this Court has recognized and applied the law of war as including that part of the law of nations which prescribes, for the conduct of war, the status, rights and duties of enemy nations as well as of enemy individuals.”). In 1996, Congress enacted the War Crimes Act, which defined “war crime” in reference to the Geneva Conventions as well as other international agreements. See 18 U.S.C. § 2441(c). The War Crimes Act provides severe penalties for commission of war crimes, including the death penalty. See § 2441(a). Based on the Geneva Conventions and their incorporation into the War Crimes Act of 1996, the Court holds that there is a customary international law norm against attacks against civilians as war crimes. See In re Agent Orange, at 112-13. See also Kadic, 70 F.3d at 242-43 (<HOLDING>); Sarei, 221 F.Supp.2d at 1139-40 (“Courts have
recognizing attempt and conspiracy as inchoate crimes holding intoxication is only a defense to specific intent crimes and not general intent crimes recognizing that dui manslaughter and vehicular homicide are two separate crimes neither being a lesser included offense of the other but holding that a single death cannot support convictions for both crimes recognizing an atca claim for war crimes holding that under the crimes code conspiracy and the completed substantive offense are separate crimes