111027ED

Page 20454

1 comfortable.

2 THE WITNESS: [Interpretation] Thank you.

3 JUDGE KWON: Yes, Mr. Tieger.

4 WITNESS: MEVLUDIN SEJMENOVIC

5 [Witness answered through interpreter]

6 Examination by Mr. Tieger:

7 Q. Sir, please state your name for the record.

8 A. I'm Mevludin Sejmenovic.

9 Q. Mr. Sejmenovic, I want to ask you to confirm a few background

10 details before we get into other questions.

11 First, is it correct that you were born in the Vlasenica area but

12 raised in the Prijedor municipality, more specifically in the Trnopolje

13 area, since you were a young child?

14 A. Yes.

15 Q. You attended university in Tuzla and served in the JNA in Serbia

16 in an artillery unit; is that right?

17 A. Correct.

18 Q. And you were a founding member of the SDA Party in 1990 and were

19 elected in the 1990 elections to the republic assembly of the chamber of

20 municipalities as the Prijedor representative; is that correct?

21 A. The Prijedor representative in the council of municipalities of

22 the republic parliament.

23 Q. Thank you. And did you also attend municipal assembly meetings

24 in Prijedor and split your time between Sarajevo and Prijedor from the

25 time of the election until 1992?

Page 20455

1 A. I attended the sessions of the republic parliament without fail,

2 and I also attended the municipal assembly sessions in Prijedor when I

3 was able to, when I was in Prijedor.

4 Q. Which party won the most seats in the November 1990 elections in

5 Prijedor?

6 A. The Party for Democratic Action, the SDA, won the most seats, and

7 the second-ranking party was the Serbian Democratic Party.

8 Q. Now, I want to -- let me ask you quickly. And did the -- did the

9 members of the SDA assume leading positions in the municipality in

10 accordance with the electoral results; and did SDS members also assume

11 numbers of significant positions in Prijedor?

12 A. That's correct. Important positions were divided according to

13 electoral results and in keeping with an inter-party agreement that had

14 been made earlier.

15 Q. Mr. Sejmenovic, I'm going to be bringing your attention soon to

16 the assumption of exclusive power in the municipality by the Serbian

17 authorities at the end of April 1992, as well as the events that

18 followed. But I first wanted to ask you if you and other members of the

19 SDA were able to identify indications between the time of the election

20 and the end of April 1992 that such events were developing or imminent;

21 and, if so, if you could tell us what those were?

22 A. In chronology, there were several things that had been

23 differently interpreted by different parties, but we were also able to

24 observe some practical moves by the SDS that were contrary to the

25 inter-party agreement, that were contrary to constitutional conduct,

Page 20456

1 followed by open conflicts within the institutions of power.

2 We lived in an atmosphere where influences from the neighbouring

3 countries also affected our area, our region. The prevailing Serbian

4 policy at the time applied in identical form in neighbouring countries,

5 which also complicated the social and political situation in Bosnia and

6 Herzegovina, including our municipality.

7 Q. And when you say "neighbouring country" do you have a particular

8 neighbouring country in mind in terms of the political policy that began

9 to be applied in identical form?

10 A. First and foremost I mean Croatia where conflicts had already

11 started because Croatia had already seceded and declared its

12 independence. And then the people in one part of its territory mounted

13 an insurgency. However, the engine of that policy was located in Serbia

14 which was obvious from the propaganda instruments. Another decisive

15 factor in all these events was the Yugoslav Army, which was increasingly

16 becoming a Serb-controlled army, an army controlled by what remained of

17 Yugoslavia.

18 Q. You referred to the actions of one part of the territory of

19 Croatia taking -- declaring independence and taking -- being involved in

20 conflict with the other. Did -- in Bosnia, to what extent were you able

21 to identify similar steps within the context of the unfolding events

22 between the election and the end of April 1992?

23 A. The events that began to unfold in Bosnia and Herzegovina and

24 especially the Bosnian Krajina were a mirror image of what was going on

25 and what had already happened in the Knin Krajina. It was not just a

Page 20457

1 similarity, an analogy, but also the newly formed Serbian forces in the

2 Knin Krajina crossed over from Croatia, and their military forces entered

3 Bosnia-Herzegovina.

4 There were some Serbs from Prijedor who joined the Martic militia

5 in Croatia as volunteers, and after individual operations, they would

6 return to Prijedor and continue to live there. And you were able to see

7 them around town, in bars, wearing uniforms.

8 Q. And did you become familiar with the process of -- termed

9 "regionalisation" in the Bosnian Krajina in 1991 or 1992?

10 A. As early as 1991, the Serbian Democratic Party, the SDS, or,

11 rather, its representatives, demanded a regionalisation of

12 Bosnia-Herzegovina although that regionalisation already existed.

13 However, it did not suit their plans because their aspiration was for

14 regionalisation to be ethnic based and that was not possible either by

15 the law or by the constitution. We realised very early on that they

16 actually wanted to create Serb regions in Bosnia and Herzegovina not

17 unlike the Serb Autonomous Region in Croatia, and the events that

18 unfolded in quick succession from that point on made their intentions

19 quite clear.

20 Q. You also earlier mentioned propaganda and propaganda instruments.

21 What were you referring to by that, in the context of events developing

22 in 1991 and 1992, leading to the end of April 1992, with the assumption

23 of power by the Bosnian Serbs?

24 A. That propaganda had a certain history before the war. It had

25 gone on for a couple of years before the war, but then it intensified.

Page 20458

1 It emanated from Serbia, and its inevitable consequence and its purpose

2 was to affect the strong traditions of peaceful co-existence in our

3 country. The propaganda was based on fueling fears from new suffering.

4 However, since they did not have enough instruments in terms of

5 propaganda, they decided to take up arms, take over the TV repeaters that

6 were until then not under their control and to broadcast their own

7 programmes. That's what happened to the TV repeater at Lisina already in

8 the middle of 1991. That takeover meant the switching off of programmes

9 that were not produced in Serbia or in Banja Luka or some other Serb

10 region. From that moment on, you could not follow any other programme

11 via that transmitter. The topics they covered and the programmes they

12 broadcast was reviving memories of the Second World War, mass graves, the

13 threats to the Serbian people, the suffering of Serbs in Croatia, and, of

14 course, later, news from the war in Croatia.

15 Throughout this time, nothing positive could be heard about any

16 other ethnic community. You could only hear these programmes about

17 conspiracy against the Serb people, victory at the front line and so on.

18 This exerted additional psychological pressure on the non-Serb population

19 but it also raised fear among the non-Serb population and tensions were

20 heightened. The aim was to mobilise all of the Serb people for what had

21 obviously been planned.

22 Q. Did you begin to hear proposals for or demands for ethnic

23 separation by the SDS, either at the republic level, or the municipality

24 level, or both?

25 A. First of all, the SDS offered this at the level of the republic

Page 20459

1 when discussing it with officials from other parties. All of us in

2 Bosnia knew full well what that meant and we realised that this could not

3 be achieved and also that it was unnecessary to begin with.

4 However, our positions were not taken into account at all. The

5 SDS justified all of this in a most unconvincing way by referring to this

6 wish to have the Serb people remain within Yugoslavia. However, there

7 was something else behind all of that. A few months later, these claims

8 were made in the territory of the municipality of Prijedor and a proposal

9 was made to divide Prijedor into two municipalities, that institutions be

10 divided along ethnic lines. Of course, that could not be considered at

11 all. That was not provided for by the constitution of Bosnia-Herzegovina

12 or the law that was in force.

13 Sometime after that, we realised what had preceded all of that.

14 We realised what the proposal was when "Kozarski Vjesnik," the official

15 newspaper of Prijedor, ran an article where the SDS openly stated that

16 over 70 per cent of the territory of Prijedor was considered to be Serb

17 territory. Also, they said that the factories, the national park, the

18 forests, the stadium, the agricultural farms, all of that which was

19 jointly owned all of a sudden was considered to be Serb property only.

20 Only some very small farms were marked as Muslim and Croat. The message

21 was quite clear. That message had nothing whatsoever to do with any law

22 or the constitution itself. It was a major reason for this incredible

23 fear that was sown among the population.

24 Q. During that same period, 1991 through early 1992, did you also

25 learn anything about the arming of the Serb -- Serbian population of

Page 20460

1 Prijedor?

2 A. It's not that we only heard about that. We also had an

3 opportunity of seeing it. In our party, we received reports several

4 times. That also happened in the village that I lived in. The army used

5 helicopters to transport weapons to two locations and then they divided

6 these weapons among the Serbs, and literally in the middle of the road at

7 midday, in front of the cultural centre, they took weapons out of a truck

8 and gave these weapons to the people who were asked to come there and

9 take them. In our talks with our colleagues who were SDS officials in

10 the municipality, we brought this up, but they all denied that kind of

11 thing having happened. For example, specifically, when the helicopter

12 landed near my village, the neighbours explained this by saying that

13 purportedly a soldier from that village was in that helicopter and they

14 wanted to stop and have coffee at his house. People saw the boxes with

15 ammunition, but they denied that there were any.

16 Q. You spoke about the fears felt by the non-Serb population. In

17 the weeks immediately preceding April 29th and 30th, did the SDA or HDZ

18 or other parties propose measures to ease the fears and ease the tensions

19 to the SDS?

20 A. Several times we made proposals to the SDS. We beseeched them,

21 saying that wherever people felt threatened by another ethnic community,

22 we should establish joint patrols consisting of persons of different

23 ethnic backgrounds who would be on guard duty during the night and that

24 way there would be no reason to have any kind of fear on either side.

25 I have to point something out. In some locations, this was an

Page 20461

1 initiative that came from the population itself, that they have this

2 joint guard duty during the night so that some troops would not come from

3 elsewhere and create a problem. The SDS opposed that, and a few days

4 later, at three locations - I know that for sure - where there were these

5 joint guards, the local SDS ordered that the Serbs withdraw from these

6 joint patrols. We know that for sure because in the village where I

7 lived, we had talks to that effect. We asked people to stay, but the man

8 said very openly, We have received our orders to withdraw, and our order

9 was that everyone should guard his own house.

10 From that moment onwards, we lost yet another hope that we would

11 manage to ease the fears and tensions in Prijedor.

12 On one occasion, we pleaded with the SDS. We said that if they

13 thought that the army was threatened along roads, that we established

14 mixed groups consisting of soldiers and locals. However, that was

15 resolutely rejected. That is to say, that any gesture that meant any

16 kind of interethnic cooperation was nipped in the bud, wherever possible.

17 Q. I wanted to ask you briefly about the nature of the parties and

18 their organisational structure.

19 With respect to the SDA first, was it a hierarchical organisation

20 where instructions from the top were passed on to lower levels and

21 obliged to be implemented?

22 A. Yes, yes. In principle, that is how all parties functioned in

23 Bosnia-Herzegovina.

24 That is what I can assert, as far as the SDA is concerned. The

25 top of the party is the president. Then there was an Executive Board of

Page 20462

1 the party. There was a Main Board. All of that was at the level of the

2 state. And then at lower levels there were party centres. That is to

3 say, there were regional committees headed by a president, and at

4 municipal level there were Municipal Boards headed by their respective

5 presidents. That was the hierarchy.

6 All important decisions were made from top to bottom. They were

7 carried out at lower levels. Initiatives could be launched from the

8 grass roots, but decisions were made at top level and then take further

9 down. Only decisions of local importance, not of republican importance,

10 could be made at local level. However, the top leadership of the party

11 needed to approve that as well.

12 Other parties, as far as I know, functioned in accordance with

13 the same principle. However, their main or executive bodies sometimes

14 had a different name. Some parties had a Presidency, others had an

15 Executive Board. They all had a Main Board. Most of them had regional

16 boards. And they all had Municipal Boards, if they had their party

17 organised at municipal level as well.

18 Q. You say that other parties, as far as you know, functioned in

19 accordance with the same principle. Specifically with respect to the

20 SDS --

21 A. I'm sorry, I have a problem with the volume.

22 JUDGE KWON: Very well. Please wait until our usher can assist

23 you.

24 Let us see how the usher can assist you. Is the volume too loud?

25 THE WITNESS: [Interpretation] Now it's fine. Now it's fine.

Page 20463

1 JUDGE KWON: Thank you.

2 Yes, let us proceed, Mr. Tieger.

3 MR. TIEGER: Thank you.

4 Q. I was about to ask the following, Mr. Sejmenovic.

5 You said that other parties, as far as you knew, functioned in

6 accordance with the same principle. I wanted to ask you specifically

7 with respect to the SDS, was that understanding based on your dealings

8 with local and republic SDS officials and your observations of their

9 interactions and their policies?

10 A. Of course. The SDS, like other parties, had a president, a

11 Main Board. And now did they have a Presidency? Were these main people

12 around the president called the Presidency or something else but they did

13 exist at any rate.

14 So basically it was a Presidency. They certainly had a

15 Main Board. At local level, they had a president. They had Municipal

16 Boards and so on.

17 Q. And, more specifically, were you able to determine whether

18 policies and instructions emanated at the top and were issued to the

19 lower levels and expected to be implemented?

20 A. Of course.

21 THE ACCUSED: [Interpretation] Objection.

22 JUDGE KWON: Just a second.

23 THE ACCUSED: [Interpretation] Objection.

24 JUDGE KWON: Yes, what is it, Mr. Karadzic?

25 THE ACCUSED: [Interpretation] This is a leading question.

Page 20464

1 MR. TIEGER: It is not a leading question, Mr. President.

2 JUDGE KWON: No.

3 MR. TIEGER: Thank you.

4 Q. And with -- specifically, Mr. Sejmenovic, with respect to --

5 JUDGE KWON: But did we have the answer to the previous question?

6 MR. TIEGER: I heard the answer. I didn't look at the transcript

7 actually.

8 Yes. The transcript indicates the witness answering, of course,

9 and then the objection, the comment, objection by Mr. Karadzic is

10 attributed to the witness.

11 JUDGE KWON: Thank you.

12 MR. TIEGER:

13 Q. And, Mr. Sejmenovic, with respect to the positions on ethnic

14 separation, did you see any difference in the position taken at the

15 republic level of the SDS and the position taken at the municipal level?

16 A. There was no difference. However, in terms of practical

17 behaviour, in Prijedor, this ethnic division went more slowly than

18 requested by the top echelons of the SDS. I heard about that from

19 Srdja Srdic who was a member of parliament from the SDS.

20 Q. Now, Mr. Sejmenovic, I indicated I wanted to take you to the

21 events of April 29th and 30th and ask you about that.

22 When did you become aware of -- first of all, can you tell us

23 what happened on April 29th or April 30th and how you became aware of it,

24 in Prijedor?

25 THE ACCUSED: [Interpretation] May I just intervene on the

Page 20465

1 transcript. The witness did not say that Srdja Srdic was a member of a

2 paramilitary. He said that he was a member of parliament.

3 THE WITNESS: [Interpretation] Yes, a member of parliament.

4 THE INTERPRETER: Interpreter's note: That is exactly what we

5 said.

6 JUDGE KWON: Yes. It is reflected as a member of parliament.

7 THE ACCUSED: [Interpretation] Up until my objection it said

8 "paramilitary."

9 JUDGE KWON: There's a magic -- let's continue, Mr. Tieger.

10 MR. TIEGER: Thank you, Mr. President.

11 Q. Mr. Sejmenovic, I had asked you if you to tell the Court what

12 happened on April 29th and 30th in Prijedor.

13 A. Until the 20th of April, including the 29th of April, we were

14 involved in talks with the SDS, and we tried to establish cooperation at

15 any level or in any way, with a view to convincing the SDS that we did

16 not have any hidden intentions whatsoever. What surprised us a day or

17 two before that was something very serious.

18 In "Kozarski Vjesnik," a long article appeared where it said that

19 Serbs in Prijedor were about to be massacred. That that was being

20 prepared. People asked for an explanation. Why was the atmosphere being

21 poisoned to that extent? There is no reason whatsoever. However,

22 something else happened during the night.

23 Between 1.00 a.m. and 5.00 a.m., the entire town was taken by

24 military means. By weapons, I mean. All institutions, all vital

25 facilities, patrols, sniper nests, machine-gun nests, sandbags, ramps,

Page 20466

1 check-points, throughout the municipality around Prijedor in several

2 different locations. It was amazing that all of that was done within

3 those four or five hours. The population was totally unaware of what was

4 going on. In the morning when people went to town, when they were

5 leaving their homes, as they were going to work, they saw soldiers and

6 policemen all over the place and they saw them behind sandbags, with

7 rifles pointed at them.

8 That morning, unaware what was going on, I had set out to

9 Prijedor. After take -- I mean, I took the bus. And after having been

10 on the bus for about 2 kilometres, soldiers stopped the bus and checked

11 the IDs of all who were on that bus. And only then I saw the sandbags

12 and the patrols and check-points. It was quite clear to me that

13 something extraordinary had happened. However, what had actually

14 happened, I found out only when I arrived Prijedor.

15 Q. And just to clarify, Mr. Sejmenovic, when you speak about

16 soldiers and policemen with rifles and behind sandbags, are you speaking

17 about soldiers and policemen of a particular ethnicity and associated

18 with any particular group?

19 A. That was all the Serbian army and Serbian policemen. Prijedor is

20 a small town, and other people, the non-Serbs who were very confused by

21 these events and who came to the party to ask for information, knew most

22 of these men. And I also met some of my colleagues who were now carrying

23 rifles in some places. They were checking people's IDs. I even tried to

24 ask one of them what that was all about. Dragan, what is this? What is

25 happening? He didn't want to tell me anything.

Page 20467

1 Q. Now, I want to ask you what happened in the aftermath of this

2 takeover by the Serbian authorities to the non-Serb population.

3 So, first of all, let me ask you, let me focus on official

4 institutions. Can you tell the Court what the impact was on non-Serb

5 officials in Prijedor, including -- go ahead.

6 A. In the morning hours of that day, the new authorities which had

7 taken over power began broadcasting messages over the radio and they made

8 clear what was happening. What was happening on the ground was this:

9 The non-Serbs who were going to work that morning were sent back from the

10 gates of their factories or institutions where they were employed. No

11 non-Serb could enter the municipal building. They were all sent back,

12 including the chief of the municipality.

13 As for the payment operation service, nobody could enter it as

14 well. No one could enter the banks. The non-Serbian population was

15 thrown out of most important enterprises, institutions, and organs of

16 power. No one was allowed entry. The only place where people requested

17 information about what was going on was the party, the SDA. But there

18 they could not obtain any information because the SDS did not respond to

19 the calls of the SDA officials who were calling them, asking for an

20 explanation.

21 Q. And what about the non-Serb members of the police?

22 A. Members of the police, we know that because our official who was

23 delegated by the SDA, Hasan Talundzic, who was the chief, informed us

24 that, during the night, they were disarmed. I mean, the policemen who

25 were non-Serbs. They were sent back from the entrance or they were

Page 20468

1 thrown out of the police station if they happened to have been there.

2 Some of them were promised that they would still be employed if they

3 signed a declaration of loyalty. He also informed us that a man tried to

4 sign this statement of loyalty but he was not allowed to do that. Four

5 or five days later we also received information that one inspector had

6 signed this statement of loyalty but he was dismissed from his position

7 anyway.

8 After a few days, non-Serb teachers were also dismissed from

9 schools, most of them. On the first day, movement outside the territory

10 of Prijedor municipality was prohibited, and a few days later, moving

11 towards the town of Prijedor from the non-Serb populated areas was also

12 prohibited. What followed later on were power cuts and telephone lines

13 were also cut in the non-Serb populated areas.

14 Simultaneously, with the -- these steps taken by the new

15 authorities, there were propaganda statements which were broadcast and

16 which talked about arming, the threats against Serbs, about the

17 Green Berets which reported they intended to take over power in Prijedor

18 and this was broadcast for days. And at the same time, on many occasions

19 one could hear the sentence that without a single shot they had managed

20 to take over the power. How, if there had been these thousands of

21 Green Berets? However, at the time, the propaganda was actually

22 necessary for the Serbian population so that they could more easily face

23 the events that would follow a few days later.

24 MR. TIEGER: If can I quickly call up 65 ter 05445.

25 Q. Mr. Sejmenovic, this is a document dated 11 May 1992 from the

Page 20469

1 Autonomous Region of Krajina Crisis Staff to the president of the

2 municipality generally.

3 If I could ask you quickly to look at the second provision in

4 item 4.

5 A. Yes. Can you zoom in a little bit, please.

6 Q. Is that sufficient or can we -- perhaps we can zoom in a bit

7 more.

8 Which indicates that:

9 "Only person who are absolutely loyal to the Serbian Republic of

10 Bosnia and Herzegovina can be placed in the management positions in

11 enterprises."

12 I wanted to ask you if that was consistent with what happened in

13 Prijedor with respect to dismissals of non-Serbs from management

14 positions. And, if you can tell us, any other positions.

15 A. Of course, of course. This is precisely how the situation in

16 Prijedor developed. In accordance with the positions which are

17 formulated in this document.

18 MR. TIEGER: I tender this document, Mr. President.

19 THE WITNESS: [Interpretation] Please allow me to say that it was

20 not just those who were in management positions but even labourers were

21 sent away from factories sometime after this. I mean, labourers who were

22 non-Serbs by ethnicity.

23 JUDGE KWON: Admitted.

24 THE REGISTRAR: As Exhibit P3694, Your Honours.

25 MR. TIEGER:

Page 20470

1 Q. Mr. Sejmenovic, you spoke about the events that followed the

2 takeover. These increasing steps against the non-Serb population. The

3 allegations of threats against the Serbs and so on. Did the SDA and

4 officials, non-Serb officials in Prijedor, attempt to meet with the SDS

5 in an effort to address these restrictions and these allegations and

6 somehow ameliorate the situation?

7 A. There were many attempts on the first two or three days. No one

8 from the SDS did not want to respond to a call from anyone from the SDA.

9 After two or three days, supposedly not as representatives of the

10 party but privately some people would meet with others but that yielded

11 no results. We kept asking and begging and we managed to beg from

12 Mr. Miskovic, who was the president of the SDS, to meet with us and to

13 try to find a solution for the situation that had arisen.

14 Q. And where did you meet?

15 A. We met in the premises of the SDS in Prijedor.

16 Q. And you don't have to identify everyone, but who came on behalf

17 of the SDA or HDZ or the non-Serb representatives?

18 A. Several officials of SDA came. We also expected that the

19 president of the SDS would be there, as well as some of the top

20 officials. However, once we got there, to his room, the SDS did not want

21 to begin the meeting. The president of the SDS, Miskovic, said that the

22 commander of the 5th Kozarac Brigade, Arsic, and the commander of the

23 Prijedor garrison, Zeljaja, had to attend the meeting. Some persons were

24 present whom I had not known up until then. And there was also a man

25 called Slobodan Kuruzovic. I later saw that he was the camp warden of

Page 20471

1 Trnopolje.

2 The meeting only began when the military commanders arrived and

3 two or three other persons who accompanied them. The commanders then

4 introduced them as security officers.

5 We hoped that these talks would be fruitful. We had a wish and a

6 mild hope that perhaps we might reach some sort of an agreement. On the

7 other hand, though, it all turned into a game. They first joked. Then

8 they began very serious talks. They accused us of wanting to have war in

9 Prijedor. And in the end, they gave us an ultimatum, to which we could

10 not respond. We could not do what they asked us to do and they knew that

11 it was impossible for us to do so.

12 Q. One quick question: You mentioned Slobodan Kuruzovic. Was he an

13 SDS member?

14 A. Yes, yes. He was one of the officials but I don't know precisely

15 what position he held.

16 Q. And you mentioned that Arsic was the commander of the

17 5th Kozarac Brigade, and Zeljaja, the commander of the Prijedor garrison.

18 Just to clarify, did you understand them to be members of the JNA?

19 A. Of course. Certainly. The Prijedor garrison existed earlier.

20 And the 5th Kozara Brigade, which was huge, had withdrawn its forces from

21 Croatia and stationed them in Prijedor. These forces were commanded by

22 Colonel Arsic.

23 Q. Did you and the other members of the SDA do your best to persuade

24 the SDS members and Zeljaja and Arsic, as you told us here, that you had

25 no interest in or did not desire war in Prijedor?

Page 20472

1 A. We tried everything. Everything that reason can do. However,

2 Your Honours, these were talks where, on one side, you had people with

3 rockets, guns, tanks, aircraft, and who told you that. That group

4 accused us, who had no army to oppose them at all, this group accused us

5 of wanting war. And then they accused us and set conditions which were

6 like an ultimatum, that within 48 hours, we had to surrender several

7 thousand pieces of weaponry, which we didn't have. After they told us

8 that with a short deadline we had to surrender the weapons, we tried to

9 explain. Medunjanin said, Look here, people, how can we do that when we

10 don't have it? Commander Zeljaja just said, That's your problem. If you

11 do not do that, I will raze Kozarac to the ground. He repeated twice

12 this sentence, I shall raze Kozarac to the ground. Repeated attempt to

13 convince them because we begged them on that occasion as well to come

14 with us so that we could show them, so that we could secure the roads

15 together. Nothing helped. They refused to hold any further talks.

16 Q. Did you -- were you able to tell any difference between the

17 positions taken by Arsic and Zeljaja and the SDS officials present?

18 A. Your Honours, I used the expression that they were playing with

19 us. One of the arguments which supports the position that they were

20 really playing with us were the jokes that they were making which were

21 not funny at all. But another argument was that one of the security men

22 claimed that we had 7.000 rifles in Kozarac. Another one claimed that we

23 had 11.500 in the territory of the municipality. Zeljaja said that, as

24 far as I can remember, that we needed to return 5.000 within 48 hours.

25 So not unanimous, but all the figures were far from reality.

Page 20473

1 There was just legitimate Territorial Defence in Kozarac. It was

2 very poorly armed, and there was nothing else except that.

3 Around Kozarac, there were several artillery batteries which had

4 ammunition, and they also had their barrels turned towards non-Serb

5 populated areas.

6 Q. Thank you, Mr. Sejmenovic. Just a couple of quick follow-up

7 questions, first of all, although it may be clear in context, the

8 artillery batteries to which you referred which had their barrels turned

9 towards non-Serb populated areas belonged to who?

10 A. They belonged to the Serbian forces or the Serbian army, as the

11 commanders called this army. And previously, it had been the JNA, the

12 Yugoslav People's Army. And all the materiel actually belonged to the

13 5th Kozara Brigade.

14 Q. And notwithstanding the difference in the claimed number of

15 weapons held by the Muslims, by various people at the meeting, I had

16 asked you whether Zeljaja and Arsic took different positions generally

17 with regard to the ultimatum and with regard to the attitude towards the

18 non-Serb population than the SDS or took the same positions, and I wanted

19 you to clarify that.

20 A. They took identical position. Their position was identical. And

21 as for the weapons, they knew and they had realistic assessments, and

22 their conditions, their request that such and such a number of barrels,

23 the thousands of barrels needed to be returned, that was part of their

24 intention to give them an ultimatum that we could not respond to. They

25 knew that the area was not armed in the military sense of the word.

Page 20474

1 Q. Now, in the face of this meeting and all you've described, did

2 you and other members of the SDA meet with the local non-Serb leaders of

3 Prijedor, in particular -- particularly Kozarac?

4 A. Of course. Several meetings were held and attempts at meetings,

5 because it was no longer easy to go to Prijedor. You had to take country

6 roads so as to avoid military patrols and several meetings were held in

7 Kozarac, which I attended.

8 After the meeting that we just talked about, we went back to

9 Kozarac and held a meeting there. It was attended by officials of the

10 Territorial Defence, the local communes, the local police. I was there

11 as a member of the republican assembly. And we decided to inform the

12 people about the ultimatum we had been given, and we decided to hold a

13 rally to invite the citizens to attend so that we would decide what we

14 should do.

15 Q. And before I go on to that, speaking of the non-Serb members of

16 the local TO and police, can you tell the Court how the SDS members and

17 Zeljaja and Arsic referred to the local TO members and police during that

18 meeting you described?

19 A. They called them all the Green Berets. Whatever was not the

20 Serbian army were the Green Berets for them.

21 Q. Now, at the meeting that you indicated you decided to hold, and

22 at the various meetings that were held, can you tell us what the -- the

23 gist of the efforts were and the focus was at -- at those meetings?

24 A. Most of these meetings were focussed on attempts to try and find

25 a way to cooperate with the SDS and this army and the police, regardless

Page 20475

1 of their ultimatum both at the level of the Prijedor municipality and the

2 level of Banja Luka, which was the then Krajina region which they had

3 established. We tried to find personal, private connections. Whoever

4 had any sort of contact, we tried to use it so that we could really show

5 the armed side that there was no reason for all this whatsoever.

6 However, all these attempts were fruitless.

7 At the same time we were living in great fear because everything

8 that was going on in the neighbouring towns told us that the same

9 scenario was being prepared for us, just like in Sanski Most, in

10 Bosanski Novi, and in some other towns in the interior of

11 Bosnia-Herzegovina.

12 Q. And did -- were any efforts made to put some kind of defence in

13 place?

14 A. [Microphone not activated] ... a very short time we tried to

15 expand and reinforce the Territorial Defence. We called on people to

16 place themselves at the disposal to the Territorial Defence. It was the

17 Territorial Defence which called on the people to place themselves at its

18 disposal. If they possessed any weapons, that the weapons should be

19 listed, and that some sort of structure should be established, in order

20 to prevent the population in non-Serb populated areas in Kozarac and

21 surrounding areas, from being massacred.

22 Q. Were people conscripted or obliged to make themselves available

23 to the Territorial Defence?

24 A. No, no, no. There was no conscription because there was no

25 fundamental condition. You cannot mobilise anything if you don't know

Page 20476

1 who you can mobilise. First of all, we needed to establish how many

2 people wished to place themselves at the disposal of the Territorial

3 Defence. It was completely voluntarily. We made the lists, and the list

4 did not only include non-Serbs, not just Bosniaks or Muslims. There were

5 others as well. At the Territorial Defence Staff in Kozarac, there were

6 two Serbian gentlemen. Unfortunately, a day or two before the attack,

7 they left.

8 The attempt to organise Territorial Defence, to reinforce it in

9 terms of establishment, was something that we could not finish. We did

10 not have the personnel we needed. We did not have the funds, the

11 materiel. We did not have appropriate communication means. We did not

12 have telecommunication equipment in -- that would enable us to establish

13 appropriate contacts. We did not have fuel. And those who had placed

14 themselves at the disposal of the Territorial Defence and who wished to

15 be included in these lists could not be used. Most of them. Either

16 because of their age or because they possessed no weapons whatsoever, or

17 they had something that they had made themselves or they had antiquated

18 weapons.

19 Q. What -- what sort -- first of all, how large was the existing TO

20 before this process began? And I just mean in general terms. Large or

21 small?

22 A. It was very small. I can give you approximate numbers. With a

23 population of 30.000, the TO had perhaps 50 to 100 men.

24 Q. And what kind of weaponry did the TO have before this process

25 began; and, if it didn't have much, why not?

Page 20477

1 A. It had no weapons because the year before, the Yugoslav army took

2 the weapons away from the Territorial Defence, stored it in their depots,

3 and then at the request of the republican leadership of

4 Bosnia-Herzegovina they returned only a small part of the weaponry. But

5 even the part they returned was obsolete, mainly rifles from the

6 Second World War, the so-called M48 rifles, and just a few automatic

7 rifles here and there [as interpreted], in symbolic amounts.

8 Q. Now you spoke about --

9 THE ACCUSED: [Interpretation] May I? And the witness said: "A

10 few other things here and there," which is not recorded in the

11 transcript.

12 MR. TIEGER: I see it in the transcript, but maybe we're talking

13 about something else. But I know that sometimes the transcribers have to

14 catch up or revise.

15 JUDGE KWON: Just for safety, shall we ask the witness to repeat

16 his last answer, if he could.

17 THE WITNESS: [Interpretation] I said mainly rifles from

18 World War II, M48, a few automatic weapons, and a few other things here

19 and there.

20 I can clarify in order not to leave any issues outstanding.

21 Along with those rifles, local TO units had a small number of RPGs each.

22 Those were projectiles that are screwed onto the barrel of a rifle to

23 fire grenades. I don't know of any other weapons they had. They

24 certainly had no artillery, at least no -- not in the local communes that

25 I had occasion to visit.

Page 20478

1 JUDGE KWON: Thank you.

2 MR. TIEGER: Thank you.

3 Q. Mr. Sejmenovic, you spoke about the artillery positions and about

4 the mounting fears of an attack on the non-Serb populated areas,

5 including Kozarac. Was there ultimately an attack on Kozarac by the

6 Bosnian Serb forces; and, if so, when did that occur?

7 A. On the 24th of May. There was an all-out attack on Kozarac with

8 artillery shelling from several directions using a variety of

9 projectiles.

10 Q. And before I ask you about the details of that attack, had there

11 been any shelling of non-Serb populated areas by the Bosnian Serb forces

12 before the 24th and the attack on Kozarac?

13 A. Two days before, that is to say, on the 22nd, a place called

14 Hambarine was shelled, and the purported reason for the shelling was that

15 a member of the Territorial Defence had shot at a vehicle carrying Serb

16 troops. That's what we heard on the radio.

17 Then followed an artillery attack, and that part of Hambarine was

18 burned down completely. You could easily hear the explosions and a huge

19 fire in that area. We could watch it from Trnopolje.

20 THE ACCUSED: [Interpretation] I have, for reasons of principle,

21 to object to the question by Mr. Tieger where he defines the forces of

22 the Bosnian Serbs. We have still not established what Bosnian Serb

23 forces are. At that time, it was the JNA and its reservists were killed

24 in Hambarine.

25 THE WITNESS: [Interpretation] Your Honours, at that time it was

Page 20479

1 not the JNA, because the JNA had decided a few days earlier to withdraw

2 from Bosnia and Herzegovina and withdrew. We welcomed the news because

3 it gave us a flicker of hope that, perhaps, peace would prevail there.

4 However, the JNA did not withdraw. They just changed their name. The

5 officers called themselves the Serb army, and the troop numbers increased

6 even more in the area of Prijedor several days after the federal decision

7 to pull the JNA out of Bosnia-Herzegovina.

8 MR. TIEGER:

9 Q. And I will ask you about the forces you observed in Kozarac. But

10 let me ask you as a predicate question whether you were able personally

11 to observe the attack on Kozarac?

12 A. Yes. I set out to go to Kozarac and the closest I was able to

13 come to the area that was shelled was about 400 metres. I couldn't go

14 any further because 155-millimetre Howitzers were firing into that area.

15 The explosions were horrific. I did my compulsory military service in

16 the artillery and I had one target practice using live rounds and I know

17 what it means. I waited for about an hour at that point. However, the

18 shelling continued. I returned to Trnopolje. The shelling still

19 continued into the night, the whole night, and the whole day the next

20 day. And it stopped only late the next day.

21 I went there again briefly before the end of the shelling. The

22 Serb infantry advanced and started burning houses at the entrance to the

23 place. The houses were burning. Flames were reaching into the sky, and

24 all we were able to see in the dark and in the light of the flames were

25 people running to and fro, people falling. Some people burnt down in the

Page 20480

1 burning houses. Some managed to escape, and those who managed to escape

2 told us about what was going on and how it had started. They said, these

3 people said, that the people burning down houses were using some special

4 bombs because the house is set ablaze in a split second.

5 After that, the fire and the shelling stopped. The military

6 action stopped. Columns of refugees started fleeing, but the Serb

7 infantry also advanced, driving people out and killing people in villages

8 if they were stragglers, if they hadn't managed to escape. That

9 situation continued and repeated itself around Trnopolje and in Trnopolje

10 itself. And because of the particular vantage point I had in some of

11 these situations, I was able to see it all with my own eyes.

12 Q. Okay. Let me ask first before I ask you about your observations

13 about what happened to some of the villages in the area.

14 If you can indicate to the Court what happened to the people from

15 Kozarac after the events you described, whether any distinction --

16 whether -- whether they went to a particular place, whether they were

17 taken to a particular place, whether any distinction was made between

18 portions of the population? If you know.

19 A. Everyone, men and even some older boys, were taken to the camp.

20 Women and children were grouped in Trnopolje or in some places where

21 groups of refugees had gathered. In the areas where there was a

22 concentration of refugees, the army came several days later and killed a

23 number of people there. And those who found shelter in those areas of

24 large refugee concentrations were deported to other areas, and if they

25 were men, they were deported to concentration camps, such as Omarska.

Page 20481

1 Approximately a month later, there was no one and nothing left

2 there. Not even birds.

3 Q. And forgive me for these clarifications, because I appreciate

4 that you may find them implicit in your evidence.

5 But when you say "everyone, men and even older boys, were taken

6 to the camp," who or what groups took them into the camps?

7 THE ACCUSED: [Interpretation] I have to protest again.

8 JUDGE KWON: [Microphone not activated]

9 THE ACCUSED: [Interpretation] The witness did not say "boys."

10 And Mr. Tieger is putting words in his mouth.

11 THE WITNESS: [Interpretation] I did say "boys." Older men and

12 also boys, minors. And I saw personally several examples.

13 JUDGE KWON: Line 25 in the previous page the witness said:

14 "Even some older boys."

15 Let's proceed, Mr. Tieger.

16 MR. TIEGER: Thank you, Mr. President.

17 Q. The question, Mr. Witness, was: Who was it that took those men

18 and boys to the camps?

19 A. They were taken by soldiers who arrived in groups, fired, and

20 then rounded up men. These soldiers wore a variety of uniforms. In the

21 specific place where I watched all of this, from beginning to end,

22 several soldiers had the Martic militia uniforms on. Others wore JNA

23 uniforms. Yet others wore the uniforms of the 5th Kozara Brigade. Some

24 wore pieces of uniform combined with civilian clothing, such as jeans

25 with a camouflage blouse and sneakers on his feet.

Page 20482

1 One of the operations was supported by a police APC. Some

2 operations involved tanks. At one point I was very close to the passing

3 group and I was able to overhear a bit of conversation among them. And

4 from what I heard, I knew straight away that some of those soldiers were

5 not from our area. They were not from Bosnian Krajina, and they were not

6 even from Bosnia-Herzegovina, because some of them wore -- spoke typical

7 Serbian from Serbia proper.

8 A semi-uniformed person in that group said in -- in a bit of

9 conversation that I managed to overhear, that he hailed from Banja Luka.

10 He didn't say exactly, I am from Banja Luka. He said, It's better for me

11 to come from Banja Luka here for a couple of days than to work a whole

12 month. It pays better. That's how I understood that he is from

13 Banja Luka, that he lives and works there, and then he comes for three-,

14 four-day stints, and that he finds it more lucrative, more profitable.

15 That was my inference from what I heard.

16 Q. Were all these groups operating together; and were these either

17 Serbs from Serbia proper, as you indicated, or Bosnian Serb forces?

18 A. There were both kinds. But they were doing an identical job

19 following the same procedure that had the same consequences. When I say

20 procedure, I say that because I noticed that they approached these

21 operations in the same way. First, they surround a hamlet, they open

22 fire from all directions. They keep approaching the houses while firing.

23 They get the men out of the houses, they line them up, and they take them

24 towards vehicles, because in some cases vehicles had been prepared in

25 advance. Otherwise, they would take them on foot towards Kozarac or

Page 20483

1 towards Trnopolje. I learned later on that it was in fact in the

2 direction of Omarska.

3 Q. Now just to clarify, during this period of time while you were

4 observing the things you described, were you walking around freely or

5 were you in hiding?

6 A. No. There was no freedom of movement whatsoever.

7 Only people who were running away in the convoys were free to

8 move within the convoy. All around, there were troops, robbers, looters.

9 There was shooting all around. Men carrying weapons went -- approached

10 the convoys and started shooting and killed people.

11 THE ACCUSED: [Interpretation] Just let's just clear it up. He

12 did not say that only in the convoys they had freedom of movement but

13 within the refugee groups.

14 THE WITNESS: [Interpretation] Within an area where the convoy of

15 refugee was, between one group and another. If you want me to be

16 precise, it's a diameter of about 300, 400 metres.

17 MR. TIEGER:

18 Q. A couple of quick questions. First of all, you referred to

19 looting. Are you referring to random acts of looting or more organised

20 forms of looting?

21 A. The first day or two I thought they were random. And then I

22 realised they were organised. I would see a big lorry arrive. I would

23 see that amounts of property were collected in one place, and every three

24 or four days it would be taken away by that lorry towards Kozarac. And

25 then the lorry would come back.

Page 20484

1 One group of looters or, rather, soldiers would be collecting

2 refrigerators. Others would be collecting stoves and cookers. In fact,

3 there was some sorting involved in their looting. And sometime later, I

4 was able to see two large collection points for this looted property and

5 I saw also a large meadow filled with refrigerators, perhaps thousands

6 and thousands of refrigerators. And another field that I saw was filled

7 with stoves using solid fuel. Very neatly lined, and I had no doubt that

8 it was property looted from the area of Prijedor, from Kozarac,

9 Hambarine, and other non-Serb places.

10 Q. And just to be clear, were you in fear of apprehension and were

11 you in hiding during this time?

12 A. Of course. Of course, I was. I was hiding. I was hiding from

13 everyone, from the Serb troops, the police, anyone Serb in uniform. But

14 I also kept away from non-Serbs because I thought they would be more

15 fearful, knowing that I was close by, and I didn't want them to suffer

16 any consequences in case I was apprehended just because they had been

17 with me or close to me, and that was why I stayed completely alone.

18 Q. Is that because you were a political figure, political leader?

19 A. Yes. Because the Serb forces were searching for surviving SDA

20 officials, officials of opposition parties, managers, directors of big

21 companies, and we were called Green Berets, Ustashas, Mujahedins, and all

22 the other names. And we were the first on their search list after the

23 occupation. I was aware of that, and that's why I decided to stay and to

24 hide alone.

25 I know of one case when some non-Serbs, fearing for their own

Page 20485

1 safety and lives, drove out my mother from the house where she was hiding

2 and turned her over to the Serb military forces. Through an unbelievable

3 combination of circumstances, she survived, and I learned of it in good

4 time. And lest I found myself in the same situation, or caused someone

5 else to find themselves in that situation, I decided to hide alone, and I

6 was making plans as to where to flee.

7 Q. You referred to the surviving SDA officials, managers, et cetera.

8 Can you tell the Court what happened to most of the SDA and HDZ

9 political leaders in Prijedor?

10 A. Your Honours, almost everyone was killed.

11 JUDGE KWON: If it is convenient, shall we take a break?

12 MR. TIEGER: Yes, Mr. President.

13 JUDGE KWON: But before we do that, since Ms. Sutherland is here,

14 in relation to the point you raised at the end of the hearing yesterday,

15 you stated that there are security concerns on matters which are not

16 normally dealt with in confidential filings, in addition to the addresses

17 of witnesses.

18 It's not clear, so if you could expand on that, if necessary, we

19 can go into private session.

20 MS. SUTHERLAND: No, Your Honour, I don't think it is necessary.

21 What I meant was that the witness's actual address was contained -- not

22 only the country where he was residing but the address and also matters

23 relating to issues of security concerns that the witness has or had at

24 that time, and those sorts of issues would normally be dealt with in a

25 confidential filing.

Page 20486

1 JUDGE KWON: If you could be more specific as to --

2 MS. SUTHERLAND: Your Honour, I'm sorry, I don't have the filings

3 in front of me at the moment. If we can have the break now and I -- we

4 can come back after the break and I can address you.

5 JUDGE KWON: Very well.

6 And I just noted there is a filing from the Prosecution for the

7 extension of word limit.

8 MR. ROBINSON: Yes, Mr. President. We don't have any objection

9 to that but we do -- I think there was possibly a misunderstanding with

10 what you ordered. There is no reason for the motions themselves to be

11 confidential. The annexes can --

12 JUDGE KWON: Annexes.

13 MR. ROBINSON: -- be provisionally confidential. But I think the

14 Registry has made everything confidential, which is, I don't believe, in

15 keeping with what you ordered.

16 JUDGE KWON: Probably the fault is on me. That can be cleared up

17 very soon.

18 We will break for 25 minutes and resume at five to 6.00.

19 --- Recess taken at 5.28 p.m.

20 --- On resuming at 5.58 p.m.

21 [Trial Chamber confers]

22 JUDGE KWON: Yes, Mr. Robinson.

23 MR. ROBINSON: Yes Mr. President. I'd like to introduce to the

24 Chamber Ben Cerini, a legal intern who will be joining us for this

25 session. Thank you.

Page 20487

1 JUDGE KWON: Thank you.

2 Yes, Mr. Tieger.

3 MR. TIEGER:

4 Q. Mr. Sejmenovic, there are three additional topics I would like to

5 address; that's the Trnopolje camp, the Omarska camp, and a bit of the

6 aftermath of your presence in Omarska camp. I'll try to do that

7 efficiently as possible and focus my questions as well as I am able.

8 First of all, you've discussed to some extent your period in

9 hiding. At some point, did you make an effort to go to the vicinity of

10 and ultimately attempt to enter Trnopolje camp?

11 A. Yes.

12 Q. And for what purpose did you want to get inside Trnopolje camp?

13 A. The reason to get close to Trnopolje camp was my plan to leave

14 the area, go via Trnopolje, Ribnjak and then Grmec. I certainly had to

15 get close to Trnopolje in order to make that journey.

16 When I got close to it, I observed the camp for two days, from a

17 distance, and also what was going on in the camp. How the guard shifts

18 went. It was quite far away, so I couldn't see everything, but I did see

19 this area from where I could see things close-up, as it were. I did that

20 because I was very close to the camp, and I noticed that the situation

21 was such that I could enter the camp unobserved, and in this way, come to

22 know what their plans were with these people. So that's what I did.

23 After two or three days in the camp, six persons were killed who

24 were in my immediate vicinity and who gave me some kind of assistance.

25 That night around 2.00 a.m., I decided to leave. So I left the camp the

Page 20488

1 same way I got in, and I went further away. However, I stayed nearby,

2 though.

3 The second time I got in was when I saw that many empty trucks

4 and buses were getting close to Trnopolje. I decided to go in again

5 because my impression was that an evacuation of the entire camp was being

6 prepared. So I wanted to avail myself of that opportunity, to be

7 evacuated as part of that group of women, children, et cetera.

8 When I went in the second time, it wasn't really any kind of

9 large-scale evacuation. Actually, the camp command had found out that I

10 had been there. They detained about 15 people who had contact with me,

11 and on pain of death, they asked about my whereabouts. Without knowing

12 that, I entered the camp, and then I found out from someone that that was

13 the case and, therefore, in order to save their lives, I surrendered,

14 feeling that was the end of my own life. I sent one of these 15 men to

15 call the camp commander so that I could surrender, and that's indeed what

16 happened.

17 Q. You mentioned that -- you mentioned six persons who were killed

18 after two or three days that you were in Trnopolje the first time. Can

19 you tell the Court the names of those six persons who were killed,

20 please.

21 A. Three families of brothers, all of them are Foric. All three

22 families were made up two brothers respectively. There was a very young

23 man among them and the oldest one there was a pensioner. They had no

24 special reason.

25 A uniformed soldier came who was a former neighbour of theirs,

Page 20489

1 spoke to one of them briefly, and then, after a while, a policeman came

2 with that soldier, and after that, they called out these men's names.

3 They took them away. A few gun-shots were heard, and a few bursts of

4 gun-fire, but in the morning we found out what had happened because a man

5 from camp was taken away to bury the corpses. When he returned, he --

6 they asked him who they -- he buried, so he described the six of them,

7 that one had Adidas sneakers, the other one had worker's overalls on and

8 so on. My impression was that all of this happened to them on my

9 account, and that is why I decided to leave the camp yet again.

10 Q. And do you know whether the bodies of the Forics have been

11 exhumed?

12 A. The bodies of the Forics were found in a mass grave. The

13 exhumation took place, I think, last year or the year before last, and

14 now they are buried in the area of Kamicani, as far as I remember.

15 Q. Can you describe for the Court the general conditions in

16 Trnopolje camp, food, medical care, sanitation facilities, security of

17 persons there and so on?

18 A. There was no serious organisation except for the military

19 organisation that supervised the camp. There was a shortage of food.

20 There was no medical care whatsoever. Medical care was improvised by

21 some medical men. Rather, a physician and a vet, a lady. Both of them

22 were non-Serbs. They happened to be in the camp, and they were trying to

23 help people.

24 As for food, the camp authorities allowed a small group of people

25 to leave the camp with proper approval to go back to their homes, to find

Page 20490

1 remaining food supplies, like potatoes and flour, and to bring that back

2 and thus feed people in the camp.

3 As for military installations in the camp zone, there were some

4 there. There were machine-gun nests, military check-points. There was a

5 machine-gun nest on the house opposite the camp. There were guard posts,

6 military guard posts. And they changed guards every two hours. They

7 went around the camp. And I know all of that because I was observing all

8 of this because I wanted to know at which point I could get out of a

9 particular zone.

10 Q. You mentioned what happened to the Forics. Can you tell us

11 whether you became aware that others in camp were in physical jeopardy;

12 and, if so, of what sort?

13 A. This is the way it was: I heard that there had been a few

14 killings. An old man had been killed. A woman. A youngish man. Out of

15 the 15 persons I already mentioned, I heard about the ways in which they

16 had been mistreated and beaten up, so that they would reveal where it was

17 that I had been hiding although they did not really know.

18 In the zone of the camp, or in the immediate vicinity of the

19 camp, rapes took place in certain houses. Rapes were committed in the

20 former cinema. That was one of the rooms within the camp itself.

21 Younger women and children -- and -- and other women were taken in the

22 area of Ribnjak and that's where rapes were committed as well.

23 Also, there were killings in the area around the camp. There --

24 certain persons were wounded too. I know that a lady neighbour of mine

25 was wounded in this way because see went to her vegetable garden to get

Page 20491

1 some potatoes.

2 Q. You mentioned that some people were allowed to leave to get food.

3 Was the camp enclosed by walls or wires or fencing?

4 A. Part of the camp was surrounded by barbed wire. In a certain

5 part, there was barbed wire even before the war but in this situation it

6 was reinforced. There was yet another part that was completely open.

7 However, there were military check-points there with machine-guns. The

8 machine-guns were pointed at the area that did not have a fence.

9 As for the roads, all around the camp there were military

10 check-points, on all of them.

11 Q. Now, you mentioned earlier that you sent someone to call the camp

12 commander so that you could -- could surrender, and that's what happened.

13 Who was that camp commander?

14 A. Slobodan Kuruzovic. A man who attended the meeting when we were

15 faced with an ultimatum.

16 At the moment when he saw me, he said, This is not Sejmenovic. I

17 know Sejmenovic. It was only when I spoke up, he said, Oh, is that you?

18 Well, look at the way you look.

19 Q. And where were you taken after your surrender to Kuruzovic?

20 A. There was a brief interrogation at the camp command in Trnopolje.

21 After that, they took me in the direction of Prijedor. They kept me for

22 about 20 minutes at the military police building which was opposite the

23 Keraterm camp. From there, they took me to the police station in

24 Prijedor. There was a brief interrogation there. Of course, I was

25 beaten up there. After that questioning, I was taken to the prison cell

Page 20492

1 that was next to the dormitory of the special police or the Red Berets.

2 Most of them came from Serbia.

3 I was beaten rather severely there, because I was unconscious for

4 a while. I was thrown into a cell where there were two women and two

5 elderly men from Gomjenica or, rather, Cele.

6 Q. How long did you stay in the police station; and where were you

7 taken after that?

8 A. Two nights at the police station. After the second night, in the

9 morning, or, rather, late in the morning, they took me to Omarska camp.

10 Q. Upon arrival in Omarska camp, to what part of the camp were you

11 taken?

12 A. The bus stopped right by the management building of the mine. As

13 I was getting off the bus, I saw large groups of people right next to the

14 bus, totally exhausted, malnourished, with bruises due to beatings. They

15 were out there on an asphalt area and it was very hot outside. They all

16 had to sit in the same position and all of them had their knees curled up

17 close to them and that is how they sat in these regular squares right

18 next to each other. And these areas were marked by chains, so they were

19 chained off, like in a parking lot.

20 Q. And you mentioned your questioning at the police station. Were

21 you interrogated at Omarska?

22 A. Yes.

23 Q. And did the interrogator question you about the number of weapons

24 that Muslims had and where they were?

25 A. No, he didn't question me about that. The first sentence was,

Page 20493

1 "We are not interested in Prijedor. We are not interested in weapons.

2 We know that you did not have any weapons. You had just a bit. But that

3 is minor." End of quote. We are interested in Sarajevo.

4 And then his interrogation started. He started interrogating me

5 about what I remembered from Sarajevo, especially what I remembered and

6 what I knew about Vitomir Zepinic and Miodrag Simovic. Later on, I was

7 asked to say what I knew about Fikret Abdic, whether I had any contact

8 with him and so on.

9 Q. And the interrogator, do you know whether he was associated with

10 any particular organ of the Bosnian Serb authorities or did you even know

11 the interrogator himself?

12 A. The inspector was from the Prijedor police. He had come from the

13 police building. He went out when I went out and he took the same bus to

14 Omarska. He and two women who were secretaries at the Prijedor police

15 station. Later on I saw that they worked in camp like secretaries as

16 well.

17 On the third day of the interrogation, he had announced that

18 inspectors from Banja Luka would come to interrogate me. On that one

19 day, there were these two inspectors from Banja Luka. People I saw for

20 the first time on that day. They said that they were from Banja Luka.

21 They attended the interrogation. They put a few questions but more or

22 less the questions that had been put by Radakovic as well. They did not

23 stay there long. Perhaps an hour or so.

24 Q. And you mentioned Radakovic. Is that the interrogator who

25 questioned you first?

Page 20494

1 A. Yes, yes, Dragan Radakovic, director of the Kozara National Park.

2 He had a master's degree in psychology and he had a university degree in

3 sculpture. He had introduced himself to me and said that we were

4 supposed to be colleagues had there not been a war.

5 Q. Can you briefly describe to the Court who guarded and secured the

6 camp and how it was secured? Police, military, others, both, et cetera.

7 A. For the most part it was the military. When the bus approached

8 Omarska, when we got off the main road between Prijedor and Banja Luka,

9 that is to say, as we got to the road leading to Omarska itself there was

10 a check-point with soldiers.

11 The other check-point with soldiers was right by the railroad in

12 Omarska and that is the road that leads to the camp or, rather, the

13 industrial zone of the mine that later on became a camp. Some -- at some

14 point halfway, near the mine installations, there was yet another

15 military check-point, and in camp itself there were a few places where

16 there was a concentration of soldiers. They were marching up and down

17 the area where the prisoners were. Also, they were in the cafeteria

18 area. There was just this glass house that the soldiers were not

19 supposed to enter. This was a room between two areas that did not have a

20 roof or ceiling but it had glass on two or three sides.

21 Within the camp, there were also some men wearing classical

22 police uniforms. The colour was blue.

23 Q. And you alluded at the beginning of your description of Omarska

24 to the conditions of prisoners. Can you briefly describe for the Court,

25 please, the conditions of prisoners and the conditions that prevailed in

Page 20495

1 the camp with respect to the treatment of prisoners.

2 A. Terrible. Not a single element that you could describe was not

3 humane. Those who were brought in were beaten immediately. They ordered

4 some inmates to beat up other inmates. They forced people to eat the one

5 meal that they gave us for a very short time so that people were eating

6 on the run. They didn't have enough time to eat this one piece of bread

7 so they would put it into their chest so that they would eat the soup.

8 People were beaten up all the time. On the PA, very loudly, they played

9 Serbian nationalist songs all the time. And everywhere among groups of

10 people you could see those who had been beaten up. Very often people had

11 to be carried to the meal because they were not able to walk.

12 The most awful scene I saw, which still haunts me, was of that a

13 boy who was around 13 and whose both arms had been freshly broken. Both

14 of them above his elbows and the right one also below the elbow. He

15 couldn't eat. Those who were older than him carried him into the mess to

16 take his piece of bread. They tried to feed him two or three spoonfuls,

17 and then they would carry him back. They began interrogating this child

18 the same day that they interrogated me. They forced him for one hour to

19 sing Serbian songs which he didn't know. It was inhumane and pitiless

20 machinery, which did not see anything human in anyone. It was turned

21 only to itself. That was Omarska.

22 Your Honour, I apologise, but this is a moment that -- thank you.

23 JUDGE KWON: No, not at all. You don't have to apologise,

24 Mr. Sejmenovic.

25 Yes, Mr. Tieger.

Page 20496

1 MR. TIEGER:

2 Q. Mr. Sejmenovic, I want to show you a video. And as it is being

3 set up - that's 40526A - I wanted to ask you quickly if you learned at

4 some point that prisoners from Omarska had been transferred to Manjaca

5 camp?

6 Just yes or no, if you know.

7 A. I learned that later, not at the Omarska camp but in Banja Luka.

8 MR. TIEGER: And if we could briefly show 40526A.

9 That's -- the transcript has been provided to the booth and we

10 would be -- we don't need to identify the particular page. It's very

11 short.

12 [Video-clip played]

13 "Reporter: The Serb offer to release all prisoners into the

14 hands of the Red Cross presents the civilised world with a sharp dilemma.

15 If they're left in the camps, the prisoners face the threat of continuing

16 humiliation, torture and death, but taking the prisoners away would help

17 the Serbs in their war aim: Clearing Bosnia of Muslims and Croats.

18 Privately, one Red Cross official calls it blackmail. Although while

19 negotiations continue, public comments are more diplomatic.

20 "Woman: You cannot only open doors and let them go. You have to

21 be absolutely sure these people can go in safety with security guarantees

22 and with a place to go.

23 "Reporter: The exact terms of the offer to release prisoners are

24 unclear. In one breath today, the Serbian leader Radovan Karadzic

25 offered to close all camps, but in another, he spoke of releasing only

Page 20497

1 prisoners of war too ill to go back into battle.

2 "Karadzic: We don't have people in prisons that have been

3 removed from their own homes. Those people have been captured in the

4 battle-field, and they can go home if they are weak and they are not

5 likely to -- to be mobilised from Muslim forces very soon."

6 MR. TIEGER:

7 Q. With reference to this video, which is dated the 20th of August,

8 1992, can you indicate to the Court the extent to which the condition of

9 these prisoners reflects the condition of or does not reflect the

10 condition of the prisoners you saw at Omarska camp?

11 A. It completely reflects their condition, though I had the chance

12 to see even some worse cases than those we can see here. But even in

13 this video we see an elderly man who is probably dying. This is what you

14 can see in the video-clip. We see people who are malnourished, who have

15 been beaten up. We see persons of various ages, from youngsters to old

16 men.

17 MR. TIEGER: I tender 40526A, Mr. President.

18 JUDGE KWON: Yes, that will be admitted.

19 THE REGISTRAR: As Exhibit P3695, Your Honours.

20 THE ACCUSED: [Interpretation] I wonder whether this was Manjaca,

21 where the witness was not held, and we will have witnesses from Manjaca.

22 So I wonder why do it through this witness?

23 THE WITNESS: [Interpretation] Your Honours, I was asked about

24 similarity, and I said that I could observe similarity.

25 JUDGE KWON: Yes.

Page 20498

1 Could we have the exhibit number again.

2 MR. TIEGER: 40526 -- oh, I'm sorry, the exhibit number. My

3 apologies.

4 THE REGISTRAR: Sorry, that's P3695, Your Honours.

5 MR. TIEGER:

6 Q. Mr. Sejmenovic, were you present in Omarska when international

7 journalists arrived?

8 A. Yes, I was.

9 Q. And were you made available or offered to them by the Omarska

10 officials to speak to?

11 A. Yes. They did not ask me anything. They just took me and

12 brought me before the foreign journalists.

13 Q. And did the foreign journalists speak to you and -- well, did the

14 foreign journalists speak to you, first?

15 A. No, they didn't. When they saw me, they categorically refused to

16 speak with me. They literally said, We won't speak with him. And the

17 woman who was the interpreter interpreted that to them. And after that,

18 they left.

19 Q. Do you know why they wouldn't speak to you?

20 A. Because, first of all, I was not brought to them on the drilling

21 ground or the glass house but in the administrative building, where I had

22 been brought previously. And, secondly, it was clear that that was

23 manipulation with one of the inmates. In this case, it was manipulation

24 with me. That was clear to the foreign journalists, and they gave up

25 talking to me. Though, frankly speaking, I really wanted to address them

Page 20499

1 because I saw a hope for my survival in this opportunity.

2 Q. Were you interviewed in Omarska by Bosnian Serb or Serbian

3 journalists?

4 A. Twice. On the previous days. There was journalist Mutic who

5 came and talked with me, told me what I should say if I wanted to save my

6 life and left. He promised that he would bring a written text that I

7 would read for him into the camera.

8 Two days later, as far as I remember, he came with the text and I

9 did read the text into the camera in the manner in which I believed it

10 was necessary for me to read it.

11 Q. And what organisation was Mutic from?

12 A. Mutic was SDS personnel.

13 Q. And did he work for any particular media outlet or agency?

14 A. Mutic worked for the "Kozarski Vjesnik" and for Radio Prijedor

15 and he was also the official cameraman of the 5th Kozara Brigade while it

16 was conducting war operations in Croatia.

17 Q. Were you also interviewed by journalists from Serbia?

18 A. Not from Serbia but there were Serbian journalists from Sarajevo,

19 or, rather, from Pale. They interviewed me. It was Dragan Bozanic

20 [Realtime transcript read in error "Bosnic"] who interviewed me. He was

21 a journalist of SRNA at the time. I think that was the name of their

22 news agency. And he conducted interview with me in one of the offices at

23 the Omarska camp.

24 Q. And let me show you a video next, 65 ter 40504A.

25 MR. TIEGER: That's page 4 of the English for the interpreters'

Page 20500

1 booth.

2 Q. And while we are waiting, Mr. Sejmenovic, the transcript says

3 Dragan Bosnic. Was it Bosnic or another name?

4 A. Dragan Bozanic, B-o-z-a-n-i-c.

5 Q. Thank you.

6 MR. TIEGER: The ERN on the English transcript is 03065658.

7 [Video-clip played]

8 "The Serb offer to release all prisoners into the hands of the

9 Red Cross presents the civilised --

10 THE INTERPRETER: [Voiceover] "... nor were they interested in the

11 hospital of this centre. They were interested in Mevludin Sejmenovic who

12 was an activist within this area.

13 "We heard that you are one of the few inmates of this reception

14 centre here" --

15 MR. TIEGER: Maybe we can stop.

16 Q. First of all, Mr. Sejmenovic, did you have a chance to see the

17 person interviewing you; and can you tell us who that is?

18 A. This is the former journalists of the radio and television of

19 Bosnia and Herzegovina who was a journalist of the Serbian television

20 from Pale in this period, and that is Dragan Bozanic about whom I have

21 been talking.

22 MR. TIEGER: And for the record just to indicate we stopped at

23 838.1.

24 Q. Mr. Sejmenovic, during the course of that interview, were you

25 asked about -- to -- to talk about the actions or activities of other SDA

Page 20501

1 leaders, about priests and -- excuse me, hodzas, that is, Muslim priests,

2 and other matters?

3 A. Bozanic, as documented in this video-clip, asked me almost

4 identical questions as journalist Mutic several days earlier, and Mutic

5 was a journalist of the local media. So everything I was asked here I

6 had mostly already been asked by journalist Mutic in -- on the previous

7 occasion when a statement was taken from me. And I answered in the

8 manner in which I was told to do because they told me that in that way I

9 could save my own life.

10 Q. The interview includes such questions and comments as condemning

11 Mirza Mujadzic as someone to blame for all the horror that happened here

12 in this region, and also refers to evidence of Muslim hodzas engaged in

13 arming or smuggling in some other way.

14 Were those things true; and, if not, why did you say them?

15 A. These things were absolutely incorrect. But that was the only

16 thing that I could say and that I was requested to say so that I would

17 not jeopardise my own life.

18 If I had told the truth, I would probably have ended my life an

19 hour after that.

20 MR. TIEGER: And if we could turn quickly to one more clip on

21 that video, 4054B is this clip. Page 7 of the English for the

22 interpreters' booth.

23 [Video-clip played]

24 THE INTERPRETER: Interpreter's note: We are not able to find

25 this on the transcript.

Page 20502

1 MR. TIEGER: I believe it begins at the very bottom of page 6 and

2 essentially begins at the top of page 7.

3 [Video-clip played]

4 THE INTERPRETER: [Voiceover] "Yes --

5 MR. TIEGER: Can we stop there, please.

6 Q. Again, do you recognise the journalist speaking there?

7 A. This is the same journalist, Dragan Bozanic. The one we already

8 talked about.

9 MR. TIEGER: And for the record I stopped that at 15.49.9, after

10 we -- after the camera panned past the journalist. If we can keep going

11 just a bit.

12 [Video-clip played]

13 THE INTERPRETER: [Voiceover] "We wish to live on -- live here

14 still, not to leave our homesteads. So you should report about that.

15 "And which government? There are many governments ..."

16 MR. TIEGER:

17 Q. And do you recognise the journalist shown on the other side of

18 the wire here? And that's at 16.01.

19 A. The one with the beard could be Mutic. It shows him in profile,

20 so I'm slightly reserved but I think that it is Mutic because he is bald

21 and because he has a beard.

22 Q. And finally, does this depict interviews conducted at a portion

23 of the Trnopolje camp that you've referred to earlier, with the wire?

24 A. Yes.

25 MR. TIEGER: I'd tender 40504A and B, Mr. President.

Page 20503

1 JUDGE KWON: Yes.

2 THE REGISTRAR: That will be Exhibits P3696 and P3697,

3 respectively, Your Honours.

4 MR. TIEGER:

5 Q. Mr. Sejmenovic, at around the time that the international

6 journalists arrived, did you also see any high-level Republika Srpska

7 officials come to the camp?

8 A. Yes, I did. There were several important local officials. They

9 were there on the same day when the journalists came. Some of them

10 arrived earlier and others at the same time as the journalists.

11 And then on the following day, an official of the Autonomous

12 Region of Krajina also came. That was Vojo Kupresanin.

13 Q. And did you learn -- first of all, did Kupresanin speak to you,

14 and did you have occasion to learn why he came to the camp?

15 A. The guards took me from the glass house to the administrative

16 building, to the top floor. I didn't know the reason until an elderly

17 greying man appeared. I believed that this was someone from the

18 municipal assembly in Prijedor but he introduced himself by saying, I'm

19 Vojo Kupresanin. And then, of course, I recalled that that was

20 Kupresanin, though it looked unbelievable. He told me that he wished to

21 talk with me. He told me to sit down. I sat on another chair, and we

22 had this conversation which was mostly Kupresanin's monologue.

23 Q. Now -- and -- and did you learn eventually whether Kupresanin

24 wanted to take you out of the camp; and, if so, why?

25 A. In the middle of this conversation, he was called to the office

Page 20504

1 next door. It was actually across the corridor from ours, with an open

2 door. A soldier called him and told him, The president needs you. I

3 think he said the president. Kupresanin responded and he told him, he

4 told him, the one who called, the president, that he needed 300 beds and

5 300 soap bars urgently. At least that number. He talked about that and

6 he also said something to the effect, I only found one. I thought that

7 referred to me but I wasn't sure.

8 Briefly after that, I learned that he actually meant me, and

9 that -- and he told me that I would be leaving for Banja Luka with him

10 now. He took me out. We got into a car and we started for Banja Luka.

11 During the ride to Banja Luka he asked me whether there were any other

12 deputies who were alive. Where was Mujadzic, where was Senad Cero

13 [phoen]. He said we should collect them. This is what he said. He

14 asked me about my family members and so on and so forth.

15 It was only later, a few hours later, and completely a day or two

16 afterwards, that I learned what exactly were Kupresanin's intentions and

17 what was the reason why he had taken me away from Omarska.

18 Q. And how did you learn that and what did you learn?

19 A. Part of it I learned from him because he was saying I need to get

20 better, to fatten up, that he would place me with a Serb -- a Serb

21 village, Kukuruzari, but I heard him talking to another man on the phone

22 to whom he said he had found me. He received some instructions and he

23 said in response he was already planning to get me a suit, to allow me

24 time to get better. And then he said that he was planning to organise

25 some round-table discussions with me so that I could make a public

Page 20505

1 appearance, speaking about the situation in Bosnian Krajina.

2 But I learned the rest of it from the driver who was taking me to

3 Vrbanija, to the house of my sister who lived up there. And the driver

4 said, I quote: It's good for you that you decided to be a member of the

5 Serbian Assembly, except somebody will kill you for it. You must not go

6 around Vrbanija. You must not leave the house because the extremists

7 would kill you otherwise.

8 I was not in a position where I could comment or respond to any

9 of this. I just took notice of what I had heard and kept thinking about

10 my situation.

11 Q. Two questions. The man that Kupresanin was speaking to in that

12 second phone call, were you able to identify who that man was from what

13 Kupresanin said or from any other aspect of the phone call?

14 A. Kupresanin said that in so many words after the conversation, and

15 I'd heard the voice of Mr. Karadzic that was very familiar to me from all

16 the sessions. Because it was the old-fashioned type of telephone set,

17 and the desk on which the telephone sat was not far away.

18 Q. And, second question, you referred to Kupresanin speaking to the

19 person he called president or who was -- he was called to as president.

20 That he needed 300 beds and 300 soap bars urgently. Can you tell the

21 Court whether you were able in -- at that time to form any impression

22 about why Kupresanin needed those items or was requesting those items;

23 that is, was it for the -- out of any particular concerns for the

24 prisoners or other reasons? Whatever you were able to deduce.

25 THE ACCUSED: [Interpretation] Speculation. Speculation. The

Page 20506

1 question calls for speculation.

2 JUDGE KWON: No, just a second. No, just a second.

3 As far as witness can answer the question, he is able to -- he is

4 entitled to answer.

5 Please proceed, Mr. Sejmenovic.

6 THE WITNESS: [Interpretation] I heard that part of the

7 conversation in Omarska. A part of the conversation I heard after the

8 filming made by foreign crews of reporters. I did not see any particular

9 concern about the conduct within the camp. And as for Kupresanin, he did

10 not express any feelings about the situation in the camp. During that

11 brief conversation we had, he spoke to me about international politics

12 and that's what he elaborated on. That it was a conspiracy of the

13 Vatican and the Comintern to portray Serbs as executioners of Muslims,

14 and he was talking in a monologue. I had no courage to get involved,

15 really, in that conversation or to debate him because of the position I

16 was in.

17 MR. TIEGER:

18 Q. Mr. Sejmenovic, you spoke about the -- what you understood to be

19 the intentions for you based on those discussions and conversations. At

20 some point, were you asked to -- well, first of all, let me set the stage

21 a little bit back.

22 After this, were you taken to Vrbanija to stay?

23 A. Yes, it was at my request.

24 Q. And at some point during the period while you were there, were

25 you told by Mr. Kupresanin that you were to come to Banja Luka to meet

Page 20507

1 Mr. Karadzic and also, perhaps, some members of a high-level

2 international delegation that were visiting?

3 A. Kupresanin came to Vrbanija twice. Once -- sorry, no, he came

4 three times.

5 Once, when he came, he wanted to take me to some place to

6 convince the Territorial Defence of Kotor Varos to surrender. I refused

7 that, explaining my reasons.

8 Another time he came saying that he was planning to drive me to

9 Bihac, to the separation line, for me to be a member of the Serbian

10 negotiating team discussing some military issues.

11 And the third time he came, he said I have very little time, to

12 get dressed, that I am to see Karadzic in Banja Luka and -- not only

13 Karadzic but some other people as well. And that's his third visit to

14 Vrbanija.

15 Q. Let me quickly show you 45389.

16 [Video-clip played]

17 THE INTERPRETER: [Voiceover] "I invited Mr. Vance and Lord Owen

18 to come to Banja Luka to see for themselves if that is indeed so; namely,

19 whenever there is a favourable course to the conference and when the

20 course is favourable for us, then it happens that some sort of lies are

21 put out by the Muslim circles, either that people are being killed in a

22 bread line or that Sarajevo is being bombed. Sarajevo, they themselves

23 are bombing Sarajevo.

24 "Moderator: It is fact that the world is beginning to grasp more

25 and more what it is all about.

Page 20508

1 "Karadzic: Yes. For the most part these tricks are quite

2 transparent. However, Vance and Owen wanted to come and see and I

3 invited them, and we met them in Bosanska Gradiska, took them around.

4 People welcomed them very warmly. There was an entire programme for

5 their stay in Banja Luka. They requested to see the people. Some people

6 they wanted to see. There were many Muslims there. There were two

7 officials of the Party for Democratic Action which is not banned in

8 Republika Srpska even though -- yes, in the territories where the Muslims

9 dominate. They were able to speak to all of them in private.

10 "They also received religious leaders, prelates from Krajina of

11 all of the three denominations. Then they talked with municipal

12 officials. They assured themselves President Radic is a very exceptional

13 person, a man who rules that city, governs that city according to the

14 law. They also saw the chief of police, Zupljanin. They could see for

15 themselves that the authorities there are doing everything they can so

16 that the tensions do not flare up, that those tensions that necessarily

17 exist because of this war do not result in any sort of evacuation. They

18 assured themselves of these things. They even publicly said that

19 Banja Luka is still not affected by ethnic cleansing although the

20 tensions run high.

21 "We showed them documentation from which one can see that a

22 secret Muslim organisation does exist there. That even one wing of the

23 Merhamet organisation is trading in arms and that this secret

24 organisation whose members we know, all of them, and we are monitoring

25 their work, wants to create chaos in Banja Luka, but that they are,

Page 20509

1 however, waiting for the European Community monitors to arrive. And that

2 is why we are postponing the arrival of the EC monitors. It might not

3 even be necessary for them to come as their arrival would cause chaos.

4 "It's a fact this did happen in Krajina, that some people left

5 the areas but not from Banja Luka. It happened, for example, after one

6 ambush between Petrovac and Bihac where 16 Serbs were killed. Not killed

7 but slaughtered. Then there was another ambush in which three Serbs were

8 killed, and in that clash, 11 Muslims were killed and 19 Serbs in total.

9 Then the families of the Muslims fighting in Alija's army or in the

10 official army wanted to leave Petrovac although they were being dissuaded

11 from this by officials. They left Petrovac anyway and went somewhere to

12 Central Bosnia.

13 "And I would be happy if the Muslim side would let the Serbs go.

14 And they will have to let them go according to the papers we signed in

15 Geneva. The Serbs from Sarajevo to go from one city, one part of the

16 city to another, or the Serbs from Tuzla about whom we are very concerned

17 and whom we shall demand to be allowed out of Zenica, Travnik and all the

18 other places under Muslim control.

19 "Simply they had to say, Lord Owen has even publically said that

20 this has not spread to Banja Luka, that there are tensions, but that we

21 are in the middle of a civil war and Banja Luka is a happy place where

22 children play in the streets. There is even a police force, including

23 Muslims and Croats."

24 Q. Mr. Sejmenovic, a couple of quick questions and we will be able

25 to complete today. First of all, the -- do you understand the event

Page 20510

1 that's being depicted here that is -- and referred to here? That is, the

2 invitation of Mr. Vance and Mr. Owen to come to Banja Luka to relate to

3 the visit that Kupresanin had you make to Banja Luka?

4 A. I understand, Your Honours. On the day before last, I heard that

5 these two high international officials were supposed to come to

6 Banja Luka, and when Kupresanin came that morning to say that I was going

7 to see Mr. Karadzic and other people, I inferred that those other people

8 were precisely those international negotiators.

9 Q. And, second, there's a reference to two functionaries of the

10 Party of Democratic Action. Did you understand you were one of the --

11 that you were an SDA functionary who was supposed to go to Banja Luka to

12 meet those international officials?

13 A. Certainly I was one of the two. Now, who the others are, I don't

14 know. Why do I say that I don't know? Because I was taken to that

15 building where this conference, this meeting, was being held.

16 Q. And, finally, Mr. Sejmenovic, when Mr. Karadzic referred to

17 people in the Krajina leaving and that those were families of Muslims

18 fighting in Alija's army who wanted to leave, is that kind of departure

19 of Muslims consistent with what you observed of the circumstances in

20 which Muslims were -- that Muslims left areas of the Krajina?

21 A. Your Honours, I'm sorry but I have to say this again. Apart from

22 the fact that these two men, Mr. Vance and Mr. Owen, really arrived, the

23 rest is complete manipulation and a travesty of what was going on there.

24 What was going on was exactly the opposite of what is described here.

25 This is the kind of pamphlet propaganda that we had so many occasions to

Page 20511

1 see even before these events and after these events.

2 MR. TIEGER: Mr. President, I see the time but I only have two

3 small clips -- one small clip and one quick document I think I can finish

4 within five minutes with the Court's permission.

5 [Trial Chamber confers]

6 JUDGE KWON: Yes with the indulgence of staff we can continue.

7 MR. TIEGER: My appreciation to the staff.

8 If we could turn quickly to 65 ter 45064. And for the

9 interpreter's booth, that's the last paragraph on that page you should

10 have.

11 [Video-clip played]

12 THE INTERPRETER: [Voiceover] "'We were not deluded,' Associated

13 Press quoted Vance as saying upon his arrival in Zagreb from Banja Luka.

14 He added, 'We heard some rumours, we went there and it's been confirmed,

15 so we know that this is happening in the region,' AP reports.

16 "Following talks with Radovan Karadzic, Vance told reporters that

17 he could not agree with the Bosnian Serb leader who said that no ethnic

18 cleansing was taking place here. And that Owen and himself should verify

19 certain matters before making up their minds, as well as that his

20 impression was that the situation was much worse than they had expected,

21 AP reports."

22 MR. TIEGER: Thank you.

23 Q. And, Mr. Sejmenovic, when Mr. Vance disputes what Mr. Karadzic

24 says and says there was ethnic cleansing, is that consistent with your

25 observations of what was taking place in the region?

Page 20512

1 A. It is consistent, Your Honours.

2 MR. TIEGER: I tender both those video-clips, Mr. President.

3 JUDGE KWON: Yes.

4 THE REGISTRAR: That will be Exhibit P3698 and P3699,

5 respectively, Your Honours.

6 MR. TIEGER: Thank you.

7 Q. And, finally, Mr. Sejmenovic, is it correct that you were finally

8 able to leave the area in January of 1993? That is, the area of Vrbanija

9 and Banja Luka.

10 A. I left on the 15th of January, 1992 -- sorry, 1993.

11 Q. And did you have to obtain a number of documents to present to

12 the international agencies in order to do so? To the international

13 agencies, as well as various officials.

14 A. I had to have an ID. I did not have an ID, so I tried to get

15 hold of one.

16 MR. TIEGER: And can we turn to 65 ter 20155, please.

17 Q. And is that one of the documents that you obtained?

18 A. Right. That's the document with the only photo that I had at the

19 time, and that's my picture from the army, when I was 19.

20 Q. Okay.

21 MR. TIEGER: And I tender this document, Mr. President.

22 JUDGE KWON: Yes.

23 THE REGISTRAR: Exhibit P3700, Your Honours.

24 MR. TIEGER: And that concludes my examination-in-chief,

25 Mr. President. Thank you.