The Indictment has been issued against Mladen Ždrale aka ‘Pata’, born on 18 April 1981 in Sarajevo, citizen of BiH, who has been in custody since 05 February 2013.

The suspect Mladen Ždrale is charged with organizing the murder of Milorad Todorović in 2005, together with Boris Govedarica, for reasons known to them, and, in accordance with their previous agreement, they acquired the means for perpetration of this criminal offense and conducted other preparatory activities for the purpose of depriving this person of his life.

On 03/04 November 2005, they stole one passenger motor vehicle and acquired stolen diplomatic license plates which they put on this vehicle, and then rented a garage in the territory of Istočno Sarajevo /East Sarajevo/ where they hid the car; subsequently, they acquired an automatic 7.62 mm rifle and determined the directions in which Milorad Todorović moved and his whereabouts.

As alleged in the Indictment, on 18 November 2005, between 8.30 PM and 9 PM, having carried out all the preparatory activities, Mladen Ždrale and Boris Govedarica went in the aforementioned motor vehicle near a catering facility in the area of Vraca and set an ambush for Milorad Todorović. Boris Govedarica approached that catering facility armed with an automatic rifle, while Mladen Ždrale stayed behind the wheel of the stolen vehicle waiting for Boris Govedarica to kill Milorad Todorović. Boris Govedarica shot a long burst of fire from his automatic rifle through the window of this catering facility, in the direction of the table at which Milorad Todorović was sitting, although several other guests were sitting at the next table.  The pellets hit Milorad Todorović, Radomir Janković, Esad Šenderović and Murat Komarica, and Milorad Todorović, Radomir Janković and Esad Šenderović succumbed instantly to their wounds, whereas Murat Komarica was heavily injured.

Boris Govedarica then entered the vehicle and escaped together with Mladen Ždrale towards Istočno Sarajevo, to the garage prepared beforehand.   

In view of its manner and all the circumstances of its commission, this multiple murder created great anxiety, fear and insecurity among the citizens of Republika Srpska and Federation of Bosnia and Herzegovina, and distrust of citizens in the institutions of power authorized to ensure protection and safety of citizens.

The accused Mladen Ždrale is suspected of participating as a co-perpetrator in taking the lives of several other persons and thus endangering the security of several other persons, which, in view of the manner of the commission of this crime, created anxiety, fear and insecurity among the citizens of Bosnia and Herzegovina, and serious adverse effects outside the entities of Republika Srpska and Federation of BiH, as well as serious repercussions and detrimental consequences for Bosnia and Herzegovina due to the damaging of the reputation of Bosnia and Herzegovina in international community, which is classed among the countries with high security risk because of the crimes like these; thereby, he committed the criminal offense of Murder, as referred to in Article 166, Paragraph 2, of the Criminal Code of the Federation of Bosnia and Herzegovina, the criminal offense of Provoking General Danger, as referred to in Article 323, Paragraph 3, of the Criminal Code of the Federation of Bosnia and Herzegovina, as read with Article 31, all in conjunction with Article 53 of the Criminal Code of the Federation of Bosnia and Herzegovina.

The Indictment was forwarded to the Court of BiH for confirmation.