International Criminal Court

MEMORIAL FOR THE PROSECUTION

College of Law, University of Saint La Salle

Bascones, Ralph Romeo B.

Inumerables, Sheila Mae E.
Abarico, Marian Christina U.
Bayawa, Anthony Isidro IV N.

(Word Count: 1932)

P01

MEMORIAL FOR THE PROSECUTOR

TABLE OF CONTENTS

INDEX OF AUTHORITIES

iii

STATEMENT OF FACTS

iv

PLEADINGS

I.

THE EXISTENCE OF ARMED CONFLICT

II.

COLONEL CALLEY JONES BEARS THE

CRIMINAL RESPONSIBILITY FOR THE WAR

CRIME OF VIOLENCE TO LIFE AND PERSON,
IN PARTICULAR CRUEL TREATMENT AND TORTURE
III.

COLONEL JONES IS GUILTY OF THE WAR

CRIME OF INTENTIONALLY DIRECTING
ATTACKS AGAINST MEDICAL TRANSPORT
AND PERSONNEL USING THE DISTINCTIVE
EMBLEMS OF THE GENEVA CONVENTIONS
IN CONFORMITY WITH THE INTERNATIONAL LAW

IV.

WAR CRIME OF LAUNCHING AN ATTACK CAUSING

EXCESSIVE INJURY OR DAMAGE IN RELATION
TO OVERALL MILITARY ADVANTAGE ANTICIPATED.

PRAYER

TABLE OF AUTHORITIES

CONVENTIONS AND INTERNATIONAL AGREEMENTS

Additional Protocol
Four Geneva Conventions
Statute of the International Criminal Court
United Nations Human Rights Committee
International Committee on Red Cross Conference

3, 5, 7,8
2
4
3
7

CASES
Akayesu (Judgement) (1998 Trial Chamber) ICTR-96-4-T, [483] (Akayesu).
Aydin v. Turkey, Report of Judgements and decisions, ECtHR, 1997-VI, (84).
ICC, Lubanga Judgment, para. 538.
ICT, Limaj Trial Judgment, para. 90.
ICTY, Delalic Trial Judgment, para. 184.
Prosecutor v. Aleksovski Case No. IT-95-14/1-A-ICTY.
Prosecutor v. Blastik (Judgment) (2000 Trial Chamber).
Prosecutor v. Krstic (Judgement) (2001 Trial Chamber) IT-98-33-T [601].
Prosecutor v. Kunarac (Judgement) (2002 Appeals Chamber).
Prosecutor v. Tadic (Decision) (1995 Appeals Chamber),IT-9401-AR72, [70].
Prosecutor v. Tadic (Judgment) (1997 Trial Chamber), IT-94-1-T, [562].
Prosecutor v. Tadic (judgment) (1999 appeal)
Prosecutor v. Valsilijevic Judgment Case No. IT 98-32-T ICTY, November 29, 2002.

6
3
1
2
1
8
3, 8
6
3, 5
1
2
2
8

MISCELLANEOUS
Blacks Law Dictionary, 9th, edn., 2009.
International legal material Reports, 31 I.L.M.612(1992).
Military Manuals of Germany, South Africa and Switzerland

6
7
5

STATEMENT OF FACTS
The Federal Republic of Bariland (FRB) is composed of 4 constituent republics: North Baron,
South Baron, East Drakona and Katoland with Centro as its capital and largest city. Katoland
was conquered and integrated in the XIX century.
The population of FRB is divided into 3 ethnic groups: Bari, Drak and Katoni. In Katolands
population composed of 65% Katoni, 25% Drak and 5%others while East Drakonias population
composed of 85% Drak, 10% Bari, 2% Katoni, 3% others.
Katoland is the second largest constituent Republic with Urbo as its capital city. Drak population
mostly concentrated in the eastern part of the Republic in a region called West Drakonia with
Mesto as the main city.
Due to Katoni Nationalism rising in Katoland, they were more inclined to reject the powers of
FRB. In 1998, Katolandelections brought to power a nationalist government openlu seeking
Katoland Independence.
Drakonian Nationalist Alliance (DNA), an influential movement in West Drakonia since 1995,
was strongly opposed to Katoland Independence which would marginalize further the Draks in
Katoland. Katoland Government, in response to DNA, took nationalist measures to radicalize
the DNA. In 2011, DNA issued a proclamation establishing the Drakonian Democratic
Republic (DDR). The Drak population boycotted the subsequent 2002 Katoloand elections and
DNA organized their own contest on December 2002. However, Katoland declared DNA
elections as illegitimate.
Violent conflict broke out towards the beginning of 2003. FRB and Katoland security troops
were dispatched to West Drakonia in February. The fighting was characterized by general
disregard of international humanitarian law by uncontrollable militias, with both sides reporting
atrocities. Meanwhile, Centro and Urbo agreed to grant Katoland its Independence in 2004.
President Stark became the interim leader.

Republic of National Front (RNF) shifted its main objective to the establishment of an
independent state of West Drakonia and allied itself with more radical DNA. Rallies were held
in West Drakonia resulting to widespread riots and demonstrations.
President Stark declared a state of emergency in June 2004 and outlawed DNA due to National
Security. Hundreds of RNF and DNA supporters were arrested and detained. By September,
violent clashes in Mesto and other towns broke out. The violence increased for 6 more months
until the UN Security Council issued a statement urging the Katoland Government to stop the
violence. Katoland accepted the ceasefire after an agreement with Drakonian Nationalist to stop
the use of force with Katoland pledging not to impose sanctions on the Draks.
Until 2010, West Drakonia was peaceful with FRB backing financial guarantees and reinforcing
West Drakonias defense capabilities. However, Katoland Government regularly protested
against continually increasing FRB economic and military presence in the Mesto Region and the
Bargo station and against the acts of uncontrolled Drak Militias in the Region.
On December 25th , the websites for the Katoland National News (KNA) and Radio (KNR) were
hacked, the contents of the websites were replaced by a feed to East Drakonia TV websites. East
Drakonia TV denied the hacking.
To face the perceived threats to Katoland security, the Katoland President established the
National Crisis Council (NCC) on 15th January. He appointed Colonel C. Jones, Minister of
Defence and Chief of the Armed Forces as Executive Vice-Chairman of the Council. On the
latter recommendation, the Head of the External Security Agency (KESA) was appointed as one
of the members.
Colonel Jones had been advocating for months that control over West Drakonia was to be reestablished at all costs to ensure Katolands security and check FRBs growing influence. The
first meetings of the NCC led by Colonel Jones were devoted to assessing to current situation
and devising a proper strategy to bring West Drakonia back under the full authority of the
Katoland government. The Council decided on three points of action: 1) to re-establish the
legitimacy of Katoland sovereignty over West Drakonia; 2) to reinforce its military and security
apparatus; 3) to diminish the influence of the FRB in West Drakonia. Colonel Jones was tasked
to direct the preparations to be able to assume full authority over West Drakonia by military

means if necessary. The Head of KESA was charged in particular to seek the reinforcement of
cyber-security within government agencies, as well as to seek means of retaliation for the recent
cyber-attacks.
The NCC also decided to send security forces to close down a vast black market complex, which
was one of the region's chief sources of revenue, leading to fighting by Katoland armed and
security forces and Drakonian civilian militias. Hostage takings, shootouts and occasional
bombings left dozens dead and wounded.
In September 2010, the NCC endorsed Colonel Joness proposal to put Western Drakonia under
full military authority. Colonel Jones reassured the Council that "all necessary measures
including any legitimate means and methods of warfare whatever the costs would be taken to
achieve the objective of re-establishing authority over Western Drakonia. He indicated that he
would personally supervise the operations but would welcome the assistance of the security
forces under the authority of the Ministry of Internal Affairs and KESA.
The central command issued a new instruction providing: (1) All medical vehicles going through
control posts, whatever the service they belong to, have to be thoroughly searched. (2) The
identity of any persons present in medical vehicles, including drivers and medical personnel,
have to be verified with the central command; (3) If a person on board a vehicle is identified as a
member of enemy forces, a separatist militant or if weapons are found on board the vehicle, all
persons on board are to be surrendered to the nearest military post. (3) Any vehicle found to be
transporting weapons or ammunition is to be confiscated.
The implementation of the new instruction led to the death of several persons in need of
immediate medical attention. At some control posts, vehicles transporting wounded were
systematically stopped and searched. Identity checks delayed controls as well, so that vehicles
were immobilized for several hours. The media reported that on October 2nd alone, 5 persons
died in the vehicle transporting them. Other reported that there were no emergency vehicles that
could not pick up and transport the wounded as many of were immobilized, while others
confiscated.
NCC made a public statement to the effect that the 2003 Emergency Proclamation was still in
force. By the end of September 2010, the main towns and villages of West Drakonia were

combed by armed and security forces. Those suspected to be either associated or supporters of
the DNA militias were arrested and kept in custody.
Three women detained at the time have claimed that during their detention, male guards
subjected them to a body search, touched them inappropriately, and threatened to strip them
naked. They further claimed that they had been detained in an underground cell in a detention
facility staffed entirely by men. According to them, the facility housed persons detained on
criminal charges as well as those under administrative arrest. Among other things, they also
claimed that: they were only fed twice a day; the heating system was turned off, despite almost
freezing temperatures at night; there was inadequate light and ventilation; other prisoners and
male staff could watch them use toilet; ad, they were frequently subjected to humiliating
comments .
As a KAF unit was approaching Corti, it came under heavy fire and shelling. The unit returned
fire from tanks and artillery units. The fighting intensified in the next days and eventually the
KAF unit with the assistance of KESA forces managed to take full control of Corti and nearby
villages after ten days. It was reported that more than 200 civilians were killed or injured during
the offensive. Official statements by both Colonel Jones and the KAF stated some of the reported
casualties were members of dissident armed forces and DNA militias members who had taken
up arms. Important caches of weapons were discovered by KAF in some of the apartments and
buildings in Corti, which prompted the arrest for interrogation of a large number of persons.
Upon the taking of the town, able-bodied men and women of Drak ethnicity were routinely
rounded up, interrogated and interned in the prison and in a school transformed into temporary
detention facilities. Within a few days, more than two thousand persons whom the KAF and
KESA believe to have some association with or to be otherwise supporters of the DNA militias
were detained. Many of the former detainees gave evidence of severe overcrowding. The
detention facilities were directly under the authority of the KAF but operated by KESA officers
who were charged of interrogating suspects .
Mistreatment of detainees, was later reported in newspaper and the media following the release
of a report by Womens Rights Watch of October 2010. The report highlighted various

testimonies about mistreatment of detainees in Argus and Corti including the testimonies of the
three victims mentioned above .
In addition to the prison and the school known to be places of detention, several locations,
including warehouses, abandoned buildings and underground storage areas were used as makeshift detention centres. An NGO reported that torture was prevalent in those places operated by
KESA where victims were interrogated before being sent to the known places of detention. A
victim testified he was subjected to severe beatings during his interrogation at one of those
unidentified location before being transferred to the prison facility.
On the internal front, support for the government actions in West Drakonia was decreasing
among the Katoland population and both the President and Colonel Jones felt that control over
the whole region of West Drakonia, including Mesto, had to be rapidly established in order to
maintain popular support for the President and his government.
Mestos electric power is supplied by a large power station that lies across the border in East
Drakonia, a remnant of the power production and distribution before the independence of
Katoland. The Bargo station supplies electricity to the towns and villages in East Drakonia
including the FRB military base in Bargo, as well as Mesto and its surroundings. There is an
airfield adjoining the military bas. An estimated 8,000 troops are stationed. The military base is
located 10 km away from the border. The station provides power for an area straddling East and
West Drakonia comprising more than 150 000 households.
On December 5th, it was reported that the power plant's computer network system was attacked
which resulted the complete shutdown of the station which resulted in massive disruptions of
power supply in the affected areas. It took six weeks to re-establish the power grid.
The Bargo military installations were partly crippled, in particular the airfield control system.
Morover, the shutdown of the station severely affected the electricity and water supply of Mesto
and residential areas in East Drakonia. Given the harsh climatic conditions at that time of the
year, it is reported that the situation resulted in nearly 500 hundred civilian deaths. Attacks on

West Drakonian, East Drakonian and FRB governmental, commercial and banking websites
were also reported, causing disruptions to essential public services.
Evidence and information sustain widespread beliefs that the NCC was behind the cyber-attacks,
in retaliation to the earlier attacks against Katolands network in December 2009. The
coordination of the attacks, as well as their timing just a few days after the offensive on Mesto
had started were seen as evidence that the Katoland Council had either contracted out some
organization to carry the cyber-attacks or had provided information to existing networks in order
to enable the coordination of the cyber-attacks. Some also alleged that the Head of KESA had
closed ties with organized crime syndicates specialising on electronic fraud.
On December 6th, the FRB President declared publicly that the attacks on the power station
amounted to an "act of war". The FRB government claimed that the Katoland government was
responsible for the attacks and indicated that it would take all necessary measures to ensure the
protection of its population. On the following day, it referred the situation to the International
Criminal Court under Article 14 of the ICC Statute.
The consequences of the shutdown of the power station brought popular support of the Katoland
Presidency to an all times low and voices raising the resignation of President Stark and his
government. Facing the prospect of impeachment, the President resigned on January 15th. As
provided in the Katoland Constitution, the Vice-President, assuming the presidential function,
dissolved the current government and appointed a new interim Prime Minister. The new cabinet
composed of representatives from opposition parties and new political figures, also included
representatives from West Drakonia.
On June 15th, Colonel Jones was indicted by the ICC prosecutor. The new Katoland government
surrendered Colonel Jones to Court. The Director of Prosecutions of Katoland notified the Court
that Katoland relinquished its jurisdiction over the case as allowed under the national ICC Act.

THE PROSECUTION UNTO THIS HONORABLE COURT, RESPECTFULLY SUBMITS

THE FOLLOWING DISPUTATIONS:

I.

THE EXISTENCE OF ARMED CONFLICT

1.

Non Internationalized Armed Conflict between DAF and KAF began on 1st

September 2010 when shootouts increased to large-scale clashes and resulting to heavy
casualties.
An armed conflict exists whenever there is protracted armed violence between
governmental authorities and organized armed groups or between such groups within the
state.1 It is distinguished from any other kind of disturbances by the level of intensity of
the conflict and the degree of organization of the parties.2
1.1

Intensity of conflict
Intensity is determined by the following factors: seriousness of attacks, spread over
territory, period of time, extent of government, forces, mobilization, and the distribution
of weapons.3 Intense attacks re-instated the 2003 Emergency Proclamation.4 With the
spreading of intense attacks over main towns and villages of West Drakonia,5 tanks and
artillery were used.6 Hence, the requirements of NIAC were satisfied.

Prosecutor vs Tadic (Decision) (1995 Appeals Chamber),IT-9401-AR72, [70].

ICTY, Delalic Trial Judgment, para. 184.
3
ICC, Lubanga Judgment, para. 538.
4
Moot Problem, para.25.
5
Ibid., paras. 26, 32.
6
Ibid.,para. 24.
2

1.2

Requisite organization.7
Organisationis determined by factors such as issuance of political statements, military
equipment availability, the groups ability to plan military operations and level of
military involvement.8
KAF is the governmental forces, high contracting party, and DNA is able to arm itself,
issue political statements, held elections, and establish a Drakonian Democratic
Republic.9 The DNA militias used artillery, tanks, mortars and grenades launchers.10 To
restore peace, Katoland security forces were deployed.11

2. International Armed Conflict (IAC) commenced between Katoland and the FRB on
December 24, 2010.
IAC is defined as armed conflicts which may arise between two or more of the High
Contracting Parties.12
2.1 The Cyber-attack was associated with an international armed conflict.
An armed conflict is international if it takes place between two or more states13. As a
result of the cyber-attack an international armed conflict arose exclusively between FRB
and Katoland. KESA knew of its importance to the FRB military and to East and West
Drakonia. KESA anticipated that its shutdown would weaken FRB military presence and
influence in Katoland.

Pros. Vs Tadic (Judgment) (1997 Trial Chamber), IT-94-1-T, [562].

ICT, Limaj Trial Judgment, para. 90.
9
Moot Problem, para. 8.
10
Ibid., para 24.
11
Ibid., para 33.
12
Four Geneva Conventions, Common Article 2.
13
Prosecutor vs. Tadic (judgment) (1999 appeal)
8

II.

COLONEL CALLEY JONES BEARS THE CRIMINAL RESPONSIBILITY FOR

THE WAR CRIME OF VIOLENCE TO LIFE AND PERSON, IN PARTICULAR

CRUEL TREATMENT AND TORTURE

1. KAF and KESA inflicted severe physical and mental sufferings to the detainees.
Beatings during questioning and the detention of persons in inhumane conditions
are enumerated by the UNHRC

14

as instances of severe sufferings.15 Severe

beatings16 and being confined in cramped or overcrowded facilities and deprived of

sufficient food and water17 were delineated in Tadic case and Blastic case, as cruel
treatment. In the instant case, treatment in detention facilities operated by KESA,
were comparable with the foregoing instances. Moreover, three women detained were
subject to inappropriate touch, humiliating comments and embarrassing situations,
without consideration due to their sex. In all manner and respect, these constitute
severe mental sufferings.
2. The detainees in Argus and Corti were hors de combat.
The victims of severe physical and mental suffering were in hand of KAF and KESA
by detention, and they have lost ability to take part in the hostilities. Hence, these
people in hand of an adverse party were hors de combat18.
3. The conduct took place in the milieu of and was associated with NIAC.
It has been established in the Kunarac case, the association with NIAC exists when
acts are closely related to19, or in furtherance of the armed conflict. The people
detained were believed to either have association with or supports of the DNA

14

United Nations Human Rights Committee

Aydin v. Turkey, Report of Judgements and decisions, ECtHR, 1997-VI, (84); Greek case, Yearbook of the
convention on Human Rights, ECiHR, p, 461.
16
Moot Problem
17
Prosecutor vs. Blastik (Judgment) (2000 Trial Chamber)
18
AP I, Article 41
19
Prosecutor v. Kunarac (Judgement) (2002 Appeals Chamber)
15

militias20. The arrest of the said people was to; for all intents and purposes, facilitate
the reinforcement of the conflict.
4. The third and fifth elements of this crime are also present.
KAF and KESA very much knew that detainees were under the safeguard of the
Conventions. Moreover, they were also aware of the existence of an armed conflict,
as proven by the attacks in Corti and nearby villages which have immediately
intensified and lasted for more than ten (10) days21.
5. In contrast with cruel treatment, the establishment of torture requires the
purpose of the perpetrator to inflict such pain or suffering22.
The victim was subjugated to severe beatings during his interrogation. Torture was
widespread in those places operated by KESA where victims were interrogated. It
could be inferred from the above mentioned circumstances that the purpose is to
obtain information or a confession.

III.

COLONEL JONES IS GUILTY OF THE WAR CRIME OF INTENTIONALLY

DIRECTING ATTACKS AGAINST MEDICAL TRANSPORT AND PERSONNEL

USING THE DISTINCTIVE EMBLEMS OF THE GENEVA CONVENTIONS IN
CONFORMITY WITH THE INTERNATIONAL LAW.
1. KAF is guilty of committing the crime of attack against medical transport.
1.1 Medical Transports were attacked by KAF. In accordance with Military Manuals,
medical transports must not be attacked or their passage arbitrarily obstructed23. Such

20

Facts
Facts
22
ICCSt, Article 8(2)(c)(i)-4, Element 2
23
Military Manuals of Germany, South Africa and Switzerland
21

medical transports shall be presumed not to be used for military purposes24 even if they
are suspected to be used as such. The facts stated that KAF members immobilized and
confiscated emergency vehicles, hindering access to medical attention of the persons in
need. In consequence, 5 persons died in the vehicles and some died while arrested and
detained in the prison facility.25 This arbitrary inspection constitutes attack under the
consequence-based approach.
1.2 The attack was intended under the instruction. Based on the facts, a new
instruction from the central command came out ordering the search of all medical
vehicles thoroughly and specified identity checks of all persons in them.26 KAF
members especially stopped and searched the medical transports using distinctive
emblems, intending them as the object of the attack under such instruction.
1.3 The conduct took place in the context of and was associated with NIAC.
According to Kunarac Appeals Chamber for ICTY, it emphasized that the nexus of
the commitment with NIAC required the act to serve the ultimate goal of a military
campaign; and committed as part of or in the context of the perpetrators official
duties.27 The search made by KAF of the medical transports was done under
instruction as their official duty. The prevention of transporting armed men and
ammunition will obviously help Katoland get a better control over Drak, which in
result serves the ultimate goal of the conflict.
1.4 The 4th element of the crime is also fulfilled. KAF was aware of the connection
between its action with NIAC, as well as its knowledge of the sporadic violence such
as the firing from the ambulance, associating with a NIAC. Such is evidenced by the
fact that KAF controlled Corti by heavy fire and that it closed the town and
implemented the later instruction to search ammunition and prevent military action of
DNA.

24

AP I, Article 52(3)
Facts (35)
26
Facts (34)
27
Kunarac, (59)
25

2. Jones should be held responsible for the individual crime of inducing the commission of
such a crime.
The legal definition of inducing is to affect, cause, and influence an act or course of
conduct, lead by persuasion or reasoning.28 As stated in the facts, Jones was in charge of
KAF with the full authority over West Drakonia by military means if necessary.29 His
intention of inducing the crime was held manifested by the fact that he welcomed the
assistance of security forces under the Ministry of Internal Affairs30 and that he was in a
position of authority to convince another to commit an offense.31

IV. WAR CRIME OF LAUNCHING AN ATTACK CAUSING EXCESSIVE INJURY OR

DAMAGE IN RELATION TO OVERALL MILITARY ADVANTAGE ANTICIPATED.

1. KESA, under Jones supervision, launched the cyber-attack on the bargo station.
An attack requires acts of violence.32 The Geneva Conference, by way of Martens
Clause, it is possible to agree that the Law on Armed Conflict applies to new means and
methods of warfare i.e. cyber-attacks33. ICRC notes, cyber operations that result in
physical damage to persons, or damage to object that goes beyond the computer program
or data attacked could be qualified as acts of violence in the sense of IHL.34 KESA was
charged to seek means of retaliation for the cyber-attacks on KNA and KNR. When Jones

28

Blacks Law Dictionary, 9th, edn., 2009.

Facts, (20)
30
Facts, (25)
31
Prosecutor v. Krstic (Judgement) (2001 Trial Chamber) IT-98-33-T [601]; Prosecutor v. Akayesu (Judgement)
(1998 Trial Chamber) ICTR-96-4-T, [483] (Akayesu)
32
AP I, Article 49(1)
33
ICRC Conference, November 2009, 60 years of Geneva Conventions and Decades Ahead
34
ICRC, 31ST International Conference of the Red Cross and Red Crescent, IHL and the challenges of the
Contemporary Armed Conflicts, Reports 31 IC/11/5.1.2, 2011.
29

welcomed KESA assistance in devising a strategy to reestablish control, the latter had
already built ties with organized crime syndicates specializing in Electronic Fraud.
2. The cyber-attack caused incidental loss of life or damage to civilian object, clearly
excessive in relation to concrete and direct overall military advantage.
Military advantage must be substantial and relatively close in weakening the enemy
armed forces after considering military operations strategically as a whole35. The Cyberattack weakening FRB military at Bargo and use of the airfield diminishes FRB influence
over West Drakonia. Incidental is the collateral outcome to civilians or civilian objects
in attacking military objectives. It is prohibited to attack, destroy, remove or render
useless object indispensable to the survival of the civilian population36 . The Cyber-attack
reduced the electricity and water supply sustaining more than 150,000 households. The
disruption continued over 6 months resulting to 500 civilian deaths. The cyber-attack is
disproportionate and clearly excessive to the anticipated military advantage.

3. NCC knew that the attack would cause excessive damage.

The mental state may be deducted from the circumstances37. Even before Katoland
Independence, the Bargo station had been vital in supplying electricity to towns and
villages, such fact could easily come to NCCs knowledge and can be expected to result
to excessive injury or damage if attacked.

4. Jones bears individual criminal responsibility for contributing to this crime

An accused will incur individual criminal responsibility for aiding and abetting a crime
under Article 7(1) where it is demonstrated that the accused carried out an act which

35

International legal material Reports, 31 I.L.M.612(1992).

AP I, Article 54
37
Prosecutor vs. Aleksovski Case No. IT-95-14/1-A-ICTY
36

consisted of practical assistance, encouragement or moral support to the principal

offender38.
Jones intent to launch the cyber-attack manifested from the fact he proposed supervision
and full military authority over West Drakonia and welcomed assistance of KESA. Proof
that the conduct of the aider and abettor had a causal effect on the act of principal
perpetrator is not required39.

38
39

Prosecutor vs. Valsilijevic Judgment Case No. IT 98-32-T ICTY, November 29, 2002
Prosecutor vs. Blastik IT-95-14, March 3, 2001.

PRAYER
The Prosecution submits that it has been proved beyond reasonable doubt that Calley Jones is
criminally responsible for three crimes under the Rome Statute. The Prosecution respectfully
requests this Honorable Court to adjudge and declare that Calley Jones is guilty on all charges.

RESPECTFULLY SUBMITTED,
Counsel for the Prosecution