The defence team requests the ICTY Appeals Chamber to order Croatia "to immediately comply with the Tribunal's orders by withdrawing its appeal in the case of Mr. Ivanovic," reads a motion filed by Gotovina's team.

"On 14 February 2011, the Appeals Chamber ruled that investigators and attorneys for the Gotovina Defence enjoy functional immunity from criminal investigation and prosecution in the Republic of Croatia for all acts undertaken as part of their official function before the Tribunal," the motion says, adding that the Appeals Chamber ordered the Trial Chamber to issue an order to the Republic of Croatia "to cease all criminal proceedings against members of the Gotovina Defence for acts performed in the fulfillment of their official function before the Tribunal."

"Nevertheless, the Croatian authorities have refused to cease their efforts to overturn on appeal Mr. Ivanovic's Judgement of Acquittal. Despite numerous communications from counsel for General Gotovina over more than seven months seeking compliance by Croatia with the Tribunal's orders, Croatian authorities have consistently responded that they will 'look into the matter', but have taken no action to stop the appeal proceedings against Mr. Ivanovic," reads the motion.

"After seven months, Croatia has given no indication that it intends to comply with the Tribunal's orders and to stop the criminal proceedings in Mr. Ivanovic's case. General Gotovina assumes that Croatia does not intend to comply with the Tribunal's orders, and therefore further action by the Appeals Chamber is needed," the defence team said in the motion seeking an order directing Croatia to comply immediately with the tribunal's orders.

It also requests that Croatia be ordered to explain "why it has failed to comply for more than seven months with orders of the Trial and Appeals Chambers."