Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15256

 1                           Thursday, 23 June 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

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

 6             JUDGE KWON:  Good morning, everyone.

 7             Good morning, Ms. Gustafson.

 8             MS GUSTAFSON:  Thank you, Your Honour.  I'd just like to raise

 9     one procedural matter before we begin.

10             You'll recall that yesterday, Mr. Karadzic requested time on the

11     basis that he had a number of documents signed by the witness he wanted

12     to show to the witness.  After court yesterday, we were able to finish

13     our review of the cross-examination notification and realised there were

14     no documents signed by the witness on that list.  We raised this with the

15     Defence team yesterday afternoon, and they informed us they'd make

16     inquiries.  We subsequently received, at about 7.00 p.m., a list of six

17     additional documents, and then at 10.00 p.m., a further six documents.

18     Again, none of these 12 documents were signed by the witness.  And then

19     this morning, just a minute or so before court commenced, we were handed

20     a list of documents signed by the witness, only one of which is included

21     in English.  And obviously this raises concerns for us, as the accused

22     appeared to be aware that he was planning to use these documents at least

23     at some time during the court session yesterday, if not before, and this

24     late notice puts us in a difficult position.  And there doesn't seem to

25     be any justification for it in this instance.  Thank you.

Page 15257

 1             JUDGE KWON:  Mr. Karadzic or Mr. Robinson.

 2             THE ACCUSED: [Interpretation] I do admit, indeed, that due to the

 3     rhythm that we have, we have disrupted the order of the steps taken.  But

 4     please do understand us.  This is too important a witness.

 5             The rhythm of witnesses is such that we have two witnesses a day,

 6     and in view of our resources, that is quite a lot.  But, anyway, there

 7     seems to have been something wrong in our order of steps.

 8             Maybe Mr. Robinson would like to add something to this.

 9             MR. ROBINSON:  Well, Mr. President, the first thing I should

10     offer is an apology to the Prosecution for not providing these documents,

11     because it should have been done.  And I don't think -- it is a fast

12     pace, and we're buried with new disclosure.  But, nevertheless, that's a

13     step that should have been taken, and I apologise on behalf of our team.

14             JUDGE KWON:  And I take it that you mean to make vigorous effort

15     to comply with the disclosure practice.

16             MR. ROBINSON:  Yes, as much as humanly possible.  And we'll

17     consider this the Prosecution's first motion for disclosure violation.

18     They're 51 behind us.  But we do apologise.

19             JUDGE MORRISON:  I thought Dr. Karadzic might have raised that

20     himself, but he was far too polite to do so.

21             JUDGE KWON:  We'll proceed.

22             Thank you, Ms. Gustafson, for your information.

23             Mr. Karadzic.

24                           WITNESS:  ASIM DZAMBASOVIC [Resumed]

25                           [Witness answered through interpreter]

Page 15258

 1             THE ACCUSED: [Interpretation] Thank you, Your Excellencies.

 2             Good morning to all.

 3                           Cross-examination by Mr. Karadzic: [Continued]

 4             MR. KARADZIC: [Interpretation].

 5        Q.   Good morning, General.

 6        A.   Good morning.

 7        Q.   Once again, I kindly ask for your understanding and I apologise,

 8     General.  I'm going to go through a number of documents very quickly.  It

 9     will be sufficient for you to identify them as your own.

10             1D3729, please.

11             It seems not to be in e-court yet.  Could I please ask the Usher

12     to place this on the ELMO.

13             While we're waiting:  General, where were you from August

14     until -- I mean from August 1993 until January 1994?  Were you in

15     Sarajevo?

16        A.   Yes, I was in Sarajevo.  But in the meantime, I was out in the

17     field for a while in the area of responsibility of the 6th Corps.

18        Q.   Thank you.  Do you remember this document?  You confirmed this

19     yesterday, but I would like the Trial Chamber and the other participants

20     to have this.  What you stated here are where the positions -- or,

21     rather, where the commands are, and you say that units want to have

22     submitted -- could you -- is this a document of yours, providing

23     information about where the corps and brigade commands are?

24        A.   Yes.

25             THE ACCUSED: [Interpretation] Thank you.

Page 15259

 1             Can this be admitted?

 2             JUDGE KWON:  Is this signature yours, General?

 3             THE WITNESS: [Interpretation] It's my signature.

 4             JUDGE KWON:  Did you bring this document with you?  Thank you.

 5             THE WITNESS: [Interpretation] No.

 6             JUDGE KWON:  Thank you.

 7             This will be marked for identification, pending English

 8     translation.

 9             THE REGISTRAR:  As MFI D1385, Your Honours.

10             THE ACCUSED: [Interpretation] Thank you.

11             1D3721, could we have that on the ELMO, please.

12             MR. KARADZIC: [Interpretation]

13        Q.   Do you remember, General, that Mr. Izetbegovic, on the 4th of

14     April, in the evening, declared a general mobilisation of the

15     Territorial Defence and the reserve police, or, rather, those forces that

16     he could issue orders to?

17        A.   I remember that, but I cannot recall the exact date.  Well,

18     that's it, anyway.

19        Q.   Thank you.  On the 5th of April, General Kukanjac responded.  Do

20     you agree that this is an order for general mobilisation of all wartime

21     units from the 2nd Military District?  And it says here that they should

22     be manned, and if some do not respond to the call-up, that others should

23     be called up straight away.  He also says that the courier system should

24     be used; right?

25        A.   Yes.  I looked at this document on several occasions.  I had an

Page 15260

 1     opportunity to see it earlier on.  But I personally heard -- that is to

 2     say, I heard myself that when this mobilisation takes place, it is going

 3     to be the mobilisation of the Serb people.  I heard that from

 4     Colonel Gagovic, I heard that in the command of my 216th Brigade.

 5        Q.   Thank you.  Is this the stamp of the 2nd Military District, and

 6     is this the signature of General Kukanjac?

 7        A.   Yes.

 8        Q.   Thank you.  Tell me, General, did you know that as for this

 9     mobilisation of the 4th of April, the Serbs would not respond, and that

10     Mr. Koljevic and Professor Plavsic voted against it and asked people not

11     to be mobilised?

12        A.   No, I didn't know about that, and I think it's a good thing if

13     that was so.

14             THE ACCUSED: [Interpretation] Thank you.

15             Can this be admitted?

16             JUDGE KWON:  Yes, Ms. Gustafson.

17             MS. GUSTAFSON:  Thank you, Your Honour.

18             Obviously, there's no translation of this at this point, but I'd

19     just like to add that at line 17, Mr. Karadzic's statement that on the th

20     of April, General Kukanjac responded appears to be just comment by

21     Mr. Karadzic, rather than a reflection of the document.  Thank you.

22             JUDGE KWON:  Thank you.  That is noted.

23             We'll mark it for identification.

24             THE REGISTRAR:  As MFI D1386, Your Honours.

25             THE ACCUSED: [Interpretation] Thank you.

Page 15261

 1             MR. KARADZIC: [Interpretation]

 2        Q.   General, could I ask you to look at 1D3724.  It's possible that

 3     you may have written it in your own hand.  24, 3724.

 4             Do you remember this document?  Is this your signature there?

 5        A.   I can't see the document yet.  You'll have to wait a bit.

 6             Yes, this is my signature, and this is my handwriting.

 7        Q.   Does this say that you are postponing the sending of units from

 8     the area of the 1st Corps to the region of Bradina for the next 48 hours,

 9     and that the Command of the 6th Corps is going to inform the Main Staff

10     and the 1st Corps when conditions are created for taking in this unit?

11        A.   Yes, that's right.  I wrote this personally.

12        Q.   Thank you.  Can you tell the Chamber how units from Sarajevo,

13     from the city, arrived in Bradina, and can you tell them where Bradina

14     is?

15        A.   Bradina is on the road between Sarajevo and Konjic; that is to

16     say, north of Konjic about 10 kilometres.  The units from the 1st Corps

17     that went to these areas went via Mount Igman, Pazaric, the Ivan Sedlo

18     Pass, and --

19             THE INTERPRETER:  The interpreter did not hear the last place.

20             MR. KARADZIC: [Interpretation] Thank you.

21        Q.   My question is how they got out of the city.  First across the

22     runway and then through the tunnel; right?

23        A.   They could not leave through the runway because this is the 30th

24     of November, 1993, when the tunnel was open.  If they did leave, they

25     went from the area of responsibility of the 104th Brigade from Hrasnica

Page 15262

 1     or some other units of the 1st Corps outside Sarajevo.

 2        Q.   Thank you.  When the tunnel was open, did the units take turns?

 3     Did they leave Sarajevo from each brigade, say one battalion went, or

 4     another unit, to the zone of the 14th and 16th Division?  Previously, it

 5     was the operational groups.  That was regularly, on a one-month basis

 6     that these unit left town and stayed out of town?

 7        A.   They did stay there, but there wasn't a system involving that it

 8     was every month, every 10 days or every 15 days.  The units went when

 9     necessary and according to developments on the ground.  If the situation

10     required that, then sometimes several units went.  If not, then units did

11     not even leave Sarajevo.  So that was the practice after the tunnel was

12     opened.

13             THE ACCUSED: [Interpretation] Thank you.

14             Can this be admitted?

15             JUDGE KWON:  We'll mark it for identification.

16             THE REGISTRAR:  As MFI D1387, Your Honours.

17             THE ACCUSED: [Interpretation] 1D3731.

18             [In English] There is translations, too.

19             MR. KARADZIC: [Interpretation]

20        Q.   Is this your signature, and is this a certificate stating that in

21     the family house of Mehmedalija Ramic, in Laticka 30, in the time between

22     the 28th of July up until the 15th of October, 1992, the Command of the

23     1st Sandzak was stationed there and its command post was there as well.

24     Is something missing here?

25             JUDGE KWON:  Ms. Gustafson.

Page 15263

 1             MS. GUSTAFSON:  I was just going to ask if the English could be

 2     put at the same time on the ELMO so that others could follow, because

 3     this one actually --

 4             JUDGE KWON:  Why don't we give the B/C/S version to the witness

 5     and put the English translation on the ELMO.  I take it the accused has a

 6     B/C/S version on his own.

 7             Yes.  What is your question, Mr. Karadzic?

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Was this command, indeed, in this private house in Stup, so was

10     this true, and was this house mobilised according to the Law on national

11     defence, All People's Defence, where by state organs have the right to

12     use privately-owned and socially-owned property, enterprises, private

13     homes, et cetera?

14        A.   This is the first time I see this document.  It's not my

15     signature.  Somebody signed on my behalf.  To tell you the truth, there

16     were private houses that were used by the soldiers, in practice, but I

17     don't know where this house is and I don't know what this was all about.

18             JUDGE KWON:  Just a second.  Put the original on the ELMO again.

19             Yes.  Please proceed, Mr. Karadzic.

20             MR. KARADZIC: [Interpretation]

21        Q.   Yes.  It says here "For Asim Dzambasovic," you're right.  Who was

22     this?  Can you recognise the signature?  It must be a co-worker of yours.

23        A.   I think it's my operations officer; I think.  I'm not sure now.

24     Because I think he is also from Sandzak, Sabro Haskovic.  I don't know

25     whether this is his signature.  I don't know who it is, but it is one of

Page 15264

 1     my associates.

 2        Q.   The number and the date are all in good order; right?

 3        A.   That's correct.

 4        Q.   Now I'd like to ask you the following:  According to the Law on

 5     All People's Defence, did the state have the right to mobilise property

 6     for defence purposes by issuing such orders, such certificates as well?

 7        A.   The state had the right to mobilise them if they weren't being

 8     used.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can this be admitted?

11             JUDGE KWON:  Yes.

12             THE REGISTRAR:  As Exhibit D1388, Your Honours.

13             THE ACCUSED: [Interpretation] The witness said that they had the

14     right to mobilise privately-owned and state-owned property if it was not

15     being used; houses.

16             MR. KARADZIC: [Interpretation]

17        Q.   Is that right?

18        A.   Yes, precisely.  If a company has certain buildings and is not

19     using them at that moment, then that area could have been mobilised.  Or

20     if a private individual, for any reason, was absent and was not using his

21     or her own home, that could be mobilised as well.

22             THE ACCUSED: [Interpretation] Thank you.

23             Can we now have 1D3732 on the ELMO.

24             MR. KARADZIC: [Interpretation]

25        Q.   Remember that they sent to the zone of the Joint Command of

Page 15265

 1     Konjic, I mean, to reorganise this operations group, or whatever it was;

 2     right?

 3        A.   That was my first task in the then Republican Staff of the TO, so

 4     I was given the task to work in Konjic on the organisation of the

 5     Territorial Defence.  So it was my first task in the area of Konjic.

 6        Q.   Thank you.  And that was already the beginning of May 1992;

 7     right?  That's when the Joint Commission was set up, and you were sent

 8     there to put things in order.  It says here "Asim Dzambasovic."

 9        A.   Yes, but this is a joint command, actually.  I formed a joint

10     command of the TO and the HVO.

11        Q.   Thank you.  I would just like to ask you the following:  Do you

12     know about this diagram?  Did you create it, was it created on the basis

13     of your orders, or does it show the usual relationship between military

14     commands and civilian authorities; the Presidency of the BiH, and on the

15     one side there is the Main Staff of the TO, and on the other, the

16     Republican MUP, and then further down the War Presidency, and so on?  Is

17     this the usual schematic on the basis of the Law on All People's Defence?

18        A.   I did not draft this schematic.  It was done by someone from the

19     TO Konjic.  I personally think that this was done in the case against

20     Zejnil Delalic here.  I feel as if I had an opportunity to see it, but

21     this is not my diagram.  They refer to my name here, saying that I

22     participated in this, and I can tell by that, too, that I did not draft

23     this schematic.  But I didn't draft it, anyway.

24             THE ACCUSED: [Interpretation] Thank you.

25             JUDGE KWON:  Where do we see the general's name in this document?

Page 15266

 1             THE ACCUSED: [Interpretation] The third paragraph.

 2             JUDGE KWON:  Yes, I found it.

 3             Mr. Karadzic, when you read out something, please slow down.  And

 4     I ask you, General Dzambasovic, to put a pause before you start answering

 5     the question, for the benefit of the interpreters.  Thank you.

 6             Let us proceed, Mr. Karadzic.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   It says here:

 9             "The Joint Command was the result of the agreement reached

10     between the municipal leadership and the leadership of the Municipal

11     Staff of the TO and the HVO."

12             In your response, it was not recorded in the transcript that this

13     was the Joint Command of the TO and the HVO Konjic.

14             And it says further on:

15             "The co-ordinator from the Republican Staff of the TO of the BiH,

16     Asim Dzambasovic, insisted on that."

17             And so on and so forth.

18             Is this a usual type of schematic?  Is this the way things were

19     established in Konjic and also in other municipalities, more or less?

20        A.   As far as communications are concerned, or, rather, their chain

21     of command, it is customary in the TO.  As for the HVO chain, it's

22     probably the case as well, but I'm not aware of all the details.

23             THE ACCUSED: [Interpretation] Thank you.

24             Can this be admitted, or, rather, marked for identification?

25             JUDGE KWON:  Yes, Ms. Gustafson.

Page 15267

 1             MS. GUSTAFSON:  Your Honour, we object to the admission of this

 2     document on two bases.  First, it appears to be irrelevant, as it relates

 3     to the command structure of a location in Central Bosnia that has nothing

 4     to do with this case.  And, secondly, as far as I've been able to gather

 5     in the last five minutes, it comes from a book, it's a page out of a

 6     book.  It's not a contemporaneous document.  And as the witness's answers

 7     make clear, he's not really able to confirm much, if any, of the contents

 8     of the document, so its reliability is also questionable.

 9             THE ACCUSED: [Interpretation] May I answer?

10             JUDGE KWON:  Yes.

11             THE ACCUSED: [Interpretation] The witness confirmed that this is

12     a customary schematic.  What I'm interested in here is the following, and

13     I believe that it will be useful for the Trial Chamber, is the links

14     between the Presidency of Bosnia-Herzegovina, the War Presidency of the

15     municipality, the MUP, the Territorial Defence, and so on.  It is clear

16     that General Dzambasovic - I believe that he was a colonel at the time,

17     or lieutenant-colonel - was sent there to get things in order.  That was

18     his primary task.  And if he did not draw the schematic himself, this

19     schematic instructor was derived from his work in the field.  That is the

20     reason.

21             I haven't read the entire book, but this schematic or diagram can

22     be a document in its own right.

23             JUDGE KWON:  I'm still struggling to understand the relevance of

24     this document, and we are not sure about the provenance of this document.

25     Until then, we'll mark it for identification.

Page 15268

 1             THE REGISTRAR:  As MFI D1389, Your Honours.

 2             THE ACCUSED: [Interpretation] Thank you.

 3             1D3722, can we have that, please.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Is this also your document, in which you ask that they inform you

 6     about the decision on grouping units on the Igman front-line?  Can you

 7     tell us, briefly, what it was that you asked for here?

 8        A.   Yes.  This is my document that I signed as the chief of staff.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can this be admitted?

11             JUDGE KWON:  Did he answer as to the question what it was about?

12             THE WITNESS: [Interpretation] No.

13             JUDGE KWON:  Could you tell us, briefly, about it?

14             THE WITNESS: [Interpretation] We are asking our units at Igman to

15     provide us with information about the area of responsibility of each of

16     the tactical groups and their tasks, about the names of the units in the

17     AOR, from the lowest-ranking up to the level of the brigade, and,

18     finally, the lines of defence.  This "P/K" means "Forward End," it's an

19     abbreviation.  And also the facilities where those units are located.

20     And then there is a remark at the end stating that this information is

21     essential in order to be able to maintain the working map and to follow

22     the situation in the field.  That is the gist of it.

23             JUDGE KWON:  Thank you.

24             THE ACCUSED: [Interpretation] Thank you, General.

25        Q.   So is this close to Sarajevo, on Mount Igman, above Hrasnica?  Is

Page 15269

 1     that the army -- is that where the army is?

 2        A.   This is south of Sarajevo --

 3             JUDGE KWON:  Yes, Ms. Gustafson.

 4             MS. GUSTAFSON:  I was just going to ask for -- I mean, I can't

 5     read the document, but I was just going to ask for more clarity in the

 6     question.  I don't understand what he meant by "is this close to

 7     Sarajevo."

 8             JUDGE KWON:  Probably the witness understood.

 9             Could you answer the question, and we'll see.

10             THE WITNESS: [Interpretation] I understood that I was supposed to

11     confirm or not whether the units in the area were south of Sarajevo, at

12     Hrasnica, on a plateau of Mount Igman.

13             MR. KARADZIC: [Interpretation]

14        Q.   And they are part of the 1st Corps of the

15     Pazaric Tactical Group which was later the 14th Division; is that

16     correct?

17        A.   Yes.  These names changed, depending on the period, depending on

18     the organisation and reorganisations that were conducted during

19     1992-1995.

20             THE ACCUSED: [Interpretation] Thank you.

21             Can this be tendered, please?

22             JUDGE KWON:  Yes, that will be marked for identification as

23     Exhibit D1390.

24             THE ACCUSED: [Interpretation] Can we have 1D3730 now on the

25     screen, please.  There is a translation.  Perhaps we can just look at the

Page 15270

 1     signature first, and then the original can be given to the general, and

 2     the translation can be put on the ELMO.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Is this your order of the 2nd of January, 1993, where you say

 5     that:

 6             "The Stup Tactical Group will provisionally organise the defence

 7     of the following axes:  Main forces, Valter Peric - Petlja-Cenex, and in

 8     the auxiliary forces axis along Laticka Street Monastery."

 9             Is this all urban combat?  Is this all in the city?

10        A.   Yes, it is, and this "G/S," that means the main force would be

11     organising the defence along the axis, and they are stated.  And then

12     "PS" is "pomocne snage," auxiliary forces, along the Laticka Street,

13     Monastery Street.

14        Q.   Thank you.  And now it says here what should be defended from

15     Nedzarici and Kasindolska Street, and losses should be inflicted and

16     conditions created to carry out broader offensive combat operations.

17             Is that correct?

18        A.   Yes, this is normal military operation.

19        Q.   General, could you tell us, please, what was the military

20     objective in the Sarajevo AOR?

21        A.   The priority military objective was defence, and then to create

22     conditions in any way, along any axis out of the encirclement to break

23     through, to break out of the siege -- out of the besieged town.  But

24     these were a little bit unrealistic, these wishes, because in order to do

25     it -- and this is the most difficult action in military tactics, to break

Page 15271

 1     out of an encirclement, out of a siege.  In order to do that, you had to

 2     secure a ratio of forces, according to some theoreticians, a ratio of

 3     forces and equipment 7:1.

 4        Q.   And are you able to tell us what was the military objective in

 5     the entire Bosnia and Herzegovina?

 6             JUDGE KWON:  Just a second.

 7             Before that, while the transcript shows the page:  In your

 8     previous question, did you not refer to urban fighting or something to

 9     that effect?  I don't think that's reflected in the transcript.  Could

10     you check it?

11             THE ACCUSED: [Interpretation] Thank you, Your Excellency.

12             I was asking that the first item in the order, the deployment of

13     the forces in the streets, whether that was preparation for urban combat,

14     and even the streets were mentioned.  And the witness confirmed that, did

15     he not?

16             THE WITNESS: [Interpretation] Yes, this area is part of the city

17     of Sarajevo, the southern section of Sarajevo.

18             MR. KARADZIC: [Interpretation] Thank you.

19        Q.   And what was the military objective of the political leadership

20     of Bosnia and Herzegovina in relation to the whole of Bosnia and

21     Herzegovina, not to upset those from Herzegovina?

22        A.   Well, that is something that is known to everyone.  The goal of

23     the Army of Bosnia and Herzegovina was to defend the territory of Bosnia

24     and Herzegovina and to liberate territories under the control of the Army

25     of Republika Srpska.  This is clear.

Page 15272

 1             THE ACCUSED: [Interpretation] Thank you, General, and it's a

 2     military goal.

 3             I would like to tender this, please.

 4             JUDGE KWON:  Yes, Ms. Gustafson.

 5             MS. GUSTAFSON:  No objection.  It appears to be simply comment by

 6     Mr. Karadzic on that at line 21 and 22.

 7             JUDGE KWON:  This will be admitted.

 8             THE REGISTRAR:  As Exhibit D1391, Your Honours.

 9             THE ACCUSED: [Interpretation] Can we now have 1D3723, please.

10             JUDGE KWON:  The previous was Exhibit D1391.

11             MR. KARADZIC: [Interpretation] Thank you.

12        Q.   Do you remember this report about the situation on the front in

13     Bosnia and Herzegovina on the 19th of September, 1993?  And we will see

14     later that that was your signature?

15        A.   Well, yes, probably.  I haven't seen it yet.

16        Q.   We can see here in the area of the 1st Corps, assault defence,

17     intense traffic on the route of Pale-Vogosca-Vojkovici-Kasindol-Vraca.

18     These are all areas in Sarajevo; is that right?  Relief of units at

19     Igman.

20        A.   In the area of Sarajevo:  We have suburban areas of Sarajevo,

21     Vojkovici, Kasindol, Lukavica.  Vraca is a part of the central area of

22     town.  Rajlovac and Reljevo are suburban neighbourhoods.

23        Q.   Are these neighbourhoods under the control of the Army of

24     Republika Srpska, and are they inhabited, as a rule, by Serbs, majority

25     population?

Page 15273

 1        A.   Pale has a majority Serb population.  Vogosca was a neighbourhood

 2     with a Muslim majority population.

 3        Q.   Well, can I just ask you this:  Did the side in Vogosca control

 4     the Serbian side of Vogosca, and the Muslim side controlled the Muslim

 5     part of Vogosca, such as --

 6             THE INTERPRETER:  And the interpreter did not manage to hear all

 7     of the names of the areas in Vogosca that the accused mentioned.

 8             JUDGE KWON:  Just a second, General.

 9             The interpreters couldn't hear them all.

10             MR. KARADZIC: [Interpretation]

11        Q.   Is it correct that in Vogosca, the Muslims controlled mostly the

12     Muslim areas and Serbs controlled mainly the Serb areas, and, for

13     example, Ugorsko as a Muslim settlement, was under the control of the

14     Muslims; that Gornji and Donji Hotonj was under the control of the

15     Muslims, that Kobilja Glava, all of these are parts of the Vogosca

16     municipality, but with a strong concentration of the Muslim population

17     and was this not controlled by the Muslims?

18        A.   Yes, for the most part.  It was more or less like that,

19     practically, on the ground.

20        Q.   All right.  Can I just summarise?  Is it correct that Vojkovici,

21     Kasindol, Lukavica, Vraca, Rajlovac and Reljevo were practically

22     100 per cent Serb?

23        A.   Well, I don't know if it was 100 per cent.  All the locations

24     that you referred to are ones with a majority Serb population, except

25     Vraca, where I really don't know what the ratio was.  I think there were

Page 15274

 1     both Serbs and Muslims there.

 2        Q.   And then here you summarise the situation in other areas; 2nd,

 3     3rd, 4th Corps.

 4             Could we look at the last page, please.

 5             [In English] Could we get the last page, the next page, please.

 6             [Interpretation] Is this your signature and stamp of the

 7     Main Staff of the Command?

 8        A.   Yes, it is.

 9        Q.   General, sir, this was sent to the president of the Presidency,

10     the vice-president -- the deputy prime minister, the Ministry of Defence,

11     and the deputy commander, Mr. Siber, and the archives.  How did your

12     service draft a report like this, let's say this report; on the basis of

13     what?

14        A.   Just like any other military personnel, this type of report was

15     drafted on the basis of reports from our subordinate commands and units.

16        Q.   Thank you.  So the reports were sent up from companies,

17     battalions, to brigades, the brigades to corps, and the corps then sent

18     reports to you, if I'm not mistaken, to the Staff of the Supreme Command;

19     is that right?

20        A.   Well, in order to make it easier to understand, reporting

21     proceeds up the chain from the lowest-ranking to the highest-ranking

22     unit.  Command or ordering proceeds the opposite way from the top-ranking

23     bodies to the lowest-ranking units.

24             THE ACCUSED: [Interpretation] Thank you.

25             Can this be admitted, please?

Page 15275

 1             JUDGE KWON:  Yes, Ms. Gustafson.

 2             MS. GUSTAFSON:  Thank you, Your Honour.

 3             I understand this will be MFI'd, pending translation.  If we

 4     could just also reserve any other observations that we might have, as

 5     this is a lengthy document and we're not able to comprehend the contents

 6     at this time.

 7             JUDGE KWON:  Very well.  We'll mark it for identification.

 8             THE REGISTRAR:  As MFI D1392, Your Honours.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can we now have 1D01207.  I think this is in e-court.  There is a

11     number.  Just a little bit of patience.  Perhaps it would be better,

12     while the Usher is still close to the ELMO, to look at the documents that

13     we can still look at on the ELMO.

14             1D3728, please, can we have that.

15             MR. KARADZIC: [Interpretation]

16        Q.   Is this something that you drafted, the list of the Command for

17     Operative Affairs?  You are the chief of that command, and this is your

18     document.

19             Can we now look at 1D3725 --

20             THE INTERPRETER:  The interpreters note the previous document was

21     the list was the members of the OP Administration on the 9th of September

22     1994.

23             JUDGE KWON:  We didn't hear an answer from the witness.  Did you

24     answer the question, General?

25             THE WITNESS: [Interpretation] I did answer, yes.  This is the

Page 15276

 1     list of my administration at the Kakanj Command Post.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   This is the Administration for operations Planning, at whose head

 4     you were?

 5        A.   Yes, that is correct.

 6        Q.   And it worked and serviced the whole of the B and H Army?

 7        A.   That is one of the administrations of the General Staff.  And, of

 8     course, our activities covered all the units subordinated to the

 9     General Staff of the B and H Army.

10        Q.   Thank you.

11             JUDGE KWON:  Yes, we'll mark this for identification.

12             THE REGISTRAR:  As MFI D1393, Your Honours.

13             THE ACCUSED: [Interpretation] Can we now have 1D3725, please.

14             [In English] 3725.

15             MR. KARADZIC: [Interpretation]

16        Q.   Is this a request of yours to have information provided to you

17     about an analysis of sabotage operations by Spahica Farm and Jusic base?

18     Since you were not satisfied, you thought that these operations were not

19     successful; correct?

20        A.   This is correct, that I'm asking for an analysis of these

21     operations.  That is to say, I am addressing the Command of the 1st Corps

22     with a request for them to carry out a detailed analysis and to explain

23     the actual situation to us.

24        Q.   In the second paragraph, it says that you have some information

25     that they were not exactly successful because of poor organisation of the

Page 15277

 1     co-ordination involved?

 2        A.   That is what is written here.  I cannot recall now, but that is

 3     what is written in the second paragraph.

 4        Q.   Where is Spahica Farm and Jusic base?

 5        A.   Well, to tell you the truth now, I really don't know where these

 6     farms are.

 7        Q.   But that is somewhere in Serb territory, because the 1st Corps

 8     did not fight with the HVO, or if so, rarely?

 9        A.   This is somewhere in the area of responsibility of the 1st Corps.

10     Specifically where this farm is, I really do not know.

11             THE ACCUSED: [Interpretation] Thank you.

12             Can this be admitted?

13             JUDGE KWON:  Yes.

14             MS. GUSTAFSON:  Your Honours, we object to this.  It's difficult

15     for us -- obviously, we can't read it, but based on the questions and

16     answers, it appears to be irrelevant.

17             THE ACCUSED: [Interpretation] Can we have an answer?

18             JUDGE KWON:  Yes.

19             THE ACCUSED: [Interpretation] I believe it is relevant.  If

20     sabotage operations are underway in the rear, in the depth of the

21     territory, it is legitimate, but it is relevant, and it shows that the

22     side on whose territory sabotage operations are carried out should be

23     cautious.  It's the same race, the same language, not to say the same

24     people.  That's what we are, and that does justify different kinds of

25     checks and control.

Page 15278

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Do you agree, General?

 3        A.   Well, I don't have to agree, but that's the logic on both sides.

 4     If such operations are carried out, it is absolutely soldierly and

 5     tactically right to do that.

 6             JUDGE KWON:  We'll mark it for identification.

 7             THE REGISTRAR:  As MFI D1394, Your Honours.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             1D3726, could we have that, please.

10             MR. KARADZIC: [Interpretation]

11        Q.   Is this your telegram of the 30th of April, 1995, sent to

12     Avdo Palic in Zepa, in which you are informing him that he has been

13     allowed to transport the persons from numbers 1 through 12, and you also

14     say the daughter of Jusuf Jusupovic, Heneda:  "Do inform Jusuf."  Is this

15     your communication with your boss?

16        A.   We did not have any communication with Zepa for a while, and I

17     believe, and I believe that this is a telegram of mine.

18        Q.   Is this the same Jusuf Jusupovic who was pro-JNA,

19     pro-Yugoslav-oriented, the one who had to be protected?

20        A.   Yes.  Unfortunately, he lost his life in a strange way as he was

21     working on an improvised hydroelectric power-plant.

22             THE ACCUSED: [Interpretation] Thank you.

23             Can this be admitted?

24             MR. KARADZIC: [Interpretation]

25        Q.   Can you tell us what kind of transportation this is about?  That

Page 15279

 1     13 persons would be transported from Zepa; right?

 2        A.   These were wounded persons.  They were transported by helicopter,

 3     and I think that the UNPROFOR Command was involved in this regard.

 4        Q.   Is this the usual way to do things?  When coming to Zepa, you

 5     land on Sokolac territory, and then the examination takes place at

 6     Sokolac, and then you proceed; right?

 7        A.   I travelled to Zepa nine times that way as the head of the team

 8     for establishing a protected area, from May 1993 until September 1993.

 9     Now, in this particular case, I don't know whether that's the way things

10     actually happened.  I cannot say that for sure.

11             THE ACCUSED: [Interpretation] Thank you.

12             Can this be admitted?

13             JUDGE KWON:  While the witness confirmed that this is his

14     telegram, I'm still struggling to understand the relevance of this

15     document.

16             Could you tell us how this is relevant?

17             THE ACCUSED: [Interpretation] Well, I believe, Excellency, that

18     one can see here that evacuation is possible and that there is a channel

19     for the evacuation of the wounded from Zepa.

20             JUDGE KWON:  I don't think Zepa is included in your indictment at

21     all.  Is it?

22             THE ACCUSED: [Interpretation] Zepa -- could Mr. Robinson please?

23             MR. ROBINSON:  Yes, Mr. President.

24             I believe certainly the events of Zepa have been the subject of

25     testimony already in the case by David Harland and anticipated to be the

Page 15280

 1     subject of other testimony when we deal with --

 2             JUDGE KWON:  My question is whether it's included in the

 3     indictment.

 4             MR. ROBINSON:  I'm not positive if it's in the indictment, but I

 5     believe it's Mr. Tieger who is best placed to answer that question.  But

 6     the relevance of events in Zepa, I think, have already been established

 7     by the Chamber.

 8                           [Trial Chamber confers]

 9             JUDGE KWON:  Yes, we'll mark it for identification.

10             THE REGISTRAR:  As MFI D1395, Your Honours.

11             JUDGE KWON:  Your time is almost up, but how many more documents?

12             THE ACCUSED: [Interpretation] There are some very important

13     documents, Excellency, that are very important for you to have an

14     overview of the situation.

15             Could I please have at least up until the end of this session?

16             JUDGE KWON:  You should have started with the important ones.

17     You'll have 15 minutes to conclude.

18             THE ACCUSED: [Interpretation] Thank you.

19             Now I'm going to ask for in-court numbers to place on the ELMO an

20     intercept of yours, a conversation with Fikret Prevljak.  Could you

21     identify it briefly?

22             MR. KARADZIC: [Interpretation]

23        Q.   Our service intercepted a conversation of yours with Prevljak in

24     which you are advocating the release -- or, rather, you're saying that

25     the wounded should be allowed to pass that way.  Prevljak is opposing

Page 15281

 1     that, and he's also opposing the passage of an UNPROFOR convoy that had

 2     not been announced and that has an extra vehicle, at that.

 3             JUDGE KWON:  When you note the trial attorney on the other side

 4     rising --

 5             THE ACCUSED: [Interpretation] I beg your pardon.  I didn't see.

 6             JUDGE KWON:  Yes, Ms. Gustafson.

 7             MS. GUSTAFSON:  Thank you, Your Honour.

 8             Mr. Karadzic didn't provide an identification number, but I don't

 9     believe we were notified of this document.  This is new to us.

10             JUDGE KWON:  Do you have an explanation, Mr. Robinson?

11             THE ACCUSED: [Interpretation] Well, the explanation is the same,

12     and the apology is the same.  We have been burdened with piles of new

13     material, and also the rhythm at which witnesses are being called is very

14     rapid for us.

15             JUDGE KWON:  Why was it not disclosed at the time the other

16     material were handed over to the OTP?

17             THE ACCUSED: [Interpretation] An oversight, Excellency, a pure

18     oversight.

19             JUDGE KWON:  Very well.  Let us proceed.

20             MR. KARADZIC: [Interpretation].

21        Q.   Do you agree that you asked Prevljak, Fikret Prevljak, who

22     commanded the unit in Hrasnica, to allow an unannounced convoy to pass

23     that way, and that he should at least allow the wounded to get through?

24     Do you remember this conversation?

25        A.   I did, among other things, work on such activities as well.  I

Page 15282

 1     had official contacts with the representatives of international

 2     organisations, as the chief of staff and later on the chief of

 3     administration.  I do not remember this conversation, specifically, but I

 4     did carry out such activities; not only in this case, but also in all

 5     other cases when it was necessary to negotiate with the representatives

 6     of international organisations, regardless of whether it was a question

 7     of convoys or requests for electricity, water, or any other humanitarian

 8     activity.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can we just have the next page.

11             MR. KARADZIC: [Interpretation]

12        Q.   I'm interested in another thing.  In a very soldierly manner, you

13     asked here that civilians be allowed to pass through, and the wounded as

14     well, whereas Fikret Prevljak was opposed to having this unannounced

15     convoy allowed to pass through, and this convoy had an extra vehicle at

16     that.  Was this the way things were handled usually, that a convoy had to

17     be announced, and if it was not announced, it would have trouble getting

18     through?

19             JUDGE KWON:  Before you answer the question, General:  Yes,

20     Ms. Gustafson.

21             MS. GUSTAFSON:  Your Honour, I don't know where we are in the

22     document, but I saw a page that had different conversations that didn't

23     contain include this witness.  If we could clarify where we are at in

24     this document and who is speaking.

25             JUDGE KWON:  All I know is the conversation between

Page 15283

 1     Fikret Prevljak and the witness, and I have no idea.  But I understood

 2     that the general was able to observe the relevant part of that intercept.

 3             Could you help us in that regard, General Dzambasovic?

 4             THE WITNESS: [Interpretation] Yes.

 5             I did carry out such conversations, and similar ones, but I do

 6     not remember this specific conversation because there were many such

 7     conversations.  The usual practice was that convoys of all kinds be

 8     announced, as well as the route that they would be taking, so that

 9     through our chain of command, we would ensure conditions for their

10     unhindered passage.

11             THE ACCUSED: [Interpretation] Thank you.

12             If the Chamber is satisfied, may I ask you something else.

13             MR. KARADZIC: [Interpretation]

14        Q.   I'm going to interpret.  Slavuj is answering, and you say, Yes,

15     Slavuj.  And he is protesting, saying that a convoy showed up, and no one

16     told him anything.  And then he says they have wounded here, and

17     Dzambasovic says, that's the highlighted bit:

18             "Let the wounded pass through."

19             And then he says there are about 10 or 12 vehicles, and they

20     haven't heard of this trouble.

21             And can we have the next page now, please.

22             Do you remember this?  Do you remember that there were such

23     cases?

24        A.   From time to time, we did have cases when commanders at local

25     level would not react always, as we had requested.

Page 15284

 1        Q.   Thank you.  Do you see the highlighted bit here?  You say:

 2             "15, I think."

 3             And he says:

 4             "You have to know, I am getting the last vehicle out if it is not

 5     announced."

 6             Is that what soldiers usually did at check-points, that the

 7     number of vehicles had to correspond to the number referred to in the

 8     announcement?

 9        A.   I'm not sure now whether the number of vehicles had to tally, I

10     mean, the registration plates with the number in the column, itself.

11     However, it is certain that convoys were announced, that's for sure.

12     There was a lot of that.  I cannot recall all details.

13             THE ACCUSED: [Interpretation] Thank you.

14             Can this be admitted?

15             JUDGE KWON:  Two questions.

16             How is this relevant to your case, Mr. Karadzic?

17             THE ACCUSED: [Interpretation] Well, it happened on our side, too,

18     that a soldier would not allow 11 vehicles to pass if 10 were announced,

19     or they would not let a convoy through if it had not been announced.  So

20     this was practiced throughout Bosnia-Herzegovina on all sides, because a

21     soldierly mind is not creative.  They need to have a piece of paper

22     allowing them to let someone get through.  The question of convoys is a

23     major issue in my indictment.

24             JUDGE KWON:  So is it the defence, according to your theory, that

25     the other party did the same?

Page 15285

 1             MR. ROBINSON:  Mr. President, if I can answer that.

 2             I think what Dr. Karadzic is trying to show is that it was

 3     reasonable for the Bosnian Serbs to sometimes refuse to allow convoys to

 4     pass when they didn't meet the requirements that had been announced in

 5     advance.  And in order to show that that is reasonable, he's showing that

 6     that practice was also engaged in by the other side.

 7             JUDGE KWON:  In light of the practice that other parties were

 8     performing?

 9             MR. ROBINSON:  That's correct.

10             JUDGE KWON:  And my second question is:  You have no doubt as to

11     the authenticity and legality of this intercept?

12             MR. ROBINSON:  Well, Mr. President, from our point of view, I

13     couldn't say that we have no doubt.  But since the witness has given

14     enough information as to the fact that he at least recalls some of these

15     events, then I think that there's enough evidence to at least mark it for

16     identification.  It's part of our practice.

17             JUDGE KWON:  I remember you rose, Ms. Gustafson.

18             MS. GUSTAFSON:  Thank you, Your Honour.

19             I'd just like to note that this document seems to contain

20     multiple conversations.  So in addition to the fact that we would have to

21     review it, its admission should be restricted to the conversation

22     discussed in the evidence today.

23             JUDGE KWON:  Of course, I agree.

24                           [Trial Chamber confers]

25             JUDGE KWON:  Given that this hasn't been interpreted, we'll mark

Page 15286

 1     it for identification.

 2             THE REGISTRAR:  As MFI D1396, Your Honours.

 3             MR. KARADZIC: [Interpretation] Thank you.

 4        Q.   Two last topics, General.  You agreed with us, during our

 5     interview, that there was a practice of placing mobile mortars on a

 6     vehicle, mounting them on a vehicle, and then opening fire, and changing

 7     positions so that the response fire would not damage the vehicle?

 8        A.   I did not agree with you on that question, but I said that by

 9     establishment, in the Armija we did not have vehicles that would be used

10     for that purpose.  However, in a number of cases, practically, this did

11     happen, and this was mostly done in the unit of the 10th Mountain

12     Brigade, Caco's unit.

13        Q.   Thank you.  Just one more before the final topic.

14             You also agreed that ammunition and weapons supplies did manage

15     to reach Zepa, because -- we're not going to be talking about Srebrenica,

16     because Zepa was in the area of 1st Corps of the B and H Army.  I'm not

17     going to show the document, because we don't have time.  Do you recall

18     agreeing that this was the practice and that it was successful?

19        A.   I did confirm that to you, with the explanation that when we

20     began to receive reports from Zepa that representatives of the

21     Ukrainian Battalion were leaving check-points under pressure of the

22     Army of Republika Srpska, that they were feeling threatened and that they

23     were asking us, as the superior command, what to do and how they could be

24     helped.

25             After that, at the level of the General Staff, a decision was

Page 15287

 1     made to try to provide supplies to Zepa by air, and this was done a

 2     number of times.

 3             THE ACCUSED: [Interpretation] All right.  Can you put this -- I

 4     would like this to be put on the ELMO, and can we have the in-court

 5     numbers for this topic that's important that relates to the incident at

 6     the 1st of June, 1993, in Dobrinja.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Do you agree that this is a document of the National Security of

 9     the Republika Srpska?  Can you please look at it?  It is informing that

10     something happened in Dobrinja and that its unit was carried out.

11             THE INTERPRETER:  The interpreters would like to have the

12     reference, please.

13             JUDGE KWON:  Just a second.

14             Did you refer to an e-court number?

15             THE ACCUSED: [Interpretation] "In court."

16             MS. GUSTAFSON:  Your Honour, if I could assist, I think this is

17     Exhibit D341.

18             JUDGE KWON:  Thank you.  Why don't we up-load it.

19             MR. KARADZIC: [Interpretation]

20        Q.   Can you see that Srdjan Sehovac is reporting here that he has

21     received relating to today's events in Dobrinja, and says that a

22     commander took out his unit to the Dobrinja 3 parking, that they were

23     playing football, and that during the football game, two shells fell,

24     resulting in people getting killed and wounded?  Do you know about this?

25        A.   Yes, I know about the incident.  I'm seeing the document for the

Page 15288

 1     first time, however.  It's clear to me that this did happen in Dobrinja.

 2     I'm sure that it did happen.  As for the details about the wounded, those

 3     killed, are something that I don't know.  I know that there were quite a

 4     few, and I know that as the superior command, we criticised assembling of

 5     that type, that it wasn't reasonable at that time to organise sports

 6     activities.

 7             I am not sure if this was attended just by soldiers.  I think

 8     that this was a sports event between soldiers and civilians.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can we now look at a document by the Presidency of Bosnia and

11     Herzegovina of the 2nd of June on the ELMO, asking the Supreme Command

12     Staff to prepare a report on this soccer match.  I don't know if this was

13     admitted or not.  Possibly, it was not.

14             MR. KARADZIC: [Interpretation]

15        Q.   In the interview, you told us that you remember that an

16     investigation was launched?

17             JUDGE KWON:  And this should be your last question.

18             Yes, Ms. Gustafson.

19             MS. GUSTAFSON:  Your Honour, again, this document and the

20     previous document, D341, were also not notified to us.

21             JUDGE KWON:  Thank you.

22             Is this document in evidence already?  I doubt it.  No.

23             THE ACCUSED: [Interpretation] Excellency, I just -- Excellencies,

24     I just have two documents on the same topic, showing exactly who was

25     there, so I would like to ask for your patience and just to ask the

Page 15289

 1     general to speak on this.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Do you see that --

 4             JUDGE KWON:  After this, I will consult my colleagues whether or

 5     not I'll give you extra time.

 6             Proceed with this question.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Do you agree that the chief of the Main Staff, Sefer Halilovic,

 9     is being informed by the general secretary that the Presidency is asking

10     the Supreme Command to prepare a report on the organising of a

11     football-match on the occasion of the religious holiday of Bajram at

12     Dobrinja, where a large number of persons were killed because of the

13     shelling by the aggressor?

14        A.   I agree that that is what the document says.  I'm seeing the

15     document for the first time, however.

16             THE ACCUSED: [Interpretation] Thank you.

17             JUDGE KWON:  This will be marked for identification.

18             MS. GUSTAFSON:  If I could just inform the Court that this

19     document is in e-court at 1D00378.

20             JUDGE KWON:  With English translation.

21             That will be marked for identification.

22             THE REGISTRAR:  As MFI D1397, Your Honours.

23             THE ACCUSED: [Interpretation] Can we now see --

24             JUDGE KWON:  Just a moment, Mr. Karadzic.

25                           [Trial Chamber confers]

Page 15290

 1             JUDGE KWON:  On a very exceptional basis, we allow you to proceed

 2     with your remaining two questions.

 3             THE ACCUSED: [Interpretation] Thank you very much.

 4             Can we put this on so that we can see what

 5     General Fikret Muslimovic responded on the 6th of June.  I don't know if

 6     he was a general at the time.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Does it not state here that --

 9             JUDGE KWON:  Let us see the first page first.

10             Yes, very well.  Next page.

11             Yes.  Proceed, Mr. Karadzic.

12             MR. KARADZIC: [Interpretation].

13        Q.   Does it not state here at the top that there was a group of

14     fighters of the 1st Battalion -- of the 1st Battalion of the

15     5th Motorised Brigade at Dobrinja, organised thus by a football

16     tournament began at the parking behind the building?  Does it not state

17     here that the 1st Battalion of the 5th Motorised Brigade organised this

18     football-match?

19        A.   Yes, the document does confirm that.

20        Q.   At the bottom, it says, in the second:

21             "Although at an oral briefing that morning, the fighters were

22     warned not to play any matches because of possible shelling, the warnings

23     did not give any results, to which the data on casualties attests,

24     amounting to 58, 11 section commanders, 2 platoon commanders, 1 deputy

25     company commander, 3 orderlies, 4 senior officers from the company."

Page 15291

 1             Does this - two couriers and 37 fighters - does this not speak of

 2     the number of those who were killed or wounded in that particular

 3     incident?

 4        A.   Yes, this is what it states in the document.  The data that is

 5     cited indicates the profile of those who were killed and wounded, and I

 6     am seeing this document for the first time.

 7        Q.   Thank you.  In the third paragraph, it says that suspicious

 8     persons were detained and mistreated, allegedly suspicious persons and

 9     fighters, exclusively members of the Serbian ethnicity, which was stopped

10     upon the intervention of the security organs; is that correct?

11        A.   Yes, this is also something that is also said in the document.

12             THE ACCUSED: [Interpretation] Thank you.

13             Can the document be marked for identification, please?

14             JUDGE KWON:  Yes, that will be done.

15             THE REGISTRAR:  MFI D1398, Your Honours.

16             THE ACCUSED: [Interpretation] Let us see what happened on the 9th

17     of June, what the new information is about that football-match, also

18     coming from General Muslimovic.

19             MS. GUSTAFSON:  Again, Your Honour, these documents have not been

20     notified to us, and Mr. Karadzic continues to pass over documents and

21     then apologise.  But if he has had these documents at least since this

22     morning, at the very least we should have received an e-mail that there

23     were even more documents that he intended to use.

24             JUDGE KWON:  I hope this is the last document for today and he

25     now understands the problem with disclosure now.

Page 15292

 1             THE ACCUSED: [Interpretation] Absolutely, yes, and we have been

 2     showing, in the past, and will continue, in the future, to show

 3     flexibility.

 4             THE INTERPRETER:  Could Mr. Karadzic repeat what he said in the

 5     English because we were overlapping.  He spoke before the translation

 6     into English was complete.

 7             JUDGE KWON:  Did you say something in English which was not

 8     noted?

 9             THE ACCUSED:  Yes, I wanted the Usher to show the first page, the

10     bottom of the page, for the date.

11             MR. KARADZIC: [Interpretation].

12        Q.   9th of June; is that correct?  Do you agree that this contains

13     new information about the football-match on the 6th of June at the

14     improvised pitch, indicating that 12 people lost their lives and 101

15     persons were wounded, and it speaks about the civilians and fighters who,

16     for several months, have regularly been organising football and other

17     sports activities in this area; the organising for this event was done

18     by -- and the name is mentioned.  They're all members of the

19     1st Battalion.  There was a poster on the tournament.  And then it

20     states:

21             "Since the majority of the participants of the tournament are

22     members of this battalion, the preparations had been carried out for such

23     a long time, so we can say, with good grounds, that the company commands

24     in this area were informed about the organisation of the tournament."

25             THE INTERPRETER:  Could Mr. Karadzic please repeat the rest of

Page 15293

 1     his question.

 2             JUDGE KWON:  Mr. Karadzic, could you repeat from "the

 3     organisation of the tournament"?  Company commands were informed about

 4     this organisation, and then the interpreter couldn't follow.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Do you agree that the report here states that the organisation of

 8     the tournament began about five or six days before Bajram, and that for

 9     several months such football-matches were held on a regular basis, that

10     it was organised by members of the 1st Battalion of the

11     5th Motorised Brigade, and their names are stated here, and then a bit

12     lower it says:

13             "In view that the majority of the participants of this tournament

14     were members of the battalion, and since the preparations had been

15     carried out for a long time, it can be stated, on good grounds, that the

16     commands of companies in this area were informed with the organisation of

17     the tournament.  This is also confirmed by information that, among the 58

18     casualties, were 21 commanding officers in the company or the platoon;

19     Omer Oglecevac, deputy commander of one company, was the captain of one

20     of the 14 teams that were registered to participate."

21             So is this a report by General Muslimovic indicating that the

22     organisation took quite some time to carry out and that it was carried

23     out by members of the 1st Battalion of the 5th Mountain Brigade?

24             JUDGE KWON:  We just heard the interpretation of Mr. Karadzic's

25     question.  Did you answer the question, General?  If you could repeat it.

Page 15294

 1             THE WITNESS: [Interpretation] No, because I was waiting for the

 2     end of the interpretation.

 3             Everything that you said is stated in the document.  I'm seeing

 4     this document for the first time, and I am reading the information here

 5     for the first time.  And as you can see, this is something that is in the

 6     jurisdiction of the security organs.  This is in their remit, and this is

 7     something that was part of their duties.  We were just informed about the

 8     events, and I know that the event did happen.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can we admit this?  And it's a pity about another document.

11             MR. KARADZIC: [Interpretation]

12        Q.   Do you know that your deputy, Jovan Divjak, submitted his

13     resignation because he felt there was a discriminatory attitude about

14     him?  Just like you felt the distrust in Han Pijesak, in the same way, he

15     felt a distrust and was submitting his resignation?  Do you remember

16     that?

17        A.   I don't remember him submitting his resignation, specifically,

18     but we did speak about these things, just the two of us, on a number of

19     occasions.

20        Q.   He was even arrested, wasn't he?  He spent three or four months

21     in prison, did he not?

22             JUDGE KWON:  We'll stop here.

23             This will be marked for identification as Exhibit D1399.

24             We'll have your re-examination after the break, Ms. Gustafson.

25             THE ACCUSED: [Interpretation] If I may reply about the relevance.

Page 15295

 1             JUDGE KWON:  We'll stop here.

 2             We'll continue with your re-examination by the Prosecution at

 3     five past 11.00, and you may be excused, General, since there's one

 4     matter I'd like to deal with in your absence.  See you later.

 5             In the meantime, shall we go into private session.

 6             THE WITNESS: [Interpretation] Thank you.

 7                           [The witness stands down]

 8                           [Private session]

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16                           [Open session]

17             JUDGE KWON:  We'll break for half an hour and resume at five past

18     11.00.

19                           --- Recess taken at 10.34 a.m.

20                           --- On resuming at 11.08 a.m.

21             JUDGE KWON:  Yes, Ms. Gustafson.

22             MS. GUSTAFSON:  Thank you, Your Honour.

23                           Re-examination by Ms. Gustafson:

24        Q.   Mr. Dzambasovic, I just have five questions for you, and they're

25     each short, so we shouldn't be more than a few minutes.  If you could

Page 15296

 1     assist me by focusing your answers as precisely as possible on the exact

 2     question, I would appreciate that.

 3             The first question relates to your testimony yesterday, when you

 4     were asked about Rajko Kusic.  And you mentioned that he very often

 5     appeared as some representative of the SDS, and this is at page 15171 of

 6     yesterday's transcript.  And you were asked:

 7             "Representative of the SDS or the representative of the local

 8     authorities?"

 9             And you said:

10             "Well, probably it is the local authorities from the area that he

11     came from."

12             And I'd just like to clarify that answer with you.

13             Was Rajko Kusic an SDS member?

14        A.   When I said that he was a representative of the local

15     authorities, I meant the area of the municipality of Rogatica.  It was

16     the SDS that was in power in Rogatica, as far as the Serb people were

17     concerned.  So he's a member of the SDS and he's a representative of the

18     authorities from the municipality of Rogatica.  Which specific office he

19     held, I don't know.

20        Q.   Thank you.  And also yesterday, in relation to your position as

21     chief of staff in the 1st Corps, you were asked about the manpower of the

22     corps, and you affirmed that it was roughly 60.000 soldiers.  And I have

23     three questions on this topic.  The first is:  Of that 60.000, how many

24     were actually -- were located outside the encircled city of Sarajevo?

25        A.   I personally think -- well, right now, I don't have the exact

Page 15297

 1     figures here, but I think that in the city, itself, there were about

 2     30.000 men, and that many outside the city as well.  At that time,

 3     Gorazde was within the area of responsibility of the 1st Corps too, so

 4     the Army of the Republic of Bosnia and Herzegovina in the area of

 5     Gorazde, was within the 1st Corps.  Also, the unit in Zepa at the time

 6     was within the 1st Corps.  That is the period of 1992 and 1993.

 7        Q.   Thank you.  And of the 30.000 who were inside the city, how many

 8     were located at the confrontation lines at any given time?

 9        A.   Well, approximately, it is my estimate right now - again, I

10     cannot give you an exact figure - but I think it is between 4.000 and

11     5.000.

12        Q.   Thank you.  And of the 30.000 soldiers located inside the city,

13     how many of them had weapons?

14        A.   Well, one quarter, roughly, had weapons.

15             MS. GUSTAFSON:  Thank you.

16             And if we could have D1381 on the screen, please.

17        Q.   Mr. Dzambasovic, the map that's about to appear on your screen is

18     an extract from the ABiH map that you marked yesterday, and it was the

19     map where you marked the location of the Military Hospital and of a gun

20     or a cannon.  And that's at the far left of this map.  Do you remember

21     making those markings yesterday?

22        A.   I do.

23        Q.   And before you made these markings, Mr. Karadzic asked you:

24             "General, can you see that above the Military Hospital, we can

25     see a howitzer on the hospital?"

Page 15298

 1             And this was at transcript page 15241.  And then he asked you to

 2     mark -- you said it was a gun or a cannon, and he asked you to mark that

 3     with a circle and put the number 2 at the Military Hospital.

 4             And I'd just like to clarify.  Is this gun that you circled on

 5     the Military Hospital, as the question suggested, or was it, in fact,

 6     some distance from the Military Hospital?

 7             THE ACCUSED: [Interpretation] May I be of assistance in order to

 8     clarify this confusion?

 9             I said "on Gorica," and Gorica is a hill above the

10     Military Hospital, the hospital being Bolnica.  So perhaps the witness

11     can explain.

12             THE WITNESS: [Interpretation] Yes, precisely.  The

13     Military Hospital is about 500 metres away from this hill.  This hill is

14     sparsely populated.  There are some areas that are not populated at all.

15     So this hill called Gorica, where these artillery pieces were, is about

16     500 metres away from the hospital, so it is not on the Hospital Bolnica.

17             MS. GUSTAFSON:

18        Q.   Thank you.  And earlier this morning, at the beginning of the

19     session, you were asked about mobilisation, and you were shown an order

20     by General Kukanjac of a mobilisation in early April.  And in answering

21     that question, you mentioned Colonel Gagovic, and I'd just like to ask

22     you:  What was Colonel Gagovic's position in the JNA at that time, early

23     April 1992?

24        A.   At the time, Colonel Gagovic was assistant commander of the

25     4th Corps for logistics, so the number-one man in the corps, as far as

Page 15299

 1     logistics security is concerned.

 2        Q.   Thank you.  And one last question.  Today, you were asked about

 3     mobile mortars in Sarajevo, and you said, at page 31 of today's

 4     transcript:

 5             "Practically, this did happen," referring to the existence of

 6     these mobile mortars.

 7             And my question for you is:  How many of these mobile mortars

 8     were in operation in Sarajevo at the time you were the 1st Corps

 9     commander -- chief of staff?  I apologise.

10        A.   I know that there was one vehicle where the soldiers of Caco's

11     brigade, the 10th Brigade, used the vehicle in that way.  Otherwise, that

12     was not the regular practice, the vehicles that were specialised for that

13     kind of use of weapons.

14        Q.   I'd just like to clarify your answer, because I'm not sure you

15     finished it.  The last part of your answer was.

16             "... the vehicles that were specialised for that kind of use of

17     weapons."

18             Did you mean to add anything after that or was that the end of

19     your answer?

20        A.   I said that the army did not have such vehicles that were

21     special-purpose vehicles like that.  The army did not have such vehicles

22     specialised for that.

23             Now, as for these vehicles, I don't know whether there were one

24     or two, but I know that it was this one improvised vehicle upon which the

25     10th Brigade used that weapon in that way.

Page 15300

 1             MS. GUSTAFSON:  Thank you.  That clarifies your answer.

 2             I have no further questions.  Thank you very much,

 3     Mr. Dzambasovic.

 4             JUDGE KWON:  Thank you, Ms. Gustafson.

 5             Thank you, General Dzambasovic.  That concludes your evidence.

 6     On behalf of the Tribunal and the Bench here, I would like to thank you

 7     for your coming all the way to The Hague to give it.  Now you're free to

 8     go.

 9             THE WITNESS: [Interpretation] Thank you, too.  And I do apologise

10     to the interpreters if I was too fast.

11             JUDGE KWON:  Thank you.

12             THE ACCUSED: [Interpretation] Have a good journey, General.  This

13     was on behalf of the Defence.

14                           [The witness withdrew]

15             JUDGE KWON:  So I take it it is you, Mr. Hayden, that will lead

16     the next evidence.

17             MR. HAYDEN:  Thank you, Mr. President.

18             The Prosecution calls Mr. Hajrudin Karic.

19             JUDGE KWON:  While we are waiting:  Mr. Tieger, I was informed

20     there is a further development in relation to Witness Ristic.

21             MR. TIEGER:  That's correct, Your Honour.  I think the -- I

22     believe the Chamber and certainly the Defence was notified accordingly

23     last night.

24             JUDGE KWON:  So there's no need to issue a decision on the

25     outstanding motion to reject the --

Page 15301

 1             MR. TIEGER:  Yes, I take your point.  Yes, I think that probably

 2     does pre-empt that issue.

 3             JUDGE KWON:  Thank you.

 4                           [The witness entered court]

 5             JUDGE KWON:  Good morning, sir.

 6             THE WITNESS: [Interpretation] Good morning.

 7             JUDGE KWON:  If you could take the solemn declaration, please.

 8             THE WITNESS: [Interpretation] I solemnly declare that I will

 9     speak the truth, the whole truth, and nothing but the truth.

10                           WITNESS:  HAJRUDIN KARIC

11                           [Witness answered through interpreter]

12             JUDGE KWON:  Thank you, sir.  Please make yourself comfortable.

13             THE WITNESS: [Interpretation] Thank you.

14             JUDGE KWON:  Yes, Mr. Hayden.

15             MR. HAYDEN:  Thank you, Mr. President.

16                           Examination by Mr. Hayden:

17        Q.   Good morning, Mr. Karic.  Please state your full name.

18        A.   Hajrudin Karic.

19             MR. HAYDEN:  I would ask for 65 ter 90241, please.

20        Q.   Mr. Karic, on the screen in front of you, you will see a

21     statement which is an amalgamation of your evidence you have provided to

22     the Office of the Prosecutor in 2002 and to the authorities of Bosnia and

23     Herzegovina in 1992 and 1993.  Have you had an opportunity to review this

24     document?

25        A.   Yes.

Page 15302

 1        Q.   And is that your signature we see on the B/C/S version of the

 2     statement, on the left-hand side?

 3        A.   Yes.

 4        Q.   Now, before I ask you to confirm the accuracy of the statement's

 5     contents, there is one correction to make.  This correction has already

 6     been made by hand in the B/C/S version, but is not yet reflected in the

 7     English version.

 8             On page 3, at paragraph 10 of the English, the surname of

 9     Zeljko Klisara should be spelled with an A, and not an O.

10             MR. HAYDEN:  Your Honours, there were two further corrections

11     made by hand by the witness to the version he signed, but I'm advised

12     that those minor corrections do not affect the English translation.

13        Q.   Now, Mr. Karic, with those corrections in mind, could you confirm

14     today that the statement is accurate, and if you were asked the same

15     questions on the same topics today, you would provide the same answers?

16        A.    Yes.  The corrections are correct.

17        Q.   And just to confirm, Mr. Karic, the corrections are correct and

18     the statement is also accurate; is that right?

19        A.   That's right.

20             MR. HAYDEN:  I tender this statement into evidence,

21     Mr. President.

22             JUDGE KWON:  That will be admitted.

23             THE REGISTRAR:  As Exhibit P2839, Your Honours.

24             MR. HAYDEN:  I will now read a summary of the statement.

25             Prior to the conflict, Mr. Hajrudin Karic lived in Sarajevo and

Page 15303

 1     worked for Centrotrans in Pale.  On 22nd of May, 1992, Muslims in Pale

 2     were fired from their jobs, and Serb forces began arresting non-Serbs.

 3             At the end of May 1992, two Serb policemen arrested Mr. Karic in

 4     Pale.  He was detained at the Pale Sports Centre, along with over 100

 5     other Muslims.  Two days after his arrest, he was beaten by a member of

 6     the Serbian paramilitary formation, who told Mr. Karic he was being

 7     detained because his brother-in-law had participated in nearby fighting.

 8             Mr. Karic was detained at Pale until 11 July 1992.  During this

 9     time, detainees were barely fed, and Mr. Karic lost tens of kilogrammes

10     in body weight.  Detainees were routinely taken out and beaten by Serb

11     forces, including by men belonging to units commanded by Rajko Kusic and

12     Srdjan Knezevic.  Many times, the detainees never returned to the room

13     and were presumed killed.  By the end of Mr. Karic's stay, only 34

14     detainees remained.  On one occasion, Mr. Karic, himself, was called out

15     and severely beaten.  The beating only stopped when another soldier came

16     into the room and told the attackers they were beating up the wrong man.

17             Mr. Karic directly witnessed the beatings of other prisoners.

18     Three prisoners, Smail Pandzic, Alija Jusufovic and Nasko Smajic, were,

19     in particular, regularly targeted and beaten.  At the beginning of July,

20     all three were beaten to death by Rajko Kusic's men.  When Malko Koroman,

21     the chief of police in Pale, came to the prison and saw the dead body of

22     one of those men, he remarked, "There must be some kind of plague in the

23     prison."

24             Mr. Karic and 33 other detainees were moved to Kula Prison on

25     11 July.  The accused visited Kula Prison on one occasion while Mr. Karic

Page 15304

 1     was there.  Mr. Karic was exchanged on the 28th of August, 1992.

 2             That concludes the summary.

 3        Q.   Mr. Karic, I have just a handful of further questions for you.

 4             You referred to the fact, in your statement, that detainees were

 5     routinely called out of the room where you were detained, and that this

 6     occurred to you on the 28th of June, 1992.  Can you describe for the

 7     Court what happened when you were called out of the room on this date?

 8        A.   On that day, they took me out to a smaller room that was in front

 9     of the hall.  It was in concrete --

10             THE INTERPRETER:  Interpreter's note:  Could all other

11     microphones please be switched off.  Thank you.

12             JUDGE KWON:  Mr. Karic, the interpreters couldn't hear you, the

13     last, but could you repeat your answer, please, and speak to the

14     microphone.  Thank you.

15             THE WITNESS: [Interpretation] I walked into a smaller room that

16     was in front of the hall that was all in concrete, and there was a piece

17     of gym equipment there.  Two Serbian soldiers met me there, and they held

18     sticks in their hands.  They started beating me straight away for 10 or

19     15 minutes, while I was still standing on my feet.  They were beating me

20     on the back, on the head, and then I fell on the right side.  And then I

21     received quite a few blows on the left side, on my shoulder, back and

22     head.  Then I passed out.

23             I just heard someone walk in, Milomir Tepes [Realtime transcript

24     read in error "Tepic"].  He worked at the sawmill, and he said, No, it's

25     not him, he's not the one.  Then they stopped beating me, and somehow

Page 15305

 1     they managed to get me up on my feet and throw me back into the hall

 2     where the other detainees were.

 3             My left arm was all black, and I lay there helpless for days

 4     without any help.  That was it.

 5             MR. HAYDEN:

 6        Q.   In your statement, Mr. Karic, and we've just heard it in the

 7     summary of your statement, you say Malko Koroman, the chief of police,

 8     came to the centre where you were being detained, and he said something

 9     like, There must be some kind of plague in the prison.  How do you know

10     he said that?

11        A.   A few days after we were beaten - there were several of us who

12     had been beaten - I described that in my statements about these three men

13     who died.  Actually, two of them died on the same day, and the third one

14     died two days later.

15             Malko Koroman entered the hall one day and said, somewhat

16     surprised, What is this, as if I have some kind of plague here.  I have

17     to transfer you from here to somewhere else, but the conditions were not

18     good.  That was it.  But that did not happen.  He did not transfer us

19     anywhere else.  We still stayed there.

20        Q.   What did he see in front of him that appeared to prompt this

21     statement from him?  Can you describe the scene he saw?

22        A.   Well, he saw these men who were lying there.  Actually, this one

23     young man who was lying down on the floor, it was as if his brains had

24     oozed out on the floor.  And then he said, Is this the plague or what?

25     We, the prisoners, were lying down.  We couldn't stand on our feet

Page 15306

 1     because we were being beaten every day.

 2        Q.   And, finally, with respect to that:  Judging from the

 3     circumstances, did it appear he really thought there was some kind of

 4     plague in this prison?

 5        A.   Oh no, he did not.  He was sort of trying to justify himself,

 6     pretending not to know anything about it.  I don't know how to explain

 7     this to you.

 8        Q.   In your statement, you say that around 11 of July, you were moved

 9     to Kula Prison.  And you describe your detention at Kula, and you state

10     that there were also women and children detained there.  How did you

11     learn that women and children were being detained while you were there?

12        A.   Well, the men who were there with me found out by way of mirrors.

13     They were talking with this other room by way of the mirror, Where are

14     you from?  These were civilians from Hadzici, women, children.  There

15     were also some men there as well.  They were brought there from their

16     houses.  So it's not that there were imprisoned soldiers there.  It was

17     all civilians who were brought from our homes, just as we were brought

18     from our homes as civilians, not as any kind of military.

19        Q.   You say that you found out or men you were being detained with by

20     way of mirrors.  Can you just explain to the Court exactly how they used

21     mirrors to find out this information?

22        A.   Well, you take a mirror out this way [indicates], and then you'd

23     turn it towards the other room, and then people would look at each other

24     and talk.  Some people could get their heads out a bit and they could

25     talk, sort of.

Page 15307

 1        Q.   While you were at Kula, did any of the detainees perform work?

 2        A.   Yes, work was performed, trenches were dug.  Some people went to

 3     bury the dead, and others went to the farm to work there, to dig, to work

 4     at the chicken farm, to put the eggs away, and things like that.

 5        Q.   And why did these detainees perform this work?

 6        A.   Well, they made them go every day.  Some went to dig trenches.

 7     Others went to bury the dead.  The greatest problem was burying the dead,

 8     because these bodies were decaying, I think, and they had to be buried.

 9     As they were going back, these people were vomiting.  They would be sick

10     for 10 days or whatever.  They went there mostly for food, because if

11     they went out to dig, then they were given some food.  The soldiers from

12     the front-line would give them something, or some of the locals there,

13     things like that.  And that is why they had to go, basically, because

14     that was a way to survive, because the food was very bad.

15             I don't know if I described this anywhere, but while I was in

16     Pale, I got only a slice of bread and a bit of water over 24 hours.  So

17     on the 28th of May, when I was taken prisoner, up until the 11th of July,

18     I would only get a slice of bread and a bit of water, whereas in Kula I

19     had sort of a slice of bread and some kind of soup which wasn't greasy,

20     or salty, or anything.  That's it.

21        Q.   Finally, with respect to Kula, you discuss a visit by

22     Mr. Karadzic in August, and I want to show you a film clip relating to a

23     visit by Mr. Karadzic.  Before that is shown, let me ask you some

24     questions.

25             At the time of the visit, was the normal routine of the prison

Page 15308

 1     followed by the detainees?

 2        A.   That day when we heard that Karadzic would come to visit with I

 3     don't know who else, before they came, it wasn't really that clean.  The

 4     food and so on, that day, they kind of fixed it up to be a bit nice.

 5     They didn't let us go out, but they let us go out a little bit then.

 6             While I was in Pale, the first time I went out was on the 28th.

 7     That was the first time I went out in the period from the 28th of May

 8     until the 11th of July.  We were shut up.  I was ill.  We were not

 9     permitted to go out anywhere.  I felt dizzy.  I had lost weight.  I had

10     lost 50 kilos, not 10 kilos.  I lost 50 kilos.  I kept falling to the

11     side.  I was unable to walk, so I didn't really go out for work much,

12     until one day one of those guys there asked me, Why don't you go out?

13     And I was quiet, and somebody said, He cannot work, he's sick.  And

14     that's when some man came to me.  After then, he took me to the

15     infirmary.  Actually, he was taking me somewhere, I wasn't sure where he

16     was taking me.  And then when I entered that room, I could see that it

17     was some kind of infirmary, there were medicines there.  He said he

18     wanted to help me, to examine me.  I took my top off.  My arm was all

19     black, it was stiff.  I couldn't move it.  He gave me some balm, he put

20     something on it, and then he took me back to the room before Karadzic

21     came.

22             So it wasn't like that.  They kind of camouflaged it, they fixed

23     it up a little bit, so it didn't look like they were mistreating us, like

24     it was bad.  They wanted to make it look like they were taking care of

25     us, but it was only like that for that one day while Dr. Karadzic was

Page 15309

 1     making the tour with the journalists and the Red Cross.

 2        Q.   And just to clarify, Mr. Karic, the visit to the infirmary, did

 3     that occur at Kula or Pale?

 4        A.   In Kula, in Kula.

 5             MR. HAYDEN:  I'd now like to play 65 ter 40173A in Sanction.

 6             JUDGE KWON:  We need to switch to Sanction?  Yes.

 7                           [Video-clip played]

 8             MR. HAYDEN:  If we could pause, please.

 9             We should be receiving sound for this video.

10                           [Video-clip played]

11                           [Trial Chamber and Registrar confer]

12             JUDGE KWON:  The technicians will take a look.

13             MR. HAYDEN:  We may be able to view it without the sound.  If we

14     admit it into evidence with the sound, and we can deal with it on that

15     basis.

16             JUDGE KWON:  Very well.

17                           [Video-clip played]

18             MR. ROBINSON:  Mr. President, I wonder if we -- could we have

19     interpretations of the captions?

20             JUDGE KWON:  Do we have it, Mr. Hayden?

21             MR. HAYDEN:  Well, the sound is being interpreted by the

22     captions, Mr. President.  So if we had sound, everyone would be able to

23     follow along in the English.

24             MR. ROBINSON:  But could the interpreters interpret the captions

25     as we're looking at it?

Page 15310

 1             THE INTERPRETER:  We believe that it might be a little bit too

 2     fast for us to do it without a transcript.

 3             MR. HAYDEN:  I'm happy to proceed.  The interpreters have

 4     indicated they're unable to translate that.  The parties can view this

 5     with sound, because it will be admitted into evidence with the sound.

 6     And perhaps --

 7             JUDGE KWON:  How long will this clip be?

 8             MR. HAYDEN:  It's approximately 2 minutes and 10 seconds,

 9     Mr. President.

10             JUDGE KWON:  Let's do it without sound.

11             MR. HAYDEN:  Thank you.

12                           [Video-clip played]

13             " ... get a few cigarettes from their visitors.

14             "'The conditions are good here,' says this man -- "

15             JUDGE KWON:  So we can start again.  You turned down the volume.

16     All right.

17                           [Video-clip played]

18             "Reporter:  57 Muslims were being held at this Serb-run prison,

19     the date of our visit.  Most are between the age of 20 and 60, and all

20     those we saw appear to be in fairly good shape, grateful to get a few

21     cigarettes from their visitors.  The conditions are good here, says this

22     man.  Everyone we asked said the same thing, although a few did look

23     desperately thin.  Indeed, Kula, on the outskirts of Sarajevo, has been a

24     prison for the last 20 years, and it is not on the list of detention

25     centres that outsider services have requested to see.  Yet this is where

Page 15311

 1     the first international observer has been brought.  He is Paddy Ashdown,

 2     leader of Britain's Liberal Democrat Party.  He was invited by the

 3     president of the Bosnian Serbs, Radovan Karadzic, under great pressure

 4     since reports of Serbian concentration camps made world headlines.

 5     Karadzic made a great show of standing aside while Ashdown interviewed

 6     these prisoners."

 7             "Ashdown:  There's never been any concern about the way this

 8     particular camp is run, but I want to suspend my judgement until I see

 9     some of the other camps."

10             "Reporter:  And Karadzic chose this moment to make his first

11     so-called unilateral gesture of international goodwill, releasing just

12     ten prisoners, those who are over 60 or in poor health.  Smiling, he

13     handed out release papers as though he was handing out awards, and it

14     brought tears of joy to those who were being freed.

15             "The Serbs say they hold a maximum of 8.250 prisoners, not the

16     58.000 that the opposition claimed.  They say they'd like to get rid of

17     all of them, but, say the Serbs, they've had no reciprocal gestures by

18     the Muslims and Croats."

19             "Karadzic:  We released only people who are not likely to be

20     mobilised again.  If we released all of those people without exchange,

21     they would be mobilised immediately and they would fight against us.  It

22     would be unreasonable."

23             "Reporter:  The Serbs say all the people here are fighters.  The

24     prisoners say they are not."

25             "I don't know weapons.  I didn't shoot."

Page 15312

 1             "Reporter:  This man is blind in one eye.  He says he couldn't

 2     fight even if he wanted to.  They all say they've been taken as

 3     bargaining chips traded for prisoners from the other side, and they don't

 4     expect to be released anytime soon.

 5             "Christiane Amanpour, at Kula Prison outside Sarajevo."

 6             MR. HAYDEN:

 7        Q.   Mr. Karic, is that the visit by Mr. Karadzic that you refer to in

 8     your statement?

 9        A.   Yes.

10        Q.   We saw, at the end of that clip, Mr. Karadzic stating that he

11     would release those who -- he would not release those who are likely to

12     be mobilised again.  When you were arrested, Mr. Karic, were you a member

13     of the military or a member of an armed group?

14        A.   I wasn't a member of any group, and I was not armed.  I wasn't a

15     member of any party at the time.  I didn't have any weapons or anything

16     like that.  They came to my house -- actually, to my cousin's house.

17     They took me away, saying they were looking for me at the MUP to provide

18     some sort of a statement.  But they actually just locked me up.

19        Q.   And from your conversations with the other detainees at Pale and

20     in Kula, were you aware of other detainees who were not members of the

21     military or any armed group?

22        A.   Everyone who was with me in Pale, none of them were from any

23     armed group, from any front.  They were from homes.  When there was an

24     attack in Renovica, they assembled people from houses, whatever they

25     could.  They put them together, brought them to Pale.  These people were

Page 15313

 1     not on front-lines, not in any kind of combat.  They actually just

 2     rounded up the civilians and brought them in.  And there were all these

 3     other people from Grahovo, and this guy, Nasko Smajic from Majdan, and

 4     these others, all of them, as far as I know, were not at the front.  They

 5     were civilians, who were brought in, rounded up and arrested from their

 6     homes.

 7             MR. HAYDEN:  I tender that clip into evidence.  And that's --

 8             JUDGE KWON:  They will be admitted.

 9             THE REGISTRAR:  As Exhibit P2840, Your Honours.

10             MR. HAYDEN:  And no further questions, Your Honour.

11             JUDGE KWON:  Thank you.

12             Mr. Karic, you'll be further asked by Mr. Karadzic, as part of

13     his cross-examination.

14             Yes, Mr. Karadzic.

15             THE ACCUSED: [Interpretation] Thank you very much.

16                           Cross-examination by Mr. Karadzic:

17             MR. KARADZIC: [Interpretation]

18        Q.   Good day, Mr. Karic.

19        A.   Good day.

20        Q.   You got your consolidated statement that you certified and signed

21     on the 10th of May, 2011; is that correct?

22        A.   Yes.

23        Q.   The two of us, since we're speaking the same language, we will

24     have to make pauses.  So I kindly ask you to understand why I am waiting.

25             Did you get that statement in your own language then?

Page 15314

 1        A.   Yes.

 2        Q.   And did you ask that it be in your language or did they give it

 3     to you without you having to ask for it?

 4        A.   I didn't ask for anything.  Well, it's quite normal for them to

 5     give it to me in my own language to read it, because I wouldn't be able

 6     to understand it in any other language.

 7        Q.   Thank you.  In your statement, paragraph 4, we say that

 8     everything began on the 1st of March, 1992.  Paragraph 4, if you have the

 9     statement, can you please look at that paragraph.  I think the referendum

10     was held on the 1st of March, that's when it all began.  Is that

11     something that you link with the referendum?

12        A.   The referendum was held on the 1st of March.  Already on the 2nd

13     of March, it was a little bit of a strange time.  It was not possible to

14     move around normally.  It was a little bit -- well, it wasn't normal.

15     That day, I went to work, and some strange things were going on.  And

16     after all of that, it wasn't a normal situation.  It was kind of tense,

17     as if something were being expected for something to happen, although I

18     didn't believe that.  But it did happen, something ugly did happen.

19        Q.   Are you thinking of some particular dramatic event in Sarajevo on

20     the 1st of March?

21        A.   No, I'm not thinking of any particular dramatic event, but it was

22     the sense that I had.  There was no freedom of speech, talking.  The

23     situation was tense.  It wasn't normal.  I don't know how I could

24     describe it.  It wasn't the way it was before usually.  Something strange

25     was happening.

Page 15315

 1             In Pale, for example, next to my business unit where I was

 2     working, there was the firefighting brigade, and one day I could see

 3     armed people who were coming and going in trucks.  They were being taken

 4     to Trebevic, up there.  That's what I heard.  That was my first bad

 5     impression, what is going on.  I asked myself something is wrong.

 6        Q.   All right.  We'll come back to that.  Let me remind you, then.

 7             On the 1st of March, didn't Celo, in Bascarsija, fire at a

 8     Serbian wedding procession and kill the bridegroom's father?

 9        A.   I only heard something about that, a little bit.  I really didn't

10     pay attention to that.  I wasn't watching the news.  There was a little

11     bit of talk about that, but I didn't really pay that much attention to

12     it.

13        Q.   Did he kill him a little bit or did he kill him outright?

14        A.   I don't know.  I'm saying I didn't really give it that much

15     attention.  It wasn't something that I was interested in.

16        Q.   What about the barricades and obstacles on the roads and these

17     strange events?  Are you not connecting them to that strange incident?

18        A.   No.

19        Q.   Is it correct that the barricades were erected in the evening,

20     after that killing, and that they stayed there on the 2nd of March too?

21        A.   I didn't notice that.  I didn't notice any barricades, even

22     though I was commuting to work and back.  I went to work as usual on the

23     2nd of March and other days.  I didn't notice anything, I didn't notice

24     any barricades.

25        Q.   In paragraph 6, you say that you saw a large gathering of Serbs

Page 15316

 1     in Pale.  Are you connecting that gathering with the killing of

 2     Nikola Basevic in Bascarsija next to the Serbian Orthodox church?

 3        A.   No, I didn't make any connections between those events, because I

 4     don't know anything about the incident anyway.  I just had the idea that

 5     because of the referendum, and after that something seemed to be up,

 6     something was strange, about to happen.  I wasn't a member of any party,

 7     so I didn't really believe that anything really would happen.  Had I

 8     believed that something would happen, I wouldn't have gone to Pale to

 9     work on the day that I did, had I believed that there would be something

10     happening or that war would break out.

11        Q.   Well, to make it easier for the Trial Chamber to understand, is

12     it correct that you worked in Sarajevo -- you lived in Sarajevo and

13     worked at Pale, which is some 15 kilometres away, even though it was

14     still a city municipality?

15        A.   Yes, it's true, I worked from 1984 in Pale, when that work unit

16     was opened there, until the war broke out in 1992.

17        Q.   Thank you.  In paragraph 7, you are describing the 4th of April,

18     1992.  You say that you set out for work.  You had to pass through

19     several check-points.  Was there a Muslim check-point near the Vijecnica

20     exit in Sarajevo?

21        A.   Yes.

22        Q.   And were you allowed to pass through?  Were you checked?  Were

23     you asked anything when you were allowed to pass through?

24        A.   Well, I came through with a van, minivan.  They stopped at the

25     Vijecnica, picked me up.  The van was stopped, it was checked, and then

Page 15317

 1     it was allowed to pass.

 2        Q.   And then you encountered a Serbian check-point near the tunnel;

 3     is that correct?

 4        A.   Yes, at Kozja Cuprija.

 5        Q.   You passed two check-points on your way to Pale.  Can you please

 6     tell us what happened at those check-points?  Can you please tell us what

 7     happened?

 8        A.   Well, it was just that one check-point at Kozja Cuprija where

 9     there was Serb soldiers.  There was a professor among them from Pale.  I

10     don't remember his name right now.  All the others were familiar to me as

11     well.  They were in uniforms.  Their faces were blackened a little bit.

12     They were just looking a little bit, checking our papers, and they let us

13     through.

14        Q.   And what was your means of transport?

15        A.   It was Opres [as interpreted] van, the van that transported

16     newspaper to Pale.

17        Q.   Allow me to read paragraph 7 of your statement.

18             THE INTERPRETER:  Interpreter's note:  We do not have the

19     statement.

20             MR. KARADZIC: [Interpretation]

21        Q.   "I set off for work on such and such a day, and on the way I had

22     to pass through several check-points.  At the first check-point, near the

23     second tunnel towards Pale, there was the regular police.  They looked at

24     the car, and then they allowed me to pass through.  The second

25     check-point was at Kozja Cuprija.  It was manned by the reserve police of

Page 15318

 1     Pale.  They wore the blue, thick uniform of the reserve police.  I was

 2     allowed to pass without difficulties."

 3             Let us clarify this now.  Were you going with your own car, you

 4     say they checked the car, or were you going by van?

 5        A.   I don't know how it's written here.  I said that I was going by

 6     van.  I did not have my own car at the time.  I didn't have my own car,

 7     and I wasn't a driver.  And I actually think that is a little bit

 8     relevant, whether I went with my own car or not.

 9        Q.   The Defence thinks it's important.  They would like the statement

10     to be correct and precise.  I don't want to be splitting hairs here.

11     And, forgive me, but I would like to see exactly what happened.

12             Were your IDs checked on these roads?

13        A.   Yes.

14        Q.   Thank you.  Was it the police or the army?

15        A.   The police was at the first check-point.  Up there, it was the

16     reserve police.  And I mentioned that professor over there.  He wasn't in

17     the police; he was a professor at school.  But on that day, he was in a

18     multi-coloured uniform at the check-point.  There were several others

19     there also wearing camouflage uniforms at Kozja Cuprija.

20        Q.   All right.  Let us see what you said in your statement from 1992.

21             Can we look at 1D3675 in the e-court, please.

22             JUDGE KWON:  Yes.

23             MR. HAYDEN:  We're yet to be notified of any cross-examination

24     documents for this witness.

25             THE ACCUSED: [Interpretation] I hope that the e-mail went out,

Page 15319

 1     but this was after the solemn statement given by -- solemn oath given by

 2     Mr. Karic.

 3             JUDGE KWON:  I think it hasn't.

 4             Let's proceed, yes.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Can you see this second paragraph:

 7             "During this second control, I recognised Policeman Furtula, who

 8     told me that Centrotrans' bus on the Pale-Sarajevo route was stopped, and

 9     the passengers were robbed, the driver beaten, and his pistol was taken.

10     He also told me that I probably would not be able to return to Sarajevo

11     that day."

12             Is that correct?

13        A.   This statement here is correct, but it was a long time ago.

14        Q.   Thank you.  Who stopped the bus, and who was the driver?

15        A.   It was Lazar Bojat who was driving.

16        Q.   A Serb; right?

17        A.   Yes, from Pale.  He was driving on the Renovica-Sarajevo route.

18        Q.   Who stopped and robbed them and beat him up?

19        A.   According to what he said, he said it was at the first barricades

20     from Sarajevo.  Allegedly, he's saying that the passengers were robbed.

21     They said that they found a pistol in his waistband, and they allegedly

22     struck him on the head with that pistol, and then they returned him back

23     with all the passengers.

24        Q.   Did they hit him or did they beat him up so that he had to seek

25     treatment?

Page 15320

 1        A.   No, they just hit him on the head.  I saw him there when he came

 2     to Pale, I mean, I saw him.  It was nothing.  They had hit him on the

 3     head with a pistol, but it wasn't really anything much that you could

 4     see.

 5             THE ACCUSED: [Interpretation] All right.

 6             Could we now see in e-court 65 ter -- excuse me, 1D802, and this

 7     the same as 65 ter 3718.  1D802, yes.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Can you look at this and also allow us to see how the press

10     agency reported about this:

11             "A bus driver on the Renovica-Sarajevo route, Lazar Bojat, on

12     Sunday, the 5th of April, 1992, replaced his Muslim colleague so that he

13     could celebrate the Muslim holiday of Bajram.

14             "In front of the underpass in Sarajevo which leads to the transit

15     road, Bojat and his bus full of passengers were stopped by traps set up

16     along the road.  Immediately after they were stopped, the bus was shot at

17     from the tunnel with automatic weapons.  Uniformed persons which were

18     wearing red berets forced the driver to drive the bus between the traps

19     into the tunnel in which some 50 Red Berets and one police car were

20     located."

21             Do you see that?  And then you can see that they took 120.000

22     from the conductor, they beat and harassed the passengers, and the bus

23     driver was beaten over the head by the Red Berets with is own gun for

24     which he had a permit.

25             "After this mistreatment, the passengers were forced to walk to

Page 15321

 1     Sarajevo, and two members of the Red Berets drove the bus off.

 2             "Bojat arrived with the passengers to the City Hall and said that

 3     he recognised those same Red Berets in the car with the insignia of the

 4     United Nations."

 5             Is this that event?

 6        A.   Yes, this is that event, but I think that there are a lot of

 7     additions here.  I don't know who gave the statement, it was probably the

 8     driver, and he stated what he saw, half of it is not true.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can this be admitted?

11             JUDGE KWON:  Yes, Mr. Hayden.

12             MR. HAYDEN:  Objection, Your Honour.

13             The witness has given his version of events.  He's stated that

14     half of this is not true, and doesn't confirm its contents in that

15     respect.

16             THE ACCUSED: [Interpretation] Well, I believe that half would be

17     enough, anyway, the half that he confirmed as being true.

18                           [Trial Chamber confers]

19             JUDGE KWON:  With that comment of the witness's, we can admit

20     this.  That all goes to the probative value or weight of the evidence.

21     We'll admit this.

22             THE REGISTRAR:  As Exhibit D1400, Your Honours.

23             MR. KARADZIC: [Interpretation] Thank you.

24        Q.   So Furtula informed you that perhaps you wouldn't be able to come

25     back because the bus was not running; right?

Page 15322

 1        A.   Well, sort of right.

 2        Q.   Taken away; right?

 3        A.   Who?

 4        Q.   Well, the bus that was supposed to take you again from Pale to

 5     Sarajevo.  It was taken away, the Red Berets took it away; right?

 6        A.   Well, how did the driver return to Pale again if it was taken

 7     away; the bus, I mean?  Why don't you explain that to me?

 8        Q.   It says here that he came with the passengers on foot to town

 9     hall; that is to say, that he returns in some different way.

10        A.   He could only return on that bus, and that was the last thing.

11     Nothing else managed to get through.  This bus was returned, and never

12     again did anything go either this way or that way.  Had it been possible,

13     I would have gone back.

14        Q.   Thank you.  Furtula knew you; right?

15        A.   That's right.

16        Q.   And he said that there was no bus, that that was the reason why

17     you couldn't go back, not because you were a Muslim; right?

18        A.   I don't know whether he put it that way.  I don't remember that.

19     I -- I mean, he just said, Well, just see what's happening there.  He

20     didn't say anything else.  Since he knew that I was the boss of those

21     drivers, he told me of this happening, and that was it.

22             When I came to Pale, I found Lazar there, and that is to say the

23     bus and him and everything, so it wasn't that the bus was taken away.  I

24     don't know why he gave this statement that it was taken away.  How else

25     did he return?

Page 15323

 1        Q.   Very well.  We'll check that.  You claim that the Red Berets did

 2     not take that bus away?

 3        A.   There were no Red Berets there.  When I passed there -- well, I

 4     mean, before me -- this happened before me, perhaps 10 minutes before I

 5     wanted to go up there.  And then when I got up there in that van, I found

 6     Lazar up there, and I heard what he said had happened.

 7        Q.   Thank you.  Let us see how you explained your trip in your

 8     amalgamated statement.

 9             You say that you were going to work on the 4th of April; is that

10     right?

11        A.   Well, probably.  I mean, all of these dates.  Was it the 4th or

12     whatever?  Probably.  Well, if that's what I said in my statement, that

13     is this latest statement.  But, I mean, after all these years and all

14     these dates --

15        Q.   It was a Sunday, wasn't it?

16        A.   Yes, it was a Sunday.

17        Q.   Thank you.  Please, let us just pause between question and

18     answer.

19             In your statement of the 15th of May of 1993 --

20             THE INTERPRETER:  Interpreter's note:  We did not catch the

21     number of the document.

22             MR. KARADZIC: [Interpretation]

23        Q.   You say it was a Sunday, and on that year, Sunday was on the 5th

24     of April?

25        A.   I don't know that either.  You probably checked that.  I don't

Page 15324

 1     know.  I know it was a Sunday, though.

 2        Q.   Thank you.  On the 14th of July, 1995, that is 1D3679 - you

 3     stated that you took a truck to Pale.  You didn't take your own vehicle

 4     or the van of Omnipresa [as interpreted]?

 5        A.   I don't know.  It was a van, or a truck, or whatever.  What did I

 6     say?  You know, it was the van that took the press around before the war.

 7     I don't know, for me, perhaps it was a truck.  How do I know?  It was a

 8     van, or a truck, or whatever.  As if that mattered, a truck or whatever,

 9     a van.

10        Q.   I'm going to read it out to you:

11             "I went to work.  However, roadblocks had already started and

12     buses were not running.  A friend came along, and somehow I managed to

13     get to Pale on this truck.  On that day, the communications were down,

14     because for two days --"

15             I cannot see this, but never mind.

16             So some man came on a truck, your friend, you took the truck.  So

17     we have three versions, and we have to establish which one was right.

18     One is in your own car, that you were checked and they let you go, the

19     second version is the van for distributing newspapers, and the third one

20     is a truck owned by your friend?

21        A.   The van that distributes newspapers.

22        Q.   Thank you.  In paragraph 8 of your amalgamated statement, you say

23     that Braco Paradzina came to you and told you to get lost until the

24     situation calmed down.  When did that happen?

25        A.   When I was in Pale and I was working, and he came in some car.

Page 15325

 1     And he entered the office -- well, he didn't put it that way.  He said

 2     that I had to go from there because there was no room for Muslims there.

 3     Next time, if I come and I find you here, I'll kill you, that's what he

 4     said to me.

 5        Q.   Aha, thank you.  Is that what you stated in your previous

 6     statements?

 7        A.   Maybe I didn't and maybe I didn't.  I don't know, I cannot say

 8     now.  I've given hundreds of statements.

 9        Q.   This is what paragraph 8 says:

10             "On the 7th of April, 1992, Braco Paradzina --"

11             JUDGE KWON:  Just a moment.  Show him the document.

12             Yes, para 8.

13             Proceed, Mr. Karadzic.

14             THE ACCUSED: [Interpretation] Now we have two versions in

15     Serbian.  Can we have the English version for the other participants.

16             MR. KARADZIC: [Interpretation]

17        Q.   This is what it says:

18             "On the 7th of April, 1992, Braco Paradzina came to the

19     Centrotrans workshop and told me to get lost until the situation calms

20     down, so I decided to go ..."

21             And so on and so forth.

22             And let us have a look at what you stated in 1992, probably after

23     the exchange.  1D375.

24             On the 9th of April, 1992, in Centrotrans, Braco Paradzina came

25     and told me to get lost until the situation calms down, so I decided to

Page 15326

 1     go to Renovica."

 2             And on the 15th of May, 1993 - 1D3677 - you stated something

 3     different.  You say:

 4             "An armed man in camouflage uniform, Braco Paradzina, entered my

 5     office, and I knew him from earlier on just by sight."

 6             JUDGE KWON:  Yes, Mr. Hayden.

 7             MR. HAYDEN:  Can the witness be given an opportunity to see the

 8     statements that Mr. Karadzic is referring to?

 9             If it helps, the witness has hard copies of the statements in

10     front of him, and in chronological order.  He may want to refer to those

11     instead of the screen.

12             JUDGE KWON:  Do you have them?  I wonder whether we have all the

13     photocopies of those statements.

14             But when you refer to the statement in such a manner, it's very

15     difficult for the witness to follow.  I would like you to show the

16     passage to the witness.

17             Where can we find that passage in this document?

18             THE ACCUSED: [Interpretation] I'll find it now.  If there's a

19     hard copy, that would be a good thing, if the witness had his own

20     statements in our language, and we can have the English versions on the

21     screen.

22             The first page, lines 13 through 15.

23             JUDGE KWON:  Can we zoom in further on the upper part?  I see

24     "Paradzina" there, "Braco."  Did you find the passage, Mr. Karic?

25             THE WITNESS: [Interpretation] No, I haven't found it.  But all of

Page 15327

 1     these statements that Karadzic is referring to were just being

 2     supplemented.  In some places, I gave more extensive information, in

 3     other places, less extensive, but all of them are correct.  I couldn't

 4     say, word for word, exactly the same thing every time.  It's not that I

 5     added this, to get lost, that there was no place for Muslims there, and

 6     that he walked in with a pistol.  All of this is correct, but I was just

 7     adding things to my statements as I gave them.  But they're all correct.

 8     It's true that he came, that he came in uniform, that he was armed, that

 9     he told me to get lost, that there was no business for Muslims to be

10     there.  All of that is correct.  And perhaps every statement is

11     different.  It's not that they're incorrect.  Maybe I just provided more

12     information and things like that.

13             JUDGE KWON:  Yes.  Your next question, Mr. Karadzic.

14             MR. KARADZIC: [Interpretation].

15        Q.   In the statement from 1992, you said that he had said to you to

16     get lost until the situation calmed down, and you decided to go to

17     Renovica.  And in the statement from the 15th of May, 1993, you

18     stated - that's the one that we have here - that he said to you to get

19     lost because, There is no room for Muslims here anymore.

20             JUDGE KWON:  He answered the question.  Move on to your next

21     topic.

22             MR. KARADZIC: [Interpretation] Thank you, thank you.

23        Q.   So then you sought shelter in Renovica, and you say that

24     Momcilo Antonic helped you, took you there.  That is paragraph 8 of the

25     amalgamated statement:

Page 15328

 1             "I went to Renovica to Muharem Alispahic, my father-in-law."

 2        A.   Muharem Salispahic.

 3        Q.   I apologise:

 4             "I passed by the Serb police roadblocks towards Praca with the

 5     assistance of my colleague Momcilo Antonic."

 6             This road from Praca to Renovica was under whose control?

 7        A.   Muslim control.

 8        Q.   This Momcilo Antonic who helped you pass through Serb territory

 9     was a Serb; right?

10        A.   Yes.

11        Q.   I'm saying this for the benefit of the participants, who cannot

12     distinguish among our names, so please bear with us.

13             And then in the statement of 1993 that was on the screen a moment

14     ago, you say that:

15             "Then one of my colleagues, Momcilo Antonic, a driver, told me

16     that he would take me wherever I wanted to go, but that I should not tell

17     anyone about it.  I said to him that he should drive me to Renovica,

18     which is exactly what he did.  And we went to Praca.  That's how far the

19     Serb roadblocks were.  And then from Praca, a Muslim driver took me to

20     Renovica."

21             Does that mean that the driver changed and that a Muslim

22     continued?

23        A.   Yes.

24        Q.   What was the reason for that?

25        A.   Well, because of his own safety.  He said, I'll take you to

Page 15329

 1     Renovica, if you want, but I'm afraid that they would arrest me there;

 2     the Muslims, I mean.  Well, that was it.  So Sefkija took me to Renovica.

 3        Q.   Thank you.  When did you go to Renovica?

 4        A.   Well, I don't know what the date was.  I can't remember.  It was

 5     immediately after Paradzina.  Was it the same day, was it the next day?

 6     I don't know.

 7        Q.   Thank you.  In 1992, you said it was on the 9th of April.  1993,

 8     that it was on the 7th of April.  And, in 1994, on the 9th of April.  And

 9     in this amalgamated statement, you say the 7th of April; right?

10        A.   Well, it's most probably the 7th.

11        Q.   As for the length of your stay in Renovica, you referred to

12     different periods.  How long did you stay in Renovica?

13        A.   I don't know.  I can't remember.  A few days, until the bus came

14     to Renovica.

15        Q.   Until normal traffic was established; right?

16        A.   Yes.

17        Q.   And when was normal traffic established?

18        A.   Well, I don't know.  I've just said.  A few days afterwards; I

19     don't know.  Perhaps the 15th.  I don't know.

20        Q.   Thank you.  May I remind you, then, that in 1992, you said you

21     stayed seven days.  In May 1993, you said that you returned on the 12th

22     of April to Pale.  In 1994, you said that you were in Renovica for three

23     or four days, or perhaps five or six days.

24        A.   It's all the same thing.

25        Q.   In 1995, in the statement we mentioned, you said that you

Page 15330

 1     returned around the 15th of April, 2002, you said the 14th of April, and

 2     in this amalgamated statement, paragraph 9, you say that you returned on

 3     the 15th of April; right?

 4        A.   I don't know what all these dates mean for you.  Whether it's a

 5     day, or two, or three, or five, give or take, I mean, you keep sticking

 6     to these dates.  That is pointless.  I don't see any reason for you to

 7     insist on that and to ask me about that, in general.

 8        Q.   All right.  How did you return to Pale?

 9        A.   The first bus came, and I took that first bus to Pale to work

10     there, because they were sending messages that I should go to work, to

11     start working, and then I decided to go to work there.  Everything I

12     believed, well, it would have been better had I not believed all that,

13     but there you go.

14        Q.   Oh, somebody was sending you messages.  Could you tell us why

15     that happened?  How come they called you, who called you?

16        A.   Well, those people living up in Pale, Danilo and Klisara, Zeljko,

17     and Tanic, Milorad, and so on.

18        Q.   These names you mentioned, they're all Serbs, aren't they?

19        A.   I really don't know.  I guess they all are.

20        Q.   What else could they be?

21        A.   Nothing.  Serbs; there you go.

22        Q.   In your statement of 1992, you say that you stayed for seven

23     days, and then when buses started running again, you went back and you

24     worked, all the way up until the 22nd of May, 1992, as you stayed with

25     Enver Karic, your uncle.  However, in your statement of the 15th of May,

Page 15331

 1     1993, you say that they sent two policemen to get you; right?

 2        A.   Well, they did send two policemen; not on the 15th and not on the

 3     22nd, but on the 28th.

 4        Q.   The arrest is a different matter.  Here, it says that on the 15th

 5     of May, 1993, you say:

 6             "I was in Renovica until the 12th of April, when two unknown

 7     policemen came to my house.  They were from the Pale SUP, and they said

 8     that they guaranteed my security and safety, and that I should go to work

 9     at the Centrotrans office in Pale."

10             Right?

11        A.   That's right.

12        Q.   Thank you.  In your statement of 1995 --

13             JUDGE KWON:  It's time to take a break.

14             MR. HAYDEN:  Just briefly before the break, Mr. President, can we

15     have an indication, if possible, whether the next witness may be required

16     today?

17             JUDGE KWON:  Mr. Karadzic.

18             THE ACCUSED: [Interpretation] Well, I don't think so.  Even

19     according to the little bit of time you've given me, there would be no

20     time for another witness.  And I'm hoping for an extension of time, that

21     you would extend my time.

22             JUDGE KWON:  After the break, I expect you to lead us to some

23     important points.

24             We'll have a break.  Given the accused's response -- I won't go

25     there, so we'll leave it there.  And we'll have a break for half an hour

Page 15332

 1     and resume at 1.00.

 2                           [The witness stands down]

 3                           --- Recess taken at 12.31 p.m.

 4                           --- On resuming at 1.02 p.m.

 5             JUDGE KWON:  Yes, Mr. Tieger.

 6             MR. TIEGER:  Thank you, Mr. President.

 7             If we could briefly move into private session.

 8             JUDGE KWON:  Yes, let's go into private session.

 9                           [Private session]

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22                           [Open session]

23             JUDGE KWON:  So let's bring in the witness.

24             THE ACCUSED: [Interpretation] Your Excellencies, did you perhaps

25     want to hear my reasons for additional time, as you announced?

Page 15333

 1             JUDGE KWON:  Yes, please go on, Mr. Karadzic.

 2             THE ACCUSED: [Interpretation] The current witness is a witness

 3     and participant in very important events at a very important location.

 4     The Prosecution has probably the ambition of presenting him as part of a

 5     pattern of events in a municipality and in a prison facility.

 6             This witness made a couple of statements that are inconsistent in

 7     certain elements.

 8                           [The witness takes the stand]

 9             JUDGE KWON:  Just a second.  I would prefer to hear that in the

10     absence of the witness.

11             Mr. Karic, I apologise for your inconvenience.  There's still

12     further matters to discuss in your absence.  Could you excuse yourself

13     once again.

14                           [Trial Chamber and Registrar confer]

15             JUDGE KWON:  Yes, please.

16                           [The witness stands down]

17             JUDGE KWON:  Very well.  Carry on, Mr. Karadzic.

18             THE ACCUSED: [Interpretation] Thank you.

19             He's made a couple of statements that are inconsistent in certain

20     important points.  They are also inconsistent with testimony of another

21     witness from the same municipality, Witness Sankar [as interpreted].

22             THE INTERPRETER:  The interpreter is unsure of the name.

23             THE ACCUSED: [Interpretation] The Defence can contest and prove

24     the inaccuracy of a number of points the witness made in his statements.

25     However, what we need for that is time.  This is the basis on which we

Page 15334

 1     seek additional time, to shed light on a number of points and to

 2     challenge all the points that need challenging.

 3                           [Trial Chamber confers]

 4             JUDGE KWON:  Mr. Karadzic, at the moment the Chamber is of the

 5     view that two hours is more than sufficient to cover anything that you

 6     refer to, so I would advise you to use your time as efficiently as you

 7     can.

 8             Judge Morrison has some further comments to you.

 9             JUDGE MORRISON:  Dr. Karadzic, what you've done in

10     cross-examination so far is really, it seems to me, very peripheral.  And

11     if there are challenges to go to the heart of the witness's evidence, in

12     terms of limitation of time and, it may be thought, in terms of tactics,

13     it's always better to make your best points first.

14             The second thing is this: that it's an impermissible line of

15     cross-examination to put what another witness has said by way of

16     inconsistency, and it's something that a witness really can't deal with

17     unless they were sitting in court at the time that the witness gave that

18     evidence, which is highly unlikely.

19             So it's a question of focus.  You can do it, because I've seen

20     you do it.

21             THE ACCUSED: [Interpretation] Thank you, Your Excellencies.

22             Let me just say I'm grateful for the additional time I'm given.

23     However, if I knew in advance that I had this time available to me, I

24     would not rush through the examination.  I know that you will make an

25     adequate ruling if I am successful in what I'm doing, but the shortage of

Page 15335

 1     time makes me commit errors on my way.

 2             JUDGE KWON:  Remember that you don't have to cover every point

 3     with every witness.

 4             Let's bring in the witness, and try to conclude your

 5     cross-examination today.

 6                           [The witness takes the stand]

 7             JUDGE KWON:  Thank you for your understanding, Mr. Karic.

 8             Yes, Mr. Karadzic, please continue your cross-examination.

 9             MR. KARADZIC: [Interpretation] Thank you.

10        Q.   Mr. Karic, in order that the participants and the Trial Chamber

11     may be aware of it, can we agree that Renovica has a predominantly Muslim

12     population; is that right?

13        A.   Yes.

14        Q.   Thank you.  You said in some statements of yours that policemen

15     arrived and guaranteed safety, and in others you said that some of your

16     colleagues from your office called you to come back to work a couple of

17     days after you had gone?

18        A.   Yes.  It was perhaps three, four, or five days later.

19        Q.   So what was the case, really?  Was it the policemen who came or

20     your colleagues called you?

21        A.   Both.

22             JUDGE KWON:  Make a pause.  Yes.

23             THE ACCUSED: [Interpretation] My apologies to the interpreters

24     and participants in the proceedings.

25             MR. KARADZIC: [Interpretation]

Page 15336

 1        Q.   Therefore, a regular public transport was restored to that area

 2     quite soon thereafter, and you returned to Pale?

 3        A.   Yes, but it was on the 22nd of May.

 4        Q.   Between the 12th of April and the 22nd of May, you continued

 5     working; is that right?

 6        A.   Yes.

 7        Q.   Thank you.  In paragraph 9 of the consolidated statement, you say

 8     that the revenue produced by all the companies from Pale was siphoned off

 9     to the Crisis Staff of the Municipality of Pale.  How are you aware of

10     that?

11        A.   Well, I'm sure about the revenue produced by my company, and I

12     heard that the same was true of the other companies at Pale.  And I knew

13     about my company, I knew that for a fact.

14        Q.   Did you, yourself, see these invoices and payments?

15        A.   Well, there were no invoices or payments to speak of.

16        Q.   Thank you.  Muhamed Saceragic, was he the manager of the branch

17     office at Pale or somewhere else?

18        A.   He was the CEO in Sarajevo.

19        Q.   Thank you.  In your 1994 statement, 1D3678, the last paragraph,

20     you say that the manager said to you quite clearly that you should pay

21     salaries to workers and that the rest should be transferred to the

22     account of the Crisis Staff at Pale?

23        A.   That's correct.

24        Q.   Can you tell Their Honours, was Centrotrans a privately-owned or

25     a socially-owned company at the time?

Page 15337

 1        A.   Socially owned.

 2             JUDGE KWON:  Mr. Karic, could I ask you again to put a pause

 3     before you start answering.  The interpreters have great difficulty

 4     following the conversation.  Please.

 5             Yes, please continue, Mr. Karadzic.

 6             MR. KARADZIC: [Interpretation] Thank you.

 7        Q.   You say that from the 15th of May -- or, actually, between the

 8     12th of April and the 15th of May, you stayed in your work-place, and

 9     from the 15th of May onwards, you were transferred to ticket sales.  Is

10     that right?

11        A.   Yes.

12        Q.   Apart from that transfer, you say that there was no mistreatment

13     or harassment?

14        A.   Well, there was no harassment, but I was exposed to all sorts

15     of -- well, I was working down there with Serbian refugees.

16        Q.   Do you mean to say that at the time there was a lot more work to

17     be done at the ticket office where you worked?

18        A.   Well, yes.  There were at least 10 to 15 buses every day leaving

19     in the direction of Cacak.  These were Serbian families fleeing the area.

20        Q.   Let's make a break between question and answer.  That's why I'm

21     pausing?

22             So there were Serbian families which had arrived in Pale from

23     somewhere else.

24        A.   Well, there were those who had arrived there from elsewhere and

25     those who were leaving the area, being locals.

Page 15338

 1        Q.   These families who arrived there from elsewhere, what was the

 2     place they fled?

 3        A.   Grbavica, Hadzici and Pale, of course.  These were Serbian

 4     families.

 5        Q.   You knew the approximate number of refugees at the time.  Was it

 6     on the rise?

 7        A.   Well, at the time I worked there, some 10 to 15 buses left the

 8     area daily in the direction of Belgrade and Cacak up until the 22nd of

 9     May.  I can't tell you for the later period, because that was the day I

10     stopped working there.

11        Q.   Was this high number of refugees, for such a small place such as

12     Pale and for your company, was it a large burden?

13        A.   Well, not really.

14        Q.   In your 1995 statement, you say that in addition to ticket sales,

15     you were also charged with maintaining lists of refugees whom you told or

16     ordered that they should go somewhere else.  What do you mean, "ordered"?

17     Did you receive instructions from someone, and you had to give them

18     guidance?

19        A.   Well, there were lines to Belgrade and Cacak, and you would make

20     tickets for these people who wanted to go there.  There was no sort of

21     order involved.

22        Q.   Did you know that there was shortage of food at Pale at the time?

23     You, yourself, said that you suffered privations?

24        A.   Well, that's true.  Shops were closed, and there was nothing to

25     be had, so I would ask people to bring foodstuffs from Sokolac because we

Page 15339

 1     had a bus line from Sokolac.  On one occasion, I went to Sokolac myself

 2     to buy foodstuffs.  I even had an unpleasant situation there, but,

 3     luckily, nothing happened.  I was lucky.

 4        Q.   Thank you.  In paragraph 15 of your statement, you say that

 5     Serbian soldiers brought food for the Serbs.  Do you mean to say here

 6     that these were soldiers from Pale who took food to their families?

 7        A.   I don't know where it was that I said that.  I suppose that since

 8     there was nothing to be bought at Pale, they had to make do.

 9        Q.   In paragraph 15 of your consolidated statement, you say all the

10     shops at Pale were closed, there was no food to be had, and the Serbian

11     soldiers brought food for the Serbs.  You meant soldiers bringing food

12     for their families; right?

13        A.   Well, probably so.

14        Q.   Thank you.  Were you brought any food by the Serbs?

15        A.   Yes.

16        Q.   You say:

17             "Staple foods were brought to me by the Serbian soldiers from our

18     company"?

19        A.   That's right.

20             THE INTERPRETER:  Interpreter's correction:  Serbian drivers.

21             THE ACCUSED: [Interpretation] Thank you.

22             Can we now look at D19 briefly.

23             MR. KARADZIC: [Interpretation].

24        Q.   In paragraph 15, you say that, meanwhile, explosions and shelling

25     could be heard from Sumbulovac, Trebevic and Hresa upon Sarajevo; is that

Page 15340

 1     right?

 2        A.   That's right.

 3        Q.   Let's look at this.  This is a board of the residents of Serb

 4     ethnicity of Hresa and Renovica, and they are giving a list of displaced

 5     Serbian families from Renovica.  I'll read it to make it easier for you:

 6             "After the 15th of May, 1992, immediately after the Serbian

 7     forces had collected weapons from the members of Muslim forces in the

 8     Renovica Local Commune in the military action, the Muslim forces took

 9     revenge on the minority Serbian population, killing four people of

10     Serbian ethnicity and destroying a large number of houses and

11     out-buildings.  Given the fact that the military and civilian authorities

12     of Pale municipality did not protect the Serbian population of Renovica

13     in any way, these Serbian families were displaced and have found a

14     temporary shelter in other villages of the municipality with a majority

15     Serbian population.  They have left behind considerable movable and

16     immovable property ...," et cetera.

17             Do you remember this event?

18        A.   No, not specifically.  As far as I know, there were two or three

19     Serb households there.  There were two or three Serb houses that I knew

20     of up there.  What happened to them, did they leave, I don't know.

21        Q.   When you found refuge in Renovica, where was that?  You must have

22     had someone there.  Did you have relatives there?

23        A.   My mother-in-law, father-in-law, and my brother-in-law with his

24     wife and children.

25        Q.   Can you give us their names?

Page 15341

 1        A.   Muharem is my father-in-law.  Serifa is my mother-in-law.  Now,

 2     as for the brothers-in-law, Munib and Taib.

 3        Q.   And is there another brother-in-law there?

 4        A.   Yes, yes.  He was known as Zecan.

 5        Q.   You said that he was known as Zecan.  That's his nickname.

 6     What's his name?

 7        A.   Yes, that was his nickname.

 8        Q.   What was his name?

 9        A.   I don't know.

10        Q.   You don't know your brother-in-law's name?

11        A.   No.

12        Q.   Your wife's brother, and you don't know his name?

13        A.   No.

14        Q.   Thank you.  So you knew that there were a couple of Serbian

15     households in Renovica?

16        A.   Well, I did go there in my youth, and I speak from experience.  I

17     was also a conductor, so I went there.  And I know that nobody harmed

18     them in any way, that the Serbian families left of their own accord.

19     That's the extent of what I know.

20        Q.   What you mean to say is that they left their homes and estates to

21     seek refuge in Serbian villages with other people, without any reason

22     whatsoever?

23        A.   Well, I'm just saying that I don't know who they were and how

24     their departure came about.  I don't know about it.

25        Q.   Thank you.  Is it true that a call was issued for

Page 15342

 1     illegally-procured weapons to be surrendered?

 2        A.   I don't know specifically.  I heard that calls were made for

 3     weapons to be surrendered.

 4        Q.   Up until your arrival in Sarajevo, that's to say between early

 5     May and late -- early April and late May, you were at Pale; is that

 6     right?

 7        A.   Right.

 8        Q.   Do you know if a police patrol went to Renovica to collect

 9     weapons and that two policemen were killed in an ambush?

10        A.   This was on the 22nd of May.  That morning, an entire military

11     company, three trucks -- it was early in the morning, at about 6.00, as I

12     was in the ticket box selling tickets.  There were at least 100 soldiers

13     went past, and it was then that the incident took place.  I heard about

14     it.  I heard that two Serbian soldiers were killed and there were wounded

15     Muslims.  And as a result, these individuals were brought to the camp in

16     Pale.

17        Q.   Well, please don't mind the fact that we have to be precise.  Is

18     it correct that before this action that you described of the 22nd of May,

19     a small patrol set off, and two policemen from that small patrol were

20     killed by Muslims in Renovica; yes or no?  Just go ahead and say it.

21        A.   Well, I don't know anything about it.  I don't know if this is

22     how they set off and if anything like that actually happened.

23        Q.   All right.  We will come back to the 22nd of May.

24             In paragraph 16, you say that there were two special units in

25     Pale.  How could you tell that these were special units?

Page 15343

 1        A.   Well, I knew them from before.  I knew Knezevic very well, I knew

 2     Rajko Kusic also.  And when I was selling tickets when I was working down

 3     there, I would see them.  They called them Specials.  They wore caps,

 4     multi-coloured uniforms.  They walked around Pale like some gang.  They

 5     did whatever they want.  When I was detained, they came 'round and they

 6     created the most problems, committed killings, beatings, and so on.

 7        Q.   Thank you.  Are you trying to say that this was a police and a

 8     military unit or these were some units that were not part of the general

 9     forces?

10        A.   I don't know.  These were units -- how can I describe them?  They

11     were special units, that sort of units.  They could do whatever they

12     wanted.

13        Q.   Is it Rajko Kusic, not from Rogatica, but the one from Pale, who

14     was a well-known athlete, karate specialist and a policeman?

15        A.   It was Rajko Kusic who was from --

16             THE INTERPRETER:  The interpreter did not hear where he was from.

17             THE WITNESS: [Interpretation] That was the one.

18             MR. KARADZIC: [Interpretation]

19        Q.   Do you know that he was --

20             JUDGE KWON:  Just a second.

21             The interpreters didn't hear where that Rajko Kusic was from.

22             THE WITNESS: [Interpretation] From Korani.  Actually, it's an

23     area of Pale by the name of Koran.

24             MR. KARADZIC: [Interpretation]

25        Q.   And you say that you know that he was a member of the SDS.  Do

Page 15344

 1     you know that he was a policeman?  And how do you know that he was a

 2     member of the SDS when you said that you did not see him with other

 3     members of the SDS?

 4        A.   Well, how should I know if he was in the SDS or not.  He probably

 5     was.  The SDS party was a popular one, and since he was in a special

 6     unit, he must have been a member of the SDS.  This is normal.

 7        Q.   Did you know any SDA members at Pale?  Was there an SDA branch in

 8     Pale?

 9        A.   Since I wasn't a member of any party, I didn't know anyone who

10     was in the SDA or in any party.  I wasn't really interested in that at

11     all.

12        Q.   So you were more familiar with the SDS membership than with the

13     SDA membership?

14        A.   No, Mr. Karadzic.  I am saying that most probably they were

15     members of the SDS.  They wouldn't have been there at all had they not

16     been members of the SDS.  The SDS was there, people were members of the

17     SDS.  One knows what happened later with the SDS.

18             THE INTERPRETER:  Could Mr. Karadzic please repeat his question.

19             JUDGE KWON:  The interpreters didn't hear your question.  Please

20     repeat your question.

21             MR. KARADZIC: [Interpretation]

22        Q.   Did you know that there was a very strong SDA organisation in

23     Pale and that well-known members of the SDA from Pale, Serif Becic,

24     Munir Radaca and Kemo Hrvo, already in 1991, took part in the formation

25     of the Patriotic League?

Page 15345

 1        A.   No, I didn't know that.  I didn't live in Pale.  I lived in

 2     Sarajevo.  I only worked in Pale.  I really didn't have too much time to

 3     speak about that or ask about it.  I wasn't really interested in that.  I

 4     only worked in Pale and lived in Sarajevo.

 5             THE INTERPRETER:  Interpreter's correction:  I lived in Sarajevo;

 6     I worked in Pale.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   But obviously you were interested in the Serbs?

 9        A.   I wasn't interested, but I just happened to be familiar with them

10     to know them, and it would have been better had I not.

11             THE ACCUSED: [Interpretation] Could we please look at 1D3733.

12             MR. KARADZIC: [Interpretation]

13        Q.   This is the letterhead of the Muslim magazine "Preporod,"

14     "Rebirth"; is that right?

15        A.   I don't know.

16             THE ACCUSED: [Interpretation] Can we look at page 2 in the

17     Serbian.

18             Could we zoom in a little bit more on the left two-thirds.  You

19     don't need to zoom in on the whole text.

20             MR. KARADZIC: [Interpretation]

21        Q.   Allow me to read to you, briefly, the second sentence from the

22     beginning:

23             "The first staff of the Patriotic League of Bosnia-Herzegovina

24     was formed in the mosque in Soukbunar precisely on this day, the 31st of

25     March, 1991, and was made up of Serif Besic, Radaca and Kemo Hrvo from

Page 15346

 1     Pale.  And you didn't hear of this, not even that this was formed, and

 2     you didn't hear of these prominent Muslims from Pale?

 3        A.   No.  I don't know why you're showing this to me at all.

 4        Q.   With all due respect, Mr. Karic, I'm not accusing you of

 5     anything.  I'm just trying to see what it is that you know and whether

 6     what you know is objective and balanced.

 7        A.   Well, that, I don't know.

 8             THE ACCUSED: [Interpretation] Is this being accepted?

 9             JUDGE KWON:  No basis for us to admit this at the moment.  We'll

10     not admit this.

11             MR. KARADZIC: [Interpretation] Thank you.

12        Q.   Do you remember that all the villages -- actually, all Muslim

13     villages handed over illegal weapons, except Renovica?  You know that?

14        A.   No, I don't.

15        Q.   In paragraph 17 of your amalgamated statement, you say that 200

16     to 300 soldiers, led by Malko Koroman, went in the direction of Renovica

17     with one bus, two trucks, and three Pragas, and at 7.00 in the morning.

18     And this is paragraph 17.  Today, you said it was 100 soldiers or 100

19     policemen.  How do you know all of this?

20        A.   Well, more or less, just judging how many people can fit into a

21     bus, into a truck, and how much the Pragas take up.  Perhaps it was not

22     100, 150.  Maybe it was 200, 250.  There were many, many of them on the

23     bus, around the bus, on the platform, on the roof.  They were all over.

24     I saw it with my own eyes as they passed by.  I don't know if it was a

25     hundred, 200, 250.  I don't know.

Page 15347

 1        Q.   Thank you.  You said that you saw that.  Did Malko Koroman

 2     command the army or the police?

 3        A.   As far as I know, he was in command of the police, but at the

 4     time, who knows who was in command of what?

 5        Q.   Mr. Karic, with all due respect, it's important to the

 6     Trial Chamber to see if the military or the police embarked on the

 7     campaign to disarm the civilians.  Malko Koroman was in charge of the

 8     police station, not the army; is that correct?

 9        A.   Well, as far as I could see, they were both soldiers and

10     policemen.  I don't know who commanded them.

11        Q.   How could you tell the police and the military apart?

12        A.   Well, the military, they had camouflage uniforms, and the police

13     wore thick, dark blue uniforms.  It was the police reserves.

14        Q.   And it was only by that?  You didn't know what military unit it

15     was, did you?

16        A.   No.

17        Q.   Perhaps they were policemen as well, but they were not wearing

18     blue uniforms, is it?

19        A.   No, it wasn't like that.  I think it was half police and half

20     soldiers.

21        Q.   Which army?  Which army was that, Mr. Karic?

22        A.   The Serbian military.

23        Q.   Thank you.  In your statement from 1992, you said that you heard,

24     but today you say that you saw?

25        A.   What?

Page 15348

 1        Q.   Well, 1D3675 is where you say, page 2-5:

 2             "As I heard, assisted by three Pragas, they left with the

 3     intention of disarming Muslims from Renovica, and that is when fighting

 4     broke out."

 5             Is that correct, "as I heard"?

 6        A.   No, it wasn't "as I heard," but it was as I saw with my own eyes.

 7        Q.   In this statement, it says "as I heard."

 8             Let's go to item 5:

 9             "Assisted by five Pragas, they left with the intention of

10     disarming Muslims from Renovica, and that is when the conflict broke out.

11     That day, they captured 28 Muslims from Renovica and brought them to the

12     sports hall at Pale."

13             This was the 22nd of May; is that correct?

14        A.   Yes.

15        Q.   In your statement from 1994, 1D3678, you mentioned that 500

16     soldiers went to disarm Muslims?

17        A.   You are again --

18        Q.   You do not mention Lazar Bojat, to whom we will come back.  Well,

19     let me read to you that paragraph.  Here also, you heard, is that

20     correct?  And now we're going to read that:

21             "That day, on the --"

22             THE INTERPRETER:  The interpreters kindly ask for the reference.

23             JUDGE KWON:  We are not hearing any interpretation.  You need to

24     give a reference to the interpreters.

25             THE ACCUSED: [Interpretation] This is 1D3678, page 2,

Page 15349

 1     paragraph 3, line 10:  "That day ..."

 2             At the beginning of the line, it says:  "22nd of May ..."

 3             Line 10 in the third paragraph:

 4             "On that day, 22nd of May, 1992, I saw Malko Koroman, the Pale

 5     Police Station commander, on a military personnel carrier, followed by

 6     about 500 men in military uniform, and I heard that they also had three

 7     Pragas.  I was told that special forces members Rajko Kusic and so on,

 8     were with Koroman then."

 9             MR. KARADZIC: [Interpretation]

10        Q.   Do you see that paragraph?

11        A.   No, I don't see it.

12        Q.   Well, you can look at the cursor.  That will show you where it

13     is:  "That day ..."  Can you see the place where the cursor is?

14        A.   Yes, I see it.  Well, I was just telling you about the numbers,

15     200, 300, 500.  There were many, many.  I don't know how many, but there

16     were many soldiers compared to the number of the Renovica inhabitants.

17        Q.   But here you say that you heard from the local inhabitants, and

18     you say that you heard that they had Pragas?

19        A.   Well, no, it wasn't the inhabitants.

20        Q.   All right.  It does say "inhabitants," "locals."  That's what it

21     says.

22             All right, well, let's go back to the statement where you talk

23     about Lazar Bojat.  This is 1993 now.

24        A.   What 1993?

25             THE ACCUSED: [Interpretation] Well, all right.  1D3676.

Page 15350

 1             MR. HAYDEN:  Sorry to interrupt, Mr. President.

 2             Assuming these other statements are not going to be admitted into

 3     evidence, I just note the accused's characterisation of what the witness

 4     said in this is misleading.  He does state that he saw the men, and it's

 5     only referring to the three Pragas that he heard that information.

 6             JUDGE KWON:  Yes, that has been noted.  Thank you, Mr. Hayden.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   In this paragraph, the statement from 1993 - this is also on

 9     page 2 - you also say:

10             "The 22nd of May, since we were all interested to find out what

11     all this was about, Lazar Bojat, the Centrotrans driver, said that they

12     were going to slaughter the few Muslims in Renovica, and that they would

13     come back quickly in the column moving towards Renovica, there were three

14     Pragas, two trucks, and a bus," and so on and so forth.

15             So in your statement, you say that they set out to disarm the

16     Muslims, and here you are quoting, and in other statements you do not;

17     you quote Lazar Bojat saying that they were going to go and slaughter

18     Muslims?

19        A.   When I was selling tickets, Lazar was standing in front of the

20     ticket office.  There were a lot of people waiting to buy tickets.  They

21     were travelling to Belgrade, Cacak.  I mentioned that before.  Then when

22     these Pragas came by and those soldiers, there was a lot of noise.  It

23     was thundering like it was shooting.  Somebody said, What is this?  And

24     he said, Well, they're just going off to slaughter some Muslims, and

25     they'll be back soon.  It was a kind of off-the-cuff remark.  He was not

Page 15351

 1     with the soldiers.  He was at his work-place, driving the refugees.  And

 2     it was only because I heard from him that I knew where they were going

 3     and what they were meaning to do.  I couldn't ask, but I concluded where

 4     they were going by what he said.

 5             In the afternoon, I heard that there was shooting there, some

 6     people were killed, some people were arrested, and so on.

 7        Q.   Thank you.  In this statement of 1997 - that is 1D03680 - you

 8     say:

 9             "On the 22nd of May, 1992, I returned to Pale.  And then in Pale,

10     I came to the conclusion that a larger group of armed soldiers was

11     getting ready with two Pragas, one bus.  Rade Hrsum drove it.  They were

12     to go to Renovica.  Among these masses, I noticed Lazar Bojat.  When I

13     heard a comment from him that the soldiers were going to Renovica to

14     slaughter some Muslims, and that they would come back soon."

15             You say here that you saw him among these masses in Pale that

16     evening, and a moment ago you said that you heard him say this by the

17     ticket office?

18        A.   No way.  What do you mean, in the evening?  It was that morning.

19     There was no evening.  It was in the morning, among these masses of

20     people who were there at the ticket office.  He was standing there as the

21     driver who would drive those masses.  You keep asking about all this

22     silly stuff, and you stick to this and that.  All of this is the truth.

23     I've already told you that.  There are no lies here.

24             THE ACCUSED: [Interpretation] Sorry, maybe I misspoke.  It says

25     "a larger group of Muslims," actually, and I misread it as meaning

Page 15352

 1     "evening."

 2             THE INTERPRETER:  The interpreter did not hear the answer.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Here it says:

 5             "On the 22nd of May, I returned to Pale."

 6             Where did you return from?

 7        A.   From nowhere.  I was there at the ticket office.  That's where my

 8     uncle lived, right by the building there.  I mean, what kind of

 9     translation is this?  What is this?  I have no idea.  Where could I be

10     returning from?

11        Q.   When you mentioned that you were going to Sokolac to shop for

12     food, did they check your ID?

13        A.   Yes, at Sokolac, up there at a check-point.

14        Q.   They saw that you were a Muslim.  They let you buy food and

15     return to Pale; right?

16        A.   Yes, thanks to the driver who was driving, because I was their

17     boss.  So he said something to him.  I don't know what he said, but he

18     let me go.

19        Q.   A moment ago, you said you didn't know about the ultimatum in

20     Renovica for weapons to be surrendered.  Did you know about this

21     ultimatum or not?

22        A.   No.

23        Q.   Thank you.  But in the Mandic trial in Sarajevo - 1D3682 is the

24     number of the document; in Serbian, it's page 23, and in English, it's

25     24 - you said that they set out at 6.00 in the morning, and then you say:

Page 15353

 1             "Witness Karic:  Because there was this ultimatum presented to

 2     Renovica that they had to hand over their weapons because Praca had

 3     already surrendered and Podgrab, they had surrendered their weapons, and

 4     Renovica, not.  And one morning, they got up early.  It was about 6.00,

 5     and they went in the direction of Renovica."

 6             Is that what you said?

 7        A.   Possibly, but this was talk amongst these masses of people,

 8     Lazar Bojat saying this and that.  I mean, what?  I wasn't interested in

 9     that.  It's not important at all.

10        Q.   It is important to me.

11        A.   Oh.

12        Q.   Did you know that there was an ultimatum, and that the others had

13     responded, and that the police did not go there, and Renovica had not

14     surrendered its weapons, and the police, therefore, went there; right?

15        A.   Well, that's what Lazar Bojat said, that.

16        Q.   Thank you.  In paragraph 20, you say that all Muslims were

17     dismissed that day in Pale.  This is what this paragraph says:

18             "After that, I did not leave my house because they started

19     arresting Muslims and taking them away.  On the day of the attack against

20     the village of Renovica, all Muslims who worked in the municipality of

21     Pale were laid off.  Miso Danojlovic, who worked in Centrotrans and who

22     was also commander of the reservists in Pale, told me not to come to work

23     anymore."

24             Were the Muslims in Pale dismissed from work?

25        A.   As for Centrotrans, yes.  These other companies weren't working

Page 15354

 1     anyway.

 2        Q.   Who were these Muslims who were dismissed from Centrotrans?

 3        A.   The drivers, and I along with them, and the mechanics that were

 4     there.

 5        Q.   Can you give us their names?

 6        A.   Well, all the Muslims who were there:  Hasib Halilovic;

 7     Sipovic, Aga; Milutovic, Alija -- Malovic, Dzemo; Ljutovic, Alija; Dzemo;

 8     Becic, Vahid; Nesevic, Enver; Ferhatovic, Avdo, and so on and so forth,

 9     not to enumerate all of them, all the Muslims who were there; drivers,

10     conductors, I along with them, the mechanics.

11        Q.   Now let us see whether you were dismissed on the 7th or the 9th

12     of April, when Paradzina came and told you to get away until the

13     situation calmed down?

14        A.   No, because he was not in a position to dismiss me.  It was not

15     for him to say.

16        Q.   And then when, on the 22nd, after this fighting in Renovica,

17     Miso Danojlovic came to you and said to you that you shouldn't come to

18     work.  Did he actually dismiss you officially?  Did he give you a

19     document stating that?

20        A.   No, but he said, For your own safety, don't come back to work

21     anymore.

22        Q.   Thank you.  Now I am perplexed, Mr. Karic.  You say that you were

23     detained on the 22nd of May.  You say that you were called to the police

24     station?

25        A.   No.  It was on the 28th of May.  Actually, sorry, the 30th.

Page 15355

 1        Q.   The 30th?

 2        A.   Yes.

 3        Q.   Let us see now what you said here on the 15th of May, 1993.

 4             1D0368.

 5             This is what you say:

 6             "The same evening --" or, rather, "the 22nd of May" - here you

 7     say it's in the evening - "after the operation in Renovica in 1992, two

 8     policemen came to my home and said that I had to go to the police station

 9     to give some statement.  I set out, came to the police station.  However,

10     that evening there was no one to hear me out, and one of the policemen

11     said that I would have to spend the night in detention or, rather, at the

12     old cultural centre."

13             Is that the way it was?

14        A.   All of it was that way, but that's not the date.  I don't know

15     about these dates.  I mean, really, they're confusing -- you're confusing

16     them all the time; the 22nd, the 23rd, the 25th, the 28th.  Now, was it

17     the 28th or the 30th, but I think that the 30th would be the right date.

18     And it wasn't that evening of the 22nd when they were arrested.  It was

19     five or six days later, and then they came to get me.

20        Q.   Did any one of these arrested persons inform on you because of

21     something?

22        A.   No, because Vehbija Karic is my uncle, so it was only because of

23     that.

24        Q.   Once again, please, let us speak slower and let us pause between

25     question and answer.

Page 15356

 1             So what you stated in 1993, that the same evening after this

 2     operation on the 22nd of May, you were summoned to the police station,

 3     that you set out, that you arrived at the police station, that is not

 4     correct; right?

 5        A.   No, it's the 30th.  Or does it really matter, the 25th, the 30th?

 6     I mean, what are you asking me all of this for?  It was the 25th, the

 7     30th, whatever date.  Who can possibly remember after all of these years?

 8        Q.   Thank you.  Please don't be so angry.  I'm not inventing all of

 9     this.  I'm reading your very own statement that you gave right after all

10     of this happened in 1993.

11        A.   Yes, but you keep sticking to all this silly stuff, and you're

12     asking me all of this silly stuff.

13        Q.   All right.  Maybe I'm a bit silly, but this lack of clarity

14     bothers me.

15             So you say, I set out and I arrived.  So did you arrive at the

16     police station because you were summoned there?

17        A.   No.

18        Q.   Did you give any statement at the police station?

19        A.   No.

20        Q.   You were never questioned?

21        A.   No.

22        Q.   Let us see what you said in the Mandic trial.  1D3682, Serbian

23     page 5, English page 5 also.

24             We can start from Serbian page 4, and in English we can keep

25     page 5.

Page 15357

 1             The Prosecutor, Krnjic, asked you about the statement you gave on

 2     the 8th of February, 2006, and you said it was the 28th of May.  Can you

 3     remember exactly which date it was?  Now, was it April or May?

 4             And you say:

 5             "I think it was April.  I can't really handle these days anymore.

 6     On the 22nd.  I think it was on the 28th, it was then, I reckon it was

 7     then."

 8             Prosecutor Krnjic:

 9             "Fine.  You have told us that these two policemen told you that

10     you had to make a statement."

11             You say:

12             "The 28th of May," and then you repeat, "May, May."

13             And then on page 5 in Serbian, you say, in English, it's also

14     page 5.  Did anyone take a statement from you?

15        A.   No one did.

16        Q.   But the answer you gave here was:

17             "That evening, when they brought me, no one did, but the next day

18     some person did take a statement from me.  I can't remember his name

19     anymore.  Well, I don't know what it was called.  I think it was some

20     kind of interrogator.  He worked in Pale then."

21             So you did give a statement the following day to a policeman in

22     Sarajevo, or at least that's what you said during the trial in Sarajevo?

23        A.   I cannot remember any longer.  I cannot say anything.  Did that

24     happen, did that not happen, I really cannot say.  Maybe it did, maybe I

25     didn't.  Now I'm thinking about it, and I really cannot think and cannot

Page 15358

 1     remember any of it.

 2        Q.   Mm-hmm, thank you.  When Judge Rodrigues asked you -- is that

 3     actually a foreign Judge in the Court of Bosnia-Herzegovina?

 4        A.   Well, probably.  I don't know.

 5        Q.   This same document, Serbian page 31, English 34-35, you answered

 6     the following to Judge Rodrigues:

 7             "They only asked me, 'Where is your Uncle Vehbija?'"

 8        A.   Yes.

 9        Q.   "'We'll catch him.  He'll get here too.'  And then they accused

10     me of something that happened before the war.  Delimustafic's father

11     travelled on the bus and forgot his personal ID card there, and I -- or,

12     rather, one of the conductors brought me that personal ID, and I left it

13     in the drawer.  And these drawers are in the table, and it was there

14     perhaps three or four years, I mean this personal ID.  And then, I mean,

15     when I was discharged of my duties up there and then when I left from

16     there, they found that ID in the desk, and there you go.  They were

17     saying that I had co-operated with Delimustafic, and that was the reason

18     to arrest me, and that was the reason ... ," and so on.

19             And Judge Rodrigues says:

20             "All right.  This statement, was it taken in written form or

21     not?"

22             And you say:

23             "It was taken.  They typed it out on one of those machines,

24     typewriters."

25             Judge Rodrigues said:

Page 15359

 1             "Did you sign it?"

 2             And you say:

 3             "I believe they didn't give me anything to sign.  I can't

 4     remember."

 5             So was this Delimustafic, Alija Delimustafic, who was the

 6     minister of the interior, was it his personal ID that you had in your

 7     desk for four years?

 8        A.   No, not his personal ID; his father's ID.  His father had

 9     travelled.  He had lost it.  They found it.  They brought it to me.  He

10     never came to pick it up.  And this, what you're -- here, this is what he

11     whispered to me as we were standing.  So it wasn't any kind of interview.

12     This was just a conversation in passing in this hall where all of us were

13     detained.

14        Q.   So they accused you of co-operating with Minister Delimustafic,

15     and that that was the reason why you were detained?

16        A.   Yes, that's right.

17        Q.   Did they think perhaps that it was a forged ID that for some

18     reason you had obtained for yourself?

19        A.   I don't know what they were thinking.  This ID was there and then

20     this little note pad of his.  I never even looked at it.  At the time, I

21     didn't even know who this Delimustafic was.  I was never interested in

22     politics; not to this day, actually.

23        Q.   All right.  You said here that they asked you about

24     Vehbija Karic?

25        A.   Yes.

Page 15360

 1        Q.   Can you tell the Trial Chamber who Vehbija Karic is, otherwise,

 2     and what he is to you?

 3        A.   Vehbija Karic is a relative of mine, a close relative.  Well, not

 4     that close, not exactly my uncle.  I don't know how to explain this.

 5        Q.   Is it correct that Vehbija Karic was a general and that he was in

 6     the JNA all the way up until the 10th of April, approximately, and then

 7     he deserted, he left the JNA?

 8        A.   That, I don't know.  I know he was an officer in the JNA.  And

 9     what kind of officer, and when he left, and whatever, I don't know any of

10     that.  I hadn't seen him until a year or so ago.  I don't really see him.

11        Q.   Did he later become commander of the Muslim army?

12        A.   I don't know anything about that.

13        Q.   Are you ashamed of Vehbija Karic or are you proud of

14     Vehbija Karic?  How come you don't know what your uncle did?

15        A.   I just told you that he wasn't my uncle and he wasn't that close

16     to me.  I am not ashamed of him at all.  Why would I be ashamed of him?

17     I didn't contact him that much before the war, during the way or after

18     the war.  I'm just telling the truth.  We are related, but it's not that

19     we are really in touch a lot.

20        Q.   A moment ago you said, Because Vehbija Karic is my uncle, my

21     uncle, "amidza," and I believe that that is the Turkish word for paternal

22     uncle.  Right?

23        A.   Yes, but that's what they said to me, actually, and that is what

24     you're saying.

25        Q.   But let us look at paragraph 23 of your statement.  You say:

Page 15361

 1             "After the arrest, two days later a member of the Serb

 2     paramilitary formation came to the prison and said to me that I was under

 3     arrest because my brother-in-law took part in fighting near the village

 4     of Bukovica.  On that occasion, he beat me and hit me in the head four

 5     times."

 6             Who was this brother-in-law of yours?

 7        A.   Zecan.

 8        Q.   And what is his last name?

 9        A.   Salispahic.

10        Q.   What was his first name?

11        A.   Well, that I don't know.

12        Q.   Is his name Ibro Salispahic?

13        A.   Oh, yes, it is.  Well, it's a good thing you just reminded me.  I

14     didn't know that.

15             THE ACCUSED: [Interpretation] Thank you.

16             Can we look at 1D3719.

17             MR. KARADZIC: [Interpretation]

18        Q.   This is a letter of Biljana Plavsic, a member of the Bosnia and

19     Herzegovina Presidency, later vice-president of Republika Srpska.

20             Can we please look at the second page.  Those who read English

21     can see that this is information about the aggression of Croatia against

22     the Republic of Srpska, genocide against the Serbs, and so on and so

23     forth.

24             Can we look at page 17 now, please.

25             Do you know where the village of Vukasinovic is?

Page 15362

 1             Probably, it's the following page.  The paper number is 17, but

 2     the e-court page is probably 18.

 3             Mr. Karic, do you know where the village of Vukasinovic is?

 4        A.   No, I don't.

 5        Q.   You don't know that Vukasinovic is between Renovica and Gorazde?

 6        A.   No.

 7        Q.   Now I'm going to read to you what happened in Vukasinovici on the

 8     25th of May in English, and then they will translate that for you:

 9             [In English] "Village of Vukasinovici, municipality of Gorazde,

10     May the 25th of 1992:  A Muslim unit of TD of BH," "TO," probably, "under

11     the command of Suad Hamzic, slaughtered eight Serbs; Veljko Vukasinovic

12     (72); Danica Vukasinovic - Veljko's wife (65), Milos Vukasinovic (64);

13     Jovanka Vukasinovic - Milos's wife (60); Vukasin Vukasinovic (90);

14     Bozana Vukasinovic - Vukasin's wife (75)."

15             Next page, please:

16             "Milorad Vukasinovic (78); and Grozda Vukasinovic - wife of

17     Perko Vukasinovic, the only one who survived the carnage."

18             I don't think Perko Vukasinovic survived; her husband.

19             "After having slaughtered them, the Muslim unit, including

20     Ferid Aganovic and Ibro Salispahic, burnt them down together with their

21     houses.

22             "Next night, the same unit slaughtered nine Serbs in the village

23     of Leleci and burnt down the houses."

24             [Interpretation] Do you know where the village of Leleci is?

25        A.   I think it's somewhere behind Bare.

Page 15363

 1             JUDGE KWON:  Yes, Mr. Hayden.

 2             MR. HAYDEN:  Objection to this line of questioning.  I'm

 3     wondering what the relevance is.

 4             THE ACCUSED: [Interpretation] It's going to be very clear, what

 5     the relevance is.  These are very critical days, and there will be

 6     reasons for arrests given.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Look at this paragraph, where you were told that you were

 9     arrested because your paternal uncle -- or brother-in-law participated in

10     fighting.  Actually, not participated in fighting, but slaughtered old

11     men and women in the villages of Vukasinovici and Leleci.  What do you

12     say to that?

13        A.   Well, I don't have anything to say.  He knows whether this

14     happened or not.  It's a matter of whether this is proved or not, but it

15     has nothing to do with me.

16        Q.   But, still, you want to stay away from what he did by forgetting

17     his name; is that the reason why you forgot the name of your wife's

18     brother?

19        A.   No, that's not the reason.  My wife and I got divorced or

20     separated in 1996.  It's been 15 or 16 years since then, and I've

21     forgotten these names.

22             THE ACCUSED: [Interpretation] Could we please tender this

23     document?

24             JUDGE KWON:  Mr. Hayden.

25             MR. HAYDEN:  Objection, Mr. President.

Page 15364

 1             It hasn't been authenticated at all by this witness, and in our

 2     view, it's not relevant.

 3                           [Trial Chamber confers]

 4             JUDGE KWON:  As far as this document is concerned, since the

 5     relevant part of the text has been read into the transcript, the Chamber

 6     does not find the need to admit this.  We'll not admit this, in addition

 7     to the reasons referred to by Mr. Hayden.

 8             MR. KARADZIC: [Interpretation] Thank you.

 9        Q.   And then you said that in battle, some Muslims in Renovica were

10     arrested and brought to the sports hall in Pale.  You stated that in your

11     statement of 1994, 1D3678; is that correct?

12        A.   Well, I'm sorry, I didn't understand what you're asking me.

13        Q.   You said that on that day, the 22nd of May, when they came back,

14     they brought with them captured Muslims from Renovica, they brought them

15     to the Pale Sports Hall; is that correct?

16        A.   Yes.

17        Q.   At the time, were you hiding in Pale?

18        A.   On the 22nd, I was at home.  I hadn't gone out anywhere.  Had I

19     left the house, perhaps I would have been arrested sooner.

20        Q.   In that paragraph, you say:

21             "I was staying and hiding in Pale at my relative's place, and

22     then on the 30th of May, 1992, I was taken to this place in the centre of

23     Pale, where I found approximately 100 others of Muslim ethnicity."

24             And so on and so forth.

25             Is that correct?

Page 15365

 1        A.   Yes.

 2        Q.   What was the reason for you to start hiding on the 22nd of May

 3     and not before the 22nd of May?

 4        A.   Well, the reason was that the arrests of Muslims had started.

 5     Before that, there were no arrests.  There was an attack there on that

 6     day, and then they arrested 28 or 30 of them.  I think it was 28 or 30,

 7     people from Renovica.  And then after that, after five or six days later,

 8     I was brought, and I joined the other group, and we were all together

 9     until the 28th of August, when we were all released.

10        Q.   And how many Muslims were there in Pale at that point in time?

11        A.   I don't know.  I mean, there were as many as were living there.

12        Q.   And it was only you and these hundred people from Renovica that

13     had been arrested.  Why weren't all the Muslims in Pale arrested?

14        A.   Well, that was your policy, why they weren't arrested.  You

15     transferred them all to Sarajevo in buses to get rid of them, to make

16     yourselves look good, and that's it.

17        Q.   Mr. Karic, I'm asking you:  Why do you say that you started to

18     hide on the 22nd of May, when the fighting broke out in Renovica, and why

19     were you arrested and not your father-in-law?

20        A.   Well, my father-in-law was not arrested because he fled.  Also,

21     my mother-in-law, my brothers-in-law, they all left.  They managed to

22     escape when the attack was taking place.

23        Q.   And where were you staying in Pale?

24        A.   At my uncle's.

25        Q.   What happened to him?

Page 15366

 1        A.   Nothing.  He, on the 11th, or on the 9th, or the 10th, or the

 2     11th, they were all transferred to Sarajevo by buses via Hresa.  All the

 3     refugees from Vrace, Podgrab and Pale were transferred by buses to

 4     Sarajevo.

 5        Q.   Which 11th, of what month?

 6        A.   The month of July.

 7        Q.   And when wasn't he arrest -- why wasn't he arrested when you

 8     were?

 9        A.   Well, I have no idea why not.

10        Q.   Is he a Muslim?

11        A.   Yes.

12             THE ACCUSED: [Interpretation] Thank you.

13             JUDGE KWON:  Did you say yes to the question whether he was a

14     Muslim?  Yes, I now note it.

15             THE WITNESS: [Interpretation] Yes, yes.  That was my uncle.

16             MR. KARADZIC: [Interpretation]

17        Q.   In the statement from 1992 about your detention in Pale, you say,

18     in paragraph 24 -- and you say that in the amalgamated statement, there

19     were about 150 to 200 Muslims in the sports hall.  In another statement,

20     you say it was 60.  This is in 3625.

21        A.   Well, you just keep dwelling on these numbers.  I mean, it was a

22     full hall.  You weren't allowed -- you didn't dare to speak to anyone or

23     look at anyone.  You keep dealing with these things that are unimportant.

24     They were quite irrelevant.  Everything that you have been asking me so

25     far has nothing to do with anything.  It's all just completely

Page 15367

 1     irrelevant.

 2        Q.   Well, all right.  Perhaps I'm not much -- a very intelligent

 3     person, but there's nothing much that can be done about that.  But it is

 4     important if we're talking about 60 people, or 150, or 200 people.

 5        A.   All right, it was a packed hall, as many people as can be fit

 6     into a packed hall.

 7        Q.   All right.  And then you say that you were taken out and beaten,

 8     and that -- let's find where that is, which paragraph that is.

 9     Paragraph 33.  They started to curse at you and hit you with a wooden

10     stick on your back, and so on and so forth.  Milomir Tepes appeared at

11     the door.  And before the examination-in-chief it was written "Tepic," so

12     can we correct that in the transcript, if the witness confirms that it

13     was Milomir Tepes who said, Not him, that's not him."

14        A.   Yes.

15        Q.   And did you find out who they mixed you up with?

16        A.   Probably it was the driver, Hasib Halilovic, but I don't know

17     what he could have done wrong.  I don't know why they were looking for

18     him.

19        Q.   Well, do you know what it is that he did wrong that they wanted

20     to beat him because?

21        A.   Well, you didn't have to do anything wrong.  They were just

22     looking for anybody just to take it out on them.  These were not proper

23     soldiers.  These were all civilians, people.  Their only fault was that

24     they were Muslims, as far as you're concerned.  I'm talking about the

25     people who were there.

Page 15368

 1        Q.   And then they stopped hitting you, and they pushed you back into

 2     the hall.  They stopped when this guy warned them that you were not the

 3     one; is that correct?

 4        A.   Yes.

 5        Q.   In a statement from 1993 - this is 13677 - you said that there

 6     were two dead bodies in the room where you were.  And then after that,

 7     you never again mentioned those two bodies?

 8        A.   When somebody would ask me, I would answer.  I don't know that I

 9     didn't mention them.  Every time I spoke about that, these were innocent

10     people who were killed.  I knew them from before the war, who they were,

11     what they were.

12        Q.   In paragraph 36 of this statement, you mention an event relating

13     to Fahrudin Sipovic?

14        A.   Sipovic.

15        Q.   Sipovic or Sipovic?

16        A.   Sipovic.

17        Q.   Thank you.  All right, Sipovic.  So the event is mentioned only

18     in your statement from 1992.  This is 65 ter 22134.  Why did you never

19     mention that before?

20        A.   Well, I actually did.  That was the first statement.  It was very

21     important, and these were the people who were killed, beaten the most,

22     who had suffered the most in captivity in this war.  There were numerous

23     others, but these are the ones that I remembered and the ones that I knew

24     before we were detained.

25        Q.   This is what you said in paragraph 36 -- 36, not 65; 36:

Page 15369

 1             "On the 6th of July, 1992, I was ordered to go to the --"

 2             JUDGE KWON:  Yes.

 3             MR. HAYDEN:  I apologise for the interruption.

 4             I'm trying to keep up with the pace here, but I'm struggling to

 5     find the references here, particularly this last one to the 1992

 6     statement.  If we could have some direction, please.

 7             JUDGE KWON:  Can you help us, Mr. Karadzic?

 8             THE ACCUSED: [Interpretation] We have it on the screen.  This is

 9     65 ter 22134, and it's on the screen.  The Registrar found it.  No, I'm

10     sorry, this is the last statement.  Just one moment.

11             This is the statement from 1993.  That is 1D3677, and it says:

12             "On one occasion, I was taken to that room.  And the room where I

13     was taken to, there were already two dead bodies there who had been

14     killed by sticks, wooden sticks."

15             And this is 1D3677.

16             MR. KARADZIC: [Interpretation]

17        Q.   In the amalgamated statement, paragraph 36, you say:

18             "On the 6th of July 1992, I was ordered to go out to the locker

19     room to get one detainee.  My left hand still hurt from the blows.  I saw

20     Fahrudin Sipovic on the floor.  He couldn't get up.  His arm was broken,

21     and he was all bloody.  He tried to get up, and then when he almost made

22     it, the soldier again hit him with a piece of wood.  I forgot my pain.  I

23     helped Fahrudin to stand up and brought him back to the hall.  Fahrudin

24     survived the beatings.  As far as I know, today he is working as a

25     policeman in Renovica."

Page 15370

 1             There is no "two dead bodies" there.  In the amalgamated

 2     statement, you do not mention these two who are dead, and that is your

 3     final statement.

 4             JUDGE KWON:  Yes, Mr. --

 5             MR. HAYDEN:  Can we please bring up the statement that apparently

 6     contradicts what the witness just said so he can at least see that for

 7     himself?

 8             JUDGE KWON:  We'll do that tomorrow.

 9             Mr. Karadzic, you'll have exactly five minutes tomorrow, not a

10     second more.

11             There's one further matter.  From tomorrow on, with the agreement

12     of the staff members, we revert to the original sitting schedule, when we

13     are sitting in an extended format, i.e., 9.00 to 3.00, meaning that we'll

14     have an hour break from 12:30 to 1:30.

15             Mr. Karic, we have to adjourn for today.  I appreciate your

16     patience.

17             We'll resume tomorrow morning at 9.00.

18                           [The witness stands down]

19                           --- Whereupon the hearing adjourned at 2.32 p.m.,

20                           to be reconvened on Friday, the 24th day of June,

21                           2011, at 9.00 a.m.