120412IT

Page 27393

1 Cross-examination by Mr. Karadzic:

2 Q. [Interpretation] Mr. Premovic, good morning.

3 A. [Interpretation] Good morning.

4 Q. I would like to ask you: If you are going to be answering in

5 Serbian to remember to pause between question and answer for purposes of

6 interpretation, but if it is easier for you, you are also free to answer

7 in English. So you can choose what you would like to do.

8 A. Well, I can do it in both languages.

9 Q. Thank you. A little bit earlier you said that the contents of

10 the conversation are correct. Am I right if I say that this refers to

11 the accuracy with which what was discussed was recorded, but other than

12 that, there are some imprecisions which we would clarify today.

13 A. [No interpretation]

14 JUDGE MORRISON: You should be able to get the translation in

15 English, Mr. Premovic.

16 THE WITNESS: Yeah ...

17 I'm confused with the headsets and everything.

18 Yes, we can discuss the ...

19 MR. KARADZIC: [Interpretation]

20 Q. Thank you. You ...

21 MR. ROBINSON: Excuse me, Mr. President. Maybe the witness can

22 make sure his headphone is on channel 4, that's the English, and then you

23 can hear the translation after Mr. Karadzic speaks and then he can answer

24 in English. That would probably be the simplest.

25 THE WITNESS: Okay. It's on channel 4 now.

Page 27394

1 JUDGE MORRISON: Yes, and in addition, if there is any further

2 confusion, if you look at the screen you should be able to see the

3 transcript being typed almost simultaneously in English.

4 THE WITNESS: Right now the input is in both languages. The

5 screen is like this and I'm not used to it. Okay.

6 THE ACCUSED: So I better do it in Serbian.

7 MR. KARADZIC: [Interpretation]

8 Q. Am I correct in having heard that you said that we can discuss

9 these imprecisions. However, the transcript recorded your answer just as

10 yes.

11 A. We can discuss it, you know. I'm of -- what's in the -- what's

12 in the -- in the script then you can say what I remember is pretty

13 consistent.

14 Q. Thank you. Am I correct if I say that you left Yugoslavia,

15 amongst other things, because there was a need for you to live in a

16 democratic world and to work in freedom and that you were successful in

17 that world. You succeeded as a successful businessman.

18 A. Yes.

19 Q. Thank you. In view of this position of yours towards the

20 previous regime, did you notice the appearance of myself personally and

21 the Serbian democratic party as well and what was your impression when we

22 appeared on the political screen?

23 JUDGE MORRISON: We have having the difficulties with the duality

24 of Serbian and English.

25 THE WITNESS: I am --

Page 27395

1 JUDGE MORRISON: Yes, I mean, that is readily understandable.

2 You're hearing the English in the headphones but we're hearing

3 the Serbian, as it were, coming through the courtroom than must be

4 causing you some confusion.

5 THE WITNESS: Yes.

6 JUDGE MORRISON: I'm not sure what the --

7 THE WITNESS: I may try it without the headphones and then just

8 listen directly and respond that way because I can't -- I'm not able to

9 listen to both conversations and the screen and then answer.

10 JUDGE MORRISON: It's something that does take a little practice.

11 THE WITNESS: Yes.

12 JUDGE MORRISON: In any event, try it without the headphones on.

13 THE WITNESS: I'll try without the headphones.

14 JUDGE MORRISON: And, Dr. Karadzic, if you can -- I don't think

15 anyone has ever accused you of having a quiet voice, but if you could

16 speak up a little more so that the witness can hear you, as it were,

17 through the courtroom rather than through the headphones.

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

19 I will try that.

20 MR. KARADZIC: [Interpretation]

21 Q. This question, is it possible for you to read that last question

22 on the screen?

23 A. [Interpretation] I did read it but I don't understand it all that

24 well. Perhaps you can rephrase it.

25 Q. I will try. In view of your past and the fact that you left for

Page 27396

1 democratic reasons, have you -- did you notice the appearance of

2 Radovan Karadzic and the Serbian Democratic Party on the political scene

3 and what was your impression?

4 A. No, I did not. I was just getting acquainted with you and with

5 the events in Bosnia only after the war started.

6 Q. Thank you. And is it correct that you happened to find yourself

7 together with some prominent figures who were dissatisfied with the

8 manner in which the conflict in Yugoslavia and in Bosnia was presented in

9 the media and in public, in general?

10 A. Yes.

11 Q. Thank you. I would like to clarify the following: The

12 Lord Byron Foundation has its headquarters in Great Britain or in the

13 United States?

14 A. Well, I really couldn't say. I know where the people are, or

15 where they decide to meet. That's what I know. But members are from

16 Canada, from Europe, and from the United States.

17 Q. Thank you. And among them are prominent figures, such as the

18 late Sir Alfred Sherman, who used to be an advisor of

19 Prime Minister Thatcher, then Professor Michael Stanton,

20 Mr. Ron Hatchett, Mr. Srdja Trifkovic, and other intellectuals; is that

21 correct?

22 A. Yes.

23 Q. And even though I am speaking in one language and you're speaking

24 in another, we still need breaks. So you can start answering only when

25 you see the letter A appear on the screen, for answer.

Page 27397

1 All right. So you noticed quite independently that there was

2 something in the reporting and in the treatment of the conflict that was

3 not quite right, is that correct, and then you met these people, after

4 that?

5 A. [In English] That's correct.

6 Q. Thank you. And when you said a little bit earlier that you

7 started to get interested in me and in us only when the war started, is

8 it correct that the first time you saw me or had any kind of contact with

9 me was in 1994?

10 A. That's correct.

11 Q. Thank you. And in 1994, you were visiting Yugoslavia and Bosnia

12 and Herzegovina and Republika Srpska, and you went to visit Gorazde,

13 which was a crisis that was topical at that time; is that right?

14 A. [No audible response]

15 Q. And is it correct that you saw many burned, devastated Serbian

16 villages, graves, cemeteries that were desecrated, lots of losses on the

17 Serbian side, as I said.

18 A. That's correct.

19 Q. Thank you. And you will recall at the time that you also met a

20 number of policemen who were in my security detail, such as Bojic,

21 Kovacevic, and that they took you to the down-town area, you and

22 Mr. Hatchett; is that correct?

23 A. That's correct.

24 Q. Thank you. And is it correct what you said that I expressed the

25 wish to meet with Mr. Hatchett and that I presented him -- well, I

Page 27398

1 informed him about the Serbian views regarding an end to the war, and do

2 you recall that this proposal was similar to the Camp David accords

3 during President Carter's term of office?

4 A. Yes. That's correct. I remember there was -- I'm not familiar

5 with the Camp David or whatever, but I would say it was very similar to,

6 I guess, the Dayton Agreement. But I don't say -- as I remember it, it

7 was an offer of a -- that, at that time, the Bosnian Serbs controlled

8 most of the territory, 85 per cent or so, and Dr. Karadzic offered a

9 return of territory to be in a minority position in the territories,

10 they'll accept anything. The change of a negotiated settlement of, I

11 could say, Sarajevo for the enclaves or vice versa, pretty much he was

12 open to any kind of arrangement at that time.

13 Q. Thank you. This was in the summer of 1994. And do you find that

14 this was implemented in November and December in 1995 in Dayton? Was

15 this proposal not very similar?

16 A. In my opinion, it is.

17 Q. Thank you. And Mr. Hatchett was a US ambassador before that; is

18 that correct?

19 A. He was a US ambassador to -- excuse me, I'm not sure of the

20 initials, but the European's security and whatever organisation in

21 Austria. Yes, he was an ambassador to that organisation for the US.

22 Q. Could that be the OSCE?

23 A. I think that's what it is.

24 Q. Thank you. And Mr. Hatchett informed you about the particulars

25 of my proposal. He also showed some enthusiasm for ending the war on

Page 27399

1 that basis; is that correct?

2 A. That's correct.

3 Q. And is it correct that Mr. Hatchett took steps to inform, first

4 of all, Mr. Rudolph Perina, who was the charges d'affaires in Belgrade,

5 about this Serbian proposal for ending the war?

6 A. Yes.

7 Q. Thank you. And is it correct that Mr. Perina's answer was that

8 the United States were not interested literally was a shock for

9 Mr. Hatchett as a completely unexpected and unusual response?

10 A. Dr. Hatchett was personally acquainted with Rudy Perina from the

11 service in the past and after presenting him with the plan that

12 Dr. Karadzic represented, Rudy Perina told them that they were not

13 interested in a deal [Realtime transcript read in error "detail"].

14 Q. Thank you. Is it correct then that Dr. Hatchett continued with

15 his efforts in the United States to reach figures in the administration

16 who would understand that proposal and that he continued to get in touch

17 with the congress, the CIA and the republican and democratic parties in

18 order to secure some kind of understanding for this particular proposal?

19 A. Yes. Dr. Hatchett is an ex-Assistant Secretary of State --

20 understood, you know, you could say the ways of alerting the

21 administration. So he did proceed to get the information to the top of

22 the US administration through the republican party, democratic party, CIA

23 and then various congressmen and senators that he was in touch with.

24 Q. Thank you. For the transcript I just wanted to say, page 9,

25 line 24, did you say: [In English] "... were not interested in a deal,"

Page 27400

1 rather than in a "detail"?

2 A. They were not interested in a deal.

3 Q. [Interpretation] Thank you. And Dr. Hatchett got in touch with

4 Senator prior and all the people who were close to President Clinton, is

5 that correct, in order to present this proposal for ending the war?

6 A. Dr. Hatchett, you could say, did contact everybody that he knew.

7 Senator Pryor was -- it was -- I tried to contact Senator Pryor and

8 because my family is from Hot Springs, Arkansas, and Arkansas is a small

9 place so kind -- we're familiar with the Clinton family anyway, so and a

10 lot of the -- and Senator Pryor was -- yes, he was given the peace plan

11 Dr. Karadzic recommended to Hatchett, I had a copy of it, and I was

12 trying to present it to the politicians in Arkansas.

13 Q. And do you agree that this was of some use but only some 15 or 16

14 months later?

15 A. Yes, I think so.

16 Q. Thank you. Just one detail from the conversation with my legal

17 advisor, Mr. Robinson. I would also like to thank you for meeting with

18 the Defence and with the Prosecution. Thank you.

19 Is it correct that you did not send your monetary donations to

20 the Bosnian Serbs but to the foundations that were working on finding the

21 truth about the conflict?

22 A. That's correct.

23 Q. Thank you. In 1995, in July, you visited Republika Srpska for

24 the second time; is that correct?

25 A. Correct.

Page 27401

1 Q. Let me just ask you this about these donations to the Lord Byron

2 Foundation and others: Is it true that you did not make it conditional

3 with these, what they would find? What you were supporting was for them

4 to find out what the truth was, whatever it may be.

5 A. That is correct.

6 THE INTERPRETER: Interpreter's note: Could the witness please

7 wait to answer in English before the English interpretation is finished.

8 JUDGE MORRISON: You won't have picked that up without earphones.

9 But I have been asked if you can wait for the English translation to

10 finish before your response, please.

11 THE WITNESS: I will try.

12 JUDGE MORRISON: Thank you very much.

13 THE ACCUSED: [Interpretation] Thank you.

14 MR. KARADZIC: [Interpretation]

15 Q. And is it correct that at the time in early July 1990 -- July, it

16 was risky for you to travel via Zvornik because there was combat going on

17 in that area at the time. Actually, this was on your return. You had to

18 go through Visegrad on your way back; is that correct?

19 A. That's correct.

20 Q. Thank you. But did you arrive via Zvornik?

21 A. Yes.

22 Q. Thank you. And when you were arriving through Zvornik, was there

23 a certain degree of caution because of the fighting that was going on at

24 the time in the area?

25 A. Not really. It was pretty quiet. We drove in without any

Page 27402

1 obstructions. The only thing is once we were in, you could say, deeper

2 in, we noticed that there was quite a bit of traffic as far as buses and

3 trucks, and so on. But there wasn't anything that was quite visible when

4 we were coming in.

5 Q. Thank you. And when you came to Pale, first of all, you had

6 meetings with Mr. Zametica, who already knew Mr. Trifkovic, and who was

7 my political advisor; is that correct?

8 A. That's correct.

9 Q. Thank you. And did you know that Mr. Zametica has a doctorate

10 from Cambridge and was a prominent investigator in --or researcher in the

11 United Kingdom and that he worked with Professor Michael Stanton and

12 others?

13 A. Yes, I did know that his education was in England and -- and I

14 really wasn't that familiar with his deeper background.

15 Q. Thank you. And even today, you can't refer to any dates with any

16 certainty. Isn't that the case?

17 A. My impressions are, you know, that I could say that I was there

18 earlier than the dates in the document.

19 Q. Thank you. In 1994, at that dinner, there were no political

20 speeches, were there? Pleasant conversation with guests in whose honour

21 the dinner had been given, and the subject that was discussed concerned

22 the difficulties that they had with resources, supplies. It concerned

23 the war time conditions.

24 A. That is correct. There was no political speeches. It was just a

25 visit and a dinner and just usual dinner conversation and depending in --

Page 27403

1 with who -- who was speaking.

2 Q. Thank you. In 1995, you also attended a dinner with me, you and

3 the other guests; is that correct?

4 A. I didn't -- I wasn't included in there, if you did have a dinner

5 with them.

6 Q. Did you leave a little earlier than they did?

7 A. Yes, I left earlier than the other two visitors.

8 Q. Thank you. So you also met the head of the Serbian press agency,

9 SRNA, you met him in Pale and he told you that they wanted to send as

10 many journalists as possible to Srebrenica in order to --

11 A. Yes.

12 Q. -- document the events, to witness the events; isn't that

13 correct?

14 JUDGE BAIRD: Your answer was yes?

15 THE WITNESS: Yes.

16 MR. KARADZIC: [Interpretation]

17 Q. I have to ask you to wait for the interpretation again. When you

18 see the letter A on the screen, that means that you can answer.

19 Were you able to notice or to see that apart from the

20 professional need to send their colleagues, the journalists over there,

21 the Serbian's attitude [Realtime transcript read in error "opportunity"]

22 was also that they could be falsely accused for all sorts of things, and

23 it was in their interest to make it possible for the media to gain access

24 to anything that might be the subject of accusations by the media, in the

25 media?

Page 27404

1 MS. WEST: Objection. Sorry.

2 I think "opportunity" here should be -- I think I heard

3 "attitude."

4 THE ACCUSED: [Interpretation] Mr. Premovic spontaneously said in

5 a conversation with the Defence that he spoke to the head of SRNA and

6 could see for himself that they wanted to send as many journalists as

7 possible there to witness everything because the Serbs felt that they

8 would be falsely accused whenever this was possible.

9 JUDGE MORRISON: Dr. Karadzic, that's not a question. That's a

10 statement.

11 Mr. Premovic, reading the last statement that Dr. Karadzic made,

12 do you agree with the -- that analysis and assertion?

13 THE WITNESS: I can tell you very basically as it was presented

14 to me by, I don't remember the name anymore but he was the -- he was

15 the -- I guess the representative or leader or whatever of S-R-N-A, SRNA,

16 which was I guess the -- yeah, he did tell me they were sending all the

17 available media that they had at their -- you know, at their disposal to

18 Srebrenica before any activities because they were -- there were

19 expecting shenanigans. They didn't -- want to make sure that, you know,

20 they had personnel there to document everything that was going on.

21 JUDGE MORRISON: Thank you.

22 THE ACCUSED: [Interpretation] Thank you.

23 MR. KARADZIC: [Interpretation]

24 Q. Did this correspond to what you knew about false accusations

25 levelled against the Serbs in the media?

Page 27405

1 THE INTERPRETER: The witness is again kindly asked to wait for

2 the interpretation.

3 JUDGE MORRISON: Mr. Premovic, you won't know this, but it is

4 also being translated into French for one of my colleagues so it is a

5 relatively slow process.

6 JUDGE BAIRD: May we have your answer to that last question

7 again, please.

8 THE WITNESS: That's correct.

9 JUDGE BAIRD: Thank you.

10 THE ACCUSED: [Interpretation] Thank you.

11 MR. KARADZIC: [Interpretation]

12 Q. Did you notice that in various circumstances, in the case of

13 various crisis, there was often this phenomenon of crying wolf as we say

14 and because of those false alarms, it was often difficulty to know what

15 the truth was.

16 A. It was very tough to discern what the truth was. Basically my

17 opinion was that the media reporting was false or fabricated.

18 Q. Thank you. When you had contact with me, did you notice that I

19 didn't want the media to be present. Was my attitude in any way

20 different from that of the attitude of the head of SRNA, S-R-N-A, or was

21 your impression that my attitude was in fact similar?

22 A. I would -- I would assume that the attitude was similar.

23 Q. Thank you. Is it true that during that meeting prisoners of war

24 and crimes of any kind that may have been committed in the Srebrenica

25 area were not mentioned?

Page 27406

1 A. When I was there in the first part of July, the dates are -- we

2 are not in agreement on dates, but, to the best of my recollection, I was

3 there on the 4th or the 5th of July of 1995, and at that time, there was

4 no discussions or conversations regarding prisoners or anything like

5 that.

6 Q. Thank you. The meetings you had with me and your colleagues from

7 America and England were, in your mind, friendly meetings, not official

8 ones; isn't that right?

9 A. That's correct.

10 Q. I'd now like to speak about the conversation with General Mladic,

11 or, rather, about my telephone conversation.

12 You said that you thought, or perhaps someone told you, that

13 General Mladic was on the phone. However, you did not recognise his

14 voice because you had never met him; is that right?

15 A. I was under the impression that the voice was of General Mladic.

16 But, no, I had never met the man, nor am I familiar with his voice.

17 Q. Thank you. So is it possible that in a certain sense you assumed

18 that it was General Mladic but that's not something that I confirmed?

19 A. I was under the impression that it was General Mladic.

20 Q. Thank you. Do you remember that during that meeting I spoke to

21 others over the phone, if the secretary put me through to them?

22 A. I remember that one phone conversations [sic].

23 Q. Thank you. At those meetings, did you hear that the Serbian side

24 was ensuring that the civilians and armed forces of Muslim ethnicity were

25 being allowed to pass through, the civilians and armed forces who were

Page 27407

1 leaving Srebrenica? I believe that was in this interview. Yes, page 66

2 and 67.

3 A. When I was there -- when I was there, the conversation was that

4 the army was providing a corridor for the passage of the Muslim army, or

5 the Muslims, or anybody basically, that was going to be heading north on

6 foot.

7 Q. Thank you. Did you also hear that transport for Muslim civilians

8 to the Muslim side was being provided?

9 A. I was told that the buses and the trucks that were heading south

10 when we were arriving in the earlier part of July, there was -- at that

11 time there was a total of 190 buses and trucks that were heading south,

12 that they were there for a population transfer or basically to get the

13 Muslim population transported from Srebrenica to Tuzla.

14 Q. Did you say 90 or 190? Because it says "190." That's the figure

15 someone mentioned; isn't that right?

16 A. Correct.

17 Q. Thank you. Is it true that the treatment of civilians or POWs

18 was not at all discussed?

19 A. From my recollections, this was prior to the -- to the conflict

20 in Srebrenica. This was the preparations for, I guess, the coming

21 conflict, or the attack, or whatever you want to call it. So these were

22 just the preparations for what's coming.

23 Q. That's a problem for us in that we can't determine the exact date

24 of your visit. But, still, is it true that you gained the impression

25 that what was at stake was something that had been agreed on by the

Page 27408

1 parties, that Zepa and Srebrenica should fall rapidly. Did somebody tell

2 you anything to that effect or did you gain that impression? You spoke

3 about that at page 70 of this interview.

4 A. That was my own conclusion that I drew, just because the events

5 were happening so fast that I thought it was a negotiated settlement

6 basically being executed.

7 Q. Thank you. You had lunch in the canteen that was in the vicinity

8 of the Presidency, and you also spoke in a leisurely manner to those who

9 were present there; isn't that right?

10 A. Yes. I had lunch at the -- I guess, the army -- oh, I lost the

11 word for -- I guess the lunch hall. So I had lunch there.

12 Q. Thank you. And there you met a number of people, and you also

13 spoke to some of them; isn't that correct?

14 A. Yes, I was there, and basically I was -- you know, could say, in

15 the presence of quite a few conversations that was going on, so I did

16 absorb information that was being passed -- passed along.

17 Q. Thank you. Do you agree that you didn't meet any members of the

18 military in my office; but in the restaurant, it was possible to see some

19 individuals in uniform?

20 A. That's correct.

21 Q. Thank you. In 1995, was it your impression that the Serbian side

22 was at the end of its tether, as in 1994, and Republika Srpska was under

23 the sanctions imposed by the international community, as well as the

24 sanctions imposed by Yugoslavia?

25 A. Yes. My impressions were basically they were in dire straits,

Page 27409

1 you know. The situation was -- well, there was no -- there was -- there

2 wasn't any supplies of anything. Yeah, it was -- the sanctions and the

3 embargo had its intended affect.

4 Q. Thank you. Did you later find out that I really did support

5 Colonel Pandurevic in his attempts to open up a corridor so that the

6 armed forces from Srebrenica could pass through it and to reduce the

7 intensity of the fighting?

8 A. I'm not familiar with that part. But, you know, could say, when

9 I was there, earlier on, you know, could say, the conversation was about

10 providing a corridor for the people of Srebrenica to pass through this

11 corridor on foot to go to Tuzla.

12 Q. Thank you. Then you left a little earlier than the other

13 visitors, but you went in the direction of Visegrad, not Zvornik, because

14 it wasn't safe in the Zvornik area; isn't that right?

15 A. Yes. The -- I guess the army was intensifying its operations and

16 that, yeah, that -- that -- that direction was closed for my departure,

17 so that the only way that I could leave was to go south to Visegrad.

18 Q. Thank you. During your stay, did you gain the impression that I

19 wanted things to be done in a correct manner, wanted to -- there to be

20 the minimum of victims and incidents. I'm asking you this question

21 because after you returned to America, you heard certain things that

22 weren't in accordance with the conclusions you had drawn through the

23 contact that you had with me.

24 A. My impressions of Dr. Karadzic was that he was genuinely working

25 towards peace and that he was doing everything that he can to bring peace

Page 27410

1 as fast as possible, basically. And my visit in 1994, when he offered

2 everything basically for a negotiated settlement pretty much, you know,

3 could say, what he told Dr. Hatchett was, you know, could say, there were

4 only a few things that are important but mostly this other stuff is

5 unimportant, just, you know, let's make a deal, you know, let's get this

6 over with.

7 Q. Thank you. Was one of the important things the idea that we

8 should have our own entity and that we were prepared to give back

9 territory in the name of peace?

10 A. Yes. You know, even at that time suggested a loose

11 confederation, and I think one of the things I remember was basically

12 having -- having -- the Republika Srpska having its own police force or

13 whatever. Something was said to -- like, three things, but now I'm not

14 sure what they were. Basically they would represent sovereignty. But,

15 you know, could say, I think was its own police force. A loose

16 confederation would be okay. Like I say, very similar to Dayton. So

17 that was offered in 1994.

18 Q. Thank you. I don't think it's been recorded that what was

19 suggested in 1994 and 1995 was very similar to Dayton. And Dayton was in

20 1995, wasn't it?

21 A. Correct.

22 Q. Thank you. And then isn't it true that the first time you heard

23 about people being killed was only upon returning to America?

24 A. I read -- basically what I read in the newspapers about

25 Srebrenica was when I was already out of there, but when I read it, it

Page 27411

1 was -- it was completely contrary to the things that were being prepared

2 for at that time.

3 Q. Thank you. And you couldn't believe that. And did this fit in

4 with your previous understanding of the partiality of the media?

5 A. From all the impressions I had when I was, yeah, that was

6 contrary to all the preparations that were being made by the army of

7 the -- of the Republika Srpska and of everything that I heard that was

8 going on there, because that's exactly what they didn't want to happen.

9 Because SRNA was sending people down there to document everything that

10 was happening. And everything they were preparing for, you know, could

11 say, the opposite happened.

12 Q. Thank you. After that, you had contacts, first of all, with

13 Mr. Trifkovic and other members of the foundation. And Trifkovic

14 suggested that you should testify and that you should tell the truth as

15 much as that is possible. You said that on page 12 of this interview

16 from 2009.

17 A. Yes. I had a call from Srdja Trifkovic. Basically he asked me

18 about the dates because he wasn't sure on the dates either. And I

19 couldn't help him because I didn't remember what exact dates they were

20 either. But did ask me, you could say, about the proceedings and he

21 just -- say -- you know, say what you remember.

22 Q. Thank you. And he also told you that he would testify. And then

23 did he tell you after he did, that he did testify?

24 A. He told me that he was asked to testify, but that was the last.

25 I wasn't familiar with his testimony or anything afterwards.

Page 27412

1 Q. Thank you. And is it correct that you acquired information that

2 a certain Jovanovic was in possession of a film tape or an audiotape of

3 the events in the bread line, parts that were not broadcast, a footage

4 that was not broadcast?

5 A. That is correct. A journalist, Vuk Jovanovic, basically a --

6 anyways, who I knew told me that he bought the excess taping of the

7 bread-line massacre of what wasn't used -- of what wasn't used on the --

8 on the news broadcasts, and he bought the excesses and he did give me a

9 copy of that tape.

10 Q. Thank you. You looked at the tape and you noticed that there

11 were old corpses that were already rigid and there were also some other

12 inconsistent details there.

13 A. Yes. I saw the tape, and basically on the tape there was, you

14 know, could say, you know, there was tape -- there was film of bodies

15 that were quite old being carried into positions, and, you know, anyways,

16 bodies that were already stiff, I guess. They were quite -- whatever the

17 term is rigour mortis, or whatever. But basically, yeah, they were quite

18 stiff. They were being carried into positions and carried on and off,

19 whatever.

20 Q. Thank you. And could that possibly be the Markale I incident in

21 1994, or is that the bread line?

22 A. To the best of my recollection, that was the incident that --

23 that -- that was the -- the -- I think that was the incident where the

24 grenade -- the grenade -- supposed grenade exploded from Bosnian Serbs

25 positions in the market-place. I'm not quite positive. I think that was

Page 27413

1 the tape. It was the second -- the second massacre.

2 Q. Thank you. You assume that. Do you have this tape perhaps in

3 Texas?

4 A. I may still have it. But I'm not -- I'm not sure that -- I

5 haven't seen it in a very long time.

6 Q. Thank you. Is it correct that in 2008 in Switzerland in Lugano

7 you met Manuel Warmley [phoen] and are you able to tell us what he

8 informed you about?

9 A. I was in Switzerland on business, and I was waiting for a

10 business meeting and a gentleman walked in also and was waiting jointly,

11 and when we started talking -- and basically he told me that -- actually,

12 we just started talking. This was in 2008 and this was just around the

13 time that the -- that the Georgia conflict flared up in Russia, and at

14 that time, we were just talking about and he told me that he was in

15 charge of the UN security for UN personnel in Georgia so I was -- and I

16 was very interested in what was happening at the time as soon as we

17 started talking about it. And that conversation led to him telling me

18 that he was also very involved, or was very involved in the ex-conflict

19 in the former Yugoslavia and that he visited all the trouble spots at

20 that time, Serbia, Bosnia, Kosovo, Croatia, everything, and that he was

21 also exchanged as a prisoner for, I guess, could say, some Serbian

22 general. I don't remember what general, but he told me that. But, also,

23 we were discussing the -- the -- excuse me, I don't know, you know, could

24 say how it's -- you know, but the grenade attack on the, you know,

25 bread-line massacre, whatever it's called, anyways it was the grenade

Page 27414

1 attack, and he told me that he personally investigated that -- that

2 incident and I told him that I didn't think it happened the way it

3 happened. And, anyways, after talking about it for quite a while, he

4 said that, no, it didn't happen by grenade, that basically their

5 conclusion was that it was -- what they called a Bosnian TV that was

6 placed -- there was some sort of mine that was placed there and that's

7 what caused the attack -- or that's what caused the massacre.

8 They called -- excuse me. They called the mine itself -- their

9 terminology was it was called the Bosnian TV. So I guess it's the way it

10 looked or something but that was -- the mine that was used was -- they

11 called a Bosnian TV.

12 Q. Could that have been the second, or, rather, the third incident

13 if the first one was in the Vasa Miskina Street, the second one in

14 Markale, and the third one in Markale, could that have been this third

15 one after which NATO bombed the Serbs in Bosnia and Herzegovina?

16 A. The one I'm talking about is the artillery that was supposed to

17 lobbed off over the tall buildings because we'd -- I'd remember

18 discussing with Manuel, you know, basically, that the way that the city

19 with the buildings and everything else basically that that -- it was

20 parabolically impossible to launch a projectile in the way it was told,

21 so that was the one that was -- it was -- it was an artillery attack so I

22 don't know which one that is as you describe it one, two, or three, but

23 that was a -- it was an artillery attack as it was reported.

24 Q. Thank you. Do you remember that this conversation which gave you

25 the impression that occurred between Mladic and myself, do you recall if

Page 27415

1 I was the one who made the call or was I one who received the call,

2 whoever was at the other end of the line?

3 Did I make the call, or was I called?

4 A. The call -- the -- you were -- you know, the call came in and you

5 answered the call, and my impressions was basically it was a -- it was

6 just a battle form report. It was a -- matter of factly, this is what

7 happened and this is what transpired, and it was a matter of -- it was

8 just, you know, it was a matter of -- there was no hysterics. It was

9 just basically -- it was just a cold battle report. Nothing special and

10 the only thing that -- that kind of stayed with me from that conversation

11 was basically at the end of the conversation, there was some promotions

12 that were mentioned of some people that fought bravely in the -- at Zepa.

13 My impressions were that it was in Zepa. And what stayed with me was

14 basically there was a general there that fought -- there was a one-legged

15 general that fought very bravely and he was promoted, of my

16 recollections.

17 Q. Is it possible that this was General Krstic who was, at the time,

18 taking over the command of the Drina Corps? Because he was the only one

19 who lost a leg.

20 A. I just remember it was -- the reason it stayed with me because

21 basically it was somebody, a one-legged general, that basically fought in

22 the conflict and basically he got promoted. So that's -- that's why this

23 stayed in my memory and a lot of the things just -- I lost. But that was

24 something that just stayed with me because it was a one-legged general.

25 Q. Thank you, Mr. Premovic. It is not my custom, but I am going to