On day of February 28 2014, Mrs. Kanevcev Nives, head attorney for Attorney’s Office of Canton Sarajevo, received a criminal complaint against: Efendic Semir, Mayor of Municipality Novi Grad Sarajevo, Smajic Muhamed, former manager of Public Enterprise for Managing, Protecting and Maintaining Facilities owned by Municipality Novi Grad Sarajevo “Lokum” Ltd. Sarajevo, Durakovic Ramiz, newly appointed Manager of Public Enterprise for Managing, Protecting and Maintaining Facilities owned by Municipality Novi Grad Sarajevo “Lokum” Ltd. Sarajevo, Sukalo Amil, acting manager of Public Enterprise for Managing, Protecting and Maintaining Facilities owned by Municipality Novi Grad Sarajevo “Lokum” Ltd. Sarajevo, Mrkulic Mustafa, D.V.M – veterinarian in Public Enterprise Veterinarian Station “Stup”, Kazazovic Jasmin, D.V.M. – Manager of Canton’s Public Enterpise “Veterinarian Station” L.t.d., Ismo Edin, worker – dog-catcher in “hygiene service” P. E. Lokom, several unknown persons – dog-catchers working with P.E. “Lokom” L.t.d. Novi Grad Sarajevo. In addition to the criminal complaint, a number of material evidence was presented, including documents, photographs, video recordings and names of eye witnesses confirming the allegations stated in the criminal complaint.
Excerpt from the criminal complaint:
Public enterprise for managing, protecting and maintaining facilities, “Lokum” Ltd. Sarajevo, is a legal entity owned by Municipality Novi Grad and is documented in the court registry under the registration number 65 – 01 – 1535 – 09.
On May 30 2013, as a component of P. E. “Lokum,” the “hygiene service” started its operation. In accordance with regulations of Article 29 (Hygiene Service) of the Animal Protection and Welfare Act of B&H, hygiene service’s function is to have its employees gather abandoned and lost animals in a manner that causes them the least amount of pain and suffering, and hand them over to animal shelters. In Federation B&H, an official operational code for hygiene services does not exist, which is clear from the current court registry brief for P. E. “Lokum”, demonstrating that P. E. “Lokum” is not registered to perform activities of hygiene service.
Establishment of the so-called hygiene service as a part of P. E. “Lokom” was done under the initiative and patronage of the primary-accused Efendic Semir, Mayor of the Municipality Novi Grad Sarajevo, who is also the founder of P. E. “Lokom”.
Management and supervision of “hygiene service” operations within P. E. “Lokom” was performed by the secondary-accused, former Manager of P. E. “Lokom,” Smajic Muhamed, and third-accused, newly appointed Manager of P. E. “Lokom,” Durakovic Ramiz, and fourth-accused Sukamlo Amil, acting Manager of P. E. “Lokom”, who also performed financial control and financing of the “hygiene service” operations.
The budget for 2013 of Municipality Novi Grad included a planned transfer under ec, code 614400 for P.E. “Lokom” in the amount of 300,000 KM. These funds are planned for, in part, financing “hygiene service” operations (around 30,000 KM). Considering P. E. “Lokom” is not registered to perform the activities of hygiene service, it is clear that budget funds are allocated for paying fictitious activities and that this is a question of criminal activity of embezzlement committed in public office and the abuse of office.
The purpose of hygiene service is to have its employees gather abandoned and lost animals in a manner that causes the animals the least amount of pain and suffering, and hand them over to animal shelters (there are no legally established and regulated animal shelters in Canton Sarajevo). Hygiene service was formed with the goal of caring for abandoned animals, and not house pets (Article 29 Hygiene Service of the Animal Protection and Welfare Act). House pets belong to the category of animals that have owners and are in possession of their owners. Abandoned animals have no owners and municipalities have legal responsibility to take care of them; from this follows that the difference in activities between taking care for house pets and abandoned animals is an essential one, because all transportation and housing services for house pets are paid for by their owners, while transportation and housing services for abandoned animals are paid for by the public budget funds.
Also, on November 25, 2013, under the F B&H Freedom of Access to Information Act, I requested from the General Management and Municipality Services for Economy, Finances and Inspections of Municipality Novi Grad to provide me with the following documents and information:
1) Budget of Municipality Novi Grad Sarajevo for the year 2013
2) Report on implementation of the Municipality Novi Grad Sarajevo budget for 2013
3) Information on whether the Municipality Novi Grad has issued a work permit for “hygiene service” of P. E. “Lokum” Novi Grad and, and if so, to provide a copy of the permit
4) Invoices delivered by the time of reception of this request to Municipality Novi Grad by P. E. “Lokom” Novi Grad for financing the needs of “hygiene service”.
I received an answer dated January 6th 2014 and sent on January 8th, stating that the budget of Municipality Novi Grad can be found in the Gazette of Canton Sarajevo, and that I should contact P. E. “Lokom” Novi Grad Sarajevo regarding the work permit and invoices delivered to Municipality Novi Grad for the purposes of funding the “hygiene service”. By breaking the Freedom of Access to Information Act of F B&H and refusing to provide requested information, Municipality services have clearly demonstrated that they are hiding the requested documents (Our suspicion that they do not have the requested documents, especially the work permit for hygiene service, has been justified). (A copy of their response has been submitted as evidence).
Since the “hygiene service” under P. E. “Lokom” was founded, the mentioned “hygiene service” has failed to meet the criteria prescribed by the Animal Protection and Welfare Act B&H or stipulations of the Rulebook on the Establishment and Regulations for hygiene services in B&H. Primarily, “hygiene service” does not have a work permit, a required document, prescribed by the Legal Entities Act of F B&H. Financing of this illegal “creation and its operation” is financed from the budget funds – tax payers’ money.
Since the day of foundation of “hygiene service” as a part of P. E. “Lokom,” there have been many irregularities in the operation of “hygiene service” indicating that the hygiene service serves as a front for extracting budget funds. Illegal activities can be seen by the fact that abandoned animals caught by the “hygiene service” workers have been disappearing under suspicious circumstances, and the hygiene service is catching abandoned dogs without any order and it acts based on citizen reports for which they have neither legal foundation or required capacity to undertake such activities. Based on statements by the hygiene service workers, dogs are taken to the abandoned animal shelter in Gladno Polje or to Canton’s Public Enterprise “Veterinary Station” – infirmary ‘Stup.’ The fact is that a certain number of dogs are being taken to ‘abandoned animals shelter’ in Gladno Polje, which is also operating illegally and whose work and financing will be the subject of another criminal complaint. The number of dogs brought to the ‘Gladno Polje’ shelter by the hygiene services workers is minuscule, while it is estimated that hundreds of abandoned dogs have disappeared from the city of Sarajevo since the the hygiene service of P. E. “Lokom” was established, and because the “hygiene service” operates outside of the boundaries of Municipality Novi Grad Sarajevo. Furthermore, workers of “hygiene service” have not been taking dogs to the “shelter” in Gladno Polje since January 1st 2014.
P. E. “Lokom” is also failing to provide reports based on their records of the number of abandoned dogs that are caught which they are legally required to track. Based on the stated situation and a great number of abandoned dogs that have gone missing were last seen being caught by the “hygiene service” workers of P. E. “Lokom”, there is a reasonable doubt that criminal activity of Torturing and Killing Animals (Article 318, Item 2 of Penal Law of F B&H) is being conducted. Sukalo Amil, Acting Manager of P. E. “Lokom” Novi Grad had repeatedly confirmed to the media that “hygiene service” was performing “cleaning of the area” from abandoned dogs and that many of them are being taken to Canton’s Public Enterprise “Veterinarian Station” – infirmary “Stup” for veterinarian processing. (Texts from the media can be found in the attachment of the criminal complaint). Majority of dogs that have disappeared from the area of Municipality of Novi Grad Sarajevo and other Sarajevo’s municipalities since the formation of “hygiene service” had previously been processed by veterinarians (castrated / sterilized, vaccinated and marked with numbers). According to my findings, Mrkulic Mustafa, veterinarian work for the veterinarian station “Stup” performs illegal euthanasia of abandoned animals – kills abandoned animals for his personal gain. Since euthanasia of abandoned animals without medical cause established by an authorized official veterinarian represents murder of an animal with intent, and in order to make financial gain, Mrkulic Mustafa has been repeatedly in violation of Act 318 Item 2 (Torturing and Killing Animals) of Penal Law of F B&H. Mrkulic Mustafa, as a guest in a talk-show “Zabranjeni forum”, aired on TV “Pink” B&H on December 12th 2013 at 22:00 h, admitted that he cooperates with hygiene service P. E. “Lokom” Novi Grad and that he continues to perform euthanasia of dogs.
In the period since formation of “hygiene service” until today, during which a great number of abandoned dogs have disappeared, invoices for provided services are being sent to the Municipality Novi Grad. Also, hygiene service P. E. “Lokom” has expanded its operation to other municipalities of City Sarajevo. Edin, Ismo and an unknown person are catching and taking dogs away in vehicles model Skoda (license plate number E83 – E – 276) and Mazda (license plate number T82 – O – 623)
When reporting different criminal activities citizens have repeatedly been met by clear obstructions from police officers, and especially police officers employed by Police Station Novi Grad Sarajevo. On these occasions police officers refused to come to the scene and determine circumstance of the events, make official record and a standardized police report, call official authorized persons from the Criminal Police, notify an attorney on duty, hence they violated a series of F B&H Penal Law regulations, Official Authorized Personnel of MIA (Ministry of Internal Affairs) CS Conduct Rulebook, Disciplinary Responsibility of Members of MIA CS Rulebook.
The pattern of criminal activity is clear here: “hygiene service” of P. E. “Lokom” catches abandoned dogs and then takes them to be killed in C. P. E. “Veterinary Station” – infirmary “Stup”. P. E. “Lokom”, which is financed from the budget of Municipality Novo Sarajevo invoices catching of abandoned dogs through formally and legally non-existent hygiene service, and C. P. E. “Veterinary Station” invoices non-existent veterinary processing (in the meantime, dogs are not being processed by a veterinarian, but killed). All illegal activities are followed and documented, and signed by the primary accused, secondary accused, third accused, fifth accused, sixth accused, while Ismo Edin and seventh accused provide “logistic support”. Budget funds paid for financing illegal activities cannot be shown in financial documents, since the foundation for its payment is illegal activity, which clearly indicates that persons named as perpetrators of criminal activities in this complaint use the budget funds for their own, personal goals.
Since “hygiene service” still operates on the major part of Canton Sarajevo’s territory, in this way I demand answers to the following:
1. Why hasn’t Attorney’s Office of Canton Sarajevo performed activities prescribed by the Penal Law of F B&H that would result in prevention of further killings of abandoned animals and stealing of budget funds, e.g. result in prevention of prolonged perpetration of criminal activity?
2. Why didn’t Police Commissary of Canton Sarajevo and the Minister of Internal Affairs of Canton Sarajevo react to letters about evident complicity of police officers (for which there is material evidence) with reported persons and clear obstruction of all police stations in City Sarajevo to document citizens’ allegations about organized crime?
3. Why hasn’t Inga Dujmovic, State Inspector for Animal Welfare in the Veterinary Office of B&H responded to any inquires about why she had not acted in accordance with regulations of the Animal Protection and Welfare Act of B&H and checked the allegations from the reports about cruelties and operation of “hygiene service”?
4. Why Ljubomir Kalaba, Head of Veterinary Office in B&H, does not answer to inquiries about not respecting the laws by the inspectors of the Veterinary Office.
5. Why do councilmen in the Municipality Council of Novi Grad Sarajevo keep quiet about organized crime conducted under disguise of “hygiene service”?
6. Why Ivo Komsic, Mayor of Sarajevo, does not react to evident criminal activities conducted under disguise of “hygiene service”?
7. Why do the media keep quiet about the crimes conducted through the “hygiene service”?
Citizens need to know that any form of helping the “workers of hygiene service” represents complicity in series of criminal activities and that criminal complaint will be filed against any citizen helping and encouraging illegal catching of dogs.
“If more persons perform a criminal activity together, by participating in perpetration of the criminal activity or doing anything else which helps in decisive way the perpetration of criminal activity, each of them will be punished by the penalty prescribed by law for this criminal activity.” (Act 31 – Accomplice; Penal Law of F B&H)
All new evidence will be delivered to the Cantonal Attorney’s Office of Canton Sarajevo and Federal Police Directive and I expect that actions prescribed by the Penal Law of F B&H will be taken. As long as the passivity of persecution authorities lasts, the budget money will keep disappearing together with abandoned dogs.
I also emphasize that every child and every citizen who have suffered anguish due to witnessing cruelty on abandoned dogs performed on daily basis by workers of the hygiene service, has the right to sue the Municipality Novi Grad Sarajevo, P. E. “Lokom”, Municipality Novi Grad Sarajevo Mayor and the Manager of P. E. “Lokom” L.t.d. as well as the authorized persecution bodies who, by not performing the actions prescribed by law, are contributing to creating the atmosphere that citizens of B&H live in someone’s backyard, where oligarchy does what and how it pleases.
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