Reed Brody to tyrants and a “spark of hope for victims.” In the wake of the Pinochet case, Brody began pursuing other former exiled leaders including Hissène Habré of Chad, Mengistu Haile Mariam of Ethiopia, Jean-Claude Duvalier and Raul Cédras of Haiti, and Idi Amin of Uganda. He wrote the Human Rights Watch booklet "The Pinochet Precedent: How Victims can Pursue Human Rights Criminals Abroad". Brody was an observer at the 2012 trial of Spanish judge Baltasar Garzón. Judge Garzón is best known for using the doctrine of universal jurisdiction to investigate war crimes and torture across national lines, most notably ordering
Jean-Claude Duvalier France). In 1998, a Haitian-born photographer, Gérald Bloncourt, formed a committee in Paris to bring Duvalier to trial. At the time, the French Ministry of the Interior said that it could not verify whether Duvalier still remained in the country due to the recently enacted Schengen Agreement which had abolished systematic border controls between the participating countries. However, Duvalier's lawyer Sauveur Vaisse said that his client was still in France and denied that the exiled leader had fallen on hard times. The 2004 "Global Transparency Report" listed Duvalier as the sixth-most corrupt world leaderbetween Slobodan Milošević and Alberto Fujimorihaving amassed