Vatican Bank Sued For Alleged War Crimes

In apparently the first
legal action of its kind, the Vatican Bank has been sued by World War Two
victims and their heirs and beneficiaries. Brought as a class action in the
U.S. District Court in San Francisco, the initial plaintiffs are Ukranians and
ex-Soviet citizens but the affected class includes Serbians, Roma, anti-Fascist
Croatians, and Jews.

The suit seeks “an
accounting, restitution, disgorgement and to recover damages arising out of
defendant VATICAN BANK (hereinafter referred to as IOR[Instituto Per Le Opere
Di Religione,Institute for Religious Works]), the FRANCISCAN ORDER, and other
banking institutions’ and religious orders and organizations participation in a
common scheme and course of conduct:

“(1) to profit from,
both directly and indirectly, the inhumane and genocidal system instituted by
the Nazi and Ustasha ideology;

“(2) to obtain,
accept, conceal, convert and profit from assets looted by the Ustasha Regime
and deposited in, or liquidated through, the IOR, Defendant Banks, and
Franciscan organization during the ascendency of the Ustasha regime and
following the demise of the regime at the behest of former Ustasha and Nazi
leaders through the offices of the Franciscan Order; and

“(3) to retain and
convert assets deposited in their institutions by the Ustasha and the
Franciscan Order.” The suit uses the definition: “The ‘Ustasha
Regime’ is defined as the German puppet fascist government of Croatia under the
direction of its leader Ante Pavelic known as the ‘Poglavnik’ (Leader). The
Ustasha regime operated under German protectorate from 1941 through 1945 and
included numerous members of the Franciscan Order as both military and civil
functionaries”.

The Court papers state
“Among the top Nazi beneficiaries of the Croatian-Vatican treasure was
Adolph Eichmann who received a new identity as a ‘Croatian refugee’ before
being smuggled to South America.”

The suit points out
“Evidence of the extent of the defendant’s participation in wrongdoing has
only recently come to light as a result of the disclosure and declassification
of archived documents in the United States, Great Britain, Germany and other
countries, as well as from the reports of several commissions and/or task
forces created by the United States, Germany, and elsewhere and in particular
the 1997 Supplemental Report by the United States State Department: U.S. and
Allied Efforts to Recover and Restore Gold and Other Assets Stolen or Hidden by
Germany During World War II,’The Fate of the Wartime Ustasha Treasury’ released
under the auspices of Under Secretary of State Stuart E. Eizenstat.”

Among the fourteen pages
of details in the Court pleadings, “Vatican Bank…has its principal place
of business and is incorporated in Vatican City but conducts business and
financial transactions worldwide on behalf of the Roman Catholic Church including
the United States and California with total assets in excess of 3 billion
dollars. Defendant IOR engages in for-profit merchant banking transactions in
the United States, California, and elsewhere through its investments and
transactions with other banks. Defendant Franciscan Order also known as First
Order of Franciscans (O.F.M.) includes and/or included several Croatian
Franciscan Orders in California, the United States, Croatia, and Italy.”

Other eye-opening details
in the suit include: “Croatian troops assisted the German occupiers of
Ukraine in their systematic plundering and looting of Ukrainian resources and
individual property. In exchange for the Croatian assistance in Ukraine, the
Ustasha were given a free hand in Croatia and Bosnia to loot, plunder and
terrorize the non-Croatian populace. The Croatian Treasury contained plunder
from Ukraine and assets seized from the Ustasha victims in Yugoslavia. Without
the full support of Nazi Germany for its loyal ally, the Ustasha, the Ustasha
Treasury would not have been permitted to retain the profits from Ustasha
atrocities, instead these funds would have been sent to Germany.”

Further, “Upon the
demise of the Ustasha government in 1945, assets valued between 50 and 180
million dollars were transferred from the capital, Zagreb. The majority of
these funds, estimated at more than 80 million dollars were transferred to
Vatican City with the assistance of Roman Catholic clergy and in particular
members of the Franciscan order part of or sympathetic to the Ustasha.”

Moreover, “Many
officials of the Ustasha government, including the war criminals like Pavelic,
were secretly housed by the Franciscan Order in Vatican City or Rome. The
Ustasha Treasury with the assistance of IOR and Franciscans was used to resettle
the Ustasha fugitives in Spain, Argentina, the United States and other
sympathetic countries. The Ustasha were also alleged to have reaped profits in
conjunction with their Franciscan and IOR benefactors by black market
activities in post war Italy, selling Vatican and Red Cross documents to Nazi
war criminals and by acting as informants and provocateurs for various
intelligence services.”

As a class action, the
suit raises common questions of fact and law, including:

“Did the defendant
IOR knowingly or otherwise carry out banking transactions that involved capital
or assets that included looted and plundered assets of victims of the Nazi and
Ustasha Regime deposited with the IOR by the remnants of the Ustasha Regime or
the Franciscan order?

“Did the Defendants
Banks, IOR, or Franciscan Order improperly retain or convert deposited assets
of the plaintiffs to/for their own or another’s use?

“Did the defendants
knowingly aid and profit from the concealment of the Ustasha wartime Treasury?

“Did the defendants
knowingly assist fugitive war criminals from the Nazi and Ustasha regimes by
making available and providing international transfer of funds?”

Among the pleadings
“Facts Specific to IOR and Roman Catholic Religious Orders”:
“Many high officials of the Ustasha government were Roman Catholic clergy
and in particular Franciscans. The Vatican maintained an ‘Apostolic visitor’ in
Zegreb, the Croatian capital from 1941 until the end of the War. Relations
between the Vatican and the Ustasha were cordial. The Papal legate in Croatia
was Mgr. Marcone, who openly blessed the Ustasha, publicly gave the Fascist
salute, and transmitted instructions from Rome to the Croatian clergy and
episcopacy, principally concerning the forced conversions of the Eastern
Orthodox Christians.”

Among the many details of
the complaint: that the former Ustasha Treasury was used post-World War Two to
finance Nazi fugitives in exile. That the Vatican Bank to date “has
refused to account for the Ustasha related transactions despite numerous
inquiriebs from other governments and the London Conference on Nazi Gold.”

Those close to the
pending lawsuit advised us not to attract too much attention to the lawsuit on
TV in Chicago. Why? The apparent reason is the large Pro-Vatican Croatian
community in the Windy City as well as what some contend is a large number of
the Ustasha or their offspring who live in Chicago. In the 1970s, there were
many violent events between the Croat and Serb communities in Chicago,
including shootings and bombings, not well reported outside of town.

A few years ago when we
taped a one hour Cable TV Show on the subject of Bosnia and Serbia, one of the
program guests threatened to leave the studio if I raised the issue of Vatican
complicity in “ethnic cleansing” of Serbs from Croatia, by which many
thousands of Serbs were killed or injured. [Another guest did raise the issue.]
During the Kosovo War, Spring of 1999, the monopoly press said almost nothing
about the bloodshed in Croatia reportedly instigated at least in part, by the
Vatican. It is perhaps no coincidence that the Vatican Bank suit was brought in
San Francisco. Headquartered there is the Bank of America, owned jointly by the
Vatican, the Jesuits, and the Rothschilds. The parent holding company, Bank
America, has been reportedly largely bought out by the Japanese mafia, the
Yakuza. Most every bank in California is reportedly owned by the Yakuza. Seldom
mentioned by the news fakers: the Yakuza is the main force in West Coast dope
trafficking.

A possible problem in the
case getting a fair hearing and trial: Most of the judges in the federal
judiciary in California are banker-judges. Will they arbitrarily protect the
Vatican Bank and other banking institutions implicated in the case? The federal
appeals court in San Francisco is riddled with banker-judges. It is an
unpublicized situation,by the way, throughout the U.S. and throughout the
history of the federal courts in the United States.

Telephone:
707-464-4513

Facsimile:
707-465-5389

Attorneys for
Plaintiffs and the Class

EMIL ALPERIN,
JEWGENIJA ROMANOVA, MARIA DANKEWITSCH, VLADIMIR MORGUNOV, VLADIMIR BRODICH,
WILLIAM DORICH, and IGOR NAJFELD on behalf of themselves and all other persons
similarly situated; ORGANIZATION OF UKRAINIAN ANTIFASCIST RESISTANCE FIGHTERS;
and UKRAINIAN UNION OF NAZI VICTIMS AND PRISONERS, on behalf of themselves and
all others similarly situated,

Plaintiffs,

v.

VATICAN BANK,
a/k/a “INSTITUTE OF RELIGIOUS WORKS” or “ISTITUTO PER LE OPERE
DI RELIGIONE” (IOR); THE FRANCISCAN ORDER (O.F.M..) a/k/a CROATIAN
FRANCISCANS and CROATIAN COFRATERNITY OF THE COLLEGE of SAN GIROLAMO DEGLI
ILLIRICI, UNKNOWN CATHOLIC RELIGIOUS ORDERS, and their successors, UNKNOWN
RECIPIENTS OF NAZI AND USTASHA LOOT, AND SWISS, AUSTRIAN, ARGENTINE, SPANISH,
ITALIAN, PORTUGUESE, VATICAN & GERMAN BANKING INSTITUTIONS AND CALIFORNIA
AND OTHER UNITED STATES CORRESPONDENT BANKS AS DOES #1-100,

Defendants.

NO.
C99-4941 MMC

FIRST
AMENDED CLASS ACTION COMPLAINT FOR:

1.
CONVERSION;

2. UNJUST
ENRICHMENT;

3.
RESTITUTION;

4. AN
ACCOUNTING; and

5. HUMAN
RIGHTS VIOLATIONS

AND
VIOLATIONS OF

INTERNATIONAL
LAW.

JURY TRIAL
DEMANDED

1. This is a
civil action arising under customary international law and the laws of the
United States of America on behalf of named Plaintiffs and a class of all Jews,
Serbians, and former Soviet Union citizens (and their heirs and beneficiaries),
who suffered physical, monetary and/or property losses including slave labor,
due to the systematic and brutal extermination of Jews, Serbians, and Romani by
the Nazi puppet Regime, The Independent State of Croatia (NDH) led by Pavelic’s
Ustasha Regime, and as a result of the occupation of the former Soviet Union by
Croatian military forces in concert with their German occupation forces. This
is an action against the Vatican Bank, Franciscan Order and Unknown Catholic
Religious Orders, and as yet unnamed recipients of Nazi and Ustasha Loot,
Swiss, Austrian, Argentine, Spanish, Italian, Portuguese, and German banking
institutions and California and other United States correspondent banks for
their participation in and benefit from the Ustasha Regime’s acts Orders.

3. Defendants
committed, conspired to commit, and aided and abetted others who committed
crimes against peace, war crimes and crimes against humanity. Defendants
assisted the Ustasha Regime and its leaders as well as prominent Nazis to
successfully evade justice for their genocidal crimes by concealing and making
available the considerable assets of the Ustasha Treasury.

3. Defendants
committed, conspired to commit, and aided and abetted others who committed
crimes against peace, war crimes and crimes against humanity. Defendants
assisted the Ustasha Regime and its leaders as well as prominent Nazis to
successfully evade justice for their genocidal crimes by concealing and making
available the considerable assets of the Ustasha Treasury.

4. Evidence
of the extent of the Defendants’ participation in wrongdoing has only recently
come to light as a result of the disclosure and declassification of archived
documents in the United States, Great Britain, Germany and other countries, as
well as from the reports of several commissions and/or task forces created in
the United States, Germany and elsewhere and in particular the Supplemental
Report of June 2, 1998 by the United States State Department: U.S. and
Allied Efforts To Recover and Restore Gold and Other Assets Stolen or Hidden by
Germany During World War II, “The Fate of the Wartime Ustasha
Treasury,” released under the auspices of Under Secretary of State,
Stuart E. Eizenstat.

5. By the
conclusion of the Second World War, all Defendants were advised by the
international community that the knowing use and benefit from the Ustasha
Treasury, and the knowing looting and plunder of assets and benefits therefrom,
were violations of international law and various codes of criminal conduct. All
Defendants nevertheless improperly retained and concealed illicit profits and
withheld them from their rightful owners. Defendants have unlawfully and
unfairly profited from these practices for more than half a century, thereby
illegally and improperly strengthening their own economic position in
California, the United States, and throughout the world.JURISDICTION AND VENUE

6.
This Court has jurisdiction pursuant to (a) 28 U.S.C. § 1350 in that certain
Plaintiffs are foreign citizens who assert claims for torts in violation of the
law of nations. Upon information and belief, the Franciscans and Unknown
Catholic Religious Orders, with knowledge and support of Vatican
representatives in Croatia and Croatian representatives in the Vatican Bank,
were aware of, participated in and facilitated (a) torture; (b) plunder; (c)
displacement; (d) slave labor; (e) conversion, screening and transfer of
assets; (f) facilitation of escape from justice of the torturers and the assets
plundered, using assets plundered to facilitate escape, secreting and
benefitting from such plunder; and (g) conspiracy to publicly and privately
support and encourage the above-mentioned acts. Further, Defendants may be
found in this District and Plaintiffs are unable to exhaust remedies in the
place where the transaction occurred in that no adequate or available remedies
exist;

(b) 28
U.S.C. § 1331 in that Plaintiffs make claims against Defendants under federal
common law as it incorporates customary international law and international
treaties in that Defendants knowingly used and benefitted from plunder taken
from Plaintiffs by the Ustasha Regime, in violation of international treaties;

(c)
28 U.S.C. §1332 in that the amount in controversy as to each claim asserted and
sought to be asserted herein by certain Plaintiffs exceeds the sum of $75,000,
exclusive of interest and costs and certain Plaintiffs herein are U.S.
residents and thus diverse in state citizenship from Defendants, citizens of
foreign states;

(d)
28 U.S.C. 1605 as to the Vatican Bank, in that (1) at the time of the filing of
this suit, the Vatican, and perhaps institutions and facilities under its
control, was a sovereign; (2) the actions Plaintiffs complain of involve an
activity for which the law provides an exception to sovereign immunity under
1605(a)(3); (3) although the acts complained of occurred prior to 1952 when the
exceptions to sovereign immunity were adopted, because the United States did
not recognize the Vatican as a sovereign prior to 1952, the Vatican could not
have expected immunity for its acts prior to that time; therefore, exercising
jurisdiction would not offend due process principles or the Vatican’s
expectation of immunity; (4) the profits which Defendants have incurred as a
result of their plunder of Plaintiffs’ property have impacted Defendants’
commercial transactions in the United States; and

(e)
28 U.S.C. § 1367 for any claims not otherwise covered by the aforementioned
jurisdictional bases.

7.
Venue is proper in this Court because all Defendants are doing business and may
be found in this District within the meaning of 28 U.S.C. § 1391(b) and/or, as
aliens, may be sued in any district pursuant to 28 U.S.C. §
1391(d).INTRADISTRICT ASSIGNMENT

8.
Venue is proper in this Court pursuant to Code of Civil Procedure § 395 and
Civil Code § 1780(c) because some of the acts and transactions complained of
herein occurred within this county, some of the Class members are residents of
this county and, upon information and belief, Defendant IOR does business, owns
property in this county and functions as a merchant offshore bank and does
business with correspondent banks in California.

PARTIES9.
Plaintiff Emil Alperin was born June 3, 1922. Prior to the German invasion of
Ukraine, he resided in Odessa, Ukraine at 63 Sverdlova Street, Apt. 11. Germans
and allied Fascists believed to be Croatians looted and destroyed all the
household belongings and personal property of Alperin. Plaintiff was held
prisoner at Buchenwald Concentration Camp from March 1944 until April 1945
where he was prisoner #34646. He currently resides in Kharkov, Ukraine. Emil
Alperin is Jewish.

10.
Plaintiff Jewgenija Romanova, formerly Petruchina, was born December 7, 1927.
Before the German occupation, she resided in Nikolayev, Ukraine at 13
Kolodeznaya Street. Germans and allied Fascists, believed to be Croatians,
looted and destroyed all the household belongings and personal property of
Romanova. Romanova was held prisoner at Ravensbruck Concentration Camp from
March 1944 until April 1945 where she was prisoner #33543. Romanova currently
resides in Kharkov, Ukraine.

11.
Plaintiff Maria Dankewitsch was born January 29, 1922. Before the German
occupation, she resided in Sevastopol, Ukraine in the Fudolf District. Germans
and allied Fascists believed to be Croatians looted and destroyed all the
household belongings and personal property of Dankewitsch. Dankewitsch was held
prisoner at Ravensbruck Concentration Camp from February 1943 until May 1945
where she was prisoner #17406. Dankewitsch currently resides in Kiev, Ukraine.

12.
Plaintiff Vladimir Morgunov was born September 2, 1925. Before the German
occupation, he resided in Mariupol, Ukraine in the 75 Kotovskoogo Street.
Germans and allied Fascists believed to be Croatians looted and destroyed all
the household belongings and personal property of Morgunov. Morgunov was held
prisoner at Buchenwald Concentration Camp from March 1943 until April 1945
where he was prisoner #13341. Morgunov’s current address is in Kiev.

13.
Plaintiff Vladimir Brodich was born March 1, 1931 in the Kingdom of Yugoslavia.
As a young Serbian Orthodox boy, Vladimir resided in the town of Kostajnica,
Krajina. In April 1941 a German officer came to his home, because both of his
parents were fluent in German (his father having lived in Austria and his
mother having received her high school education in Salzburg, Austria). The
officer showed them photographs of Ustasha atrocities, warning them that they
should leave immediately for Belgrade beyond the reach of the Ustasha. The
German officer prepared documents for the escape of the whole family.
Unfortunately, the town mayor persuaded his father to stay. In August 1941 the
Ustasha took away his father Nickola, his 24 year old brother Dragomir, and his
older sister to a detention center. Vladimir’s father and brother were
tortured, then murdered. Before their death, his father asked to embrace his
son, and thus they were shot together. Five years later, their bodies were
exhumed and identified because still embracing one another. At the detention
center Vladimir’s sister was gang raped by Ustasha; she only survived by the efforts
of a Chetnik partisan (who was later captured, tortured, and thrown alive into
an oven to die by the Ustasha), and died in 1997 without being able to bear
children. Vladimir and his mother survived by escaping to Belgrade. Vladimir’s
family lost their two homes, and because Vladimir’s bother was so wealthy, it
took the Ustasha more than two years to auction all of his murdered brother’s
property. Vladimir came to the United States in 1949, is the only surviving
heir to the family property, and currently resides in Arizona.

14.
Plaintiff, William Dorich was born July 17, 1939 in West Virginia. Plaintiff’s
father, Samuel Todorovic Sr., came to the United States at the end of WWI as a
“displaced person,” (along with plaintiff’s brother George and their
parents) from the village of Vojnic in the Krajina region, having been
“ethnically cleansed” by Croatians who sided with Germany in WWI.
Upon becoming a naturalized citizen Samuel Todorovic Sr., changed the family
name to Dorich just prior to the birth of his two sons, Samuel Jr., and
William. During WWII, the Ustasha burned to death 45 Serbian victims in the
Orthodox Serbian church in the village of Vojnic, of which 17 victims were
relatives of the Dorich family. Plaintiff has spent his lifetime speaking out
against the Ustasha and is the author of numerous books on the Balkans. The
only member of plaintiff’s family still alive is his 83 year-old
Serbian-American mother, Mary Savage Dorich. Plaintiff resides in California.

15.
Plaintiff Igor Najfeld was born June 28, 1944 in Yugoslavia, on the day that
his mother, a Yugoslavian Jewish physician, and father, a Polish Jewish
physician, escaped from years of slave labor by the Ustasha Regime beginning in
1941. Plaintiff’s parents had been living in Zagreb on April 10, 1941 when the
Nazi’s invaded Yugoslavia, but by December 1941 the Ustasha Regime had
imprisoned plaintiff’s parents as slave laborers in Bosnia. Plaintiff’s
grandmother had a department store in Slavonskibrod that was looted by the
Ustasha. At least 56 of plaintiff’s mother’s relatives were killed by the
Ustasha, many of whom perished in the Jasenovac Concentration Camp. Many of
plaintiff’s relatives were prosperous and all lost property to the Ustasha
looting. Plaintiff grew up in Yugoslavia and eventually emigrated to the United
States, where he now resides in Vermont.

16.
Plaintiff Ukraine Organization of Ukrainian Antifascist Resistance Fighters is
recognized by Ukrainian Ministry of Justice as an official representative of
8,500 former partisans and resistors of the Nazi occupation of Ukraine and
concentration camp victims.

17.
Plaintiff Ukrainian Union of Nazi Victims And Prisoners represents over 300,000
former slave and forced laborers, prisoners, concentration camp, and ghetto
survivors.

18.
Defendant Vatican Bank, also known by its official title “Istituto per le
Opere di Religione” or Institute of Religious Works (“IOR”) has
its principal place of business in Vatican City Rome, Italy but conducts
business and financial transactions worldwide on behalf of the Roman Catholic
Church, including the United States and California, with total assets believed
to be in excess of 3 billion dollars. Defendant, IOR, engages in for-profit
merchant banking transactions in the United States, California, and elsewhere
through its investments and transactions with other banks. The Vatican Bank is
headed by a Bishop but also has an advisory panel consisting of prominent
European and American bankers.

19.
Defendant, Franciscan Order, also known as First Order of Franciscans (O.F.M.)
includes and/or included several Croatian Franciscan Orders in California, the
United States, Croatia, and Italy. Upon information and belief, it is the
O.F.M. that owned, operated, and managed the affairs of the College of San
Girolamo degli illirici and provided aid to former Ustasha after 1945.

20.
Defendants, Does One through One Hundred inclusive, are unknown Catholic
Religious Orders and private banking corporations who conduct business in, and
who are also responsible for the acts complained of herein. Plaintiffs are
unaware of the true names or capacities of the Defendants sued herein under the
fictitious names of Does One through One Hundred inclusive, and after
ascertaining the true identity of a Defendant sued as a “Doe,”
Plaintiffs will amend the Complaint accordingly.

DEFINITIONS21.
“Nazi Regime” is defined as the National Socialist government of
Germany from 1933 through 1945, as more specifically defined in “the
Accused Organizations and Individuals” in The Nuremberg Trial, 6 F.R.D. 69
(1946), and persons, organizations or entities which acted in furtherance of
the interests of, on behalf of, or under the authority of, that government
(including persons, organizations and/or entities of the European Axis
countries).

22.
The “Ustasha Regime” is defined as the German puppet, fascist
government of Croatia under the direction of its leader, Ante Pavelic, known as
the “Poglavnik” (Leader). The Ustasha Regime operated under German
protectorate from 1941 through 1945 and included numerous members of the
Franciscan Order as both military and civil functionaries.

23.
“Looted Assets” is defined as any and all personal, commercial, real,
and/or intangible property, including cash, securities, silver, gold, jewelry,
businesses, art masterpieces, equipment and intellectual property, that was
illegally and/or improperly taken from the ownership or control of an
individual, organization or entity, by means including, but not limited to,
theft, forced transfer and exploitation, during the period of 1941 through 1946
by any person, organization or entity acting on behalf of, or in furtherance of
the acts of, the Nazi or Ustasha Regime, its officials or related entities, in
connection with crimes against humanity, war crimes, crimes against peace,
genocide, or any other violations of fundamental human rights.

24.
“Croatian or Ustasha Treasury” refers to amounts of gold, silver,
gems, currency, and other valuables plundered and looted from Serbs, Jews,
Romani, and citizens of the former Soviet Union, including Ukraine. The
treasury existed independent from the Nazi Regime in part as a reward for the
Ustasha cooperation in the pursuit of Axis goals in the former Soviet
Union.FACTUAL ALLEGATIONS

25.
The Nazi Regime maintained a policy of looting the assets of its persecution
targets to finance its illegal war, collecting the looted assets in central
depositories, and transferring the looted assets to the Doe Defendant Banks in
return for currency needed to purchase war material. The Ustasha Regime
mirrored the Nazi Regime in its financial policies. The Ustasha Regime, like
the Nazi Regime, maintained concentration camps and confiscated the assets of
its victims. More than 700,000 victims were “liquidated” by the Ustasha
in their bloody campaign to clear “Greater Croatia” of Serbs, Romani,
and Jews. The plundered and looted assets of the Ustasha victims were deposited
in the Ustasha Treasury.

26.
When Nazi Germany invaded Russia on June 22, 1941, the Ustasha leader, Ante
Pavelic, met with the military and civilian leadership of Croatia to decide how
best to support their German ally. All present were strongly in favor of the
German attack, seeing the invasion as a battle between the progressive forces
of Europe against the Communist forces in the East. All present agreed that
Croatia should participate in the invasion alongside Germany. Pavelic prepared
a letter the following day, on June 23, 1941. In his letter, Pavelic explained
to Hitler the wishes of the Croatian people to join the battle of “all
freedom loving nations against Communism.” Pavelic offered ground, sea and
air forces, to be committed “as soon as possible” to fight alongside
Germany. Hitler responded to Pavelic’s letter on July 1, 1941, accepting the
Croatian offer and thanking them for their service.

27.
Beginning in July 1941, Croatian ground, sea, and air forces invaded the Soviet
Union including Ukraine, Belarus, and Russia. Croatian units wore German
uniforms and provided front line and support units in Russian, Belarus, and
Russia. Croatian air force and navy units patrolled the Black and Azov Seas.
Croatian ground troops took part in battles in Kiev, Kharkov, and Stalingrad.
In September 1942, Pavelic, on behalf of the Croatian government, visited
Croatian troops outside Stalingrad.

28.
Croatian troops assisted the German occupiers of Ukraine in their systematic
plunder and looting of Ukrainian resources and individual property. In exchange
for the Croatian assistance in Ukraine, the Ustasha were given a free hand in
Croatia and Bosnia to loot, plunder and terrorize the non-Croatian populace.
The Ustasha Treasury contained plunder from Ukraine and assets seized from the
Ustasha victims in Yugoslavia.

29.
In addition to the property crimes and Nazi collaboration committed in the
former Soviet Union, the Ustasha engaged in atrocities against Serbs, Jews, and
Roma in Croatia.

30.
The Ustasha’s Minister of the Interior, Andrija Artukovic, ordered Jews and
Serbs of Zagreb to leave their homes where they were liquidated immediately or
sent to one of the many concentration camps. By late April 1941 Serbs were
forced to wear a blue armband with the letter “P”, the initial for
Orthodox (Pravoslavac). The Jews had to wear the Star of David on their
sleeves, and later, across their backs.

31.
Serbians, Jews, and the Roma were slaughtered in their villages after
unspeakable tortures or burned alive in their churches. Those that were not
murdered were expelled to Serbia proper after being despoiled of all their
property or forcibly converted to the Roman Catholic faith by Franciscan and
Roman Catholic clergy. Many were used as slave laborers. The remaining people
were taken to concentration camps where the majority perished.

32.
Jasenovac Concentration Camp complex, termed by historians as the
“Auschwitz of the Balkans,” was the home of indescribable brutality
against Jews, Serbs and Roma. Historians estimate that the Ustasha murdered
between 700,000 to one million Serbs, Jews, and Roma in Croatia during this
time.

33.
Many high officials of the Ustasha government were Roman Catholic clergy and,
in particular, Franciscans. Indeed, the Vatican maintained an “Apostolic
visitor” in Zagreb, the Croatian capital from 1941 until the end of the
War. Relations between the Vatican and the Ustasha were cordial. The Papal
legate in Croatia was Mgr. Marcone, who openly blessed the Ustasha, publicly
gave the Fascist salute, and transmitted instructions from Rome to the Croatian
clergy and episcopacy, principally concerning the forced conversions of the
Serbian Orthodox.

33.
Upon the demise of the Ustasha Regime in 1945, all or a portion of the Ustasha
Treasury was transferred to cooperative Roman Catholic clergyman and
Franciscans for transport to Rome where Franciscans sympathetic to the Ustasha
were based. Intelligence reports confirm that in their attempts to escape, the
Ustasha were found at the British-occupied Austro-Swiss border with gold valued
at 350 million Swiss francs. Intelligence reports also confirm that more than
200 million Swiss francs were eventually transferred to Vatican City and the
IOR with the assistance of Roman Catholic clergy and the Franciscan Order.

34.
In addition to the Bigelow Report, cited above, in 1948, U.S. Army Intelligence
reports confirmed that 2,400 kilos of Ustasha stolen gold were moved from the
Vatican to one of the Vatican’s secret Swiss bank accounts.

35.
Many officials of the Ustasha government, including war criminals like Ante
Pavelic, were secretly housed by the Franciscan Order in Vatican City or Rome.
The College of San Girolamo degli illirici became the headquarters for the
creation of the so-called “ratlines.” With the transfer of the
Ustasha Treasury to the IOR and the Franciscan Order, Ustasha and Nazi war
criminals were given money and a means to escape to Spain, Argentina, the
United States and other countries. By 1946, the former Ustasha Treasury was
being used to finance the post war activities of the Ustasha government in
exile and Nazi fugitives.

36.
Transfer of funds and financial transactions were made by IOR. Ustasha Treasury
assets were banked by IOR for use in Argentine, Spain and elsewhere. Not only
were the IOR and the Franciscans aware of the origins of the Ustasha Treasury,
but covert Ustasha activities, under the guise of religious orders, were
officially tolerated at the highest levels in the Vatican.

37.
IOR reaped a competitive advantage in the post World War II years through the
Ustasha Treasury related transactions. The Ustasha Treasury provided
substantial assets to IOR in form of gold, silver, cash, and gems. As the
principal post war banker to the Ustasha Government in Exile, the IOR profited
from Ustasha Treasury transactions involving banks in various European and South
American countries. The Franciscan Order and unknown Catholic Religious Orders,
reaped similar monetary benefits from their involvement with the Ustasha
Treasury.

38.
IOR has consistently refused requests for an accounting of the Ustasha
Treasury, including recent queries by the United States State Department, the
London Conference on Nazi Gold of December 2, 1997, and the Simon Wiesenthal
Center. CLASS ALLEGATIONS

39.
This action is brought and may properly be maintained as a class action
pursuant to the provisions of Federal Rule of Civil Procedure 23. Plaintiffs
bring this action on behalf of themselves and a class of all Jews, Serbians,
and former Soviet Union citizens (and their heirs and beneficiaries), who
suffered monetary and/or property losses or forced into slave labor due to the
systematic and brutal extermination of Jews, Serbians, and Romani by the Nazi
puppet Regime, Ustasha, and as a result of the occupation of the Soviet Union
by Croatian military forces in concert with their German occupation forces.

40.
The exact number of the members of the class, as identified above, is not known
to Plaintiffs, but it is estimated that members of the class number in the tens
or hundreds of thousands and are so numerous that joinder of individual members
herein is impracticable.

41.
Questions of fact and law common to the class predominate over any questions
affecting only individual members. Common questions of fact and law include:

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