The Accused  Nebojsa PAVKOVIC born 10 April 1946 in Senjski Rudnik, present-day Serbia and Montenegro Transferred to the ICTY: 25 April 2005 Vladimir LAZAREVIC born 23 March 1949 in Gricar Transferred to the ICTY: 3 February 2005 Initial appearance: 7 February 2005, pleaded “not guilty” to the five counts of the Indictment Provisional release: granted on 14 April 2005, effective on 15 April 2005 Vlastimir DJORDJEVIC born in 1948 in Koznica, Vladicin Han Municipality Remains at large Sreten LUKIC born 28 March 1955 in Visegrad municipality, present-day Bosnia and Herzegovina Transferred to the ICTY: 4 April 2005 Initial Appearance: 6 April 2005

Factual allegations:
The Indictment, filed confidentially and ex parte on 25 September 2003, alleges that the Accused planned, instigated, ordered, committed, or otherwise aided and abetted in the planning, preparation, or execution of the alleged crimes of Counts one to five. "Committing" in this Indictment refers to participation in a joint criminal enterprise as a co-perpetrator. The Indictment alleges that the purpose of this joint criminal enterprise was, inter alia, the expulsion of a substantial portion of the Kosovo Albanian population from the territory of the province of Kosovo in an effort to ensure continued Serbian control over the province. This joint criminal enterprise allegedly came into existence no later than October 1998 and continued throughout the time period when the crimes alleged in Counts one to five occurred: beginning on or about 1 January 1999 and continuing until 20 June 1999. The Indictment continues to allege that each of the Accused, acting individually or in concert with each other and with others known and unknown, significantly contributed to the joint criminal enterprise using de jure and de facto powers available to them.

The Indictment alleges that forces of the Federal Republic of Yugoslavia ("FRY") and Serbia, in a deliberate and widespread or systematic manner, forcibly expelled and internally displaced hundreds of thousands of Kosovo Albanians. To facilitate these expulsions and displacements, these forces intentionally created an atmosphere of fear and oppression through the use of force, threats of force and acts of violence. It is further alleged that throughout Kosovo, forces of the FRY and Serbia engaged in a widespread and systematic campaign of destruction of property owned by Kosovo Albanian civilians. This was accomplished by the widespread shelling of towns and villages and the burning and destruction of property. As a result of these orchestrated actions, villages, towns, and entire regions were made uninhabitable for Kosovo Albanians. In order to perpetuate the climate of fear, forces of the FRY and Serbia allegedly committed widespread and systematic acts of brutality and violence against Kosovo Albanians. Many Kosovo Albanians who were not directly forcibly expelled from their communities fled as a result of the climate of terror created by the widespread or systematic beatings, harassment, sexual assaults, unlawful arrests, killings, shelling and looting carried out across the province.

Colonel General Nebojsa Pavkovic was appointed Commander of the Armed Forces of the Federal Republic of Yugoslavia ("VJ") 3^rd Army on 25 December 1998 and assumed command on 13 January 1999. He exercised his authority as VJ 3^rd Army Commander in relation to events in Kosovo from January 1999 to June 1999, inclusive. Under the law of the FRY and through joint command and coordination structures, Nebojsa Pavkovic also exercised command authority or control over republic police units subordinated to, or operating in co-operation or co-ordination with, the VJ 3^rd Army as well as military-territorial units, civil defence units, members of the Serbian Ministry of Internal Affairs ("MUP") and other armed groups.

Colonel General Vladimir Lazarevic was appointed Commander of the Pristina Corps of the VJ 3^rd Army in December 1998 and assumed command no later than 6 January 1999. He exercised his authority as commander of the Pristina Corps as well as, through the FRY Law on Defence and through joint command and coordination structures and mechanisms, military-territorial units, civil defence units and other armed groups in relation to events in Kosovo from January 1999 to June 1999, inclusive. It further alleges that his subordinates included members of the MUP, military-territorial units, civil defence units and other armed groups.

Colonel General Vlastimir Djordjevic was Assistant Minister of the MUP and Chief of the Public Security Department (“RJB”) by 1 June 1997. The Indictment alleges he was responsible for ensuring that all units of the RJB in Serbia (including Kosovo) between 1 January and 20 June 1999, operated in accordance with decisions made by other members of the joint criminal enterprise and federal and republic laws and regulations. It further alleges that his subordinates included members of the MUP, military-territorial units, civil defence units and other armed groups.

Colonel General Sreten Lukic became Head of the MUP Staff for Kosovo on 1 June 1998. The Indictment alleges that in this capacity he planned, organized, guided, co-ordinated and controlled the work of the MUP in Kosovo. As such he was obligated to protect human lives and the safety of persons and possessions, to prevent and detect criminal acts and to arrest their perpetrators and to maintain law and order. As a superior officer of the MUP, Sreten Lukic was allegedly responsible for ensuring that MUP units in Kosovo, between 1 January and 20 June 1999, operated in accordance with decisions made by other members of the joint criminal enterprise and federal and republic laws and regulations. It further alleges that his subordinates included members of the MUP, military-territorial units, civil defence units and other armed groups.

Charges
The Indictment charges Nebojsa Pavkovic, Vladimir Lazarevic, Vlastimir Djordjevic and Sreten Lukic on the basis of their individual criminal responsibility (Article 7(1) of the Statute of the Tribunal) and their superior criminal responsibility (Article 7(3) of the Statute) with:

Four counts of crimes against humanity (Article 5 – deportation; other inhumane acts (forcible transfer); murder; persecutions on political, racial and religious grounds)
One count of violations of the laws or customs of war (Article 3 – murder)