TABLE OF CONTENTS

I. INTRODUCTION

II. CONSIDERATIONS REGARDING THE EVALUATION OF EVIDENCE

III. THE CONTEXT IN WHICH THE ATTACK OF 6 DECEMBER 1991 TOOK PLACE

A. General background
B. Dubrovnik before October 1991

1. The broader Dubrovnik, the city of Dubrovnik and the Old Town
2. Croatian forces in Dubrovnik
3. JNA forces around Dubrovnik

C. Combat operations around Dubrovnik before October 1991

1. JNA blockade by Croatian forces
2. Mobilisation of Croatian and JNA forces
3. JNA directive to blockade Dubrovnik

D. Combat operations around Dubrovnik in October 1991
E. Shelling of Dubrovnik in October 1991
F. October negotiations and ceasefire
G. Combat operations around Dubrovnik in early November 1991
H. The shelling of the Old Town in November 1991
I. November negotiations and ceasefire

IV. THE ATTACK ON 6 DECEMBER 1991

A. The planning of the attack – events before 6 December 1991
B. The attack on the Old Town on 6 December 1991 – the experience of the residents
C. The attack on the Old Town of Dubrovnik on 6 December 1991 - the attackers
D. The events of 6 December 1991
E. The role of the Accused - interrelationship of the Accused, Admiral Jokic and General Kadijevic
F. How did the Old Town come to be shelled?

1. Extent of damage
2. Was damage deliberately inflicted by Croatian forces or interests?
3. Did JNA forces fire only at Croatian military positions?

V. JURISDICTION UNDER ARTICLE 3 OF THE STATUTE

A. Existence of an armed conflict and nexus between the acts of the Accused and the armed conflict
B. The four Tadic conditions

1. Murder and cruel treatment
2. Attacks on civilians and civilian objects

(a) Attacks on civilians
(b) Attacks on civilian objects

3. Destruction and devastation of property, including cultural property

VI. THE CHARGES

A. Crimes against persons (Count 1 and 2)

1. Murder (Count 1)

(a) Law
(b) Findings

(i) Tonci Skocko
(ii) Pavo Urban

2. Cruel treatment (Count 2)

(a) Law
(b) Findings

(i) Ivo Vlasica
(ii) Mato Valjalo

B. Attacks on civilians and civilian objects (Counts 3 and 5)

1. Law
2. Findings

C. Crimes against property, including cultural property (Counts 4 and 6)

1. Law on devastation not justified by military necessity (Count 4)
2. Law on destruction or wilful damage of cultural property (Count 6)
3. Findings on Counts 4 and 6

VII. INDIVIDUAL CRIMINAL RESPONSIBILITY OF THE ACCUSED

A. Ordering

1. Law
2. Findings
3. Conclusion

B. Aiding and abetting

1. Law
2. Findings
3. Conclusion

C. Command responsibility

1. Law

(a) Superior-subordinate relationship
(b) Mental element: the superior knew or had reason to know
(c) Necessary and reasonable measures

2. Findings

(a) Superior-subordinate relationship

(i) Command structure
(ii) Effective control

a. Did the Accused have the material ability to prevent the attack on the Old Town of 6 December 1991?
b. Did the Accused have the material ability to punish the perpetrators?

(iii) Conclusion

(b) Mental element: did the Accused know or have reason to know that his subordinates were about to or had committed crimes?
(c) Measures to prevent and to punish

(i) Measures to prevent
(ii) Measures to punish

3. Conclusion

VIII. CUMULATIVE CONVICTIONS

A. Should there be cumulative convictions?
B. Concurrent responsibility under Articles 7(1) and 7(3) of the Statute

IX. SENTENCING

A. The gravity of the offence
B. Aggravating and mitigating circumstances
C. The general practice in the courts of the former Yugoslavia
D. Credit for time served in custody

X. DISPOSITION

ANNEX I: DESTROYED OR DAMAGED BUILDINGS OR STRUCTURES

ANNEX II: GLOSSARY OF TERMS

ANNEX III: MAPS & PHOTOGRAPHS

ANNEX IV: PROCEDURAL HISTORY

A. Pre-trial proceedings

1. Indictment and initial appearance
2. History of indictments
3. Severance of proceedings and guilty pleas
4. Order for provisional release
5. Commencement of trial and vacation of the Accused’s order for provisional release
6. Trial Chamber composition

B. Trial proceedings

1. Overview
2. Matters relating to witnesses
3. Evidentiary issues
4. Access to documents
5. Health of the Accused
6. Rule 98bis Decision
7. Site visit