Tribunal Criminal Tribunal for the Former Yugoslavia

Page 9032

1 Tuesday, 11 May 2004

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.02 a.m.

6 JUDGE LIU: Call the case please, Mr. Court Deputy.

7 THE REGISTRAR: Good morning, Your Honours. This is Case Number

8 IT-02-60-T, the Prosecutor versus Vidoje Blagojevic and Dragan Jokic.

9 JUDGE LIU: Thank you.

10 Good morning, everybody.

11 Good morning, Witness. Can you hear me?

12 THE WITNESS: [Interpretation] Yes.

13 THE INTERPRETER: Could the witness's microphone please be

14 switched on. Thank you.

15 THE WITNESS: [Interpretation] Yes, I can hear you.

16 JUDGE LIU: Yes. Would you please stand up and make the solemn

17 declaration in accordance with the paper the usher is showing to you.

18 THE WITNESS: [Interpretation] I solemnly declare that I will speak

19 the truth, the whole truth, and nothing but the truth.


21 [Witness answered through interpreter]

22 JUDGE LIU: Thank you very much. You may sit down, please.

23 THE WITNESS: [Interpretation] Thank you.

24 JUDGE LIU: Mr. Karnavas, your witness.

25 MR. KARNAVAS: Good morning, Mr. President. Good morning, Your

Page 9033

1 Honours.

2 Examined by Mr. Karnavas:

3 Q. Good morning, sir. Could you please tell us what your name is,

4 please.

5 A. My name is Milan Drakula.

6 Q. And could you please spell your last name, give us letter by

7 letter.

8 A. D-r-a-k-u-l-a.

9 Q. Sir, where are you from?

10 A. From Gorazde.

11 Q. Is that where you grew up?

12 A. Yes, that's where I was born and that's where I grew up.

13 Q. And could you please tell us your educational background.

14 A. I completed secondary school for the worker's trades of the metal

15 vocational stream.

16 Q. And did you do your JNA service?

17 A. Yes, I did.

18 Q. Where did you do your service?

19 A. In Nis and in Djakovica.

20 Q. What year was this?

21 A. 1980, 1981.

22 Q. Now, after completing your JNA service, where did you live and

23 work?

24 A. I lived by Gorazde and I worked in the factory for processing

25 equipment of Vitkovici and Gorazde.

Page 9034

1 Q. Now, were you mobilised during the war?

2 A. Yes.

3 Q. Could you please tell us when you were mobilised.

4 A. From the beginning of the war in Gorazde, which was the 4th of

5 May, 1992.

6 Q. Okay. And I take it you were in a Territorial Defence then?

7 A. Yes, on the Serb side.

8 Q. Now, did you ever become a member of the Bratunac Brigade?

9 A. Yes.

10 Q. When was this?

11 A. When we withdrew from Gorazde, or rather, when Gorazde fell. We

12 moved to the Bratunac Brigade on the 10th of September, 1992.

13 Q. All right. Prior to the war could you tell us, if you know, what

14 the breakdown was in the community of Gorazde, the ethnic breakdown.

15 A. There were 25 per cent Serbs and 75 per cent Muslims.

16 Q. When did you actually get -- you indicated that you went to

17 Bratunac on the 10th of September. When you got to Bratunac, was it

18 mandatory that you sign up to be mobilised in that area?

19 A. Well, anyone who came to Bratunac had to be in the army and had to

20 go up to the positions.

21 Q. All right. Now, when you started in Bratunac, what position were

22 you holding when you were mobilised there?

23 A. I was a soldier in the trench, in the TO of Pobrdje.

24 Q. Once the Bratunac Brigade was formed, in which unit did you serve?

25 A. The unit remained the same, the TO of Pobrdje.

Page 9035

1 Q. I want to fast forward to July 1995. Could you please tell us

2 what position did you hold in the Bratunac Brigade during that period.

3 A. I was in Pribicevac, which is not far from the command of the

4 3rd Infantry Battalion, in the 2nd Infantry Company.

5 Q. What position did you hold within the 2nd Company of the

6 3rd Infantry Battalion of the Bratunac Brigade?

7 A. I was a soldier in the trench.

8 Q. So from 1992 to 1995, you never advanced?

9 A. For a time I was deputy komandir of the company for a period of

10 eight months, but I stopped holding that post at my own personal request.

11 Q. And at what period of time would that have been, when you were the

12 deputy komandir of the company?

13 A. From February until November 1994.

14 Q. All right. So back in 1995 in July, you're just back to being a

15 soldier?

16 A. That's right.

17 Q. Now, you indicated that you were up in Pribicevac. Could you

18 please describe to us a little bit about that area where you were located.

19 Pribicevac is the dominant elevation point, comparing it to the other

20 elevation points. It's a little lower than Kvarc. And you can see part

21 of Srebrenica and the left and right side at an altitude of 800 mothers.

22 Q. All right. Now, what sort of facilities were there? It was a

23 forward command post, as I understand, so what sort of facilities were

24 available?

25 A. There was a village there, numbering three or four houses which

Page 9036

1 had been set fire to, and they were later transformed to be the command of

2 the 3rd Infantry Battalion; a covering was placed above it, some trenches

3 were dug, a line was set up, there was a kitchen, there was one house for

4 accommodation or sleeping, there was a sort of warehouse for storage

5 space, that kind of thing.

6 Q. Now, were you actually located at the forward command post of the

7 3rd Battalion, Pribicevac? Is that where you were physically located? Or

8 were you in another location?

9 A. I was in the trench, and that was the defence line. It was called

10 Kula.

11 Q. All right. And how far was Kula from the forward command post?

12 A. 100 to 120 metres.

13 Q. What sort of facilities did you have while you were there?

14 A. We had infantry weapons, a Browning and an APC.

15 Q. But the physical facilities I'm speaking of. When you say it was

16 a trench, could you please describe it to us. Was it just a hole in the

17 ground? Was there a physical structure to it? If you could just give us

18 a description of your location.

19 A. My trench was 3 by 3. It was dug into the ground. There was a

20 roof that didn't let in rain; it was impermeable. There was a stove

21 inside. There were logs, there beds for sleeping. And there were

22 communicating trenches to the left and right, and a loophole for firing

23 out of.

24 Q. What sort of means of communications did you have?

25 A. My trench was communicated with the command of the 3rd Battalion,

Page 9037

1 and it had an M-63-type telephone, which means a line, a wire connection.

2 Q. But aside from you being able to communicate with the forward

3 command post of the 3rd -- or the command post of the 3rd Battalion, where

4 else could you communicate with that line?

5 A. We weren't able to communicate directly with anyone unless we were

6 connected by the switchboard, then we could. But not directly.

7 Q. So the switch -- so you would have to place a call to the

8 battalion post, and then from there you could get connected. Is that what

9 you're telling us?

10 A. Yes. Yes. You couldn't do it directly.

11 Q. What about communicating with other trenches? Were there any

12 other means, such as Motorolas?

13 A. We didn't have a Motorola.

14 Q. So how would you communicate with the other soldiers?

15 A. The trenches weren't far, just 50 to 60 metres away. And usually

16 we would communicate personally. You would go to the trench, see what

17 they needed, what they didn't need, that kind of thing.

18 Q. How many trenches were there in the 2nd Company?

19 A. About ten trenches.

20 Q. And how many soldiers would be on the line at any given time?

21 A. The trench was -- well, 3 to 4, 6 at the most. There might have

22 been two -- well, there were never more than 60.

23 Q. Now, did you have any artillery power while you were over there?

24 A. At Pribicevac there was a mortar battery. I don't know how many

25 mortars exactly, but they fired very rarely. And there was an APC, too,

Page 9038

1 an old one, an old kind of APC not far from me.

2 Q. All right. And this motor battery belonged to the 3rd Battalion,

3 did it not?

4 A. Yes, that's right.

5 Q. Now, you indicated that there was a transporter. Is that the APC

6 that you've just made reference to?

7 A. Yes, that's right, the transporter is the APC.

8 Q. And who was that operated by, do you know?

9 A. There was a crew, several of them, the driver, the mechanic.

10 There were always between four to six men or three to six men manning it,

11 depending, sometimes just two.

12 Q. Okay. Could you please tell us just very briefly to your

13 knowledge what was the condition of the APC?

14 A. Mostly it was out of order and didn't have any fuel. They would

15 take a battery to Bratunac, for example, and so they wouldn't have a

16 battery. Then they would fetch a battery. They would switch the motor

17 on, and it used up a lot of fuel. Anyway, it was in very poor condition

18 and broke down very frequently.

19 Q. All right. Now, I want to speak to you about the events

20 surrounding the -- Srebrenica that began on June 6th -- July 6th, 1995,

21 with the fall of Srebrenica of July 11, 1995, and a few days thereafter.

22 Could you please tell us whether you were in your trench, on the line, the

23 day the events began concerning Srebrenica, that would be July 6th.

24 A. I was at the same place I was at the previous two and a half

25 years.

Page 9039

1 Q. All right. For those previous two and a half years, had you been

2 ever given any orders to advance and try to capture any terrain?

3 A. That was impossible.

4 Q. Why is that?

5 A. Because at the time we were at the dominant elevation points,

6 which means the Pribicevac ridge, and any advancement would have

7 threatened our positions. It was a very good position.

8 Q. All right. Well, could you please sort of describe it to us. I

9 mean, where is Srebrenica? Where is Pribicevac? I mean, what's the

10 significance of your dominant position?

11 A. Pribicevac is the dominant elevation point, from which you can see

12 Srebrenica. It was about 2.000 metres away, as the crow flies. You could

13 see part of Srebrenica, actually. And from Pribicevac you could see quite

14 a lot of outlying land.

15 Q. What was the terrain like in front of you?

16 A. To Srebrenica it was steep. A large slope, streams, forests.

17 Q. Was there a road or some sort of a passageway that could take you

18 from Pribicevac to Srebrenica?

19 A. As far as I knew there was, via Sase and Zalazje, across Potocari,

20 across Zeleni Jadar. So that would mean Zeleni Jadar, Srebrenica.

21 Q. What about the vegetation there? Was it bare, or did you have

22 trees? Can you please describe that for us from where your location was.

23 A. Well, in front of us there were age-old forests, untapped

24 territory.

25 Q. Okay. So July 6th, had you been given any prior instructions or

Page 9040

1 warnings or information that something was about to happen on that

2 particular day?

3 A. Nothing. We didn't receive anything.

4 Q. Did you know or were you aware of the activities that were about

5 to happen?

6 A. I saw that something would be done on the left-hand side in the

7 Zeleni Jadar area.

8 Q. What gave you that impression?

9 A. Well, some machinery turned up, several tanks, and rumours were

10 going around that some soldiers had arrived, not many, but some army. And

11 I expected something to happen there.

12 Q. Were those tanks from the Bratunac Brigade?

13 A. No.

14 Q. Now, did you have a company komandir?

15 A. Yes.

16 Q. And I take it he --

17 A. We did have a company komandir. He was in the next-door trench to

18 mine.

19 Q. All right. And what about a battalion commander, did you have a

20 battalion commander?

21 A. Yes.

22 Q. All right. Do you recall whether the battalion commander or the

23 company komandir ever gave you and the others instructions or information

24 regarding what tasks you might have during those days?

25 A. No.

Page 9041

1 Q. You also had a brigade commander, did you not?

2 A. Yes.

3 Q. Did the brigade commander ever give any instructions or pass along

4 any information as far as what you would be doing or what to expect during

5 those days?

6 A. No, he didn't.

7 Q. How did you know, other than seeing something happening on the

8 left side or this equipment, how did you know something was going on on

9 July 6th, 1995? What caught your attention?

10 A. The shooting started.

11 Q. So I take it you could hear it from that location?

12 A. Yes.

13 Q. Could you also see it?

14 A. Well, no, you couldn't see it. It was too far off.

15 Q. All right. Now, do you recall seeing your commander, the

16 commander of the Bratunac Brigade, during those days?

17 A. I remember seeing him, yes.

18 Q. And could you please describe to us when was the first time that

19 you saw him and where was it that you saw him.

20 A. I saw him first at the Kula or tower at my trench.

21 Q. All right. So what was he doing when -- when did you see him, do

22 you recall, in comparison to when you had heard the activities, the

23 firing?

24 A. I don't remember the date exactly, whether it was the 6th of 7th

25 or possibly the 8th. But I think it could have been either -- any of

Page 9042

1 those days, the 6th or the 7th. He would come to Kula frequently and he

2 would spend some time there frequently.

3 Q. And when he came -- first of all, when he first came, did you know

4 who he was?

5 A. I had heard from the soldiers, so that was the new commander,

6 Colonel Blagojevic.

7 Q. So you did not know him? You had learned this from others?

8 A. No. Yes.

9 Q. Okay. Did he introduce himself as the commander to give any

10 instructions or to give any information?

11 A. Not to me personally, no. And I wasn't present when he introduced

12 himself to any of the others.

13 Q. All right. Now, could you please tell us what you were able to

14 observe, what was your commander doing when he was in your trench?

15 A. He would often be in the trench -- in front of the trench,

16 observing to the left and to the right. And on the table he would place

17 some maps; he would look at them. He didn't do much talking. He didn't

18 talk to me at all, nor did I ever ask him anything, nor did he address me

19 at all ever.

20 Q. All right. Why was he in Kula, do you know?

21 A. I think that somebody had told him to go to Kula. That's what the

22 soldiers said, that he was sent to Kula and that it was the forward

23 command post, because the commander would be there mostly from now on.

24 Q. To your understanding, where was the forward command post of the

25 Bratunac Brigade during those days?

Page 9043

1 A. My conclusion is that it was precisely there, in my trench, the

2 forward command post of the brigade.

3 Q. Now, you said that he was looking at some maps. Could you please

4 tell us where he was looking at those maps.

5 A. In front of the trench, there was a little table in the connecting

6 trench. And it was there he laid out those maps and looked at them.

7 Q. And how long was he looking at those maps when he was there?

8 A. Well, from time to time, often in fact.

9 Q. All right. Well, did you see him giving any orders?

10 A. I didn't see him giving any orders, no.

11 Q. While you were there, did you ever see General Krstic come by to

12 have a conversation or to meet with your commander?

13 A. I never saw the two of them together.

14 Q. Did you ever, while you were there, hear the telephone ring asking

15 for your commander to go to the forward command post to have any

16 discussions?

17 JUDGE LIU: Yes, Ms. Issa.

18 MS. ISSA: Your Honour, I object to that. There's no foundation.

19 I don't see how this witness could possibly answer that question.

20 JUDGE LIU: Yes, and it's very leading.

21 MR. KARNAVAS: Well, I beg to differ, Your Honour. While you were

22 there, while you were there. That's when he was there, not when he wasn't

23 there. I'm asking him while he was there did the phone ever ring and, you

24 know -- but I'll move on.

25 JUDGE LIU: Yes. Yes, please.

Page 9044


2 Q. Did any couriers come while you were there that you were able to

3 see, observe, hear, asking for your commander to meet with General Krstic?

4 A. I didn't see that.

5 Q. Did you see any other commanders come over to have any discussions

6 with Colonel Blagojevic?

7 A. I didn't see anybody, any of the other commanders that is, coming

8 in to see him from elsewhere.

9 Q. Please describe to us what you saw Colonel Blagojevic doing while

10 you were there. I'm just asking for your observations, not to speculate,

11 just what you heard, what you saw, saw, what you were personally able to

12 observe.

13 MR. KARNAVAS: I would appreciate if the Prosecutor would stop

14 making faces, stop whispering, stop interrupting. I understand the

15 strategy, Your Honour, but it's not necessary. They can write notes to

16 each other, but it's very distracting, and if he doesn't like the direct,

17 that's his business. But I'm entitled to some courtesy in this courtroom.

18 JUDGE LIU: Yes, Mr. McCloskey.

19 MR. McCLOSKEY: I don't know why Mr. Karnavas is so grumpy this

20 morning. Ms. Issa and I occasionally communicate in whispers. I think

21 that's normal. We're being very polite to Mr. Karnavas, we're not

22 interrupting him. This is nonsense.

23 JUDGE LIU: I didn't notice that, Mr. Karnavas. But from now on

24 I'll pay more attention on this side. You may move on.


Page 9045

1 Q. What did you see? I want you to think back, and please describe

2 to us what you were able to observe. What was Commander Blagojevic during

3 there during those days, if anything?

4 A. I saw that Blagojevic looked at maps, just as anyone would who had

5 arrived in a new location. It was logical that he had to look at the maps

6 in order to get familiar with the territory. He didn't ask me what

7 villages is that or what hill is that, but he did look at the maps.

8 Q. All right. Did you ever see any of his commanders, that is from

9 the 1st, the 2nd, the 3rd, or the 4th Battalion, come to him and have any

10 discussions?

11 A. No. Nobody came.

12 Q. What about with the company commanders, at least with the

13 3rd -- of the 3rd Battalion, since you were there?

14 A. I didn't see my komandir coming to see him; there was no need. I

15 don't know really.

16 Q. All right. Now, could you please tell us what your activities

17 were on the 6th of July, 1995. What were you ordered to do?

18 A. In view of the fact that the fighting had started at the left

19 front line, we expected to be attacked. We thought there would be a

20 counterattack, so we prepared for defence. We were all mobile. We took

21 very little rest. We were all in the trenches waiting.

22 Q. What about -- well, did you fire your weapons on the 6th?

23 A. We didn't fire.

24 Q. What about on the 7th? Did you receive any orders on the 7th to

25 do anything in particular, something that you hadn't done, for instance,

Page 9046

1 in the last two and a half years?

2 A. No, we didn't.

3 Q. What about the 8th, the next day?

4 A. On the 7th and 8th, it was quiet in the wider area. There was a

5 lot of fog. Nothing happened. But still, we did expect to be attacked

6 out of that fog.

7 Q. Well, were you ever attacked?

8 A. At Pribicevac, we were never attacked.

9 Q. All right. What about the 9th?

10 A. No, we were not attacked on the 9th either.

11 Q. Were you -- did you do any attacking on the 9th?

12 A. We personally didn't. My company was given the task to move to

13 the edge of the wood two or three trenches further on, into the depth of

14 the wood so that we would not be there at Pribicevac.

15 Q. Okay. What about the 10th?

16 A. On the 10th we didn't go anywhere. We were always there and we

17 did not attack, nor were we attacked.

18 Q. What about the 11th? Were you ever given any orders on the 11th

19 to do something?

20 A. Not we, no.

21 Q. Now, I'm not speaking from Colonel Blagojevic, I'm talking about

22 did you receive any orders from anyone else on the 11th, the day

23 Srebrenica fell?

24 A. We didn't get any orders except when Mladic arrived.

25 Q. All right. Now, before we get to what happened when Mladic

Page 9047

1 arrived, and we're speaking of General Mladic. Correct?

2 A. Yes. Nothing happened until he arrived.

3 Q. Okay. Now, do you know who was occupying the command post of the

4 3rd Battalion of the Bratunac Brigade?

5 A. Where up to that point the command of the 3rd Battalion had been,

6 General Krstic was there, that was the forward command post of the Drina

7 Corps.

8 Q. And how often did you see, that you were able to personally

9 observe, your commander, Colonel Blagojevic, go to the forward command

10 post of the Drina Corps during those days, the 6th, the 7th, the 8th, the

11 9th, the 10th, the 11?

12 A. I didn't see him go there.

13 Q. All right. Now, did the Drina Corps have any artillery equipment

14 up there during those days that they brought?

15 A. Not far from my trench. There was a self-propelled weapon. It

16 was right next to the trench. Down there, there was some sort of gun.

17 130-millimetre I think it was, with a long barrel.

18 Q. All right. And how often was that being fired?

19 A. The self-propelled weapon was fired when there was fighting on the

20 right-hand side, toward Divljakinje.

21 Q. And was that a Bratunac Brigade crew that was doing the firing?

22 A. No. No.

23 Q. Now, on that side, who was located, which company, of the -- on

24 the right of your company, which company is located of the 3rd Battalion?

25 A. The members of the 3rd Battalion. I don't know exactly what

Page 9048

1 company. They were at Kvarc, and something was being done about

2 Divljakinje. Divljakinje had been taken and the aim was to have our

3 troops reach Divljakinje. And that's where the shooting was going on.

4 Q. Now, do you know which troops were located over there? Do you

5 actually know which troops were located?

6 A. Those of the 3rd Infantry Battalion held their positions there. I

7 don't know what company it was, whether the 1st or -- Sreten Petrovic was

8 there, too, at the time.

9 Q. All right. And that's on the right. What about the left? Do you

10 know who was on your left side, which units?

11 A. I didn't see them, but they said those were members of the

12 Zvornik Brigade.

13 Q. Now, let's talk about when Mladic came, General Mladic came on the

14 11th of July, first of all where was it that there was this encounter

15 where Mladic came? Where did it take place?

16 A. Mladic came to Pribicevac.

17 Q. All right.

18 A. He parked his car in front of the headquarters, that is the

19 buildings where the headquarters was. He passed by the headquarters on

20 foot. I didn't see that, but I did see him when he came out onto a

21 plateau and set out toward Kula.

22 Q. That's where you were located or the company was located?

23 A. Yes. He set out right towards Kula.

24 Q. All right. And then what?

25 A. We withdrew into the trenches, so as not to be there at Kula but

Page 9049

1 at the edge of the wood at our defence positions.

2 Q. And why did you do that?

3 A. We did that so that the general wouldn't say we were lying about.

4 We went to our combat positions.

5 Q. All right. Do you recall whether your commander,

6 Colonel Blagojevic, was there? Did you see him at that time when Mladic

7 was approaching Kula?

8 A. In view of the fact that I had withdrawn and gone down there, I

9 couldn't see what was going on up there.

10 Q. All right. So what happened after that?

11 A. Mladic came to Kula.

12 Q. And then what?

13 A. He asked us: "Lads, are there any minefields in front of you?"

14 Q. Who did he ask?

15 A. He was facing me.

16 Q. All right. And what was the response?

17 A. "Yes, this has all been mined."

18 Q. And then what?

19 A. I heard him issue an order that the demining crew be called.

20 Q. All right. So what happened after he issued this order?

21 A. Several minutes later, the deminer was standing next to him.

22 Q. All right. And then what? Please describe to us what happened.

23 A. He said: "Who's in command of this unit?" The company komandir

24 spoke up and said he was commanding the unit. He told him: "Go in the

25 direction of Srebrenica."

Page 9050

1 Q. All right. And what was the response of the company komandir?

2 A. The company komandir turned to us and made a gesture with his hand

3 as to say: "Let's go, lads."

4 Q. And did you go?

5 A. Yes. We set out in a column toward the place where the demining

6 was to take place, and that's on the Pribicevac-Crni Guber line, about 100

7 metres down that axis.

8 Q. How much time did the company komandir give you and the other men

9 to get ready to advance forward towards Srebrenica, pursuant to

10 General Mladic's order?

11 A. We set out right away.

12 Q. All right. And where did you go? Please describe to us where you

13 went.

14 A. We went from Pribicevac to the right along the line next to the

15 trenches. And when we came to the place that had been demined, we turned

16 left towards Srebrenica.

17 Q. And how far did you go?

18 A. We went on for about 800 metres.

19 Q. And then what?

20 A. Behind us another company of the Bratunac Brigade set out. That

21 was the company from Fakovici.

22 Q. All right. And I take it they joined you?

23 A. Yes. Yes, yes.

24 Q. How far did you advance on that particular day, since you had been

25 given orders by General Mladic to go to Srebrenica? How far did you go?

Page 9051

1 A. I said about 100 -- about 800 metres from Pribicevac.

2 Q. How far away is that from Srebrenica?

3 A. We were halfway there, almost halfway. There was more to

4 go -- there was a greater distance towards Srebrenica than there was

5 towards Pribicevac.

6 Q. All right. Where did you spend the night?

7 A. We made a circular defence there, and that's where we spent the

8 night.

9 Q. Now, did you see Colonel Blagojevic while you were on your way to

10 Srebrenica, as you had been ordered by General Mladic?

11 A. I did see Colonel Blagojevic there.

12 Q. Where did you see him, at what location?

13 A. He came to where we were.

14 Q. Was that, say, 100 metres down from Pribicevac, from Kula?

15 A. No, 800 metres, where we had stopped.

16 Q. Okay. And did he have any conversations with anyone that you were

17 able to observe, that you saw, personally saw? We don't want you to

18 speculate here.

19 A. I only saw him briefly, for a moment. I saw that he was there and

20 that his escort, Ilic, was there. I didn't see him talking to anyone or

21 hear what he was saying. I personally didn't ask him any questions.

22 Q. All right. Now, after spending the night there, where did you go?

23 A. In the morning we were given orders to move towards Srebrenica.

24 Q. All right. And did you do so? Please describe to us, just tell

25 us step by step, where did you go on that day?

Page 9052

1 A. We went downhill towards Srebrenica. The path was difficult.

2 There were stones, rocks. That was the first time in my life I have gone

3 down such a difficult path.

4 Q. All right. Did you get -- did you go all the way into Srebrenica?

5 A. We arrived as far as the Argentarija spa which is the first

6 building in Guberski Potok.

7 Q. All right. Well, is that near Srebrenica, since we don't know

8 that area?

9 A. Between that and the entrance to Srebrenica, the church, and the

10 community centre, I think the distance is about 800 to 1.000 metres.

11 Q. All right. Now, when you say "the entrance of Srebrenica," from

12 which side are we speaking of? From the one as you enter Srebrenica from

13 Potocari or from the other direction, the opposite direction, that is?

14 A. The opposite direction. From the direction of Pribicevac.

15 Potocari are at the other end.

16 Q. All right.

17 A. Srebrenica is long and narrow.

18 Q. All right. Now, did you actually physically go into Srebrenica on

19 that particular day?

20 A. No.

21 Q. Where did you go from there?

22 A. We went to the right toward the Kozarica settlement in the

23 direction of Zalazje.

24 Q. All right. Now, what was the reason for going there?

25 A. I don't know.

Page 9053

1 Q. And I take it you went there by foot?

2 A. Yes.

3 Q. Would you please describe to us how the men were on foot. Were

4 they spread out? Were they marching in groups, going in single column?

5 A. We were going in a column one after the other. There was a

6 macadam road, and then we got out on to the asphalt road between Zalazje

7 and Srebrenica. And along this asphalt road, we went to Zalazje.

8 Q. Were you ever in any of the wooded areas searching for anyone?

9 A. Nobody left the road.

10 Q. While you were on the road, did you ever observe any Muslim men,

11 or anybody for that matter?

12 A. No. No, we didn't.

13 Q. Did you see any dead bodies while you were marching on the road?

14 A. No.

15 Q. Did you find any weapons that might have been abandoned?

16 A. No.

17 Q. Okay. So what did you do that day other than march? Was there

18 anything in particular?

19 A. Nothing. We got to Zalazje and we laid down to have a rest and

20 waited for further instructions.

21 Q. All right. How long were you in that location?

22 A. We spent the night there.

23 Q. And then what happened? What did you do the next day?

24 A. On the next day we were given orders to get moving again.

25 Q. Who gave you those orders?

Page 9054

1 A. Well, I was given the order by my komandir.

2 Q. Do you know whether your komandir had any radio equipment with

3 him, a Motorola, for instance?

4 A. No, he didn't.

5 Q. Now, you said there was another company from the Bratunac Brigade.

6 Do you know whether they had any means of communication, such as a radio?

7 A. I don't know, but at Zalazje there were lots of soldiers at that

8 moment. The troops from Kvarc had also come down to Zalazje.

9 Q. All right. And were those members of the Bratunac Brigade?

10 A. Yes.

11 Q. All right. Now, what were your orders for that day?

12 A. I don't understand your question.

13 Q. All right. There were orders that day that your komandir

14 received. What orders did he receive that were passed on to you?

15 A. Yes. He said we should get ready to go on, and we did.

16 Q. Where did you go to?

17 A. We went from Zalazje through a wood and got down to Solocusa.

18 Q. Were you searching the terrain there, or were you still marching

19 in a column?

20 A. It was a column.

21 Q. Were you told why you were going in that direction?

22 A. Well, nobody told me specifically why.

23 Q. Were you given any particular instructions?

24 A. No. No.

25 Q. So how long did you march? How long did it take you to get to the

Page 9055

1 next location?

2 A. I think it was about 5 kilometres, so that means one, two, perhaps

3 three hours. I can't remember exactly.

4 Q. When you got to that location, what did you do?

5 A. We came out at, or rather, we went down to the asphalt road

6 running from Bratunac to Srebrenica at Solocusa, near the playing ground.

7 Q. All right. So now you are at or by Srebrenica. Is that correct?

8 A. Yes, nearby, although to the entrance to Srebrenica from the other

9 side, opposite direction, is 1 kilometre.

10 Q. All right. So now you're by the entrance as if you're going to

11 Srebrenica from Potocari. That's where the playground is.

12 A. Yes.

13 Q. Did you go into Srebrenica on that particular day?

14 A. No.

15 Q. What did you do? Where did you stay?

16 A. We were told to get away from the road and go into the houses, and

17 that we should stay there and wait for further instructions, orders.

18 Q. And is that what you did?

19 A. Yes.

20 Q. How long were you in that area?

21 A. We spent the night there.

22 Q. After spending the night there, did you receive any other orders

23 the next day?

24 A. Yes.

25 Q. All right. And what were those orders?

Page 9056

1 A. A bus arrived. We got into the bus. We passed through

2 Srebrenica. We arrived at Bojna, and we got out of the bus at Bojna.

3 Q. Where did -- I'm sorry. Go ahead.

4 A. The battalion commander was there, Zekic.

5 Q. All right.

6 A. And there was that transporter of ours from Pribicevac and the

7 crew next to the transporter.

8 Q. All right. Could you please tell us, if you know, who sent the

9 bus over there.

10 A. I don't know.

11 Q. When you got there, about what time of day are we talking about?

12 A. About noon.

13 Q. And when you got to that location, did you get any further

14 instructions?

15 A. We stopped at Bojna briefly. The komandir talked to Zekic. I

16 don't know what they talked about. But then we got back into the bus, and

17 the bus drove us to the village of Ljubisavljevici which is next to Jadar,

18 or rather not far away from Jadar.

19 Q. What was the purpose for going there?

20 A. Well, we were supposed to search the terrain there, that's what I

21 was told at least.

22 Q. And was the terrain searched over there?

23 A. At Bojna, our komandir agreed with Zekic where we were to meet up

24 after searching the terrain. And it was decided that this should be at

25 the village of Kovacica.

Page 9057

1 Q. All right. But my question was: Did you actually search the

2 terrain? Because you said you were supposed to search the terrain. So

3 the question is: Did you in fact search the terrain?

4 A. We passed by -- we took the route that we were supposed to take.

5 Q. All right. Well, how did you take this route, by foot? By bus?

6 A. On foot. They are -- it's forest ground.

7 Q. All right. Now, could you please describe to us the formation of

8 the men when you were over there.

9 A. They were all soldiers, soldiers from those villages who knew the

10 area and who would be passing by their own houses. I was the only one to

11 come from other parts.

12 Q. All right. Well, what I'm trying to get at is: How were you

13 searching the terrain? Describe to us the manner in which you and the

14 other soldiers were physically conducting this search.

15 A. We took the road up until a certain place and then carried on. We

16 would stop a little, take a look around, and carry on, that's what we did.

17 But it wasn't a real search of the terrain. Our goal was to pass by there

18 and reach the point we were supposed to reach.

19 Q. All right. Were the soldiers spread out searching -- as they

20 searched the terrain, as you marched forward on that terrain? That's what

21 I'm trying to ask you.

22 A. We were in a group.

23 Q. All right. How long did the searching of this terrain take?

24 A. Three to four hours.

25 Q. All right. Now, you said some of the soldiers -- or you were the

Page 9058

1 only soldier that wasn't from that area. What did some of these other

2 soldiers do, since they were from that area, if anything?

3 A. I remember a young guy who was one of the crew in the APC, he came

4 to his house. We stopped there and then carried on. And he would say:

5 "This is so-and-so's house, that's so-and-so's house." He would point

6 out who the houses belonged to.

7 Q. During that day when you were searching for three or four hours,

8 did you find anyone? Did you come across any Muslim men or anyone?

9 A. No.

10 Q. Were any prisoners taken that day?

11 A. No.

12 Q. Did you find any dead bodies in that location that might have been

13 killed?

14 A. No.

15 Q. Did you find any weapons?

16 A. No.

17 Q. All right. What did you do after that search? What was the next

18 order?

19 A. We reached a certain collection point, as we called it, in the

20 village of Kovacica, near Zekic's house.

21 Q. And when you got to this collection point, about what time are we

22 talking about?

23 A. Well, it was afternoon. There were another two or three hours of

24 daylight left before dark.

25 Q. And when you got to this collection point, what if anything did

Page 9059

1 you do?

2 A. Nothing. We had dinner.

3 Q. All right. And then what?

4 A. We spent the night there.

5 Q. Okay. From -- all right. And was your commander or the battalion

6 commander, Zekic, there?

7 A. My komandir was.

8 Q. All right. From there, what did you do? You spent the night

9 there. Where do you go next?

10 A. The next day, we received orders to move on.

11 Q. Well, move on to where?

12 A. We went down some routes and reached Srebrenica and the petrol

13 station there.

14 Q. Okay. Now, when you went on these routes, to reach Srebrenica

15 were you searching the terrain?

16 A. We took the road again.

17 Q. And which road are we talking about?

18 A. The nearest road going through some villages down to the petrol

19 pump.

20 Q. All right. On that route, did you find anybody? Did you come

21 across any prisoners?

22 A. No, we didn't.

23 Q. Okay. Now, did you get to Srebrenica?

24 A. We reached the petrol station.

25 Q. Now, which side are we talking about? Are we still back by the

Page 9060

1 entrance by -- if you're coming from Potocari?

2 A. Yes, the petrol station is at the entrance to Srebrenica from the

3 Potocari side.

4 Q. Once you got to that location, what did you do?

5 A. We waited for about an hour, and then the bus arrived.

6 Q. When the bus arrived, where did it take you, assuming you got in

7 the bus?

8 A. Yes.

9 Q. Where did it take you?

10 A. It took us to Bratunac.

11 Q. And when you got to Bratunac, about what time of day was this?

12 A. It was sometime in the afternoon.

13 JUDGE LIU: Well, Mr. Karnavas, I'm sorry to interrupt, but

14 somehow I lost the dates. Would you please try to establish that it's on

15 the 13th and 14th of July.

16 MR. KARNAVAS: Thank you, Mr. President. What I was going to do

17 now that we reached this point, I was going to show him a map that he

18 looked and marked and go through the actual dates so that we actually have

19 the actual locations with the date. And I was looking at the time and it

20 would take about 10 minutes to do that, so perhaps we can have the break

21 and then we can fill in the dates so we have a clear record. I first

22 wanted to get the story out.

23 JUDGE LIU: Yes. Thank you.

24 And we'll resume at quarter to 11.00.

25 --- Recess taken at 10.14 a.m.

Page 9061

1 --- On resuming at 10.47 a.m.

2 JUDGE LIU: Yes, Mr. Karnavas, please continue.

3 MR. KARNAVAS: Thank you, Mr. President, Your Honours.

4 Q. Sir, I want to show you now what has been marked for

5 identification purposes as D146. It has previously come into evidence, I

6 believe the original map, as P369. Could you please look at this. And if

7 we can put it on the ELMO. I have an extra copy for the gentleman.

8 MR. KARNAVAS: And just for the record D146 for identification is

9 part of P369. And we've blown it up a little bit.

10 Q. Would you please look at this document, sir. Do you recognise it?

11 A. Yes.

12 Q. Now, you note on the document itself that there are some markings,

13 some lines, and some numbers. Do you recognise those markings, sir?

14 A. Yes.

15 Q. Whose markings are they?

16 A. They are my markings.

17 Q. And when were those markings made, sir?

18 A. Last night.

19 Q. All right. And in fact, on the larger map, the larger copy, you

20 even placed your signature on it. Is that correct?

21 A. Yes.

22 Q. All right. Now, if you could please tell us - we're going to go

23 step by step - number one, that location. What is over there?

24 A. Here we have the starting out point, Pribicevac, to the first line

25 is where we spent the night on the 11th.

Page 9062

1 Q. All right. Well, just -- let's take it step by step. First of

2 all, where you have the 1, that is where the forward command post was

3 located of the Drina Corps at the time. Correct?

4 A. Yes, Pribicevac was the forward command post of the Drina Corps.

5 Q. And we can even see that on the map. And 100 or so, 150 metres

6 away is Kula where you had your trench, wasn't it?

7 A. Yes.

8 Q. And I believe that where you said it was your impression that your

9 commander had set up his forward command post during that period. Is that

10 right?

11 A. Well, yes, because he would be there frequently.

12 Q. All right. Now, between 1 and 2 we see a line, you marked a line.

13 Is that right?

14 A. Yes.

15 Q. So what does that line reflect?

16 A. That line reflects the road, the route, that I took.

17 Q. Okay. Now, you said you left on the 11th pursuant to orders given

18 by General Mladic to your komandir. How far did you get on the 11th? If

19 you look at this map. About 800 metres from Pribicevac.

20 Q. And can you designate to us or tell us where exactly on the map is

21 that shown.

22 A. Where the line across is.

23 Q. All right. So if you could reach over to the projector and you

24 can point to us, maybe even put 11 there to designate --

25 A. Pribicevac is here. That's where we spent the night.

Page 9063

1 Q. Okay.

2 A. Is it 1 or 11? Whatever you like. Do you want me to put 1 or 11?

3 Q. Put 11 so we know it's the 11th of July. Can you put an 11 right

4 where you spent the night.

5 A. [Witness complies]

6 Q. Okay. Now, from there could you please tell us how far did you go

7 the next day.

8 A. The next day we started off from this point, took this road, and

9 came to Banja Guber, went up Kozarica and reached this road here, the

10 Srebrenica/Zalazje road, continued along that road and reached Zalazje.

11 Q. All right. Now, what is the 2 for? Is that for day 2? What does

12 2 stand for?

13 A. Yes, it was the second day.

14 Q. Okay. And where you marked 12 on the map, that's how far you went

15 on that second day?

16 A. Yes. And we spent the night there.

17 Q. All right. Now, on the 13th, could you please tell us how far did

18 you go?

19 A. On the 13th we set out from Zalazje here. We took this

20 road -- actually, it was a path through the forest, and we came down to

21 the road here not far from the playground.

22 Q. All right. And that's as far as you got on that day?

23 A. We spent the night there.

24 Q. Okay. And could you put there 13 so we know that that's the night

25 of the 13th that you spent there?

Page 9064

1 A. [Witness complies]

2 Q. Okay. Now on the morning of the 14th could you show us

3 where -- what route you took. Where did you go?

4 A. We got into the buses here and we went through Srebrenica. We

5 passed Srebrenica and reached Bojna. And we had a rest there, a short

6 rest, and that's where the transporter was, the APC. And then we

7 continued along this road to Ljubisavljevici. And we got off the bus

8 here.

9 Q. Okay. And did you spend the night there?

10 A. No.

11 Q. Okay. Where did you spend the night? How far did you go?

12 A. We took this route, passed by Zivkovo Brdo, went across

13 Siljato Brdo hill, and reached the village of Kovacica here.

14 Q. And that's where you would have spent the night of the 14th?

15 A. Yes.

16 Q. Can you put 14 there.

17 A. I've placed it there, yes, number 14.

18 Q. And just so we know before we go any further, where is the area

19 that you searched, you were asked to search? Could you just point that on

20 the map for us.

21 A. We left the bus here, got off the bus. We took this route,

22 Zeleni Jadar remained to our left. Zivkovo Brdo or hill on the right. We

23 passed across Siljato Brdo or hill through some villages, called Saraci,

24 Viogor and went down to the village of Kovacica. The broader region of

25 Orahovac, but the village of Kovacica in particular.

Page 9065

1 Q. Could you draw that in? Is it possible for you to sort of draw in

2 with the pen the area, the general area, where you would have searched on

3 that particular day.

4 A. Where we got off the bus, we took this route. Well, I don't know

5 if it's exactly like this, but anyway Jadar remained to our left, the

6 ridge there by Zivkovo hill, Siljato hill, Viogor and the village of

7 Kovacica. That was the first and last time I ever passed by that way. I

8 was never there before and I was never there since.

9 Q. But just so we have a record, so after you leave we know exactly

10 what area, would you just with your pen mark that particular copy of the

11 map the general area where you would have been searching.

12 A. I can't do that; that would be impossible. I couldn't even do it

13 on a larger map, let alone this one.

14 Q. Okay. Very well. Okay. Could you tell us from the 14th, where

15 did you go? You spent the night on the 14th; you've designated where it

16 is. Could you tell us from there, where did you go?

17 A. We went down this road passing the village of Bajramovici, we

18 emerged on to this road here and reached the petrol station in Srebrenica.

19 Q. Okay. And you spent the night there?

20 A. No.

21 Q. Where did you spend the night?

22 A. We waited for the buses there.

23 Q. Okay. And from there where did you go?

24 A. We waited for the buses and then got into the buses and then drove

25 off to Bratunac.

Page 9066

1 Q. All right. And what time -- when -- so this would have been what

2 day when you got to Bratunac?

3 A. It was always the -- it was already the 15th, I think.

4 Q. Okay. Now, you told us earlier that at one point you went to the

5 entrance point of Srebrenica and you spent the night over there in some

6 houses. When was that?

7 A. Yes.

8 Q. Where was that?

9 A. That was at Solocusa.

10 Q. What day are we talking about?

11 A. The third day, that is to say, the 13th.

12 Q. Okay. All right. So the 15th is when you returned to Bratunac?

13 A. Yes.

14 Q. And what -- about what time would that have been?

15 A. In the afternoon.

16 Q. Okay. Now, once you got to Bratunac, what was your next order?

17 A. We were given time off.

18 Q. All right. How much time?

19 A. To spend the night.

20 Q. All right. And then what? What was your next destination?

21 A. We spent the night, and then the next morning we got into the

22 buses again.

23 Q. All right. And where did you go?

24 A. And went along this road not far from the command of the

25 1st Infantry Battalion in the village of Magasici.

Page 9067

1 Q. All right. And could you please point that out, if we

2 could -- okay.

3 A. Bratunac is here, then this way to Magasici.

4 Q. And that day would have been what day now? You got back to

5 Bratunac on the 15th, what date would you have --

6 A. Well, then it was the next day, the 16th.

7 Q. Okay --

8 A. Probably. And I think that coincides with the date when the

9 1st Infantry Battalion went to Zepa. It remained empty here, and we were

10 given the assignment of being there.

11 Q. Okay. So are you sure it was the next day or could it have been

12 later -- let me rephrase. How many days do you recall resting in Bratunac

13 before going to --

14 A. One night.

15 Q. Okay. All right. And when you got to this area, this location,

16 what were your tasks? What orders were you given?

17 A. We were given the order to stay there until further instructions

18 and orders. And that's what we did, we spent the night there.

19 Q. All right. And could you please put a 16 over there so we know

20 that this is the 16th.

21 A. [Witness complies]

22 Q. All right. Now you said you spent the night there. Before

23 spending the night there -- well, first of all, what time of day did you

24 arrive there?

25 A. We arrived sometime around, or rather, in the -- before noon.

Page 9068

1 Q. Okay. And what did you do once you arrived there?

2 A. Nothing much. We just spread out among the houses, and that's

3 where we were. We were resting up.

4 Q. Okay. So I take it on the 16th you didn't do anything other than

5 rest up?

6 A. That's right.

7 Q. Did you locate any prisoners that day?

8 A. No.

9 Q. Did you see any dead bodies over there on that day, in the area?

10 A. No, no.

11 Q. Did you see any abandoned weapons in that area?

12 A. No.

13 Q. All right. The next day, the 17th, what do you do?

14 A. We spent the night there, one night.

15 Q. Okay. So that was the night of the 16th. So now we're talking

16 about the 17th. What do you do on the 17th?

17 A. In the morning we were told to be ready and that we would be going

18 most probably to some other location.

19 Q. All right. Do you recall where you went the following day -- on

20 that day? What was your next location?

21 A. I assumed the vehicle that was to have picked us up was to

22 supposed to come from the direction of Kravica, but as the vehicle never

23 turned up, we set out on foot and reached Bratunac walking.

24 Q. So you walked back to Bratunac?

25 A. Yes.

Page 9069

1 Q. Could you please tell us what time it was on the 17th that you

2 walked back to Bratunac.

3 A. Well, it was about noon, perhaps a little after noon.

4 Q. All right. On your way to Bratunac -- well, first of all how long

5 did it take you to get there?

6 A. It's quite a long way, 5 or 6 kilometres. It took us a couple of

7 hours.

8 Q. All right. Now, from the place that you set off, okay, on the

9 17th, in which direction would Glogova be? Would it be on the way toward

10 Bratunac or would it be in the opposite direction?

11 A. Towards Bratunac.

12 Q. Okay. Now, as you -- so then I take it as you were walking

13 towards Bratunac you would have passed Glogova?

14 A. Yes. We passed through Glogova, because that's the way the road

15 takes you, through Glogova.

16 Q. All right. Now when you -- could you please point out where

17 Glogova is on the map.

18 A. [Witness complies]

19 Q. You circled that area.

20 A. That's the broader area around Glogova.

21 Q. Okay. Now, when you were going through Glogova, did you notice

22 anything unusual going on over there?

23 A. Yes.

24 Q. Would you please describe to us what it is that you saw.

25 A. When we were moving down from Magasici to the flat land down

Page 9070

1 below, on the way I saw a freight train with a machine, a loader, digger,

2 something big.

3 Q. All right. Do you know where that machine was from?

4 A. I don't know.

5 Q. How close did you go there?

6 A. We passed by that truck, because it was along the whole road.

7 Q. All right. So you would have been near the truck, then,

8 within -- a few metres away, then?

9 A. Yes, we passed by the truck.

10 Q. And did you notice the -- any individuals over there?

11 A. Well, there were a couple of people there around that trailer

12 truck, as if there was something wrong with it and they were waiting for

13 instructions. I didn't ask who.

14 Q. Did you recognise them?

15 A. No.

16 Q. Did you ask them what they were doing there?

17 A. No, I didn't.

18 Q. Did you notice if any digging was going on?

19 A. Well, this truck was standing on the road. It wasn't doing

20 anything.

21 Q. But I'm not asking you whether this truck was doing anything; I'm

22 asking you whether you were able to observe anyone digging anything, off

23 the road?

24 A. No, no.

25 Q. Did you notice any graves, any patches of land that looked like

Page 9071

1 they had been disturbed?

2 A. I didn't notice anything at that time, no.

3 Q. Okay. Did you notice it at another time?

4 A. Later I did, later.

5 Q. Now, when you say "later," are we talking later in the day?

6 A. No, no.

7 Q. All right. Now, what time was it when you got into Bratunac on

8 the 17th?

9 A. We arrived sometime in the afternoon.

10 Q. And after that period, after arriving in Bratunac, did you receive

11 any other orders?

12 A. We were given leave to rest.

13 Q. All right. How much rest were you given?

14 A. A day or two. I think it was more likely to be just one day. In

15 fact, only one night.

16 Q. Okay. And after that where did you go?

17 A. After that we went to Zepa in the late afternoon.

18 Q. Okay. All right. Now, I want to fast-forward to another period,

19 1996.

20 JUDGE LIU: Well, Mr. Karnavas, before you left this map I believe

21 that the witness testified that he spent one night in Bratunac before

22 going there, and we need a number there.

23 MR. KARNAVAS: Okay. All right.

24 JUDGE LIU: And secondly, if you want to tender this document into

25 the evidence, since the witness has already made some marks on this map,

Page 9072

1 we need a new number on it.


3 Q. Can you please put on Bratunac -- I guess this would have been the

4 night of the 17th when you returned to Bratunac. Correct?

5 A. It was probably the 17th, yes. It should be the 17th.

6 Q. If you can put a 17 by Bratunac; I know you already have a 15

7 there. Why don't you put -- why don't you mark 15 --

8 A. [Witness complies]

9 Q. I'm sorry. So that would be 17. Okay. All right.

10 Now --

11 JUDGE LIU: Do we have 15 there?

12 MR. KARNAVAS: Maybe I'm seeing things. We don't. I have it on

13 mine because I put it there.

14 Q. Could you -- okay. I just want to make sure that I don't confuse

15 you any more than I've confused myself. Before -- we have Magasici, we

16 have 16. The night before going to Magasici, you were in Bratunac. Is

17 that correct?

18 A. Yes. Yes. The 15th.

19 Q. So if you could put a 15 as well?

20 A. [Witness complies]

21 Q. Okay.

22 A. Yes.

23 Q. Thank you very much. And I apologise for confusing you. Now,

24 we -- we said that the identification number was D146. We could put

25 it -- we could designate it as D146 bis. All right.

Page 9073

1 All right.

2 MR. KARNAVAS: We don't need the maps anymore.

3 Q. Now, I want to move to another period; I believe it's sometime in

4 1996. Were you still with the Bratunac Brigade back then?

5 A. Yes.

6 Q. Okay. And could you please tell us what kind of position you held

7 at that period.

8 A. After the Dayton Accords, they asked we show the VES -- from the

9 VES -- from the civilian population. And because I had a place in the

10 communications they offered me to take a course and to continue working in

11 communications.

12 Q. Okay.

13 A. I accepted the offer.

14 Q. Okay.

15 A. And on the 20th of February I went for the training course and I

16 returned on the 10th of March. The course was in Zalukovik. And there I

17 was trained for -- and there I was trained to be a specialist in coding

18 and teleprinter communications.

19 Q. Okay. Before we go any further you said "VES." Just so we

20 understand, what is that? What are you referring to?

21 A. V-E-S is what I have been trained to do in the army in which I

22 served.

23 Q. And what does it stand for? What is it exactly? Some of us

24 didn't serve in the army, so we wouldn't know.

25 A. I think it's specialist military training. There's this

Page 9074

1 abbreviation, VES, followed by a number, and there are different

2 specialties such as infantry man, artillery man, rear man, and so on.

3 Q. And your training was in communications after Dayton?

4 A. Yes.

5 Q. Okay. All right.

6 A. I completed a training course and was trained to be a code person.

7 Q. Okay. Now, after your training, where were you working?

8 A. I came to the command of the Bratunac Brigade.

9 Q. All right. Now, when you came back to the Bratunac Brigade, was

10 Colonel Blagojevic still the commander, to your understanding?

11 A. Yes.

12 Q. And could you please tell us during this period of time whether

13 you had any conversations with your commander, Colonel Blagojevic, with

14 respect to any documents that you had located?

15 A. When I arrived in the encrypting service in the brigade command, I

16 found a situation that was not appropriate. I came across something that

17 was not in accordance with the rules.

18 Q. Such as?

19 A. A person was working there who, in my view, was not a serious

20 person. He left documents lying on the desk, in packages, and so on.

21 Q. All right. So what's wrong with that?

22 A. According to the rules, when I, as an encrypter, am given a

23 document by my commander to encrypt and to pass on in code, I take the

24 document, I process it, I write down the date and hour when I received it,

25 when I processed it, when I forwarded it. And then in the records book, I

Page 9075

1 write down when I gave it back to the person who had given it to me.

2 Q. All right. So that's the normal procedure?

3 A. Yes.

4 Q. Okay. And what was wrong with these documents that you just told

5 us?

6 A. The documents should not have been there. They should have been

7 given back to the person who had had them sent.

8 Q. Now, since you had encrypted -- since they were encrypted

9 documents or documents that had been encrypted, would they have been of a

10 sensitive nature, or does every document that's sent out encrypted?

11 A. Every document is encrypted -- well, not necessarily. But as a

12 rule, they were.

13 Q. Okay. So what happened to the -- so when you saw these documents,

14 what did you do?

15 A. I concluded that this was not the proper place for them to be, so

16 I called Colonel Blagojevic and said to him that the documents should be

17 removed from there. He asked me why.

18 Q. And what was your response?

19 A. I told him I didn't want them there because somebody one day might

20 ask me for a document, a document might get lost, they would look for it,

21 be unable to find it. And I said, well, this was not the proper place for

22 the documents to be in the encryption room. There were other places where

23 it was proper for the documents to be, but certainly not there.

24 Q. All right. And what instructions, if any, did he give you?

25 A. No.

Page 9076

1 Q. No, what? Are you saying he didn't give you any instructions?

2 A. He didn't say anything. He said: Well, let them stay here.

3 Q. Did he ever ask you to destroy any documents?

4 A. No.

5 Q. After that, did you bring this matter up with anybody else, that

6 is the documents, these documents, laying around?

7 A. I spoke to the security man, Momir Nikolic, and I put the same

8 question to him.

9 Q. And what was his response?

10 A. Nothing. He also said: Well, let them stay there.

11 Q. All right. Well, did you bring it to anybody else's attention?

12 A. When Momir Nikolic left to take up another business, he was

13 replaced by Lazar Ostojic.

14 Q. All right.

15 A. And I put the same question to Lazar Ostojic, and he replied in

16 the same way.

17 Q. All right. Eventually what happened to all of these documents, if

18 you know?

19 A. Later on Savo Cvjetinovic became the commander, and he didn't take

20 any steps to remove these documents. They were not just lying about in my

21 office; they were lying about everywhere, in every office. Then

22 Major Radic arrived, a commander who I view as a serious person. I said

23 the same thing to him, that the documents should not be in my office, in

24 the encryption room.

25 Q. Okay. And what were the response that you got from this

Page 9077

1 gentleman?

2 A. He issued an order that a team be set up and that these documents

3 be archived by year, and this was done. And in my communications

4 storeroom where the communications equipment was kept, a documents

5 department was set up. Everything was put away in files, 1992, 1993,

6 1994, 1995. There were at least 50 or 60 files.

7 Q. Okay. Who -- did you participate in this endeavour?

8 A. I didn't participate in it. Other people put these documents in

9 binders and archived them and placed them on a shelf in that department.

10 Q. How do you know that?

11 A. I know that because I had the key to the storeroom.

12 Q. Would you please tell us about what period, what time are we

13 talking about, what year.

14 A. All this happened in 1996. I don't know exactly what date it was

15 when the documents were archived or when Major Radic became the commander.

16 But as soon as he arrived, this work was done.

17 Q. Now, do you know what happened to those documents?

18 A. One day the investigators of The Hague Tribunal arrived and asked

19 for access to the headquarters and the offices there, including that

20 storeroom and those documents.

21 Q. Were you still with the Bratunac Brigade or working in those

22 headquarters when the folks from The Hague Tribunal came?

23 A. Oh, yes, yes, I was still there, yes.

24 Q. All right. And what happened when they came and they asked for

25 access to the headquarters and the offices, including the storeroom of

Page 9078

1 the -- and those documents?

2 A. They went through all the offices. They looked in the desks.

3 They took some maps. And finally they arrived at the storeroom where the

4 documents were kept. They opened the binders and then they put them in

5 their boxes.

6 Q. Okay. And so they took them?

7 A. Yes. They packed them in their boxes. They said thank you, and

8 they left.

9 Q. Okay. Now, from the time that they had been put in that storage

10 room to the time that the folks, the investigators, from The Hague

11 Tribunal came, to your knowledge do you know whether any of those

12 documents were ordered to be destroyed?

13 A. I'm not aware of any such thing.

14 Q. Were you ever asked to destroy any documents or hide any

15 documents?

16 A. No.

17 Q. And just finally, who had access to those documents?

18 A. The personnel department, for example, the personnel officer. If

19 he was looking for something from 1993 or 1994 or any year, he could come

20 and take the binder, have a look inside, find the document, look at it,

21 put it back, and so on. Anyone who was sent by the commander could have

22 access.

23 Q. All right. And when somebody would access these documents, was

24 there anybody there to make sure the documents weren't taken away or

25 weren't destroyed?

Page 9079

1 A. As far as I know, only rarely did someone come to make use of

2 these documents. They just stood there and nobody took much account of

3 them. They were practically just collecting dust. But I cannot exclude

4 the possibility that someone came along and took a document out. I was

5 not the only person who had the key to the warehouse.

6 Q. All right. While you were there, did anyone from the Main Staff

7 or from the Drina Corps come along and ask to look at the documents or

8 take any documents?

9 A. I'm not aware of that.

10 Q. Okay. But as far as -- with respect to you, did anybody come to

11 you?

12 A. No.

13 Q. All right. Now, sir, I just want to go back and ask one last

14 question, basically. I want to go back to the days from July 6th to July

15 11th, 1995, when you were up there in Kula and in Pribicevac. Based on

16 what you were able to see, observe, your experience in being in the

17 Bratunac Brigade for two and a half years plus, did you form an opinion as

18 to what extent your commander, Commander Blagojevic, was engaged in what

19 was happening in and around Srebrenica on those days.

20 JUDGE LIU: Yes, Ms. Issa.

21 MS. ISSA: Your Honour, I'm objecting to that. There's no way

22 that this gentleman can answer the question. It's entirely speculative.

23 He's already testified that he didn't know Commander Blagojevic until

24 somebody pointed him out to him at some point. So it's totally

25 speculative. I don't see how he can answer the question.

Page 9080

1 JUDGE LIU: Yes. And especially you asked the opinion of this

2 witness towards his commander at that time.

3 MR. KARNAVAS: Well, I'm asking if he formed an impression, based

4 on what he was able to see was happening. So he's a soldier, he's asked

5 to put his life on the line, he's there for two and a half years. Here

6 you have a commander who comes into his foxhole, basically, looking at

7 maps all day long, nobody's coming to see him, nobody's giving him any

8 orders. Surely this soldier would have formed an opinion.

9 JUDGE LIU: Well, as the witness testified he had worked with

10 Blagojevic later on, so the opinion at that time was somehow influenced by

11 the later experience. I don't think there's any probative value in this

12 question.

13 MR. KARNAVAS: Thank you, Mr. President. I have no further

14 questions.

15 Q. Sir, thank you very, very much. I appreciate your candor and

16 honesty in answering all of my questions. Mr. Lukic might have some

17 questions; he represents Mr. Jokic. The Prosecutor undoubtedly will have

18 some questions, and perhaps there might be some questions from the Judges.

19 And I would appreciate it if you could be as honest and forthright as you

20 have been with me.

21 JUDGE LIU: Thank you.

22 Mr. Lukic, do you have any questions for this witness?

23 MR. LUKIC: No, Your Honour. Mr. Jokic's Defence does not have

24 any questions for this witness.

25 JUDGE LIU: Thank you very much.

Page 9081

1 Ms. Issa?

2 MS. ISSA: Yes, Your Honour, I do have a couple of questions.

3 I'm just wondering if I can borrow the podium, please.

4 Cross-examined by Ms. Issa:

5 Q. Now, sir, you've told us earlier that you went towards -- you left

6 Pribicevac on the 11th of July and you stopped at some point 800 metres

7 down from Pribicevac. Do you recall telling us that?

8 A. Yes.

9 Q. Now, how long were you there at that location before

10 Commander Blagojevic got to your location?

11 A. I don't know exactly, but we didn't stay there long. Maybe after

12 an hour or two, the colonel arrived.

13 Q. Okay. And how did you travel to that location from Pribicevac?

14 Was it on foot or some other mode of transportation?

15 A. This is terrain where you can only go on foot. It's very steep

16 and the path is dangerous. We didn't know what there was down there. We

17 were afraid of an ambush. We didn't know what was going on around us. I

18 even thought we might be misused down there. I had all kinds of thoughts.

19 It was very hard for me.

20 Q. Okay. Thank you. So you got there on foot. Now, you indicated

21 that Colonel Blagojevic arrived approximately an hour or two after your

22 arrival. So obviously he knew that -- where to find you, didn't he?

23 MR. KARNAVAS: Objection.

24 JUDGE LIU: Yes.

25 MR. KARNAVAS: Calls for speculation. "Obviously he knew." It's

Page 9082

1 a bit speculative. We can draw conclusions that he found them, but that

2 he obviously knew where they were, that's a bit speculative.

3 JUDGE LIU: Well, I think it's a quite natural consequence.

4 You may proceed, Ms. Issa.

5 MS. ISSA: Thank you.

6 Q. Can you answer that question, sir?

7 A. Could you please repeat your question. I didn't understand it.

8 Q. Obviously Colonel Blagojevic knew where to find you, since you've

9 told us that he arrived at your location some time after you got there?

10 A. He did arrive, yes. I saw him.

11 Q. Okay. Now, turning to where you told us you spent some time

12 between the 6th of July to the 11th of July in Pribicevac, from your

13 position, sir, were you able --

14 A. Yes.

15 Q. From your position, were you able to observe or see into the town

16 of Srebrenica?

17 A. From Pribicevac, you can just see a small section of Srebrenica.

18 Q. Okay. And did you see any mortar rounds or artillery rounds

19 hitting Srebrenica between that time period, 6 to 11 July?

20 A. No, there was no firing at Srebrenica.

21 Q. You couldn't hear any detonations during that time period coming

22 from Srebrenica?

23 A. No, I couldn't.

24 Q. Well, according to the reports provided by the UN DutchBat at the

25 time, during that time period, sir, there was - and I'll take an example

Page 9083

1 from 6th July - they reported an: "Ongoing offensive launched within the

2 enclave." And it said that: "The Bosnian Serb army used tanks,

3 artillery, mortars, rockets, and they targeted the Bandera triangle, the

4 DutchBat observation posts, and south of the observation posts, the

5 Potocari township."

6 You didn't hear any of that or see any of that?

7 A. No, I didn't see that from Pribicevac; it's impossible to see

8 that. It's a broad concept.

9 MS. ISSA: Just to correct myself, I said the DutchBat. It was

10 actually the UN military observers, Your Honour, for the record.

11 Q. And on the 10th of July, it was reported that the Srebrenica

12 township was undergoing heavy shelling. They recorded figures of 49

13 shells since around 1.00 in the afternoon to 2.00. There was

14 approximately nine rockets that was launched into the town and additional

15 firing. You didn't see any of that either or hear any of those

16 detonations?

17 A. I didn't hear any and it was impossible to hear that or see that

18 from the position I was or notice.

19 Q. Were you aware of the air strikes going on on the 11th of July?

20 A. Yes.

21 Q. Were you aware that it was also reported by the UN military

22 observers that the shelling of Srebrenica has been going on despite the

23 air strikes?

24 MR. KARNAVAS: Your Honour, may I ask the relevancy of this? Is

25 this in dispute? This gentleman has not testified about whether there

Page 9084

1 were strikes in Srebrenica or not. I just don't see the relevancy of this

2 line of questioning.

3 JUDGE LIU: Well, I believe that in the Prosecution's case,

4 especially in the indictment, the indictment alleged that all those

5 shellings created an atmosphere of terror, which is one of the ways to

6 expel the Muslims from that area.

7 Am I right?

8 MS. ISSA: Yes, Your Honour.

9 MR. KARNAVAS: I thought --

10 MS. ISSA: And it speaks to the issue of credibility, of course.

11 JUDGE LIU: Well, you may proceed.

12 MS. ISSA:

13 Q. Were you aware of that, sir?

14 A. Could you repeat the question, please.

15 Q. Were you aware of the constant shelling of Srebrenica on the 11th

16 of July, despite the air strikes?

17 A. I didn't know on the 11th of July. I didn't believe when

18 Srebrenica -- it when Srebrenica fell. I don't know if any member of the

19 Bratunac Brigade knew about that, at least the people I was with, that

20 Srebrenica would fall and that it would be liberated.

21 Q. That wasn't my question, sir. I was asking if you were aware of

22 the constant shelling that occurred on that day. Did you hear it or see

23 it?

24 A. I couldn't see anything from up there, and when planes turned up,

25 I just noticed down there among those century-old trees where you couldn't

Page 9085

1 see anything or hear anything.

2 Q. All right. So during that entire period between 6 and 11 July,

3 it's -- what you're telling us you didn't hear or see any of the

4 explosions coming from the direction of Srebrenica. Is that correct?

5 A. Well, no, I didn't hear them. It was -- there was some work going

6 on to the left and right flank, but not Srebrenica.

7 Q. Now, sir, you testified about a map that Colonel Blagojevic, you

8 observed him during that period looking at. Could you tell whether that

9 map was an artillery plan.

10 A. I don't know what map Colonel Blagojevic was looking at. There

11 was a map, at least that's what I saw. There was a map, but what map it

12 was I really don't know. I can't talk about that because I don't know.

13 Q. Okay. You've also told us that the -- you actually on the 11th of

14 July advanced towards Srebrenica, and you indicated the direction that you

15 went. So my -- right?

16 A. Yes.

17 Q. So my question is: If the commander, the battalion commander,

18 Zekic, said that his unit did not advance a single metre towards

19 Srebrenica until the 13th of July, he would be wrong?

20 A. I don't know what Zekic said.

21 Q. Well, I'm just asking you, sir, if he had said that, would he be

22 wrong, in your view?

23 A. In my opinion -- you mentioned the 13th of July. Is that it? On

24 the 11th of July, we moved from Pribicevac toward Srebrenica.

25 Q. So if he said you hadn't moved until the 13th of July, that would

Page 9086

1 be wrong. Isn't that right?

2 A. On the 11th of July, we moved towards Srebrenica, after Mladic's

3 order.

4 Q. Okay. You also indicated, sir, in your testimony that at some

5 point, I believe you had said it was the 15th, there were buses that

6 arrived and you got on the buses as a means of transport. Can you tell us

7 who arranged for those buses.

8 A. I don't know who organised them, but when we arrived at the petrol

9 station, we waited for an hour or two. The buses turned up. They loaded

10 us up, and then we went off to Bratunac.

11 Q. So you don't know where they came from?

12 A. Well, no, I don't.

13 Q. Did you go to Potocari on the 13th of July?

14 A. No.

15 Q. Were you aware that some of your colleagues from the same company

16 that you worked out of were in Potocari, for example, Milomir Tanasijevic?

17 MR. KARNAVAS: Your Honour, he's not from the same company, number

18 one; and number two, what is the relevance? And she can pose that

19 question when the gentleman comes in the next day or so. What is the

20 relevance?

21 JUDGE LIU: Well, do you have any basis as for this person is from

22 the same company?

23 MS. ISSA: According to the roster, Your Honour. Perhaps I can

24 pose another question first.

25 JUDGE LIU: Yes, please rephrase your question.

Page 9087


2 Q. Sir, isn't Milomir Tanasijevic part of the 2nd Company,

3 3rd Battalion, wasn't he at that time?

4 A. He was - how shall I put this? - disciplinarily subordinated to

5 the 2nd Company, but the company commander was not in command of the

6 transporter. So he could be treated as not belonging to that company, but

7 he was there because that was the best place for that transporter, if it

8 were ever to be used.

9 Q. Okay. But I didn't ask you if he was -- why he was there. I

10 asked you if he was, in fact, part of the 2nd Company, and I understand

11 you're saying he was.

12 A. I don't know whether he was a member of the 2nd Company, judging

13 by the lists. It's not my job to know that.

14 Q. Okay. And you were talking about the transporter just a minute

15 ago, sir. Can you tell us what that is, what you're talking about.

16 A. When from Magasici we set off for Bratunac, we saw the trailer

17 truck in the village of Glogova.

18 Q. Okay. And what does that have to do with Milomir Tanasijevic?

19 A. I don't know. Who said it had anything to do with him? The

20 trailer truck with Milomir Tanasijevic, I don't understand.

21 Q. A moment ago, sir, when I asked you a question about

22 Milomir Tanasijevic, whether or not he was part of the 2nd Company, you

23 said he was there with the transporter, and I'm just trying to understand

24 what you're talking about, what you mean by that.

25 A. I really don't know. I don't understand this.

Page 9088

1 Q. Well, let me just read your answer. You said: "He was a

2 disciplinary subordinated to the 2nd Company, but the company commander

3 was not in command of the transporter, so he could be treated as not

4 belonging to that company, but he was there because that was the best

5 place for that transporter, if it were ever to be used."

6 What did you mean when you said: "He was there because that was

7 the best place for the transporter"?

8 A. Well, somebody told him to be there.

9 Q. When you say "there," what are you referring to?

10 A. Well, that place where that transporter was.

11 Q. What is that place?

12 A. The transporter was at Kula for a time, then it was moved from

13 Kula towards the command at Pribicevac halfway, and that's where it was.

14 It was there while I was at Pribicevac. Well, we moved from Pribicevac on

15 the 11th, I don't know where the transporter went, it, and what happened

16 to it.

17 Q. Did it go to Potocari?

18 A. I don't know. I was down there in the forest.

19 Q. Can you describe the transporter? What is a transporter?

20 A. That transporter was intended in wartime to carry, to transport

21 people, to pull out the wounded, that kind of thing. It was at Pribicevac

22 as a sort of model, a piece of iron that didn't actually serve any

23 purpose.

24 Q. Well, can you describe it for us. You told us what it was

25 intended for. Can you just tell us what it looks like.

Page 9089

1 A. The transporter had caterpillar tracks. It was 3 or 4 metres

2 long, 2 metres wide, approximately. It had a turret. You could put a

3 Browing [as interpreted], put a Browing [as interpreted] weapon,

4 anti-aircraft machine-gun.

5 Q. So what you're talking about --

6 THE INTERPRETER: Browning, interpreter's correction.

7 MS. ISSA: Thank you.

8 Q. So what you're talking about then, just so that it's clear to all

9 of us, is an APC. Is that right?

10 A. Well, yes, an armoured -- an APC with a small window.

11 Q. Okay. Thank you. Just going then to when you passed through

12 Glogova, sir, you said at that time you didn't notice the graves.

13 A. I didn't notice any graves.

14 Q. But you also said later you did notice graves.

15 A. Several months later when I passed by through Glogova. I assumed

16 what that was doing there.

17 Q. Okay. So several months later you saw graves in Glogova?

18 A. Well, once I did see that something was being done there that was

19 unusual.

20 Q. And what did you see?

21 A. I saw the ground -- bare ground, bare soil.

22 Q. Did you see anything else?

23 A. No, I didn't see anything else.

24 Q. Did you see equipment several months later, digging equipment?

25 A. Well, I didn't see any equipment, but afterwards I saw that people

Page 9090

1 had been there and there was a yellow band denoting that place, and not

2 only there, there was several places like that as you pass through

3 Glogova.

4 Q. Okay. Now, when you were there in July, and I believe you said it

5 was the 17th of July, didn't you smell anything unusual when you passed

6 through Glogova?

7 A. No, I didn't notice any unusual smell.

8 Q. During that period, sir, did you pass through Kravica?

9 A. I passed through Kravica when we set out for Zepa.

10 Q. Did you pass by the Kravica warehouse?

11 A. In the bus, along the road.

12 Q. Did you see any bodies there?

13 A. No, I didn't see any bodies.

14 Q. During that period, had you heard of anything occurring at the

15 Kravica warehouse, any killings?

16 A. That some incident had taken place, I did hear about that. We

17 always had a small radio of some kind and we listened to the media,

18 usually Sarajevo radio, and they would inform this happened, that

19 happened. So I can't say that I didn't hear anything; I did.

20 Q. When was that?

21 A. Well, along the road to Zepa and at Zepa and after Zepa.

22 Q. So you heard it on the radio, along with your -- the other members

23 of your unit, that there was an incident at Kravica warehouse. Is that

24 correct?

25 A. Well, not only in Kravica, but the media would report that things

Page 9091

1 happened in Konjevic Polje and elsewhere as well.

2 Q. Okay. And when you're saying that things happened in Kravica and

3 Konjevic Polje and elsewhere, are you referring to the killings that

4 occurred there?

5 A. Well, it said on the radio that there were killings and that

6 before Srebrenica fell, too, that people were being killed. But the media

7 will be the media. Even when nothing was going on in Srebrenica, things

8 happened as broadcast over the radio. We kept hearing about things

9 happening, even when they weren't.

10 Q. So you heard specifically that the Muslims were being killed at

11 the warehouse and in Konjevic Polje and elsewhere?

12 A. From the media, sort of, but specifically I didn't hear that from

13 anyone. But the media did convey reports like that.

14 Q. So the reports they conveyed was that Muslims were killed by

15 members of the army. Is that right?

16 A. Well, I don't know what they conveyed and reported, but generally

17 that the civilians were killed. And we would listen from time to time, or

18 rather, the road to Zepa was a very difficult road. We had to think about

19 our own lives and protecting them. We weren't out on a picnic, you know,

20 so we could listen to things like that. We first of all took those

21 reports with a pinch of salt, the ones we heard over the radio, because we

22 didn't know what was true and what wasn't true. And the media would

23 report and say that fighting was going on around Zvornik, that the Tuzla

24 Corps was attacking, that this was happening and that was happening, but I

25 really don't know.

Page 9092

1 Q. Thank you.

2 MS. ISSA: I have no further questions.

3 JUDGE LIU: Thank you.

4 Well, it's time for a break. Should we break now?

5 MS. ISSA: Yes, Your Honour.

6 JUDGE LIU: We'll resume at 12.00 -- 12.30, I'm sorry.

7 --- Recess taken at 12.04 p.m.

8 --- On resuming at 12.32 p.m.

9 JUDGE LIU: Yes, Mr. Karnavas, any re-direct?

10 MR. KARNAVAS: Very brief, Your Honour.

11 JUDGE LIU: It should be.

12 MR. KARNAVAS: As always.

13 Re-examined by Mr. Karnavas:

14 Q. Sir, I just want to clarify a couple of points. You were asked

15 about shelling, whether from your position you could hear any shelling.

16 And I believe you said something to the effect that there were some -- you

17 could hear activity, at least, from the left and from the right. Was I

18 correct in -- is that what you stated?

19 A. Well, there were battles going on on the left and shooting on the

20 right.

21 Q. And could you hear that?

22 A. Yes, you could hear that.

23 Q. Were you able to observe it?

24 A. Well, as to the right-hand side, you could see that.

25 Q. Now, from your location, did that transporter, the APC, did it

Page 9093

1 fire at all during those days?

2 A. No, it did not fire.

3 Q. Now, you indicated that based on what you were able to see and

4 hear and the activities that were going on, you did not believe that

5 Srebrenica would fall. Would you please tell us why.

6 A. I personally didn't believe that Srebrenica would fall. I didn't

7 believe that Srebrenica could fall.

8 Q. Why is that?

9 A. Because I knew from the intelligence reports that were coming in

10 that Srebrenica was being defended by five brigades, that they had 15.000

11 soldiers under arms.

12 Q. All right.

13 A. And we -- those of us who were attacking, there weren't a lot of

14 us. Not many soldiers had turned up at Pribicevac, just several units

15 from Zvornik and so on. So there wasn't a lot of equipment there. And

16 all the actions led by the Army of Republika Srpska prior to that had been

17 unsuccessful. To quote an example, the attack at Gorazde wasn't

18 liberated, Bihac was attacked and not liberated, Teocak, and so on. Other

19 examples, Krusevo, up there. So that from my point of view, even the

20 greatest optimists, those who wanted to liberate Srebrenica more than

21 anything else couldn't believe that anything like that would ever happen,

22 that Srebrenica could fall at all. And I believe that what could perhaps

23 happen that we could draw closer to Srebrenica perhaps and to apply the

24 principle which was applied in 1994, in May, around Gorazde. Because I

25 asked about that Zvijezda 94, Star 94 operation a lot, because my house

Page 9094

1 was there, so I was interested in learning more about it, in learning what

2 had happened there, how many soldiers had taken part, how many -- how much

3 weapons -- how many weapons were used, so that there was none of that at

4 Srebrenica. There was an attack to the left and a little attack to the

5 right, but Srebrenica is a very broad area. And the lines around

6 Srebrenica, well I don't know. I'm sure that 10 to 15 kilometres around

7 about. That's the circumference. It wasn't tied up, linked up. There

8 weren't enough soldiers. We were dispersed too wide apart and we never

9 knew whether we would be attacked from the front or the back or whether we

10 would reach Pribicevac or whether we'd come across an ambush or a mine --

11 JUDGE LIU: Yes, Ms. Issa.

12 Witness, I'm sorry to interrupt you.

13 MS. ISSA: The answer is becoming nonresponsive at this point,

14 Your Honour. It's just going on and on and on.

15 JUDGE LIU: Yes.

16 Well, Witness, the Defence counsel promised me that his re-direct

17 will be very brief. I hope your answer to his question would be as

18 concise as possible.

19 MR. KARNAVAS: The --

20 JUDGE LIU: We'll let you leave the courtroom as soon as possible.

21 MR. KARNAVAS: Thank you, Mr. President. Okay.

22 Q. Now, let me ask about another question with respect to your

23 commander, Zekic. When General Mladic came and gave you and the company

24 an order to head for Srebrenica, was your commander, Zekic, there?

25 A. Not at Pribicevac, no. At least I didn't see him.

Page 9095

1 Q. Do you know whether your commander told Mladic, after Mladic

2 instructed him to go to Srebrenica, that he needed to get his commander's

3 permission, Zekic's permission, to move on to Srebrenica as General Mladic

4 was ordering?

5 JUDGE LIU: Yes, Ms. Issa?

6 MS. ISSA: Your Honour, there's no foundation for that question,

7 and I don't really see how it arises out of the cross-examination. And

8 it's also quite leading.


10 We also believe that, Mr. Karnavas. That does not give you

11 another opportunity for the direct.

12 MR. KARNAVAS: Your Honour, again, the Prosecutor is trying to

13 suggest that Mr. Zekic lied in court under oath when he said that his

14 people did not move, his troops did not move an inch. It's clear that

15 Mr. Zekic wasn't there. It's also clear from this gentleman that

16 General Mladic ordered members of the Bratunac Brigade --

17 MS. ISSA: Your Honour, it's totally inappropriate for

18 Mr. Karnavas to put his argument at this point. The witness is still here

19 and I think that's a misstatement of the evidence.

20 JUDGE LIU: Well, you may ask some questions along this line.

21 Maybe they are not at the same location or maybe not at the same time.

22 MR. KARNAVAS: All right.

23 Q. Do you know that your komandir tried to locate Zekic to inform him

24 that he had been instructed by Mladic to take the company towards

25 Srebrenica on July 11th, 1995?

Page 9096

1 A. I'm not aware of that.

2 Q. All right. Now, you were asked about media and what you heard and

3 whether you believed it and so on and so forth. Would it surprise you,

4 sir, that since I began representing Mr. Blagojevic, the media has claimed

5 I have been --

6 MS. ISSA: This is totally inappropriate, Your Honour --

7 MR. KARNAVAS: It's not inappropriate and it goes --

8 JUDGE LIU: Well, Mr. Karnavas, I have to know what Ms. Issa is

9 objecting at.

10 MR. KARNAVAS: She hasn't heard the question. I'm entitled to

11 pose the question. The cross-examination was suggesting that what the

12 gentleman was receiving was accurate information from the radio at the

13 time. Now, what I'm trying to suggest in my question is in my

14 representing Mr. Blagojevic, the media from Sarajevo claims that I have

15 been smuggling oil in Bosnia-Herzegovina, so if he knows whether that's

16 accurate. I'm trying to make the point that the media in that part of the

17 world is less than accurate.

18 JUDGE LIU: Yes, Ms. Issa.

19 MS. ISSA: Well, first of all it started off as being a completely

20 leading question. What Mr. Karnavas is suggesting is completely

21 irrelevant to this proceeding, and we know that what the media was

22 suggesting was accurate because there were, in fact, killings that

23 occurred at Kravica. I don't believe that that fact is in dispute at this

24 point.

25 JUDGE LIU: Well, Mr. Karnavas, I don't think your question is

Page 9097

1 totally relevant to this issue. I hope you could drop it.

2 MR. KARNAVAS: Very well.

3 Q. When you said that you were hearing things from the radio, could

4 you give us the exact date as to when you heard what was going on or what

5 had happened in Kravica and from what media.

6 A. I can't know that. I don't know which media, what the radio

7 stations were, what time. I can't really answer that question.

8 Q. Well, could you tell us what month. The incident happened in

9 Kravica warehouse on the 13th of July, 1995. Was it in July? Was it in

10 August? Was it sometime later? Do you know? Can you help us out here?

11 A. As to certain things, I don't even know to this day what I heard

12 and if what I heard was true or how true, I really don't know that to this

13 day, let alone to have learnt something afterwards. I heard that

14 something had happened there, but I don't know what.

15 Q. All right. And finally, did you ever hear anything from the Serb

16 media, from the RS, that proved to be less than accurate?

17 A. I don't know. I didn't hear anything of any interest.

18 Q. Okay. Thank you.

19 MR. KARNAVAS: I have no further questions.

20 JUDGE LIU: Thank you.

21 At this stage are there any documents to tender? Mr. Karnavas?

22 MR. KARNAVAS: Yes, Your Honour. D146, which is the map; and D146

23 bis, which is a copy or a section of the map which the gentleman marked in

24 court during his direct examination.

25 JUDGE LIU: Thank you.

Page 9098

1 Any objections? Ms. Issa?

2 MS. ISSA: No objections, Your Honour.

3 JUDGE LIU: Thank you. This document is admitted into the

4 evidence.

5 Are there any from the side of the Prosecution?

6 MS. ISSA: No, Your Honour. Thank you.

7 JUDGE LIU: Thank you.

8 Well, Witness, thank you very much for coming to The Hague to give

9 your evidence. The usher will show you out of the room. We wish you a

10 pleasant journey back home. You may leave now.

11 THE WITNESS: [Interpretation] Thank you. Thank you, too.

12 [The witness withdrew]

13 JUDGE LIU: Mr. Karnavas, are there any protective measures for

14 the next witness?

15 MR. KARNAVAS: None, Your Honour.

16 JUDGE LIU: Thank you.

17 Are you ready to call him this morning?

18 MR. KARNAVAS: Yes, Your Honour.

19 JUDGE LIU: Thank you.

20 MS. ISSA: I wonder if I just may be excused from the courtroom,

21 Your Honour.

22 JUDGE LIU: Yes, of course.

23 MS. ISSA: Thank you.

24 [The witness entered court]

25 JUDGE LIU: Good afternoon, Witness.

Page 9099

1 THE WITNESS: [Interpretation] Good afternoon.

2 JUDGE LIU: Would you please make the solemn declaration in

3 accordance with the paper the usher is showing to you.

4 THE WITNESS: [Interpretation] I solemnly declare that I will speak

5 the truth, the whole truth, and nothing but the truth.


7 [Witness answered through interpreter]

8 JUDGE LIU: Thank you. You may sit down, please.

9 Mr. Karnavas.

10 MR. KARNAVAS: Thank you, Mr. President, Your Honours.

11 Examined by Mr. Karnavas:

12 Q. Good afternoon, sir.

13 A. Good afternoon.

14 Q. Could you please tell us your name.

15 A. Milan Radic.

16 Q. You may need to speak up a little bit and I'll ask you to speak a

17 little slowly. Could you please tell us your last name letter by letter.

18 A. Milan Radic.

19 Q. And where are you from, Mr. Radic?

20 A. From Bratunac.

21 Q. Where did you grow up?

22 A. In Bratunac.

23 Q. What is the level of your education?

24 A. Secondary vocational school, the building construction stream.

25 Q. Now, did you ever do your military service with the JNA?

Page 9100

1 A. No.

2 Q. Were you -- did you participate in -- during the war activities in

3 Bosnia and Herzegovina back in 1992 and onwards?

4 A. Yes.

5 Q. Could you please tell us when you were mobilised.

6 A. The 5th of July, 1993.

7 Q. All right. And where were you mobilised?

8 A. The barracks was in Han Pijesak.

9 Q. Prior to 1993, did you participate in the Territorial Defence that

10 had been set up in Bratunac as early as 1992?

11 A. No.

12 Q. All right. So when you went to Han Pijesak in 1993, could you

13 please tell us what sort of training you received, if any.

14 A. Yes. I received infantry training, and that lasted a month.

15 Q. And after that, what -- did you receive any further training?

16 A. Yes.

17 Q. And where was that, sir?

18 A. In Han Pijesak.

19 Q. What sort of training was that?

20 A. It was communications.

21 Q. For how long was that training?

22 A. About six months.

23 Q. What was the purpose of that training? What sort of function

24 would you be carrying out after this sort of six-month training on

25 communications?

Page 9101

1 A. This training was to use radio equipment.

2 Q. All right. And after you received your training, where did you

3 serve?

4 A. Close to Han Pijesak.

5 Q. Did there come a time when you left Han Pijesak and moved to the

6 Bratunac Brigade?

7 A. Yes. This was before my term of service expired.

8 Q. And when was that?

9 A. I don't remember precisely what the date was, but it was sometime

10 in August 1994.

11 Q. Okay. So in 1994 sometime at or about August, when you moved to

12 the Bratunac Brigade could you please tell us what position you held.

13 A. I was working in the Bratunac Brigade exchange, communications.

14 And I had shifts near an elevation where we had equipment to maintain

15 communications with the corps.

16 Q. All right. I want to go step by step, and you may need to speak

17 up just a little bit louder. You don't need to shout, but just a little

18 bit louder. First of all, you said that you were working in the brigade.

19 What exactly -- in the headquarters. What exactly were your functions

20 when you were at the headquarters? Please describe them to us.

21 A. I worked on maintaining communications. I would work eight hours

22 in the command at the switchboard, connecting lines at the command level

23 for officers and so on. And then occasionally I was sent up to that

24 elevation where we had that equipment, because I had been trained to use

25 it. If there was no signal, if something broke down, I would be sent up

Page 9102

1 there to maintain the equipment and service it.

2 Q. All right. Now, before we get to the elevation, you said that you

3 were connecting lines. Would you please tell us who you were connecting

4 or what places were you connecting, the Bratunac Brigade headquarters with

5 whom, these places.

6 A. Mainly the switchboard was in the building of the

7 Bratunac Brigade, but it also had lines with the rear men and various

8 officers and so on.

9 Q. All right. What about with the corps of the Main Staff?

10 A. Yes. We did communicate with the corps, but rarely.

11 Q. All right. Now, you talked about this elevation. First of all,

12 where is this elevation physically?

13 A. Physically, it's in the Bratunac area. As the crow flies, maybe 5

14 or 600 metres away.

15 Q. And does this elevation have a name that you could identify it?

16 A. Yes. It's called Kik.

17 Q. Okay. How do you spell that, letter by letter?

18 A. I do apologise. It's K-i-k, Kik.

19 Q. Kik, all right. And at this elevation, at Kik, what is located?

20 A. We had a shack there that we had built, and there was an RU-800

21 [as interpreted] piece of equipment there with a relay connection to the

22 corps.

23 Q. Now, what's an RU-800, just briefly, if you could describe that or

24 tell us a little bit about it so we have a better understanding.

25 A. It's RRU, there are two R's. It's a radio relay apparatus.

Page 9103

1 Q. All right. And what was the purpose for that RRU being there?

2 A. It was reached by a wire connection, and then from it messages

3 were sent in code by teleprinter through a relay connection.

4 Q. And where were these messages sent to?

5 A. They were sent to the corps.

6 Q. All right. Now, was there other activity going on at that

7 location, at Kik?

8 A. Yes.

9 Q. All right. Well, could you please tell us what activities were

10 going on and by whom.

11 A. These were operators using a small piece of equipment, which was

12 also an intercept centre. The operators were from the corps.

13 Q. All right. So -- and I'm going to have to ask you to speak up a

14 little bit louder. But if I understood you correctly, there were

15 intercept operators from the corps working at Kik, at that elevation

16 point. Is that correct?

17 A. Yes.

18 Q. What were they intercepting?

19 A. They could intercept the course of events in the Bratunac area of

20 responsibility.

21 Q. Okay. Well, were they listening in on the Serbs or on the Muslims

22 or the Croats?

23 A. Well, mostly the Muslims. The equipment had a range that was

24 quite big, but for the most part it was the Muslims.

25 Q. All right. Now, did you participate in any of these activities

Page 9104

1 that were going on by these intercept operators from the corps?

2 A. Quite simply, I was there while I was servicing my equipment. If

3 they were not there, if they had gone away for a few minutes, I would

4 respond. That's all.

5 Q. In other words, you would help out?

6 A. Yes.

7 Q. All right. Now, from what you were able to observe while you were

8 up there at that elevation point called Kik, would you please describe to

9 us what would happen to these intercepts, the information that was

10 collected and gathered, what would happen to it?

11 A. They were sent by courier, packed in the normal way, as all the

12 messages were in code. They were sent by courier to the corps.

13 Q. So they were physically sent as opposed to being transmitted in

14 another fashion?

15 A. No.

16 Q. So when you say "no," were they physically taken there by courier

17 or would you send them through the RRU-800?

18 A. They were physically taken there.

19 Q. All right. And where were they taken to, to which department?

20 You said they were taken to the corps; that's Vlasenica, I take it?

21 A. Yes, to the Vlasenica Corps.

22 Q. And who would receive them?

23 JUDGE LIU: Yes, Mr. McCloskey.

24 MR. McCLOSKEY: Objection. There's been several leading, and

25 we're getting to locations and all. It would be better if the witness

Page 9105

1 could give us the locations and how they're gone.

2 MR. KARNAVAS: I'll rephrase.



5 Q. Do you know where the Drina Corps headquarters are?

6 MR. McCLOSKEY: I think we can go on. He's already given that

7 answer.

8 MR. KARNAVAS: Since we're going to be making these sorts of petty

9 objections, I would like to have an answer from the witness.

10 Q. Do you know where the Drina Corps headquarters are?

11 A. In Vlasenica.

12 Q. And do you know where the main headquarters are, the Main Staff?

13 A. I think it was in Han Pijesak.

14 Q. Okay. What about the Bratunac Brigade headquarters, do you know

15 where they were, which city they might have been located?

16 MR. McCLOSKEY: Objection.

17 JUDGE LIU: Yes.

18 MR. McCLOSKEY: The attitude directed in this manner is --

19 MR. KARNAVAS: Well, Your Honour, I'm trying to speed it up, and

20 it's kind of mind-boggling that somebody wouldn't know where the

21 Drina Corps headquarters are when they're sending messages there.

22 JUDGE LIU: Well, it's very obvious where the Bratunac Brigade

23 headquarters is located, isn't it?


25 Q. Where were these messages that were sent off to the Drina Corps,

Page 9106

1 where were they analysed, if you know?

2 MR. McCLOSKEY: Objection on the foundation. There's no

3 indication about any analysis yet.

4 MR. KARNAVAS: If he knows.

5 MR. McCLOSKEY: If this is an important witness, we should do it

6 right.

7 MR. KARNAVAS: I'll rephrase.

8 JUDGE LIU: Yes, please rephrase it.


10 Q. Were those messages decoded, analysed, on spot, in situ, right

11 there in Kik while you were there? Did you ever observe any of that?

12 A. Only once, on one occasion we saw that. But it wasn't anything

13 important.

14 Q. All right. What would happen to these messages? Take us step by

15 step. What's the process? Take your time.

16 A. These messages were not sent. They went by courier. They were

17 not sent by courier, but these lads told me what had happened there. If

18 it was not something important, if they were not speaking in code but

19 normally, they didn't even record those conversations or send them on. It

20 was only if something was in code so we couldn't understand it, that it

21 was taken down, packed, and then sent.

22 Q. All right. Now, when it was taken down, was it taken down in

23 writing or was it actually recorded and a recording was sent? What was

24 actually sent by courier?

25 JUDGE LIU: Yes, Mr. McCloskey.

Page 9107

1 MR. McCLOSKEY: I'm sorry to object, but this is to foundation.

2 So far we've heard that this witness was there -- was stationed in the

3 brigade headquarters, that he occasionally went to this site, did not work

4 on this, and perhaps occasionally helped out, but if he's going to ask

5 these questions that we're all used to from the other intercepts, they

6 need to establish how he knows any of this. We heard a little bit that

7 some lads told him something, but if he was there for any length of time

8 and how he learned, I think before he get into the substance, the

9 foundation is needed so we know what he is basing this.

10 JUDGE LIU: Well, I think the foundation is there. As you said,

11 the witness testified that these lads told me what happened there, so I

12 believe that the testimony of this witness is not the firsthand knowledge

13 but hearsay.


15 Q. Were any messages, to your knowledge, sent to the Bratunac Brigade

16 directly? Just to your knowledge.

17 A. No.

18 Q. Now, what period of time were you filling in, what are the months,

19 in you can recall, that you would go to Kik?

20 A. It wasn't strictly determined, but about once a month I would go

21 and take a shift there.

22 Q. All right. And did you do that all the way until July 1995?

23 A. Yes.

24 Q. Let's move on to another area, since this was not relevant,

25 actually. Let's talk about July 1995. Where were you at the period when

Page 9108

1 Srebrenica -- the events in Srebrenica occurred?

2 A. As I used to go there, as I've said, I happened to be up there. I

3 don't recall the exact date, whether it was the 5th or the 6th or the 4th

4 maybe, I don't know. But my komandir gave me an order to get down from

5 there and to go to the forward command post with the commander.

6 Q. Up there, we're talking about Kik?

7 A. Yes. Yes.

8 Q. And during that period of time, just so we allay any suspense that

9 might be in the air, did you hear any sensitive conversations? Did you

10 participate in intercepting anything sensitive when you were up there in

11 Kik, as you would go on occasion?

12 A. No.

13 Q. Okay. That was just part of your job?

14 A. Yes.

15 Q. Okay. Now, when you got this message -- first of all, you said it

16 was from your komandir. Who was your komandir?

17 A. It was a colonel, Dragan Stojanovic.

18 THE INTERPRETER: The interpreter apologises, lieutenant.

19 MR. KARNAVAS: Okay. All right.

20 Q. And what was the message exactly, what were you to do?

21 A. The message was that I should go to the command to be issued with

22 my instructions, and in the brigade command -- from there I went to

23 Pribicevac by car. I was given a piece of equipment with which to

24 maintain communications with the brigade command. I went together with

25 the commander.

Page 9109

1 Q. Okay. Let's go step by step. First of all, had you been to

2 Pribicevac before?

3 A. No.

4 Q. Did you know what was at Pribicevac?

5 A. No.

6 Q. When you went to Pribicevac at that point in time with your

7 commander, did you know why you were going there?

8 A. No.

9 Q. Now, you said that you were given a piece of equipment, did you

10 recognise that piece of equipment, and if so, what was it?

11 A. Yes, this was a piece of equipment I was trained to use. I was

12 familiar with it. It was a field apparatus, radio relay apparatus.

13 Q. Okay. Could you please describe it to us. Some of us may not

14 have seen such a piece of equipment. So what does it look like?

15 A. This set is called a RUP 12K, which means it has 12 channels. And

16 the range is not significant. It's only used for communications at rather

17 close range with the brigade.

18 Q. Could you give us an estimation of what the range would be.

19 A. I think perhaps some 10 kilometres or so.

20 Q. All right. Does that range -- is that range affected by the

21 terrain in any way?

22 A. Yes.

23 Q. Now, were you linked up with anyone, this piece of equipment?

24 A. Only with the brigade command.

25 Q. And that would be in Bratunac?

Page 9110

1 A. Yes.

2 Q. Were you linked up with any of the commanders of the battalions of

3 the Bratunac Brigade?

4 A. No.

5 Q. All right. What about the Drina Corps, now that we know that it's

6 in Vlasenica, were you linked up with Vlasenica?

7 JUDGE LIU: Yes, Mr. McCloskey.

8 MR. McCLOSKEY: Objection, if he could help us. That's vague.

9 What does linked up mean? It doesn't mean anything.

10 MR. KARNAVAS: I haven't --

11 JUDGE LIU: Yes.

12 MR. KARNAVAS: It will be a long afternoon.

13 Q. Linked up. Were you able to communicate between where you were

14 and the corps in Vlasenica?

15 A. No.

16 Q. All right. Were you able to communicate with the other battalions

17 of the Bratunac Brigade with that piece of equipment that you had?

18 A. Yes, we were. But I did not receive from the komandir any papers

19 with their frequencies. I only had the frequencies of my original brigade

20 in Bratunac.

21 Q. All right. Now, why would you need their frequencies?

22 A. How could I communicate with them if we were not on the same

23 frequency? It would be impossible.

24 Q. All right. Well, can I make this assumption that they had RUPs as

25 well?

Page 9111

1 A. I am not aware of that. I don't know. They may have had one, but

2 I don't know that.

3 Q. All right. Well, could you communicate with this RUP 12K, if they

4 had a Motorola, for instance?

5 A. No.

6 Q. Well, what would they need to have, what kind of a piece of

7 equipment would they need to have with them for you to communicate with

8 them, assuming you had their frequencies?

9 A. Only if they had the same piece of equipment, the RUP 12.

10 Q. Okay. Do you know whether they had that equipment, the battalion

11 commanders, had such equipment with them?

12 A. I said that I didn't know about that, and I really don't.

13 Q. All right. Now, could you communicate -- well, let me back up. A

14 foundational step. Did you see General Krstic while you were up there?

15 A. Yes.

16 Q. Could you please tell us where was he when you saw him.

17 A. When we were put up up there in a house, let's call it the forward

18 command post, he was some 30 metres away from us. There was some tents,

19 and they had their devices and equipment, too.

20 Q. Were you connected, linked up, able to communicate with

21 General Krstic and his communications staff?

22 A. No.

23 Q. Do you know what kind of communication equipment General Krstic

24 had in his IKM?

25 A. No.

Page 9112

1 Q. Did you ever make contact with those individuals, I mean since you

2 were a communications man, I would suspect that maybe some curiosity, did

3 you ever go to speak with them and to see what they had?

4 A. Well, yes. That's my specialty, and I was interested in finding

5 out. And as they had people who were well-versed in that kind of thing,

6 but as the commander did not allow me to do that.

7 Q. Which commander are we speaking about?

8 A. Mr. Blagojevic.

9 Q. So did you ever meet with these individuals and see -- well, first

10 of all, who they were and what equipment they were using?

11 A. No.

12 Q. Now, when you got to Pribicevac, could you please describe to us

13 what you did.

14 A. We were put up there in a room. There were two beds, I think, or

15 one; I don't remember. And a table. And that's where I placed my

16 equipment, adjusted the frequencies, and checked the connection with my

17 brigade in Bratunac.

18 Q. All right. Now, in that building where that room was located with

19 the two beds and the table and where you had set up your equipment, was

20 that the same building that General Krstic and his crew were in?

21 A. No.

22 Q. Who else was in that building, if anyone?

23 A. Well, there might have been two other rooms. I know that in one

24 there was that battalion or the logistics people from the battalion, and

25 there was a bakery. They prepared food there. So I would see people,

Page 9113

1 although I didn't know them. I was never there. Whether they cooked the

2 food, baked the bread there, or whatever, but I would see them around.

3 Q. All right. And once you got yourself set up -- well, first of

4 all, where was Colonel Blagojevic when you were doing all of this?

5 A. Mr. Blagojevic was there with me.

6 Q. Well, how close was he to you? Was he within sight and sound?

7 A. Well, yes. Next to me.

8 Q. All right. And could you please -- before we go on to what you

9 did and what Colonel Blagojevic did, who else was up in that area, that

10 Pribicevac area? You told us there was Krstic, that there were some

11 tents. We know that there is this building that you're in with a bakery

12 and what have you. What else is located physically there, so we can have

13 a pretty good picture?

14 A. Well, where we were there was what I said there was. And just

15 beyond that, maybe some 100 metres away, on a small hill, hillock, called

16 Kula, there were trenches there of that 3rd Battalion.

17 Q. All right. And did you ever visit Kula?

18 A. Yes.

19 Q. By yourself or was Colonel Blagojevic with you?

20 A. Yes. Colonel Blagojevic went with me. That was from time to

21 time. We would go there occasionally.

22 Q. All right. How many days were you up in that area? And

23 let's -- let me just tell you that as a reference point we know that for a

24 fact July 11th is the day that Srebrenica fell.

25 A. Yes. So from that day, I don't remember the exact date, but on

Page 9114

1 the 5th or 6th -- from the 5th or 6th to the 11th.

2 Q. All right. Now, could you please describe to us what you and

3 Colonel Blagojevic did during those days, the 6th, the 7th, the 8th, the

4 9th, the 10th, the 11th. We'll go one by one. On the 6th, what were you

5 able to observe on that particular day, as far as Colonel Blagojevic's

6 movements, since he was within your sight and sound?

7 A. Well, yes. Everything appeared normal. We spent our time there,

8 in that room. There was a mist or fog. We would go outside and take a

9 walk to Kula, go up and see the soldiers. I had some connections there.

10 I took my equipment, and then we would go back to Kula. And we spent our

11 time down there in that room. We would play cards or something or just

12 slept. And on one occasion, I went to sleep on the bed. And

13 Colonel Blagojevic went to sleep resting on the table. And he awoke and

14 was astonished to see me, and I said: "Colonel, why didn't you wake me up

15 from the bed?" He said: "No, no, just you go ahead. Keep on sleeping.

16 No problem."

17 Q. All right. Now, did he ask you to place any calls on that

18 particular day, since you were the communications man?

19 A. No. Just the usual testing of the communication line with the

20 Bratunac Brigade, nothing more than that.

21 Q. Did you receive any calls for Colonel Blagojevic on that day?

22 A. No.

23 Q. On that day did you notice whether Colonel Blagojevic had any

24 meetings with any higher-echelon officers that might have been there on

25 that location?

Page 9115

1 A. No, no.

2 Q. Concretely, did you see him and General Krstic conversing?

3 A. No.

4 Q. Did General Krstic ever come over to that spot or to Kula where

5 you and your commander were to meet and perhaps even speak with

6 Colonel Blagojevic?

7 A. No.

8 Q. What about on the 7th of July, was that any different than the

9 6th?

10 A. No.

11 Q. No contact with General Krstic?

12 A. No, no.

13 Q. Any contact with the battalion commanders, the 1st, the 2nd, the

14 3rd, the 4th?

15 A. No.

16 Q. Any couriers come from the 1st, the 2nd, the 3rd, the 4th, or

17 maybe even General Krstic to pass along any messages, if you are aware?

18 A. No, I'm not aware of that.

19 Q. Okay. Let's move on then to the 8th. Surely something must have

20 happened on the 8th, since nothing happened on the 6th or 7th. Did you

21 notice anything on the 8th?

22 MR. McCLOSKEY: Objection.

23 JUDGE LIU: Yes.

24 MR. McCLOSKEY: Mr. Karnavas is testifying, it also doesn't

25 reflect the reality. This person said he didn't notice things, and

Page 9116

1 Mr. Karnavas is now concluding that nothing happened. I think that's

2 different and so the conclusions are inappropriate based on the testimony.

3 JUDGE LIU: Well, we understand that the witness answered no,

4 means that he was not aware of anything happening.


6 Q. Now, just to make sure, sir, I only want you to see what you saw

7 when Colonel Blagojevic was in your sight and sound for that entire

8 period. Okay.

9 Now, on the 8th did you notice if anyone -- did you notice whether

10 Colonel Blagojevic had contact with General Krstic?

11 A. No.

12 Q. Did you notice whether General Krstic was in that area on those

13 days, on the 8th, for instance?

14 A. I don't remember.

15 Q. All right. Did you -- do you remember whether on that day, the

16 8th, whether there were any messages that came through the communication

17 equipment for your commander?

18 A. No.

19 Q. Did your commander ask you to get through any messages, to pass

20 along any messages, since you were in control over this communication

21 equipment?

22 A. No.

23 Q. Did you -- do you know where your commander spent that day?

24 A. Which day do you mean?

25 Q. Well, the 8th. You know, whether it was at that location or

Page 9117

1 whether you moved to someplace else to pay any visits to any troops or ...

2 A. No. I'm certain that at that day we were at Kula and went back

3 down, had lunch.

4 Q. Okay.

5 A. And that's how the day passed.

6 Q. Now, when you say you went back down, from Kula you went back down

7 to where?

8 A. Well, 100 metres there, to the room we were stationed in.

9 Q. All right. When you went to Kula, what was your commander doing?

10 Based on what you were able to observe now. I don't want you to guess.

11 Don't tell me what somebody else told you, just what you were able to see

12 when he was within your sight and sound.

13 A. He had his map with him. I wasn't right up next to him; I was

14 some 5 or 6 metres away. I was looking for a better signal for our

15 equipment. But I was thereabouts, and what I noticed was that he was

16 becoming acquainted on the map -- actually, he didn't know the names of

17 the hills, so he asked people standing around about or people who were

18 there: "What's this hill? What's its name? What elevation point?"

19 Because this was an area he didn't know.

20 Q. All right. And who was he asking?

21 A. Well, the people who were at that first trench, at Kula. Some

22 soldiers, actually. I don't know them.

23 Q. All right. Well, did you know these elevation points?

24 A. No. I was never there.

25 Q. Well, then you said that you were trying -- you were a few

Page 9118

1 metres -- 5 or 6 metres away and you were trying to get a better signal.

2 Why were you trying to get a better signal? Were you trying to get a hold

3 of somebody?

4 A. No. It was the only contact with the brigade, but it sort of got

5 lost there. So I was looking for a better signal, should they happen to

6 call.

7 Q. Let me make sure that I have it right. When you would go to Kula,

8 would you take your communications equipment with you?

9 A. Yes.

10 Q. So at any point in time, you're next to the commander with your

11 equipment, in case he wants to use it or in case somebody puts in a call.

12 Do I have it right?

13 A. Yes.

14 Q. It's like a backpack?

15 A. Well, in a sense, you could say that, yes.

16 Q. All right. Now, on the next day, on the 9th or the 10th, did you

17 see whether Colonel Blagojevic had any contact with General Krstic or

18 General Zivanovic or any higher-echelon officers?

19 A. No.

20 Q. On those days did he ask you to place any calls, perhaps to issue

21 some orders to the men, to battalion commanders, to his company

22 commanders?

23 A. No, certainly not.

24 Q. Now, on the 11th, were you there in that area for the entire day,

25 or did you leave at some point - we're talking the 11th, the day that

Page 9119

1 Srebrenica fell - if you know?

2 A. Yes. We went from that room up to Kula about -- well, a number

3 of times. We spent the day. We would come back sometime in the

4 afternoon, 2.00 or 3.00. I don't know the exact time.

5 Q. Okay. Now, before we go on as to where you went after that, I

6 just have one question with respect to Momir Nikolic, also known as

7 Penzijica. That's his nickname I understand. Did you know Momir Nikolic

8 at that point? Did you know who he was?

9 A. Yes.

10 Q. Did you know his position within the brigade?

11 A. Yes.

12 Q. Do you recall whether Momir Nikolic ever contacted his commander

13 during that time when you were up there, the 6th, the 7th, the 8th, the

14 9th, the 10th, the 11th, you know, to perhaps pass along some intelligence

15 information, since part of his job was head of intelligence?

16 A. No.

17 Q. Did you ever see him in Pribicevac and perhaps he wanted to have a

18 tete-a-tete, a four-eyes and a four-ears conversation with his commander.

19 Did you ever see Momir Nikolic in Pribicevac during those days?

20 A. No.

21 Q. Now, on the 11th, on the 11th of July, 1995, would you please tell

22 us when you left that area with your commander, at what time, and of

23 course I want to go step by step so we have an accurate accounting as to

24 what happened on that day.

25 MR. McCLOSKEY: Objection.

Page 9120


2 MR. McCLOSKEY: This is leading. He has told this person that he

3 left with him on the 11th and now he's told him again. So I would prefer

4 if we're getting into this that Mr. Karnavas not be the one who is telling

5 this person.


7 MR. KARNAVAS: Very well, Your Honour, maybe I'm tired but I

8 thought the gentleman indicated that they had left. But very well.



11 Q. Did you leave Pribicevac on the 11th or did you stay there the

12 entire time, the entire day?

13 A. We left Pribicevac.

14 Q. What time did you leave Pribicevac?

15 A. As I said, I don't remember the exact time but it was sometime in

16 the afternoon.

17 Q. All right. Could you please tell us: Where did you go to or

18 where were you heading? Let's start with that. Where were you heading,

19 in which direction?

20 A. Well, since we were already there at Kula and our trenches were

21 down there somewhere in the forest, so we were thereabouts when

22 General Mladic came by.

23 Q. All right. And when General Mladic came by, could you please

24 describe to us what you saw, what you heard.

25 A. We were there, and down there you could hear him coming towards

Page 9121

1 Kula. He was shouting something out. And Colonel Blagojevic said to me

2 that we should go to another trench so that -- so we went down a trench

3 further into the forest. That's what we did.

4 Q. All right.

5 A. We went down.

6 Q. And first of all, did you know General Mladic?

7 A. Yes, by sight.

8 Q. All right. And when you moved and Colonel Blagojevic said to you

9 that the two of you should go to another trench, in which direction were

10 you heading, towards General Mladic or away from General Mladic?

11 A. Away from General Mladic.

12 Q. Was there a reason why, if it was expressed to you -- in other

13 words, did Colonel Blagojevic tell you why you should move to another

14 trench?

15 A. Well, not in so many words. The colonel, Colonel Blagojevic,

16 didn't say anything to me, but I had the impression that he would like us

17 to get a little further away from him because he was usually shouting.

18 Q. All right. And did you get away? Did you go further down?

19 A. Not straight away. We were there for a time; however, they

20 started towards us from that first trench, the soldiers who were up there

21 started down towards us, and they said that they had been ordered to move

22 and were moving toward Srebrenica. So they passed by us, and we asked

23 them because we didn't know what was going on at all. So they passed by

24 us and went through the forests. There were quite a number of them as far

25 as I could see, but they were moving downwards.

Page 9122

1 Q. Did they say who had ordered them to go and move towards

2 Srebrenica?

3 A. All they said was that they had received orders.

4 Q. All right. Do you recall whether -- do you know, first of all,

5 whether those soldiers were from the Bratunac Brigade?

6 A. Well, I didn't know them from before, but while we were there,

7 yes, they were.

8 Q. All right. And since you were -- where was your commander,

9 Colonel Blagojevic, at the time when these soldiers went by and said:

10 "We've been ordered to go to Srebrenica"?

11 A. Well, he was just by me.

12 Q. All right.

13 A. Close by.

14 Q. All right. Now, did he ask who had ordered them?

15 A. No.

16 Q. Did you see general -- any other generals at the time when you saw

17 Mladic there?

18 A. Well, as we stayed there at that time, Colonel Blagojevic told me

19 to go and get some food for us from up there because we hadn't had

20 anything to eat. And if we would go -- were to go down to the forest, in

21 view of the situation, that we would have something to eat while we were

22 down there. So I did go up to where we were. He stayed in the forest,

23 Colonel Blagojevic, that is. Because I wanted to take a rucksack of food

24 back down.

25 Q. Okay. Let me stop you here. Now, when you say you were down

Page 9123

1 there and you went up there, where are you located at this point in time,

2 physically speaking? We know where Kula is and you said there was some

3 trenches. At this point in time, where are you physically located?

4 A. From Kula, downwards, down the line, some 50 metres down.

5 Q. Okay. And that's where you first saw the soldiers coming in that

6 direction?

7 A. Yes.

8 Q. Okay. Now, about what time of day is that? Do you remember

9 perhaps from the light in the sky?

10 A. Yes.

11 Q. Do you know what time of day it was, about what time?

12 A. Well, I didn't have a watch on me, but I assume it was sometime in

13 the afternoon, perhaps 2.00 or 3.00.

14 Q. Okay. So you wanted to go back and get some food. Where

15 would -- did you go back?

16 A. Yes.

17 Q. All right. Where did you go?

18 A. The same way that I went to get there.

19 Q. Okay. But did you just go to Kula or did you have to go to the

20 other place where you had the two beds and the table?

21 A. Yes, I went to that other place where we were in the room.

22 Q. All right.

23 MR. KARNAVAS: I see that our time is up. Perhaps we can pick up

24 here tomorrow and continue.

25 JUDGE LIU: Yes.

Page 9124

1 Witness, I'm afraid that you have to stay in The Hague for another

2 day because we haven't finished your testimony. And during your stay

3 here, you have to remember that you are still under oath, so do not let

4 anybody talk to you and do not let anybody talk to you and do not talk to

5 anybody about your testimony today.

6 Well, we'll resume at 9.00 tomorrow morning.

7 --- Whereupon the hearing adjourned

8 at 1.46 p.m., to be reconvened on Wednesday,

9 the 11th day of May, 2004,

10 at 9.00 a.m.