IN THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

RE: William J. Clinton, Madeleine Albright, William S. Cohen, Tony Blair, Robin Cook, George Robertson, Javier Solana, Jamie Shea, Wesley K. Clark, Harold W. German, Konrad Freytag. D.J.G. Wilby, Fabrizio Maltinti, Giuseppe Marani, Daniel P. Leaf, Jean Chrétien, Lloyd Axworthy, Arthur Eggleton, Jean-Luc Dehaene, E. Derycke, J.-P. Poncelet, Vaclav Havel, J. Kavan, V. Vetchy, Poul Nyrup Rasmussen, N.H. Petersen, H. Haekkerup, Jacques Chirac, Lionel Jospin, H. Védrine, Alain Richard, Gerhard Schröder, J. Fischer, R. Scharping, Kostas Simitis, G. Papandreou, A. Tsohatzopoulos, Viktor Orban, J. Martonyi, J. Szabo, David Oddsson, H. Asgrimsson, G. Palsson, Massimo D'Alema, L. Dini, C. Scognamiglio, Jean-Claude Juncker, J. Poos, Alex Bodry, Willem Kok, J. van Aartsen, F.H.G. de Grave, Kjell Magne Bondevik, K. Vollebæk, D.J. Fjærvoll, Jerzy Buzek, B. Geremek, J. Onyszkiewicz, Antonio Manuel de Oliveira Guterres, J.J. Matos da Gama, V. Simão, Jose Maria Aznar, A. Matutes, E. Serra Rexach, Bulent Ecevit, I. Cem and H. S. Turk.

NOTICE OF THE EXISTENCE OF INFORMATION CONCERNING SERIOUS VIOLATIONS OF INTERNATIONAL HUMANITARIAN LAW WITHIN THE JURISDICTION OF THE TRIBUNAL;

REQUEST THAT THE PROSECUTOR INVESTIGATE NAMED INDIVIDUALS FOR VIOLATIONS OF INTERNATIONAL HUMANITARIAN LAW AND PREPARE INDICTMENTS AGAINST THEM PURSUANT TO ARTICLES 18.1 AND 18.4 OF THE TRIBUNAL STATUTE.

TO:

Madam Justice Louise Arbour
Prosecutor
International Criminal Tribunal for the Former Yugoslavia,
Churchillplein 1, 2501 EW,
The Hague,
Netherlands.

AND TO: William J. Clinton, Madeleine Albright and William S. Cohen,
C/o William J. Clinton
President
The White House, 1600 Pennsylvania Ave NW
Washington, District of Columbia 20500
United States of America

Tony Blair, Robin Cook and George Robertson,
C/o Rt. Hon. Tony Blair
Prime Minister
10 Downing St.
SW1A 2AA London
United Kingdom

Javier Solana, Jamie Shea, Wesley K. Clark, Harold W. German, Konrad Freytag. D.J.G. Wilby, Fabrizio Maltinti, Giuseppe Marani and Daniel P. Leaf,
C/o Javier Solana, Secretary General
NATO
NATO Headquarters,
1110 Brussels,
Belgium

Jean Chrétien, Lloyd Axworthy and Arthur Eggleton,
C/o Jean Chretien, M.P.
Prime Minister
House of Commons, PO Box 1103
Ottawa, Ontario K1A 0A6
Canada

Jean-Luc Dehaene, E. Derycke and J.-P. Poncelet,
C/o M. Jean-Luc Dehaene
Premier Ministre
rue de la Loi 16
B-1000 Brussels
Belgium

Vaclav Havel, J. Kavan and V. Vetchy,
C/o Vaclav Havel
President
Office of the President of the C.R.
Hrad (Castle)
119 08 Praha 1
Czech Republic

Poul Nyrup Rasmussen, N.H. Petersen and H. Haekkerup, C/o Poul Nyrup Rasmussen
Prime Minister
Prime Minister`s Office
Christiansborg, Prins Jorgens Gaard 11
DK-1218 Copenhagen
Denmark

Jacques Chirac, Lionel Jospin, H. Védrine and Alain Richard,
C/o M. Jacques Chirac
President de la Republique
Palais de l`Elysee
55 et 57, rue du Faubourg Saint-Honore
75008 Paris
France

Gerhard Schröder, J. Fischer and R. Scharping,
C/o Gerhard Schoeder
Chancellor
Adenauerallee 141
PA: Briefpost, PLZ 53106
53113 Bonn
Germany

Kostas Simitis, G. Papandreou and A. Tsohatzopoulos,
C/o Kostas Simitis
Prime Minister
Office of the Prime Minister
Greek Parliament Bldg., Constitution Square
Athens
Greece

Viktor Orban, J. Martonyi and J. Szabo,
C/oViktor Orban
Prime Minister
Kossuth Lajos ter 1-3
1055 Budapest, Budapest fovaros
Hungary

David Oddsson, H. Asgrimsson and G. Palsson,
C/o David Oddsson
Prime Minister
Office of the Prime Minister
Stjornarradshusinu
150 Reykjavik
Iceland

Massimo D'Alema, L. Dini and C. Scognamiglio,
C/o Massimo D'Alema
Presidenza del Consiglio dei Ministri (Prime Minister)
Piazza Colonna, 370
00187 Rome
Italy

Jean-Claude Juncker, J. Poos and Alex Bodry,
C/o Jean-Claude Juncker
Prime Minister
Ministere d`Etat
4, rue de la Congregation
L-2910 Luxembourg
Luxembourg

Willem Kok, J. van Aartsen and F.H.G. de Grave,
C/o Willem Kok
Prime Minister
Binnenhof 20, 2513 AA
Postbus 20001, 2500 EA
The Hague
Netherlands

Kjell Magne Bondevik, K. Vollebæk and D.J. Fjærvoll,
C/o Kjell Magne Bondevik
Prime Minister
Akersgt. 42, blokk H
P.O. Box 8001 Dep
N-0030 Oslo
Norway

Jerzy Buzek, B. Geremek and J. Onyszkiewicz,
C/o Jerzy Buzek
Prime Minister
Prime Minister's Office
al. Ujazdowskie 1/3
00-583 Warsaw
Poland

Antonio Manuel de Oliveira Guterres, J.J. Matos da Gama and V. Simão,
C/o Antonio Manuel de Oliveira Guterres
Prime Minister
Gabinete do Primeiro-Ministro
Lisboa
Portugal

Jose Maria Aznar, A. Matutes and E. Serra Rexach,
C/o Excmo. Sr. Jose Maria Aznar
Presidente del Gobierno
Complejo de la Moncloa
Edf. Semillas
28071 Madrid
Spain

Bulent Ecevit, I. Cem and H. S. Turk,
C/o Bulent Ecevit
Prime Minister
Office of the Prime Minister
Basbakanlik
06573 Ankara
Turkey

FROM:

Professor Michael Mandel, Professor W. Neil Brooks, Professor Judith A. Fudge, Professor H. J. Glasbeek, Professor Reuben A. Hasson and Sil Salvaterra, Barrister and Solicitor, Community Legal Aid Services Programme,
Osgoode Hall Law School, York University,
Toronto, Ontario,
Canada M3J 1P3


David Jacobs and Brian Shell, Barristers and Solicitors,
Shell, Jacobs Lawyers
672 Dupont Street,
Suite 401
Toronto, Ontario
Canada M6G 1Z6

Christopher Black, Barrister and Solicitor,
121 Nymark Avenue
Toronto, Ontario
Canada M2J 2H3

John Philpot, Barrister and Solicitor,
Alariel Legault Beachemin Paquin Jobin Brisson & Philpot
1259 rue Berri suite 1000
Montréal, Québec
Canada H2L 4C7

Fred Stasiuk, Barrister and Solicitor,
296 Mill Road,
Unit B6
Etobicoke, Ontario,
Canada M9G 4X8

Professor Peter Rosenthal, Barrister and Solicitor,
Mathematics Department,
The University of Toronto,
Toronto, Ontario
Canada

Professor Roberto Bergalli,
Departament de Dret Penal i Ciences Penals
Universitat de Barcelona,
Av. Diagonal 684 E-08034
Barcelona, Spain

The American Association of Jurists:

Alejandro Teitelbaum,
Permanent Representative to the United Nations in Geneva.
80 Quai Gillet
69004 Lyon, France

Alvaro Ramirez Gonzalez, President,
Del Porton Oriental de la UCA 1 y media cuadra arriba
Apdo Postal 3348
Managua, Nicaragua

Vanessa Ramos,
Secretary General
200 Mercer Street 4E
New York, NY 10012

Beinusz Szmukler,
President, Consultative Council,
Peru 971 8 piso, B
1068 Buenos Aires, Argentina

IN THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

RE: William J. Clinton, Madeleine Albright, William S. Cohen, Tony Blair, Robin Cook, George Robertson, Javier Solana, Jamie Shea, Wesley K. Clark, Harold W. German, Konrad Freytag. D.J.G. Wilby, Fabrizio Maltinti, Giuseppe Marani, Daniel P. Leaf, Jean Chrétien, Lloyd Axworthy, Arthur Eggleton, Jean-Luc Dehaene, E. Derycke, J.-P. Poncelet, Vaclav Havel, J. Kavan, V. Vetchy, Poul Nyrup Rasmussen, N.H. Petersen, H. Haekkerup, Jacques Chirac, Lionel Jospin, H. Védrine, Alain Richard, Gerhard Schröder, J. Fischer, R. Scharping, Kostas Simitis, G. Papandreou, A. Tsohatzopoulos, Viktor Orban, J. Martonyi, J. Szabo, David Oddsson, H. Asgrimsson, G. Palsson, Massimo D'Alema, L. Dini, C. Scognamiglio, Jean-Claude Juncker, J. Poos, Alex Bodry, Willem Kok, J. van Aartsen, F.H.G. de Grave, Kjell Magne Bondevik, K. Vollebæk, D.J. Fjærvoll, Jerzy Buzek, B. Geremek, J. Onyszkiewicz, Antonio Manuel de Oliveira Guterres, J.J. Matos da Gama, V. Simão, Jose Maria Aznar, A. Matutes, E. Serra Rexach, Bulent Ecevit, I. Cem and H. S. Turk.

NOTICE OF THE EXISTENCE OF INFORMATION CONCERNING SERIOUS VIOLATIONS OF INTERNATIONAL HUMANITARIAN LAW WITHIN THE JURISDICTION OF THE TRIBUNAL;

REQUEST THAT THE PROSECUTOR INVESTIGATE NAMED INDIVIDUALS FOR VIOLATIONS OF INTERNATIONAL HUMANITARIAN LAW AND PREPARE INDICTMENTS AGAINST THEM PURSUANT TO ARTICLES 18.1 AND 18.4 OF THE TRIBUNAL STATUTE.

WHEREAS the International Tribunal for the Prosecution of Persons Responsible for Serious Violations of International Humanitarian Law Committed in the Territory of the Former Yugoslavia since 1991 was established by the UN Security Council with "the power to prosecute persons responsible for serious violations of international humanitarian law committed in the territory of the former Yugoslavia since 1991 in accordance with the provisions of" its Statute (Article 1);

AND WHEREAS by Article 2 of the said Statute, the Tribunal has the power "to prosecute persons committing or ordering to be committed grave breaches of the Geneva Conventions of 12 August 1949, namely the following acts against persons or property protected under the provisions of the relevant Geneva Convention" including the following:

(a) wilful killing;

(c) wilfully causing great suffering or serious injury to body or health;

(d) extensive destruction and appropriation of property, not justified by military necessity and carried out unlawfully and wantonly.

AND WHEREAS by Article 3 of the said Statute, "the International Tribunal shall have the power to prosecute persons violating the laws or customs of war. Such violations shall include, but not be limited to:

(a) employment of poisonous weapons or other weapons to cause unnecessary suffering;

(b) wanton destruction of cities, towns or villages, or devastation not justified by military necessity;

(c) attack, or bombardment, by whatever means, of undefended towns, villages, dwellings, or buildings;

(d) seizure of, destruction or wilful damage done to institutions dedicated to religion, charity and education, the arts and sciences, historic monuments and works of art and science.

AND WHEREAS by Article 6 of the said Statute "the International Tribunal shall have jurisdiction over natural persons pursuant to the provisions of the present Statute;"

AND WHEREAS Article 7 of the said Statute provides for individual criminal responsibility thus:

1. A person who planned, instigated, ordered, committed or otherwise aided and abetted in the planning, preparation or execution of a crime referred to in articles 2 to 5 of the present Statute, shall be individually responsible for the crime.

2. The official position of any accused person, whether as Head of State or Government or s a responsible Government official, shall not relieve such person of criminal responsibility or mitigate punishment.

3. The fact that any of the acts referred to in articles 2 to 5 of the present Statute was committed by a subordinate does not relieve his superior of criminal responsibility if he knew or had reason to know that the subordinate was about to commit such acts or had done so and the superior failed to take the necessary and reasonable measures to prevent such acts or to punish the perpetrators thereof.

4. The fact that an accused person acted pursuant to an order of a Government or of a superior shall not relieve him of criminal responsibility, but may be considered in mitigation of punishment if the International Tribunal determines that justice so requires.

AND WHEREAS Article 8 of the said Statute provides that the territorial and temporal jurisdiction of the Tribunal "shall extend to the territory of the former Socialist Federal Republic of Yugoslavia, including its land surface, airspace and territorial waters. The temporal jurisdiction of the International Tribunal shall extend to a period beginning on 1 January 1991;"

AND WHEREAS by Article 9 of the said Statute "the International Tribunal and national courts shall have concurrent jurisdiction to prosecute persons for serious violations of international humanitarian law committed in the territory of the former Yugoslavia since 1 January 1991" but the International Tribunal "shall have primacy over national courts;"

AND WHEREAS Article 18 of the said Statute provides inter alia that:

1. The Prosecutor shall initiate investigations ex-officio or on the basis of information obtained from any source, particularly from Governments, United Nations organs, intergovernmental and non-governmental organizations. The Prosecutor shall assess the information received or obtained and decide whether there is sufficient basis to proceed.

2. The Prosecutor shall have the power to question suspects, victims and witnesses, to collect evidence and to conduct on-site investigations. In carrying out these tasks, the Prosecutor may, as appropriate, seek the assistance of the State authorities concerned.

4. Upon a determination that a prima facie case exists, the Prosecutor shall prepare an indictment containing a concise statement of the facts and the crime or crimes with which the accused is charged under the Statute. The indictment shall be transmitted to a judge of the Trial Chamber.

AND WHEREAS the President of the Tribunal, Judge Gabrielle Kirk McDonald, in a press release of April 8, 1999, urged that:

All States and organisations in possession of information pertaining to the alleged commission of crimes within the jurisdiction of the Tribunal should make such information available without delay to the Prosecutor.

AND WHEREAS on April 30 in Geneva the United Nations High Commissioner for Human Rights Mary Robinson in a speech to the Commission cited a letter from the Prosecutor in which the Prosecutor stated:

The actions of individuals belonging to Serb forces, the Kosovo Liberation Army (KLA), or NATO may ¼ come under scrutiny, if it appears that serious violations of international humanitarian law have occurred.

AND WHEREAS High Commissioner Robinson also stated in her speech:

In the NATO bombing of the Federal Republic of Yugoslavia, large numbers of civilians have incontestably been killed, civilian installations targeted on the grounds that they are or could be of military application and NATO remains sole judge of what is or is not acceptable to bomb¼In this situation, the principle of proportionality must be adhered to by those carrying out the bombing campaign. It surely must be right to ask those carrying out the bombing campaign to weigh the consequences of their campaign for civilians in the Federal Republic of Yugoslavia.

AND WHEREAS NATO has carried out between 5,000 and 10,000 bombing missions over the territories of the former Yugoslavia since March 24, 1999;

AND WHEREAS NATO leaders have openly admitted targeting civilian infrastructure as well as military targets;

AND WHEREAS the list of targets has included fuel depots, oil refineries, government offices, power stations and communications links, such as roads, tunnels, bridges and railway links, including those not inside the region of, or in the vicinity of, Kosovo;

AND WHEREAS in addition to these deliberate attacks on civilian infrastructure and objects, there have been a great number of attacks which have caused direct physical harm and death to civilians;

AND WHEREAS it appears that these bombing missions have directly caused the death of approximately 1,000 civilian men, women and children and serious injury to 4,500 more;

AND WHEREAS instances of this nature include the 12 April bombing of a train travelling from Belgrade to Ristovac as it crossed the bridge spanning the Yuzhna Morava river at the Grdelica gorge, killing at least 10 passengers and wounding 16; the 15 April bombing of a refugee convoy in four separate locations along a 12 mile stretch of the road that runs from Prizren to Djakovica, killing approximately 74 people; the 23 April bombing of Serbian Television editorial offices, killing approximately 15 people; the 27 April bombing of a residential district in Surdulica, killing 16 people including 12 children; and the May 1 bombing of a bus on the Luzan bridge in Kosovo killing at least 34 people including 15 children;

AND WHEREAS, though the above-named NATO leaders have claimed that these incidents were accidents, they have also admitted that they were an inevitable result of their bombing strategy, a strategy which they appear to have continued unmodified and even to have intensified throughout these incidents;

AND WHEREAS there is ample evidence in the public statements of NATO leaders that these attacks on civilian targets are part of a deliberate attempt to terrorize the population to turn it against its leadership;

AND WHEREAS the NATO bombing has done an estimated $100 billion dollars in property damage and completely destroyed or seriously damaged dozens of bridges, railways and railway stations, major roads, airports, including civilian airports, hospitals and health care centres, television transmitters, medieval monasteries and religious shrines, cultural-historical monuments and museums, hundreds of schools, faculties and facilities for students and children, thousands of dwellings and civilian industrial and agricultural facilities;

AND WHEREAS refineries and warehouses storing liquid raw materials and chemicals have been hit causing environmental contamination and exposing the civilian population to the emission of poisonous gases;

AND WHEREAS the NATO bombings have also made use of weapons banned by international convention, including cruise missiles utilizing depleted uranium highly toxic to human beings;

AND WHEREAS credible detailed reports of the civilian death and destruction inflicted by the NATO bombing are attached as an Annex to this Notice;

AND WHEREAS THEREFORE there is abundant evidence that many instances of serious violations of international humanitarian law within the jurisdiction of the Tribunal have been committed by NATO forces in the attack on Yugoslavia commencing March 24 and continuing to this day;

AND WHEREAS this evidence is readily available to the Prosecutor in eyewitness, videotaped, televised and publicly broadcast reports, in press reports and on the Internet, and in the evidence presented by the Federal Republic of Yugoslavia in its current complaint against the NATO countries before the International Court of Justice;

AND WHEREAS all of the above-named persons, Heads of State and Government of the 19 NATO countries, their Foreign Ministers and Ministers of Defence, and officials and military leaders of NATO, have admitted publicly to having agreed upon and ordered these actions, being fully aware of their nature and effects;

AND WHEREAS the above-named persons have acted in open violation of the United Nations Charter, which provides in so far as is relevant:

Article 2

3. All Members shall settle their international disputes by peaceful means in such a manner that international peace and security, and justice, are not endangered.

4. All Members shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any state, or in any other manner inconsistent with the Purposes of the United Nations.

 

Article 33

1. The parties to any dispute, the continuance of which is likely to endanger the maintenance of international peace and security, shall, first of all, seek a solution by negotiation, enquiry, mediation, conciliation, arbitration, judicial settlement, resort to regional agencies or arrangements, or other peaceful means of their own choice.

Article 37

1. Should the parties to a dispute of the nature referred to in Article 33 fail to settle it by the means indicated in that Article, they shall refer it to the Security Council.

2. If the Security Council deems that the continuance of the dispute is in fact likely to endanger the maintenance of international peace and security, it shall decide whether to take action under Article 36 or to recommend such terms of settlement as it may consider appropriate.

Article 39

The Security Council shall determine the existence of any threat to the peace, breach of the peace, or act of aggression and shall make recommendations, or decide what measures shall be taken in accordance with Articles 41 and 42, to maintain or restore international peace and security.

Article 41

The Security Council may decide what measures not involving the use of armed force are to be employed to give effect to its decisions, and it may call upon the Members of the United Nations to apply such measures. These may include complete or partial interruption of economic relations and of rail, sea, air, postal, telegraphic, radio, and other means of communication, and the severance of diplomatic relations.

Article 42

Should the Security Council consider that measures provided for in Article 41 would be inadequate or have proved to be inadequate, it may take such action by air, sea, or land forces as may be necessary to maintain or restore international peace and security. Such action may include demonstrations, blockade, and other operations by air, sea, or land forces of Members of the United Nations.

Article 51

Nothing in the present Charter shall impair the inherent right of individual or collective self-defence if an armed attack occurs against a Member of the United Nations, until the Security Council has taken measures necessary to maintain international peace and security. Measures taken by Members in the exercise of this right of self-defence shall be immediately reported to the Security Council and shall not in any way affect the authority and responsibility of the Security Council under the present Charter to take at any time such action as it deems necessary in order to maintain or restore international peace and security;

AND WHEREAS the International Court of Justice has stated in ruling against United States intervention in Nicaragua:

In any event, while the United States might form its own appraisal of the situation as to respect for human rights in Nicaragua, the use of force could not be the appropriate method to monitor or ensure such respect. With regard to the steps actually taken, the protection of human rights, a strictly humanitarian objective, cannot be compatible with de mining of ports, the destruction of oil installations, or again with de training, arming and equipping of the contras.

(CASE CONCERNING THE MILITARY AND PARAMILITARY ACTIVITIES IN AND AGAINST NICARAGUA (NICARAGUA v. UNITED STATES OF AMERICA) (MERITS) Judgment of 27 June 1986, I.C.J. Reports, 1986, p.134-135, paragraphs 267 and 268)

AND WHEREAS the above-named persons, Heads of State and Government of the 19 NATO countries, their Foreign Ministers and Ministers of Defence, and officials and military leaders of NATO have acted in open violation of the NATO Treaty which provides in so far as is relevant:

Article 1

The Parties undertake, as set forth in the Charter of the United Nations, to settle any international dispute in which they may be involved by peaceful means in such a manner that international peace and security and justice are not endangered, and to refrain in their international relations from the threat or use of force in any manner inconsistent with the purposes of the United Nations.

Article 7

This Treaty does not affect, and shall not be interpreted as affecting in any way the rights and obligations under the Charter of the Parties which are members of the United Nations, or the primary responsibility of the Security Council for the maintenance of international peace and security;

AND WHEREAS the above-named persons have acted in open violation of the Protocol Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of International Armed Conflicts (Protocol I), 8 June 1977, which provides as follows:

Art 51. - Protection of the civilian population

1. The civilian population and individual civilians shall enjoy general protection against dangers arising from military operations. To give effect to this protection, the following rules, which are additional to other applicable rules of international law, shall be observed in all circumstances.

2. The civilian population as such, as well as individual civilians, shall not be the object of attack. Acts or threats of violence the primary purpose of which is to spread terror among the civilian population are prohibited.

3. Civilians shall enjoy the protection afforded by this section, unless and for such time as they take a direct part in hostilities.

4. Indiscriminate attacks are prohibited. Indiscriminate attacks are:

(a) those which are not directed at a specific military objective;

(b) those which employ a method or means of combat which cannot be directed at a specific military objective; or

(c) those which employ a method or means of combat the effects of which cannot be limited as required by this Protocol;

and consequently, in each such case, are of a nature to strike military objectives and civilians or civilian objects without distinction.

5. Among others, the following types of attacks are to be considered as indiscriminate:

(a) an attack by bombardment by any methods or means which treats as a single military objective a number of clearly separated and distinct military objectives located in a city, town, village or other area containing a similar concentration of civilians or civilian objects;

and

(b) an attack which may be expected to cause incidental loss of civilian life, injury to civilians, damage to civilian objects, or a combination thereof, which would be excessive in relation to the concrete and direct military advantage anticipated.

Art 79. Measures or protection for journalists

1. Journalists engaged in dangerous professional missions in areas of armed conflict shall be considered as civilians within the meaning of Article 50, paragraph 1.

Article 85 - Repression of breaches of this Protocol

3. In addition to the grave breaches defined in Article 11, the following acts shall be regarded as grave breaches of this Protocol, when committed wilfully, in violation of the relevant provisions of this Protocol, and causing death or serious injury to body or health:

(a) making the civilian population or individual civilians the object of attack;

(b) launching an indiscriminate attack affecting the civilian population or civilian objects in the knowledge that such attack will cause excessive loss of life, injury to civilians or damage to civilian objects, as defined in Article 57, paragraph 2 (a)(iii);

5. Without prejudice to the application of the Conventions and of this Protocol, grave breaches of these instruments shall be regarded as war crimes.

AND WHEREAS the above-named persons have acted in open violation of the Principles of International Law Recognized in the Charter of the Nüremberg Tribunal and in the Judgment of the Tribunal, as adopted by the General Assembly of the united Nations (1950), which provide in so far as is relevant:

Principle III

The fact that a person who committed an act which constitutes a crime under international law acted as Head of State or responsible Government official does not relieve him from responsibility under international law.

Principle IV

The fact that a person acted pursuant to order of his Government or of a superior does not relieve him from responsibility under international law, provided a moral choice was in fact possible to him.

Principle VI

The crimes hereinafter set out are punishable as crimes under international law:

(a) Crimes against peace:

(i) Planning, preparation, initiation or waging of a war of aggression or a war in violation of international treaties, agreements or assurances;

(ii) Participation in a common plan or conspiracy for the accomplishment of any of the acts mentioned under (i).

(b) War crimes:

Violations of the laws or customs of war include, but are not limited to, murder wanton destruction of cities, towns, or villages, or devastation not justified by military necessity.

Principle VII

Complicity in the commission of a crime against peace, a war crime, or a crime against humanity as set forth in Principle VI is a crime under international law;

THEREFORE we respectfully request that the Prosecutor immediately investigate and indict for serious crimes against international humanitarian law:

THE FOLLOWING HEADS OF STATE AND GOVERNMENT, MINISTERS OF FOREIGN AFFAIRS AND MINISTERS OF DEFENCE OF THE NATO COUNTRIES: William J. Clinton, Madeleine Albright, William S. Cohen (United States of America), Tony Blair, Robin Cook, George Robertson (United Kingdom), Jean Chrétien, Lloyd Axworthy, Arthur Eggleton (Canada), Jean-Luc Dehaene, E. Derycke, J.-P. Poncelet (Belgium), Vaclav Havel, J. Kavan, V. Vetchy (Czech Republic), Poul Nyrup Rasmussen, N.H. Petersen, H. Haekkerup (Denmark), Jacques Chirac, Lionel Jospin, H. Védrine, Alain Richard (France), Gerhard Schröder, J. Fischer, R. Scharping (Germany), Kostas Simitis, G. Papandreou, A. Tsohatzopoulos (Greece), Viktor Orban, J. Martonyi, J. Szabo (Hungary), David Oddsson, H. Asgrimsson, G. Palsson (Iceland), Massimo D'Alema, L. Dini, C. Scognamiglio (Italy), Jean-Claude Juncker, J. Poos, Alex Bodry (Luxembourg), Willem Kok, J. van Aartsen, F.H.G. de Grave (Netherlands), Kjell Magne Bondevik, K. Vollebæk, D.J. Fjærvoll (Norway), Jerzy Buzek, B. Geremek, J. Onyszkiewicz (Poland), Antonio Manuel de Oliveira Guterres, J.J. Matos da Gama, V. Simão (Portugal), Jose Maria Aznar, A. Matutes, E. Serra Rexach (Spain), Bulent Ecevit, I. Cem and H. S. Turk (Turkey);

AND THE FOLLOWING OFFICIALS AND MILITARY LEADERS OF NATO: Javier Solana, Jamie Shea, Wesley K. Clark, Harold W. German, Konrad Freytag, D.J.G. Wilby, Fabrizio Maltinti, Giuseppe Marani and Daniel P. Leaf;

AND WHOEVER ELSE shall be determined by the Prosecutor’s investigations to have committed crimes in the NATO attack on Yugoslavia commencing March 24, 1999.

Respectfully submitted, this 6th day of May, 1999__________________________

Michael Mandel (Professor)

for

W. Neil Brooks
Judith A. Fudge
H. J. Glasbeek
Reuben A. Hasson
(Professors)

Sil Salvaterra
David Jacobs
Brian Shell
Christopher Black
John Philpot
Fred Stasiuk
(Barristers and Solicitors)

Peter Rosenthal
(Professor, Barrister and Solicitor)

Roberto Bergalli (Professor)

Alejandro Teitelbaum
Alvaro Ramirez Gonzalez
Vanessa Ramos
Beinusz Szmukler
(American Association of Jurists)

ANNEX: CIVILIAN DEATH AND DESTRUCTION IN THE FORMER YUGOSLAVIA

The following are two reports from Ministry of Foreign Affairs of the Federal Republic of Yugoslavia (a designated source of information under Article 18.1 of the Stature of the Tribunal): 1) NATO Crimes Against Civilians and Civilian Infrastructure in the Federal Republic of Yugoslavia (MINISTRY OF FOREIGN AFFAIRS YUGOSLAV DAILY SURVEY - www.mfa.gov.yu/Bilteni/Engleski/si290499_1-e.html); and 2) Civilian Victims and Devastation in NATO Aggression on Yugoslavia (SERBIAINFO - www.serbia-info.com/news/1999-04/23/11210.html)

NATO CRIMES AGAINST CIVILIANS AND CIVILIAN INFRASTRUCTURE IN THE FEDERAL REPUBLIC OF YUGOSLAVIA (April 29, 1999)

The NATO criminal aggression represents the most flagrant violation

of the Charter of the United Nations since the inception of the

world Organization, a violation of the Helsinki Final Act and the

undermining of the very foundations of the international legal

order. At the same time, this aggression is a crime against peace,

stability and humanity.

The Federal Republic of Yugoslavia has warned on time the United

Nations Security Council of a possible aggression, and during the

aggression itself it requested that it be immediately halted and

most strongly condemned. Had this legitimate request of the Federal

Republic of Yugoslavia been met, enormous human sufferings and

destruction would have been avoided. The most illustrative examples

are given below.

KILLING AND PLIGHT OF THE CIVILIANS

During the last thirty-six days of NATO aggression, the Federal

Republic of Yugoslavia has been exposed to extensive civilian

destruction, unprecedented in modern history of the world. NATO

aggressors have focused their attacks primarily on civilian targets,

directly threatening the lives and fundamental human rights of the

entire population of the Federal Republic of Yugoslavia. By bombing

relentlessly the cities, towns and villages throughout Yugoslavia,

the NATO aggressor has killed so far, in nine hundred attacks, more

than a thousand civilians, including a great number of children.

Over five thousand people sustained injuries, many of whom will

remain crippled for life. At the same time, several thousand private

homes and flats have been ruined, mostly in Belgrade, Nis, Cuprija,

Aleksinac, Pristina, etc. We shall present the most tragic instances

of the killings and plight of the innocent civilian population.

Fifty-five passengers were killed and twenty-six injured in an

international passenger train on the Belgrade-Thessaloniki line.

More than four hundred civilians were killed by NATO bombs in

Kosmet: in the centre of Pristina, in Djakovica, Prizren, Kosovo

Polje, Urosevac, Kosovska Mitrovica, in refugee camps in Orahovac

and Srbica, Vitina, etc.

Thirteen civilians were killed and twenty-five wounded in an attack

on Kursumlija.

Twelve civilians were killed and forty wounded in the bombing of Aleksinac.

Sixteen RTS workers were killed and seventeen wounded in the bombing

of the headquarters of this biggest Radio and Television outlets in

the FRY. Unfortunately, the final number of victims has not been

established yet since more victims have remained buried in the

rubble.

In Pancevo, Cacak, Vranje and Nis the number of casualties has been

increasing each day.

KILLING OF CHILDREN

Children are the most vulnerable category of the population,

innocent and defenceless which suffer in particular due to the

barbaric bombing of NATO aircraft, which is illustrated by the

following examples:

The killing of seven children in Srbica from cluster bombs;

The killing of five children from the Kodza family in the village of

Doganovici near Urosevac on 24 April 1999 as a result of the delayed

effect of bombs (Edon, aged 3, Fisnik, aged 9, Osman, aged 13,

Burim, aged 14 and Vajdet, aged 15. Six other children were also

injured in the same incident, two of them were seriously wounded.

The killing of a three-year old Milica Rakic in the Belgrade suburb

of Batajnica;

The killing of six children in the refugee centre in Djakovica and

19 children in the refugee column on the Prizren-Djakovica road;

The death of a child in Kosovo Polje;

The killing of five years old girl Arta Lugic while her brothers

Neron and Egzon and her sister Arijeta were seriously wounded in

Lipljane;

The killing of nine children in Kursumlija;

The killing of two children in Aleksinac, as well as other numerous

examples.

Children are most often victims of the sprinkle cluster bombs with

delayed effect. The death toll on children would have been even more

tragic, had the missile struck the biggest Maternity Hospital in

Belgrade (It exploded some thirty metres away from the Hospital).

KILLING AND PLIGHT OF REFUGEES

Particularly tragic is the fate of refugees, who convinced that they

should not believe the propaganda ploys on the alleged "ethnic

cleansing" decided to return to their homes. Legitimate authorities

of the FRY encourage them every day to do so and guarantee their

safety. On the occasion of a return of a large group of refugees, on

14 April, on the Djakovica-Prizren road, NATO aircraft killed 75

citizens of the FRY and wounded 111. The attack of NATO aircraft was

systematically prepared and lasted for three hours. In this way,

NATO has in the most brutal way "demonstrated" that the story of

"humanitarian catastrophe" suits it only if it fits in the

legitimate aggression on the FRY, as well as that innocent civilians

are constantly taken advantage of for NATO interests in the Balkans.

In addition, NATO bombed several refugee camps in which Serbs

expelled from Croatia and Bosnia and Herzegovina were accommodated

(Djakovica, Pristina, Kursumlija, etc). Several dozens of refugees

were killed, mostly children and the frail, ruthlessly ending their

tragedy which came about in the wake of the break-up of Yugoslavia.

BOMBING OF SURDULICA

The aggressors war planes bombed at noon, on 27 April 1999, the

residential area of the town of Surdulica. On that occasion 16

citizens were killed (including 12 children), while several dozen

were wounded out of which twenty persons remained in hospital for

further medical treatment. Hundreds of houses were raised to the

ground or damaged. Special teams are still clearing up the debris so

that it is not possible at the moment to estimate the real

proportions of this notorious crime.

ASSASSINATION ATTEMPT ON PRESIDENT OF THE FEDERAL REPUBLIC OF YUGOSLAVIA SLOBODAN MILOSEVIC

An assassination attempt on the President of the Federal Republic of

Yugoslavia on 22 April 1999 represents an organised terrorist act

without precedent in the history of modern Europe. This is not only

a crime against a Head of a sovereign State, but primarily an attack

on the democratically expressed will of a people and thus against

the foundations of the democratic values of the civilisation.

Although the residence of the President of the Federal Republic of

Yugoslavia was targeted, this attack has also a symbolic meaning as

if the targets had been the homes of all Yugoslav citizens. This

crime has caused abhorrence and condemnation by international

public. However, it is incomprehensible that the United Nations

Security Council has remained silent and failed to condemn this

terrorist act or the killings of civilians and children.

CRIME AGAINST THE FREEDOM OF SPEECH

The destruction of more than ten private radio and television

stations, two dozen TV transmitters, as well as the bombing of the

Radio and Television of Serbia building on 23 April 1999 represents

the biggest aggression against freedom of thought and a disgrace to

the civilization at the threshold of a third millennium.

Transmitters at Iriski venac, Krnjaca, Mt Cer, Bukulja, Tornik, Crni

vrh, Jasetrebac, Ovcar, Grmija and others were destroyed, so that

the transmitter infrastructure at the entire territory of Serbia was

severely damaged. Two times in six days the studios and transmitter

located at the business centre "Usce" which housed TV stations: BK

TV, Pink, Kosava and SOS Channel, as well as several other radio

stations were bombed.

Transmitter of the TV station Palma was bombed and destroyed on 28

April 1999.

The satellite station "Yugoslavia" in the village of Prilike near

Ivanjica was severely damaged.

BOMBING OF THE BUILDING OF THE RADIO AND

TELEVISION OF SERBIA The building was demolished taking a heavy toll

during the bombing of the largest Radio and TV company in the

Balkans with 7000 employees and the state-of-the-art infrastructure

which was made available to hundreds of foreign correspondence. The

aim of this crime, in which 16 RTS workers were killed and 19

wounded, was more than obvious: to suppress the right to a different

opinion and its being publicly expressed with a view to pursuing

further war-mongering manipulation with the world public. Clearly,

the intention of NATO aggressors is to prevent the world public from

learning the extensive scope of their crimes and to impose on the

world their totalitarian and single-minded perception. Many

newspapers in the world and renowned journalists have already raised

their voice against the propaganda fabrications of the NATO

aggressors.

For all champions of the freedom of speech and for all people

committed to the right to freedom of expression, this destructive

act represents the last warning alarm before NATO generals take

control over the aggressors' media.

DESTRUCTION OF VITAL YUGOSLAV ECONOMIC FACILITIES According to the assessment of experts from Western countries, the

damage done to date by NATO air strikes is well in excess of one

hundred billion US dollars. By the destruction of factories,

business capacities and production facilities, more than half a

million people have lost their jobs and over two million of them

remained without any kind of income. Destroyed are the industrial

complexes in Belgrade, Novi Sad, Kragujevac, Nis, Pancevo, Cacak,

Kraljevo, Valjevo, Pristina, Vranje, Kursumlija, Krusevac, Kula,

Gnjilane, Sremska Mitrovica and in other towns and cities.

The petrochemical industry of the Federal Republic of Yugoslavia has

been totally destroyed, as well as the largest Yugoslav factory of

artificial fertilisers.

Private entrepreneurs are a particular target of NATO aggression and

the most glaring example of it is the destruction of the "Usce"

business centre in Novi Beograd which was hit on 21 and 27 April

1999. That was one of the biggest business centres in the Balkans,

which housed more than a hundred newly established private firms in

full business expansion, foreign representative offices, seven

private Radio and TV stations and one of the most modern

poli-clinics in the FRY. The building of this business centre is

also one of the landmarks of modern Belgrade.

DESTRUCTION OF BRIDGES

On the false pretext of "neutralizing the military power of the

Federal Republic of Yugoslavia", the NATO aggressor started

systematic destruction of the major Yugoslav road and rail traffic

routes. About 20 bridges have been totally demolished so far and a

few dozen of them have been damaged. Also, several dozen major and

local roads, airports, railway tracks, railway stations, etc. have

been destroyed. All ruined facilities were part of costly capital

investments, into which the resources and the efforts of several

generations of Yugoslav citizens were pooled. All the facilities are

strategic part of the European traffic infrastructure, and some of

them are of historical and cultural importance ("The Wailing Bridge

" in Novi Sad, on which the Fascists killed several thousand Jews in

the Second World War).

About 30 bridges have been destroyed including those at the

strategic European E-75 corridor. By the destruction of the bridges

on the Danube river the aggressors have blocked the entire river

navigation at this traffic artery of the greatest importance for

European economy and the shortest link between the Northern and

Mediterranean sea (The Rhein-Mein-Danube route). Thus, the European

shipping companies suffer each day the damage of over 20 million DM.

Examples: Sloboda Bridge, Wailing Bridge, Zezelj Bridge and the

bridge in Beska (all in the city of Novi Sad), several bridges on

the Ibar primary road and on the major railway lines.

ENVIRONMENTAL DISASTER

Concurrently with the humanitarian, NATO strikes have caused an

environmental catastrophe which is endangering not only the Federal

Republic of Yugoslavia, but also the neighbouring countries and the

entire European continent. Ecology does not recognize boundaries.

The NATO aggressor is thus teetering on the brink of another

Chernobyl in the heart of Europe. The destruction of petrochemical

installations, the warehouses storing semi-processed and finished

products of the chemical industry have already caused significant

adverse effects on the health of the population of the Federal

Republic of Yugoslavia and the neighbouring countries. During some

of the air strikes it was pure luck that an environmental

catastrophe was not provoked spreading all over Europe.

The aggressor's attacks did not spare even huge forests, tourist

centres and the national parks on the mountains of Serbia (Kopaonik,

Zlatibor, Divcibare, Tara, Prokletije, Sara, Fruska Gora). The ozone

layer was depleted by the exhaust gases. The Black Sea, Aegean and

the Adriatic basins, practically the entire Mediterranean, are

threatened by environmental pollution.

Examples: Nitrogen factory in Pancevo, the oil refineries in Pancevo

and Novi Sad, the chemical company "Prva iskra" in Baric and others.

HOSPITALS AND HEALTH INSTITUTIONS

The aggressors' bombings, calculated to provoke the greatest

possible confusion and panic among innocent people, have damaged

many clinical and hospital centres, inflicting not only great

material damage to property (destruction of buildings and expensive

medical equipment), but also causing new health problems and

intensifying psychological traumas among the sick people. The

destruction of all the three bridges in Novi Sad totally cut off and

left, without the supply of water, the largest Yugoslav centre for

the treatment of cardiovascular diseases, to which several million

people gravitate. The Maternity Hospital in Belgrade, and the

biggest hospital in the Balkans (Military Medical Academy Hospital -

VMA), and the Orthopaedic hospital of Banjica, the hospitals in

Cuprija and Aleksinac, as well as the medical centres in Pristina

and in many other towns were damaged.

DESTRUCTION OF PRE-SCHOOL INSTITUTIONS, SCHOOLS

AND UNIVERSITIES

Since the outset of the aggression, NATO has put a stop to the

education of close to one million pupils and students in Yugoslavia.

Over three hundred facilities built for the education and upbringing

of children and young people of all ages were destroyed. This will

inevitably be reflected on the development and social integration of

young people. Hard hit are university centre in Nis (Machine

Engineering, Civil Engineering, Electronical, Technical, Law and

Economics faculties), in Pristina (Agricultural and Machine

Engineering faculty) and Novi Sad (Faculty of Philosophy).

DESTRUCTION OF WORLD CULTURAL HERITAGE

ON THE SOIL OF THE FR OF YUGOSLAVIA

Kosovo and Metohija in particular, but also the entire territory of

the FR of Yugoslavia, is a treasury of European culture and

civilization since ancient times. By violating all international

conventions on the protection of civilization and its heritage, and

in the pursuit of the spirit of aggressive nihilism and new

barbarity, more than 50 monasteries and churches have been severely

damaged thus far, as well as a couple of dozen of other cultural and

historic monuments, some under UNESCO protection. Severe damage was

caused to the monastery of the Patriarchate of Pec (12th century),

Zica (13th century), Decani and Gracanica (14th century, under

UNSECO protection), medieval towns of Zvecan (13th century) and

Smederevo (15th century), Petrovaradin fortress (18th century),

seventeen monasteries on Fruska Gora (15-18th century) and many

other priceless historical monuments. The bombs have even destroyed

many cemeteries all across Yugoslavia.

USE OF PROHIBITED WEAPONS

In NATO attacks, the state-of-the-art weapons have been used, but

also those prohibited under international conventions, such as

cluster bombs and slow activating bombs. In a month-long attacks on

civilian and other facilities in Serbia, NATO aircraft fired more

than 3,500 missiles, including 60 containers with 14,400 cluster

bombs. As many as 3,600 cluster bombs were used in the attacks

against towns in Kosmet - Pristina, Urosevac, Djakovica, Prizren

etc, and many other places and facilities in Serbia. Before the

attacks, radio locators were dropped from the aircraft, found in the

vicinity of many civilian and business facilities in Serbia.

CO-ORDINATION BETWEEN NATO AND TERRORISTS OF THE SO-CALLED "KLA"

While before the onset of the aggression Albanian terrorists counted

on NATO aircraft as air support to their armed groups, now arming,

equipping and transport of Albanians living in the USA and other

western countries is under way, for actions in the FRY, with a view

to making armed formations from them to serve as ground troops of

the "Alliance". Albanian terrorists are being trained and armed in

the camps in northern Albania - in Tropoje, Kukes and Bajram Curri

(they are trained by British, US and Turkish commandos), and then

illegally infiltrated into Kosovo and Metohija. Such activity, in

direct violation of the resolutions of Security Council, has been

particularly stepped up in April when concrete plans for ground

invasion against the FRY started to be hatched. So far, several

hundred terrorists have been transported from the USA to Albania.

Plans are made to equip, arm and train for coordinated actions with

NATO, around 6,000 Albanians. According to western sources, Albanian

terrorists represent the main source of intelligence for NATO, of

military character or those aimed at spreading propaganda against

our country.

At the moment it is difficult to perceive and evaluate all the

humanitarian, economic, environmental, health and other consequences

of the NATO criminal aggression against the FR of Yugoslavia. The

greatest victim of the aggression is the entire Yugoslav people and

its material and cultural resources. At the same time, the violation

of the Charter of the United Nations, the NATO has created a

precedent which may a cast a shadow over the future of all peoples

and sovereign States. The cause for concern is all the grater

because, by combining pressure and promises, NATO is drawing an

increasing number of countries into its aggression against the FR of

Yugoslavia, which will have long-term negative consequences on the

future relations and co-operation between all Southeast European

countries. Attempts by NATO to justify its brutal aggression by an

alleged care for the refugees may bring about an irreversible

degradation of the United Nations and involve this highest

international forum in the crime against a country which is one of

its founding members.

 

 

 

CIVILIAN VICTIMS AND DEVASTATION IN NATO AGGRESSION ON YUGOSLAVIA (April 23, 1999)

OVERVIEW OF DESTRUCTION OF CIVILIAN TARGETS ON THE TERRITORY OF THE FEDERAL REPUBLIC OF YUGOSLAVIA AS A RESULT OF BARBARIC AND CRIMINAL AGGRESSION BY NATO, FROM 24 MARCH TO 19 APRIL 1999

CIVILIAN CASUALTIES

From the onset of NATO aggression against our country up to 19 April 1999, the North Atlantic Alliance made over 7,000 criminal attacks against the territory of the Federal Republic of Yugoslavia. 700 warplanes, of which 530 combat planes, were used; more than 2000 cruise missiles were launched and over 6,000 tons of explosives were dropped.

About 500 civilians were killed and more than 4,000 sustained serious injuries e.g.: in Kursumlija: 13 dead and 25 wounded;

in Pancevo: 2 dead and 4 wounded;

in Cacak: one dead and 7 wounded;

in Kragujevac: over 120 workers were wounded during an attack on the car factory "Zastava";

in Vranje: two dead and 23 wounded;

in Aleksinac: 12 dead and more than 40 wounded;

in Nagavac village, Orahovac municipality: 11 dead and 5 wounded;

in Pristina: 10 dead and 8 wounded;

Grdelicka gorge: 55 killed and 16 wounded;

attack on two refugee columns, with four cruise missiles, on the

Djakovica-Prizren road: 75 killed and 100 wounded, of whom 26 critically;

in the village of Srbica: 10 killed, among whom 7 children;

Belgrade suburb of Batajnica: a three year old girl was killed,and

five civilians wounded.

Three million children are endangered in our country as a result of war and bombardment by NATO criminals.

After these barbarian attacks hundreds of thousands citizens have

been exposed to poisonous gasses which can have a lasting

consequences on the health of the entire population and the

environment.

After the demolition of the Petrovaradin bridge, Novi Sad and

Petrovaradin were cut of water supply (600 000 citizens) since the

main and city pipeline was constructed into the bridge. About one

million citizens in our country are short of water supply due to the bombardment of NATO aggressors.

About 500 000 workers became jobless due to the total destruction of industrial facilities all around the country. Two million citizens have no means for living and cannot ensure the minimum for existence.

Overall material damage is enormous. Preliminary estimates indicate that barbaric air strikes of the neo-fascist NATO alliance, since the beginning of the unprovoked aggression on the SR of Yugoslavia,on industrial, commercial and civil facilities and structures throughout our peace-loving country, have incurred damages in excess of 10 billion dollars. In the territory of the northern province of Vojvodine alone, damages have been estimated in excess of 3,5 billion dollars.

TRAFFIC

The road and railway networks, especially road and rail bridges,

most of which were destroyed or damaged beyond repair, suffered

extensive destruction. The targets of attacks were such

communications as:

1. BRIDGES (11 DESTROYED AND 13 DAMAGED):

1.The Varadin Bridge over the Danube was destroyed (on 1 April

1999);

2.The "Sloboda" (Freedom) Bridge over the Danube was destroyed (on 4 April 1999);

3.The "Mladosti" (Youth) Bridge over the Danube, connecting Backa

Palanka with Ilok, was damaged (on 4 April 1999);

4.The new railway bridge over the Danube connecting Bogojevo and

Erdut was damaged (on 5 April 1999);

5.The road bridge over the Danube, connecting Bogojevo with Erdut

was damaged (on 5 April 1999);

6.The bridge over the Danube along the Beograd-Novi Sad road, near

Beska, Indjija municipality, was damaged (on 1 April 1999);

7.The road bridge along the Magura Belacevac road, 15 kilometres

from Pristina, suffered extensive damage;

8.The "Zezeljov" Bridge in Novi Sad was damaged (on 5 April 1999);

9.The bridge over the Ibar river, Biljanovac municipality, was

damaged (on 5 - 13 April 1999);

10.The bridge over the Vrbacka river near Jezgrovic was destroyed

(on 5 April 1999);

11.The "Lozno" railway bridge near Usce was destroyed (on 5 April

1999);

12.The road bridge on the road leading to Brvenik, near Usce, was

destroyed (on 5 April 1999);

13.The bridge along the Nis-Pristina primary road, near Kursumlija,suffered extensive damage (on 5 April 1999);

14.The bridge near Zubin Potok was destroyed (on 5 April 1999);

15.The Grdelica gorge railway bridge was damaged (on 12 April 1999);

16.The road bridge over the Kosanica river near Kursumlija was

damaged (on 13 April 1999);

17.The old bridge on the river Rasina in the town of Krusevac (12-13 April 1999);

18.The Krusevac-Pojate bridge on the river Zapadna Morava, at the

village of Jasika, was destroyed (on 13 April 1999);

19.The railway bridge on the river Lim, between Priboj and

Prijepolje, near hydroelectric power station Bistrica was destroyed(on 15 April 1999);

20.The road bridge on the river Toplica, on the Nis-Pristina road

near the town of Kursumlija, was heavily damaged (14 and 19 April

1999);

21.The bridge on the river Ibar, at the village of Biljanovac near

Raska, sustained heavy damages (15.04.1999.);

22.The bridge between Smederevo and Kovin has been destroyed (16

April 1999);

23.The railway bridge on the river Kostajnica, near Kursumlija, has sustained heavy damages and is out of service (18.04.1999.);

24.The bridge on the river Kosanica, at the village of Selo Visoko,has sustained heavy damages and is out of service (18.04.1999.);

2. RAILWAYS RAILWAY STATIONS (12):

1.The Kraljevo - Kosovo Polje rail, near Ibarska Slatina;

2.The Belgrade - Bar rail, due to the destruction of the railway

track near the village of Strbce and destruction of the bridge on

the river Lim, between Priboj and Prijepolje;

3.The Kursumlija - Prokuplje rail, near Pepeljevac village;

4.The Kraljevo - Kosovo Polje rail, near Ibarska Slatina;

5.The Nis - Pristina rail, near Kursumlija;

6."Sarpelj" tunnel, near Jerinje village, 15 km north of Leposavic

towards Raska, was destroyed;

7.Railway station in Kraljevo (Bogutovac);

8.Railway station in Kosovo Polje;

9.The Belgrade - Thessaloniki rail, due to the destruction of the

bridge in the Grdelica gorge;

10.Railway station in the town of Biljanovac;

11.Railway track and overpass (Josinacka Banja) near the town of

Biljanovac;

12.Railway track Kursumlija - Podujevo, due to damages on the

railway bridge at Kursumlija;

3. ROADS AND TRANSPORTERS (6 MAJOR ROADS):

1.Ibarska primary road, due to damages to the bridge on the Ibar

river, Biljanovac municipality, and destruction of the road between Pozega and Cacak;

2.Belgrade-Zagreb highway, near Stari Banovci;

3.Traffic suspended on the Kosovska Mitrovica-Ribarici section of

the Adriatic highway due to the destruction of the bridge over the

Vrbacka river;

4."Jedinstvo" bus station in Vranje sustained extensive damage;

5."Kosmet Prevoz" transporter in Gnjilane (a hangar full of new

buses);

6.Kraljevo-Raska primary road;

7.Bus station in Pristina;

8.Traffic has been suspended on the Krusevac-Pojate road due to the destruction of the bridge on the Zapadna Morava, in the village of Jasika;

9.Traffic has been suspended on the Nis-Pristina road, due to the

fact that the bridge on the river Toplica, near the town of

Kursumlija, has sustained heavy damage;

4. AIRPORTS (7):

"Slatina" in Pristina; "Batajnica" and "Surcin" in Belgrade; Nis

airport; "Ponikve" in Uzice; "Golubovac" in Podgorica, "Ladjevci"

airport near Kraljevo; agricultural and sports airfield in Sombor.

ECONOMIC AND CIVILIAN TARGETS, PUBLIC INSTITUTIONS

The air strikes have so far destroyed or damaged all over the

Federal Republic of Yugoslavia several thousand economic facilities and dwellings. In the Leskovac region alone, over 3,500 industrial facilities and dwellings were either destroyed or damaged.

The devastation of NATO forces was particularly manifest in

Pristina, Novi Sad, Aleksinac, Djakovica, Prokuplje, Gracanica,

Cuprija, etc. Housing blocks on the outskirts of Belgrade - Kijevo

Knecevac, Batajnica, Jakovo, Borca, as well as the area around

Pancevo, were under attack.

1. INDUSTRY AND TRADE:

The NATO aggressor's attacks targeted the factories and industrial

facilities which directly cater for the needs of the population,

among which are:

1."Lola Utva" agricultural aircraft factory in Pancevo;

2."Galenika" drug factory in Belgrade;

3."Zdravlje" pharmaceutical plant in Leskovac;

4."Sloboda" white goods factory in Cacak;

5."Din" tobacco industry in Nis;

6."Elektronska industrija" factory in Nis;

7."Div" cigarette factory in Vranje;

8.Tubes factory in Urosevac;

9."Jastrebac" machine industry in Nis;

10."Milan Blagojevic" chemical plant in Lucani;

11.Plastics factory in Pristina;

12."Binacka Morava" hydro construction company in Gnjilane;

13."Nova Jugoslavija" printers in Vranje;

14.Facilities of the "Beograd" rail company in Nis;

15.Over 250 commercial and crafts shops in Djakovica were destroyed;

16."Dijana" shoe factory in Sremska Mitrovica;

17."Zastava" car factory in Kragujevac;

18."14 Oktobar" machine factory in Krusevac;

19.Cotton yarn factory in PriStina;

20."Krusik" holding corporation in Valjevo;

21."Ciklonizacija" in Novi Sad;

22."Tehnogas" in Novi Sad;

23."Novograp" in Novi Sad;

24."Gumins" in Novi Sad;

25."Albus" in Novi Sad;

26."Petar Drapsin" in Novi Sad;

27."Motins" in Novi Sad;

28."Izolacija" in Novi Sad;

29."Novokabel" in Novi Sad;

30."Istra" fittings factory in Kula;

31.The port of Bogojevo;

32.Industrial complex "Dvadeset Prvi Maj" in Rakovica;

33.Machine building plant "Industrija Motora Rakovica" in Rakovica;

34.Factory "Jugostroj" in Pancevo;

35.Factory "Frigostroj" in Pancevo;

36.Surface coal mine "Belacevac";

2. REFINERIES AND WAREHOUSES

Refineries and warehouses storing liquid raw materials and chemicals intended for the oil and chemical industry, were hit in Pancevo, Novi Sad, Sombor and elsewhere, causing large contamination of soil and the air:

1.Fuel storage in Lipovica, which caused a great fire in the

Lipovica forest (on 26 March 1999);

2.Oil Refinery in Pancevo - totally demolished (4-16 April 1999);

3."Jugopetrol" installations in Smederevo (on 4-13 April 1999);

4."Jugopetrol" storage in Sombor (on 7 April 1999);

5."Beopetrol" storages in Belgrade and Bogutovac (on 4 April 1999);

6."Beopetrol" fuel storage in Pristina (on 7 April 1999);

7.Fuel storage of the boiler plant in Novi Beograd (on 4 April

1999);

8.Thermo electric power station/boiler plant in Novi Sad (on 5 April1999);

9.Oil Refinery in Novi Sad, storage of bitumen (5 and 6 April 1999);

10.Fuel storage "Naftagas promet" which is located 10 km from Sombor(5 April 1999);

11.Naftagas warehouse between Conoplje and Kljaicevo (Sombor);

12.Jugopetrol warehouse in Pristina (on 12 April 1999);

13.Jugopetrol petrol station in Pristina ( on 13 April 1999);

14.Petrochemical industry "DP HIP PETROHEMIJA" in Pancevo – totally demolished (14-15 April 1999);

15.Fertilizer plant "DP HIP AZOTARA" in Pancevo - totally destroyed (14-15 April 1999);

16.Chemical plant "Prva Iskra" in Baric - destruction of the

production line (19 April 1999);

3. AGRICULTURE:

1.PIK "Kopaonik" in Kursumlija;

2.PIK "Mladost" in Gnjilane;

3.Agricultural Complex "Malizgan" in Dolac;

4.Agricultural Complex "Djuro Strugar" in Kula;

5.In forest fires caused by NATO cruise missiles and bombs over 250 hectares of forests have been burned down;

6.Several thousand hectares of fertile land, many rivers, lakes and underground waters have been polluted due to the spillage of petrochemical substances, oil spills and slicks;

4. HOSPITALS AND HEALTH CARE CENTRES (16):

NATO aviation also targeted many hospitals and health-care

institutions, which have been partially damaged or totally

destroyed, including:

Hospital and Medical Centre in the territory in Leskovac;

Hospital and Poly-clinic in Nis;

Gerontological Centre in Leskovac;

General Hospital in Djakovica;

City Hospital in Novi Sad;

Gynaecological Hospital and Maternity Ward of the Clinical Centre in Belgrade;

Neuropsychiatric Ward "Dr. Laza Lazarevic" and Central Pharmacy of

the Emergency Centre in Belgrade;

Army Medical Academy in Belgrade;

Medical Centre and Ambulance Centre in Aleksinac;

"Sveti Sava" hospital in Belgrade;

Medical Centre in Kraljevo;

Dispensary on Mount Zlatibor;

Health Care Centre in Rakovica;

5. SCHOOLS (MORE THAN 190 FACILITIES)

Over 190 schools, faculties and facilities for students and children were damaged or destroyed (over 20 faculties, 6 collages, 40 secondary and 80 elementary schools, 6 student dormitories), including:

Elementary schools "16. oktobar" and "Vladimir Rolovic" in Belgrade;

Day-care centre in settlement Petlovo Brdo in Belgrade;

Two secondary schools in the territory of Nis;

Elementary schools "Toza Markovic", "Djordje Natosevic", "Veljko

Vlahovic", "Sangaj" and "Djuro Danicic" and a day-care centre "Duga" in Novi Sad and creches in Visarionova Street and in the

neighbourhood of Sangaj; Traffic School Centre, Faculty of

Philosophy;

Four elementary schools and a Medical high school in the territory

of Leskovac;

Elementary school in Lucane, as well as a larger number of educationfacilities in the territory of Kosovo and Metohija;

Faculties of Law and Economics and elementary school "Radoje

Domanovic" in Nis;

Elementary schools in Kraljevo and the villages of Cvetka, Aketa and Ladjevci;

In Sombor: elementary schools "Ivo Lola Ribar", "A. Mrazovic", "N.

Vukicevic" and "Nikola Tesla" in Kljajicevo;

School centre in Kula;

Elementary school and Engineering secondary school centre in

Rakovica;

6. PUBLIC AND HOUSING FACILITIES (TENS OF THOUSANDS)

Severe damage to the facilities of the Republican and Federal

Ministry of the Interior in Belgrade (3 April 1999),

Damage to the building of the Institute for Security of the Ministry of the Interior in Banjica (3 April 1999);

Severe damage to the TV RTS studio in Pristina;

Heavy damage to Hydro-Meteorological Station (Bukulja, near

Arandjelovac);

Post Office in Pristina destroyed (7 April 1999);

Refugee centre in Pristina destroyed (7 April 1999);

"Tornik" ski resort on Mount Zlatibor (on 8 April 1999);

"Divcibare" mountain resort (on 11 April 1999);

"Baciste" Hotel on Mount Kopaonik (on 12 April 1999);

City power plant in the town of Krusevac (12-13 April 1999);

Meteorological Station on Mount Kopaonik damaged (on 13 April 1999);

Four libraries in Rakovica sustained heavy damage: "Radoje Dakic",

"Isidora Sekulic", "Milos Crnjanski" and "Dusan Matic";

Refugee camp "7 juli" in Paracin has sustained heavy damage;

Office building of the Provincial Executive Council of Vojvodina,

Novi Sad;

Several thousand housing facilities damaged or destroyed, privatelyor State owned, across Yugoslavia - most striking examples being housing blocks in downtown Aleksinac and those near Post Office in Pristina.

7. INFRASTRUCTURE:

Electrical Power Supply in Batajnica (26 March 1999);

Damage to water supply system in Zemun (5 April 1999);

Damage to a power station in Bogutovac (10 April 1999);

Telephone lines cut off in Bogutovac (10 April 1999);

Damage to a power station in Pristina (12 April 1999);

Damage to Bistrica hydroelectric power station in Polinje (13 April 1999);

TELECOMMUNICATIONS

TV TRANSMITTERS (17):

1.Jastrebac (Prokuplje)

2.Gucevo (Loznica)

3.Cot (Fruska Gora)

4.Grmija (Pristina)

5.Bogutovac (Pristina)

6.TV transmitter on Mt Goles (Pristina)

7.Mokra Gora (Pristina)

8.Kutlovac (Stari Trg)

9."Cigota" (Uzice)

10."Tornik" (Uzice)

11.Transmitter on Crni Vrh (Jagodina)

12.Satellite station (in Prilike near Ivanjica)

13.TV masts and transmitters (Novi Sad)

14.TV transmitter on Mt Ovcara (Cacak)

15.TV transmitter in Kijevo (Belgrade)

16.TV transmitter on Mt Cer

17.Communications relay on Mt Jagodnji (Krupanj)

CULTURAL-HISTORICAL MONUMENTS AND RELIGIOUS SHRINES

MEDIEVAL MONASTERIES AND RELIGIOUS SHRINES (16):

1.Monastery Gracanica from 14th century (24 March - 6 April 1999);

2.Monastery Rakovica from 17th century (29 March 1999);

3.Patriarchate of Pec (1 April 1999);

4.Church in Jelasnica near Surdulica (4 April 1999);

5.Monastery of the Church of St. Juraj (built in 1714) in

Petrovaradin (1 April 1999);

6.Monastery of Holy Mother (12th century) at the estuary of the Kosanica in the Toplica - territory of municipality of Kursumlija (4 April 1999);

7.Monastery of St. Nicholas (12th century) in the territory of the

municipality of Kursumlija (4 April 1999);

8.Monastery of St. Archangel Gabriel in Zemun (5 April 1999);

9.Roman Catholic Church St. Antonio in Djakovica (29 March 1999);

10.Orthodox cemetery in Gnjilane (30 March 1999);

11.Monuments destroyed in Bogutovac (8 April 1999);

12."Kadinjaca" memorial complex (8 April 1999);

13.Vojlovica monastery near Pancevo (12 April 1999);

14.Hopovo monastery, iconostasis damaged (12 April 1999);

15.Orthodox Christian cemetery in Pristina (12 April 1999);

16.Monastery church St, Archangel Michael in Rakovica (16 April

1999);

CULTURAL-HISTORICAL MONUMENTS AND MUSEUMS (8):

1.Severe damage to the roof structure of the Fortress of

Petrovaradin (1 April 1999);

2.Heavy damage to "Tabacki bridge", four centuries old, in Djakovica(5 April 1999);

3.Substantial damage to the building in Stara Carsija (Old street)

in Djakovica (5 April 1999);

4.Destroyed archives housed in one of the Government buildings in

Belgrade (3 April 1999);

5.Memorial complex in Gucevo (Loznica);

6.Memorial complex "Sumarice" in Kragujevac;

7.Vojvodina Museum in Novi Sad;

8.Old Military Barracks in Kragujevac - under the protection of the state (16 April 1999);

Source: Ministry of Foreign Affairs of FR Yugoslavia