nd day of February 2005
At The Hague
The Netherlands

1. Some Ministers of the Republika Srpska Ministry of Defence received their pay and their benefits from the 30^th Personnel Centre of the Yugoslav Army General Staff, which also regulated their service.

1. Major General Bogdan Subotic (April 1992 – January 1993). In October of 1993 Subotic was considered for a promotion to Major General in the VJ. No decision was taken pending a report from General Mladic. Subotic’s retirement from the VJ was considered in 1995 before he was officially retired from the VJ on 3 January 1996.
2. Major General Dusan Kovacevic (January 1993 – August 1994). In October of 1993 Kovacevic was considered for a promotion to Major General in the VJ. No decision was taken pending a report from General Mladic. Kovacevic’s retirement from the VJ was contemplated in 1995 before he was officially retired from the VJ on 3 January 1996.

Officer Corps of the Army of Republika Srpska

2. Key members of the VRS Main Staff including its Chief of Staff received their pay and their benefits from the 30^th Personnel Centre of the Yugoslav Army General Staff which also regulated their service.

Commander of the Main Staff:

1. General Colonel Ratko Mladic. General Mladic was promoted to the rank of General Colonel in the VJ on 24 June 1994. During the period relevant to this indictment he could be reached through a Belgrade telephone number. On 16 June 2001, Mladic was removed from the records of the VJ professional soldiers. On 7 March 2002, the professional military service of Mladic ceased for service requirements, and he was discharged from professional military service as of 28 February 2002.

Chief of the Main Staff:

2. Lieutenant Colonel General Manojlo Milovanovic. In 1994, General Milovanovic was promoted to the rank of Lieutenant Colonel General in the VRS. A final decision on the promotion was postponed until December 1995 when he was promoted to the rank of Lieutenant Colonel General in the VJ. He would later become the Republika Srpska Minister of Defence.

Chief of Operations and Training:

3. Major General Radivoje Miletic. In June 1995, a proposal to promote Miletic the rank of Major General in the VJ was approved.
4. Lieutenant Colonel General Bogdan Sladojevic (operations officer, July 1995). Sladojevic’s military service was terminated in March 2002. The RS Presidential decree announcing the termination referred to the 30^th Personnel Centre of the Yugoslav Army General Staff and his acquired pension rights.

3. The VRS Main Staff was divided into six primary departments. The heads of all of these departments received their pay and their benefits from the 30^th Personnel Centre of the Yugoslav Army General Staff which also regulated their service.

Department for Air Force and Anti-Aircraft Defence:

1. Major General Jovan Maric. In 1994, Maric was nominally promoted to the rank of Major General in the VRS. The VJ postponed a final decision on the promotion at that time. In June 1995, he was promoted to the rank of Major General in the VJ.

Department for Security and Intelligence Affairs:

2. Major General Zdravko Tolimir. In 1994, Tolimir was nominally promoted to the rank of Major General in the VRS. The VJ postponed a final decision on the promotion at that time. In June 1995, he was promoted to the rank of Major General in the VJ.
3. Lieutenant Colonel Dragomir Keserovic. (Chief of Police Section, Security Administration, February 1995 to October 1995). In March 2002 his military service was terminated. The RS Presidential decree announcing the termination makes reference to the 30^th Personnel Centre and acquired pension rights.

Department for Moral, Religion and Legal Affairs:

4. Lieutenant Colonel General Milan Gvero. In 1994, Gvero was nominally promoted to the rank of Lieutenant Colonel General in the VRS. The VJ postponed a final decision on the promotion at that time. In June 1995 he was promoted to the rank of Lieutenant Colonel General in the VJ. In 1997 he retired from the 30^th Personnel Centre of the VJ.

Department for Mobilisation and Personnel Affairs:

5. Colonel Mico Grubor (May 1992 to May 1994). In 1994, Grubor was promoted to the rank of Major General in the VRS. The VJ considered retiring Colonel Grubor at this higher position but postponed a final decision at the time. In 1995 the proposal to promote Grubor to the same rank he nominally held in the VRS was rejected.
6. Beginning in June 1994 Major General Petar Skrbic assumed Grubor’s duties. In December 1995 Skrbic was nominally promoted to the rank of Major General in the VJ.

Department for Rear Services:

7. Lieutenant Colonel General Dordje Dukic. In 1994 Dukic was nominally promoted to the rank of Lieutenant Colonel General in the VRS. The VJ postponed a final decision on the promotion. In 1995, Dukic was promoted to the rank of Lieutenant Colonel General. During the period relevant to this indictment General Dukic possessed a valid VJ identification card and could be contacted through a Belgrade telephone number.

Department for Development and Finance:

8. Major General Stevan Tomic. In 1994, Tomic was nominally promoted to the rank of Major General in the VRS. The VJ postponed a final decision on the promotion at this time. In 1995, the proposal to promote Tomic to the rank of Major General was rejected in 1995 because of his membership in the Serbian Democratic Party.

4. Combat troops of the VRS were organised into six primary corps and the Air Force and Anti-Aircraft Defence. The Commanders of all of these formations received their pay and their benefits from the 30^th Personnel Centre of the Yugoslav Army General Staff, which also regulated their service.

1^st Krajina Corps

1. Lieutenant Colonel General Momir Talic. In 1993, Talic was nominally promoted to the rank of Lieutenant Colonel General in the VRS. In October 1993 the VJ postponed a final decision on the promotion pending a report from General Mladic. In November 1993, after PERISIC received a report from Mladic, Talic was promoted to the rank of Lieutenant Colonel General in the VJ. During the period relevant to this indictment General Talic could be contacted via a Belgrade phone number.
2. The Chief of Staff of the 1^st Krajina Corps was Lieutenant Colonel General Bosko Kelecevic. In 1993, Kelecevic was nominally promoted to the rank of Major General in the VRS. In October 1993, the VJ postponed a final decision on the promotion pending a report from General Mladic. In November 1993, after PERISIC received a report from Mladic, Kelecevic was promoted to the rank of Major General in the VJ. In 1995, Kelecevic was promoted to the rank of Lieutenant Colonel General in the VJ. He was ultimately retired by the 30^th Personnel Centre in March of 1997.

2nd Krajina Corps

1. Major General Grujo Boric. In 1993 Boric was nominally promoted to the rank of Major General in the VRS. In October 1993, the VJ postponed a final decision on the promotion pending a report from General Mladic. In November 1993, after PERISIC received a report from Mladic, Boric was promoted to the rank of Major General in the VJ. In March 1997 Boric was retired by the 30^th Personnel Centre.
2. The Chief of Staff of the 2^nd Krajina Corps was Colonel Mico Vlaisavljevic. In 1994 Vlaisavljevic was nominally promoted to the rank of Major General in the VRS. The VJ postponed a final decision on the promotion and ultimately rejected his promotion to the rank of Major General in the VJ.

East Bosnia Corps

1. Major General Novica Simic. In 1993, Simic was nominally promoted to the rank of Major General in the VRS. In October 1993, the VJ postponed a final decision on the promotion pending a report from General Mladic. In November 1993, after PERISIC received a report from Mladic, Simic was promoted to the rank of Major General in the VJ. In March 2002 his military service was terminated. The Republika Srpska Presidential decree announcing the termination makes reference to the 30^th Personnel Centre and acquired pension rights.
2. The Chief of Staff of the East Bosnia Corps was Major General Budimir Gavric. In 1994 Gavric was nominally promoted to the rank of Major General in the VRS. The VJ postponed a decision on this promotion and initially rejected it because of Gavric’s affiliation with the SDS. In December 1995 Gavric’s promotion to Major General in the VJ was ultimately approved. He was retired from the 30^th Personnel Centre in 1996.

Sarajevo Romanija Corps

1. Major General Stanislav Galic (September 1992 to August 1994). In 1993 Galic was nominally promoted to the rank of Major General in the VRS. In October 1993 the VJ postponed a final decision on the promotion pending a report from General Mladic. In November 1993, after PERISIC received a report from Mladic, Galic was promoted to the rank of Major General in the VJ. In September 1994, General Galic was retired at the request of General Mladic. The terms of Galic’s retirement were the subject of some controversy being ultimately resolved by a Presidential decree of the FRY in 1994.
2. Major General Dragomir Milosevic (from August 1994). In 1994, Milosevic was nominally promoted to the rank of Major General in the VRS. At that time the VJ postponed making a final determination on this promotion. Milosevic’s promotion was initially rejected in the VJ because of his affiliation with the SDS but was ultimately confirmed in December 1995. In 1996, the decision was taken to place him at the disposal of the VJ in order to keep control over him. He was finally retired from the 30^th Personnel Centre in December 1996.
3. Lieutenant Colonel General Vlado Lizdek. (1^st Romanija Infantry Brigade Commander, April 1993 to 1995). In March 2002 his military service was terminated. The Republika Srpska Presidential decree announcing the termination makes reference to the 30^th Personnel Centre and acquired pension rights.
4. Major General Veljko Stojanovic. (1^st Sarajevo Motorised (Mechanised) Brigade Commander, May 1992 - 1996). In March 2002 his military service was terminated. The Republika Srpska decree announcing the termination makes reference to the 30^th Personnel Centre and acquired pension rights.

Herzegovina Corps

1. Major General Radovan Grubac. In 1993, Grubac was nominally promoted to the rank of Major General in the VRS. In October 1993, the VJ postponed a final decision on the promotion pending a report from General Mladic. In November 1993, after PERISIC received a report from Mladic, Grubac was promoted to Major General in the VJ.
2. The Chief of Staff of the Herzegovina Corps was Colonel Vlado Spremo. In 1994 Spremo was retired from the 30^th Personnel Centre at the request of General Mladic.

Drina Corps

1. Major General Milenko Zivanovic, Commander. The order relieving Zivanovic as commander stated: "Major General Radislav Krstic, father’s name Milorad, assumed the post of Corps Commander, and Major General Milenko Zivanovic, the previous Corps Commander, was appointed to new duties in the VJ-VRS."
2. Major General Radislav Krstic. On 3 March 1995 the Yugoslav Army issued General Krstic identification documents identifying him as a member of the Yugoslav Army. General Krstic was assigned as the commander of the Drina Corps from 13 July 1995. During the period relevant to this indictment General Krstic could be reached through a Belgrade telephone number. General Krstic was promoted to the rank of Major General in the VJ in December 1995, some five months after the massacres of the men from Srebrenica became widely known.
3. The Chief of Staff of the Drina Corps from November 1992 to September 1994 was Colonel Milutin Skocajic. In 1994, the promotion of Skocajic to the rank of Major General was considered and no decision was taken. His promotion in the VJ was ultimately rejected in 1995.
4. Lieutenant Colonel General Svetozar Andric. General Andric was assigned as the Chief of Staff of the Drina Corps from 13 July 1995. In March 2002 his military service was terminated. The Republika Srpska Presidential decree announcing the termination makes reference to the 30^th Personnel Centre and acquired pension rights.
5. Colonel Vujadin Popovic, Assistant Commander for Security. At the beginning of the war in Bosnia Popovic was an active military officer serving in the former JNA in Knin. In 1994, he was promoted by Lieutenant Colonel PERISIC to the rank of Major in the VJ. The promotion order stated that it was effective from 18 July 1993^. At the time of the massacres in Srebrenica, in July 1995, Popovic held the position of Assistant Commander for Security in the VRS Drina Corps Command.
6. Colonel Vinko Pandurevic. Pandurevic, Commander of the 1st Zvornik Infantry Brigade (December 1992 - November 1996). Personnel records show that Pandurevic was administered through the 30^th Personnel Centre. Pandurevic was extraordinarily promoted to the rank of Colonel in the VRS in December 1995, some five months after the massacres of the men from Srebrenica became widely known. The order specifically notes that Pandurevic was serving at the 30^th personnel Centre of the VJ General Staff.
7. Lieutenant Colonel Dragan Obrenovic. Obrenovic, Chief of Staff of the 1st Zvornik Infantry Brigade (June 1992 to November 1996). Personnel records show that Obrenovic was administered through the 30^th Personnel Centre. In January 1994 Obrenovic, on duty at the 30^th Personnel Centre, is promoted to the rank of Captain 1^st Class by the order of the VJ Chief of the General Staff, Lieutenant Colonel General Momcilo PERISIC. Obrenovic was extraordinarily promoted to the rank of Lieutenant Colonel in the VRS in December 1995, some five months after the massacres of the men from Srebrenica became widely known. The order specifically notes that Obrenovic was serving at the 30^th personnel Centre of the VJ General Staff.

Air Force and Anti-Aircraft Defence

1. Major General Zivomir Ninkovic. In 1993 Ninkovic was nominally promoted to the rank of Major General in the Air Force. In October 1993 the VJ postponed a final decision on the promotion pending a report from General Mladic. In November 1993, after PERISIC received a report from Mladic, was promoted to Major General in the VJ.
2. The Chief of Staff of Air Force and Anti-Aircraft Defence was Major General Bozo Novak. In 1994, Novak was nominally promoted to the rank of Major General in the VRS. The VJ postponed a final decision on the promotion but ultimately approved it in June 1995. In September 1996, it was decided by the VJ that Novak be recalled and placed at the disposal of the VJ. He was later retired from the 30^th Personnel Centre at the end of 1996.

Officer Corps of the Army of the Republic of Serbian Krajina

5. Key members of the SVK Main Staff including its Commander received their pay and their benefits from the 40^th Personnel Centre of the Yugoslav Army General Staff which also regulated their service.

Commander of the SVK:

1. Major General Mile Novakovic, Commander of the SVK (May 1992 – February 1994). In October 1993 the VJ postponed a decision on a proposal to promote Novakovic to the rank of Major General in the VJ. In November 1993 he was promoted to that rank. On 10 February 1995, Momcilo PERISIC approved a decision granting Novakovic enhanced benefits for serving under "harsh" conditions in Croatia. On 14 February 1995, the SVK sent a proposal to the 40^th Personnel Centre of the VJ Main Staff with respect to the promotion of Novakovic and 37 other officers.
2. General Milan Celeketic, Commander of the SVK (February 1994 – May 1995). In February of 1994, Milan Martic, then the President of the RSK promoted him to the rank of Major General and appointed him as Commander of the SVK Main Staff. In March 1994, PERISIC received this as a proposal for promotion in the VJ. PERISIC decided not to promote Celeketic at that time, but to observe him in his new post as Commander before deciding whether to recommend or oppose his promotion in the VJ. On 5 May 1994, the Momcilo PERISIC approved a decision granting Celeketic enhanced benefits for service under "harsh" conditions. In June 1994 Celeketic was promoted to the rank of Major General in the VJ. The promotion was not made public in order to disguise his relationship to the VJ. PERISIC once again approved enhanced pay and benefits for Celeketic on 10 February 1995. In March 1995, Celeketic was promoted to the rank of Lieutenant Colonel General by a Presidential decree of the RSK and subsequently by an act of the RSK Assembly in May of 1995. In June of 1995 PERISIC considered the proposal to promote Celeketic to the rank of Lieutenant Colonel General in the VJ. PERISIC rejected this proposal because he held Celeketic responsible for the loss of territory in the RSK. In October 1995, Celeketic was retired from 40^th Personnel Centre of the Yugoslav Army.
3. Lieutenant Colonel General Mile Mrksic, Commander of the SVK (May – August 1995). In June 1994 Mrksic was promoted to the rank of Lieutenant Colonel General in the VJ and was assigned as Assistant Chief of the VJ General Staff for Ground Forces. In February 1995, Mrksic was initially appointed as Military Adviser to the Commander of the 40^th Personnel Centre, a decision which was rescinded a short time later and he was instead appointed as an adviser to the Federal Minister of Defence. On 18 May 1995 he was appointed as Chief of the Main Staff of the SVK. In October 1995 Mrksic was retired from the 40^th Personnel Centre of the Yugoslav Army.

Chief of Staff of the Main Staff

1. Major General Borislav Dukic, Chief of the Main Staff (May 1992 – February 1994). In October 1993, the VJ postponed a decision on a proposal to promote Dukic to the rank of Major General in the VJ. In November 1993 he was promoted to that rank. On 10 June 1994 General PERISIC took a decision regulating the status of Dukic in the VJ. In September 1994, Dukic was retired from the VJ because he was no longer needed for the requirements of the service.
2. Major General Dusan Loncar, Chief of the Main Staff (April 1994). On 12 April 1994 at the Supreme Defence Council Session of the Republic of Srpska Krajina, a proposal was adopted to reassign Colonel Dusan (Mitar) Loncar to the 40^th Personnel Centre and appoint him as the Chief of Staff of the SVK Main Staff. On 5 May 1994 and 6 December 1994 General PERISIC took decisions granting General Loncar enhanced pay for his service in the SVK. On 10 December 1994 General Celeketic sent a letter to General PERISIC requesting him to issue orders on the appointment of a number of SVK officers from the 40^th Personnel Centre, including Loncar. In June of 1995, PERISIC considered the proposal to promote Loncar to the rank of Major General in the VJ. PERISIC rejected this proposal because he held Loncar responsible for recent losses in the territory of the RSK.

6. The SVK Main Staff was divided into several departments. Among the heads of these departments were key officers who received their pay and their benefits from the 40^th Personnel Centre of the Yugoslav Army General Staff which also regulated their service.

Assistant Commander for Security:

1. Lieutenant Colonel Dragan Sarac. On 30 June 1994, General Celeketic addressed a report to the 40^th Personnel Centre of the VJ Main Staff concerning and referencing "VJ Lt. Col. Dragan Sarac.

Assistant Commander for Intelligence & Security

2. Lieutenant Colonel Dusan Smiljanic. On 6 December 1994 the 40^th Personnel Centre of the VJ Main Staff issued a decision granting Lieutenant Colonel Smiljanic enhanced pay for serving under "harsh" conditions in Croatia. On 25 December 1994 General Celeketic issued a document certifying that Smiljanic served as a member of the Yugoslav Army in units performing combat activities in Knin from 15 October 1993 to 27 December 1994.

Chief of Intelligence

3. Colonel Rade Orlic (June 1994 – December 1994). Colonel Orlic was ordered to transfer from his unit in the VJ to the SVK on three separate occasions. During his service in the SVK he remained within the VJ chain of command.

Assistant Commander for Moral, Religion and Legal Issues

4. Colonel Kosta Novakovic. In his autobiography Colonel Novakovic stated that he served in the Serbian Army of the Krajina Main Staff and his permanent address was Military Post 4001, Belgrade.

Assistant Commander for Logistics

5. Major General Mirko Bjelanovic. In December 1993 General PERISIC transferred Bjelanovic from his position as a Navy Major General to the 40^th Personnel Centre for service in the Krajina. In October 1995, Bjelanovic was retired from 40^th Personnel Centre of the Yugoslav Army.

Chief of Technical Services

6. Colonel Ilija Sladakovic. On 14 February 1995 the SVK requested that the 40^th Personnel Centre of the VJ Main Staff take decisions on the proposed promotion of 37 professional officers including Sladakovic.

7. The combat troops of the SVK were divided into six corps. The Commanders of all of these corps received their pay and their benefits from the 40^th Personnel Centre of the Yugoslav Army General Staff which also regulated their service.

11^th Eastern Slavonian Corps

1. Colonel Stoja Spanovic was the Chief of Staff. On 5 July 1994 Major General Milan Celeketic signed a letter to the 40^th Personnel Centre of the VJ General Staff proposing that a number of professional soldiers in the SVK be promoted. Colonel Spanovic was one of those persons proposed for promotion and for appointment as Chief of Staff.

18^th Western Slavonian Corps

2. Colonel Lazar Babic, Commander. On 10 December 1994 Celeketic sent a letter to the 40^th Personnel Centre of the VJ General Staff proposing that Colonel Babic be promoted to the rank of Major General in the VJ. During the course of a battle General PERISIC called Babic three times to give him tactical advice on fighting the battle.

39^th Banija Corps

3. Colonel Zarko Gacic, Commander. On 10 December 1994 Celeketic sent a letter to the 40^th Personnel Centre of the VJ General Staff proposing that Colonel Gacic be promoted to the rank of Major General in the VJ.

21^st Kordun Corps

4. Colonel Veljko Bosanac, Commander. On 10 December 1994 Celeketic sent a letter to the 40^th Personnel Centre of the VJ General Staff proposing that Colonel Bosanac be promoted to the rank of Major General in the VJ.

7^th Knin Corps

5. Colonel Milan Dilas, Commander (1993). On 14 February 1995 the SVK addressed a letter to the 40^th Personnel Centre of the VJ General Staff requesting the promotion of 37 officers. Colonel Dilas’s name was included in this request.

6. Colonel Boro Poznanovic, Commander (1994). On 10 December 1994 Celeketic sent a letter to the 40^th Personnel Centre of the VJ General Staff proposing that Colonel Poznanovic be promoted to the rank of Major General in the VJ.

15^th Lika Corps

7. Colonel Stevo Sevo, Commander (1994). On 18 April 1994 Martic sent a confidential order to the VJ noting that Colonel Sevo should be appointed commander of the Lika Corps.