1. Between 1 July 1991 and 30 November 1995, Radovan KARADZIC, acting individually or in concert with others, including acting in concert with Momcilo KRAJISNIK and Biljana PLAVSIC between 1 July 1991 and 31 December 1992; participated in the below-charged crimes in order to secure control of those areas of Bosnia and Herzegovina which had been proclaimed part of the Serbian republic. Those areas include but are not limited to the municipalities of: Banja Luka; Bijeljina; Bileca; Bosanska Krupa; Bosanski Novi; Bosanski Petrovac; Bosanski Samac; Bratunac; Brcko; Cajnice; Celinac; Doboj; Donji Vakuf; Foca; Gacko; Hadzici; Ilidza; Ilijas; Jajce; Kljuc; Kalinovik; Kotor Varos; Nevesinje; Novi Grad; Novo Sarajevo; Pale; Prijedor; Prnjavor; Rogatica; Rudo; Sanski Most; Sekovici; Sipovo; Sokolac; Teslic; Trnovo; Visegrad; Vlasenica; Vogosca; Zavidovici; and Zvornik.
2. In order to achieve this objective, the Bosnian Serb leadership, including Radovan KARADZIC, and at relevant times Momcilo KRAJISNIK, Biljana PLAVSIC and others, initiated and implemented a course of conduct which included the creation of impossible conditions of life, involving persecution and terror tactics, that would have the effect of encouraging non-Serbs to leave those areas; the deportation of those who were reluctant to leave; and the liquidation of others.
3. Bosnian Serb forces including military, paramilitary, territorial defence and police units (hereafter Bosnian Serb forces), SDS and government authorities acting under the direction and control of Radovan KARADZIC, and at relevant times Momcilo KRAJISNIK, Biljana PLAVSIC and others, were engaged in a variety of actions to significantly reduce the Bosnian Muslim, Bosnian Croat and other non-Serb populations of these municipalities.
4. From late March to 31 December 1992, Bosnian Serb forces seized physical control of the municipalities listed in Paragraph 9, often through violent attacks. These attacks and take-overs occurred in a co-ordinated and planned manner. Organisation and direction of the take-overs that occurred between late March and 31 December 1992 and the continuing acts of persecution and deportation that occurred up to 30 November 1995, in particular from the municipalities of Bijeljina, Banja Luka and the UN designated "safe area" of Srebrenica (hereafter Srebrenica enclave) and its surroundings, were provided by the SDS, military and police leadership, and the governing organs of Serb municipalities, including the Crisis Staffs, War Presidencies and War Commissions.
5. Between 1 April 1992 and 30 November 1995, Bosnian Serb forces were also engaged in a forty-four month attack of Sarajevo, which involved inflicting terror on persons living within Sarajevo.
6. Between 11 and 18 July 1995, Bosnian Serb forces killed thousands of Bosnian Muslim men, who had been captured in several different locations in and around the Srebrenica enclave.
7. By 30 November 1995, this course of conduct resulted in the death or forced departure of a significant portion of the Bosnian Muslim, Bosnian Croat and other non-Serb groups from the municipalities listed in Paragraph 9 and in and around the Srebrenica enclave.