“PRAVDA ZA DAVIDA”: Prijava Međunarodnom krivičnom sudu u Hagu
Piše: Borislav Radovanović
Objavljujem
sadržaj prijave Međunarodnom krivičnom sudu za “Zločin protiv čovječnosti” na
štetu zajednice “PRAVDA ZA DAVIDA”, gdje ističem potrebu hitne reakcije
Kancelarije tužioca ICC. Da bi što prije produkovali reakciju Kancelarije tužioca
ICC potrebno je sadržaj prijave ili ovaj link slati na adrese međunarodnih
institucija, organizacija za ljudska prava i medija. Ovo je slično prijavama
ubistva koje smo svojevremeno podnosili banjalučkom tužilaštvu – gdje su sad
Lepir i Vrećo, sa Lukačom, Ćulumom, Luburom, Ilićem i Švrakom, prijavljeni za “Zločin
protiv čovječnosti”. Ima međunarodni sud koji će utvrđivati jesmo li mi
počinili “državni udar” ili trpimo jedan od najtežih zločina po međunarodnom
pravu.
SADRŽAJ
PRIJAVE ZA PREUZIMANJE (copy-paste)
DAMAGED:
DavorDragičević
Franca
Šuberta 50A
78000
Banja Luka
President
of the Association of Citizens „JUSTICE FOR DAVID“
DAMAGED/APPLICANT:
BorislavRadovanović
AbdulahaKuruzovića
35
79206
Ljubija
r.borislav1970@gmail.com
Tel:
+38765994630
INTERNATIONAL CRIMINAL COURT, Hag (Den Hag)
-
Prosecutor's office
PROSECUTOR'S OFFICE OF BOSNIA AND HERZEGOVINA, Sarajevo
-
Chief Prosecutor
RELATION: Our Supplement to the Report of the
Criminal Offense "Heavy Murder" against David Dragičević since
30.05.1018.
APPLICATION OF CRIMINAL OFFENSE "CRIME AGAINST
HUMANITY"
In the capacity of a direct victim and as a
member of the "JUSTICE FOR DAVID" community, the unlawfully attacked
group of civilian population as a collective injured person, I declare that the
persons listed below, as well, from March 26 to the present day, in the
territory of Bosnia and Herzegovina and outside the country, the serious abuses
of the state-repressive apparatus and institutions of the Serb Republic
constitute an unlawful broad and systematic attack on the damaged community as
a target group of the civilian population.
Through active actions, the intentional,
conscientiously, targeted, planned and organized, registered persons have
materialized the characteristics of the criminal offense "Crime against
humanity" under Article 172 of the BiH Criminal Code (Official Herald BiH
No. 03/03), and in accordance with the interpretation of the Rome Statute of
the International Criminal Court and the Law on the Application of the Rome
Statute of the International Criminal Court and cooperation with the
International Criminal Court of BiH.
As for now identified direct perpetrators of
the crime, I report:
1.
Darko
Ćulum, Director of the Police of the Ministry of the Interior of the Serb
Republic,
2.
Dragan
Lukač, Minister of the Interior Ministry
of the Serb Republic,
3.
Nedeljko
Lubura, Chief of the Police office for the Prevention of Terrorism of the
Ministry of the
Interior of the Serb Republic,
4.
Darko
Ilić, head of the Police office for organized and serious forms of crime,
5.
Želimir
Lepir, Chief Prosecutor of the Banja Luka District Prosecutor's Office,
6.
Mahmut
Švraka, The Serb Republic Chief Prosecutor.
In the framework of a joint criminal
enterprise (intentional, contractual, targeted, planned and organized), they
committed acts of severe life and physical harm, severe unlawful and
disproportionate violence against civilians, persecutions in the field of
activities prohibited by international law, forced disappearance of persons,
torture, inhumane and the degrading deprivation of liberty and punishment, the
prevention of the freedom of opinion and expression of opinion, the freedom of
movement and assembly, the ill-founded abduction of individuals and the community
by public media satanisation, unlawful public incriminations of victims of
crime, violations of fundamental and labor rights, and other inhumane acts for
the purpose of applying physical and mental pains forbidden by national and
international law.
All unlawful actions are directed directly
against the target group of the civilian population gathered around the idea of
"JUSTICE FOR DAVID", just because the civilian population expressed
an opinion contrary to what the perpetrators tried to impose on unlawful
actions, and with the obvious intention of preventing the existence and action
of the community in guaranteed domain. For the realization of an unlawful
attack, reporters were even heavily abusing institutions (parliament,
government, institutions) and social goods (public media services, media in the
country and abroad, social networks, public areas, events). For example,
Minister DraganLukač repeatedly committed serious crimes at the expense of the
community during the formal sittings of the parliament and the work of the
parliamentary body, without any reaction from that highest political and
legislative body, about which we submitted concrete evidence to the
applications.
It should be noted in particular that the
bodies authorized to conduct and control the work of the police (the RS
President, the RS Government and the National Assembly of the Serb Republic) by
actively performing or by failing to perform due actions allowed the reported
perpetration of criminal offenses, where we even have indications of complicity
assistance and all the way to co-perpetration. However, at this moment and with
the available evidence fund, it is not possible to claim that the holders of
public functions hierarchically above the applicants did so intently and with the
awareness of an unlawful attack with the features of "Crime against
humanity".
I note that Ćulum, Lukač, Ilić and Lepir,
together with Prosecutor DaliborVreć, with our Supplement to the Application
from the May 30, 2018. have been reported for committing an extended criminal
offense "Abuse of official position or authority" in connection with
"Non-reporting of a criminal offense or perpetrator" (according to
the Criminal Code of RS) in relation to the main criminal offense "Tough
Murder" at the damage of David Dragičević. By this report, we have pointed
out the need to prevent the reporting of further criminal offenses, and the
absence of an adequate reaction by the competent prosecuting authorities
enabled them to continue to commit crimes as they have today's characteristics
of "Crime against humanity".
In the explanation of the application, I
state the current situation where complete humanity testifies against the
targeted group of civilian population by an unlawful, brutal and ruthless
attack on Serb Republic’s repressive apparatus, and the competent institutions
do not undertake due actions to prevent further prosecution of the crime and
protection of life and physically endangered individuals and the community
such. It is clear that unlawful attacks by the police and judicial bodies are
organized on international holidays when expectations of inadequate reaction of
the international community and state institutions of BiH are expected.
From 25.12.2018.to today, in relation to
dozens of people, we have a forced disappearance of persons (deprivations of
liberty and arrest warrants), imprisonment and other deprivation of physical
liberty, torture, inhuman and degrading deprivation of liberty and punishment
and other acts prohibited by international law. We have no knowledge of most of
the leading community activists “JUSTICE FOR DAVID ", and especially for
the leader of the community, DavorDragicevic, who is also the president of the
citizens' association of the same name. This is the main reason why I report
the criminal offense in this urgent manner and without submitting evidence
(which is impossible to get in this situation). In my opinion, the principle of
the prevention of further prosecution of the criminal offense and the serious
harmful consequences have priority over the acts of proof. That is why I will
only describe in detail the elements by which the events I report are treated
as a "Crime against Humanity".
Reported Ćulum, Lukač, Ilić and Lepir,
together with OT Banja Luka prosecutor DaliborVreć, from 26 March 2018., as a
group organized for the commission of a criminal offense started offenses of
prolonged criminal offense "Abuse of official position or authority"
in connection with the criminal offense of "Non-reporting of a criminal
offense or perpetrator" in relation to the criminal offense of "Heavy
Murder" against David Dragičević and other serious criminal offenses in
the area of prevention of prosecution and proving criminal works. In the
Republic Public Prosecutor's Office, the criminal case "ŽelimirLepir and
others" was formed on the occasion of the application for the
"Serious Murder" of David Dragičević, filed by the injured
DavorDragičević and myself. In this case, there are grounds for suspecting that
the perpetrators committed crimes, however, the prosecution did not take legal
action against the applicants in accordance with the rules of the profession.
On the other hand, reporters are continuously abusing their official positions
and the power they have against the community of citizens "THE JUSTICE FOR
DAVID", and as reported by it, in the two amendments to the application
and my testimony are stated.
Registered since 26.03.2018. in the same
year, they begin unlawful actions against anyone who did not accept the illegal
legal qualification by which they qualified the death of David Dragičević in
the form of "drowning, no elements of the criminal offense", and this
takes time with the characteristics of an unlawful attack directed specifically
at the target group of civilian population by the state- repressive apparatus
of Serb Republic and certain institutions of the same. What kind of
illegalities we reported were described in the basic application to the
District Prosecutor's Office Banja Luka on May 17, 2018, supplementing the
application with the RS Public Prosecutor's Office of 30 May 2018. (in the form
of information submitted to the Prosecutor's Office of BiH), in addition to the
application to the RS Public Prosecutor's Office of 20.08.2018, in the Proposal
for the establishment of a prosecutorial team to the Republican Prosecutor of
the Republic of RS from 22.05.2018, and in my statement given to the Special
Department of the RS Public Prosecutor's Office of 12.7.2018. All of these are
in the criminal record of the RS Public Prosecutor's Office under the number
T12 1 KTK 0000686 18 and the name "ŽelimirLepir and others", where
they can be excluded or obtained.
In the domain of the act of deprivation of
life, as incriminated acts of committing "Crimes against humanity" to
the detriment of members of the community and persons associated with it,
several unlawful attacks were processed and processed as murder in an attempt,
threatening security by threats of murder, bodily injury and other. Recognizing
that the competent police and prosecuting authorities did not undertake
adequate prosecution of the perpetrators, community members have stopped
reporting the daily threats they receive even through publicly available
broadcasters (electronic media, social networks). In the domain of publicly
accessible data, there is a huge fund of evidence that threatens the attack on
the life and body of individual members of the community and the community as
such, but there is a continuing lack of legal actions to protect the perpetrators
and prosecuting the perpetrator.
However, multiple dangerous, brutal and
utterly reckless attacks on police cordons on children, women and other
vulnerable categories of civilian population can also be submerged under severe
threats to life and body. It is particularly worth pointing out the
inconsistent violation of the principle of proportionality in the use of force,
whereby the force that has been declared is legally ungrounded and even
unlawful. In order to deal with the possibility that some 50 members of the
community, especially women, 25.12.2018. over 200 police officers (mainly from
the Support Unit that acted as formations) attacked or even threatened to
descend to the level of legal nonsense. It also applies to allegations that
DavorDragicevic "jeopardized the security" of Minister Lukac and the
Mayor Ilic. Over nine months, Dragičević, just like most of the community
activists, is under unlawful intensified police supervision and, in particular,
the PU for the prevention of the terrorism of the Minister's son-in-law,
NedeljkoLubura, who for sure would have discovered for all that time any
realistic endangerment attempt.
There is a wide range of incriminated actions
in the domain of unlawful persecution. In the first place, I point out unlawful
criminal and misdemeanor persecutions of a large number of members of the
community and persons related to the same as torture, inhumane and degrading
treatment and punishment prohibited by Article 3 of the European Convention on
Human Rights. Personally on 03/09/2018 I was exposed to such deprivation of
liberty and punishment, and I am also familiar with a greater number of members
of the community who are exposed to similar prohibited acts. This will be
explained in more detail in my statement, and the same will be done by other
members of the community who also have evidence of unlawful deprivation of
liberty, torture, inhuman and degrading treatment and punishment.
At the same time, I would point out that
numerous members of the community will testify and even hand over video
recordings of unlawful police attacks of a formative type (Support Unit), which
were seriously life-threatening and physically endangered, their freedom of
movement and retention, and so on. All this has been done in the last days
regarding the alleged ban on the gathering of the "JUSTICE FOR DAVID"
community, but in a formal sense such a ban has never been passed, and the
lending is legally communicated to those to whom it relates to others. In the
domain of proof of the applicants, they should be asked to prove the existence
of a legal ban on the gathering of citizens, but at the beginning I claim that
there are no such prohibitions. From this position, any use of force against
citizens and the use of authority is unlawful, and even all acts made by the
judicial authorities in relation to police reports or requests.
Furthermore, I point out that there are
reasons to suspect that in several cases the disappearance of persons is
forbidden in the sense that persons deprived of their liberty do not have
guaranteed rights (informing the relatives, contacting a lawyer, hiding
information that a person has been deprived of their liberty, etc.). The
applicants know that certain members of the community did not commit any crime
and for them they illegally and abusively issued warrants, so that at this
moment with numerous members of the community it is not possible to find out
where and what is happening to them. After previous experiences in the area of
illegal deprivation of liberty and prosecution, many of them subsequently avoided
calls or arrests, were hiding or still hiding, and what resulted in the arrest
warrants. Anyone who has previously been exposed to unlawful deprivation of
liberty, torture and inhuman treatment or punishment is expected to fear
repetition of similar incriminations and avoid contact with the police. And
this is one of the key reasons for filing such an application and seeking a way
to provide people with legal protection.
In the end, I will just mention various forms
of grave violations of the rights and freedoms of citizens, disenfranchisement,
public satanisation, undisclosed public accusations and similar actions in the
domain of unlawful attack on the target group of the civilian population. The
publicly available data on what all this community is basically indicted is a
literally huge fund and it is truly worrying that the competent institutions
did not recognize this as an unlawful broad and systematic attack on the target
group of the civilian population. Is there only one proof of the strong public
statements made about the "colored revolutions", the
"demolition" of the Serb Republic, the threat of Russian Minister
Lavrov, the payment or the issuance? Such incrimination of victims of crime
according to the parameters of the profession of the mountain is from what the
Nazis did to the Jews and other unthinkable (I am ready to prove it from the
position of the profession). It is known to the public and how the rights of
single mothers and other employees in the institutions are targeted, with the aim
of intimidating the community and the public in general with the expression of
utterly inhumanity. The same applies to the public satanisation of anyone who
expressed opinion differently from those reported to the elected
representatives of citizens and holders of parliamentary mandates. They were
reportedly abused for carrying out criminal intentions, even abruptly abused by
public sittings (publicly transmitted), public services and other public goods.
There is unquestionable evidence of all this, and we have many of them in the
form of a National Assembly stenographer.
Finally, I point out that the largest fund of
evidence of the reported crime is in the criminal and misdemeanor files of
proceedings initiated or conducted against members of the community and in
police records. Since I am submitting this application in this way and even
planning to announce (the public application) the expected certain
incriminations, I have not explained in detail and pointed to the evidence of
the same, but I will do so through my statement, as well as by handing over the
prosecution of earlier statements and evidence I own.
Again, I emphasize that this application is
primarily in the function of animating the competent prosecutor's office in
order to prevent further prosecution of the criminal offense and serious
consequences, and what is the priority with regard to the actions of proof. I
file this application under full criminal responsibility and with the awareness
of the criminal offense I'm reporting, iethat this crime is objectively and
that the registered persons are the perpetrators. A special problem in the
given situation is the status of DavorDragičević, who is also the president of
the association and the informal leader of the community "JUSTICE FOR DAVID",
and is currently disabled in the process of action. DavorDragicevic is a key
witness in the case of his son's murder, and he also has numerous evidence
important for criminal proceedings. We can reasonably suspect that the current
attacks on him are primarily aimed at finding and destroying evidence against
them, and preventing DavorDragicevic from giving evidence in the applications
that we filed. At the same time, he has the most knowledge of unlawful attacks
on members of the community and the community in general since he provided
legal protection to the majority.
ANNEX:
- Supplement to the
report of the crime of "Serious Murder" at the expense of David
Dragičević
In Ljubija, 02.01.2019.godine
APPLICANT:
BorislavRadovanović
r.borislav1970@gmail.com
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