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Picture

I ACCUSE

TURKEY, THE UNITED STATES AND THEIR GLOBAL GANG

CASE REFERRED TO THE INTERNATIONAL CRIMINAL COURT

--ENTIRE CRIMINAL COMPLAINT FOLLOWS--

International Criminal Court
Office of the Prosecutor
Communications
Post Office Box 19519
2500 CM The Hague
The Netherlands.


A Criminal Complaint Communication to the Office of the Prosecutor

 Respectfully submitted by James C. Ryan, Ph.D.
Istanbul, Turkey
6 October 2014

Picture
Only the dead have seen the end of war.
—George Santayana

For as long as Winston can recall, Oceania has been in a constant state of war –
with whom it was at war is of neither importance nor consequence.
—George Orwell, 1984

________________________________________________________________

Criminal Carnage in Syria by the Criminal Cabal for Perpetual War
________________________________________________________________

INDEX

1. SUMMARY  


2. INTRODUCTION
  A. Misbegotten in a Crime               
  B. The Benghazi Rat Line                  
  C. Arms and the Men and Some Countries                   
  D. Intelligence Sharing                      
  E. The Premise for Legal Action                  
  F. The Criminal Cabal                   
  G. The Accused                  

3. LEGAL SUBMISSIONS
  A. Introduction              
     1. Summary of Submissions
     2. Summary of Steps Sought from Office of the Prosecutor

  B. Jurisdiction      
     1. On Grounds of Territoriality
     2. On Grounds of Nationality

  C. Admissibility              
     1. On Grounds of Gravity,
     2. On Grounds of Complementarity
     3. On Grounds of Interests of Justice

  D. Crimes within the Jurisdiction of the Court             
  E. Summary of Charges               
  G. Conclusion                  
  H. The Complainant

APPENDICES
  1. Preamble: Rome Statute of the International Criminal Court
  2. Media Evidentiary Extracts (chronological)
  3. Summary of Exhibits


1. SUMMARY
Since January 2011 the Syrian Arab Republic, a sovereign state with 18 million people, has been under attack. Hundreds of thousands have died; three million have fled the country; half the nation’s population has been displaced. The West, in particular the United States, seeks, as seems usual, “regime change” and has enlisted the financial support of Saudi Arabia and Qatar to get it. Turkey is the key implementer providing a staging area primarily in the southern province of Hatay on the Syrian border. It also serves as a logistics base affording housing, hospital support, training and a supply line across the border into Syria. As the world and the United Nations now know, this border is porous, dangerous and corrupt. A stream of trailer-trucks, shielded from inspection by Turkish intelligence agents, regularly passes through the gates and disappears into this most savage war. This is the rolling oil pipeline that finances the bestial offspring of the largely fictional “moderately Islamic” Free Syria Army now variously known as ISID, ISIS, ISIL and/or IS. Whatever it’s called, it’s the awful result of massive, aggressive collusion of the United States, Turkey, Saudi Arabia and Qatar, enthusiastically supported by Jordan, a State Party signatory to the Rome Statute and hence bound by the provisions of the Statute. These five constitute the Criminal Cabal.[1]     

Arab Spring, a knock-off label from Czechoslovakia’s Prague Spring of 1968, has drowned North Africa and the Middle East in a sea of blood. Libya has failed into complete violence. The Syrian people are on the run—millions have fled the country. The dubious “civil war” is a full-blown catastrophe, with radical groups now attacking each other, and the most radical of all, the Islamic State of Syria (ISIS), murdering, pillaging and beheading its way towards Baghdad. Once thinking it could tell moderates from maniacs, once thinking it could trust the prime minister of Turkey, America now flounders about how to nuance its the fight with its own creation—ISIS—without helping the real objective, namely, waging a proxy (and criminal) war of aggression using mercenaries against Syria and the duly constituted government of President Bashar al-Assad.

This is the stupidest of quandaries, one caused by a criminal disregard for international law, incredibly poor judgment and incredibly radical accomplices, in particular the government of Turkey, specifically its former prime minister now president Recep Tayyip Erdoğan. The other accomplices—Saudi Arabia, Qatar and Jordan— are equally morally abject and treacherous. It is a sordid off-key cabal, this criminal quintet, this Criminal Cabal, violating international law with impunity. These arrogant five seem to draw their criminal strength from the fact that, except for Jordan, none are signatories to the Rome Statute and hence supposedly not subject to its provisions for humane behavior among law-abiding nations. These four believe their misdeeds are outside the jurisdiction of the International Criminal Court (ICC) and even the United Nations. These felonious four do what they please, say what they like, incite war with their well-financed fanatical, mercenary hordes and inflict horrendous criminal atrocities on men, women and children, to wit, humanity. And Jordan, a signatory to the Rome Statute, betrays its promise and illegally collaborates with the Criminal Cabal.

Illegal weapons support and training from a host of nations, many of them signatories to the Rome Statute[2], has spawned a monstrous, Islamic militant swarm, grown horrendously violent on its diet of western arms and money. This fact is undeniable as will be shown and as you may already well know. The danger is clear and present. So much so that the monster’s benefactors now must try to destroy the monster they created. And by the usual way—high altitude bombing—guaranteed to harden the monster’s resolve and metastasize its violent effect. All of which means that more innocent people will die. Such is what passes for strategic thinking by the United States and its collaborators. Sadly, it is an old story. Such is the horribly complicated nature of the Cabal’s crimes—a blowback beyond imagination. Such is the reason for rendering this Complaint to the International Criminal Court (ICC). The allegations are heinous: war crimes, crimes against humanity and the ultimate international crime, aggression, indeed an evil thing.

The United States is not a signatory to the Rome Statute, nor is Turkey, Saudi Arabia or Qatar. Jordan is, but its criminal behavior belies its signature. The Criminal Cabal ordered the commission of ICC statutory crimes on, in, and over the respective territories of several ICC member nations, Jordan, Belgium, Bulgaria, Croatia and Romania, for immediate example. Therefore, the ICC has jurisdiction over the Accused for their statutory crimes in accordance with Rome Statute Article 12(2)(a).

Importantly, pursuant to Article 27, those accused who operate in an official capacity as head of state, member of government or government official are neither exempt from criminal responsibility nor enjoy any immunity whatsoever that constrains the Court’s jurisdiction. Additionally, there is no statute of limitation regarding the prosecution of these crimes, to wit: violations of Article 7, Crimes against humanity and Article 8, Crime of aggression.

The Accused
Listed below are the Accused nations. Principal accused are those primary malefactor nations most responsible for the crimes committed. Names and specific charges will be proffered later.

Principal Accused:
United States of America
Turkey
Saudi Arabia
Qatar
Jordan*

Accessory Accused:
Belgium*
Bulgaria*
Croatia*
France*
Great Britain*
Romania*

* denotes a State Party signatory to the Rome Statute.

And now onward to the details wherein the devils always reside.


FOOTNOTES        
[1] A State (nation) which becomes a Party to the Rome Statute accepts the jurisdiction of the International Criminal Court regarding the most serious crimes afflicting the international community: genocide, crimes against humanity, war crimes and the crime of aggression (Rome Statute, Article 5). Obviously those State Parties who aid and abet the commission of these crimes by nations outside ICC jurisdiction will not be held harmless nor will the non-State Party (Rome Statute, Article 12). 


2. INTRODUCTION

A. Misbegotten in a Crime
The carnage commenced on 20 March 2003 with a night cruise-missile attack on Baghdad primarily by the United States. Dubbed shock-and-awe, based on deceit, that crime of aggression rages still in unparalleled barbarity, in unparalleled illegality, in all its essential evil. Neither in self-defense nor in accord with the United Nations Charter, American, British, Australian, Polish and Danish military forces committed “the supreme international crime…essentially an evil thing.” Such was the judgment of the International Military Tribunal at Nuremberg regarding wars of aggression. According to the Tribunal, such wars were essentially an evil thing...to initiate a war of aggression...is not only an international crime; it is the supreme international crime, differing only from other war crimes in that it contains within itself the accumulated evil of the whole.[1]

Today, there seems no stopping this evil. Millions dead, wounded and displaced. Syria, and again Iraq, both under attack from a reincarnated, vicious Mujahedeen, variously called ISIL, ISID, ISID, and IS. This mercenary mob has been created and funded by America and its equally ambitious, criminal partners. Why? Lacking the will of its citizens to continue the perpetual war madness on their account (“No boots on the ground!”) a discouraged and confused America and a servile NATO has resorted to the use of proxy armies—mercenary guns for hire—to do its dirty work of aggression. Such violence and callous disregard for international law have erased national borders, setting in flight millions of refugees. All secular Middle Eastern nations have been destroyed. To what end? Is it oil? Religion? Unashamed political ambition? Is it democracy? Security? The security of the grave? It is too late for labels! Time is of the essence. It is time to stop. The rule of law must finally and at long last be enforced. Without this, the consequences are dire—perpetual war.

The invasion of Iraq in 2003 was illegal. The undeclared war and current bombing campaign in Syria is illegal. Both countries are now overrun by renegade bands of Islamic militants seeking to establish their own Islamic state within the territory of existing nations, a clear crime of aggression. However outrageously bestial these mercenary gangs behave cannot sever the responsibility from their foundational roots that reside in the Criminal Cabal for Perpetual War, that is, American and its primary collaborators—Turkey, Saudi Arabia and Qatar and Jordan. Nor can this evil be divorced from the numerous enablers and suppliers that support America’s illegal scheme.

Guns and knives do not work by themselves. The deliverers of deadly weapons into the hands of terrorist mercenaries bear the full burden for how they are used. For European Union weapons mongers like Belgium, the European Common Position on Arms Sales sets precise criteria regarding the sales of such weapons.[2] These criteria seem to have been disregarded. Furthermore, many of these collaborating countries are State Party Signatories to the Rome Statute of the International Criminal Court, thus culpable, thus liable for prosecution.

Robert Jackson, the chief prosecutor at the Nuremberg Tribunal, called war of aggression "the greatest menace of our times." What more can be added? We have eyes. Innocent people are suffering so grievously and we have learned so little.  

B. The Benghazi Rat Line
A “rat line” is an escape route. There were Nazi and fascist rat lines from various sites in Europe to South America at the close of World War II. In CIA parlance it’s a back channel, in this particular case, from Benghazi, Libya into Syria. Strange indeed to set this up. Strange because UN Security Council Resolution 1970 (26 Feb. 2011) was designed to have an immediate ceasefire and provided for an arms embargo regarding Libya.[3] It did not seem strange at the time because no one knew about the rat line. Even stranger, by hindsight, was the subsequent resolution 1973 that provided for a no-fly zone. Enacted on 17 March 2011, it removed the arms embargo provisions from the earlier resolution.[4] Therein resided the secret loophole that gave pseudo-legitimacy for the Benghazi Rat Line. One could now bring in arms for humanitarian purposes, that is, to protect the Libyan civilians who were already being bombed by NATO. And when that murderous fiasco was over and Muammar Gaddaffi was disemboweled and anal raped, the arms were needed elsewhere as the Arab Spring sprung to Syria. And so began the illicit arms transfer system, initially managed by CIA head, David Petraeus, and later, and disastrously, by the prime minister of Turkey who directed the weapons flow to radical groups in Syria.[5]

In this manner, the arms embargo in Libya was violated and the weapons stocks already huge, grew and grew.[6] Early in 2012 the Rat Line began to ship massive amounts of weapons, much of it from Muammar Gaddafi’s arsenals. Its destination? Southern Turkey, to the province of Hatay on the northern Syrian border. It’s ultimate destination? Radical elements of the opposition to the Syrian government of Bashar al-Assad. Recep Tayyip Erdoğan, the Turkish prime minister, suddenly shifted from bosom buddy to vitriolic, bombastic hater of Syria’s Bashar al-Assad. (He had earlier pulled the same two-faced trick on Muammar Gaddafi.)[7] Erdoğan made little effort to hide his agenda. And his agenda was to fund radical Sunni groups, in particular, al-Nusra, a well-known affiliate of al-Qaeda. The United States and Great Britain intelligence services obtained the weapons through front companies and organized the transfer operation. Great Britain’s intelligence service, MI6, was a cover to enable the CIA to call the “intelligence” relationship a “liaison” which somehow avoided the requirement to report an illicit operation like this to the US Congress. Loopholes, always bloody loopholes.

Funding for the Rat Line came from Turkey, Saudi Arabia and Qatar. Airports in Turkey including the US airbase at Incirlik were used extensively. Heavy-freight handling trucks with TIR designations were used on the ground.[8] After the September 2012 attack on the US consulate, the CIA pulled out. The Rat Line had lengthened its reach beyond Benghazi and all roads and air routes now led to Turkey, in particular Hatay and its gates opening to the bloody inferno called Syria. Their lintels should have read, as Dante wrote over the entrance to hell, “Abandon all hope, you who enter here.”

And post-CIA, who now ran the show? Turkey and Recep Tayyip Erdoğan.[9]  The US knew in early 2013 that the Turkish government, its intelligence service (M.I.T.) and the Gendarmes were enabling weapons and other lethal equipment to get into the hands of al-Nusra.[10] So did most Turks who chose to notice. The airports were full of jihadists, in particular on flights from Istanbul to Hatay Airport.  

What lay ahead was the sarin gas attack fiascos, the Turkish false-flag provocations, the gold-for-oil evasions of UN sanctions, and today, the support of the Turkish government for the ISID terrorist group, the child born of Libyan terrorist seed, cultured by Turkey and now pillaging Iraq and Syria with apocalyptic, satanic violence. This is Turkey today. America’s (and the Criminal Cabal’s) willing stooge, a duplicitous government that endangers its own people and indeed humanity.[11]  
 
 C. Arms and the Men and Some Countries
Arms were and are smuggled into Syria through a vast, not-so-secret network of sea and land routes primarily using Turkey as a huge logistical depot and diligent freight-forwarding agent. And business was very good. Former Soviet block nations like Bulgaria and Rumania had huge stockpiles of soviet-era military weapons. The Belgian-manufactured FN FAL assault rifle is in great demand due to its superior range and accuracy vis-à-vis the AK-47. Large numbers of Belgian weapons have been purchased by Qatar for re-export purposes.  All of these nations involved in the illicit arms transfer scheme--Jordan, Belgium, Bulgaria, Croatia, France, Great Britain and Rumania—are state party signatories to the Rome Statute hence fall within the jurisdiction of the International Criminal Court.

Belgium is the largest manufacturer of military small arms in Europe through its government-owned firm, FN-Herstal, which also owns two US-based weapons manufacturers—Winchester and Browning. Herstal’s two largest customers are the United States and Saudi Arabia. It also does significant business with Qatar. Indeed FN-Herstal seems to be the world’s weapon-maker of choice. Customers of FN-Herstal like France, Egypt, Qatar and the United Arab Emirates were eager suppliers to the Libyan opposition. Qatar was so eager that it was in breach of UN Resolution 1970 that imposed an arms embargo on 26 February 2011. Furthermore, Qatar and other “customers” may have violated agreements not to re-export these weapons. Much of the Libyan weaponry is now in Syria thanks to the Benghazi Rat Line.[12] 

Those European Union members who have exported military weaponry and technology to Libya and Syria seem to be in broad and reprehensible violation of the spirit and letter of the 2008 European Common Position on Arms Exports. Clearly, even a cursory reading of its criteria would dictate a total prohibition of arms exports.[13] Article 2(2)(a) and (2)(d) clearly state the need to examine the human rights conditions in the country and, most importantly, “the need not to affect adversely regional stability in any significant way.” Obviously there was little attention paid to these and any other criteria in this important instrument designed to control arms exportation. Yesterday’s Benghazi Rat Line bred today’s slaughter house in Syria.

The men and, sadly, the women and even the children, some as young as seven years old,[14] that mostly flow through Turkey come from more than 80 countries. There were 7,000 in Syria in January 2014, now it’s at least double that. No one knows for sure, least of all Turkey’s border guards. Not when there is an al-Nusra promoting prime minister who has yet to call ISID a terror group. Not where the terrorist oil is smuggled into Turkey, a NATO member, for quick, cheap sale, thus financing terrorist violence and filling more than a few Turkish pockets.[15] Not when hospitals in southern Turkey regularly treat wounded terrorists. Turkey is indeed a staging area, a fully operating logistical base and supply line for the terrorist assault on Syria. So it is no surprise that Richard Barrett notes in his exacting analysis entitled Foreign Fighters in Syria,

that most extremist groups are concentrated in the North of the country, and so are the first that many foreigners meet when they cross the Turkish border.[16]

Approximately one-half of the countries providing citizens to fight as illegal mercenaries in Syria are State Parties to the Rome Statute.[17] Reports abound of individual monthly salaries paid by Saudi Arabia and Qatar of $500-2000.  

So what about the responsibility to control this flood of people and armaments into Turkey by air and sea? Aren’t visas required? Surely non-Syrians, primarily westerners, exiting southern Turkey to enter Syria have but one purpose: violence. Porosity is the word; the Turkish border checkpoints have the solidity and diligence of a summer breeze.[18] Trucks enter uninspected, indeed often protected from scrutiny by Turkish authorities.[19]

And what about the responsibility of the countries allowing their primarily youthful[20] citizens to travel unhindered and unchecked to the most dangerous place in the world. Are these nations, particularly those that are signatories to the Rome Statute, not violating the war crime provisions of that statute? Are not these signatory nations, either willfully or negligently, aiding and abetting the commission of grave crimes against humanity by their failure to adequately supervise the passage of their citizens into war-ravaged Syria? And by enabling their citizens to join with mercenary forces to commit heinous crimes, aren’t these countries in breach of the Rome Statute?

There are two bold violators, signatories of the Rome Statute, worth citing, to wit, the Hashemite Kingdom of Jordan and the Republic of Croatia. In clear violation of Article 8(b), Jordan has been a CIA training center for terrorist mercenaries dedicated to overthrowing the Syrian government. Furthermore, Jordanian, Saudi and Qatari cargo transport airplanes have been widely used to transport arms to Esenboğa Airport near Ankara as well as to other Turkish and Jordanian airports. Moreover, CIA operatives have been regularly assisting Saudi Arabia to procure weapons from Croatia. These caches have been flown to Jordan on Jordanian transport planes for transfer to southern Turkey for fast forwarding to terrorist mercenaries.[21]

What can be made of nations like this? They sign to abide by the provisions of the Rome Statute, an admirable, moral act taken with many other nations to stand against the “grave crimes that threaten the peace, security and well-being of the world.” As signatories to the Rome Statute, Belgium, Bulgaria, Croatia, France, Great Britain, Rumania and Jordan all resolved to agree “to guarantee lasting respect for and the enforcement of international justice.”[22] So what happened? When the time came to take a stand for justice and peace they collaborated with the Criminal Cabal and became dogs of war. How can this treacherous betrayal of principles stand unpunished? It cannot. If it does, the International Criminal Court, the last bastion of hope against the barbarity of preemptive, illegal war, will collapse, betrayed by its constituent nations.   

D. Intelligence Sharing
There have been numerous reports of Signatory Party nations to the Rome Statute providing intelligence and training to mercenary forces seeking the overthrow of the legitimate Syrian regime of Bashar al-Assad. The United States, a non-signatory, has used its CIA to recruit the cooperation of British, French and Jordanian intelligence to train so-called Syrian rebel forces in the use of weapons. It is also widely reported that French, British and Jordanian intelligence services are training mercenaries to assist in the destruction of the Syrian government. This training is being conducted in Syria and is an American-led operation.[23]

Turkey also established a secret base near the Syrian border to help direct vital military and communications support to the mercenary opponents of the Syrian government. In August 2012, reports abounded of an operations “nerve center” established in Adana, Turkey, the location of the Incirlik US air base.[24]

E. The Premise for Legal Action
There is a significant body of evidence from official sources, non-governmental organizations and investigative journalists that provides a reasonable case for the Prosecutor of the International Criminal Court to investigate whether the United States and/or any of its collaborators and accessories are guilty of crimes within the Court’s jurisdiction. Indeed, the crimes in question fall within the jurisdiction of the court and relate to the following violations of the Rome Statute:

Article 7. Crimes against Humanity
Article 8. War Crimes and the Crime of Aggression

The use of proxy mercenary armies may to a degree mask the identities of their sponsors. But surely it does not hide them, nor their aggression from the reaches of international law. Aggression is a manifest violation of the Charter of the United Nations, indeed, an evil thing. Article 8(1) and Article 8(2)(g) are crystalline on that point. The Crime of Aggression as articulated in the Rome Statute originated in the Nuremberg Principles and the United Nations Charter. The aspects of aggression as defined were originally called “crimes against peace,” as they remain labeled today in the U.S. Army’s Field Manual 27-10, Law of Land Warfare.[25] Peace lovers always seek peace. But first seek justice!

As discussed earlier, four of the Principal Accused—the United States, Turkey, Saudi Arabia and Qatar—are not contracting parties to the Rome Statute. Nevertheless, it was under their order and influence that the planning and preparation commenced to procure armaments, establish logistical bases and transportation conveyances in order to commit the ultimate crime of aggression. To that end they. The Principal Accused, employed the services of Accessory nations, all of whom were signatories to the Rome Statute. These accessories-before-the-fact made a vital contribution to enable the Principal Accused to launch their act of aggression against Syria, a sovereign nation and fellow member of the United Nations. For these criminal actions, these Accessory Nations are clearly liable for prosecution by the International Criminal Court. But so too is the Principal Accused, to wit, the Criminal Cabal.

The Criminal Cabal encouraged and allowed their criminal accessories to commit International Criminal Court statutory crimes on, in, and over the respective territories of several ICC State Party signatories, to wit, Belgium, Bulgaria, Croatia, Romania and Jordan. Therefore, the ICC has jurisdiction over the Accused for these statutory crimes in accordance with Rome Statute article 12(2)(a) and (b) which affords the jurisdiction to the ICC to prosecute statutory crimes committed in ICC member states.

In fact, the intelligence agencies of the principal Accused ordered and were responsible for the commission of these ICC. statutory crimes in the respective territories of several ICC member states. Weapons and ammunition were requisitioned in and sent from numerous member states. Training facilities were provided by Jordan, a clear crime of aggression (Article 8(1) and (2). Finally, manpower was provided from a vast number of aiding and abetting nations that failed to be aware of the provisions of international law, in this case, the naked aggression that their citizens were committing against the duly constituted government of sovereign Syria.

Surely these undercover activities qualify as a crime of aggression under the language of Article 5 as the “planning, preparation, initiating or execution” of military action against another sovereign nation. And “armed bands, groups, irregulars or mercenaries” are similarly proscribed.

F. The Criminal Cabal
Four members of the Criminal Cabal for Perpetual War, to wit, the United States of America, Turkey, Saudi Arabia and Qatar, unfortunately, but understandably, are not State Parties to the Rome Statute. The other member, Jordan, is, a fact that may prove the Cabal’s demise. The Cabal and their aforementioned Accessory Accomplice nations, who are signatory parties, have embarked together on a violent, selfish, criminal pursuit of national interest. In so doing they have committed the ultimate international crime, the crime of aggression. Their “strategic interests,” largely unspecified except by generalities like “democracy”, “freedom”, and “markets” have made a charnel house of North Africa and the Middle East.

These rogue, flagrantly criminal nations should not go unpunished. They have violated with impunity Rome Statute Article 8, Crime of Aggression by aiding and abetting mercenary forces to commit savage war crimes in Syria, and now Iraq. These are laws that emerged from the Nuremberg War Crimes Trials. These are laws that any civilized nation would embrace as a way of life, indeed they are a code of universal honorable behavior. These are the laws that the Criminal Cabal and its collaborator nations have shredded and ignored.

As for the forty signatory nations that allowed, either wittingly or unwittingly, its citizens to ally themselves with mercenary forces attacking the sovereign nation of Syria, and now Iraq, provisions of Article 8 also apply. Article 8(1) “planning, preparation” language and paragraph 2(g) relating to “sending […] irregulars or mercenaries” should be applied and enforced.

The basis of this Criminal Complaint to the International Criminal Court regarding accusations of committing the crime of aggression is consistent with the purpose of the Rome Statute, Article 8(1) which defines the crime as:

“crime of aggression” means the planning, preparation, initiation or execution, by a person in a position effectively to exercise control over or to direct the political or military action of a State, of an act of aggression which, by its character, gravity and scale, constitutes a manifest violation of the Charter of the United Nations.” [26]

The next paragraph, Article 8(2)(g) explains that the aggression need not be committed by the regular armed forces of a State. The sending of mercenaries also qualifies as a crime of aggression, to wit,

The sending by or on behalf of a State of armed bands, groups, irregulars or mercenaries, which carry out acts of armed force against another State of such gravity as to amount to the acts listed above, or its substantial involvement therein.[27]

G. The Accused
Principals:
 United States of America citizens: Barack Hussein Obama, Hillary Rodham Clinton, John Forbes Kerry, John Owen Brennan, Michael Joseph Morell, David Howell Petraeus, Leon Edward Panetta
 Turkish citizens: Recep Tayyip Erdoğan, Ahmet Davutoğlu, Hakan Fidan.
 Saudi Arabian citizens: King Abdullah bin Abdulaziz and Prince Saud al-Faisal.
 Qatari citizens: Tamim bin Hamad Al Thani, Abdullah bin Nasser bin Khalifa and Al Thani Hamad bin Khalifa Al Thani.
 Jordanian citizens: Abdullah II ibn al-Hussein and Abdullah Ensour.

Accessories:
Belgian citizen: Elio Di Rupo,
Bulgarian citizens: Boyko Borisov, Marin Raykov Nikolov and  Plamen Vasilev Oresharski
Croatian citizens: Ivo Josipović and Zoran Milanović.
French citizen: François Gérard Georges Nicolas Hollande
Great Britain citizen: David William Donald Cameron
Romanian citizens: Traian Băsescu and Victor-Viorel Ponta. 

The specific charges against the above individuals, all in positions to exercise varying degrees of control over the political and military actions of a state, will be enumerated in the Legal Submissions, Section 3 below. Presidents, prime ministers and kings do not operate in a vacuum, nor do their advisors.

FOOTNOTES
[1]  Broomhall, Bruce. (2 ed.). Oxford University Press, p. 46. ISBN 978-0-19-925600-6.  
Cohn, Marjorie. Aggressive War: Supreme International Crime, International Clearing House. 
11 September 2004   http://www.informationclearinghouse.info/article7249.htm

[2] http://eeas.europa.eu/non-proliferation-and-disarmament/arms-export-control/index_en.htm

[3] UN Security Council Resolution 1970, para. 9.
http://www.icc-cpi.int/NR/rdonlyres/2B57BBA2-07D9-4C35-B45E-EED275080E87/0/N1124558.pdf

[4] UN Security Council Resolution 1973, para. 4.
http://daccess-dds-ny.un.org/doc/UNDOC/GEN/N11/268/39/PDF/N1126839.pdf?OpenElement

[5] Foreign nations’ proxy war in Syria creates chaos. Washington Post, David Ignatius. 2 October 2014. http://www.washingtonpost.com/opinions/david-ignatius-foreign-nations-proxy-war-creates-syrian-chaos/2014/10/02/061fb50c-4a7a-11e4-a046-120a8a855cca_story.html

[6] See: e.g., Libya: foreign mercenaries terrorising citizens, The Telegraph, By Adrian Blomfield, Salloum, February 23, 2011 http://www.telegraph.co.uk/news/worldnews/africaandindianocean/libya/8343959/Libya-foreign-mercenaries-terrorising-citizens.html;  Libyan Rebels Say They’re Being Sent Weapons, The New York Times, By ROD NORDLAND April 16, 2011 http://www.nytimes.com/2011/04/17/world/africa/17libya.html?_r=2&; La France a parachuté des armes aux rebelles libyens, Le Figaro, Philippe Gelie, Juin 28, 2011, http://www.lefigaro.fr/international/2011/06/28/01003-20110628ARTFIG00704-la-france-a-parachute-des-armes-aux-rebelles-libyens.php

[7] Erdogan Receives Gaddafi Human Rights Prize, Tripoli Post, 6 December 2010, http://www.tripolipost.com/articledetail.asp?c=1&i=5195; [Turkish] PM rules out NATO intervention in Libya
Today’s Zaman, February 28, 2011, http://www.todayszaman.com/news-236953-pm-rules-out-nato-intervention-in-libya.html;
Parliament OKs Turkey's involvement in Libya, The Oakland Press, March 24, 2011,
http://www.theoaklandpress.com/general-news/20110324/parliament-oks-turkeys-involvement-in-libya; Turkey Recognizes Libyan Rebels, Gives $300 Million, AP Reports Bloomberg,   by Zaid Sabah and Kim Chipman, July 4, 2011, 
http://www.bloomberg.com/news/2011-07-03/turkey-recognizes-libyan-rebels-gives-300-million-ap-reports.html;
In Great Company: Erdogan Wins Gaddafi Human Rights Prize, Asbarez.com, March 2, 2011, http://asbarez.com/93789/in-great-company-erdogan-wins-gaddafi-human-rights-prize/;

[8] TIR convention. International Road Transports (Transports Internationaux Routiers) TIR, https://www.iru.org/en_iru_tirconvention

[9]  See the undocumented but eminently reasonable: The Red Line and the Rat Line, London Review of Books, by Seymour M. Hersh, 17 April 2014,  http://www.lrb.co.uk/v36/n08/seymour-m-hersh/the-red-line-and-the-rat-line

[10] Biden’s admission: US allies armed ISIS, World Socialist Web, Patrick Martin. 6 October 2014
http://www.wsws.org/en/articles/2014/10/06/pers-o06.html

[11] C.I.A. Said to Aid in Steering Arms to Syrian Opposition, New York Times, by ERIC SCHMITT, June 21, 2012, http://www.nytimes.com/2012/06/21/world/middleeast/cia-said-to-aid-in-steering-arms-to-syrian-rebels.html?pagewanted=all&_r=0  

[12] See, e.g., Syria Crisis: Where Syrian Fighters Get Their Weapons From, Reuters, By Jonathan Saul and Mariam Karouny
July 13, 2012, http://www.huffingtonpost.com/2012/07/13/syria-crisis-rebels-weapons_n_1670780.html; Profit and Proliferation: A Special Report on Belgian Arms in the Arab Uprising, Part I,  AT WAR New York Times, By DAMIEN SPLEETERS
April 5, 2012, http://atwar.blogs.nytimes.com/2012/04/05/profit-and-proliferation-a-special-report-on-belgian-arms-in-the-arab-uprising-part-i/; Profit and Proliferation, Part 2: Will Belgian Arms End Up in Syria?, AT WAR  New York Times, by DAMIEN SPLEETERS,  April 6, 2012, http://atwar.blogs.nytimes.com/2012/04/06/profit-and-proliferation-part-2-will-belgian-arms-end-up-in-syria/?_php=true&_&_r=0, C.I.A. Said to Aid in Steering Arms to Syrian Opposition, New York Times, by ERIC SCHMITT, June 21, 2012, ww.nytimes.com/2012/06/21/world/middleeast/cia-said-to-aid-in-steering-arms-to-syrian-rebels.html?pagewanted=all&_r=0; UN Security Council Resolution 1970, http://www.icc-cpi.int/NR/rdonlyres/2B57BBA2-07D9-4C35-B45E-EED275080E87/0/N1124558.pdf; France admits it directly supplied arms to Syrian “rebels”, World Socialist Web, By Pierre Mabut, 27 August 2014, http://www.wsws.org/en/articles/2014/08/27/frsy-a27.html; The US Is Openly Sending Heavy Weapons From Libya To Syrian Rebels, GEOFFREY INGERSOLL AND MICHAEL B KELLEY, December 9, 2012,
http://www.businessinsider.com/obama-admin-admits-to-covertly-sending-heavy-weapons-to-syrian-rebels-2012-12;



[13] See, e.g., Council of the European Union, ‘European Union Code of Conduct on Arms Exports’, 8675/2/98 Rev 2, 5 June 1998; and Council Common Position 2008/944/CFSP of 8 December 2008 defining common rules governing control of exports of military technology and equipment, Official Journal of the European Union, L335, 8 Dec.2008.
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2008.335.01.0099.01.ENG;
EU Non-Proliferation Consortium, January 2012, The Review of the EU Common Position on Arms Exports, http://www.sipri.org/research/disarmament/eu-consortium/publications/publications/non-proliferation-paper-7

[14] ISIS Is Recruiting And Training Children To Fight, http://www.businessinsider.com/isis-recruiting-children-war-crimes-2014-8. The UN Human Rights Commission Report, A/HRC/27/60,13 August 2014 said that this case should be referred to the International Criminal Court. 
http://www.ohchr.org/Documents/HRBodies/HRCouncil/CoISyria/A.HRC.27.60_Eng.pdf

[15] How Isil is funded, trained and operating in Iraq and Syria. http://www.telegraph.co.uk/news/worldnews/middleeast/iraq/11052919/How-Isil-is-funded-trained-and-operating-in-Iraq-and-Syria.html

[16] Foreign Fighters in Syria, June 2014. Richard Barrett, P. 24, http://en.calameo.com/read/000009779f631011a5baa

[17]  Ibid., Pp.13,14.

[18] See, e.g., Turkey's Syria borders an open door for smugglers, http://www.al-monitor.com/pulse/ru/originals/2014/04/turkey-syria-borders-smuggling-guns-conflict-kurds-pkk-isis.html#; "TIR'ı verin yoksa çatışma çıkar", http://www.haber7.com/guncel/haber/1124219-tiri-verin-yoksa-catisma-cikar; As Turkey turned blind eye, ISIS took advantage, http://news.yahoo.com/turkey-turned-blind-eye-isis-031003793.html

[19] Turkey declares vanishing truck to Syria 'state secret', http://www.al-monitor.com/pulse/originals/2014/01/vanished-turkish-truck-state-secret.html#

[20]  Op.cit.,Barrett, P. 15. “the typical age range is 18-29”

[21] See, e.g., CIA ramping up covert training program for moderate Syrian rebels,  http://www.washingtonpost.com/world/national-security/cia-ramping-up-covert-training-program-for-moderate-syrian-rebels/2013/10/02/a0bba084-2af6-11e3-8ade-a1f23cda135e_story.html; I LEARNED TO FIGHT LIKE AN AMERICAN AT tHE FSA TRAINING CAMP IN JORDAN, http://www.vice.com/en_uk/read/syria-deraa-USA-Jordan-FSA-regime-CIA; CIA Activities in Syria: US Never Stops to Step on Same Rake, http://www.globalresearch.ca/cia-activities-in-syria-us-never-stops-to-step-on-same-rake/5353324; Syrie : l'opération anti-Assad a commence,
http://www.lefigaro.fr/international/2013/08/22/01003-20130822ARTFIG00438-syrie-l-operation-anti-assad-a-commence.php

[22] Rome Statute of the International Criminal Court, p.1.
http://www.icc-cpi.int/nr/rdonlyres/ea9aeff7-5752-4f84-be94-0a655eb30e16/0/rome_statute_english.pdf

[23]See, e.g., Report: CIA provides intelligence to Syrian rebels, AFP, Yitzhak Benhorin, March 23, 2013
http://www.ynetnews.com/articles/0,7340,L-4360110,00.html; CIA monitors potential terrorists in Syria, YNET, March 16, 2013, http://www.ynetnews.com/articles/0,7340,L-4357006,00.html; Report: Americans training Syria rebels in Jordan, Reuters, March 10, 2013, http://www.ynetnews.com/articles/0,7340,L-4354749,00.html

[24] See, e.g., Obama authorized covert support for Syrian rebels, sources say, CNN, August 2, 2012, http://edition.cnn.com/2012/08/01/us/syria-rebels-us-aid/; Darnell Gitti-(TAMAMI), Aydinlik, August 8. 2012, http://www.aydinlikgazete.com/mansetler/14303-darnell-gitti.html; Fars Haber Ajansı Aydınlık’ın haberini dünyaya duyurdu, Aydinlik,  August 9, 2012, http://www.aydinlikgazete.com/mansetler/14273-fars-haber-ajansi-aydinlikin-haberini-dunyaya-duyurdu.html; Rebel Groups in Syria Make Framework for Military, New York Times, by NEIL MacFARQUHAR and HWAIDA SAAD, December 7, 2012, http://www.nytimes.com/2012/12/08/world/middleeast/rebel-groups-in-syria-make-framework-for-military.html;

[25] U.S. Army Field Manual 27-10, Chapter 8 Remedies for Violation of International Law, Sect. II (498)(a)
       http://www.globalsecurity.org/military/library/policy/army/fm/27-10/Ch8.htm#s2

[26] Rome Statute, Article 8(1).

[27] Ibid., Article 8(2)(g).


3. LEGAL SUBMISSIONS

A. INTRODUCTION
As the evidence shown above illustrates, the arming, training and logistical support of mercenary forces by the United States, Turkey, Saudi Arabia, Qatar and Jordan for groups opposed to the duly constituted government in Syria, raises profoundly serious issues of potential criminality under the Rome Statute. Reports indicate that hundreds of thousands of Syrian civilians have been killed, three million have fled the country. Overall, nine million people—one-half the nation’s population—have been displaced. There is a significant body of evidence from official sources, NGOs and investigative journalists that suggests there is a reasonable basis to believe that crimes of the utmost gravity within the jurisdiction of the International Criminal Court may have been committed. 

Of anticipatory concern to the Complainant is that the Prosecutor might conclude that the submitted information does not provide a reasonable basis to conduct a formal investigation. Given the vast and horrendous nature of the crimes, the availability of information alone should not be a reason to refuse further investigation. Allowance should and can be made for the real prospect of additional compelling evidence becoming available through a formal investigation, particularly if the Complainant has demonstrated the existence of a reasonable probability that these crimes were committed. Certainly the Prosecutor would be able to obtain such evidence from the relevant authorities whose cooperation has not yet been forthcoming. For the avoidance of doubt, it is submitted that the Prosecutor should consider this Complaint in the context of a preliminary evaluation that has demonstrated probable cause that serious crimes have been committed.

In analyzing the seriousness of the information received, it is respectfully requested that the Prosecutor seek additional information from the United States, Turkey, Saudi Arabia, Qatar, Jordan, Belgium, Bulgaria, Croatia, France, Great Britain, Rumania, Syria and NATO, as well as intergovernmental and non-governmental organizations and other reliable sources in accordance with Article 15(2) of the Rome Statute.

The crime of aggression subsumes all other crimes of war. And the signatory nations that aid and abet the four non-signatory “principal” nations—the United States, Turkey, Saudi Arabia and Qatar—in their misdeeds are accomplices-before-the-fact and deserve no lesser punishment than the principals. Surely Jordan, Belgium, Bulgaria, Croatia, France, Great Britain, and Rumania, being State Party Signatories presumes a heightened awareness of these most serious crimes that plague the international community. Being a State Party implies, as the Rome Statute states, “a lasting respect for and the enforcement of international justice.” Instead, these accomplices chose the darkness and became accessories to the crimes of the Cabal. Jordan deserves special condemnation for its cooperation with the Cabal, thus defiling the spirit of the Rome Statute. If nothing is done about the transgressions of these nations and their accomplices, the civilized world will finish. This is terribly obvious, as obvious as serving the interests and collaborating in the crimes of the Cabal is a crime against humanity.
  
1. Summary of Submissions
In particular, the Court has jurisdiction in respect to the subject matter of the present complaint under Article 12(2) of the Rome Statute on the grounds that:

·        First, while the United States, Turkey, Saudi Arabia and Qatar are not contracting parties to the Rome Statute, nevertheless, the Accused ordered and were responsible for the commission of ICC statutory crimes on, in, and over the respective territories of several ICC member states: Jordan, Belgium, Bulgaria, Croatia, France, Great Britain and Romania.  Therefore, the ICC has jurisdiction over the Accused for their statutory crimes in accordance with Rome Statute article 12(2)(a) and (b) that affords jurisdiction to prosecute for ICC statutory crimes committed in member states; and/or

·        Second, perpetrators of crimes resulting from conduct discussed in this Complaint are, or may be, nationals of State Parties to the Rome Statute in accordance with Article 25(3) which assigns individual criminal responsibility. This includes nationals of Jordan as well as NATO member state signatories Belgium, Bulgaria, Croatia, France, Great Britain and Romania who provided material assistance in planning, preparation, initiation and execution of the aggression against Syria.

 ·        Third, not surprisingly, Syria has not consented to the use of force within its territory. To the contrary, Syria has repeatedly described this mercenary proxy invasion as a violation of its sovereignty. Nor is there any UN Resolution that authorizes the use of force in Syria.

Therefore, there is a reasonable basis for concluding that:

·        The Court has jurisdiction over the subject matter of this complaint.

·        The complaints are admissible.

·        The deaths, injuries and destruction caused by this horrific aggression are of such gravity as to justify investigation by the Prosecutor.

·        It is solidly in the interests of justice that, if crimes have, or may have been, committed, they be prosecuted. In these circumstances the Office of the Prosecutor must ensure that these crimes are investigated in accordance with Article 53 of the Rome Statute.

Finally, it is respectfully requested that the International Criminal Court issue arrest warrants immediately for the above name principal Accused in accordance with Rome Statute Article 58(1)(a), Article 58(1)(b)(i), Article 58(1)(b)(ii), and Article 58(1)(b)(iii). The sooner the better for all humankind.

 

 2. Summary of Steps Sought from Office of the Prosecutor

·        In analyzing the serious nature of the information received, it is requested that the Prosecutor seek additional information from the United States, Turkey, Saudi Arabia, Qatar,  Jordan, Croatia, Romania, Bulgaria, NATO and intergovernmental and non-governmental organizations and other reliable sources in accordance with Article 15 (2) of the Rome Statute.

·        Before determining the question of territorial jurisdiction, a matter of great importance, it is further requested that the Prosecutor request a ruling from the court on this question in accordance with Article 19 (3) of the Statute.

·        Finally, it is requested that the Prosecutor initiate an investigation of the facts surrounding this Communication in accordance with Article 51 (1) of the Statute.

 These steps are of great importance to the Complainant and to humanity. It will further validate the stated purpose of the International Criminal Court, to wit:

that the most serious crimes of concern to the international community must not go unpunished and that their effective prosecution must be ensured.[1]  

It is vital to the world that a legal process commence to bring justice to all those who have been unable to challenge the conduct of the Cabal and its collaborators in any forum, domestic or international. This Complaint is made on behalf of the dead, the dying, the grievously wounded, and all the psychologically traumatized victims of this apparently endless criminal aggression. The opportunity to be heard and acknowledged is of critical importance. For the sake of present and future generations, justice must not only be served but also preserved.


B. JURISDICTION ON GROUNDS OF TERRITORIALITY AND NATIONALITY

The International Criminal Court’s jurisdiction over the crimes committed arises in two aspects:

·        First, on the grounds of territorial jurisdiction since the attacks on the sovereign State of Syria were prepared and supplied and de facto partially planned and executed in State Party territories by State Parties. This is tantamount to launching attacks from a State Party, to wit: Jordan, Belgium, Bulgaria, Croatia and Romania.

·        Second, regarding nationality jurisdiction, there is a reasonable and well-documented basis to conclude that nationals of approximately 40 State Parties to the Rome Statute have participated in the execution and ongoing commission of the crime of aggression under the Statute. [2]


1. Territoriality
 Although the United States, Turkey, Saudi Arabia, Qatar and Syria are not signatories (State Parties) to the Rome Statute the court has jurisdiction over conduct which has occurred on the territory of a non-State Party where the accused is a national of a State that has accepted jurisdiction. Accordingly, via Article 12(2)(a) of the Statute, the ICC has jurisdiction over acts amounting to crimes under the ICC Statute that were committed by citizens of the following States: United States, Turkey, Saudi Arabia, Qatar, Belgium, Bulgaria, Croatia, France, Great Britain, Jordan and Romania.  [3]

It has been well documented that arms have been exported, gathered, shipped and otherwise transported to Syria from, at least, the following State Party nations: Belgium, Bulgaria, Croatia, Jordan and Romania. The process of firing weapons used in a criminal aggression by rogue mercenaries begins with the process of procuring and delivering these weapons into their criminal hands. Regarding territorial jurisdiction, according to Article 12 (2), the Court may exercise jurisdiction under the Statute where “The State on the territory of which the conduct in question occurred” is a State Party to the Statute. Furthermore France and Great Britain have collaborated with the Cabal by training mercenaries thus furthering their criminal purpose and pursuit. This, too, has been largely conducted in Jordan, a State Party to the Rome Statute.

Importantly, Article 31 of the Vienna Convention on the Law of Treaties holds that a “treaty shall be interpreted in good faith in accordance with the ordinary meaning to be given to the terms of the treaty in their context and in light of its object and purpose.” [4] Rome Statute Article 12(2)(a) is absent any stipulation that all of the criminal conduct must occur within the territory of the State Party to the Statute.

Within the context of Article 2(2)(a), other provisions of the Statute must be considered. Article 25 elaborates the conditions under which individuals can incur criminal responsibility under the Statute. This includes aiding and abetting, facilitating, ordering, soliciting or inducing a crime or joint criminal enterprise. There is no basis to interpret Article 2(2)(a) requiring that each and every element of the criminal conduct be committed within the territory of a State Party. Many crimes will involve conduct occurring partly within the territory of a State Party and partly without. Were liability to be precluded for this reason many crimes would avoid the jurisdiction of the Court. Such an interpretation would undermine the concept of individual criminal responsibility as established in Article 25 of the Statute.   

Thus the above State Party nations are accessories-before-the-fact with apparent foreknowledge that a crime of aggression was being planned. Furthermore, Jordan reportedly was and is used as a training base for radical mercenaries allegedly under the supervision of the CIA. Owing to a lack of a comprehensive investigation, this Complainant is unable to establish whether the “planning, preparation, initiation or execution”[5] phases of the crime of aggression were limited to the above State Party nations.

It is almost unnecessary to state that the nationality of a perpetrator is irrelevant to the territorial jurisdiction of the Court. States are allowed to prosecute foreign nationals who commit crimes in their territories. Furthermore, territorial jurisdiction does not and could not apply only to crimes occurring completely within the State. For example, in the case of this Complaint, aiding and abetting a crime by supplying arms to perpetrators outside the State’s territory where they know a crime will be committed. The principle of subjective territorial jurisdiction, established in 1926 in the S.S. Lotus case (France v. Turkey) [6], entitles a State on whose territory a criminal attack was launched to exercise jurisdiction over that crime.

So the fact that the United States, Turkey, Saudi Arabia and Qatar are not contracting parties to the Rome Statute is no bar to the Court’s prosecution of these Accused because they have ordered and been responsible for the commission of the Rome Statute Crime of Aggression on, in, and over the respective territories of at least five ICC State Parties. Article 13, paragraphs (a) and/or (c), explains the Court’s prerogatives for exercising its jurisdiction. Paragraph (a) provides jurisdiction if one or more of the States are Parties to this Statute or have accepted the jurisdiction of the Court in accordance with paragraph (3).[7] Paragraph (c) allows the Court to exercise its jurisdiction if “The Prosecutor has initiated an investigation in respect of such a crime in accordance with Article 15.” [8]
 Pursuant to Rome Statute Article 13(c), it is requested that the Prosecutor initiate an investigation proprio motu against the Accused in accordance with Rome Statute Article 15 (1): “The Prosecutor may initiate investigations proprio motu on the basis of information on crimes within the jurisdiction of the Court.” It is suggested that this Complaint alone against the Accused constitutes “sufficient information” in accordance with Rome Statute Article 15(1). Additionally, it is respectfully suggested that this Complaint also constitutes a reasonable basis to proceed with an investigation under Rome Statute Article 15(3).

2. Nationality
 There is a reasonable basis to believe that nationals of State Parties to the Rome Statute may have aided and abetted the commission of war crimes and the crime of aggression all amounting to crimes within the jurisdiction of the Court. Certainly the flood of arms, primarily through Jordan and Turkey, engendered the use of the nationals of State Parties. Jordanian citizens would be subject to immediate scrutiny. But the State Party weapons suppliers mentioned earlier—Belgium, Bulgaria, Croatia, Romania—undoubtedly employed their citizens in implementing the arms shipments.[9] Jordan was a particularly accommodating State Party. Not only did it allow weapons to flow over its border into Syria, it used its military cargo planes to expedite the delivery of weapons by its fellow State Party nations. Not satisfied with these brazen breaches in the Rome Statute, Jordan also permitted foreign intelligence agents to operate secret training camps on its territory.[10] One wonders why it bothered to sign and ratify the Rome Statute. Finally, the flow of foreign fighters into Syria was intense and mostly ignored until of late. At least 81 countries, half of them signatories to the Rome Statute, provided at least 2,500 of their citizens to participate in the Cabal’s crime of aggression in Syria.[11]  Of course, this number has expanded significantly since the documentation occurred.  

These criminal practices have been the subject of considerable publicity and controversy. The above cited State Parties and their nationals who supplied the vast arsenal of weaponry to the forces attempting to overthrow the duly constituted Syrian government surely knew that the armaments would be used in the furtherance of a crime of aggression. Surely they should have known that such a crime would be within the jurisdiction of the Court. In the case of Croatia, the huge size of the weapons shipments suggests such foreknowledge and approval by the government thus implying criminal intent by the government.
 

C. Admissibility: Gravity, Complementarity and Interests of Justice

1. Gravity
From any viewpoint, the nature, scale and impact of these acts of astounding violence provides reasonable grounds to believe that crimes against humanity, war crimes and the overarching crime of aggression have been committed. Can there be any doubt that the conduct in question is of sufficient gravity to fall within the Court’s jurisdiction as a matter of principle? Hundreds of thousands killed, half of Syria’s population displaced, three million have fled to neighboring countries. Does this not render self-evident the question of whether this conduct is sufficiently grave and disproportionate to pass the gravity threshold? Is it not almost beyond the reach of human thought that arming, training and encouraging mercenary forces to overthrow a sovereign nation would entail such wholesale murder of innocent people? Have not the consumption of the internal organs of dying people, along with crucifixions, beheadings and dismemberments gone well beyond all standards of “gravity?” The interests of the victims of these horrors must be served. Is this not what the Court meant when it said in its Preamble (see Appendix, Exhibit 1) that “the most serious crimes of concern to the international community as a whole must not go unpunished and that their effective prosecution must be ensured”?

2. Complementarity
There are no national investigative or prosecutorial authorities willing or able to investigate or bring to trial the conduct that is the subject of this Complaint. Surely none of the institutions of these Accused are interested. And an investigation by Syrian authorities, a nation beset on all sides by aggressors, is clearly unfeasible and even ridiculous. As matters now stand, there is no possibility that some national authority would investigate much less prosecute these crimes. Accordingly, the only institution capable of conducting an investigation is the International Criminal Court. This Court is indeed humanity’s justice institution of last resort.

3. Interests of Justice
Clearly these crimes are of sufficient gravity to fall within the jurisdiction of the Court. Equally evident is the incontrovertible fact that any and all national authorities are unwilling and/or unable to investigate such massive crimes. Accordingly, it is inconceivable that the interests of justice would intervene against the investigation of these crimes. The sheer mayhem involved in this aggression would argue for investigation. Furthermore, it is essential that the commitment of State Parties to vigorous enforcement the Rome Statue continue. The Court itself said as much

Paragraph four of the Preamble underlines that the States Parties are determined to put an end to impunity for the perpetrators of the most serious crimes of concern to the international community and thus to contribute to their prevention. The last paragraph indicates their resolve “to guarantee lasting respect for and the enforcement of international justice”. Thus, considerations of prevention of serious crimes and guaranteeing lasting respect for international justice may be significant touchstones in assessing the interests of justice.[12]

It is exactly the impunity of the Criminal Cabal that must be checked. Nothing less than the continuation of a law-abiding world is at stake. Notwithstanding this, the Prosecutor has a specific responsibility to consider the interests of the victims[13]—hundreds of thousands killed, millions displaced by the aggression perpetrated by the Criminal Cabal. And not just to see justice done on their behalf but to see justice triumphant as a safeguard for all those who might be victims of this, or some other criminal cabal in the future. Everything depends upon making impunity impossible.
  

D. CRIMES WITHIN THE JURISDICTION OF THE COURT

The following summary sets out some of the central evidence of crimes within the jurisdiction of the Court. Obviously, it does not purport to provide an exhaustive summary of all the evidence available in respect to each crime. Nor is it intended to set out exhaustively all those crimes under the Statute which may have arisen through these criminal acts. It does, however, identify and summarize a body of evidence which indicates a reasonable basis (indeed, in some instances, a compelling basis) for concluding, at this stage, that these incidents and circumstances involve crimes within the jurisdiction of the Court.

It is important to note that Rome Statute, Article 8 is clear that those aggressors that empower mercenaries receive no protection from the law, to wit, Article 8 (2) (g):

The sending by or on behalf of a State of armed bands, groups, irregulars or mercenaries, which carry out acts of armed force against another State of such gravity as to amount to the acts listed above, or its substantial involvement therein.[14]

Accordingly, the following nations are charged as follows:

Jordan
 ·        Primary malefactor. There are twelve nations herein accused of criminal behavior relevant to the breach of the Rome Statute. Of the five Principal Accused only one, Jordan, is a State Party signatory to the Rome Statute. Jordan has been extraordinarily helpful as a war monger to the other members of the Criminal Cabal—the United States, Turkey, Saudi Arabia and Qatar. It has employed and devoted its intelligence services, its military transport planes for weapons delivery and its own territory for training purposes in the planning, preparation, initiation and execution of an act of aggression against the sovereign nation of Syria. These are gross and obvious crimes against the Rome Statute, a body of law that Jordan embraced, signing on 7 October 1998, ratifying on 11 April 2002 and now in complete and criminal breach of Article 8, Crime of Aggression.     

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)

 ·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.


United States of America
·        Primary malefactor. Adana, Turkey control center. Encouraged and incited State Party nations—Belgium, Bulgaria, Croatia, France, Great Britain, Romania—to provide intelligence services and military instruction to mercenary forces to attack the sovereign nation of Syria. Procurer of arms for illegal mercenary forces to commit the crime of aggression.

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 

·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.



 Turkey
 ·        Primary malefactor. Procurer and supplier of arms, including chemical weaponry, to mercenary forces, primarily al-Nusra gangs. Prime minister contributed relentless war-mongering rhetoric against Syrian president Bashar al-Assad. Intelligence services intensively aided rebel militants.

·        Provided transportation services for weapons and other lethal equipment to mercenaries.

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)  

·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.
 

Saudi Arabia
 ·        Primary malefactor. Provided intelligence services and military instruction to mercenary forces to attack the sovereign nation of Syria.

·        Provided financing for weapons procurement to overthrow Syrian government.

·        Provided transportation services for weapons and other lethal equipment to mercenaries.

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)

·        Aiding and abetting subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.


Qatar
·        Primary malefactor. Provided intelligence services and military instruction to mercenary forces to attack the sovereign nation of Syria.

·        Provided financing for weapons procurement to overthrow duly constituted Syrian government.

·        Provided transportation services for weapons and other lethal equipment to mercenary forces.

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)

·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.

 
 Belgium
·        Secondary malefactor. Provided weapons for use by illegal mercenaries to overthrow the duly established government of Syria.

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)

·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.
  

Bulgaria
 ·        Secondary malefactor. Provided weapons for use by illegal mercenaries to overthrow the duly established government of Syria.

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)

·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.
 

Croatia
 ·        Secondary malefactor. Provided weapons for use by illegal mercenaries to overthrow the duly established government of Syria.

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)

·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.
 

France
 ·        Provided intelligence services and military instruction to mercenary forces to attack the sovereign nation of Syria.

·        Aided and abetted the illegal transfer of armaments and other lethal weaponry.

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)

·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.
  

Great Britain
 ·        Provided intelligence services and military instruction to mercenary forces to attack the sovereign nation of Syria.

·        Conspired with CIA to conceal from the U.S. Congress weapons illegal transfers from Libya to Syria

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)

·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.


Romania
 ·        Secondary malefactor. Provided weapons for use by illegal mercenaries to overthrow the duly established government of Syria.

·        Contributed to the “planning, preparation, initiation or execution” of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)

·        Aided and abetted subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.



Principal Accused:
 United States of America
Turkey
 Saudi Arabia
 Qatar
 Jordan*


Accessory Accused: All signatories to the Rome Statute
 Belgium*
 Bulgaria*
Croatia*
 France*
 Great Britain*
 Romania*

* State Party to Rome Statute


E. SUMMARY OF CHARGES

In accordance with the Rome Statute, Article 25, Individual Criminal Responsibility, the names and capacities of the individuals shown below are specifically charged with flagrantly violating the letter and spirit of the law that constrains civilized nations from committing crimes against humanity and aggression. Importantly, Article 27, Irrelevance of Official Capacity, renders a truly democratic and humanistic approach to the enforcement of the Rome Statute. Not only are all people equal under the law, no person or persons, no matter how important and prestigious, is above the law. A cat may not only look at a king, but can also file a criminal complaint against the monarch. From the lowest to the highest, the International Criminal Court embraces a truly democratic safeguard for humanity. No immunities or special treatment are allowed under national or international law for those brought before the Court. No doubt to George Orwell’s delight, there is indeed a place in this world where no one person is more equal than others, to wit, the International Criminal Court. The Complainant understands that there may well be lesser included offenses that might be deemed chargeable. Accordingly, it is also understood that the generality of the following charges are a consequence of the evidence now extant. Thus, there may well be a modification, extenuation or heightening in the seriousness of the crimes ultimately charged.  In that spirit and resolve, and well aware that a thorough investigation by the Prosecutor must and should ensue, the Complainant accuses the following individuals accordingly: (Following FOOTNOTES section)

FOOTNOTES

[1] Rome Statute, p.1.

[2] See Appendix 3, Foreign Fighters in Syria.

[3] Rome Statute, Article 12 (2) (a), Preconditions to the exercise of jurisdiction
 http://legal.un.org/icc/statute/romefra.htm

[4]   VIENNA CONVENTION ON THE LAW OF TREATIES, Section 3, Article 31, General Rule of Interpretation.

[5] Ibid.. Article 8 (1), Crime of aggression.

[6] UNTERM, Territorial Principle, http://unterm.un.org/dgaacs/unterm.nsf/8fa942046ff7601c85256983007ca4d8/082fdcf5273de32485256e7b00645b66?OpenDocument

[7] Ibid., Article 12 (3). “If the acceptance of a State which is not a Party to this Statute is required under paragraph 2, that State may, by declaration lodged with the Registrar, accept the exercise of jurisdiction by the Court with respect to the crime in question. The accepting State shall cooperate with the Court without any delay or exception in accordance with Part 9.” 

[8] Ibid., Article 13, Exercise of jurisdiction.

[9] See, e.g., Arms Airlift to Syria Rebels Expands, With Aid From C.I.A., New York Times, March 24, 2013
http://www.nytimes.com/2013/03/25/world/middleeast/arms-airlift-to-syrian-rebels-expands-with-cia-aid.html?pagewanted=all;
 Saudis Step Up Help for Rebels in Syria With Croatian Arms, New York Times, February 25, 2013 
 http://www.nytimes.com/2013/02/26/world/middleeast/in-shift-saudis-are-said-to-arm-rebels-in-syria.html?pagewanted=all&_r=0
 Syria Crisis: Where Syrian Fighters Get Their Weapons From, Reuters, July 13, 2012;
http://www.huffingtonpost.com/2012/07/13/syria-crisis-rebels-weapons_n_1670780.html; Advanced U.S. Weapons Flow to Syrian Rebels, Wall Street Journal, April 18, 2014, http://online.wsj.com/news/articles/SB10001424052702304626304579509401865454762;  In Turnabout, Syria Rebels Get Libyan Weapons, , New York Times, June 21, 2013
 http://www.nytimes.com/2013/06/22/world/africa/in-a-turnabout-syria-rebels-get-libyan-weapons.html?_r=0
 Profit and Proliferation: A Special Report on Belgian Arms in the Arab Uprising, Part I
 New York Times,  April 5, 2012
http://atwar.blogs.nytimes.com/2012/04/05/profit-and-proliferation-a-special-report-on-belgian-arms-in-the-arab-uprising-part-i/
 Profit and Proliferation, Part 2: Will Belgian Arms End Up in Syria? New York Times, April 6, 2012
 http://atwar.blogs.nytimes.com/2012/04/06/profit-and-proliferation-part-2-will-belgian-arms-end-up-in-syria/?_php=true&_&_r=0

[10] CIA ramping up covert training program for moderate Syrian rebels, Washington Post, October 2, 2013
 http://www.washingtonpost.com/world/national-security/cia-ramping-up-covert-training-program-for-moderate-syrian-rebels/2013/10/02/a0bba084-2af6-11e3-8ade-a1f23cda135e_story.html; CIA Activities in Syria: US Never Stops to Step on Same Rake, Global Research, October 7, 2013,
 http://www.globalresearch.ca/cia-activities-in-syria-us-never-stops-to-step-on-same-rake/5353324; I LEARNED TO FIGHT LIKE AN AMERICAN AT tHE FSA TRAINING CAMP IN JORDAN, VICE.COM, April 3, 2014
http://www.vice.com/en_uk/read/syria-deraa-USA-Jordan-FSA-regime-CIA;

[11] Hundreds Of Westerners Have Joined ISIS, And Here's Where They Came From, Business Insider, April 27, 2014  http://www.businessinsider.com/isis-is-recruiting-westerners-countries-2014-8; FOREIGN FIGHTERS IN SYRIA, Soufan Group, June 2014, http://soufangroup.com/foreign-fighters-in-syria/; Turkey struggles as "lone gatekeeper" against Islamic State recruitment, REUTERS, August 26, 2014, http://af.reuters.com/article/worldNews/idAFKBN0GQ0ZE20140826?feed&sp=true;

[12]  International Criminal Court, Policy Paper on the Interests of Justice, Understanding the meaning of the Interests of Justice within the Statute, 4 (c). September 2007.
 http://www.icc-cpi.int/NR/rdonlyres/772C95C9-F54D-4321-BF09-73422BB23528/143640/ICCOTPInterestsOfJustice.pdf’

[13] Ibid., p. 5.

[14] Rome Statute, Article 8 (2) (g), Crime of aggression. 


THE ACCUSED: The United States of America
Picture
Barack Hussein Obama
President of the United States, 21 January 2009-present
Date of Birth: August 4, 1961
Place of Birth: Honolulu, Hawaii
Nationality: American

 
CHARGES: 
·        Responsible for the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)  
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 




Picture
Hillary Rodham Clinton
US Secretary of State, 21 January 2009-1 February 2013
Date of Birth: October 26, 1947
Place of Birth: Chicago, Illinois
Nationality:  American


CHARGES: 
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.




Picture
John Forbes Kerry
US Secretary of State, 1 February 2013-present
Date of Birth: December 11, 1943
Place of Birth: Aurora, Colorado
Nationality: American


CHARGES: 
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 


Picture
John Owen Brennan
Director of CIA, 8 March 2013-present
Date of Birth: September 22, 1955
Place of Birth: North Bergen, New Jersey
Nationality:  American

 

CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 


Picture
Michael Joseph Morell
Acting Director of the CIA, 9 November 2012 – 8 March 2013
Date of Birth: September 4, 1958
Place of Birth: Cuyahoga Falls, Ohio
Nationality: American


 

CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 


Picture
David Howell Petraeus
Director of CIA, 6 September 2011 – 9 November 2012
Date of Birth: November 7, 1952
Place of Birth: Cornwall-on-Hudson, New York
Nationality: American


CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.


Picture
Leon Edward Panetta
Director of CIA, 13 February 2009 – 30 June 2011
Date of Birth: June 28, 1938
Place of Birth: Monterey, California
Nationality: American

  
 CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.



THE ACCUSED: Turkey
Picture
Recep Tayyip Erdoğan
ex-Prime Minister now President of Turkey
14 March 2003-present
Date of Birth: 26 February 1954
Place of Birth: Istanbul
Nationality: Turkish


CHARGES:
·        Responsible for the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts

. 

Picture
 Ahmet Davutoğlu
ex-Foreign Minister now Prime Minister of Turkey
Date of Birth: 26 February 1959 
Place of Birth: Taşkent,
Konya Province, Turkey
Nationality: Turkish


CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 




Picture
 Hakan Fidan
Director of Turkish Intelligence (M.I.T.), 27 May 2010-present
Date of Birth: 1968
Place of Birth: Ankara
Nationality: Turkish


CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 



THE ACCUSED: Saudi Arabia
Picture
Abdullah bin Abdulaziz
King of Saudia Arabia, 1 August 2005-to his death
Date of Birth: 1 August 1924
Place of Birth:
Nationality: Saudi

CHARGES
·        Responsible for the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 


Picture
Prince Saud al-Faisal
Foreign Minister of Saudi Arabia, 13 October 1975-present
Date of Birth: 2 January 1940
Place of Birth:
Nationality: Saudi


CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.


THE ACCUSED: Qatar
Picture
Tamim bin Hamad Al Thani
Emir of Qatar, 25 June 2013-present
Date of Birth: 3June 1980
Place of Birth:
Nationality: Qatari

CHARGES:
·        Responsible for the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.   


Picture
 Abdullah bin Nasser bin Khalifa Al Thani
Prime Minister of Qatar, 26 June 2013-present
Date of Birth: 1959
Place of Birth:
Nationality: Qatari

CHARGES
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.


Picture
Hamad bin Khalifa Al Thani
Ex-Emir of Qatar, 27 June 1995-25 June 2013
Date of Birth: 1952
Place of Birth:
Nationality: Qatari


 
CHARGES
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.


THE ACCUSED: JORDAN
Picture
Abdullah II ibn al-Hussein
King of Jordan, 7 February 1999-present
Date of Birth: 30 January 1962
Place of Birth: Amman
Nationality: Jordanian



 

CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·       
Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.


Picture
Abdullah Ensour
Prime Minister of Jordan, October 2012-present
Date of Birth: 20 January 1939
Place of Birth: Salt
Nationality: Jordanian

 
 CHARGES: 
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 


THE ACCUSED: BELGIUM
Picture
 
Elio Di Rupo
Prime Minister of Belgium, 6 December 2011-present
Date of Birth: 18 July 1951
Place of Birth: Morlanwelz, Wallonia
Nationality: Belgian


 
CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.



THE ACCUSED: BULGARIA
Picture
Boyko Borisov
Prime Minister of Bulgaria,  27 July 2009 – 13 March 2013
Date of Birth: 13 June 1959
Place of Birth: Bankya
Nationality: Bulgarian




CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.  


Picture
Marin Raykov Nikolov
Acting Prime Minister of Bulgaria, 13 March 2013 – 29 May 2013
Date of Birth: 17 December 1960
Place of Birth: Washington, D.C., USA
Nationality: Bulgarian




CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·       
Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 


Picture
Plamen Vasilev Oresharski
Prime Minister of Bulgaria, 29 May 2013 – 6 August 2014
Date of Birth: 21 February 1960
Place of Birth: Dupnista
Nationality: Bulgarian


 

CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.



THE ACCUSED: CROATIA
Picture
Ivo Josipović
President of Croatia, 19 February 2010-present
Date of Birth: 28 August 1957
Place of Birth: Zagreb
Nationality: Croatian





CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·       
Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.

 


Picture
Zoran Milanović
Prime Minister of Croatia, 23 December 2011-present
Date of Birth: 30 October 1966
Place of Birth:
Nationality: Croatian



 

CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 


THE ACCUSED: FRANCE
Picture
François Gérard Georges Nicolas Hollande
President of France, 15 May 2012-present
Date of Birth: 12 August 1954
Place of Birth: Rouen
Nationality: French


 

CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 


THE ACCUSED: GREAT BRITAIN
Picture
David William Donald Cameron
Prime Minister of England, 11 May 2010-presnet
Date of Birth: 9 October 1966
Place of Birth: London
Nationality: English



CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 


THE ACCUSED: ROMANIA
Picture
Traian Băsescu
President of Romania, 27 August 2012-present
Date of Birth: 4 November 1951 
Place of Birth: Basarabi
Nationality: Romanian



CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression) 
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts.


Picture
Victor-Viorel Ponta
Prime Minister  of Romania, 7 May 2012-present
Date of Birth: 20 September 1972 
Place of Birth: Bucharest
Nationality: Romanian



CHARGES:
·        Aided and abetted the planning, preparation, initiation and execution of an act of aggression which by its character and scale constitutes a manifest violation of the Charter of the United Nations. (Article 8 (2), Crime of aggression)
·        Aided and abetted the subsequent crimes against humanity. Rome Statute, Article 7, Crimes against humanity, paragraph 1, “widespread or systematic attack directed against any civilian population…”  (a) Murder, (b) Extermination, (d) Forcible transfer of population, (f) Torture, (h) Persecution, (Enforced disappearance of persons, (k) Other inhumane acts. 




G. CONCLUSION
Law and life are sacred things. Without the former, the latter is valueless and predatory. Today, we approach that sad condition. When it doesn’t suit their immediate interest, nations honor bound to abide by the humane purposes and principles of the Charter of the United Nations blithely ignore their airy promises and attempt to destroy sovereign nations not to their liking. Talk is cheap and bombs are loud and deadly.

Many nations, impressed with the idea of it all, have codified their support for and adherence to a legal remedy to help prevent the most serious crimes of international concern, that is, war crimes, crimes against humanity and genocide. Importantly, they became signatories to this legislation, the Rome Statute. What an important first step towards a more peaceful world! Yet, while the ink was still damp, a few violated their obligations arising from this Statute and provided rogue state, non-signatory aggressor nations with a full range of accomplice services: weapons procurement, transportation, mercenary training camps and shared intelligence operations. All of this was designed to aid and abet the perpetration of war crimes against the Syrian Arab Republic. Employing violent, mercenary hordes, these rogue states attacked their latest enemy–of-choice. And some State Parties bound together by the Rome Statute acted as accomplices for the Criminal Cabal. What a grand, cowardly new world we all inhabit! 

And it will not stop. We see the purpose. Nothing is any longer mysterious. We see the current Syrian catastrophe as the awful proof hurled in our faces by these criminal aggressors, this Criminal Cabal. The law is ignored with impunity. Impunity, that sublimely arrogant condition with respect to the law that the International Criminal Court seeks to end. Justice has been slow in coming in this war-torn century. Lies and deceptions fuel barbaric, murderous hordes on the payrolls of the great powers and their secretive intelligence operators. Justice too long delayed is justice denied, said Martin Luther King almost fifty years ago. Can we not arrest this rush to chaos, this deadly, immoral, illegal marathon of aggression? Only the law can stop these deadly, dark powers. This court, the International Criminal Court, is now the only judicial institution that can save the international community that it has pledged to protect.

Without an investigation by the Prosecutor there can be no doubt that the result will be a continuation of the absolute impunity of the Criminal Cabal. The gravest, most atrocious crimes within the jurisdiction of the Court are flung in its face and in the face of humanity. To do nothing is an even graver crime.

“Our problems are man-made, therefore they may be solved by man,” said John F. Kennedy over a half-century ago, adding, “And man can be as big as he wants.” That is indeed the question. We well know how low some specimens of humanity can stoop. But with the courageous support and determination of the International Criminal Court we, the vast majority of peace-loving members of the international community, can become a huge force for international restraint and even peace.

Finally, it is respectfully requested that the International Criminal Court immediately issue arrest warrants for the above name principal Accused in accordance with Rome Statute Article 58(1)(a), Article 58(1)(b)(i), Article 58(1)(b)(ii), and Article 58(1)(b)(iii). The sooner the better for all humankind. The sooner the better that the legal battle against impunity begins.
 

James C. Ryan. Ph.D.
Istanbul, Turkey
6 October 2014



H. THE COMPLAINANT
 James C. Ryan is a writer, an aggressive peace activist and a columnist for Aydınlık Daily, an Istanbul-based newspaper. He is a 1962 graduate of the United States Military Academy at West Point. In response to the war criminality of the Bush administration’s preemptive attack on Iraq, he co-founded West Point Graduates Against the War (http://wpgaw.org/) and Service Academy Graduates Against the War (http://sagaw.org/). He holds graduate degrees in literature, economics, fiction writing (M.F.A) and a Ph.D. in the Sociology of Literature. He has taught at Columbia University, the City College of New York and Istanbul’s Kadır Has University. 







Oceania was at war with Eurasia: 

therefore Oceania had always been at war with Eurasia.
The enemy of the moment always represented absolute evil, 

and it followed that any past or future agreement with him was impossible.

—George Orwell, 1984


 

SEE APPENDICES AT:   
http://www.brighteningglance.org/slaughter-in-syria-appendices-to-criminal-complaint-to-icc.html 
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