Tribunal Criminal Tribunal for the Former Yugoslavia

Page 21143

 1                           Thursday, 10 November 2011

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Page 21144











11  Pages 21144-21184 redacted.  Closed session.















Page 21185

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 4                           [Open session]

 5                           [The witness entered court]

 6                           --- On resuming at 11.16 a.m.

 7             JUDGE MORRISON:  Good morning.  Could you take the solemn

 8     declaration, please.

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

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

11             JUDGE MORRISON:  Thank you.  If you would like to make yourself

12     comfortable.  First of all, you'll be asked some questions by the Office

13     of the Prosecutor --

14             THE WITNESS: [Interpretation] Thank you.

15             JUDGE MORRISON:  -- and later cross-examined by Dr. Karadzic.

16     Thank you.

17             MS. SUTHERLAND:  Good morning, Your Honours.

18                           WITNESS:  KDZ011

19                           [Witness answered through interpreter]

20                           Examination by Ms. Sutherland:

21        Q.   Good morning, sir.

22             MS. SUTHERLAND:  I'd first like to ask if 65 ter 90295 could be

23     brought up on the screen, please, but not broadcast.

24        Q.   Sir, do you see on the screen in front of you your name correctly

25     indicated and your witness pseudonym number in this case?

Page 21186

 1        A.   Yes, that's correct.

 2             MS. SUTHERLAND:  I tender that for admission under seal.

 3             THE REGISTRAR:  Exhibit P3798, under seal, Your Honours.

 4             MS. SUTHERLAND:

 5        Q.   Sir, as we discussed, part of your evidence in this case will be

 6     submitted in writing and we first need to deal with the formalities

 7     associate with that submission.  You testified in two trials before this

 8     Tribunal and in particular in the Brdjanin case on the 31st of January

 9     and the 3rd of February, 2003.  And you have subsequently had an

10     opportunity to review the audio recording of that testimony.  Is that

11     right?

12        A.   Yes, that's right.

13        Q.   I have two matters I wish to clarify with you.  The first matter

14     at transcript page 13968, you were asked a question about:

15             "How long in terms of days did the shelling last of Suhaca?"

16             And you answered:

17             "The shelling lasted for four to five weeks."

18             In your Krajisnik testimony at transcript page 2680 to 2681, you

19     said that the shelling of Suhaca lasted a week and stated at transcript

20     page 2718 that there was shooting during a period of several weeks.  Can

21     you confirm today how long the shelling lasted of the Suhaca village?

22        A.   The shelling of Suhaca went on for seven weeks, but the whole

23     process from the surrender of weapons to the arrival of Blagaj lasted

24     five to six weeks.

25        Q.   I just -- the interpretation was that the shelling lasted for

Page 21187

 1     seven weeks.  Do you mean seven weeks or seven days?

 2        A.   The shelling lasted for seven days.

 3        Q.   And the shooting lasted over a longer period of time which you've

 4     just clarified?

 5        A.   Yes, that's correct.

 6        Q.   Also transcript page 13968 of the Brdjanin testimony, you said

 7     that the shelling was coming from the villages of Josava and Krslje, and

 8     in the Krajisnik trial at page 2737, you said that "the Serb soldiers

 9     shot at us from the surrounding hills."

10             Can you clarify now whether you mean the shelling was coming from

11     the villages or the surrounding hills; and if so, the surrounding hills

12     of which villages?

13        A.   The shelling came from the surrounding hills, the hills above

14     Suhaca, from the direction of the village of Josava and the direction of

15     the village of Krslje.  Their positions were on the hills surrounding

16     Suhaca.

17        Q.   The second matter I wish to deal with is when you were asked in

18     the Brdjanin trial about the Suhaca mosque, you stated at transcript

19     page 14012 that it was seven days after you heard the loud explosions,

20     when you were in the village of Blagaj, that two men went to the Suhaca

21     village to bring a man back who had been killed.  In the Krajisnik trial

22     at transcript page 2683, you stated it was a day after you heard the loud

23     detonations that the two men went to the Suhaca village.

24             Can you confirm now how long after the explosions did the two men

25     go to the Suhaca village?

Page 21188

 1        A.   The same day we were expelled to the village of Blagaj we heard

 2     the explosion, the detonation.  On the following day, two men went to

 3     Suhaca at the request of the Serbian soldiers who asked them to bring the

 4     body of the man who had been killed.

 5        Q.   With those clarifications, can you confirm that the audio

 6     recording of the Brdjanin testimony accurately -- is accurate?

 7        A.   Yes, it is accurate.

 8        Q.   If you were asked today about the matters you testified to in the

 9     Brdjanin case with the clarifications that you made today, would you

10     provide the same information to the Trial Chamber?

11        A.   Whatever I stated last time is the truth and I would repeat it

12     today.

13        Q.   Sir, when you say "last time," I'm specifically asking you in

14     relation to your testimony in the Brdjanin case.

15        A.   Yes, everything I said then was the truth.

16             MS. SUTHERLAND:  Your Honours, I also note at transcript

17     page 13967, line 11, I think the word "such" should read "search."  It's

18     obvious on a reading of that sentence.  I tender that under seal,

19     65 ter 22140A which is the witness's Brdjanin testimony for admission

20     into evidence and 65 ter 22140B which is a public redacted version of the

21     witness's Brdjanin testimony.

22             JUDGE MORRISON:  Yes, that can be done.  Thank you.

23             THE REGISTRAR:  Your Honours, 65 ter number 22140A will be

24     Exhibit P3799, under seal; and 65 ter number 22140B will be

25     Exhibit P3800.

Page 21189

 1             MS. SUTHERLAND:  And with Your Honour's leave I will now read a

 2     summary of the witness's written evidence.

 3             JUDGE MORRISON:  Thank you.

 4             MS. SUTHERLAND:  The witness is a Bosnian Muslim from the village

 5     of Suhaca in the Bosanski Novi municipality.  He testified to the

 6     dismissal of non-Serb employees from their employment, the setting up of

 7     check-points which were manned by the Serb soldiers, and the surrendering

 8     of weapons to the Serb authorities at the end of April 1992.  Three days

 9     after the weapons had been surrendered, the shelling of the Suhaca

10     village, which was a Muslim village, started and lasted the whole day and

11     the whole night.  In the days that followed, the shelling took place in

12     the early hours of the morning.  The shelling lasted for a week.  The

13     shells were coming from the hills surrounding the village of Suhaca from

14     the direction of the villages of Josava and Krslje and were mostly

15     targeted at hamlets where mosques were located.

16             On the 24th of May, 1992, the inhabitants of Suhaca village were

17     told by JNA soldiers that they had to leave the village.  The witness

18     testified that on that day, around 1200 men, women and children left

19     Suhaca.  On the same day, all the inhabitants of surrounding non-Serb

20     villages also left the valley.  This was approximately 8.000 to

21     10.000 inhabitants.

22             The witness testified that the convoy of villagers were stopped

23     at the bridge near Blagaj Japra by Serb soldiers wearing JNA uniforms and

24     subsequently returned to the village of Blagaj Japra.  While there, the

25     witness heard explosions and received information that the Suhaca mosque

Page 21190

 1     was destroyed, and this is scheduled incident D.4.  17 days later Serb

 2     soldiers surrounded the village of Blagaj Japra.  The witness, along with

 3     hundreds of other Bosnian Muslims, was forced into a railroad cattle

 4     carrier.  The train travelled to Prijedor, where the men aged between 15

 5     and 60 were separated from the women and children.  The women, children,

 6     and elderly men were taken to Doboj.  The train with 700 to 730 men

 7     ultimately returned to Bosanski Novi.

 8             From the 11th of June, 1992, these men were held captive at the

 9     Mlakve football stadium in Bosanski Novi, and this is scheduled detention

10     facility C.4.1.  The witness was at the stadium for 46 days.  He

11     testified that the detainees were provided with minimal food and water.

12     While detained at the stadium he lost 11 kilos.  Detainees were treated

13     roughly and intimidated by the guards.  The witness testified that people

14     detained at the football stadium had not been involved in any sort of

15     armed combat.

16             The witness testified that he and other detainees were forced to

17     sign a statement renouncing all of their property and only then were they

18     released from the Mlakve football stadium.  While leaving the

19     municipality, the witness saw that Muslim houses and mosques were

20     destroyed.

21             The witness testified that by the end of 1992 not a single Muslim

22     remained in the Suhaca village.

23             That completes the summary of the evidence, Your Honour.

24        Q.   Sir, I have a limited number of questions for you.

25             MS. SUTHERLAND:  If -- Your Honours, in the Rule 92 ter

Page 21191

 1     notification filed on the 4th of November I listed as an additional

 2     exhibit 65 ter 06732, however, this document is part of a Defence

 3     exhibit.  So rather than create another exhibit I would seek leave to use

 4     the Defence exhibit D00470.

 5             JUDGE MORRISON: [Microphone not activated]

 6             MS. SUTHERLAND:  If that could be brought up on the screen,

 7     please.

 8        Q.   Sir, this is a Bosanski Novi SJB report dated the 15th of August,

 9     1992, making reference to the detention of Bosnian Muslims at the Mlakve

10     football stadium.

11             MS. SUTHERLAND:  If we could go to the last paragraph of page 2

12     of the B/C/S document and that's in page 23 -- on page 23 in e-court.

13     And in English it's the first full paragraph on page 3 of the document

14     which is page 19 in e-court.  The first paragraph of that sentence -- the

15     first sentence of that paragraph reads:

16             "According to our information, the persons at the collection

17     centre, that is, the stadium, were occasionally permitted visits by their

18     families."

19        Q.   Were your family allowed to visit?

20             THE INTERPRETER:  Could all the microphones not in use be

21     switched off so we can hear the witness.  Thank you.

22             THE WITNESS: [Interpretation] No, they were not allowed to visit

23     me.  They were allowed to visit me only on the day when we were to be

24     released, on the last day.

25             MS. SUTHERLAND:

Page 21192

 1        Q.   The second sentence reads:

 2             "The municipal Territorial Defence staff regularly provided them

 3     with food which meant one cooked meal a day" --

 4             THE INTERPRETER:  Thank you for slowing down.

 5             MS. SUTHERLAND:

 6        Q.   You stated at transcript page 13999 to 14000 that on the first

 7     day you received a quarter of a loaf of bread and one packet of liver

 8     paste for four men.  And the following day you didn't get much food, only

 9     some sort of watery tea.  Is that correct?

10             THE INTERPRETER:  Please switch off microphone.  Thank you.

11             THE WITNESS: [Interpretation] Yes, that's correct.  The first day

12     when we got off the train and went to the stadium we got one-fourth of a

13     loaf of bread and some cold meat.  And on the following days we received

14     even less food and only warm water.

15             MS. SUTHERLAND:

16        Q.   The next sentence of this document reads:

17             "The citizens at the collection centre had at their disposal the

18     use of the football field and the premises of the football club as

19     sleeping quarters."

20             You testified at transcript page 13999 that you slept under the

21     stands for spectators and in one of the locker-rooms.  Were you able to

22     use the football field for recreational purposes?

23        A.   We were not able to use the stadium for recreational purposes.

24     We were not allowed to move around.  We could only move underneath the

25     stands and up to the first half of the width of the stadium.

Page 21193

 1        Q.   The next sentence reads:

 2             "If necessary, they were given medical care ..."

 3             You stated at transcript page 14000 that you received no medical

 4     care at all.

 5             MS. SUTHERLAND:  I'd like to move on to the top of page 5 of the

 6     B/C/S document which is page 26 in e-court and the last paragraph on page

 7     5 of the English translation, and that's page 21 in e-court.

 8             Halfway down this page it states:

 9             "Proceeding from a decision on the voluntary moving out of the

10     citizens issued by the government of the AR Krajina and an order by the

11     Bosanski Novi municipality Crisis Staff on criteria for voluntary moving

12     out, the Bosanski Novi public security station has, in accordance with

13     due procedure, dealt with citizens' requests in the following manner:"

14             And then it lists:

15             "Permanently cancelled residency ... 5.680 persons."

16             And a little bit further down the page, and this is the next page

17     in English, it says:

18             "According to ethnicity the total number of cancelled

19     residencies, Muslims 5.629 ..."

20             And the paragraph below that relevant part -- the relevant part

21     states:

22             "Citizens who have moved out voluntarily have given written

23     statements to the competent municipal organ that their moving was

24     voluntary."

25        Q.   Sir, there are several references there to the voluntary moving

Page 21194

 1     of Muslim civilians.  Did you voluntarily decide to leave your village of

 2     Suhaca?

 3        A.   No, I didn't do it voluntary, neither did any other villager of

 4     Suhaca.

 5        Q.   Did you voluntarily surrender your property to the Bosnian Serb

 6     authorities?

 7        A.   No, I did not.

 8        Q.   And I think you said that you were -- at the stadium that you

 9     were forced to sign the document; is that correct?  This is at transcript

10     page 14014, that you signed the document yourself?

11        A.   Yes, I signed the document at the stadium under duress before the

12     Serbian soldiers who were there.

13        Q.   A little below it, it states that:

14             "On the 23rd of July, 1992, 6.000 citizens in 50 buses,

15     11 freighters, 12 trucks, and 200 passenger cars joined the convoy moving

16     out of the territory."

17             What day did you leave the stadium?

18        A.   On that same day we left the territory, the city of

19     Bosanski Novi, and the stadium.

20        Q.   You said -- at transcript page 14017 you made mention that you

21     got onto buses and trucks.  Did you also see freighters and this large

22     number of passenger cars in the convoy when you were leaving the Mlakve

23     stadium and Bosanski Novi municipality?

24        A.   As I was waiting at the stadium for my turn to arrive, we could

25     see a long convoy forming on the main road in the direction of Dvor and

Page 21195

 1     Kostajnica.

 2        Q.   I wish to turn briefly now to another topic.  At transcript

 3     page 14012 to 14013 you testified about the damage that was done to the

 4     Suhaca mosque, and I want to ask you about certain other mosques.  And

 5     I'll simply read the name of the mosque and if you could please tell us

 6     what condition it was in when you left in 1992, and if it was damaged, if

 7     you know when and by whom.  And I would like you to keep your answers as

 8     brief as possible, please.

 9             The mosque in Blagaj Japra?

10        A.   The mosque is Blagaj Japra was already damaged on the day when we

11     arrived.  The minaret, the bell-tower, was heavily damaged.

12        Q.   The mosques in Prekosanje, Urije and Gornji Agici?

13        A.   I couldn't see the mosque in Gornji Agici.  We couldn't go in

14     that direction.  As for the mosque in Prekosanje, I saw it on my way back

15     from Ostruzna.  I could see it from the train.

16        Q.   Was it damaged?

17        A.   The minaret was destroyed.

18        Q.   And the mosque in Urije?

19        A.   The mosque in Urije, that we could see from the train across the

20     River Sana also.  The minaret had been destroyed.

21        Q.   The old wooden mosque in Blagaj Reka?

22        A.   That mosque was torched while we were still in Blagaj.

23        Q.   Did you witness this?

24        A.   Yes, I saw two soldiers in a civilian car who set the mosque on

25     fire because it had a wooden minaret.

Page 21196

 1        Q.   And when you say "two soldiers," do you know the ethnicity of

 2     these soldiers?

 3        A.   I was not close to them.  They were probably Serbs.  They were in

 4     military uniform.  All the Muslims were in Blagaj.  We could not even

 5     cross the bridge to go there.

 6        Q.   And the town mosques in Bosanski Novi, that is, the Gradiska

 7     dzamija and the Vidorija mosques?

 8        A.   I saw those two mosques before I left the stadium.  We were

 9     travelling in an open-top lorry and we could see very well that

10     Vidorijska mosque was damaged, the minaret had been destroyed and the

11     roof had been set on fire.  And the city mosque was completely destroyed

12     and most of the -- most of it was razed to the ground.

13        Q.   And final the Stara Suhaca mosque?

14        A.   Suhaca had two mosques.  When we left they were both intact;

15     however, after that detonation people went there to bring the man's body

16     and they saw that the Brcanska [phoen] mosque in Suhaca had the minaret

17     destroyed and the main mosque in Dzemat also had its minaret destroyed.

18     They couldn't pass on that road.  They had to leave the car and proceed

19     on foot.

20        Q.   Thank you.  I have no further questions.

21        A.   You're welcome.

22             JUDGE MORRISON:  Dr. Karadzic, now your opportunity to

23     cross-examine.  We'll stick to the original time-scale, so we'll break at

24     12.30, if you would like to take that into account when structuring your

25     cross-examination.

Page 21197

 1             Ms. Sutherland.

 2             MS. SUTHERLAND: [Microphone not activated] Your Honour, I seek to

 3     tender the associated exhibits.

 4             MR. ROBINSON:  No objection, Mr. President.

 5             JUDGE MORRISON:  So be it, those will be admitted.

 6             MR. ROBINSON:  Mr. President, if I could just note that we didn't

 7     receive the allocation of our time for this cross-examination until this

 8     morning, so in terms of structuring the cross-examination it was

 9     difficult to do that because we didn't know how long would be allowed.

10     So if you would take that into consideration if Dr. Karadzic needs some

11     additional time, we would appreciate that.

12             JUDGE MORRISON:  All those things will be considered on their

13     merits, Mr. Robinson.  I do appreciate it was a late notification.

14             THE ACCUSED: [Interpretation] Thank you, Excellency.

15                           Cross-examination by Mr. Karadzic:

16        Q.   [Interpretation] Good morning, Witness.

17        A.   Good morning.

18        Q.   I have to ask you a few unusual questions briefly.  The answers

19     you gave to the questions put by the Prosecutor here and also in the

20     transcript that was admitted, is that true?  Was that correct?  Is there

21     no exaggeration there?

22        A.   Yes, that is true, there is no exaggeration whatsoever.

23        Q.   Is it the whole truth?

24        A.   Well, there are a few other things too, but these are minor

25     points that are perhaps not of interest here.

Page 21198

 1        Q.   Thank you.  The distinguished Madam Sutherland asked you to give

 2     brief answers.  Can I count on brief answers too?

 3        A.   No problem, fine.

 4        Q.   Can I also count on what you are going to say is going to be

 5     true?

 6        A.   As I said, nothing but the truth.

 7        Q.   Is it correct that Muslims in your area organised themselves

 8     militarily and armed themselves already in the beginning of June 1991?

 9        A.   No, that is not correct.

10        Q.   Is it correct that from the central level of the party, the Una

11     staff was ordered to be appointed and Bosanski Novi belonged to it too?

12        A.   That I don't know.

13        Q.   Could it have happened that the arming went on without you

14     knowing about it?

15        A.   In my village and in the valley of the Japra, I certainly knew

16     what was going on.  So that is something that was transferred.

17        Q.   Thank you.  Is it correct that the first victims in your

18     municipalities were Serbs in Bosanska Kostajnica who already in

19     September 1991 suffered from shells coming from Croatia?

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

21        Q.   Is it correct that the war in Croatia was very close to you,

22     basically on the other bank of the Una river?

23        A.   That is correct.  It could be felt too.

24        Q.   Could it be felt because shells were coming there and sniper

25     fire?

Page 21199

 1        A.   No, not because of that, because of the soldiers who would come

 2     from the front line and then create problems and open fire.  Sometimes we

 3     couldn't sleep all night.

 4        Q.   Thank you.  Are you saying now that there was no shooting

 5     whatsoever from Croatia in 1991, no shooting at the territory of

 6     Bosnia-Herzegovina and you in your municipality?

 7        A.   Not in the Japra valley.  I do not know directly for Kostajnica

 8     or the town of Bosanski Novi because our movement was restricted already.

 9        Q.   Are you trying to say that in 1991 somebody restricted your

10     movement at the time when there was no war in our area?

11        A.   Yes.  During the day we would move about freely.  After 7.00 p.m.

12     they had certain check-points where we were checked, maltreated, and that

13     is why we avoided moving about at that time unless it was absolutely

14     necessary.

15        Q.   You're talking about 1991; right?

16        A.   Yes, already in 1991 they were in military uniforms.

17        Q.   Do you know who was in power in Bosnia and Herzegovina in 1991?

18        A.   I do, yes.  Is that necessary?

19        Q.   Do you know who the minister of the interior was in 1991?

20        A.   I know that too.

21        Q.   Please tell the Trial Chamber, give us the name and the person's

22     ethnic background.

23        A.   Do I have to?  It was a Muslim.

24        Q.   Alija Delimustafic; right?

25        A.   Yes.

Page 21200

 1        Q.   He comes from your area, doesn't he?

 2        A.   He's a Bosnian.

 3        Q.   All right.  I'm saying now that it's not correct, that in 1991

 4     there was a force that would do that to you.  Even if that did exist, the

 5     entire world would have known about it and the Assembly would have

 6     discussed it.  Why are you bringing in 1991 as this year of restrictions?

 7        A.   Because I personally was checked at such check-points between the

 8     village of Rozici and Donji Agici, near the so-called Mala Ravska.

 9        Q.   Checked by who?

10        A.   Serb soldiers, and the main one was Gojko Davidovic, who worked

11     for the municipality as a clerk in Donji Agici.

12        Q.   Let us clarify this now.  Was this happening while Bosnia was

13     still in Yugoslavia and while the JNA was fighting in Croatia on the

14     other side of the river?

15        A.   Yes, that's right.

16        Q.   Does the main road go through your village or close to your

17     village?

18        A.   Yes, yes, it goes through my village.

19        Q.   Yes, coming from Sanski Most or Prijedor, this road I mean?

20        A.   Prijedor-Bosanski Novi is the main road that could be used to

21     reach Sanski Most as well.

22        Q.   Thank you.  So let us be very specific.  The war is on the other

23     side of the river.  The area is close to this area.  So you're checked by

24     the JNA, not by the Serb army; right?

25        A.   I was checked by local inhabitants of Donji Agici who were ethnic

Page 21201

 1     Serbs and wearing JNA uniforms.

 2        Q.   Thank you.  Do you know that in September 1991 Serbs from your

 3     area responded to the JNA call-up en masse and that they were the ones

 4     who were checking you, these were the mobilised reservists that I just

 5     mentioned?

 6        A.   Yes, these were reservists who went to the Croatian front line.

 7        Q.   Thank you.  Now we've clarified that, yes.

 8             In your statement you said, you said -- as a matter of fact, you

 9     said that in the Krajisnik case and in your statement in the Brdjanin

10     case.  You said that the SDA won in Bosanski Novi.  Is that correct or is

11     it correct that it was the SDS that won in Bosanski Novi?

12        A.   The SDA won in Suhaca and the SDS won in Bosanski Novi because at

13     the time there was Kostajnica and Bosanski Novi as a single municipality.

14        Q.   Thank you.  In Bosanski Novi were there two times more Serbs than

15     Muslims almost, 25.000 Serbs, 1.500 Yugoslavs, and 14.000 Muslims?

16        A.   Possibly, but as I said, because Kostajnica was also part of

17     Bosanski Novi.

18        Q.   Whereas you and Suhaca had how many Serbs?

19        A.   Not a single one.

20        Q.   Since when?  According to the census you had nine Serbs.  What

21     happened to them?

22        A.   No.  Maslovare and Josava and Uzice are the villages that had

23     those nine.  Suhaca as a village did not have a single one.

24        Q.   Thank you.  The census says that there were 1.070 Muslims, there

25     were -- no, no.  Four Serbs and nine were in Svodna.  So there were

Page 21202

 1     four Serbs, one Yugoslav, and the rest 1.077 were Muslims; right?

 2        A.   That's what the census said, but most of the elderly inhabitants

 3     said that they were Yugoslavs or that they were undecided.  Some even

 4     said that they were Serbs although they were Muslims.

 5        Q.   Why do you think a Muslim cannot be a Serb?

 6        A.   I didn't say that they cannot, but that is what the papers said.

 7        Q.   Thank you.

 8        A.   I think that this had to do with those Yugoslav communists.

 9        Q.   Thank you.  Is it correct that in the beginning of April 1992 a

10     Crisis Staff was established in Bosanski Novi?

11        A.   In Bosanski Novi, yes.

12        Q.   Thank you.  Do you remember that on the 15th of April, 1992, the

13     Executive Board of the Municipal Assembly asked for different goods to be

14     bought and that they should be located in particular areas in order to

15     feed the population?

16        A.   I don't know.  We did not get anything up there.

17        Q.   Do you remember that towards the end of April in Bosanska Krupa,

18     which is your neighbouring municipality, there were armed conflicts?

19        A.   No, I don't know that.

20        Q.   Thank you.  Do you know that on the 4th of May, 1992,

21     negotiations started between the SDS and the SDA at local level.  What

22     was discussed was the preservation of peace and the disarming of

23     unlegally armed groups.

24        A.   Perhaps there were negotiations, but we were in Blagaj by then.

25     We had already been expelled.

Page 21203

 1        Q.   The 4th of May?

 2        A.   Yes.

 3        Q.   Do you remember that on the 4th of May all illegally armed

 4     individuals and groups were asked to surrender their weapons to the

 5     TO staff by the 11th of May at the latest?

 6        A.   Yes, I know that, but we had already resolved that, and on the

 7     11th of May I was at the stadium.

 8        Q.   Thank you.  Is it correct that in Blagaj on the 9th of May there

 9     was a meeting of Dzafer Kapetanovic and Nesmir Ceric, operatives who

10     elaborated a plan to liquidate Serbs in the municipality of

11     Bosanski Novi?

12        A.   No, I don't know about that.  On the 9th of May we were loaded

13     onto a train.

14        Q.   Thank you.  Then you're probably going to say that you don't know

15     that between the 10th and 11th of May in Blagaj Rijeka, the military

16     police patrol was attacked by armed Muslims?

17        A.   Between the 9th and 11th of May we were on that train in Ostruzna

18     and I don't know about this at all.  I don't know who could have done

19     that because there were no Muslims left there.  There were only three

20     families left.

21        Q.   Thank you.  I'm asking you about your knowledge, to see what it

22     is that you know.  That is very important for me.  You can feel free to

23     say whatever you wish to say.

24             Did you hear of the Bosanski Novi staff ordering a cease-fire on

25     the evening of the 11th of May and the continued implementation of the

Page 21204

 1     decision stating that the police and TO should continue collecting

 2     weapons?

 3        A.   No, I don't know about that.  I was detained at the stadium from

 4     the 11th of May onwards, and from that day onwards I did not hear

 5     anything, I did not know about anything.

 6        Q.   Thank you.  We'll go back to that.  Let us now see whether you

 7     knew that on the 12th of May the Crisis Staff warned against looting and

 8     said that measures should be taken to prevent looting?

 9        A.   As I've already said, I don't know about that.

10        Q.   Thank you.  Is it correct that from Donji Agici and Gornji Agici,

11     on the 12th and 13th of May citizens formed a column to leave their

12     village and they set out towards Prijedor and Sanski Most?

13        A.   Yes, most of the citizens of Gornji Agici, they set out in the

14     direction of Prijedor and Sanski Most.  Part of them even joined us.

15        Q.   Thank you.  No doubt that at the time both Prijedor and

16     Sanski Most were in Republika Srpska; right?

17        A.   Yes.

18        Q.   Also there is no doubt that Prijedor and Sanski Most are further

19     away from the front line in Croatia, further away from the Una river;

20     right?

21        A.   Yes, that's right.

22        Q.   Thank you.  Did you find out that on the 13th of May the

23     Crisis Staff dissociated itself from the activity of groups that were out

24     of control and ordered to have the terrain searched and to have them

25     arrested in order to create conditions for the return of the population

Page 21205

 1     that had fled?

 2        A.   No, I don't know about that.  I was at the stadium.

 3        Q.   Thank you.  You also don't know that on the 15th of May the

 4     Crisis Staff passed decisions to continue disarming paramilitaries and

 5     persons who were illegally armed?

 6        A.   I don't know any of that.  As I've already said, we were not

 7     informed about anything at the stadium.

 8        Q.   Thank you.  Do you know that the Municipal Board of the SDS on

 9     the 20th of May held a meeting and adopted certain conclusions, stating

10     that all citizens who wished to leave Bosanski Novi should be allowed to

11     do so and the authorities were asked to ban all activities aimed at

12     expelling the population?

13        A.   No, I'm not aware of that.

14        Q.   Thank you.

15             JUDGE MORRISON:  Yes, Ms. Sutherland.

16             MS. SUTHERLAND:  Your Honour, I'm sorry to interrupt, but it's a

17     matter that I would want to re-examine on and I think it's probably best

18     that it get cleared up right now.  In the witness's transcript at

19     page 13998 he says that he went to the football stadium on the

20     11th of June, 1992, not the 11th of May.  And I think that there may be

21     some confusion and he's a month out.  And I -- in fixing it in

22     re-examination, then Mr. Karadzic would want to then re -- further --

23     further cross-examine because of all the answers that have been given up

24     until this point.  So I think it's -- it might be helpful to clarify it

25     now.

Page 21206

 1             JUDGE MORRISON:  I agree, Ms. Sutherland.

 2             THE ACCUSED: [Interpretation] I had intended to clarify that, but

 3     I wanted to take care of this stage of my cross-examination.  It's quite

 4     clear to me that it was in June.

 5             JUDGE MORRISON:  Mr. Witness, do you agree that it was June?

 6             THE WITNESS: [Interpretation] Yes, I do agree.  It was June.

 7             JUDGE MORRISON:  All right.

 8             THE WITNESS: [Interpretation] But the dates are the 9th and the

 9     11th of June.  They're actually the same like the 9th and 11th of May, as

10     Mr. Karadzic was saying.

11             MR. KARADZIC: [Interpretation]

12        Q.   I believe that the 9th and 11th of July and August and September

13     and whatever are all the same.

14        A.   Yes, but the situation that I described, the 9th leaving Blagaj,

15     the 11th ending up in camp.

16        Q.   June?

17        A.   June.

18        Q.   So in May you were in your village, you had electricity, access

19     to the news, and so on?

20        A.   We did not have any electricity.

21        Q.   What about transistor radios?

22        A.   Well, it depended on who had batteries.

23        Q.   Thank you.  Do you agree that on the 21st of May the

24     representatives of the SDA and the SDS discussed the conclusions of the

25     SDS of the 20th of May; namely, that the SDS had handed over their

Page 21207

 1     conclusions and they met up together in order to look at these

 2     conclusions to see whether the SDA had any objections?

 3        A.   I don't know about that.  I just know that while we were in

 4     Blagaj, a member of the SDA went to Bosanski Novi, and every time he

 5     would return he would say, "We didn't manage to resolve anything."

 6        Q.   Thank you.  They did not inform you that the SDA, on the

 7     21st of March, accepted the policy of the SDS and also the positions that

 8     were agreed upon, the conclusions of the SDS on the 20th of May?

 9        A.   No, I'm not aware of that.

10        Q.   Thank you.  Is it correct that on the 24th of May, the Muslim

11     population assembled in the central part of the village of Blagaj Japra?

12        A.   Correct.

13        Q.   Thank you.  Did you know that on the 25th of May, the

14     Crisis Staff ordered the municipal TO staff to urgently place under

15     control all armed individuals and units and to use the military police to

16     arrest those who were not under control and to disarm them?

17        A.   I don't know that.  The people who resided in Blagaj were not

18     armed.  The disarmament process had already taken place.

19        Q.   Thank you.  Did you know that following the order even greater

20     chaos occurred and that there were more groups and individuals which were

21     no longer under control; in other words, they were infuriated by the Serb

22     authority's decisions?

23        A.   I don't know about that.

24        Q.   Did you know that in your municipality certain policemen were

25     killed in Prijedor during an attack by the Green Beret Muslim forces on

Page 21208

 1     the town of Prijedor on the 29th, 30th, and 31st of May; and that there

 2     were funerals in your municipality?

 3        A.   I know about the funerals, but I don't know where those people

 4     had been killed.

 5        Q.   Thank you.  Do you recall that on the June 1st, in the evening,

 6     following the funeral of a policeman killed in Prijedor, there was combat

 7     in the settlement of Prekosanje?  There was a clash between armed Muslims

 8     and armed Serbs?

 9        A.   I didn't know that.

10        Q.   Thank you.  Did you know that on the 2nd of June, the TO of

11     Bosanski Novi and the military police evacuated the residents to the

12     stadium for the duration of the fighting.  They assembled them at the

13     stadium?

14        A.   Yes, I know that.

15        Q.   Did you know that it was a legal obligation on their part under

16     the Law on All People's Defence?

17        A.   As far as I know - and a relative of mine was there at the

18     stadium at the time - was that there were searches of Muslim houses.  And

19     a few days later they were returned to their homes.

20        Q.   Thank you.  A few days, exactly, on the 4th of June.  It was then

21     that the municipal Crisis Staff ordered the municipal TO staff to release

22     all those who were held there, save for a number of perpetrators.  A few

23     Muslim extremists were held back.  You don't have to agree with me when I

24     say that they were extremists, but there were a few people who were

25     retained.  Those were deemed to be extremists by the Crisis Staff.  The

Page 21209

 1     rest were released.  Correct?

 2        A.   I don't know if they kept anyone.  The rest were sent home and

 3     they were not guarded by either civilians or soldiers.  They were simply

 4     brought to the stadium, where they spent a few days.

 5        Q.   Thank you.  Military police data indicated that 17 people were

 6     kept in the premises of the military police, and that is perhaps why you

 7     were unaware of it because the number is relatively small; correct?

 8        A.   That is possible.

 9        Q.   Is it correct that on the 8th of June the residents of Blagaj

10     went towards Banja Luka in an organised fashion?

11        A.   That is not correct.  We did not leave of our own accord.  Your

12     request was sent to -- was to either go to Bosanski Novi or across the

13     river to Croatia.

14        Q.   Thank you.  Who prevented you from crossing the river into

15     Croatia?

16        A.   The Serb authorities of Bosanski Novi.

17        Q.   Thank you.  Then on the 11th of June, since around the

18     8th of June or 9th of June 22 railway cars were filled up, how many

19     railway cars were there exactly and how many people were placed in those

20     cars and where did they go to?

21        A.   In Blagaj there was a total of around 8.000 people.  On that day

22     we were driven out by soldiers wearing JNA uniforms.  We were sent to the

23     bridge which they controlled.  And from there we went to the Japra

24     factory.  We were checked there again.  They removed a few people and the

25     rest were placed on railway cars which went to Banja Luka -- towards

Page 21210

 1     Banja Luka.  We arrived at Ostruzna, near Doboj, where we stopped for two

 2     hours without anyone being around.  Then soldiers reappeared and some

 3     750 people were placed on board four railway cars.  Those cars were

 4     returned back to Bosanski Novi and the rest of the train went on to

 5     Doboj.

 6        Q.   Thank you.  Did the soldiers know that you asked to go to

 7     Croatia?  Were they informed of that and was it contrary to your wishes

 8     that they sent you to Doboj?

 9        A.   They did know.

10        Q.   Thank you.  Did you repeat your request to them, saying that you

11     did not wish to go to Doboj but across the river to Croatia?

12        A.   We did.  But they said, "Well, this is another route you can take

13     to Croatia."

14        Q.   Thank you.  Is it correct that Doboj at the time, as now, was in

15     Republika Srpska?

16        A.   The borders did change, but I think it was the case even back

17     then.

18        Q.   Thank you.  How many cars were there?

19        A.   Four railway cars were returned to Bosanski Novi.

20        Q.   No, no.  When the whole train started off, how many people were

21     placed in how many cars?

22        A.   It's difficult to say.  There were around 7.000 people, I

23     believe.

24        Q.   And let's say there were about a hundred people per car?

25        A.   More.

Page 21211

 1        Q.   This would mean that there must have been between 70 and 80 cars;

 2     correct?

 3        A.   Yes, if the math is correct, but there weren't as many cars.

 4        Q.   Well, a railway car is about 16 metres in length.  If there were

 5     60, what was the entire length of the train?  Between 900 and

 6     1.000 metres; correct?

 7        A.   The train was not that long.

 8        Q.   I was trying to ascertain something.  Do you agree that a train

 9     longer than 500 or 600 metres could not move along that railroad line

10     because its technical characteristics would not allow it?

11        A.   The train --

12             THE INTERPRETER:  Interpreter's note:  Could the witness repeat

13     his answer.

14             MR. KARADZIC: [Interpretation]

15        Q.   How many of the 700 returned?  Did you say one-third?

16             THE ACCUSED: [Interpretation] The answer was not recorded.

17             MR. KARADZIC: [Interpretation]

18        Q.   You said that a longer train could not move along that line;

19     correct?

20        A.   Yes, due to the technical characteristics of the line.

21        Q.   Did you say anywhere that approximately one-third of those of

22     fighting age were returned?

23        A.   Between 700 and 750.

24        Q.   Can we agree then that there must have been four -- or less than

25     4.000 people and not between 7 - and 8.000?

Page 21212

 1        A.   In Blagaj there were 7- to 8.000 people, whereas the cars which

 2     went to Doboj had around 4- or 5.000 people.  During the stay in Doboj,

 3     some of the people went to Bosanski Novi to stay with their relatives.

 4     There simply wasn't enough space in Blagaj.

 5        Q.   So they did that on their own?

 6        A.   Yes, and for the most part there were children and women doing

 7     that.

 8        Q.   Thank you.  Was it unsafe to stay in Blagaj at the time, given

 9     the fighting and people who were out of control?  Was it unsafe?

10        A.   It was, and there was firing from the direction of Petkovci, but

11     there were nowhere for us to go.

12        Q.   Was anybody killed at the stadium, was fire opened at the stadium

13     in Mlakve?

14        A.   No one was killed at the stadium, although there was firing,

15     whenever soldiers passed by on the road nearby.

16        Q.   They fired in the air?

17        A.   Yes, they cursed, they fired, and in those situations we were

18     told by the guards to hide under the seats.

19        Q.   Does it mean that the guards were trying to protect you from

20     those passing by?

21        A.   Yes, from the soldiers who were passing by, they would try to

22     give us cover.

23        Q.   Can we conclude then that there were more of you there and that

24     you were safer there and guarded there, which was not the situation in

25     Blagaj?

Page 21213

 1        A.   That's a good question.  I felt safer in Blagaj.

 2        Q.   Do you agree that at the time of your stay at the stadium, the

 3     Posavina corridor was closed, in other words, there was no link between

 4     Bosanska Krajina and Srpska Krajina as well as Semberija, there was no

 5     traffic?  The corridor was cut off?

 6        A.   I didn't know it then, but later on my wife told me that she went

 7     a good part of the road on foot because the rest was closed.

 8        Q.   Do you recall that the fighting for the corridor took place on

 9     the 28th of June and the corridor was unsafe until a few months later,

10     perhaps up to September?

11        A.   I don't know any of that.  While we were at the stadium we had no

12     information.

13        Q.   Given all that, did you learn that there was a shortage of food

14     and that the shops were no longer being supplied from Serbia because of

15     the situation?

16        A.   I didn't know that.

17        Q.   Thank you.  Are you aware that the 7- or 8.000 of you -- that

18     providing at least a single meal for each one of you was a very difficult

19     task; would you agree with that?

20        A.   I would, but if you looked at how much food and supplies we left

21     back at Blagaj, it would have been enough for four or five months for us.

22        Q.   You said you slept in the changing rooms and on the seats.  Are

23     these standard facilities on a soccer pitch?

24        A.   Yes, there were changing rooms and showers.

25        Q.   In other words, you had access to the showers and water?

Page 21214

 1        A.   No, we only slept there but there was no water.

 2        Q.   But there were showers, weren't there?

 3        A.   Yes, but there was no water.  We basically used the facility to

 4     dry our clothes off.

 5        Q.   You said somewhere that en route through the town you saw the

 6     Orthodox church was intact; correct?

 7        A.   Correct.

 8        Q.   Did you know that it was built after the war?

 9        A.   I don't know which one you mean.  The one I saw existed before

10     that.

11        Q.   Thank you.  In your testimony in the Brdjanin case, on page 13595

12     you said that the relationship between the Serbs and Muslims in Suhaca

13     were good, that you played soccer and associated with the Serbs in Suhaca

14     as well as with the Serbs from Josava, but the relationship was disturbed

15     once the war in Croatia began.  Correct?

16        A.   Correct.

17        Q.   Could we agree that there is a significant difference -- there

18     came a significant change when the mobilisations began taking place and

19     when Croatia seceded?

20        A.   Yes.  The Serb residents were drafted, mobilised, and equipped,

21     and as of that moment they no longer remained in touch.

22        Q.   Thank you.  Do you know that the Presidency of B&H and the SDA

23     ordered their followers not to respond to any JNA calls?

24        A.   I didn't know that.

25        Q.   Do you agree they didn't -- they didn't respond to either the

Page 21215

 1     June or September calls by the JNA, the Muslims and Croats simply failed

 2     to respond?

 3        A.   I didn't know that.

 4        Q.   Were you a military conscript?

 5        A.   I had been before the war in the JNA.

 6        Q.   Did you respond to the mobilisation call?

 7        A.   During that period there were no further reserve mobilisations.

 8     Once I completed my compulsory military term, I was no longer under the

 9     obligation to keep my uniform.  I was no longer obliged to do that under

10     the law.

11        Q.   Thank you.  In your statement of the 11th of December in the

12     Brdjanin case -- it is actually your testimony on page 00 -- sorry, no,

13     it is indeed your statement of the 11th of December, 1998.  The page is

14     00672865, paragraph 8, as well as in your Brdjanin evidence on the

15     31st of January, 2003, on page 13961, you say that following the

16     elections and during the war in Croatia but before the war in Bosnia the

17     Serbs began firing people from their jobs.  Can you tell us whether it is

18     correct.  Did it indeed take place in 1991 during the war in Croatia?

19     Were Serbs laying people off?

20        A.   Yes, in late 1991, three people in Bosanski Novi were dismissed

21     from work.

22        Q.   Who was that?

23        A.   Two civil -- public servants and a policeman.

24        Q.   Why were they dismissed?

25        A.   I know of them -- one of them personally and he told me that he

Page 21216

 1     was dismissed only because he was a Muslim.

 2        Q.   Hmm.  Well, thank you.

 3             THE ACCUSED: [Interpretation] Can we now look at 65 ter 6706.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Do you agree that a joint MUP existed up to 27 or 28 March 1992?

 6        A.   The MUP existed, whether it was a joint organisation or not, I

 7     don't know.

 8        Q.   Please pay attention to the report on the current security

 9     situation and the circumstances of reserve police forces mobilisation.

10     The report was issued on the 11th of July, 1991.  And there is a

11     reference here in the first line to the recent events in Slovenia and

12     Croatia, and it says that in the municipality of Bosanski Novi, Bosanska

13     Dubica, Bosanska Gradiska and Srbac, bordering with the territory of

14     Croatia, the security situation has become drastically complicated, thus

15     taking the characteristics of a state of emergency and even of war.

16             Is it therefore correct that even before the war in Croatia as a

17     result of announcements of the events in Croatia and Slovenia, this is

18     how the police assessed the situation in several municipalities bordering

19     on Croatia?

20        A.   It is true that in 1991 there were two Muslim police officers in

21     Suhaca.  They patrolled the area during the day and they represented the

22     MUP of Bosanski Novi.

23        Q.   You're saying that in Suhaca -- or rather, that the police had

24     sent two police officers to Suhaca?

25        A.   Yes, they were reserve policemen because none of the Serbs wanted

Page 21217

 1     to patrol the area.  Serbs patrolled the area in the Serbian villages,

 2     Muslim patrolled around Muslim villages, and that's how we received these

 3     two men.

 4        Q.   So you're saying that the Serb police already in mid-1991

 5     patrolled Serbian villages, whereas Muslim policemen manned and patrolled

 6     the Muslim villages, and that all that was done with the blessing of the

 7     police station and this was done with full understanding of the police

 8     and the population?

 9        A.   Yes.  Those two police officers patrolled the village of Suhaca

10     as I've told you.

11        Q.   Thank you.  Look at the text and you will see how the situation

12     is characterised.  It says that due to a continuous reflection of all

13     known incidents on the territory of Croatia, a few special forces of

14     Croatian MUP have been noticed on the border, rumour is spreading -- were

15     there rumours at the time that intimidated and irritated the population

16     of all three ethnic groups?

17        A.   I heard rumours, but according to those rumours the situation was

18     rather bad in Croatia.  There was fear of fighting going on.  It would

19     spill over into Bosnia, and we could feel that when the combatants

20     returned from the front line.

21        Q.   Thank you.  However, they did not return in June and July?

22        A.   You mean from Croatia?

23        Q.   I have to wait and I'm kindly asking you to wait for the

24     interpretation to finish.

25             On the 11th of July they were still not returning from Croatia,

Page 21218

 1     and if you look at the report you will see that the report speaks about

 2     high tensions among our peoples in the municipalities along the border

 3     because of the events in Croatia.  It says here that there is fire being

 4     opened from automatic weapons from Kozibrod, Uncani, Struga, all in the

 5     territory of Croatia.  Were you aware of all that?

 6        A.   No, I was not aware of that.  I'm talking -- I'm speaking more in

 7     general terms.

 8        Q.   And it says here that occasionally fire would be returned from

 9     Bosanski Novi which means that fire was returned from your municipality.

10     Did you know that?

11        A.   No, I didn't know that.  Suhaca is 8 kilometres away from the

12     border, so I wouldn't know that.

13             THE ACCUSED: [Interpretation] Can I go to the following page,

14     please.

15             MR. KARADZIC: [Interpretation]

16        Q.   Do you really base everything you know only on what you saw in

17     Suhaca?  Did you know anything that was going on in the entire

18     municipality and the surrounding area?

19        A.   Most of what I know comes from Suhaca, the valley of Japra,

20     Blagaj, the train, and the stadium.  And as far as Bosanski Novi

21     municipality is concerned we only heard things.  I didn't see anything.

22             JUDGE MORRISON:  Dr. Karadzic, if it's convenient we'll break

23     now.

24             THE ACCUSED: [Interpretation] Thank you.

25             JUDGE MORRISON:  We'll break now until 1.30.  Thank you.

Page 21219

 1                           --- Luncheon recess taken at 12.31 p.m.

 2                           --- On resuming at 1.31 p.m.

 3             JUDGE MORRISON:  Yes, Dr. Karadzic.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             Could we have this document admitted?  It is the one from

 6     July 1991.

 7             JUDGE MORRISON:  Yes.

 8             THE REGISTRAR:  Exhibit D1911, Your Honours.

 9             THE ACCUSED: [Interpretation] Thank you.

10             MR. KARADZIC: [Interpretation]

11        Q.   Witness, let me check something.  So you don't know whether only

12     the two were fired and why, except that one of them told you that he had

13     been fired for being a Muslim; correct?

14        A.   Yes.

15        Q.   Did you know that some Serbs were laid off too?

16        A.   I didn't know that.

17        Q.   Thank you.  Let's look at 65 ter 6697 in e-court.

18             Can you tell us first who were the Muslim leaders in Suhaca, do

19     you know their names?

20        A.   Sifet Barjaktarevic.

21        Q.   Anybody else?

22        A.   Adem Barjaktarevic.

23        Q.   Adem Barjaktarevic is one of the people who were fired; correct?

24        A.   Yes.

25        Q.   This is mid-April, Banja Luka, national security, it discusses --

Page 21220

 1             THE ACCUSED: [Interpretation] Do we have a translation?  We

 2     should.  It seems we don't.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   So this is a security situation assessment in Bosanski Novi on

 5     the 16th of April.  Apparently at that moment in time, the inter-ethnic

 6     relations were complex with divergent views in the way the escalation in

 7     violence is interpreted.  There were clashes among paramilitary

 8     formations, self-organised citizens, and JNA units throughout the

 9     republic.

10             The second paragraph, the momentary -- the balance in the

11     situation is contributed by a cessation in military clashes and the

12     arrival of peacekeeping forces in Banja and Western Slavonia, where many

13     mobilised citizens from the area of Bosanski Novi acted as part of JNA

14     units.

15             In April when the UN arrived in Croatia, the tensions were eased,

16     at least for a while; would you agree?

17        A.   I see this document for the first time.  As for the situation in

18     Croatia and the -- and its influence, I wasn't familiar with it.

19        Q.   In the next paragraph we have a mention made of escalating

20     war-time conflicts, permanent aggression against units and barracks of

21     the JNA in Bosnia-Herzegovina, and the presence of Croatian paramilitary

22     forces (HOS and ZNG) in the outskirts of our general region, in keeping

23     with personal and property insecurity experienced by the citizens at the

24     general collapse of the economy ..." and so on and so forth.

25             By that time the war in Croatia was underway, and were you

Page 21221

 1     familiar with the fact that there were armed groups of ZNG members in

 2     your area?

 3        A.   I was not familiar with that.  In the valley of Japra, in the

 4     villages there, there were no armed clashes or any other soldiers, save

 5     for those of the JNA.

 6        Q.   Thank you.

 7             THE ACCUSED: [Interpretation] Could we have this admitted, as it

 8     is a list illustrative of the events at the time?  I believe we'll have

 9     to have it marked for identification.  I really did think we had a

10     translation.

11             THE REGISTRAR:  MFI D1912, Your Honours.

12             MS. SUTHERLAND:  I don't think the Trial Chamber had ruled yet.

13             JUDGE MORRISON: [Microphone not activated]

14             THE ACCUSED: [Interpretation] Could we have 65 ter 6736.

15             MR. KARADZIC: [Interpretation]

16        Q.   Did you know that the Patriotic League was established in

17     Bosnia-Herzegovina on the 13th of April, and did you know that in your

18     area the Patriotic League and Green Berets had their units?

19        A.   I wasn't familiar with that.

20        Q.   Thank you.  This is a review of security findings in the area of

21     the Assembly of municipalities in Bosanski Novi concerning illegally

22     obtaining, possessing, and using fire-arms and forming military

23     organisations under the command of the SDA.  The date is the 18th of May,

24     1992.  Let's see what it says.

25             "In Bosanski Novi, due to the conflict in Croatia in late 1991

Page 21222

 1     and early 1992, the situation is characterised by deteriorating relations

 2     which are coming to a head between ethnic groups.  During the

 3     above-mentioned period, SDA activists started organising Crisis Staffs

 4     and forming military organisations whose purpose was to fight the Serbian

 5     people in the JNA and TO units with the final objective of establishing,

 6     in accordance with official SDA policies, an independent state of

 7     Bosnia-Herzegovina."

 8             What do you have to say about this?

 9        A.   Nothing.  We were not privy to any political developments.  We

10     were simply told there was a war in Croatia, which we could feel

11     ourselves, and that nothing good would come out of it for us.

12        Q.   Thank you.

13             THE ACCUSED: [Interpretation] Can we have the next page.

14             MR. KARADZIC: [Interpretation]

15        Q.   You can see at the top it says that on the 12th of January, in

16     the house of Vehid Huzejrovic -- do you know him?  He's from Blagaj

17     Rijeka.

18        A.   It does ring a bell.

19        Q.   It goes on to say a meeting of SDA activists was held which took

20     six hours, and the activists arrived from Agici, Suhaca, and

21     Blagaj Japra, totalling 14 people.  The meeting was presided by

22     Dzafer Kapetanovic and Resad Berberovic.  Do you know the two?

23        A.   Yes, they are from Bosanski Novi.

24        Q.   Thank you.  They discussed the creation of an armed formation

25     commanded by the SDA with its seat in Blagaj.

Page 21223

 1             And the next paragraph, on the 23rd of February we see Topic

 2     Alaga from Cazin.  He attended a meeting where there were about 160 SDA

 3     activists.  He stated that the SDA official policy and that of the senior

 4     members of the Islamic religious community must advocate living together

 5     with the Serbian people in this territory but that military organisations

 6     had to be fortified or strengthened at the same time.

 7        A.   I have no knowledge of this.  Where was this held?

 8        Q.   In the community hall in Blagaj Rijeka.

 9        A.   I'm not familiar with this.

10        Q.   Let's look at March and April, then.  It says:

11             "In Blagaj Rijeka, Sefik Velentalic ..." do you know him?

12        A.   I don't.

13        Q.   "... with the help of his wife Vesna and a certain Zdenka, both

14     employees of the medical centre in Bosanski Novi, worked on preparing and

15     organising medical care for the SDA military group in case fighting broke

16     out with members of the TO and JNA."

17             Then it says that Agrokomerc trucks were used to bring in

18     five mortars, two or three anti-aircraft guns, a machine-gun, and so on

19     and so forth.  Did you know about that?

20        A.   I did not.  I was discussing only the valley of Japra and no such

21     things took place there.

22        Q.   But Blagaj is not far away, is it?

23        A.   It is not.

24        Q.   Then it says that data was received about the position of

25     automatic weapons and we have a list of 20 people who were involved in

Page 21224

 1     that armed organisation.  Do you know any of them?  (redacted)

 2     (redacted)  No, you don't need to say that.

 3             THE ACCUSED: [Interpretation] Could we have that redacted,

 4     please.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Do you see Mr. Sisic, a hodza from Burim?  He too seemed to have

 7     taken part in the arming process --

 8             JUDGE MORRISON:  Dr. Karadzic, it might be better if you just let

 9     the witness read through the list and then ask him a question as to

10     whether he knows any of them and deal with it on that basis.

11             THE ACCUSED: [Interpretation] You're quite right.

12             MR. KARADZIC: [Interpretation]

13        Q.   Can you have a look at the list and tell us if you know any of

14     the initial 12 people?

15        A.   I do.  Not all of them, though.

16        Q.   Number 2, is it not a hodza who took part in that military

17     organisation?

18        A.   I don't know that people -- that person and I don't know if he

19     was a hodza or not.

20        Q.   Thank you.  Now, look at the rest of the list, do you know

21     anyone?

22        A.   I do know one person.

23        Q.   Thank you.

24             THE ACCUSED: [Interpretation] Can we move on to the next page.

25             We have Ibro Selimagic and Vehid Husejrovic who kept documents

Page 21225

 1     and lists produced by the SDA.  Can we go to page 5 immediately since we

 2     don't have much time.  This regards Bosanski Novi.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Could you read the first paragraph so that we would know who is

 5     at the helm of the military wing of the SDA.  Do you want me to read it

 6     out?

 7        A.   You wanted me to read it out loud?

 8        Q.   Yes.

 9        A.   "At the helm of the military organisation of the SDA are

10     Izet Mehmedagic, Ismet Muslimovic, Resad Berberovic, and Azemir Ceric.

11     Organising things in the field are Dzafer Kapetanovic, Sejad Ceric,

12     Hajrudin Grudic, and Kasim Falan.  In the area of Bosanski Novi, an

13     office was established in order to gather data about JNA units and

14     political and security-related decisions of the official -- official

15     authorities of Bosanski Novi and the Serb Republic of

16     Bosnia-Herzegovina."

17        Q.   So we have some familiar names --

18             JUDGE MORRISON:  One moment, Dr. Karadzic.  Ms. Sutherland.

19             MS. SUTHERLAND: [Microphone not activated]

20             JUDGE MORRISON:  Microphone.

21             MS. SUTHERLAND:  I was just wondering why the witness was needing

22     to read it out and why simply a question couldn't be put to the witness.

23             JUDGE MORRISON:  I think it's going to be now.

24             MR. KARADZIC: [Interpretation]

25        Q.   You know Mehmedagic or at least you heard of him?

Page 21226

 1        A.   Yes.

 2        Q.   I'm running out of time.  The entire document is quite precise in

 3     terms of dates and places where people were.  Mehmedagic is also

 4     mentioned in relation to arrests; correct?

 5        A.   Yes.

 6             THE ACCUSED: [Interpretation] Could we have this admitted?

 7             MS. SUTHERLAND:  Your Honour, based on what the witness has

 8     testified to, there doesn't appear to be a basis at the moment.  He

 9     simply agreed that he knows a couple of people that are named in the

10     document, and then he read a passage when he was asked to by the -- by

11     the accused.  So it may be that this isn't the right witness to put this

12     document to.

13             JUDGE MORRISON:  Well, that must be right, mustn't it,

14     Dr. Karadzic?  It cannot be said that this witness has adopted the

15     document or confirmed any material aspect of it.

16             THE ACCUSED: [Interpretation] Very well.  Thank you.  Although it

17     seems to me that this is relevant because the document was produced at

18     the time and concerns the events surrounding this witness.  So it's

19     important whether he knew about those events or not.

20             JUDGE MORRISON:  Ms. Sutherland.

21             MS. SUTHERLAND: [Microphone not activated]

22             JUDGE MORRISON:  Microphone again, please.

23             MS. SUTHERLAND:  I was just going to say I would also ask --

24     respectfully ask Your Honour to reconsider admitting the last

25     two documents because also on the basis of what the witness answered in

Page 21227

 1     relation to the first document dated July 1991, there really is no basis

 2     to have it admitted.  And that was the one we dealt with before the lunch

 3     break or the one just previous to this document, given the witness --

 4     what the witness had testified to.

 5             JUDGE MORRISON:  Mr. Robinson.

 6             MR. ROBINSON:  Excuse me.  Yes, Mr. President, I think this is an

 7     example that we've encountered before where even though the witness may

 8     not adopt the document or significant parts of it, it deals directly with

 9     events that -- in his municipality that he might be thought to -- ought

10     to be aware of and reflects on his credibility, the fact that he denies

11     knowledge of all that.  I think in the past we've taken the position that

12     documents which contradict the testimony of the witness or which deal

13     directly with things involving the witness or something he would be

14     expected to know can also be admitted.  We're not only admitting

15     consistent documents -- documents consistent with his testimony, but we

16     admit documents that are pointed and affect the witness and also are not

17     consistent.  And I think this falls within this category, these -- all

18     three documents.

19             MS. SUTHERLAND:  May I respond?

20             JUDGE MORRISON:  Of course.

21             MS. SUTHERLAND:  Certainly in respect of the first two documents

22     that were admitted, D1911, the one dated July 1991, and the previous

23     document, D1912, none of the answers the witness gave you could actually

24     say that -- that it would reflect on his credibility.

25             JUDGE MORRISON:  Well, speaking for myself, I find that a

Page 21228

 1     difficult concept to embrace in terms of what the witness actually said

 2     in respect of the document.  But I'll consult with my colleagues, but can

 3     we move on now and we'll deal with this matter in due course.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             I would like to call up 65 ter 6709.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Look at the third paragraph.  Kapetanovic and -- attended a

 8     meeting in Blagaj to discuss the plan to expel and execute Serbs.

 9             THE ACCUSED: [Interpretation] Can we go to the following page.

10             MR. KARADZIC: [Interpretation]

11        Q.   Here it says Suhaca village and it says that Sifet Barjaktarevic

12     was in charge of all activities.  It is in this village that the

13     activities -- the most organised, both paramilitary and every other kind.

14     In the last world war, Suhaca was a prominent Ustasha stronghold.  This

15     state body says that Suhaca was well organised, that Sifet Barjaktarevic

16     was the organiser and they were very active.  At the top of that page

17     there is a reference to red caps instead of red berets and that there are

18     strong links with the Islamic Religious Community, that criminals are

19     used for the purchasing and transport of weapons and so on and so forth.

20     And you knew nothing of that, although somebody thought that your village

21     had the best possible organisation?

22        A.   Sifet Barjaktarevic was the organiser in my village but he

23     organised the surrender of weapons that people already had, mostly

24     pistols and hunting rifles.  And he was the one who organised that.  When

25     people set out for Blagaj, he was in favour of heading towards

Page 21229

 1     Bosanski Novi or Croatia.  There were no other organisations at all.

 2        Q.   How many pieces of weaponry were handed over?

 3        A.   I don't know the exact number.  I would say about 300 pieces.

 4        Q.   There were 700.  You already said there were 700 pieces of

 5     weaponry all together and 200 were handed over, which constitutes a

 6     difference of 500.

 7        A.   I never said 700.  I said that there were about 300.

 8             JUDGE MORRISON:  Ms. Sutherland.

 9             MS. SUTHERLAND:  Your Honour, it's my recollection of 300.  So if

10     Mr. Karadzic is saying 700, can he please give me a transcript reference

11     page.

12             JUDGE MORRISON:  Yes.

13             THE ACCUSED: [Interpretation] I've found the reference.  This was

14     said when you said that you had hunting rifles, some pistols, and

15     homemade rifles and two semi-automatic rifles that were handed over.  All

16     together 300 [In English] in -- of which 70 to 80 were hunting rifles.

17             MR. KARADZIC: [Interpretation]

18        Q.   70 to 80 were hunting rifles, and what about the remaining 220?

19     You said that you only had two semi-automatic rifles.

20        A.   Yes, most were pistols, handmade rifles, and two semi-automatic

21     rifles.

22        Q.   Who was it who made their own weapons at home and why?

23        A.   This was part of our tradition.  A lot of people hang those

24     rifles as decorations on the walls and there were people who knew how to

25     make them.

Page 21230

 1        Q.   Thank you.

 2             THE ACCUSED: [Interpretation] Can this document be admitted or

 3     will it be considered in the same way as the previous one?

 4             JUDGE MORRISON:  Ms. Sutherland.

 5             MS. SUTHERLAND:  One moment, Your Honour.

 6                           [Prosecution counsel confer]

 7             MS. SUTHERLAND:  No objection, Your Honour.

 8             JUDGE MORRISON:  That's what I thought.  It will be admitted.

 9             THE REGISTRAR:  As Exhibit D1913, Your Honours.

10             THE ACCUSED: [Interpretation] Thank you.

11             MR. KARADZIC: [Interpretation]

12        Q.   Did you know that Sifet Barjaktarevic was a suspect, or rather,

13     that criminal proceedings were instituted against him for his activities

14     in the arming of Suhaca and for possessions of explosives on behalf of

15     the SDA?  Did you know that?

16        A.   No, I didn't know that.

17        Q.   He was actually offered explosives by the SDA.  Did you know that

18     Ilija Alibasic offered explosives to Sifet?

19             THE ACCUSED: [Interpretation] Can we look at 1D4688.  1D4688.

20     Can we look at the date, please.

21             MR. KARADZIC: [Interpretation]

22        Q.   The date is 28 November.  The document is a reply to a dispatch

23     dated 19 November about terrorist activities of a group of persons in

24     Bosanski Novi.  Five people were interviewed and information was

25     obtained.

Page 21231

 1             THE ACCUSED: [Interpretation] Can we go to the following page.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   We learned that Ilija Alibasic a few days ago persistently

 4     offered explosives to Sifet Barjaktarevic on behalf of the SDA and that

 5     after consultations were carried out in the regional board of the SDA in

 6     Bosanski Novi, Ilijaz Alibasic's offer was turned down.

 7             Did you know -- and now look at the bottom of the page and you

 8     will see that 164 kilogrammes of explosives and the rest was found in

 9     Jasminka Hasanbasic's shed?

10        A.   Yes, I can see all that but I'm not aware of the situation.  I

11     never learned about that.

12        Q.   The premises were searched, the source is reliable, and it is a

13     fact that a lot of explosives were found, clock mechanisms for detonation

14     of explosives.  That was in November 1991 and it was in your municipality

15     and people from Suhaca were involved?

16        A.   I'm not familiar with that.  Nothing of the sort happened in

17     Suhaca.

18        Q.   Thank you.

19             THE ACCUSED: [Interpretation] Can this be admitted?

20             JUDGE MORRISON:  No, Dr. Karadzic.  There's absolutely no

21     adoption by this witness of anything in the document.  He says he knows

22     nothing about it.

23             THE ACCUSED: [Interpretation] Your Excellency, with all due

24     respect, I find this very important.  What the witness knows or doesn't

25     know as the basis for his conclusions.  However, we can offer that

Page 21232

 1     through another witness.

 2             Can we now look at 1D4830.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Here again this is a document issued by the state security.  This

 5     is a list of persons who left the collection centre in Omarska on the

 6     18th of June, 1992, and operatives Bukva and Mijatovic escorted them to

 7     Bosanski Novi.  The persons who were released from Omarska were

 8     Resid Berberovic and Dzafer Kapetanovic.  They had been processed and, as

 9     a result of that, we obtained certain information about the illegal trade

10     in arms in the territory of Bosanski Novo and the operatives of the

11     public security service will be able to use that information.

12             Did you know that Dzafer Kapetanovic and Resid Berberovic

13     returned -- or, rather, were escorted to Bosanski Novi?  You said about

14     some of them that you didn't know where they ended and how they ended.

15        A.   I didn't know where they were.  I only know that seven days later

16     they were brought to the stadium and joined us.  I didn't know where they

17     were brought from and why.

18             JUDGE MORRISON:  Ms. Sutherland.

19             MS. SUTHERLAND:  Your Honour, I just provided a translation of

20     the document to assist you.

21             MR. KARADZIC: [Interpretation]

22        Q.   Resid Berberovic provided more information about the illegal

23     trade of weapons in Bosanski Novi.  In addition to that, he provided some

24     interesting information which will be used in the future.

25     Dzafer Kapetanovic was also released and returned to Bosanski Novi, and

Page 21233

 1     it says here that these persons were interesting for -- from the security

 2     point of view.  And that's why it is proposed that they should be further

 3     processed at the public security station in Bosanski Novi.

 4             Did you know that people were released from Omarska after having

 5     been interviewed and that they were referred to -- for further internship

 6     to the public security station in Bosanski Novi?

 7        A.   No, I didn't know that.  As I already told you, I only know that

 8     they -- the two of them joined us a few days later at the stadium.

 9        Q.   Thank you.

10             THE ACCUSED: [Interpretation] Can this be admitted?

11             JUDGE MORRISON:  Well, Mr. Karadzic, again no.  The witness has

12     said all he can say and it doesn't relate to the document.

13             THE ACCUSED: [Interpretation] However, he confirmed that they

14     returned, that they joined them at the stadium.  He confirmed that they

15     were somewhere.  He doesn't know where they were, but that they were

16     returned to the stadium.

17             JUDGE MORRISON:  Well, obviously when they weren't at the stadium

18     they were somewhere, but the fact he knows they were returned to the

19     stadium doesn't support the contents of the document because he doesn't

20     say where they were.  It's just stretching the document too far.

21             THE ACCUSED: [Interpretation] Very well.  We will find a way to

22     have this admitted.

23             I would like to call up 1D4838, please.

24             MR. KARADZIC: [Interpretation]

25        Q.   You know that "Dnevni Avaz" was -- is the most popular Muslim

Page 21234

 1     newspaper in Bosnia-Herzegovina at the moment?

 2        A.   It is possible.

 3        Q.   This was issued on the 4th of October this year, 2011, and it

 4     brings a story of Senad Mehdin Hodzic's mother.  She is interviewed and

 5     she is bitter about the fact that her son is not on the list of

 6     combatants.

 7             THE ACCUSED: [Interpretation] Can we scroll down, please.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   The government established who the organiser of the resistance in

10     Bosnia and Herzegovina were and their objections to the list and people

11     want the list to be supplemented by additional names.  It --

12             THE ACCUSED: [Interpretation] We have to scroll up a little and

13     display the right column.  Yes, this is it.

14             MR. KARADZIC: [Interpretation]

15        Q.   It says here the organiser of the resistance in Banja Luka,

16     Bosanska Dubica, Bosanska Gradiska, Bosanski Novi, Glamoc, and all the

17     other municipalities which are listed in here, and it says that the

18     organisers were Mirza Mujadzic, Bajazit Jahic, Safedin Begovic,

19     Muharem Krzic, Omer Veladzic, Esad Sekic, Izet Muhamedagic,

20     Rahmija Hodzic, Mujo Bacvic, Midhat Karadzic, that's one of my relatives

21     I suppose, Fadil Mecavica, Adem Spahic, Abdurahman Secic, Fahrudin Cenad,

22     Asim Egrlic, Muhamed Filipovic, Omer Filipovic, Ejub Basic, Muhamed

23     Sadikovic, Rasim Alekic, Rasim Heganovic -- did you know any of these

24     people?  There are a few other names one of them Mirza Mujadzic,

25     Mirzet Karabeg, Ifet Hukanovic, Redzo Kurbegovic, and so on and so forth.

Page 21235

 1             Did you know any of them?

 2        A.   I didn't know any of them personally.

 3        Q.   Do you agree that this is a Muslim newspaper and that this

 4     information originates from the Muslim army, i.e., from the Army of

 5     Bosnia and Herzegovina?

 6        A.   These are Muslim names.  I don't know where the information

 7     originates from.  I wouldn't be able to confirm that.  I don't know any

 8     of these people.

 9             THE ACCUSED: [Interpretation] Can we zoom in to see who the

10     organisers of resistance in Bosnia and Herzegovina were -- this is

11     actually the title of the text:  "Who are the organisers of resistance in

12     Bosnia and Herzegovina."  And can we scroll down, yes, a bit more, a bit

13     more, yes, yes, a bit more.

14             MR. KARADZIC: [Interpretation]

15        Q.   And now look where it says here "Alaga Topic."  Do you see the

16     name Alaga Topic, Ahmo Mujic, Nermin Hadzic?  Asim Barjaktarevic, you

17     know him, don't you?

18        A.   I don't know Asim.

19        Q.   But you are related to the Barjaktarevic's; right?

20        A.   No.

21        Q.   Do you see that the Muslim side openly writes and speaks about

22     persons who were organisers of struggle in your area?

23        A.   This is nothing but a newspaper.

24        Q.   Thank you.

25             THE ACCUSED: [Interpretation] Can this be admitted.

Page 21236

 1             JUDGE MORRISON:  There is no conceivable basis on the answers of

 2     the witness to admit this.  He adopts nothing, he recognises nothing, and

 3     he knows nothing of the provenance.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Is that one and the same Izet Mehmedagic, are these people from

 6     your area?

 7        A.   No, they're not.  I don't know them.

 8        Q.   You don't know Izet Mehmedagic?

 9        A.   It's somebody else, another person by that same name.

10        Q.   But just a while ago we saw that there was an Izet Izmetbegovic

11     [as interpreted] from Bosanski Novo?

12        A.   But the name in the newspaper is different.  And I didn't know

13     him.

14        Q.   Very well.  Do you know Alaga Topic then?

15        A.   From Donji Agici, yes, if that's the same man then I know him.

16        Q.   Thank you.

17             THE ACCUSED: [Interpretation] I believe that this should be

18     admitted, but it's up to you.

19             JUDGE MORRISON:  Dr. Karadzic, there has to be a basis for the

20     admission of an article from a newspaper merely beyond the fact that it's

21     an article from a newspaper.  Otherwise, the Court would be admitting an

22     untold number of newspaper articles which may or may not be true and

23     which provenance may or may not be of any relevance.  And in respect of

24     this witness there is none.  It may be that there is another witness who

25     does recognise some of those names and can speak to the accuracy of the

Page 21237

 1     information.

 2             THE ACCUSED: [Interpretation] Thank you, Excellency.  Then I will

 3     try in some different way.  However, these are Muslim sources and that is

 4     why I thought it was of value, but let's move on.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   You said that there were watches in your village and you said

 7     that there were two Muslims who were patrolling in order to protect you;

 8     right?

 9        A.   That's right.

10        Q.   Thank you.  However, you mentioned in your statement of

11     December 1998, paragraph 7, that there were five or six policemen who

12     patrolled the area with the intention of protecting you and that this was

13     done on the orders of the public security station in Bosanski Novi that

14     had also provided them with weapons; right?

15        A.   Yes, but these five or six policemen were supposed to take care

16     of all the villages, Blagaj, Suhaca, Vozici [phoen].

17        Q.   Ah-ha.  So do you agree that the chief of the public security

18     station in Bosanski Novi was a Serb and the commander of the police was a

19     Muslim?

20        A.   I don't know.

21        Q.   All right.  But you know that this public security station sent

22     these people to you and you say that they worked in different shifts in

23     these three villages, Suhaca, Donji Agici, and I don't know what else.

24     In your village it was mostly Muslims, and in Serb villages, Serbs;

25     right?

Page 21238

 1        A.   That's right.

 2        Q.   Thank you.  Did you know that there was smuggling going on and

 3     that sometimes it was more successful and sometimes it was impeded by the

 4     war operations in Croatia?

 5        A.   I didn't know about that.

 6        Q.   You see, in the Brdjanin case, on page 14024, you say that there

 7     was smuggling across the border but that it decreased considerably during

 8     the war and when there were checks between Bosanski Novi and Dvor on the

 9     bridge.  Isn't that what you said?

10        A.   No, that is not what I stated.

11        Q.   We have the page number so we'll check, 14024.  Do you know that

12     a prize had been promised to whoever would blow up that bridge?

13        A.   I don't know.

14        Q.   Do you know that on the Sava River between Bosnia and Croatia

15     some bridges were destroyed before that and after that too?

16        A.   I know after about that -- I mean I heard about it.  I didn't see

17     this.

18        Q.   Do you know which side was interested in having these bridges

19     blown up?

20        A.   I don't know.

21        Q.   Thank you.

22             THE ACCUSED: [Interpretation] Can we have a look at 65 ter 6709.

23             JUDGE MORRISON:  Five more minutes, Dr. Karadzic.

24             THE ACCUSED: [Interpretation] Well, I cannot do a thing,

25     Excellency.  I would have had even more to deal with had our time not run

Page 21239

 1     out.  Could Ram help with this?

 2             Let's look at the footnote, please, in Serbian.  We see it in

 3     English but let's have a look at the footnote in Serbian.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Do you see what it says here, that bridges are a constant object

 6     of interest and a reward of $25.000 has been offered to anyone who

 7     destroys the bridge between Bosanski Novi and Dvor on the Una.  The

 8     Croatian side wants to be cut off from the rest of Yugoslavia.  Do you

 9     find that understandable?

10        A.   I don't know about that.  I just know that up until the war

11     people used to work in Croatia and Slovenia, and then people crossed the

12     bridge in Bosanska Dubica.  As for Bosanski Novi and Kostajnica, these

13     bridges were blocked.  Why?  I don't know.  People would just say it's

14     because of the war in Croatia and that would be it.

15        Q.   Thank you.  Is it correct that during these searches in your

16     village, Suhaca, the Serb soldiers, as you call them, took Husein Ismet

17     from Suhaca and then returned them later on, and they told you that you

18     could leave freely.  And then two soldiers said to you everything is

19     fine, they haven't found anything, you can go home in peace?

20        A.   Yes, that's correct.

21        Q.   So it depended on whether they would find something or not;

22     right?

23        A.   No, we knew that there was nothing to be found.  We had handed

24     over the weapons that we had had, and then we were ordered to go to this

25     meadow and then they wanted to make sure because they didn't believe us.

Page 21240

 1     All of this is something that has been forced upon us.

 2        Q.   And then you were told that you could go home in peace because

 3     nothing had been found?

 4        A.   We could go home in peace and go on with our daily lives.

 5        Q.   Josava and Krslje were the villages from where gun-fire was

 6     coming; right?

 7        A.   From those directions, from the hills.

 8        Q.   Ah-ha.  From that direction but not from these villages?

 9        A.   Yes, from those directions.

10        Q.   Are these hills between your village and these villages?

11        A.   Yes.

12        Q.   Thank you.  However, in 2004, when you testified in

13     Mr. Krajisnik's trial, you said that gun-fire came from the direction of

14     Josava and Rasula or Rasula, whatever you pronounce it.  This is in the

15     Krajisnik case, the 23rd of May, 2648 is the page number.  You said

16     something different.

17             Is it true that Krslje is 5 kilometres away and Josava

18     2 kilometres away -- more than 2 kilometres away?

19        A.   It is correct, those are the distances between the villages.

20     However, the positions of the Serb villages were on the hills around

21     Suhaca.

22        Q.   Thank you.  You spoke about shelling and shells.  However, you

23     say that no one was a victim of these shells?

24        A.   Not in the village of Suhaca.

25        Q.   Thank you.  You also said, isn't that right, that when you left

Page 21241

 1     the houses remained in their normal state, and that would mean that they

 2     hadn't been hit; right?

 3        A.   Well, the houses that were abandoned were torched on that day and

 4     a house and a garage near the mosque had been hit and the old bridge.

 5        Q.   On page 2684, on the 24th of May, 2004, in the Krajisnik trial,

 6     you said:  However, when the Muslims left the village of Suhaca, all the

 7     houses remained in a normal state.

 8             Isn't that right?

 9        A.   Yes, all the houses remained intact, but these abandoned houses

10     in the hills had been set on fire and hit by shells.

11        Q.   You also said that there was a convoy of Muslim peasants from

12     Agici, Dedici, Donji Agici, Suhaca, Crna Rijeka, and Blagaj, and you say

13     that the Serbs were telling us to go in the direction of Prijedor and

14     Bosanski Novi.  And you say that there were about 1200 people there from

15     Suhaca, and the Muslims wanted -- actually, they took their own cars,

16     tractors, ox carts, everyone wanted to go to Bosanski Novi, and Sifet

17     negotiated several times.  He asked for permission to leave

18     Republika Srpska, that is to say, to go Croatia; right?

19        A.   We went -- we actually wanted to go in the direction of

20     Bosanski Novi and Sifet negotiated about that, that we either return home

21     or go in the direction of Bosanski Novi because they kept saying to him

22     that we should go in the direction of Banja Luka only.

23        Q.   Thank you.  And then -- and then you came to a bridge, where the

24     soldiers told you to board a train.  However, you refused that, right,

25     Izet Mehmedagic, then some Hamzagic, Sifet Barjaktarevic and soldiers on

Page 21242

 1     the bridge discussed that and you refused that, the people there refused

 2     to board the train; right?

 3        A.   Yes, we refused.  The train was supposed to go to Banja Luka.  It

 4     stood there on the tracks and we said that we would take our own vehicles

 5     to Bosanski Novi.

 6        Q.   We see that the two of them appeared there with Sifet, and did

 7     you return to Blagaj Japra then and did you stay there for another

 8     17 days?

 9        A.   Yes, we returned to the village of Blagaj then and stayed there

10     for 17 days.

11        Q.   All right.  Then you said that Croatia would be a far better

12     option and that's what you said for yourself and for others.  Over

13     70 per cent of you had some family or accommodation in Croatia, and in

14     Banja Luka and Doboj the situation was not safe because there was a war

15     going on, whereas the war in Croatia had already stopped?

16        A.   In Croatia people mostly had acquaintances, relatives, friends,

17     whereas in Banja Luka and Doboj, we didn't really know anyone.

18        Q.   And you said it wasn't safe too.  That's what you said in the

19     Brdjanin case, 14030; right?

20        A.   Not that it wasn't safe.  We just didn't know where we were

21     going.

22        Q.   Thank you.

23             JUDGE MORRISON:  Last question, please, Mr. -- Dr. Karadzic.

24             MR. KARADZIC: [Interpretation]

25        Q.   Is it correct that even when this shelling took place around

Page 21243

 1     Blagaj, no civilians were hurt and that the shooting went on for about

 2     two hours, and that the civilians moved towards the bridge in

 3     Blagaj Rijeka; right?

 4        A.   Yes.  The shelling came the night before that from the direction

 5     of Petkovac.  Everything was empty above the hamlet of Troske, and then

 6     the next day the soldiers made us go to the bridge.

 7        Q.   Is it correct that on the 11th of May, the Muslim paramilitaries

 8     attacked a patrol of the military police of the JNA and killed at least

 9     one military policeman?

10        A.   I don't know about that.

11             JUDGE MORRISON:  Dr. Karadzic, that's the allotted time plus.

12             Any re-examination, Ms. Sutherland?

13             MS. SUTHERLAND:  No, Your Honour.

14             THE ACCUSED: [Interpretation] Please, could Mr. Robinson say a

15     word.

16             JUDGE MORRISON:  Of course.

17             MR. ROBINSON:  Yes, Mr. President.  Unfortunately, Dr. Karadzic

18     didn't reach an issue that is relevant to this witness's credibility

19     concerning material which has recently been disclosed to us, which is the

20     subject of the 63rd disclosure violation motion concerning promises made

21     by the Office of the Prosecutor and this witness's place of residence.  I

22     was wondering if you would allow me a few minutes to put a few questions

23     to the witness about that.

24             JUDGE MORRISON:  Well, it's a pity if it was highly relevant that

25     that wasn't done.  I take, for an example, right at the beginning of the

Page 21244

 1     cross-examination when the witness was talking about roadblocks,

 2     ten minutes was spent before the essential question was asked, that

 3     whether or not the soldiers on the roadblocks were wearing JNA uniforms

 4     which was obviously what mattered to Dr. Karadzic, and the answer was

 5     yes.  If that answer had been -- if that question had been asked

 6     ab initio, then that ten minutes would have been saved.  If this is a

 7     matter which in your judgement is absolutely crucial, Mr. Robinson,

 8     please proceed as expeditiously as you can.

 9             MR. ROBINSON:  Well, Mr. President, I can't say it's absolutely

10     crucial.  It's something that should have been covered in the

11     cross-examination, but I really can't tell you it's absolutely crucial.

12             JUDGE MORRISON:  Well, I'm not -- define "absolutely crucial."

13             MR. ROBINSON:  I think it's relevant but it may not make an

14     ultimate difference in whether you find the witness credible or not, but

15     it's something that ought to be considered.

16             JUDGE MORRISON:  Well, Mr. Robinson, if you can again put it as

17     quickly as you possibly can.

18             MR. ROBINSON:  Okay.  Let's call up 1D4839, not to be broadcast,

19     and in the meantime I will ask some questions.

20                           Cross-examination by Mr. Robinson:

21        Q.   Mr. Witness, I'm Peter Robinson.  I'm the legal advisor for

22     Dr. Karadzic.  And the first question I want to ask you --

23             THE ACCUSED: [Interpretation] No broadcasting, right?  This

24     document should not be broadcast; right?

25             MR. ROBINSON:  That's correct.

Page 21245

 1             JUDGE MORRISON:  That's correct.

 2             MR. ROBINSON:

 3        Q.   I want to ask you some questions about the country where you

 4     reside, so let's be cautious and not name that country.  Okay?  So my

 5     first question is:  When did you arrive in the country that you presently

 6     reside, in what year?

 7        A.   1992.

 8        Q.   Okay.  Did there come a time when you went to another country to

 9     live?

10        A.   No.

11        Q.   In 1999 were you living in the country where you currently

12     reside?

13        A.   No.

14        Q.   Okay.  So thinking of the country where you were living in 1999,

15     did there --

16        A.   I apologise.  In 1999 I lived in that country.

17        Q.   And did there come a time when that country wanted to return you

18     and your family to Bosnia?

19        A.   Yes.

20        Q.   And it's true, is it not, that the Office of the Prosecutor of

21     the ICTY intervened so you were allowed to stay in that country with your

22     family?

23        A.   It is correct.  After the first statements, my residency was

24     extended because of these statement dates, and on the basis of that, I

25     managed to stay on.  Although, I had already submitted a request for the

Page 21246

 1     USA, for America, like many other people.

 2        Q.   And how long were you able to stay in the country that you lived

 3     in in 1999 as a result of the Prosecution's request?

 4        A.   My residency was extended for six months.

 5        Q.   And after that, have you still lived in that country or did you

 6     move to another country?

 7        A.   I continued to live in the same country.

 8        Q.   How long did you live total in that country?

 9        A.   From August 1992 without any interruptions.

10        Q.   And you're still living there now?

11        A.   Yes, that's correct.

12        Q.   And so it was an important benefit to you, was it not, to be

13     allowed to stay in that country rather than have to be returned to

14     Bosnia?

15        A.   Well, there was one- , three- or five-year residency in that

16     country so you could apply for permanent residence.  I was employed so

17     these few months were welcome.

18             MR. ROBINSON:  Thank you, Mr. President.  I have nothing further.

19     I'd like to tender the document that's on the screen, 1D4839.

20             JUDGE MORRISON:  Yes, well, this gives the basis for the

21     questions, Ms. Sutherland.  It's a document which we already had seen in

22     any event, so that can be admitted.

23             Any re-examination of the witness?

24             MS. SUTHERLAND:  No, Your Honour.

25             THE REGISTRAR:  The document will be Exhibit D1914 [Realtime

Page 21247

 1     transcript read in error "D1419"], under seal.

 2             JUDGE MORRISON:  That includes your evidence, Mr. Witness.  Thank

 3     you very much for coming to give it and you're now free to go and have a

 4     safe journey back to your place of residence.

 5             THE WITNESS: [Interpretation] Thank you.

 6             THE ACCUSED: [Interpretation] I don't think that the number of

 7     the document that has been admitted is not correct.  19 -- no, 18 -- it's

 8     not 14 in any case.

 9             THE REGISTRAR:  It's Exhibit D1914, under seal.

10                           [Trial Chamber and Registrar confer]

11             JUDGE MORRISON:  I'm told it will be necessary to have a

12     five-minute interlude before the next witness can come into court so

13     we'll all rise together.

14                           --- Break taken at 2.31 p.m.

15                           [The witness withdrew]

16                           [The witness entered court]

17                           --- On resuming at 2.41 p.m.

18             JUDGE MORRISON:  Yes, good day, sir.  Would you please take the

19     solemn declaration.

20             THE WITNESS:  I solemnly declare that I will speak the truth, the

21     whole truth, and nothing but the truth.

22             JUDGE MORRISON:  If you'd like to make yourself comfortable, I'm

23     sorry, but the -- you're only going to be in court for some 20 minutes

24     today.  It's just the way things have worked out before we need to rise,

25     and you'll, first of all, be dealt with by the Office of the Prosecutor

Page 21248

 1     and then later, but not today I suspect, cross-examined by Dr. Karadzic.

 2     Thank you.

 3                           WITNESS:  CHARLES KIRUDJA

 4                           Examination by Ms. Sutherland:

 5        Q.   Good afternoon, sir.  Please state your full name.

 6        A.   My name is Dr. Charles Kirudja.

 7        Q.   Dr. Kirudja, as we discussed earlier, part of your evidence in

 8     this case will be submitted in writing and we first need to deal with the

 9     formalities associated with that submission.  You have provided three

10     statements to the Office of the Prosecutor and testified in six trials

11     between 2003 and November 2010.  An amalgamated statement was prepared

12     which contains relevant portions of statements and your prior testimony

13     and this is a statement which you reviewed over two days and signed on

14     the 17th of November, 2010.  Is this correct?

15        A.   Yes, that is correct.

16             MS. SUTHERLAND:  Could I have 65 ter 90204, please.

17        Q.   Is this the statement which you reviewed and signed?

18        A.   Yes.

19        Q.   Can you confirm that it accurately reflects the statements that

20     you have previously made?

21        A.   Yes, I do hereby confirm.

22        Q.   Sir, if you were asked today about matters contained in the

23     amalgamated statement, would you provide the same information to the

24     Trial Chamber?

25        A.   Yes, I would.

Page 21249

 1             MS. SUTHERLAND:  Your Honour, I tender 65 ter 90204.

 2             JUDGE MORRISON:  Yes.

 3             THE REGISTRAR:  Exhibit P3804, Your Honours.

 4             MS. SUTHERLAND:  And with Your Honour's leave I will now read a

 5     summary of the witness's written evidence.

 6             JUDGE MORRISON:  Thank you.

 7             MS. SUTHERLAND:  Between April 1992 and June 1995, the witness,

 8     Dr. Charles Kirudja, served in a number of significant positions in UN

 9     missions in the former Yugoslavia, including civil affairs co-ordinator

10     in one of four protected -- four UN-protected areas, that is, Sector

11     North within Croatia.  Dr. Kirudja describes the UN mission in the former

12     Yugoslavia and his general responsibilities in Sector North, including

13     meetings he had with JNA personnel, local officials from the Republic of

14     Serbian Krajina, and Serb leaders in northern Bosnia and Herzegovina in

15     relation to the forcible removal of Muslims and other non-Serbs in

16     northern Bosnia.

17             The witness testified about his repeated interactions with senior

18     Bosnian Serb leaders in Bosanski Novi in connection with the departure --

19     sorry, with the desperate circumstances faced by the non-Serb civilians

20     from Bosanski Novi.  In particular, in May and June of 1992, the witness

21     participated in extensive discussions with Radomir Pasic, the SDS mayor

22     of Bosanski Novi and head of the Bosanski Novi Crisis Staff, about the

23     plight of local Bosnian Muslim civilians.  The witness testifies that

24     Pasic admitted that armed Serb paramilitary forces were, in fact,

25     harassing non-Serb civilians and pressuring them to leave Bosanski Novi.

Page 21250

 1     The witness further testifies that he came to the conclusion, based upon

 2     his discussions with Pasic, that the Bosnian Serb authorities were

 3     planning a mass expulsion of the non-Serb population from Bosanski Novi.

 4             Dr. Kirudja authenticates numerous documents, including a letter

 5     written to Pasic in June 1992, advising him of the illegality under

 6     international humanitarian law of the forced mass transfer of the

 7     population.  The witness was informed by UN personnel of mass gatherings

 8     of displaced non-Serb civilians by Bosnian Serb armed forces and the

 9     internment of non-Serb civilians at the football stadium in

10     Bosanski Novi.  This is scheduled detention facility C.1.4.  The witness

11     provides testimony as to the circumstances leading to UNPROFOR aiding in

12     the transport of the Bosnian Muslim population from Bosanski Novi

13     including numerous meetings at which the mounting humanitarian concerns

14     were discussed and the witness's conclusions that Bosnian Serb

15     authorities were spreading misinformation about alleged atrocities

16     committed by non-Serbs, and that the Bosnian Serb authorities were trying

17     to establish a territory that was free of Bosnian Muslims.

18             The witness also discusses the forcible disarmament of non-Serbs.

19     The witness describes meetings he attended as delegate of the

20     Special Representative of the Secretary-General to the former Republic of

21     Yugoslavia from August 1994 until October 1995.  In particular, he

22     testifies about hostage-taking of UN personnel by Bosnian Serb forces in

23     May 1995, for which the Bosnian Serb leadership in Pale was responsible,

24     and his involvement in negotiating their release.  The witness dealt in

25     particular with Jovica Stanisic, who was in turn in contact with the

Page 21251

 1     accused during this period.  The witness describes meetings he attended

 2     in Belgrade and authenticates a number of documents relating to

 3     hostage-taking.

 4             Your Honour, that concludes the summary and I have a very limited

 5     number of questions to put to the witness.

 6        Q.   Dr. Kirudja, I want to ask you a couple of questions related to

 7     four documents that you've recently reviewed.  In paragraph -- I want to

 8     show you three documents, and that's relating to the release of the UN

 9     hostages from Republika Srpska, which is detailed in paragraphs 149 to

10     164 of your amalgamated statement.  In paragraph 160 of your statement

11     you make reference to documents which acknowledge that UNPROFOR and

12     UNMO hostages were handed over to the Republic of Serbian MUP, including

13     being taken over by Risto Zaric.

14             MS. SUTHERLAND:  If we could have 65 ter 01348 on the screen,

15     please.

16        Q.   Sir, this is a document you reviewed in the past couple of days.

17     Is this another document acknowledging that six UNPROFOR members were

18     taken from the VRS Main Staff hospital and handed over to Risto Zaric on

19     the 2nd of June?

20        A.   Yes.

21             MS. SUTHERLAND:  Your Honour, I tender that document.

22             JUDGE MORRISON:  Yes, that will be exhibited.

23             THE REGISTRAR:  As Exhibit P3805, Your Honours.

24             MS. SUTHERLAND:  If I could have 65 ter 09063.

25        Q.   This is another document you recently reviewed.  Is this another

Page 21252

 1     document which acknowledges that five UN personnel were handed from the

 2     Vlasenica military police battalion to Risto Zaric on the 2nd of June?

 3        A.   Yes.

 4             MS. SUTHERLAND:  Your Honour, I tender that document.

 5             JUDGE MORRISON:  Yes, in addition.

 6             THE REGISTRAR:  As Exhibit P3806, Your Honours.

 7             MS. SUTHERLAND:  And finally 65 ter 09339.

 8        Q.   Do you recognise this document as one you recently reviewed?

 9        A.   Yes.

10        Q.   And is this a dispatch from the deputy minister of the RS MUP to

11     the president of the Republika Srpska, which confirms that 141 captured

12     UNPROFOR members were transferred from the VRS to the RS MUP and that

13     these persons were subsequently handed over to the MUP in the Republic of

14     Serbia?

15        A.   Yes.

16             MS. SUTHERLAND:  Your Honour, I tender that document.

17             JUDGE MORRISON:  Yes.

18             THE REGISTRAR:  Exhibit P3807, Your Honours.

19             MS. SUTHERLAND:  Your Honour, I have no further questions for the

20     witness, and I seek to tender the associated exhibits to the amalgamated

21     statement.

22             MR. ROBINSON:  No objection, Mr. President.

23             JUDGE MORRISON:  So be it, those will be exhibited as well.

24             MS. SUTHERLAND:  Your Honour, may we just go into private session

25     for one moment in relation to the associated exhibits?

Page 21253

 1             JUDGE MORRISON:  Certainly.

 2                           [Private session]

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14                           [Open session]

15             THE REGISTRAR:  We're back in open session.

16             JUDGE MORRISON:  Well, as I thought, Dr. Kirudja, we've about

17     four minutes left for today's session, so it's probably not worthwhile

18     Dr. Karadzic starting his cross-examination.  We can make up the few

19     minutes lost today tomorrow.

20             And, Dr. Karadzic, is it worthwhile asking anything at all today

21     or would you prefer to wait until tomorrow?

22             THE ACCUSED: [Interpretation] I couldn't agree more with you,

23     that it is not worthwhile to start today.  I would prefer to start

24     tomorrow.  I can only ask Mr. Kirudja how he is and that would be all.

25             JUDGE MORRISON:  Well, he looks very well to me, but I can't

Page 21254

 1     speak for him.

 2             Dr. Kirudja, I'm sorry that your initial appearance has been so

 3     short, but we've got going and we will go as expeditiously as we can from

 4     9.00 tomorrow morning.  You will, of course, know that having started

 5     your testimony, it's inadvisable to let anybody speak to you and not to

 6     speak to anybody else concerning the testimony you have given or you

 7     might give.  But you, of course, knew that already.

 8             THE WITNESS:  I would like to say thank you to Dr. Karadzic for

 9     his kind question, and yes, I'm all right and I thank him.

10             JUDGE MORRISON:  Then we'll all rise and meet again at 9.00

11     tomorrow morning.  Thank you.

12                           --- Whereupon the hearing adjourned at 2.58 p.m.,

13                           to be reconvened on Friday, the 11th day of

14                           November, 2011, at 9.00 a.m.