Moreno-Ocampo alleged that Kadafi, Sanoussi and Seif Islam huddled in private to plan how to crush demonstrations. Kadafi mobilized security forces, including newly recruited mercenaries, and appointed another son, Saadi, to be mayor of Benghazi, the eastern city where the protests first broke out and that now serves as the rebels' de facto capital.
"In the early days of the demonstrations, Kadafi transmitted orders through his secretariat to discipline civilians by killing them and destroying their property," he charged. "Further, Sanoussi, upon Kadafi's instructions, directed and coordinated the operation of the security forces in Benghazi and expressly ordered the shooting at civilians."
Security forces opened fire around Benghazi, including on a funeral procession Feb. 18.
"The same attacks were replicated throughout the country," the prosecutor's brief read, including the shooting of a funeral procession in Misurata two days later. Kadafi also ordered snipers and security forces to take up strategic positions around mosques in Tripoli, the capital, where they killed up to 100 civilians on Feb. 25, the prosecutor said.
Since mid-February, Moreno-Ocampo said, many journalists, political activists, demonstrators and others have been arrested and disappeared, and torture has taken place inside Kadafi's jails. The prosecutor described methods of torture such as "tying electric wires around victims' genitals and shocking them with electricity and whipping victims with an electric wire after tying them upside down with a rope connected to a stick."
At first, the prosecutor had focused solely on Kadafi, but he said it became clear early on that Kadafi shared authority with the two others. "Seif is more [about] planning, hiring mercenaries and making speeches. Sanoussi is the executioner. Sanoussi is cracking their backs," Moreno-Ocampo said.
Sanoussi, who is married to the sister of Kadafi's second wife, is head of military intelligence. The prosecutor's brief says he is believed to have ordered security forces to open fire on prisoners during a riot in 1996, killing about 1,000 of them, and that a French court convicted him in absentia of involvement in the 1989 bombing of UTA Flight 772, which killed 170 people.
McDonnell reported from Tripoli and Parker from Baghdad. Times staff writer Molly Hennessy-Fiske in Cairo contributed to this report.