Tribunal Criminal Tribunal for the Former Yugoslavia

Page 19046

 1                           Monday, 19 September 2011

 2                           [Open session]

 3                           [The witness entered court]

 4                           [The accused entered court]

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

 6             JUDGE KWON:  Good morning, everyone.  We will be sitting for the

 7     whole of this week pursuant to Rule 15 bis.  Judge Morrison should be

 8     away due to his obligation in his country.

 9             Good morning, witness, I hope you had a good weekend.

10             THE WITNESS: [Interpretation] Good morning.  Thank you.

11                           WITNESS:  KDZ-075 [Resumed]

12                           [Witness answered through interpreter]

13             JUDGE KWON:  Yes, Mr. Karadzic?

14             MR. KARADZIC: [Interpretation] Good morning, Excellencies, good

15     morning to all.

16                           Cross-examination by Mr. Karadzic: (Continued)

17        Q.   Good morning, Mr. Witness.

18        A.   Good morning.

19        Q.   Could you please help us understand what happened exactly and in

20     which way.  Did I understand things correctly?  Were you hiding for all

21     of two months?  Is that right?  And if so, where?

22        A.   It is correct that I was hiding for about two months from 10 July

23     until 20 September, or rather to be more precise, 10 September.  I hid on

24     the outskirts of the village, in the corn fields and near the woods close

25     to the village.  From time to time I did go home.  But I didn't go to my

Page 19047

 1     own home actually.  I went to the house of a relative of mine that was

 2     nearby, that was near the woods and the corn field.

 3        Q.   And who was there at the house of that relative?

 4        A.   That relative had sons but he himself, at the time, was 65, or

 5     rather, 70 years old.  He had two daughters and his wife.

 6        Q.   Thank you.  Why were you hiding?

 7        A.   Well, you know, in our village, all men from age 18 to 65 were

 8     taken in, and I saw that some of them had been killed too.  I didn't know

 9     about the rest.  And then that evening, after the 10th, when I returned

10     home, they told me, since actually on the same day, on two or three

11     times, the army passed through the village and searched the houses to see

12     whether anyone was left, and they were looking for weapons and whatever

13     else, of course I didn't dare stay at home.  I had to stay outside my

14     house, otherwise they would have taken me away probably, had they found

15     me.

16        Q.   Ah-hah.  And then you got in touch with your neighbour, not to

17     mention his name, and he helped you?

18        A.   No.  It was my sister that established contact with him.

19        Q.   Thank you.  And then you came to Kljuc and how much time did you

20     spend in Kljuc?

21        A.   Seven or eight days.

22        Q.   Thank you.  Was it hard to get on to that list for transport to

23     Travnik?

24        A.   To tell you the truth, I don't really know about that.  But I

25     know that certain documentation had to be taken care of first.  For

Page 19048

 1     instance, one had to have a proper ID, then also proper land documents,

 2     tax documents, and, of course, at the police station, you get some kind

 3     of document allowing you to leave, and then with that you buy a ticket.

 4        Q.   Ah-hah.  And then you pay the ticket - don't you? - the entire

 5     convoy does.

 6        A.   Well, yes, yes, a certain person had to pay a certain amount of

 7     money.

 8        Q.   Thank you.  Was it a long list or did a person have to wait for a

 9     long time?

10        A.   Well, sometimes you'd have to wait for seven, eight or 10 days.

11     Since it wasn't just one convoy, there were several convoys going from

12     Kljuc, to tell you the truth, I didn't really go for that ticket so

13     I don't really know that well how that went but I know that my folks had

14     to wait three or four days until they managed to get tickets.

15        Q.   Thank you.  Was it that way for all or was it only for your

16     family?

17        A.   For all, for all citizens of Kljuc.

18        Q.   Under whose control was Kljuc then?

19        A.   At the time, it was basically the police of the

20     then-Republika Srpska.  I mean at that time.  So it was only natural that

21     all power was in the hands of ethnic Serbs.

22        Q.   Thank you.  I'm a bit confused now.  How come that Serbs, Serb

23     authorities, just let you be, whereas you were the survivor of such a

24     drastic incident and this neighbour of yours disregards that, and the

25     authorities disregard that, they just don't care and they let you go.  Do

Page 19049

 1     you have any explanation how come that happened?

 2        A.   I've already said, I didn't go to buy the tickets.  Because some

 3     friends of mine bought two tickets.  Due to health problems, they could

 4     not leave so my sister took these two tickets from them.  When they were

 5     sending convoys, trucks, buses, I personally got on to a trailer truck

 6     and they didn't ask me who I was and what I was doing.  It was just

 7     important to have that coupon, that ticket, and to board the truck.

 8        Q.   Thank you.  But this neighbour did know that you had survived

 9     that and he let you go, right?

10        A.   Had he known, he probably wouldn't have taken me away at all.

11        Q.   So he did not know that you were on that bus?

12        A.   No, he didn't know at all.

13        Q.   Thank you.  What about the authorities in Kljuc?  Did they know

14     that you were a survivor of that?

15        A.   No.

16        Q.   Thank you.  And then you reported to the

17     Army of Bosnia-Herzegovina.  (redacted)

18     (redacted)

19        A.   Yes.

20        Q.   After a while, after a bit of rest, as you describe in your

21     statements, you joined one particular unit.  What was that unit?  You

22     don't have to say it, never mind, never mind.

23             JUDGE KWON:  Just a second.  We will redact line 18.

24             MR. KARADZIC: [Interpretation] I do apologise.

25        Q.   Did you get a certificate as to your participation in the war?

Page 19050

 1        A.   Yes.

 2        Q.   Thank you.  So from which date does your participation in the war

 3     run?

 4        A.   I don't wish to answer.

 5        Q.   Can we move into closed session?

 6             JUDGE KWON:  Yes.

 7             [Private session] [Confidentiality partially lifted by order of Chamber] 

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Page 19051











11  Pages 19051-19054 redacted. Private session.















Page 19055

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23        Q.   Let's see how these people are listed on lists of sehids,

24     combatants, can you tell us what the word "sehid" means, exactly?

25        A.   Well, to be honest with you, and I think I mentioned this

Page 19056

 1     recently, in order for their families to actually get some compensation,

 2     to get some kind of compensation, and have some means of subsistence,

 3     they would then name their relatives who had been killed as sehids in

 4     order for them to qualify for certain -- to qualify for certain

 5     compensation.

 6        Q.   Well, that would be fraud, isn't it?

 7        A.   Well, if you say so.

 8        Q.   Could we now please see D115, page 3 -- yes, that's what he said

 9     in translation.  In relation to the fraud that I asked about, the witness

10     said yes, something to that effect.  Is that what you said?

11        A.   Well, yes.  What I -- as I said already, in order for them to

12     qualify for certain compensation because these families had to live off

13     of something, there were all these children whose fathers had been

14     killed, they had to go to school and so on, so they did have to qualify

15     for certain rights so that they would get compensation to have some means

16     of subsistence.

17        Q.   Well, I believe we did have the correct text before, 1D1115, page

18     33, but my question was:  Is this how they defrauded the state?

19        A.   Well, probably that was the case.

20        Q.   D1115, D.  That is an exhibit already, D1115.  About this fraud,

21     how many men were listed as sehids, whereas they weren't sehids, and what

22     was the scope of this fraud that was perpetrated there?

23        A.   Well, most of them.

24        Q.   So you waited for these seven months to tell this story.  Why

25     didn't you talk about this as soon as you arrived there?

Page 19057

 1        A.   Well, when I came back, when I arrived, when I actually reached

 2     the free territory, I did not even leave my -- the premises where I was

 3     staying for two months.

 4        Q.   Could we now please see page 333?  Let me just see if this is the

 5     correct document?  In e-court, that's page 333.

 6             Can you see Domazet, Fuad Domazet's name on this list?  And you

 7     can also see the name of Smajo Cajic.

 8        A.   Yes.

 9        Q.   There are a lot of people from Kljuc.  Were all these people

10     civilians who are now listed as sehids?

11        A.   Well, only the people from Biljani.

12        Q.   Would you please take a look at this page?  Do you see how many

13     people there are listed as being from Kljuc?

14        A.   Well, they all just put down Kljuc but most of these people were

15     from Biljani.  Dedic, the Dedic people, are from another town.  But as

16     I've already said, in order to qualify for certain compensation, this is

17     what they did.

18        Q.   Well, can you see the name of Cajic?

19        A.   I did.  I did.  I see Avdo and Smajo Cajic.

20        Q.   Can you also see the Cehics and then the Domazets, all these

21     people were from Kljuc and not a single one of them was a fighter, is

22     that what you're saying?

23        A.   Well, as I've already said, in Biljani, out of those 200 or so

24     people in Biljani, not a single bullet was shot.  All the weapons had

25     been surrendered, they were all taken to this school, they all went to

Page 19058

 1     the school, reported there to the elementary school in Biljani.

 2        Q.   Thank you.  But you did not really answer my question, my

 3     original question.  What is the meaning of the word "sehids"?

 4        A.   Well, sehid is a person who gets killed on God's path, I'll be

 5     quite frank.

 6        Q.   That's an Islamic holy warrior, correct?

 7        A.   Well, I wouldn't put it that way.  When you're defending your

 8     hearth, you would also be a sehid or when you get killed on God's path

 9     that would also be a sehid.

10        Q.   Now let's go back to the incident itself.  You got on the bus.

11     How many people were on the bus?

12        A.   About 70 men approximately.

13             JUDGE KWON:  Just a second.  Did we need to stay in private

14     session for the whole of that?

15             MR. KARADZIC: [In English] No, no.  I don't think --

16             JUDGE KWON:  Are you're suggesting going back to open session

17     now?

18             MR. KARADZIC:  Yes.

19             JUDGE KWON:  Yes.

20                           [Open session]

21             JUDGE KWON:  Yes, please continue, Mr. Karadzic.

22             MR. KARADZIC: [Interpretation] Thank you.

23        Q.   So that number of people got on the bus and there was not a

24     single soldier or officer on that bus?

25        A.   Well, there were only the driver, who was in the front, and two

Page 19059

 1     or three soldiers.

 2        Q.   But in your statements, you said that there wasn't a single

 3     soldier.

 4        A.   Well, you're probably right.  It was the military police who were

 5     on the bus then, if we want to be very precise.  But I said that when the

 6     bus set off, two more policemen got on the bus, they were looking for

 7     some four men or so, and then we started off and then they got on the bus

 8     again, they asked us all to get on another bus, and that's how it went.

 9        Q.   But when you set off, there was not a single soldier or officer,

10     correct?

11        A.   Well, I may have -- I don't know.  Maybe I didn't mention that

12     because no one had asked about it but I didn't really see much.  I was

13     seated in the back of the bus, next to the back door, rear door, and

14     that's where I spent most of the time, on the floor.

15        Q.   And how long then did the bus go before you were stopped?

16        A.   Well, we just covered some 100 metres or so and then it stopped.

17        Q.   Outside whose house did you stop?

18        A.   Well, some 20 to 30 metres beyond Alic, Mehmed, across from

19     Habir's house.

20        Q.   And then they asked for two or four men to get off the bus,

21     strong men.

22        A.   Well, I said that the first time the bus stopped was some ten

23     metres later, and they asked for four strong men to get off the bus, and

24     then I raised my head and I recognised (redacted)

25     I recalled also this other person, Mujo from Krnojevic [phoen] and there

Page 19060

 1     were two other men, I saw them and they got off the bus, out the front

 2     door.  I thought they needed them to do some work, to perform some labour

 3     or something.

 4        Q.   I see.  And then you road for another 100 metres or so?

 5        A.   Well, yes.  After a few moments, the bus set off again and the

 6     driver already then said that they couldn't really reach Kljuc because

 7     the bus was overcrowded.  So then he drove on for some 100 metres more

 8     and then we stopped again.

 9        Q.   And then they said that some of you should move to another bus,

10     correct?

11        A.   Yes.  And then someone said, "Will you open the back door and

12     left the first five, the five people who are closest to the door get

13     off?"  And when they did, I was among those five who got off the bus.

14     There were also Fikret Balagic, Avdic, Alija, Besim Avdic and Rufad.

15     They I don't know his last name.  They took us past the bus and some ten

16     metres behind there was another bus but they didn't take us to that bus.

17     First, they let us get on the bus through the back door.  However, when

18     we did that, they -- when we headed for the back door they actually took

19     us behind the house of Mehmed and they just took us behind the house.

20        Q.   Thank you.  Can we see now page 329, please?  That's D1115, the

21     document we had a few moments ago on the screen.  Would you please take a

22     look at the lower third of the page, the bottom third of the list, the

23     names that you mentioned, the Balagics for instance?

24        A.   Fikret Balagic.

25        Q.   Is that the man you mentioned?

Page 19061

 1        A.   Just a moment, please.

 2        Q.   His name appears under the name Sulejman Bajric?

 3        A.   Well, let me just take a look, Elmir, no, that's not him, no.

 4     Fikret was an older man.  He used to work in the municipality as the

 5     deputy chairman or something, I'm not sure.

 6        Q.   What was his father's name?

 7        A.   I believe it was Arif.

 8        Q.   Now, can you see under number 32780 --

 9        A.   Yes, yes, I can see it now.  Yes, that could be the man because

10     he was born in 1940.

11        Q.   Thank you.  Now, could you find the other names?  All those names

12     that you mentioned, they are all on listed here as sehids.  Can you

13     please find them?

14        A.   Well, it's true they are listed as sehids.

15        Q.   Thank you.  Now, could you please explain this?  After some

16     hundred metres or so, you were stopped and then you were taken towards a

17     house.

18        A.   We were taken outside the house, in front of that house, and then

19     at one point they stopped, they said, we have to stop, they needed to get

20     something or something, but because the barrel was already in my mouth,

21     they pushed me with the gun forward, and I saw at that time a relative of

22     mine who was already on the ground, and we just stepped over them.

23     I think Rufad then tried to flee.  He ran towards the right.  These men

24     followed him.  I ran to the left, Besim after me and I just heard them

25     calling after us, "stop, fuck your balija mothers" and then they started

Page 19062

 1     shooting.  This would have been some ten metres away or so where they

 2     were shooting from.  First I only saw Besim, as I stepped in front of him

 3     I saw Besim falling down and then I also dropped to the ground, I don't

 4     know why.  Anyway, when he dropped to the ground, I did too.

 5        Q.   Well, what I am not clear on is this:  What about those people

 6     who had been taken off a hundred metres earlier and allegedly had been

 7     shot?  How was it that now you could see them in front of you, a hundred

 8     metres away, further off?

 9        A.   Well, I was just telling you now.  They asked for those four men

10     to be taken off the bus.  And I was taken off the bus with four other

11     men, some 100 metres later.  They had probably been taken outside the

12     same house or behind the same house.

13        Q.   But how was it that they could be in front of you when you rode

14     on the bus?

15        A.   Well, as I've already said, when we stopped, when these four men

16     were taken off the bus, the four strong men, the driver lingered there

17     for a while and then he said that we couldn't reach Kljuc we were so

18     overcrowded and then he started moving and some ten metres later he

19     stopped again and sort of wondered how we could go on and then -- so this

20     could have been some five minutes or so and then he moved 100 metres

21     further.

22        Q.   I understand but they were taken a hundred metres away, whereas

23     you stopped, your bus stopped so how come the bus -- you were not faster

24     than them?  How did they happen to be in your way?

25        A.   I told you they were taken away five minutes earlier.  I walked

Page 19063

 1     some ten metres only.  If you give me a map I can show you.  I did not

 2     have time to count metres or minutes.  Those minutes lasted forever, to

 3     all of us who were waiting in all that uncertainty, not knowing what's

 4     going to happen.

 5        Q.   And when you fell to the ground, was it next to Besim?

 6        A.   Yes, next to Besim.

 7        Q.   In your first statement you said you fell over his body.

 8        A.   Well, that's possible but I was so close to Besim, I could have

 9     touched him if I stretched my arm.  I don't really remember every detail

10     of it any more.

11        Q.   So those 65 continued peacefully on their way to Kljuc, right?

12        A.   Some five, six minutes later, as I think I said in my statement,

13     that's how long it lasted and then two or three minutes later, they said,

14     "Come back quickly.  We are going on to Kljuc."  And according to some

15     statements of eyewitnesses on the road to Velagici, there were two buses,

16     and it's true there were two buses, but I know that in the second bus, as

17     we were passing by, there were no civilians.  I just saw a couple of

18     soldiers.  I think I said that in my statement.

19        Q.   Witness, those people who were put on the same bus with you

20     continued some five minutes later.  Will you give us some names of these

21     people who can confirm your story?

22        A.   How can I give you their names?  They were all killed.

23        Q.   You said that the others stayed 90 minutes and then today you say

24     later it was a couple of minutes.  Today you are saying five minutes.

25        A.   That's not what I said.  I said the whole killing, the whole

Page 19064

 1     process, lasted seven to nine hours.  I cannot tell you exactly how long

 2     it was.  I didn't have a watch and I didn't mind the time, and that time

 3     from the point when we left the school until the end, it was some hours.

 4        Q.   But in this incident, you were stopped 100 metres after you

 5     started, just give me a few names of people or the name of the unit.  Who

 6     stopped you?

 7        A.   I've told you before, the driver said he couldn't get to Kljuc

 8     because we were too many on the bus, and we were stopped.  Now, who

 9     stopped us, who ordered this transfer, I don't know.  You are better

10     placed to know than I.  Maybe you have some lists.  I didn't see

11     anything.

12        Q.   So after the killing of those four men, did anyone remain alive

13     out of the other five people who got off the bus?

14        A.   No.

15        Q.   But you survived and all of it took no more than five minutes but

16     in your later statements you said they stayed there for another hour,

17     hour and a half, they were drunken, they were singing and you could infer

18     to those men had been killed and then those soldiers left.  Do you know

19     where?

20             JUDGE KWON:  Yes, Ms. Sutherland?

21             MS. SUTHERLAND:  Your Honour, Mr. Karadzic is confusing two

22     incidents.  I think the witness is trying to explain that but the hour

23     and a half is after when the witness had been lying still on the ground.

24     I think the witness is trying to answer that now.

25             JUDGE KWON:  Thank you.  Yes, please proceed to answer the

Page 19065

 1     question, yes.

 2             THE WITNESS: [Interpretation] Yes.  That's correct.  And that's

 3     what I said.  It was no more than five minutes between the time when we

 4     were taken off the bus to the point when the bus continued to Kljuc.

 5     I remained on the same spot for an hour, perhaps more, perhaps an hour

 6     and a half.  In that time, within five minutes, soldiers came.  Of

 7     course, I didn't see them but I could hear them well.  They first came to

 8     that house and one of them even went around the house calling, "Come on,

 9     there are some more dead men here."  And somebody said, "I've had enough.

10     I'm fed up."  And those soldiers stayed around for another hour after the

11     bus left.  Some were saying, "Let's burn this down."  Others said, "Let's

12     not do that.  Maybe somebody can use it."  And then they brought drinks

13     and they were talking and drinking before they left.  In both directions.

14     And I remained for another ten, 15 minutes after things got quiet.  Or

15     perhaps it was an hour.  I don't know.  I didn't have a watch.  I didn't

16     know how long it was.  But after things got quiet, when I thought that

17     the soldiers had gone, I ran away to the woods nearby.

18             MR. KARADZIC: [Interpretation]

19        Q.   But you said in one statement, witness, that you were lying for

20     ten, 15 minutes before you got up.

21        A.   You know how it is.  I say something and then the interpreter

22     doesn't interpret it correctly.  It couldn't have been that long.  I lay

23     on the ground five minutes before the soldiers left.  But after they

24     left, I stayed for another half an hour, not less, before I got up and

25     ran.

Page 19066

 1             JUDGE KWON:  Mr. Karadzic, do you have more to continue?

 2             MR. KARADZIC: [Interpretation] Yes, your Excellency.  There is a

 3     lot of ground to cover.  Many inconsistencies, many discrepancies and to

 4     establish the truth we need to know what happened and whether it happened

 5     exactly as he describes it.

 6             JUDGE KWON:  Just a second.  Your time was up about ten minutes

 7     ago.  But just -- we will consult.

 8                           [Trial Chamber confers]

 9             JUDGE KWON:  Please conclude in five minutes.

10             MR. KARADZIC: [Interpretation] Thank you.

11        Q.   You said that towards the end of June, when soldiers came from

12     Palanka and rounded up people according to a list, one of the soldiers

13     wanted to kill them and the commander said, the houses had been searched,

14     they were innocent and had to be released, correct?

15        A.   No.  I said the soldier was reluctant to kill them and then the

16     commander asked, "What are we going to do with these three, four men?

17     Take them behind the house."  The soldier said, "I can't do it."  And the

18     commander said, "Then take them home."  And they took the bus to the next

19     hamlet.  That's what I said and that's what my statement says.

20        Q.   We'll find it now to see exactly what you said.

21        A.   Go ahead.

22        Q.   While we are looking for it, do you deny, witness, that there

23     were three companies in Biljani?

24        A.   Excuse me, what kind of companies?

25        Q.   Three companies of the Muslim army, commanded by Amir Avdic and

Page 19067

 1     Ale Mujezinovic?

 2        A.   I honestly know nothing about it and I'm telling you that in

 3     Biljani in the course of 1992, not a single bullet was fired.  And

 4     whatever hunting weapons there had been were surrendered, you can find it

 5     in statements, you can find it in reports, and you can find it in police

 6     reports, that there was not a single bullet fired in Biljani in 1992

 7     while the Muslims were there.

 8        Q.   Is it the case that Smail Domazet was the commander of a platoon?

 9        A.   I don't know.

10        Q.   What about Zijad Abdic in Brkici?

11        A.   I don't know.  I wasn't there.  I don't know about these things.

12        Q.   What about your relative -- sorry.  Maybe it can be redacted but

13     I didn't say the last name.

14             When the search was conducted in Brkici, you said no weapons were

15     found and then one soldier wanted to take revenge and the officer stopped

16     him; is that correct?

17        A.   Yes.  I said that, in Biljani, outside our houses, my brother

18     told me about this when he returned.  One soldier was sharpening a knife

19     and was saying, "I'm going to slit the throat of the dark-haired one."

20     But they didn't do anything.  They went to the next hamlet and from

21     Atkovci [phoen] they were returned to Domazet and in Domazeti with the

22     consent of one Serb, who testified that those men were good people and

23     good neighbours, those men were returned to their homes.  Mladjo and Boro

24     took them away that morning, spent the entire day with them, and the same

25     evening returned them home.

Page 19068

 1        Q.   They returned them -- they took them back in their own cars?

 2        A.   They did not dare to go back alone because of the army so they

 3     were looking for somebody to escort them to Brkici and Domazeti, so Boro

 4     and Mladjo walked with them to Brkici village.

 5        Q.   In your statement of 3 June 2000, paragraph 2, you stated around

 6     50 men were brought to the schoolhouse in Kljuc to be interrogated.

 7     After that, ten were released while the remaining 40 were sent to

 8     Manjaca.  Is this true?

 9        A.   It's true because out of those ten, I know two or three who

10     returned in June 1992, they came to Biljani, and they told us that the

11     others had remained in Kljuc, in the schoolhouse.

12        Q.   You say here you did not believe that the Green Berets were

13     attacking although the policemen told you they were, and you were in fact

14     put in the schoolhouse for your own safety?

15        A.   He said, "How can there be talk about any Green Berets?"  He was

16     just standing there in the doorway.  He said, "We will deal with them

17     quickly."

18        Q.   But you didn't believe him.  You thought there were no Green

19     Berets?

20        A.   Of course there were no Green Berets.  Not a single bullet was

21     fired in Biljani.  And in around the place, there was not a single

22     incident.  How could the Green Berets suddenly appear out of nowhere at

23     that time?

24        Q.   You say several times that some people went somewhere and then

25     volleys of automatic fire were heard.

Page 19069

 1        A.   As they were taking people out of the school, as they took

 2     someone out of the school, two or three minutes later you would hear

 3     automatic fire.  For instance, Omer Dervisevic was taken out first, and

 4     then Ale Cajic and as they were getting out, you could hear automatic

 5     fire within two or three minutes or within ten minutes.  I didn't --

 6     I wasn't watching the time.  Every time someone was taken out, you could

 7     hear very soon the sound of automatic fire.

 8        Q.   But you didn't see what happened to those people?

 9        A.   No.  Looking out of the classroom you could only see the soldiers

10     under the trees and you could see those standing on the road.

11        Q.   Is it true that you stated, on 3 June, page 345, that you heard

12     somebody saying, "It should never have happened.  They should have been

13     taken to Kljuc, the killing should not have happened.  We were supposed

14     to be taken to Kljuc"?

15        A.   I can't remember all of my statements.  I gave a number of

16     statements, in some I stated one thing that I omitted in another.  I

17     don't know about this one.

18        Q.   Did you hear the man saying that?

19        A.   No.  I understood it differently.  As I was sitting on the bus,

20     in the back of the bus, and when the bus was already filled up, somebody

21     said, "What are we going to do with the rest who are still inside the

22     school?"  Somebody else answered, "Just kill them all.  We don't need

23     them."

24        Q.   We are talking about the incident where you were the victim.

25     After that, soldiers came, you say, they started talking, somebody said,

Page 19070

 1     "This shouldn't have happened."

 2        A.   Oh, yes.  That was after the execution.  As I was lying on the

 3     ground behind the house, with the others, there was -- they were saying

 4     all sorts of things and I told you it was at least half an hour that they

 5     were talking.  One of them even stopped his friend from burning down the

 6     house while the others were shouting, "Torch it all."  Somebody said,

 7     "No, we shouldn't."  They were all expressing their different opinions.

 8     That's normal.

 9        Q.   Thank you.

10             MR. KARADZIC: [Interpretation] I don't think you will give me

11     more time so I'm not going to --

12        Q.   Thank you, witness, were you on the list that this man Omer had?

13        A.   No.  I wasn't even aware of a list.

14             MR. KARADZIC: [Interpretation] Thank you.

15             JUDGE KWON:  Do you have re-examination, Ms. Sutherland?

16             MS. SUTHERLAND:  No, Your Honour.

17             JUDGE KWON:  One clarifying question for Mr. Karadzic, we saw the

18     list of -- I think it's the Prosecution exhibit, the list of 125 dead

19     persons which we admitted as P3362.  Do we see that word "sehid" on that

20     list at all?

21             MS. SUTHERLAND:  No, Your Honour, that was Mr. Karadzic 's

22     exhibit D --

23             JUDGE KWON:  I'm sorry, D1115.  Do we see the word on that

24     document, Mr. Karadzic?  Can you upload D1115?

25             MR. KARADZIC: [Interpretation] We are going to take a look now.

Page 19071

 1     The first page, the Army of BH, that's what it says there.  The

 2     terminology is "sehid," unless it's a Christian, a Serb or a Croat.  The

 3     BH Army.

 4             JUDGE KWON:  Where is it?  You mean the title, Vojska BiH, you

 5     translate it as sehid?  Where do we find the word "sehid"?

 6             MR. KARADZIC: [Interpretation] "Sehid" is the way it is usually

 7     put when speaking.  "Sehid" is the word used for Muslims but not for

 8     Christians.  Whoever gets killed in the army is called a sehid.

 9             JUDGE KWON:  But you do concede that the word "sehid" does not

10     appear on this document?

11             MR. KARADZIC: [Interpretation] Probably not on this list.  It

12     says up here, Vojska BH, that is to say the Army of BH, the BH Army, and

13     that has not been translated into English.  Also, your Excellencies, this

14     last rubric here, when it says, "Killed" that is killed in combat.  And

15     then if there is the word "preminvo," that means died a natural death.

16     Whereas when it says "ubijen," that is killed as a result of a crime, a

17     criminal act.  So "poginvo" is killed in combat and "preminvo" is died a

18     natural death.

19             JUDGE KWON:  I think we are done with this document.  Thank you

20     for the clarification.  Yes, Mr. Witness, that concludes your evidence.

21     On behalf of this Chamber, as well as the Tribunal as a whole, I would

22     like to thank you for your coming to The Hague yet again to give it.

23             Now, you are free to go.  Please have a safe journey back home.

24             THE WITNESS: [Interpretation] Thank you very much.

25             JUDGE KWON:  Could you wait until we draw the curtain.

Page 19072

 1                           [The witness withdrew]

 2             JUDGE KWON:  Shall we go into private session briefly?

 3                           [Private session]

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

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   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19073

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15                           [Open session]

16             JUDGE KWON:  Do we need a short break in order to bring in the

17     next witness?  I doubt it.

18             MS. SUTHERLAND:  No, Your Honour, the Prosecution calls KDZ-052.

19             JUDGE KWON:  Thank you.  Let the witness be brought in.

20                           [The witness entered court]

21             JUDGE KWON:  Good morning, sir.

22             THE WITNESS: [Interpretation] Good morning.

23             JUDGE KWON:  Could you kindly take the solemn declaration.

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

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

Page 19074

 1                           WITNESS:  KDZ-052

 2                           [Witness answered through interpreter]

 3             JUDGE KWON:  Please be seated and make yourself comfortable.

 4             THE WITNESS: [Interpretation] Thank you.

 5             JUDGE KWON:  Sir, I take it you have been told about this but you

 6     will be testifying today with the benefit of pseudonym, which is KDZ-052,

 7     and image distortion.  This means that there will be no reference to your

 8     real name or information which might reveal your identity to the public

 9     or media.  The audiovisual record of your testimony, which is broadcast

10     to the public, will have a distorted image, like this.  Do you understand

11     that?

12             THE WITNESS: [Interpretation] Yes.

13             JUDGE KWON:  That's to ensure that your identity is protected and

14     the transcript, while available to the public, will always refer to your

15     pseudonym.

16             So are you happy with this regime?

17             THE WITNESS: [Interpretation] Yes.

18             JUDGE KWON:  Thank you.  Yes, Ms. Sutherland?

19             MS. SUTHERLAND:  Thank you, Your Honour.

20                           Examination by Ms. Sutherland:

21             MS. SUTHERLAND:  Could I have 65 ter 90277, please?

22        Q.   Sir, you'll see a pseudonym sheet in front of you.  Can this not

23     be broadcast, please?  It has your name and your date of birth.  Can you,

24     without saying either of your name or your date of birth, indicate

25     whether that -- those details are correct?

Page 19075

 1        A.   Yes.

 2             MS. SUTHERLAND:  I tender that, Your Honour.

 3             JUDGE KWON:  That's admitted.

 4             THE REGISTRAR:  As Exhibit P3368 under seal.

 5             MS. SUTHERLAND:  Sir, as we also discussed, part of your evidence

 6     in this case will be submitted in writing and we need to deal with a few

 7     formalities associated with that submission.  You testified as a

 8     protected witness in the Brdjanin case; is that correct?

 9        A.   Yes, that's correct.

10             JUDGE KWON:  The pseudonym sheet is Exhibit P3363?

11             THE REGISTRAR:  P3368, under seal.

12             JUDGE KWON:  Thank you.

13             MS. SUTHERLAND:

14        Q.   You subsequently had an opportunity to review the audio

15     recordings of that testimony?

16        A.   That's right.

17        Q.   You wish to correct two answers that you gave.  The first one is

18     on page -- transcript page 8061 at line 21.  The answer Mico Djukic and

19     his brother Milutin.  Should properly read Rade Djukic and his brother

20     Milutin, also known as Mico, unquote?

21        A.   That's right.

22        Q.   And at transcript page 8070, at line 1, the answer, "At the

23     beginning, Serb soldiers.  About 15 days later, the police came" should

24     read, "At the beginning, Serb soldiers.  About seven days later, the

25     police came"?  Is that correct?

Page 19076

 1        A.   That's right.

 2        Q.   Can you confirm that with these corrections the audio recording

 3     accurately reflects the evidence you gave at that time?

 4        A.   Yes, that's right.

 5        Q.   If you were asked the same questions today, or if you were asked

 6     today about the same matters that you testified to in the Brdjanin case,

 7     would you provide the same information to the Trial Chamber, that is even

 8     if you wouldn't be able to formulate everything in the same words the

 9     essence of your answers would be the same?

10        A.   Yes, that's right.

11             MS. SUTHERLAND:  Your Honour, I tender 65 ter 00 -- 22087 under

12     seal and 22087A which is a public redacted version of the witness's

13     testimony.

14             JUDGE KWON:  Both admitted.

15             THE REGISTRAR:  Your Honours, 65 ter 22087 will be Exhibit P3369

16     under seal and 65 ter 22087A will be Exhibit P3370.

17             JUDGE KWON:  Thank you.

18             MS. SUTHERLAND:  With Your Honour's leave, I'll read a summary of

19     the witness's written evidence.  Witness KDZ-052 was born and raised in

20     the Sanski Most municipality.  He testified about the check-point set up

21     in 1992 in the area where he resided and the fact that only non-Serbs

22     would be stopped and searched.

23             He also testified that he heard on the radio at the end of May

24     1992 an announcement to the Muslims to surrender their weapons.  The

25     witness testified that the shelling and attack on Hrustovo and Vrhpolje

Page 19077

 1     was conducted by the 6th Krajina Brigade and it began at the end of May

 2     1992.  He gives evidence of the killings and the looting and burning of

 3     houses.  The witness testified that troops surrounded the village of

 4     Kenjari on 27 June 1992.  The villagers were rounded up and the men were

 5     separated from the women.

 6             A number of men were escorted to a house owned by a Croat,

 7     Marko Juric where they were visited by Vlado Vrkes.  The following day

 8     the men were taken to Dujo Banovic's former house in the hamlet of

 9     Blazevici.  The witness and a few of the younger men entered the house,

10     the older men stayed in front of the house.  The witness testified that a

11     bomb was then thrown at the house.

12             At this point, the witness and another man jumped out an open

13     window at the back of a house -- at the back of the house.  The other man

14     ran away.  The witness hid in a deep hole several metres from the house.

15     The witness heard the men being thrown out of the house and a blast of

16     fire directed toward the men which lasted about two minutes.

17             The witness continued to hide in the hole.  The killed men were

18     brought into the house and the house was then set on fire.  18 persons

19     died that day.

20             The witness stayed in the deep hole until dawn the following day

21     when he returned to his village.  He observed all the houses had been

22     burnt.  The witness testified that he then went to Tomina where he joined

23     other Muslims that had been displaced from Hrustovo and Vrhpolje.  The

24     Serbs drove this group of refugees to Krings facility in Sanski Most

25     which is Schedule C, 22.4.

Page 19078

 1             The witness was detained in Krings for a month.  Krings was first

 2     guarded by the military and after about seven days by the police.  There

 3     were around 600 people detained there.  The witness described the

 4     inhumane conditions at the camp including inadequate space and sanitary

 5     facilities, insufficient food, and no medical facilities.  He gave

 6     evidence about beatings which began after the police came to guard the

 7     facility.  Detainees were beaten with boots, batons and rifle butts.  He

 8     testified that one detainee, Ejup Masic died as a result of the beating

 9     he received.  The witness was released from Krings Hall in early August

10     1992 and left Sanski Most shortly thereafter on a convoy that went to

11     Travnik.

12             That completes the summary of the witness's written evidence.

13        Q.   Sir, I have very limited -- a very limited number of questions

14     which I wish to ask you.  First of all, I want to show you three

15     photographs and the first one is 65 ter 05205.

16             Sir, do you recognise what's depicted in this photograph?

17        A.   Yes.  That is the Krings hall.

18        Q.   Which of the buildings, the big red building, what building was

19     that?

20        A.   Yes, we were detained in that big red building.  There was

21     nothing there except for a few old pieces of equipment and perhaps the

22     remains of an old machine but that wasn't really much.

23        Q.   And the white building on the right-hand side of the photograph,

24     do you know what that building is?

25        A.   We were brought into that building only once.  I think there were

Page 19079

 1     offices there.  Maybe the management offices of that company or something

 2     like that.

 3        Q.   Why were you taken to that building?

 4        A.   We were taken there to be interrogated by the police.

 5             MS. SUTHERLAND:  I tender that document, that photograph.

 6             JUDGE KWON:  Yes.

 7             THE REGISTRAR:  As Exhibit P3371, Your Honours.

 8             MS. SUTHERLAND:  Could I have 65 ter 05204, please.

 9        Q.   Do you recognise what's depicted in that photograph?

10        A.   The Interior of the Krings hall.

11             MS. SUTHERLAND:  I tender that photograph.

12             JUDGE KWON:  Yes.

13             THE REGISTRAR:  Exhibit P3372, Your Honours.

14             MS. SUTHERLAND:  May we go into private session?

15             JUDGE KWON:  Yes.

16                           [Private session]

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19080











11  Pages 19080-19081 redacted. Private session.















Page 19082

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10                           [Open session]

11             THE REGISTRAR:  We are now in open session.

12             MS. SUTHERLAND:  I wasn't -- sorry, there is now a photo on the

13     screen, which is 05207.  I wasn't going to bother with this one.

14        Q.   Sir, that was the building that you recognised in the earlier

15     photograph of the Krings facility as the room or the building that you

16     were taken to for interrogation; is that correct?

17        A.   That's correct.

18             MS. SUTHERLAND:  I tender that document, Your Honour, 05207.

19             JUDGE KWON:  Yes.  Exhibit 3375.

20             MS. SUTHERLAND:  If I could have 65 ter number 05209 on the

21     screen, please.  If we could go to page 7 of the English and page 7 of

22     the B/C/S?

23        Q.   Sir, do you recognise these names that are listed here, 1 to 18?

24        A.   Yes.

25        Q.   Are these the names of -- well, you tell the Court who these

Page 19083

 1     people are?

 2        A.   These people are the people who were killed and that I was there

 3     with, the village of Kenjar.  They were killed.  We were taken away and

 4     they were killed.

 5        Q.   In the village of Blazevici?

 6        A.   Yes, yes.

 7        Q.   What was the age of the youngest person there on that day?

 8        A.   I think he was 14 or 15, Husein Kenjar, the son of Hasan.

 9             MS. SUTHERLAND:  Thank you.  Your Honour, that's part of a larger

10     report by the federal Ministry of the Interior affairs in Sarajevo

11     regarding the exhumations in Hrustovo and Vrhpolje villages conducted in

12     1996.  So I don't know -- I seek to only tender with this witness the

13     page that I referred to which is page 7 in the English and B/C/S and we

14     will seek to tender the entire document via the bar table.

15             JUDGE KWON:  Thank you.  That will be admitted as Exhibit P3376.

16             MS. SUTHERLAND:

17        Q.   Finally, I just have one question for you, sir.  How many of your

18     relatives or friends from Sanski Most municipality were killed in 1992?

19     Or have been missing since 1992?

20   (redacted)

21        Q.   Sorry, sorry.

22             MS. SUTHERLAND:  If we could go into private session, please.

23             JUDGE KWON:  Yes.

24                           [Private session]

25   (redacted)

Page 19084

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17                           [Open session]

18             MS. SUTHERLAND:

19        Q.   Sir, are you able to tell the Trial Chamber the number of people,

20     either relatives of yours or friends, who were killed or have been

21     missing since 1992?

22        A.   I've lost three or four close relatives.  As for friends and

23     neighbours, there were too many of them.

24             MS. SUTHERLAND:  Thank you.  I have no further questions.

25             JUDGE KWON:  We will deal with the associated exhibits.  I think

Page 19085

 1     we dealt with one already.  We have three others.  Did we deal with your

 2     leave to add an associated exhibit to the 65 ter list which was

 3     65 ter 23455.

 4             MS. SUTHERLAND:  No, Your Honour, and I seek leave to add that.

 5     That's mentioned in the witness's transcript.

 6             MR. ROBINSON:  Yes, Mr. President, we don't mind if they add it

 7     but we object to the admission of the exhibit because we don't think that

 8     it forms an indispensable part of the transcript because it's basically a

 9     report of an investigation and the witness, while having seen the report,

10     just commented about names involved as opposed to any of the substance.

11     We don't think that it should be sufficient to enable this to be

12     admitted.

13             JUDGE KWON:  You don't have any objection to the remaining two,

14     19921 and 19922?

15             MR. ROBINSON:  No.

16             JUDGE KWON:  The two will be admitted.  And the simple way is for

17     Ms. Sutherland to deal with this document with the witness right now.

18             MS. SUTHERLAND:  Yes, Your Honour.  Could I have 65 ter 23 ...

19             JUDGE KWON:  23455?

20             MS. SUTHERLAND:  Yes, thank you, Your Honour.

21             MR. KARADZIC: [Interpretation] If I may say something before the

22     break?  There are over 70 pages of transcript, and in my experience so

23     far, that would be testimony of a whole day.  So I would appreciate it if

24     you would reconsider one more time the time that you're willing to allot

25     me.

Page 19086

 1             JUDGE KWON:  You're asking for eight hours?

 2             MR. KARADZIC: [Interpretation] Well, I don't know what I was

 3     asking, but I'm asking for at least three or four hours because it is

 4     impossible to deal with this because this is the testimony of a whole

 5     day, and I am supposed to actually question the witness on this in a

 6     single hour or so.

 7             MS. SUTHERLAND:  Your Honour, I'm sorry, but the witness started

 8     his evidence at around quarter to 4 one afternoon, on -- sorry I won't

 9     mention the day, and concluded his testimony at 6.22.  So it's --

10             JUDGE KWON:  I think he started in 2 past 4.

11             MS. SUTHERLAND:  Your Honour, the transcript -- the transcript

12     says recess taken at 3.40 p.m., on resuming, yes, you're right,

13     Your Honour, 2 minutes past 4 and it finished at 6.30.

14             MR. KARADZIC: [Interpretation] But there is another testimony.

15     There is another testimony, and the transcript has been admitted.

16             MS. SUTHERLAND:  The Rule 92 ter package for this witness is the

17     Brdjanin testimony only.

18             JUDGE KWON:  Given the time, it's time to take a break.  We

19     will -- the tape is running out.

20             MS. SUTHERLAND:  Yes, Your Honour, I'll deal with this after the

21     break and then I have one other question that I wanted to clarify.  Thank

22     you.

23             JUDGE KWON:  We will resume at ten past 11.

24                           --- Recess taken at 10.38 a.m.

25                           --- On resuming at 11.10 a.m.

Page 19087

 1             JUDGE KWON:  Mr. Witness -- yes, let's finish your examination in

 2     chief, yes, Ms. Sutherland?

 3             MS. SUTHERLAND:  Your Honour, can we go into private session,

 4     please?

 5             JUDGE KWON:  Yes.

 6                           [Private session]

 7   (redacted)

 8   (redacted)

 9   (redacted)

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   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19088

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12                           [Open session]

13             MS. SUTHERLAND:  I have no further questions, Your Honour.

14             JUDGE KWON:  Thank you, Ms. Sutherland.

15             Sir, you will be further asked by the accused in his

16     cross-examination.

17             Mr. Karadzic, the Chamber considered the request.  However, an

18     hour for your cross-examination of this witness in the Chamber's view is

19     more than sufficient.  Just get on -- please get on with your

20     cross-examination.

21             MR. KARADZIC: [Interpretation] Thank you, Your Excellency.  But

22     for the transcript, I need to say -- in fact, are we in open session,

23     right now?

24             JUDGE KWON:  Yes.

25             MR. KARADZIC: [Interpretation] For the record, I'd like to say

Page 19089

 1     that we've had a large number of witnesses that the Defence considers

 2     improperly questioned.  That was the case with the previous witness as

 3     well.  He was not questioned about many of the incidents, and it is quite

 4     impossible for us, Your Honour, because the statements created by the

 5     Prosecution are very complex and they speak of many incidents, not just

 6     one, because if it were for one incident alone, it would be much easier

 7     for us to cross-examine the witness.  However, the witness repeats the

 8     whole story, and it is very difficult.  And then, the Prosecutor gets up

 9     on his or her feet and says that the Defence did not really challenge

10     that properly.  Well, how can I challenge it when I'm not given the

11     opportunity?

12             JUDGE KWON:  Please don't waste your time.  The Chamber's

13     position has been made clear to you on several occasions.  I won't repeat

14     it.  Please get on with your cross-examination.

15             MR. KARADZIC: [Interpretation] Thank you.

16                           Cross-examination by Mr. Karadzic:

17        Q.   Mr. Witness, were you familiar with the political developments in

18     Bosnia and in your own municipality?

19        A.   Well, I was never involved in politics.  I was not really

20     interested.

21        Q.   Thank you.  Were you familiar with negotiations on the future of

22     Bosnia, and of your own municipality in the event that Bosnia became

23     independent?

24        A.   No.

25             JUDGE KWON:  If you are going to continue to complain about your

Page 19090

 1     shortage of time, I'll have to intervene with you.  How are the

 2     negotiations relevant to this witness's evidence, which is talking about

 3     what he experienced as a victim mainly, Mr. Karadzic.

 4             MR. KARADZIC: [Interpretation] Well, Your Excellency, that's not

 5     what we are talking about, he says that the Muslims were expelled from

 6     the police station.  He was told this by his relative.  What I'm trying

 7     to establish here is whether we should discuss matters and issues that he

 8     has no knowledge of and then just move on directly to the incident.  And

 9     that's why I'm asking about his knowledge.  Whether he knew that there

10     were two police stations and that Muslims had not been expelled and that

11     they could accept --

12        Q.   So did you know about this?

13        A.   No.

14        Q.   So why did you talk about these things in your statement?  Your

15     statement is replete with very generalised statements that you -- matters

16     that you know nothing about.

17        A.   Well, as I've already said, I was not involved in politics and

18     I didn't really know what the situation was but I know that the policemen

19     or actually it was being said that the policemen were expelled from the

20     police station, then they moved to the municipal building and then a few

21     days later they were expelled from there too and as far as I know they

22     had been shot at.

23        Q.   Well, that is precisely the problem, witness.  You're discussing

24     matters that you have no knowledge of.  Now, do you know that the Muslims

25     could remain within the police station, the Serb police station, provided

Page 19091

 1     that they signed a statement?

 2        A.   Well, I don't know that.

 3             JUDGE KWON:  Yes, Ms. Sutherland?

 4             MS. SUTHERLAND:  Can Mr. Karadzic keep his tone of voice down and

 5     let the witness answer, please?

 6             JUDGE KWON:  Reference.

 7             MS. SUTHERLAND:  And also provide references to me of the page

 8     number of the statements when he's going to put these assertions to the

 9     witness.

10             JUDGE KWON:  Mr. Witness, have you been following the question?

11     Are you able to answer the question?  Then please proceed.

12             MR. KARADZIC: [Interpretation]

13        Q.   Well, I don't have enough time for all references and I should

14     actually yell here at the Prosecutor, not the witness, because these

15     statements are overly ambitious and I'm unable to test them in an hour's

16     time.

17             Now, witness shall -- if I ask the witness, is it correct that

18     your relatives told you that these policemen were kicked out and -- but

19     you didn't know that they could stay if they signed an oath of loyalty?

20        A.   Well, that's correct, I didn't know.

21             JUDGE KWON:  Mr. Karadzic, I repeat:  All witnesses are

22     different, and some are indeed more difficult than others.  Even every

23     experienced lawyer conducting cross-examination has to deal with

24     witnesses who may make broad and general statements or are difficult in

25     some way or another.  However, this does not mean that you should explore

Page 19092

 1     every single general statement a witness may make.  As I emphasised

 2     several times earlier on, the point of cross-examination is to pick

 3     certain parts of evidence led in chief that can be challenged.  Thus you

 4     should focus on challenging the evidence of the witness in certain areas,

 5     preferably where you have best material to do so.  Please bear that in

 6     mind.  And please stop making these statements about you being

 7     disadvantaged by difficult witnesses.  Every lawyer has to deal with this

 8     problem.  That's just the nature of trial in general.  Let us move on.

 9             MR. KARADZIC: [Interpretation] Well, perhaps this was

10     misinterpreted.  I don't have the problem with this witness.  I have a

11     problem with insufficient time to test and challenge each of the

12     positions forwarded by the Prosecutor in the statements.  And whether

13     these can be grounds for a conviction, because if they can or cannot,

14     then I really cannot -- I'm not given an opportunity to challenge that.

15     And my hands are tied.

16             JUDGE KWON:  Yes, Ms. Sutherland?

17             MS. SUTHERLAND:  Your Honour, his statements are not part of the

18     evidence for this witness.  It's his Brdjanin testimony.

19             JUDGE KWON:  Yes.  Thank you, Ms. Sutherland.  Please get on with

20     your cross-examination.

21             MR. KARADZIC: [Interpretation] Just one final word.  I am

22     entitled to challenge the credibility of a witness and I cannot do that

23     on the basis of one statement alone.

24        Q.   Now, witness, sir, you said that in 1991, check-points were set

25     up.  Is it correct, and did you actually go through these check-points,

Page 19093

 1     on numerous occasions and ask for your IDs?

 2        A.   Well, I said the check-points were set up in 1992 and I did have

 3     occasion to go through them on a number of times.

 4        Q.   Very well.  And of course they verified, they checked your

 5     papers, they checked your car, they didn't find anything suspicious and

 6     you were allowed through, correct?

 7        A.   Yes.

 8        Q.   You know, don't you, that Muslims and Croats did not join the JNA

 9     either as regular conscripts or as reserve staff but Serbs did, correct?

10        A.   Yes.

11        Q.   You know -- also know that Serbs who had up until recently, as

12     you stated, been civilians, once the mobilisation was in place, they

13     joined the 6th Krajina Brigade; is that correct?

14        A.   Yes, that's correct.

15        Q.   You have also stated that up until 27 June, in 1992, there were

16     no disturbances of any kind in your village?

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19094

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6        A.   Well, I think about three kilometres, maybe four.

 7        Q.   Thank you.  Do you know that Hrustovo and Vrhpolje had 300

 8     Muslims, there was an armed formation in Hrustovo of 300 armed Muslims,

 9     whereas there were a total of some 900 fighters in that area?

10        A.   I think that's not true.

11        Q.   Thank you.  Do you know that fighting began in Prijedor, which is

12     some 20 kilometres away from Sanski Most, and that this fighting broke

13     out on 23 May?

14        A.   I don't know anything about that.

15        Q.   Do you know that the entire valley of the Sana river, Kljuc,

16     Sanski Most, Prijedor, Bosanski Novi, all those places, in all those

17     places there was a series of attacks by the Patriotic League and the

18     Green Berets against Serb -- the Serbian army and Serb villages between

19     the 25th and 27th?

20        A.   Well, I don't know anything about that.

21        Q.   Do you know that that is how the fighting began in late May, in

22     other words between 23 May and 31 May, there was major fighting between

23     the Muslim army and -- the Muslim soldiers and the Serbian army there?

24        A.   Well, I was unable to leave my village, and in late May I wasn't

25     even unable to go to Sanski Most.  In other words, the tensions were

Page 19095

 1     already too high.  So I couldn't know anything about the developments in

 2     Prijedor, Bosanski Novi or Kljuc or anywhere like that.  I didn't know

 3     anything about that.

 4        Q.   Is it correct that you said that you were in Hrustovo in late

 5     May?

 6        A.   Yes.

 7        Q.   Was there a lot of fighting in late May in Hrustovo?

 8        A.   Well, at the time when I was in Hrustovo the fighting had just

 9     begun.

10        Q.   What fighting was this, between whom?

11        A.   Well, this was fighting between Muslims and Serbs.

12        Q.   Which units were present there from -- on the Serb side and which

13     Muslim units were there?

14        A.   I don't know about the Serb units, but in Hrustovo village, there

15     were a few men who remained there, but as for units, an organised armed

16     force there, I know nothing about that.  I didn't see anyone there.

17        Q.   Thank you.  And how long did the fighting last in Hrustovo?

18        A.   When the fighting started, I stayed in Hrustovo perhaps two more

19     days.  On the second day after the fighting started I left Hrustovo and

20     moved to the neighbouring (redacted)

21        Q.   And you spent a few days with this relative.  I don't want to

22     mention his name.  Why didn't you go to your own home instead?

23        A.   Because he asked me to bring his mother, who was also in Hrustovo

24     at the time, visiting her daughter, and he said his place might be safer

25     than Hrustovo.

Page 19096

 1        Q.   Why would his home be safer than yours?

 2        A.   Because he had Serb neighbours, and he must have discussed it

 3     with them, and it was decided that it was safer.  There was no fighting

 4     there, whereas there was fighting in Hrustovo.

 5        Q.   So for a whole month after the fighting in Hrustovo, nobody

 6     (redacted)

 7        A.   That's correct, not until 27 June.

 8             JUDGE KWON:  Just a second.  Yes, Ms. Sutherland?

 9             MS. SUTHERLAND:  I seek a redaction on page 48, lines 13 and 25,

10     and I'm wondering about page 50, line 17.  The village that was mentioned

11     there.

12             JUDGE KWON:  Thank you.  Let us continue, Mr. Karadzic.

13             MS. SUTHERLAND:  And also, sorry, line 51 -- page 51, line 3.

14             MR. KARADZIC: [Interpretation] Thank you.  Then in the future,

15     I'll refer to it as your village.  Are we in open session?

16             JUDGE KWON:  Yes.

17             MR. KARADZIC: [Interpretation]

18        Q.   You've said that before the conflict and at the outbreak of the

19     conflict, you saw different units around town wearing a variety of

20     uniforms.  How would you describe it briefly?  What kind of units were

21     they?  What kind of uniforms, what kind of insignia?

22        A.   You mean in Sanski Most?

23        Q.   Yes.

24        A.   In Sanski Most, I was able to see a lot of soldiers, reservists,

25     military policemen, civilian police, and the reserve police.

Page 19097

 1        Q.   As far as the army is concerned, they all wore the same uniforms

 2     and the police wore the same uniforms, but you said you saw a variety of

 3     uniforms.  Did you see any more uniforms with different insignia?  You

 4     said that in the trial from which we have your transcript that was

 5     admitted.

 6        A.   I saw camouflage uniforms and the regular green olive-grey

 7     uniforms, and the insignia were the Serbian Tricolour, and I'm not sure

 8     about that sign with the coat of arms with the four S.  I think I saw

 9     that too.

10        Q.   In your evidence on page ending with 081, you said you had not

11     seen any insignia at all.

12        A.   I don't know about that.

13        Q.   It was page 8081 in that testimony you gave.  Is it true that you

14     said, and you were aware, that on 28 May the Serbs announced on the radio

15     that all Muslims had to turn over their weapons, those who turned over

16     their weapons will be allowed to go to Tominska Palanka, a Muslim hamlet

17     near Tomina?

18        A.   Correct.

19        Q.   Is it true, witness, that Serb soldiers took civilians from

20     Hrustovo and Vrhpolje to Tominska Palanka while the fighting lasted?

21        A.   That time I was not in Hrustovo so I cannot confirm but I heard

22     later from other people that they had been taken to Tominska Palanka.

23        Q.   But towards the end of May, you were in Hrustovo, why?

24        A.   I lived there.

25        Q.   You were not living in your village, were you?

Page 19098

 1        A.   I don't think you understood.  I lived in my village first.  Then

 2     I moved to the other village where my relative lived, which is the native

 3     village of my family.

 4        Q.   Let me ask you openly, witness:  After the fighting in Hrustovo,

 5     did you actually find shelter with your relative rather than your own

 6     home?

 7        A.   It was into the second day of the fighting that he invited me to

 8     move to his place.  But the fighting continued after that.

 9        Q.   P761, a document under 92 bis, is a statement I would recommend

10     to everyone's attention.  The witness described how a Serbian unit looked

11     after a group of civilians one whole day before moving them to Tomina.

12     Is that also in your municipality?

13             JUDGE KWON:  Yes, Ms. Sutherland?

14             MS. SUTHERLAND:  Your Honour, this is a comment by Mr. Karadzic,

15     he should be putting questions to the witness.

16             JUDGE KWON:  All the question he put so far in relation to that

17     statement is that -- is just a confirmation of the place, Tomina.  I look

18     forward to hearing any questions.  Yes, Mr. Karadzic.

19             MR. KARADZIC: [Interpretation]

20        Q.   Tomina is also in your municipality and it's a mixed Serb-Muslim

21     village; right?

22        A.   Tomina is a village in Sanski Most municipality but it was not

23     really mixed.  It was rather separated.  Tominska Palanka for instance

24     was an exclusively Muslim place.  The other part was almost purely Serb.

25        Q.   You're talking about two hamlets in the same village.

Page 19099

 1        A.   Right.

 2        Q.   And when you came there, you moved into Muslim houses, the mosque

 3     was still standing, and there was no fighting in Tomina, correct?

 4        A.   The mosque was still standing, I think, there was no fighting.

 5        Q.   Thank you.  And then you were taken away to Krings, right?

 6        A.   Right.

 7        Q.   Now, witness, I would like to know about 4 August, when you were

 8     released.  How could the authorities afford to release such a dangerous

 9     witness of such a dangerous incident?  Did the authorities know about the

10     incident and that you were involved in it?

11        A.   I think the policemen who interrogated me were not aware of that

12     incident.  And if I had told them I had survived it, I am certain

13     I wouldn't be sitting here today.

14        Q.   So they didn't know about it.  Did any other authorities know?

15        A.   I don't know.  You have to ask them.

16        Q.   Thank you.  So you stayed in Sanski Most for a while.  Was it

17     difficult to get on the list for transport?

18        A.   You mean to leave Sanski Most?

19        Q.   Yes.

20        A.   There was no list, I think.  They just said on the radio that

21     whoever wants to leave Sanski Most should go to the main road, that buses

22     would be provided, and we would somehow be shipped out of there.  You

23     didn't have to register anywhere.

24        Q.   Did they ask you for any money for the ticket?

25        A.   No.

Page 19100

 1        Q.   Did you have to produce some certificates that you had paid your

 2     taxes or something like that?  Was there any paperwork?

 3        A.   I don't think so.

 4        Q.   And where did you go?

 5        A.   From Sanski Most?

 6        Q.   Yes.

 7        A.   To Travnik.

 8        Q.   And then you joined the army, right?

 9        A.   No.  Certainly not.  I took the first chance I got to leave

10     Bosnia-Herzegovina.

11        Q.   And then when did you give the first statement about this

12     incident?

13        A.   After Sanski Most was liberated.

14        Q.   And how come you failed to give a statement about such a drastic

15     incident as soon as you came to Travnik?

16        A.   I wouldn't have known who to approach in Travnik.  Chaos reigned

17     there too.

18        Q.   We will go back to the incident in a moment.  But before that,

19     what about the people from your village and the other village where you

20     stayed or the hamlet that bears the same name an as your relatives?  Did

21     they look for any weapons there?

22        A.   They said everybody should surrender weapons and those people who

23     had licensed weapons, hunting weapons and pistols, surrendered them.

24        Q.   Were there any automatic rifles there and weapons in illegal

25     possession?

Page 19101

 1        A.   No.

 2        Q.   Did you turn over any weapons that a friend of yours took to the

 3     Serbs?

 4        A.   I did.

 5        Q.   What did you turn over?

 6        A.   An automatic rifle.

 7        Q.   Very well.  There was a debate among you whether to hand in the

 8     weapons or not, right?

 9        A.   Yes.

10        Q.   And when did you hand your weapon in, around what date?

11        A.   I can't remember the exact date.  Perhaps two days after the

12     shooting started.

13        Q.   Thank you.  And then if that was on 28 May, for the next 27 days

14     you did not have any more problems; right?

15        A.   Right.

16        Q.   And then Mr. Karanovic came, you say, with some reservists to

17     that hamlet and started searching houses; right?

18        A.   Yes.

19        Q.   And those searches for weapons lasted until 27 June?

20        A.   Which day you said they started?  They actually started one

21     morning with the searches, they took two hours, and then they took us

22     away.

23        Q.   They told you to gather at an intersection, right?

24        A.   Yes.

25        Q.   You described them as local reservists.  What kind of insignia

Page 19102

 1     did you see on them?

 2        A.   Can't remember any more.  But they were all locals.  People who

 3     lived nearby.  Some of them wore uniforms, some of them wore parts of

 4     uniforms.  One would have the shirt of a uniform.  Another would have the

 5     trousers of the uniform.  Some had weapons, some had not.

 6        Q.   What would you say what unit was it or were they perhaps not even

 7     a unit and under whose command were they?

 8        A.   I can't tell you anything about that.

 9        Q.   And then you were taken from that intersection, you were taken to

10     the Blazevic house?

11        A.   They told us we were being taken to be interrogated because they

12     suspected some of us still had weapons.  And when we came to the school,

13     they went on, they didn't even stop, and then we came to Marko Juric's

14     house.  We spent one whole day there.  This one man left us saying he was

15     going to look for the command because there was nobody around that house.

16     That was in the morning.  We spent the whole day there.  And he did not

17     reappear.

18        Q.   That's this Karanovic person; right?

19        A.   Yes.

20        Q.   You say on 28 June Vlado Vrkes stopped by, he was surprised and

21     asked you what you were doing there?

22        A.   Yes, a man came that day.  We didn't know him.  Then he

23     introduced himself as Vlado Vrkes, president of the SDS in Sanski Most.

24     And he asked us, what are you doing there?  And we explained that we had

25     been taken away from our homes to be interrogated.  He told us not to

Page 19103

 1     worry, that we would probably be exchanged for Serbs elsewhere in Bosnia.

 2        Q.   And you did not recognise him?

 3        A.   I couldn't recognise him because I didn't know him.  I knew

 4     nothing about politics.

 5        Q.   I'm confused because in that statement given in 1996, that

 6     65 ter 22086, page 2, you said you recognised him as soon as he appeared.

 7        A.   It must be some sort of mistake.  I didn't know him.  He

 8     introduced himself by name and surname.

 9        Q.   And he said you shouldn't worry, nothing to worry about, you will

10     probably be part of an exchange?

11        A.   That's correct.

12        Q.   And then he left, right?

13        A.   Yes, he left.  He was with us for a very short while.

14        Q.   Then Karanovic returned that afternoon and escorted you to where?

15        A.   When Karanovic returned he told us to pack our things, we were

16     going to Blazevici, the command was there, he said, and that's where we

17     would be interrogated.

18        Q.   And the two of them, they escorted you, they didn't tie your

19     hands behind your back; right?

20        A.   They didn't.  They took us further on.  We passed through a

21     hamlet called Djukici after which the road went through the forest, where

22     two other soldiers emerged.  I asked my relatives who they were.  And

23     they answered that those were the Djukic brothers who lived there.

24        Q.   Could we briefly look at 65 ter 22086?  Would you please take a

25     look at this page, page number 2?  Oh, please get the page back, do get

Page 19104

 1     the Serbian version back.

 2             MS. SUTHERLAND:  Can we ensure this isn't broadcast, please?

 3             JUDGE KWON:  Thank you.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Did you give this statement in our language and sign it?  You see

 6     what it says there, in the meantime, on 28 June, Vlado Vrkes came?

 7             JUDGE KWON:  We didn't get the answer from the witness to your

 8     previous question.  What was your answer?  Did you give this statement in

 9     your language?

10             THE WITNESS: [Interpretation] Yes, yes.

11             JUDGE KWON:  Thank you.

12             MR. KARADZIC: [Interpretation]

13        Q.   And you say here that you did not know these two men who came

14     with Vrkes, right?

15        A.   I didn't know Vrkes or the other two.

16        Q.   Take a look at what it says here:

17             "Vrkes was in a military uniform and I recognised him as soon as

18     he arrived."

19        A.   I don't know.  It may be a mistake.  I didn't know this Vrkes.

20     Maybe I wasn't paying attention when I was reading this and signing it.

21     But the fact remains that I did not know him.

22        Q.   So anyone could have said, "I'm Vrkes" and you would have

23     accepted that because you had not known him from before?

24        A.   That could have been the case.

25        Q.   Thank you.  So then you were taken to the house, you say that you

Page 19105

 1     were taken by two criminals, right?

 2        A.   No, I did not say criminals.  These were two Serbs who lived in

 3     that village too.  When we passed through those woods, then two other men

 4     got out, so there were four of them there ultimately.

 5        Q.   Let us look at page 2 of this same statement from 1996 where you

 6     say that there were two criminals, that's how you describe them.

 7        A.   I can't find it now.

 8        Q.   It should be page 2.  Now, is it in e-court?  Just a moment,

 9     please.  Just a moment, please.

10             JUDGE KWON:  Are you referring to two local Chetniks?

11             MS. SUTHERLAND:  Yes.  That's what I was about to say,

12     Your Honour.

13             MR. KARADZIC: [Interpretation]

14        Q.   You characterised them as local Chetniks, right?

15        A.   Yes.

16        Q.   What do you mean by that?

17        A.   For me, a Serb soldier who wears a cockade is a Chetnik.

18        Q.   They did wear cockade?

19        A.   One did and the other one had the tricolour flag on his uniform.

20        Q.   You never mentioned the Tricolour flag until now.

21        A.   Possibly.

22        Q.   Then two more Chetniks joined them from Djukici, right?  And you

23     called them Chetniks, too, right?

24        A.   Yes.  One of them had a cockade.

25        Q.   So first there were two of them and then there were another two

Page 19106

 1     and they took you to Dujo Banovic's house; is that right?

 2        A.   That's correct.

 3        Q.   What about Dujo Banovic, was he a Serb?

 4        A.   I didn't know the man.  He did not live in that house at that

 5     point in time.  I think he was a Catholic, though.

 6        Q.   Dusan Banovic could hardly be a Catholic, Mr. Witness; isn't that

 7     right?  It's a Serb name.  First name and last name.

 8        A.   I didn't say Dusan, I said Dujo.

 9        Q.   Isn't Dujo a term of endearment for Dusan?

10        A.   I don't know.  I just know that that was the man's name.  Dujo.

11     And there was this other house there near that one, another man lived

12     there, I don't know his name and I know that they were both Catholics.

13        Q.   All right.  Tell us, then, how many of you walked into the house?

14     You younger people.  And how many older people sat outside?

15        A.   Perhaps five younger persons entered the house.  Some people were

16     still standing by the entrance into the house, whereas these elderly

17     people were still outside.  I don't know how many of them there were

18     there.

19        Q.   Thank you.  They remained sitting outside.  That's what you said.

20        A.   They were still outside.  They had told us that we had to go

21     inside and that they were cocking their rifles - whatever the word may

22     be - and they pointed rifles at us and shade said that we had to go in.

23     I was among the first people who went in these people stayed outside and

24     they said, "Why do we have to go inside if we can stay outside.  If you

25     want to interrogate us you can go do that outdoors.  You don't have to

Page 19107

 1     make us go inside."

 2        Q.   You say, we younger men went inside whereas the others sat

 3     outside in front of the house trying to persuade Djukic Rado and Mico to

 4     stay outside; right?

 5        A.   Yes.

 6        Q.   And this discussion went on as they were sitting outside, right?

 7        A.   Once I walked in, I could not know whether they were still

 8     sitting outside or not, when they told us that we had to go into the

 9     house, they were still sitting out there and then when they told us we

10     should go in, they stayed outside although we went in.  And I don't know

11     how long they stayed outside.

12        Q.   When was it that someone shouted, "Watch out, grenade"?

13        A.   Perhaps two or three minutes had gone by.

14        Q.   Where did the grenade come from?

15        A.   I don't know from where.  Probably from outside, because you

16     could hear it hit against the wooden boards, probably it came from the

17     entrance door.

18        Q.   And who was it that shouted, "Watch out, grenade"?

19        A.   Probably those who were still standing by the door.

20        Q.   Ah-hah.  Whose grenade was that?

21        A.   Probably those Serbs who brought us there.

22        Q.   It couldn't have belonged to some Muslim?

23        A.   No.

24        Q.   How come you know that?

25        A.   Because no one had a grenade.

Page 19108

 1        Q.   Did you search them and thereby know that they did not have any

 2     grenades?

 3        A.   No, I did not.

 4        Q.   And then you say that you jumped out before the grenade exploded;

 5     right?

 6        A.   That's right.

 7        Q.   Three of you jumped out; right?

 8        A.   I know that I jumped out and how many others did, I don't know.

 9     Later on, I think there was another man but I'm not sure.

10        Q.   I don't know whether I can mention the name of the person who

11     jumped out but you say that he fell and then you fell over him, right?

12        A.   Yes.  Once we jumped out of that house, it was about two or three

13     metres down, and then this -- one of these Serbs started firing at us,

14     one of the Serbs who brought us there.  Then I hid behind a rock that was

15     right below the house.  When he stopped shooting then we started running

16     through this valley by the house.  It was full of bushes, shrubs, and

17     then he was running and then he stumbled over and then I stumbled over

18     him and then if I'd fall, then he'd run over me, but he was the first one

19     to get out of that valley.

20        Q.   How long did you go on running?

21        A.   Well, that is actually about 10 or 15 metres, that valley, that

22     is, that's its diameter.

23        Q.   That is something that you can cover in two leaps, witness, so

24     how did you manage to stumble and walk over each other so many times?

25        A.   Well, that's what you can do if it's clear, but I've already told

Page 19109

 1     you that there were lots of bushes and shrubs there so it wasn't a road.

 2     It was a forest.

 3        Q.   And then you left that valley and you went where?

 4        A.   When I got out of the valley, this Muharem, well, he had already

 5     started running, he got out of the valley, and then there was a meadow

 6     that was a clearing of about 200 metres, no woods there, and then he ran,

 7     he started running, at that moment I saw that one of these Serbs walked

 8     around this valley.  It was clear there.  So he went around and he

 9     started firing after the man who had fled.  I thought that I should flee

10     too.  But then I thought that I wouldn't stand a chance of running away

11     because they would hit me.  Then he emptied his magazine, and then

12     I jumped into the valley again.

13        Q.   And then you say that you heard what was going on in the house,

14     right?  You fled in the direction opposite the door, right?

15        A.   Well, the door wasn't exactly on the opposite side.  It was -- it

16     was on the side, in relation to where I was in the valley.

17        Q.   And what did you hear then, what was Karanovic saying to them?

18        A.   It wasn't only Karanovic who was there.

19        Q.   There were four of them?

20        A.   There were four of them and they were making them go out and they

21     were telling them to stand by the wall with their hands up.

22        Q.   Well, I'm a bit perplexed by that too, witness.  How did they

23     manage to drive them out when they had already been outside?

24        A.   Not all of them.  Not everybody was outside.  I've already said

25     that perhaps five of us were in a room.  Some were still standing at the

Page 19110

 1     door.  And others were outside.  Now, whether they came in as well, I

 2     don't know.  I have no way of seeing that.

 3        Q.   All right.  That means that they should have entered the room

 4     where the grenade had exploded?

 5        A.   It's possible that they entered the room where I had been.  Those

 6     people who were by the door.  Maybe those people who were outside also

 7     went in to the place where the grenade had exploded.

 8        Q.   And what happened then?  Was anybody wounded by this grenade?

 9        A.   That, I don't know.

10        Q.   And then you heard them being taken out, and you heard them

11     shooting, and then bringing them inside again, into the house, that is?

12        A.   Yes.  I heard them saying, "This one is heavy.  He weighs like

13     100 kilos."  Things like that.

14        Q.   Mr. Witness, how can you claim that this grenade was not thrown

15     by a Muslim thus leading to this catastrophe?

16        A.   Are you saying that we tried to kill ourselves?  Or what?

17        Q.   I'm not trying to say that you wanted to kill yourselves but you

18     did want to kill these four Chetniks.  Not you from the inside but the

19     others who were outdoors because you said that the grenade had come from

20     outside, right?

21        A.   Well, yes.  Out there, in front of the entrance door.  I believe

22     it came from there.  There was no other possibility because that house

23     was a very old house, it was boarded up, and there was just this one room

24     where that person used to live before.

25        Q.   And then you went to Tomina, after Tomina you spent a month in

Page 19111

 1     Krings, right?

 2        A.   Yes.

 3        Q.   These four men, did they brag about this?  Did they inform anyone

 4     about this?

 5        A.   What do you mean, inform who?

 6        Q.   These people who took you to Krings, did they inform anyone about

 7     what they had done?

 8        A.   That, I don't know.

 9        Q.   Did you inform any authorities about what had happened?

10        A.   No.

11        Q.   This Muharem is mentioned in relation to that exhumation as well.

12     However, you know that he fled.  Also you heard that he was arrested

13     later on, right?

14        A.   Yes.

15        Q.   How come he's on that list, then, the exhumation list?

16        A.   You'll have to ask the person who wrote up that list.  Probably

17     since there is a memorial plaque there on the spot, that was erected by

18     the relatives of the victims, then his name was included too.  Now,

19     whether this person wrote the list on the basis of that memorial plaque

20     taking the names from the memorial plaque book, that's a possibility.

21        Q.   Can we have page 4 of this statement now?  The one that's here

22     right now, that is.

23             In case of an exhumation, does one write the names that are found

24     on a list or does one write the names of persons who had been identified?

25     How can that kind of list include the name of a man who was not killed

Page 19112

 1     there?  I think it's the one before this, the page before this.  Maybe

 2     it's all right in English but I think in Serbian we need the previous

 3     page.  How do you explain that?  How do you explain that on the list of

 4     exhumed persons you find the name of a man who did not lose his life

 5     there?

 6        A.   I don't know who wrote the list.

 7             JUDGE KWON:  Just a second.  Yes, Ms. Sutherland?

 8             MS. SUTHERLAND:  I'll just make the observation that it's not for

 9     the witness to comment on why somebody writes something down in an

10     exhumation report.

11             JUDGE KWON:  But he's talking about the witness's statement.

12             MS. SUTHERLAND:  I'm sorry, I misunderstood, Your Honour.

13             MR. KARADZIC: [Interpretation].

14        Q.   Can you see this here, where the name of this gentleman is

15     mentioned?  I don't want to mention it.

16        A.   On this page that is here?

17        Q.   In this statement, did you say that he had fled, that he had not

18     lost his life there?

19        A.   I'd have to read the statement again to see whether I had stated

20     that he had fled from that spot, and that is what I kept saying all the

21     time because it's the truth.  He fled from that spot, the place where

22     that house is.  He fled from there.

23             JUDGE KWON:  Let's check out whether you mentioned that he fled

24     at the time, but could you confirm that he is here as having been killed

25     and burned on that place?  Do you see his name or not?  We can collapse

Page 19113

 1     the English page and zoom in on the B/C/S version, in particular I think

 2     his name appears in the sixth line from the bottom.  Or around there.

 3             THE WITNESS: [Interpretation] Could you please zoom out a bit

 4     perhaps?

 5             JUDGE KWON:  Okay.  Yes, Ms. Sutherland?

 6             MS. SUTHERLAND:  Your Honour, that's, as I understand it, a

 7     different Muharem.

 8             JUDGE KWON:  Thank you.  That's something the witness should tell

 9     us.  Did you find it?

10             MR. KARADZIC: [Interpretation].

11        Q.   That's on the sixth line from the bottom.

12        A.   Yes, I can see his name here.  Yes, it's Muharem Kenjar.  He was

13     born, it's possible that he was born in 1966 but as you can see most of

14     these people had similar names, Muharem, Mehmed, son of this or that man.

15     So there was always confusion about that.

16        Q.   What was the name of the man who had fled?

17        A.   Safet.

18        Q.   Can you see below this stamp here that it says, son of Safet?

19        A.   Well, I can't really read it.  I can't make it out.

20        Q.   You can't see the S and the A?  And the F?  Could we just zoom in

21     on the stamp itself?  The Tribunal's stamp.  Yes, that's the one.  Can

22     you make out SAF?

23        A.   Well, I can see the S but as for the rest, I'm not sure.  It is

24     possible that that's what it states there.  It may be an error or

25     something but I am still -- I'm still saying that this Muharem had fled

Page 19114

 1     and that later on he was seen in Sanski Most and then after that all

 2     track is lost of him.

 3        Q.   How far was this Blazevic house from Kijevci?

 4        A.   From where we were, about four kilometres perhaps.

 5        Q.   And you managed to walk that distance in how long?

 6        A.   Well, we were taken there one day, and we managed to get to

 7     Juric's house in about half -- in 30 minutes or half an hour.  We stayed

 8     there the whole day and then on the next day we walked again for about

 9     half an hour or maybe even less.

10        Q.   Thank you.  We don't need this document any more.

11             Witness, sir, while you were in Tomina, you said that there were

12     two kinds of men.  One group were prisoners of war and the other were

13     refugees, correct?

14        A.   Well, I don't understand your question.  I never said anything

15     like that.  I didn't mention prisoners of war.

16        Q.   Well, how were you treated and how were the others treated?

17        A.   Well, we who had come from these two villages mentioned earlier,

18     who came to Tomina, we were refugees.  As for the rest, they were hosts

19     there, they were locals.

20        Q.   You said that you had spent the night in a house of a Muslim,

21     I don't want to mention his name, that you found your mother there or his

22     mother there, they fed you?

23        A.   Yes.

24        Q.   And they told you that Muslim refugees from Hrustovo and Vrhpolje

25     were accommodated there and that there were men there as well?

Page 19115

 1        A.   That's correct.

 2        Q.   And then you say Chetniks came and took you away.

 3        A.   Yes, that's correct.  Some police and military personnel came.

 4     They used a bull horn.  They were saying that everyone, all refugees,

 5     should come out and get on the main road and wait there, stay there.

 6        Q.   And then the men whom they considered to be combatants, they took

 7     them away to Krings?

 8        A.   No.  We were all taken to Krings.  Men, women, grown-ups,

 9     everyone.

10        Q.   And when were women and children released?

11        A.   They were transported in the morning on buses and trucks.  Later

12     on, I learned that they were taken to Gracanica.  You know where that is

13     in Central Bosnia, near Doboj or whatever, thereabouts.

14        Q.   Who were you interrogated by in Krings?

15        A.   By a policeman.

16        Q.   What did he question you about?

17        A.   Well, he asked me -- he told me to tell him everything, from the

18     day the conflict broke out, up until that moment, to tell him my

19     whereabouts, what I did, whether I had any weapons and so on.  And

20     whether I knew who had weapons.

21        Q.   How many times were you interrogated?

22        A.   Once.

23        Q.   Was he writing anything down?

24        A.   I think so.

25        Q.   And on the basis of what you told him, you were released on

Page 19116

 1     4 August, correct?

 2        A.   I believe so.

 3        Q.   While some were sent to Manjaca?

 4        A.   Some people were taken to Manjaca as soon as we were brought in

 5     there, on that same morning, the women, the children and the elderly and

 6     infirm were transferred, they were taken away, whereas a group was sent

 7     to Manjaca either on the same day or the following day, I'm not quite

 8     sure about that.

 9        Q.   Thank you.  Are there two judges in Sanski Most by the name of

10     Adil Draganovic, or is there one man alone by that name?

11        A.   I believe there is only one man.

12        Q.   Do you know to what extent he was involved in the preparations

13     for armed conflict in Sanski Most?

14        A.   I saw Mr. Draganovic for the first time on the day when

15     I provided the statement.  What he did before that, I don't know.

16        Q.   Do you find it a bit unusual that he would investigate or

17     question about matters that he participated in himself?

18        A.   Well, I don't know what you mean.  He did not take part in these

19     events where I was involved.  He wasn't there.

20        Q.   Thank you.  In your statement provided to him in 1996, it says

21     that you came there on your own, without being summoned.  How is it that

22     you spoke about those matters for the first time then?

23        A.   Because I was not in Bosnia and Herzegovina.

24        Q.   Do you know what the outcome of this battle in Hrustovo which

25     lasted about two or three days, do you know how many dead, how many dead

Page 19117

 1     there were on either side?

 2        A.   Well, I didn't at the time.  I learned later on.

 3        Q.   What did you find out?

 4        A.   That there were many casualties, there were a lot of civilians

 5     killed in Hrustovo, in Vrhpolje, that one or two Serb soldiers were

 6     killed.

 7        Q.   And that's what you've learned?

 8        A.   Yes.

 9        Q.   You were not beaten in Krings by anyone, correct?

10        A.   Yes.  I was not beaten.

11        Q.   You say that you weren't beaten harshly, that you weren't beaten

12     much?

13        A.   Well, yes, compared to the other prisoners, I was not mistreated

14     too much.

15        Q.   Were you allowed at first to receive visitors by your relatives

16     and to be brought some foodstuffs by them, but -- and that those visits

17     were only banned later on but you were still -- you were still allowed to

18     get food from outside, correct?

19        A.   Yes.  That's true.

20        Q.   Please bear with me.  I have to make selection here of what I'm

21     going to skip.

22             What did you know about paramilitary units?  You mentioned some

23     Serb defence forces or something.  Did you know anything about

24     paramilitary forces in Sanski Most?

25        A.   I'm not sure what paramilitary units you're referring to.

Page 19118

 1        Q.   Well, what did you know about the military units that were there?

 2        A.   I knew that there were a lot of reservists and that there were a

 3     lot of armed Serbian soldiers, nothing else.

 4        Q.   These were reservists until the time when the

 5     Army of Republika Srpska was established, correct?

 6        A.   That's possible.

 7        Q.   They were JNA reservists?

 8        A.   That's possible.  I know that they were there.  I mean the JNA

 9     did not even exist any more at the time.  It was abolished earlier, as

10     far as I know.

11        Q.   Well, the JNA left Bosnia on 9 May, do you remember?

12        A.   Maybe the JA, the Yugoslav army, but the NA, no.

13        Q.   Would you agree, then, that the Army of Republika Srpska was

14     already in existence on 20 May and that these reservists of the Yugoslav

15     army or the JNA at that time ceased being JNA reservists, they became

16     reservists of the VRS?

17        A.   Do you mean as of 20 May and onwards?

18        Q.   Yes.

19        A.   Well, I believe that those units had become a Serb army long

20     before that because there weren't any Muslims or Catholics in their

21     ranks.  There were just Serb forces.

22        Q.   Serb forces, you're talking about the composition, right, but was

23     the Army of Republika Srpska in existence before 20 May?

24        A.   I don't know that.

25        Q.   Thank you.

Page 19119

 1             JUDGE KWON:  For planning purpose, I take it you do not have much

 2     for your re-examination, Ms. Sutherland?

 3             MS. SUTHERLAND:  Less than five minutes, I would think.

 4             JUDGE KWON:  You have something?

 5             MS. SUTHERLAND:  Yes.

 6             JUDGE KWON:  Mr. Karadzic, your time was up five minutes ago.

 7     Please conclude in five minutes.

 8             MR. KARADZIC: [Interpretation] Thank you.

 9        Q.   Witness, sir, do you know that the police in Sanski Most, the

10     Serb police in Sanski Most, documented each incident and prosecuted them

11     during the war and if it hadn't managed to do it during the war it did

12     that after the war, all these prosecutions were conducted pursuant to

13     investigations that had been conducted by Serbs during the war?

14        A.   I didn't know anything about that.

15        Q.   Did you know that Mr. Draganovic found at least 30 criminal

16     prosecutions of Serbs who had committed something against Muslims?

17        A.   I didn't.

18        Q.   Mr. Witness, wouldn't it be -- wouldn't it have been appropriate

19     for you to report what had happened at the Banovic house so that it could

20     be documented and investigated by an investigating team?

21        A.   I don't think that would have been appropriate.  I think that

22     Muharem perhaps, who had fled the scene, that he would have been able to

23     perhaps say something to the police and explain it.  Had I tried to do

24     that, the same would have happened to me.

25        Q.   But, sir, we have a lot of documents that we cannot show today,

Page 19120

 1     where we see that Muslims approached freely went to the courts and

 2     submitted their criminal complaints and that these are still being

 3     prosecuted to this day.  Did you know about that?

 4        A.   No.

 5        Q.   Very well.  But as I'm out of time, I have no further questions.

 6     Thank you.

 7             JUDGE KWON:  Thank you, Mr. Karadzic.

 8             Yes, Ms. Sutherland?

 9                           Re-examination by Ms. Sutherland:

10        Q.   Witness, earlier this afternoon, Mr. Karadzic put to you, after

11     the fighting in Hrustovo did you actually find shelter, and went on a

12     little more and then you said it was into the second day of the fighting

13     that you were invited to move into a certain place.

14             And then just a moment ago, Mr. Karadzic also asked you -- he

15     referred to the battle in Hrustovo.  Do you recall both of those

16     questions from Mr. Karadzic?

17        A.   Yes.

18        Q.   Do you recall, when you testified in the Brdjanin case, and this

19     is at transcript page 8053 and 8054, when you were asked about -- first

20     of all, when there was a -- you were asked -- there was an announcement

21     to hand over the weapons, and then you were asked in any point in May was

22     Hrustovo shelled and you said yes.  Was it before or after the

23     announcement to hand over the weapons?  You said to a slight degree

24     before the announcement and then afterwards it was continued.  Do you

25     recall saying that in -- when you were asked in your evidence in the

Page 19121

 1     Brdjanin case?  Giving that answer?

 2        A.   Well, I can say this:  I can't recall what he said in the other

 3     case but I will tell you as I recall the events themselves.  First, the

 4     fighting broke out.  Then the shelling started of Hrustovo.  And then a

 5     day or two later, there was the announcement on the radio that weapons

 6     should be surrendered.  That whoever had a weapon should surrender it and

 7     would be allowed to leave the town.  In other words, to be able to get

 8     away from the combat zone.

 9             MS. SUTHERLAND:  Just a moment, Your Honour.

10                           [Prosecution counsel confer]

11             MS. SUTHERLAND:

12        Q.   Sir, when you referred to the continued fighting, were you --

13     were you referring -- what were you referring to?  Were you referring to

14     that or the continued shelling?

15             MR. KARADZIC: [Interpretation] Well, this is really a leading

16     question and it is just putting pressure on the witness.  The witness has

17     already given an answer.  Perhaps not to their liking but there is no

18     need to seek another one.

19             JUDGE KWON:  We can ask him this way.  You said that after the

20     fighting in Hrustovo, you found shelter with your relative, we can say

21     that in public.  So what did you mean by "fighting"?  And you also said

22     in your answer that it was into the second day of the fighting that you

23     found shelter.  And you also said the fighting continued after that.  So

24     what did you mean by that word "fighting"?

25             THE WITNESS: [Interpretation] Do you mean after I left Hrustovo?

Page 19122

 1             JUDGE KWON:  I will leave it in your hands.  Please continue.

 2             MS. SUTHERLAND:

 3        Q.   No.  Before, when you said that you went to your relative's place

 4     in Hrustovo, after the fighting, my question was, are you referring to --

 5     what do you mean by the fighting?  Are you referring to the shelling of

 6     Hrustovo which you mentioned in your prior testimony --

 7             MR. KARADZIC: [Interpretation] Could we have a reference?  And

 8     could we please ask the Prosecutor to abstain from leading the witness?

 9             MS. SUTHERLAND:  It's on transcript page 8053.

10             JUDGE KWON:  No, no, no.  I asked the question.  I asked the

11     witness to clarify the meaning of "fighting" which he referred to.  So it

12     was before you left.  So what did you mean by "fighting"?

13             THE WITNESS: [Interpretation] Well, I meant the Muslims were

14     shooting from one side and the Serbs from the other.  This was how it was

15     at the beginning.  At first, it was with light weapons, perhaps there

16     were one, two or three shells that landed.  I don't know who fired them.

17     But then some half day later or so, the shelling of Hrustovo started, and

18     this was the Serb army shelling it.  And this shelling went on for the

19     whole day.  And then on the next day, around noon time, there was a lull.

20     And then came this announcement on the radio that all weapons should be

21     surrendered and that afternoon there was no shelling any more.  In other

22     words, it was on that afternoon that I found shelter with my relative.

23     At that time there was no shelling.  But then a few days later, it got

24     even worse, and I don't know much about that.  All I could hear is the

25     blasts, and I don't know who and how much shelling there was, but I do

Page 19123

 1     know one thing:  There were no heavy weapons in Hrustovo.  If anybody did

 2     have any weapons, that would be just light weapons, personal weapons.

 3     And also, in addition to that, I could see above Tomina village which is

 4     where the Serb positions were, I could see shells being fired.  There was

 5     some artillery there.  We could see flashes from the barrels and then --

 6     from those positions, and then later on, a few moments later, we would

 7     hear the shell hitting Hrustovo.

 8             MS. SUTHERLAND:  I have no further questions, Your Honour.

 9             JUDGE KWON:  Thank you.  Sir --

10                           [Trial Chamber and registrar confer]

11             THE REGISTRAR:  Your Honours, there are two associated exhibits

12     for which numbers will be assigned.  The first is 65 ter number 19922

13     which will be Exhibit P3377 under seal.  And the second will be 19921

14     which will be Exhibit P3378 under seal.

15             JUDGE KWON:  Thank you.  Sir, that concludes your evidence.  On

16     behalf of the Chamber and the Tribunal, I would like to thank you for

17     your coming to The Hague to give it again.

18             Now you are free to go, and please have a safe journey back home.

19             We will take break for half an hour and resume at -- no, I'm

20     sorry, for an hour, and resume at 1.40.

21                           [The witness withdrew]

22                           --- Recess taken at 12.37 p.m.

23                           [The witness entered court]

24                           --- On resuming at 1.43 p.m.

25             JUDGE KWON:  Good afternoon, sir.  Please take the solemn

Page 19124

 1     declaration.

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

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

 4                           WITNESS:  PETKO PANIC

 5                           [Witness answered through interpreter]

 6             JUDGE KWON:  Thank you, please be seated and make yourself

 7     comfortable.  Yes, Ms. Elliott?

 8             MS. ELLIOTT:  Can I please call up 65 ter number 22584 and

 9     e-court page 36.

10                           Examination by Ms. Elliott:

11        Q.   What's going to come up on the screen, Mr. Panic, is a transcript

12     of your testimony in the Stanisic and Zupljanin proceedings on 11 to 13

13     November 2009.  This is referring to page T-2902, at line 21, the

14     transcript records the name "Milan Radic" and I understand from speaking

15     with you that this should read, Milan Radovic.  Is that correct?

16        A.   Yes.

17        Q.   Mr. Panic, you've listened to your testimony in your own

18     language.  Was the information you provided to the Court accurate, and if

19     you were asked the same questions today, would you provide the same

20     information?

21        A.   Yes.

22             MS. ELLIOTT:  May the transcript be admitted as the next exhibit,

23     please?

24             JUDGE KWON:  That will be admitted.

25             THE REGISTRAR:  As Exhibit P3380, Your Honours.

Page 19125

 1             MR. KARADZIC: [Interpretation] May I ask why the agreed practice

 2     has been abandoned of presenting an amalgamated statement?  Is the OTP

 3     also suffering from time pressure or what?

 4             JUDGE KWON:  I don't think there is any violation or

 5     inconsistency in admitting one statement.  If the -- what was ordered was

 6     that if the OTP is minded to tender various statements, it should produce

 7     one amalgamated statement.  However, in this case, they are going to

 8     tender just one transcript of testimony.

 9             Yes, Ms. Elliott.

10             MS. ELLIOTT:  I'll read the 92 ter summary.

11             Mr. Panic was the assistant commander for the reserve police

12     station in Zvornik in 1992.  On 6 April 1992, upon the order of police

13     commander Dragan Spasojevic, the Serb police in Zvornik separated from

14     the multi-ethnic police force.  When they arrived at Alhos building in

15     Karakaj, Dragan Spasojevic, Brano Grujic and some of Arkan's and Seselj's

16     men were already there.

17             On 8 April 1992, the action to take over Zvornik began.

18             Arkan's unit led the action and the police were ordered to follow

19     them and guard certain facilities.  There was no serious resistance from

20     the Muslim side.  During this operation, Mr. Panic saw approximately five

21     bodies dressed in civilian clothes.

22             Various paramilitary units operated in Zvornik, including units

23     under Zuca, Crni, Niski, Pivarski, Milorad Gogic and Simo Chetnik as well

24     as the White Eagles.  Several of these units were involved in moving

25     women and children out of Muslim villages and detaining the men.

Page 19126

 1             Some paramilitary units were paid by the municipality or the MUP.

 2             On 1 June 1992, the Zvornik police commander at the time,

 3     Marinko Vasilic, ordered Mr. Panic and other police officers to

 4     Bijeli Potok where they assisted VRS units to load Muslims from the area

 5     of Klisa on to trucks and buses.  Approximately 5.000 to 6.000 women,

 6     children and elderly men were put on buses and taken out of the area

 7     while approximately 700 men were taken to Karakaj Technical School.

 8             The Karakaj Technical School was guarded by the Karakaj Company.

 9     A few days later, Mr. Panic heard that the men from the Technical School

10     were being executed at Gero's slaughterhouse.

11             The police official who ran the reserve police station in Celopek

12     reported to Mr. Panic that Muslims from Divic who were detained at the

13     Celopek Dom Kulture were being killed and abused by a group led by Repic.

14     Detention facilities in Zvornik including the Ekonomija farm, Ciglana and

15     Celopek Dom Kulture were guarded by the Zvornik police.

16             That completes the summary, Your Honour.

17             If I can call up 65 ter number 00669, page 1 in the B/C/S and

18     page 3 in the English, please.

19        Q.   While this document is coming on to the screen, Mr. Panic, in

20     your previous testimony, and this is at T-2872 for the Court's reference,

21     you have named the Crisis Staff members of the Zvornik Crisis Staff.  I'm

22     not asking you to name them, but -- at this point but were these members

23     generally associated with a particular political party?

24        A.   Yes.  At that time, as far as the Serbian people were concerned,

25     there was only the Serbian Democratic Party.

Page 19127

 1        Q.   Looking at the document on the screen, were you aware of the

 2     establishment of an interim government in Zvornik?

 3        A.   I heard of that.

 4        Q.   And did many members also belong to the SDS?

 5        A.   Yes.

 6        Q.   If I can go to page 2 in the B/C/S and page 5 in the English,

 7     please?  What I'm referring you to, Mr. Panic, is the order on general

 8     mobilisation and my question is:  Did this mobilisation take place?

 9        A.   Yes.

10        Q.   What measures were taken to implement the mobilisation order?

11        A.   People who did not respond to the mobilisation call-up were taken

12     into custody by the military and the civilian police.  And sometimes even

13     the paramilitaries brought them in by force.  So Pivarski and Niski went

14     around the village and detained people.

15             MR. KARADZIC: [Interpretation] May I just correct the transcript?

16     I think the witness said something like, "They took people off."  What

17     does that mean?

18             THE WITNESS: [Interpretation] They stripped people, walked them

19     around villages, and then they took them to detention facilities.

20             MS. ELLIOTT:  Thank you.  May this be admitted?

21             JUDGE KWON:  Yes.

22             THE REGISTRAR:  Exhibit P3381, Your Honours.

23             MS. ELLIOTT:  I'd ask that we go to Sanction, please.  And I'm

24     going to ask that Exhibit P2002 be played, without the sound.

25                           [Video-clip played]

Page 19128


 2             MS. ELLIOTT:  If we can pause, this is not the correct exhibit.

 3                           [Video-clip played]

 4             MS. ELLIOTT:

 5        Q.   Yes, we just paused it at 11 seconds in the exhibit.  Mr. Panic,

 6     do you recognise this location?

 7        A.   This is a hamlet called Hrid in Zvornik, below Jedrinje.  On the

 8     other side of the river is Mali Zvornik.

 9             JUDGE KWON:  We are at .000516.6.  Not 11 seconds.  If you could

10     confirm that.

11             MS. ELLIOTT:  Yes.  This is a clip from a larger video so I think

12     it's both but I can use that designation.

13             JUDGE KWON:  Yes.

14             THE INTERPRETER:  Interpreter's correction:  After the word

15     "Zvornik" in the previous answer, the witness said, "Below is the Drina

16     River."

17             MS. ELLIOTT:  If we can carry on playing the clip.

18                           [Video-clip played]

19             MS. ELLIOTT:

20        Q.   Mr. Panic, do you recognise any of these individuals?

21        A.   I think the man in the sheepskin coat, stout, is Milan Radovic,

22     who used to work in the public utilities company.  He drove a truck and

23     collected dead bodies.

24             MS. ELLIOTT:  For the record, I've stopped at 531.8.

25             If we could carry on playing the video, please?

Page 19129

 1                           [Video-clip played]

 2             MS. ELLIOTT:

 3        Q.   Mr. Panic, do you recognise this building?

 4        A.   This is the SUP building in Zvornik.

 5        Q.   How about this -- the person that's in this picture?  Are you

 6     able to tell us anything about this person?

 7        A.   Judging by the uniform, it's one of Arkan's men, and if you look

 8     at his back, he might even be Arkan himself.

 9        Q.   And do you have any idea of what's happening here, what's being

10     shown?

11        A.   Arkan's unit went to Zvornik first with the others, and they took

12     control of the SUP building and they were hoisting the flag probably to

13     celebrate liberation.  I don't know.

14             MS. ELLIOTT:  I'm done with this.  Oh, for the record I've paused

15     it here at five minutes 43.4 and I'm done with the video at the moment.

16             JUDGE KWON:  What is this clip part of?

17             MS. ELLIOTT:  This is a clip that was footage taken by

18     Mr. [Indiscernible] that was introduced through Martin Bell.

19             JUDGE KWON:  The first part we saw was Sarajevo?

20             MS. ELLIOTT:  No, Your Honour, I believe from when we started

21     playing the correct clip the first part where we saw the --

22             JUDGE KWON:  No, I meant the incorrect part.

23             MS. ELLIOTT:  Yes.  I don't know what the incorrect part was.

24     But the video we have just played is Exhibit P2002.

25             JUDGE KWON:  So that's part of video that has already been

Page 19130

 1     admitted?

 2             MS. ELLIOTT:  Yes.

 3             JUDGE KWON:  Thank you.

 4             MS. ELLIOTT:

 5        Q.   Mr. Panic, just following up on Arkan, do you have any

 6     information as to how he came to be involved in the -- what you described

 7     as the liberation of Zvornik?

 8        A.   His unit came earlier, and it was put up in the spa called

 9     Radaljska Banja in the environs of Zvornik and I heard later that Dragan

10     Spasojevic talked around that 300.000 Deutschmark had been paid for the

11     arrival of that unit, so he came with his unit and stayed at

12     Radaljska Banja and during the attack on Zvornik itself on 8 or 9 April,

13     the unit was led by a man called Pejo because Arkan himself was not there

14     at the time.  He came later.

15        Q.   And Arkan, and Arkan's men, what sort of reputation did they have

16     at the time, to your knowledge?

17        A.   He had the reputation of a bad-tempered man.  His name alone put

18     the fear of God in everyone.  He had been involved in the war in Croatia,

19     in all the disorders and unrests at football matches and elsewhere.

20        Q.   What about the other paramilitary groups operating in Zvornik?

21     Do you have any information about whether they were invited or supported

22     by the Serbian authorities?

23        A.   Well, whether they were invited or not, I wouldn't know, but I

24     know that Gogic's men were called to come again in May, and they put on

25     police uniforms.  In the beginning, they were paid by the municipality.

Page 19131

 1     Later on by the police.  Whereas Zuca's men were paid by the

 2     municipality.  But I don't know who was invited or not.

 3        Q.   If I could call up 65 ter number 00635?  Mr. Panic, looking at

 4     the document on the screen before you, what formation does this document

 5     relate to?

 6        A.   This is Gogic's unit, but it was called in even before the

 7     conflict started, and you can see from this paper that the municipality

 8     paid them.  More precisely, the national defence staff.  However, in May,

 9     they were paid by the police station in Zvornik.

10             MS. ELLIOTT:  May this document be admitted, please.

11             JUDGE KWON:  Yes.

12             THE REGISTRAR:  Exhibit P3382, Your Honours.

13             MS. ELLIOTT:  May I have 65 ter number 07693 and page 2 in the

14     B/C/S, page 2 also in the English.

15        Q.   Mr. Panic, are you familiar with this unit, and can you recognise

16     any of the signatures on the document?

17        A.   This is a reconnaissance unit led by Zoran Alexic originally from

18     Brasina in Zvornik municipality.  And below in handwriting, it says, "To

19     accounts, pay out 100.000, approved by the commander."

20             And somebody's signature.  Brano Grujic, I think.

21             MS. ELLIOTT:  May this document be admitted, please?

22             JUDGE KWON:  In its entirety, I take it there is no objection.

23     It will be admitted.

24             THE REGISTRAR:  Exhibit P3383, Your Honours.

25             MS. ELLIOTT:  May I please have 65 ter 15660 on the screen?

Page 19132

 1        Q.   Mr. Panic, were you aware that this group was in Zvornik and

 2     receiving support by the Serbian municipality?

 3        A.   I heard that White Eagles had been put up in Snagovo village

 4     which is in Zvornik municipality too but I didn't know about this

 5     certificate.

 6             MS. ELLIOTT:  May this document be admitted?

 7             MR. ROBINSON:  I don't think based on what the witness just said,

 8     I don't think that's a sufficient foundation.

 9             JUDGE KWON:  Can you recognise Mr. Grujic's signature?

10     Mr. Panic?

11             THE WITNESS: [Interpretation] It's typewritten, Branko Grujic but

12     somebody else signed for him, as far as I can make out, it's Lazarevic.

13             JUDGE KWON:  And you know who he is?

14             THE WITNESS: [Interpretation] I don't know which Lazarevic it is.

15                           [Trial Chamber confers]

16             JUDGE KWON:  You will have another opportunity to tender this,

17     Ms. Elliott.

18             MS. ELLIOTT:  May I please call up 65 ter 13934?

19        Q.   And while this document is coming up on the screen, Mr. Panic,

20     I just want to ask you a clarification from your testimony, your prior

21     testimony.  And in that testimony you described a man from Seselj's unit

22     beating a police colleague of yours because you and your colleagues were

23     wearing your JNA caps with the five-pointed star.  So my question has two

24     parts:  Did paramilitary units wear the JNA cap?  And if not, what was

25     their issue with it, to the best of your knowledge?

Page 19133

 1        A.   Paramilitary units did not wear the five-pointed star.  In the

 2     former state of Yugoslavia, the five-pointed star was worn by the regular

 3     army and the police.  Paramilitaries didn't.  They had emblems depicting

 4     the eagle, the Serbian eagle, that we put on caps, and when we took them

 5     off later and replaced them again with the five-pointed star, he was so

 6     bitter about it he wanted to beat up a colleague with his truncheon

 7     because he had put on again the five-pointed star.

 8        Q.   Turning your attention to the document before you on the screen,

 9     which is an Eastern Bosnia Corps report on the problems of

10     Captain Dragan's training centre dated 7 June 1992, are you able to

11     comment, Mr. Panic, comment on the issues surrounding the establishment

12     of Captain Dragan's training centre in Divic?

13        A.   Captain Dragan came sometime around the end of May.  He arrived

14     in Zvornik then.  That was 1992.  As for this decision, I did not know

15     about that before, but I heard then that he wanted to establish a centre

16     at the Vidikovac hotel in Divic but the municipal authorities did not

17     agree and did not consent.  But I heard that the army agreed to that and

18     he opened it for a month or two.  There was training up there in Divic.

19             MS. ELLIOTT:  May this document be admitted, please?

20             MR. ROBINSON:  Again, Mr. President, I don't think that this

21     document other than the witness's knowledge of Captain Dragan and where

22     he was operating has been sufficiently confirmed by the witness and

23     I point your attention, call your attention in the document to the part,

24     portion, which states that Captain Dragan stated that he has the support

25     of the president of the Presidency, Mr. Radovan Karadzic, and other

Page 19134

 1     ministers in the government of the Serb Republic of Bosnia-Herzegovina

 2     and we don't think that a document with this assertion ought to be

 3     admitted for all purposes when the witness can only say that

 4     Captain Dragan had a centre at a certain location.

 5             JUDGE KWON:  Would you like to respond, Ms. Elliott?

 6             MS. ELLIOTT:  Well, I think the witness confirmed more than the

 7     mere existence of the centre.  He confirmed that the centre was set up,

 8     that it was set up against the wishes of the municipal authorities, and

 9     I think there is sufficient connection to this document.  In respect of

10     the reference to Mr. Karadzic, we are about to see another document which

11     is already in evidence that contains similar information.  So I don't

12     think that should be a barrier to admitting the document.

13                           [Trial Chamber confers]

14             JUDGE KWON:  I think the Chamber has a basis to admit this, in

15     light of the witness's confirmation of the existence of the training

16     centre as well as the -- its relation with the Eastern Bosnia Corps, but

17     with respect to that passage in question, the Chamber will emphasise that

18     it will give no weight in the absence of any corroborating evidence at

19     the moment.  On that basis this will be admitted.

20             THE REGISTRAR:  As Exhibit P3384, Your Honours.

21             MS. ELLIOTT:  If I can call up Exhibit P1478, and this is a

22     portion of the Mladic notebooks so I'd like the B/C/S transcript, not the

23     handwritten notebook, but the B/C/S transcript, e-court page 268 and

24     English page 270.

25        Q.   Mr. Panic, what's going to come up on the screen is 30 June 1992

Page 19135

 1     entry that we looked at a few days ago, and while we are on the subject

 2     of the training centre, I'm going to direct your attention to remarks

 3     attributed to Mr. Karadzic, and then I'll go back to the beginning of

 4     that entry.  So again, the e-court page is 268 in B/C/S and 270 in

 5     English.  And I'm directing your attention to the comments of

 6     Mr. Karadzic to the effect that it would be a shame to abolish the

 7     centre.  My question for you, Mr. Panic, is did Captain Dragan continue

 8     to operate the training centre after this time, which is 30 June 1992,

 9     and if so, do you know until when?

10        A.   I don't know until when he had that centre, but I see here that a

11     person called Crni is mentioned.  He came from Teslic, and was attached

12     to the police station at Zvornik and later on he went to Captain Dragan

13     to Divic.  I don't know exactly at what time the centre was closed.

14        Q.   Do you know whether it was operating after 30 June 1992?

15        A.   No.  I've already said I don't know the date until which it

16     operated.

17        Q.   Not the exact date, sir, but do you have any indication of the

18     time period until which it operated, approximately?

19        A.   I seem to remember that Captain Dragan stayed for about two

20     months, two and a half months.  He came at the end of May after

21     Slavko Eric was killed.  I think that he worked some more but I don't

22     know until when.

23        Q.   Thank you.  If we can go to B/C/S page 244, English page 246.

24     Mr. Panic, do you recognise the names of any of the participants at this

25     meeting?

Page 19136

 1        A.   Number 13, Jovo Mijatovic.  Number 14, Radosav Peric.

 2        Q.   And what were their functions within Zvornik?

 3        A.   Jovo Mijatovic was an MP.  He worked in Glinica before the war.

 4     Radosav Peric was the principal of the school and later on he was Prime

 5     Minister in Zvornik, at the beginning of the war.  And Vasilic, Slobodan,

 6     he was deputy commander of the brigade in Zvornik.

 7        Q.   If we could go over to the next page in both languages, please?

 8     Under the number 18, there are some more names listed.  Do you recognise

 9     any of these individuals?

10        A.   Marko Pavlovic.  That's how he introduced himself there.  He was

11     commander of the staff of the Territorial Defence.  However, later on,

12     after he was tried as well as the group from Zvornik, that that is not

13     his name; Gordan Jovanovic, a lawyer from Zvornik, he worked in the

14     municipality previously; Tomasevic, Slavoljub, he worked in Glinica; then

15     Grujic, Branko, that's the president of the municipality and president of

16     the party; then Dragan Jokic is a military man, now, was he a captain or

17     something.  That is probably the composition of the staff of the

18     Territorial Defence because it says chief up here by the name of

19     Marko Pavlovic.

20        Q.   Can I go to B/C/S page 247, English page 249, please?  I think we

21     have English on both of them.  If I could have the B/C/S page 249,

22     please?  Sorry, that's not the correct B/C/S page, sorry.  It should be

23     247.  My apologies.  Yes, thank you.  I'm directing your attention,

24     Mr. Panic to where we have Mr. Grujic, this is at point number 4,

25     reporting about the successful implementation of the president's

Page 19137

 1     decision, and my first question is:  What happened to the inhabitants of

 2     Divic and Kozluk?

 3        A.   Most of the inhabitants were relocated.  Olovsko -- Municipality

 4     of Olovo was the place where the people of Divic were taken and

 5     Gornji Sepak, Subotica, Serbia and then Hungary.

 6        Q.   What about the inhabitants of Kozluk?

 7        A.   I've already said the inhabitants of Kozluk were taken to Serbia.

 8     They stayed in Subotica, that's what I heard and then went to Hungary.

 9        Q.   And the inhabitants of Divic and Kozluk, were these Muslims?

10        A.   These places are primarily inhabited by Muslims.

11        Q.   And after the Muslims were relocated, were -- who settled in

12     Divic and Kozluk?

13        A.   Persons of Serb ethnicity who had fled from their homes in

14     Vogosca, Zenica and elsewhere.

15        Q.   If I can go to B/C/S page 249, and English page 251?  I'm just

16     showing you this page, Mr. Panic, to show you that we have Marko Pavlovic

17     speaking and you've already told us about him.  So now if I can go to

18     B/C/S page 251, English page 253 for a continuation of his comments?  And

19     I'm directing your attention to the bottom of this page, where

20     Mr. Pavlovic is reporting:

21             [As read] "We were most active in evicting the Muslims.  We

22     had" -- and I'll ask that we go to the next page in both languages,

23     please.

24             And continuing on:

25             [As read] "We had brought peace to Sepak, Divic and Kozluk.  Some

Page 19138

 1     of them wanted to move out, while we demanded it.  We had to evict some

 2     of the people also for the sake of our heroes who fled from Kovacevici."

 3             My first question is you've told us about Divic and Kozluk.  What

 4     happened to the inhabitants of Sepak?

 5        A.   There are three Sepaks:  Donji, Gornji, and Srednji.  Gornji and

 6     part of Srednji were mostly inhabited by Muslims and they moved to Serbia

 7     and I don't know where they went after that.

 8             MR. KARADZIC: [Interpretation] I wonder whether the translation

 9     is correct here "evict."  "[In English] We had to evict some of the

10     people."

11             JUDGE KWON:  Can we see the previous page?  I didn't find the

12     passage myself.

13             MS. ELLIOTT:  It's at the very bottom of the previous page.

14             JUDGE KWON:  It's not in the bottom part.  It's up a bit.  That's

15     right.

16             MS. ELLIOTT:  The reference to evict is, yes, the last star

17     point.

18             MR. KARADZIC: [Interpretation] That's an incorrect translation

19     too.  English cannot be justified by English.

20             JUDGE KWON:  No.  That's the -- that's something that should be

21     taken up on a separate moment, but not at the moment.  Let's continue,

22     Ms. Elliott.

23             MS. ELLIOTT:

24        Q.   My next question, Mr. Panic, is are you able to comment on the

25     reference Mr. Pavlovic made to the "heroes" from Kovacevici?  Do you know

Page 19139

 1     what he would be referring to there?

 2        A.   Well, he probably meant persons of Serb ethnicity who had fled

 3     from the Muslims in Kovacevici, and then the -- they would move into

 4     those areas because Kovacevici was a predominantly Muslim village.

 5        Q.   If I can call up 65 ter 17273, please?  And while this document

 6     is coming up on the screen, Mr. Panic, can you provide an estimate as to

 7     when the process of moving out the Muslims from the

 8     Serbian Municipality of Zvornik was completed?

 9        A.   Well, I cannot tell you the date, but it was right in the

10     beginning, and then ended towards the end of June.  I cannot give you the

11     exact date.

12        Q.   Looking at the document before you, were you aware of abandoned

13     property being seized by the temporary government in Zvornik?

14        A.   Yes.  The property of ethnic Muslims who had moved out was

15     distributed to persons who were ethnic Serbs and who had moved in from

16     other areas.  This was done by a commission.

17        Q.   The document before us on the screen isn't the correct page.  Is

18     this page 1 of the B/C/S and the English?  And this is 17273?  Yes, so

19     instead of the right-hand side, I'll need the -- sorry, the right-hand

20     side of the document enlarged.  Yes, and on the basis of the witness's

21     evidence, I'd ask that this document be marked as the next exhibit?

22             JUDGE KWON:  Yes.

23             THE REGISTRAR:  As Exhibit P3385, Your Honours.

24             MS. ELLIOTT:  If I can call up P03187, P3187, please?

25        Q.   And while this is coming up on the screen, Mr. Panic, this is a

Page 19140

 1     map that you looked at in a larger print form when we met, and I'm

 2     turning now to a different subject, which is the detention facilities

 3     that you describe in your prior testimony.

 4             Mr. Panic, does this map with the photographs accurately depict

 5     those facilities, the facilities described there?

 6        A.   Yes.  Except that there is Novi Izvor Ciglana here and then there

 7     was also the administration building and the misdemeanours court, in

 8     addition to all of this.

 9        Q.   Just to clarify, what you refer to as the Ciglana is also what's

10     recorded here as the Novi Izvor company; is that correct?

11        A.   Novi Izvor Ciglana is a factory where bricks are manufactured and

12     tiles.  Novi Izvor is a company, this is in Karakaj, but their main

13     administration building was in Zvornik.

14        Q.   What you refer to as the Ciglana, do you see a picture of that on

15     this map?  Can you see a picture of the Ciglana?

16        A.   Yes, yes.  The first photograph, up here.

17        Q.   Perhaps we could zoom in on what's the -- the photograph depicts

18     that depicts what's called there the Novi Izvor company.  It's got -- is

19     this the photograph you're referring to?  It bears the number 00406537.

20        A.   Yes.  That is Ciglana, Novi Izvor.  It is a factory that

21     manufactures bricks and tiles so that is not their administration

22     building.  This is the actual factory.

23        Q.   So the administration building that you refer to, and also

24     misdemeanour court, that's a separate facility that's not shown on this

25     map; is that correct?

Page 19141

 1        A.   That's a separate facility that is in Zvornik.  It was secured by

 2     the police, whereas at the factory, Ciglana, the police did not secure

 3     that.  This camp was founded by a paramilitary unit and later on it was

 4     abolished.  But the police did secure the administration building in

 5     Zvornik.

 6        Q.   Thank you.  If I can call up 65 ter 14642, please?  Mr. Panic,

 7     were you aware that there was TO command at Ekonomija at the time of this

 8     document?

 9        A.   I know that for a while the Territorial Defence -- a unit of it,

10     not the command -- headed by Miladin Mijatovic who was a reserve captain

11     of the army, was stationed there.

12             MS. ELLIOTT:  May this document be admitted, please?

13             JUDGE KWON:  Yes.

14             MR. ROBINSON:  Excuse me, Mr. President.

15             JUDGE KWON:  Yes, Mr. Robinson?

16             MR. ROBINSON:  I really question whether this witness has given a

17     sufficient basis for admission of this document, simply on the fact that

18     the unit -- a unit was located at a certain place.

19                           [Trial Chamber confers]

20             JUDGE KWON:  The Chamber is of the view, on the basis of the

21     witness's evidence, we can admit this unless you challenge the

22     authenticity of this document.

23             MR. ROBINSON:  Well, we note that the people who received it

24     haven't -- there is no signatures of the people that received it so it

25     may not be a complete document but we don't challenge the authenticity of

Page 19142

 1     this document per se.

 2             JUDGE KWON:  We will give it a number.

 3             THE REGISTRAR:  Exhibit P3386, Your Honours.

 4             MS. ELLIOTT:

 5        Q.   Now turning, Mr. Panic, to a couple of questions about the

 6     Karakaj Technical School, in your prior testimony you talked about the

 7     execution of men from the school at the slaughterhouse.  How did you hear

 8     about that?  Where did you get that information from?

 9        A.   I heard of that in a conversation with police officer

10     Petar Tanic, who secured the commission for sanitisation, and on one

11     occasion he told me that he had to go to the slaughterhouse in order to

12     secure the bodies of the ethnic Muslims who had been held at the

13     Technical School and who had been slaughtered there but there was also

14     talk about it, there were rumours in the town itself.

15        Q.   And how about at the school itself?  Did you hear whether any

16     killings took place at the Karakaj Technical School?

17        A.   Well, it was rumoured that paramilitary units, Pivarski, Repic

18     came, went there and that they mistreated and beat the people there but

19     whether they killed them or not I really wouldn't know because I did not

20     go to the technical centre.  There were all kinds of stories, but

21     I didn't see any of it so I couldn't really say.

22        Q.   Did you ever see Milan Radovic around the

23     Karakaj Technical School around June of 1992?

24        A.   Yes.  One day as I was passing, going over the overpass in

25     Karakaj, I saw that there was a municipal truck driven by Milan Radovic

Page 19143

 1     at that time, leaving the premises, but what it was that he was

 2     transporting, I didn't see.

 3        Q.   Thank you.  I'm moving to my final topic.  In your prior

 4     testimony, you spoke of seven policemen who were sentenced in Sarajevo

 5     for these war events and the reference is T-2934.  When did this happen?

 6        A.   I think that they were sentenced last year, and that they are

 7     serving their terms.  These people had been guards at the administration

 8     building in Novi Zvornik during the war.

 9        Q.   And at the time, and by that I mean in 1992, were you involved in

10     or aware of any investigations into abuses at any of the detention

11     facilities in Zvornik?

12        A.   In the early days of the war operations, I don't think there were

13     any investigations conducted.  I just know that doctors, pathologists,

14     came to examine, to carry out examinations, but later on I know that in a

15     report that was submitted by the chief of police.

16             THE INTERPRETER:  The interpreter did not catch the name.

17        A.   I saw that there were three criminal complaints against three

18     individuals for war crimes and one criminal complaint for rape.  Now,

19     this report was drafted sometime either on 7 or 9 January 1993, and the

20     report referred to the period 1992.

21        Q.   And were you personally involved in any of these investigations?

22        A.   No.

23             MS. ELLIOTT:  Thank you.  That completes my examination.

24             JUDGE KWON:  Shall we deal with the associated exhibits you are

25     going to tender?

Page 19144

 1             MS. ELLIOTT:  Yes, Your Honour.  Now there is only seven of them.

 2     A number of them have been admitted.

 3             JUDGE KWON:  Yes.  Are there any objections?

 4             MR. ROBINSON:  No, Mr. President.

 5             JUDGE KWON:  Can you take a look at 65 ter 18479, which was

 6     referred to in transcript page 2935?  If you could explain to me how it

 7     was -- it forms an inseparable and indispensable part of this transcript?

 8             MS. ELLIOTT:  I believe the witness commented that he was

 9     familiar with the author of this document and his position as well as

10     that he was generally aware that Zuco had been released.

11             JUDGE KWON:  I think he said -- he identified the author and

12     that's it.  If you could deal with this document, if you would like to

13     tender it now.

14             MS. ELLIOTT:  Yes.  If I can call up 18479, please?

15        Q.   First of all, Mr. Witness, looking at the document before you on

16     the screen, were you aware that Zuco had been disarmed on 29 July 1992?

17        A.   Yes.  At that time, the Special Police came and not only disarmed

18     but also arrested Zuco's unit, and on the days prior to that, the 27th

19     and 28th, we managed to expel Gogic and his men across the bridge and

20     into Mali Zvornik.

21        Q.   And you mentioned that Zuco was arrested.  Do you know what

22     happened to him after his arrest?

23        A.   They were all escorted to Bijeljina.  What happened after that,

24     I really don't know.  I did see him later on.  He married a woman from

25     Celopek, and he came there so I could -- I saw him, I had occasion to see

Page 19145

 1     him.  But I don't know what happened with the trial or the prosecution.

 2        Q.   Did you know at -- or did you hear at some point in time that he

 3     had been released?

 4        A.   Yes.  He was released, because I saw him on a number of occasions

 5     later on.  He moved around our area.  And later on he was also arrested

 6     in Belgrade on a couple of occasions, and I heard that there too he would

 7     then be released.

 8             MS. ELLIOTT:  Your Honour, I'm not sure if that's sufficient.

 9             JUDGE KWON:  Yes, I think that's a sufficient basis.  Thank you,

10     Ms. Elliott.  Including that part the seven associated exhibits, all of

11     them, will be admitted and given number in due course.  Thank you,

12     Ms. Elliott.  We have some ten minutes, Mr. Karadzic.  Can you start on

13     some introductory part?  Yes, Mr. Robinson?

14             MR. ROBINSON:  Yes, Mr. President, can you leave me about two

15     minutes, if we could make an oral response to the Prosecution's motion

16     for leave to reply to a document relating to the ICMP.  Before we recess

17     if I could have about two minutes to give you an oral response to that?

18             JUDGE KWON:  Thank you.

19             Yes, Mr. Karadzic?

20             MR. KARADZIC: [Interpretation] Thank you.

21                           Cross-examination by Mr. Karadzic:

22        Q.   Good afternoon, Mr. Panic.

23        A.   Good afternoon.

24        Q.   I would like to use what little time is left to us to clarify

25     some of your words of today.  When you say that Zuco was released, does

Page 19146

 1     that mean that the proceedings against him have been -- had ended or that

 2     he was -- that he had served his sentence and left, that it was still

 3     ongoing?

 4        A.   Well, I don't really know.  He was released but whether the

 5     proceedings against him were still in effect or ongoing, I don't know.

 6        Q.   It was not properly interpreted.  It doesn't mean that the

 7     proceedings were suspended but that he was probably released from

 8     detention, but the proceedings against him, whether they were still

 9     ongoing, I don't know.  Is that what you said?

10        A.   Yes.

11             JUDGE KWON:  Mr. Panic, since both of you are speaking the same

12     language, you need to put a pause between the question and answer.

13     Please bear that in mind tomorrow.  Let's continue, Mr. Karadzic.

14             THE WITNESS: [Interpretation] I understand.

15             MR. KARADZIC: [Interpretation] Thank you.

16        Q.   We saw that video insert where the two bodies were being carried

17     out.  Would you agree with me that it would be hard to determine, based

18     on their clothes, what those two men were by ethnicity, and that the

19     woman was probably a Serb woman?

20        A.   I don't understand which two men you're referring to.  Are you

21     referring to the two men who were carrying the body or --

22        Q.   No, the two bodies.  They were carrying a body of a man, and

23     would you agree that we couldn't determine his ethnicity but would you

24     also agree that the body of the woman, judging by her clothes, the

25     clothing, it's probably a Serb woman?  And I'm referring to the bodies.

Page 19147

 1        A.   Well, I couldn't really decide on anyone's ethnicity based on

 2     their clothes.

 3        Q.   Thank you.  Did you ever hear that some part owner, some of the

 4     owners of Glinica from Serbia were concerned about their investments and

 5     this factory had an output of up to $1 million per day and that they had

 6     to do something in order to pay for the protection of Glinica?  Of

 7     Alumina?

 8        A.   Well, all I know is that Jefto Subotic, the former manager of

 9     Glinica, came to Glinica for some reason but why it was, I don't know.

10        Q.   Thank you.  Did the municipality have at their disposal 300.000

11     marks in order to pay out Arkan?

12        A.   Well, I believe that the municipality did not have those funds,

13     but where they managed to get them, I don't know.

14        Q.   Thank you.  Now, on page 67 that was shown earlier, relating to

15     Captain Dragan, it says that he helped with equipping and training.  Now,

16     would you tell us, please, up to that point in time, did -- had

17     Captain Dragan taken any part in any combat or did he only train men,

18     those men who were referred from the brigade?  Now, did he only -- was he

19     only involved in training and did you ever hear of any crime that he had

20     committed prior to that?

21        A.   Well, I know he didn't take part in the fighting.  He arrived

22     there sometime after 25 May, and from what I heard, it was in order to go

23     to Kamenica village in order to pull out the body of -- the bodies of

24     some men who were killed there.  However, he then went to Zvornik, he

25     walked about Zvornik, and I don't know.  He did establish the centre but

Page 19148

 1     I don't know that he took part in any fighting.

 2        Q.   And you don't know that he committed any crime?

 3        A.   Well, no, I don't really know.  Maybe they engaged in robberies

 4     but I'm not sure.

 5        Q.   Thank you.

 6             MR. KARADZIC: [Interpretation] Should we wrap up for the day or

 7     should I continue?  There are three minutes left.

 8             JUDGE KWON:  Yes, probably yes.

 9             Mr. Panic, we will continue tomorrow at 9.00.  Probably you have

10     been told about this, but you are not supposed to discuss with anybody

11     about your testimony.  Do you understand that, sir?

12             THE WITNESS: [Interpretation] Yes.

13             JUDGE KWON:  So you may be excused now.  Please have a nice

14     evening.

15             THE WITNESS: [Interpretation] Thank you.

16                           [The witness stands down]

17             JUDGE KWON:  Mr. Robinson, I take it we need to go into private

18     session?

19             MR. ROBINSON:  No, I think this can be heard in public session.

20             JUDGE KWON:  Very well.

21             MR. ROBINSON:  Mr. President, this morning the OTP filed a

22     request for leave to reply to the response to the Prosecution's request

23     for further orders with respect to ICMP.

24             JUDGE KWON:  On two points, I take it?

25             MR. ROBINSON:  That's correct.  And I'd like to make an oral

Page 19149

 1     response so that you could make a timely ruling on it, if that's okay.

 2     It will just take a minute.  Normally we don't object.

 3             JUDGE KWON:  Thank you.

 4             MR. ROBINSON:  Normally we don't object to requests.  We think

 5     the parties ought to be free to make whatever replies they would like but

 6     I would just note in this particular instance given that we have not

 7     really taken an objection to the relief sought by OTP, that the reply

 8     really seems more in the nature of bickering among -- about some facts

 9     that aren't particularly of assistance to the Chamber.  And so we oppose

10     the request for leave to apply and ask you to just go ahead and decide

11     the motion on what you have.  Thank you.

12             JUDGE KWON:  Yes, Mr. Tieger.

13             MR. TIEGER:  Well, obviously, once that characterisation is made

14     then any response there is going to be an attempt to shoehorn any

15     response into the category of bickering.  It's not.  Where

16     representations are made that the Prosecution believes need to be

17     clarified so that the matter can proceed, on the basis of accurate

18     information, we attempt to do so and that's all we have done here,

19     Mr. President.  We want to ensure that the record is kept straight and

20     that the Trial Chamber can make the most appropriate decision based on

21     the most accurate information.

22             JUDGE KWON:  Thank you.  We will consider the submissions.

23             Yes, Mr. Harvey?  Could you introduce your new member?

24             MR. HARVEY:  Good afternoon, Your Honours.  I apologise for not

25     introducing earlier Ms. Sarah Codde who is a pro bono legal assistant

Page 19150

 1     working with my team.  Thank you.

 2             JUDGE KWON:  Thank you.  Welcome, Ms. Codde.

 3             We will rise today and resume tomorrow morning at 9.00.

 4                           --- Whereupon the hearing adjourned at 3.00 p.m.,

 5                           to be reconvened on Tuesday, the 20th day of

 6                           September, 2011, at 9.00 a.m.