The prosecution's submission of the public version for a pre-trial brief gives a review of evidence the UN war crimes tribunal's Prosecutor's Office collected to show why it holds the three generals accountable for crimes against local Serbs during Operation Storm in August 1995.
The prosecution holds that the crimes were aimed at ethnically cleansing the area within the joint criminal enterprise.
The ICTY prosecution believes that apart from the three accused generals, the main protagonists of the joint criminal enterprise were the then Croatian President Franjo Tudjman, the then Defence Minister Gojko Susak and generals Janko Bobetko and Zvonimir Cervenko. All four have died in the meantime.
Basing its statements on presidential transcripts from a Brijuni meeting on 31 July 1995, the prosecution writes that "believing that the international political circumstances were propitious for the capture of the Krajina, President Tudjman, along with various military and political leaders, finalised military plans for operation Storm on 31 July 1995."
The prosecution quoted Tudjman as saying that one objective of the planned attacks was to achieve the flight of Serb civilians.
The prosecution also quoted Gotovina as saying at the Brijuni meeting that "a large number of civilians are already evacuating Knin and heading towards Banja Luka and Belgrade. That means that if we continue this pressure, probably for some time to come, there won't be so many civilians, just those who have to stay, who have no possibility of leaving".
The prosecution also writes that Tudjman showed "a long-standing interest" in the ethnic homogeneity of Croatia.
It says that since its very start, Operation Storm was marked by indiscriminate attacks against civilians with an aim of forcing them to flee.
The prosecution quotes data collected by several sources, including the United Nations, about figures regarding the casualties of the operation. The figures vary between several hundred and 1,600 people killed, and the UN reported that 60 to 80 percent of the Serb property in the then UN Sector South was fully or partially destroyed during the operation.
Apart from the presidential transcripts, other documents that the prosecution will use to prove General Gotovina's accountability are testimonies of UN and European Communities representatives in Croatia as well as military documentation, including orders issued by the indicted general and military logs.
When it comes to General Ivan Cermak, the prosecution will rely also on correspondence between the three accused generals and documentation on Cermak's meetings with Gotovina and Markac.
General Cermak is not mentioned in the context of the so-called presidential transcripts.
However, the prosecution accuses the three indictees of having co-ordinated the ethnic cleansing on the ground.
The prosecution believes that in his capacity as the commander of the Knin garrison, Cermak had an effective control over Croatian Army units deployed in the area.
General Mladen Markac is the only one to have been indicted from the police structures for this crime.
To prove charges against Markac, the prosecution relies on special police documentation and on his coordination of military activities with Generals Gotovina and Cermak.
In the case of General Markac, the prosecution has not announced evidence collected from international sources such as the UN or the European Community.
The defence teams for the three generals are expected to present their counter-statements by 5 April.
The next status conference in the Gotovina, Cermak, Markac case is scheduled for 3 April.