Haydee Dijkstal was instructed by two non-profit organisations, Antiquities Coalition and Blue Shield, for the submission of an amicus curiae brief before the International Criminal Court (ICC) in the case against Bosco Ntaganda. The brief, filed on 18 September, addressed the definition and scope of the term 'attack' under sources of international law, including international criminal, humanitarian and human rights law, in regards to the crime before the ICC of destruction of cultural heritage, and examined whether an 'attack' under this crime can occur outside the conduct of hositilities. The brief was filed before the Appeals Chamber which is considering the Prosecution's appeal of the Trial Judgment and its dismissal of the charged crime of destruction of cultural heritage on this point.