The evidence revealed the secret of the SDB's criminal operation in Croatia and Bosnia, said prosecutor Dermot Groom, adding that the crimes against the non-Serb population were committed as part of a joint criminal enterprise.
Under the indictment, Stanisic and Simatovic, as key members of said enterprise, killed, deported, forcibly relocated and expelled thousands of non-Serbs from large parts of Croatia and Bosnia over nearly five years. The prosecution requested they be sentenced to life imprisonment.
Stanisic and Simatovic significantly contributed to the realisation of that criminal plan, prosecutors said, adding that they were responsible for the financing, training, logistical support and other forms of aid to SDB special units and other Serb forces that took part in the crimes in Bosnia and Croatia.
The crimes were committed by SDB units as well as units and paramilitary formations created by the SDB or those in whose creation the SDB was involved, the indictment said.
One of the first crimes committed by those units was the attack on Lovinac in 1991 in which Simatovic took part, Groom said, adding that it was followed by murder, destruction and attacks on other targets in Croatia, from Kijevo to Skabrnja. Groom said it was proved that Stanisic had personally sent Arkan's men to eastern Slavonia, Croatia, where they were among the bloodthirstiest perpetrators of crimes.
After Croatia, the units under the SDB's control crossed into Bosnia, where they used the skilled they had acquired with even greater efficiency, Groom said. The prosecutors said those units operated unpunished.
The five-count indictment accuses Stanisic and Simatovic of crimes against humanity and violations of the laws and customs of war committed in Croatia and Bosnia through persecution, murder, deportation and other inhumane acts.
The prosecution charges the two men with involvement in a joint criminal enterprise aimed at removing the majority of non-Serbs from large parts of Croatia and Bosnia from 1991 to 1995. The other participants in said enterprise were former Yugoslav President Slobodan Milosevic and Bosnian and Croatian Serb leaders Ratko Mladic, Radovan Karadzic, Biljana Plavsic, Milan Martic, Goran Hadzic and Milan Babic, Serbian Radicals leader Vojislav Seselj, and paramilitary commander Zeljko Raznatovic Arkan.