Prosecution's second amended indictment - ICTY

2879048. Such persecutory acts were committed as part of the objective topermanently remove Bosnian Muslims and/or Bosnian Croats in theMunicipalities, as well as part of the objective to eliminate the BosnianMuslims in Srebrenica. Ratko MLADIC acted in concert with various otherindividuals, depending on the time period and location, to achieve theseobjectives through the commission of the crime of persecutions.49. As alleged in paragraphs 8 to 13, between 12 May 1992 and 30November 1995 Ratko MLADIC participated in a joint criminal enterpriseto permanently remove Bosnian Muslims and Bosnian Croats from theterritories of BiH claimed as Bosnian Serb territory through the commissionof crimes, including persecution. Members of this joint criminal enterpriseshared the intent to commit the persecutory acts enumerated in paragraph 59in the Municipalities on political and/or religious grounds. Alternatively, asalleged in paragraph 9, it was foreseeable that such persecutory acts might beperpetrated by one or more members of this joint criminal enterprise and/orby persons used by any such member(s) to carry out the crimes of deportationand forcible transfer. Ratko MLADIC was aware that persecution was apossible consequence of the implementation of the objective to permanentlyremove Bosnian Muslims and Bosnian Croats from Bosnian Serb-claimedterritories and willingly took that risk.50. The persecutory acts carried out in the Municipalities and againstBosnian Muslims in Srebrenica are illustrative of the wider persecutorycampaign implemented in large areas of BiH pursuant to the objective topermanently remove Bosnian Muslims and Bosnian Croats from theterritories of BiH claimed as Bosnian Serb territory.Case No. IT- 09-92-1 22 1 June 2011