WRITTEN EVIDENCE PRESENTED TO THE COURT AND THE DEFENDANT STATE

IN THE LAWSUITS FOR COMPENSATION OF DAMAGES
INITIATED BY THE FAMILIES OF VICTIMS OF DEPORTATION

(1) Certificate of the Police Department of Herceg Novi on deprivation of liberty and deportation of Enes Bičo to the "Foča collective centre" of 25 May 1992;

(2)  Certificate of the Police Department of Herceg Novi on deprivation of liberty and deportation of Ismet Isaković to the "Foča collective centre" of 25 May 1992;

(3)  Certificate of the Police Department of Herceg Novi on deprivation of liberty and deportation of Sadik Demirović to the "Foča collective centre" of 25 May 1992;

(4)  Response of the Minister of Interior Affairs of the Government of Montenegro to the appeal of Danijela Stupar -Titorić (the wife of Alenko Titorić) directed to the President of the Government of the State of Montenegro in 1992, number 905 /3, of 18 August 1992. According to the Minister, Alenko Titorić was deported from Montenegro to the Republic of Srpska "in order to get into the group of Muslims intended for exchange of the captured Serbian territorial fighters".

(5)  Response of the Department for petitions and proposals of the Parliament of Montenegro to Sanja Bošnjak (the wife of Muhamed Pilavdžić), number 04-1386-5, of 05 July 1993 , claims that Muhamed Pilavdžić "was delivered to and taken away from the Srebrenica area by the competent officers of the Police Department of Srebrenica, Mitrović Petar and Perendić Predrag" .

(6) Response of the General Secretariat of the President of the Republic of Montenegro - Department for petitions and appeals of 05 July 1993 to Čardaklija Suada (the wife of Alija Čardaklija), signed by the secretary Ljiljana Ivanović, claims that "the officers of the Ministry of Interior Affairs of the Republic of Montenegro on 25 May 1992 handed over 37 persons to Koroman Slavko in Foca prison (KP Dom). Among these 37 people were 21 Muslims and 16 Serbs. Čardaklija Alija was among those men.".

(7) Response of the General Secretariat of the President of the Republic of Montenegro, number 07-194/4 of 14 April 1993 delivered to Fahrudin Cengic (grandfather of the deported and missing Amer Prelo, father of the deported and missing Himzo Cengic and father-in-law of the deported and missing Smail Hasanbegovic), stating that: "On the request of the police station of the Police Department of Srebrenica (Amer, Himzo and Smail) were arrested . directed to and handed over to the officers of the Police Department of Srebrenica" .

(8) ''Information on measures undertaken by the Ministry of Interior Affairs regarding the displaced people from the Bosnia and Hercegovina area'', Minister of Interior Affairs' office number 05-129 of 24 November 1992 directed to the vice-president of the Montenegrin Parliament, Asim Dizdarevic PhD, presents the names of 69 deported ''persons of Muslim nationality'' and states that the decision on deportation of these men to the officers of the Republic of Srpska in May 1992 had been passed in accordance with 'the official Prosecutor's office of the Republic of Montenegro".

(9) "Response to the interpellation", Minister 's office, number 278/2 of 08 April 1993 which presents the names of 48 deported ''persons of muslim nationality'' with dates and places of the delivery to the officers of the Republic Srpska as well as it states that the act of deportation was undertaken by the competent officers of the Ministry of Interior Affairs of the Republic of Montenegro ''in accordance with the competent Prosecutor 's office ''

(10)  The copies of the texts from the daily newspaper Pobjeda of April and May 1992:

- ,,Our journalists in Bosnia and Hercegovina: Convoys of refugees'' , no. 9465 of 07 April 1992 ;

- ,,Planned evacuation of the citizens from the Montenegro and Bosnia and Hercegovina: The comeback today'', front page, of 12 April 1992 .

- ,,Pobjeda with picture and word at the scene of the event: Foča, started complicating a long time ago'', column ,,Current issues '", of 26 April 1992 and

- ,,What stops the life in Foča; Is there a cure for the wounds of war?", Pobjeda , no. 9496 of 10 May 1992 .

The above texts present the fact that at the time of the deportation of Bosnian refugees from Herceg Novi to the "collective center", i.e. the Foča prison (KP Dom), in Montenegro it was a common knowledge that in Bosnia and Herzegovina, and especially in Foča, the war was going on. It was also widely known that the military forces of Republika Srpska in April 1992, a whole month before the deportation of refugees took possession of the entire territory of Foča , including the Foca prison;

(11)   The copies of the texts from the daily newspaper Pobjeda .

- ,,Boka is safe" of 30 May 1992 , and

- ,,Mobility for peace" of 08 June 1992 , and

- transcription of the interview of Slobodan Pejović, the then officer of the Police Department of Herceg-Novi, Radio Free Europe , the Hague Chronicle, of 23 June 2004.

The presented texts contain the reports and statements of the employees at that time of the Police Department of Herceg Novi testifying on the harmful event, which confirm the claims of the victims' families.

(12)  The information from the meeeting of the commander of the Foca station of the United Nation 's mission in Bosnia and Hercegovina and the representative of the management of the Foca prison of 21 March 1997, claiming that the Foca prison was taken over by ''the Serbian army'' on 20 April 1992.

(13) The verdict of the Hague tribunal in the case ''The prosecutor against Milorad Krnojelac'' case number IT-97-25-T, Hearing council, of 15 March 2002, paras. 190 and 191.

"190. The Prosecutor has alleged in par 5.5 that FWS-71 was beaten, kicked and hit with rifle butts by soldiers when he arrived at the KP Dom in a group of 21 detainees on 25 May 1992 . 191. The Trial Chamber is satisfied that, on that date, FWS-71 was transported from the police station in Herceg-Novi to the KP Dom in a group of 21 detainees. On arrival, these men were met by a group of about ten individuals in uniforms. These soldiers started beating the Muslim detainees one by one as they were getting off the bus. The soldiers lined them up against the wall of the KP Dom and struck each one with a rifle butt.During the beatings, the soldiers used expletives and offensive language. FWS-71 was kicked and hit a number of times by several soldiers during this incident. His mistreatment resulted in a bruise on his right shoulder which was clearly visible for between five and ten days. He also had pain around the rib cage and in the shoulder area.Slavko Koroman, Zoran Mijovic and Milenko Elecic of the regular KP Dom prison guard staff were present at the entrance to the KP Dom building, right next to where the detainees were lined up, when the incident occurred.These guards did not react at all while the detainees were being beaten. "

(14) UNHCR intervened to stop deportation in 1992

NOTE: At the time of the deportation action of the Montenegrin police, Bosnia and Herzegovina was an internationally recognized state (even a member of the United Nations since 22 May 1992!), all deported people were civilians and all de facto refugees, and most of them even carried certificates that they have registered as refugees with the Organization of Red Cross of Montenegro.