120503IT

Page 28427

1 THE WITNESS: Well, we know each other from previous --

2 [Interpretation] I'm sorry -- [In English] we know each other from

3 previous case. Well, sir, you are commander here, so you do -- I am

4 Dr. Petrovic.

5 JUDGE KWON: Thank you.

6 THE WITNESS: But it is your choice, sir.

7 JUDGE KWON: Yes. Thank you, Dr. Petrovic.

8 As you noted, your evidence given in the case of Popovic et al.

9 was admitted in lieu of your examination-in-chief, and then now you will

10 be further asked by Mr. Karadzic in his cross-examination.

11 THE WITNESS: Yes, sir.

12 JUDGE KWON: Yes, Mr. Karadzic.

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

14 morning, Excellency. Good morning to everyone.

15 Cross-examination by Mr. Karadzic:

16 Q. [Interpretation] Good morning, Dr. Petrovic.

17 A. Good morning.

18 Q. I have to remind both you and myself to be careful to make pauses

19 because it seems that the interpreters are angry with me with forcing the

20 pace.

21 A. Mr. President, one sentence, if possible. Due to technical

22 reasons, I would like to congratulate you on the 20th anniversary of

23 Republika Srpska because without you, to a great extent, the Serbs

24 wouldn't have had their state.

25 Q. Thank you. And through you I would like to congratulate you on

Page 28428

1 the international day of journalists, and that is today.

2 A. And also it's a volunteers day.

3 Q. Yes, we have another jubilee today. And with the Chamber's

4 leave, I would like to ask you something else.

5 THE INTERPRETER: Could the speakers please pause between

6 questions and answers.

7 JUDGE KWON: Mr. Petrovic, Dr. Petrovic, please put a pause

8 before you start answering the question because bear in mind the

9 interpreters. Thank you.

10 THE WITNESS: Yes, sir.

11 MR. KARADZIC: [Interpretation]

12 Q. If I may suggest, you should probably look at the transcript and

13 once you see that the interpretation is over, you can start your answer.

14 A. [Interpretation] Thank you, Mr. President.

15 Q. Let me ask you this: You knew a lot about the political life in

16 Bosnia and Herzegovina and how the conflict started; is that correct?

17 A. That is correct, Mr. President.

18 Q. I'm not going to ask you about any political issues, however, but

19 what you as a journalist could find out at the time.

20 Is it correct that with respect to the zone around Srebrenica you

21 had some partially knowledge, and is it true that you found out that on

22 the 29th of August, 1992, a captured Serbian soldier, captured in

23 Podravanje, Muslim soldiers roasted him on a spit?

24 A. Yes. Even in a book wrote [as interpreted] by a group of

25 authors, I published this photograph. It's a man whose name I shall

Page 28429

1 remember for as long as I live. He was born in 1958, and his photograph

2 exists. He was roasted on a spit in 1992 on the 28th or 29th of August.

3 What is interesting about this photograph is that it shows what

4 kind of war that was. I have to admit to you now that I practically

5 stole this photograph from Republika Srpska. I had some people who were

6 able to extract that from the archives. I'll call them insiders because

7 the principle of the JNA was still in force and the notion of brotherhood

8 and unity was observed. Therefore, this photograph was considered a

9 military secret. But I stole it and I published it this book, and that

10 is why you know about it now.

11 Q. Was that photograph part of the investigation material that was

12 not conveyed to the public?

13 A. I didn't know the status of this photograph either at that time

14 or today. I only found out its location. I managed to find people who

15 had enough courage to get hold of this photograph for the sake of the

16 truth. But it was totally out of the civilian reach, or the reach of the

17 government.

18 Q. Thank you. Quite early, you had an insight into the presence of

19 foreign elements in our civil war, particularly those who came from

20 Muslim countries, and I'm talking about the Mujahedin.

21 Can you please tell the Chamber, how did you find out about the

22 presence of Mujahedin? And then especially how did you learn about the

23 presence of Osama bin Laden in Sarajevo and his encounters with

24 Mr. Izetbegovic?

25 A. These are two things. Osama bin Laden didn't come immediately,

Page 28430

1 as far as I know. Initially there were only small volunteer groups

2 coming from various Islamic countries led by a few commanders who had

3 experience from Afghanistan. They are called Afghan Saluni [phoen].

4 These are the best and most seasoned combatants. And that is what I

5 heard about them, in addition to them being the fiercest and the most

6 merciless fighters that Izetbegovic had at his disposal during the war.

7 They appeared, according to my information, because, at the time,

8 I worked for a small independent news agency called INA in Belgrade and

9 had problems in dissemination this kind of news, because the official

10 policy of Belgrade was still not to publish them in order not to disturb

11 the western countries; because at the beginning of the war, NATO pact was

12 providing considerable assistance to these combatants and to

13 Mr. Izetbegovic's army in general, not so much by interfering but,

14 rather, by allowing various things such as the use of the Tuzla airport

15 for a major air transport of various ammunition and weapons that had been

16 coming from Iran because they were allies with Iran at the time, and I

17 also know that Turkish aircraft landed in Tuzla as well.

18 So my news agency acquired information through, I have to say it

19 here, some Israeli journalists, people from Israel who had close

20 connections with their intelligence services, but also through a number

21 of Serbian businessmen who, due to the nature of their work, knew more

22 than ordinary businessmen. So we put together this puzzle of the

23 presence of Islamic fighters there.

24 I have to say that at the time I worked as a commentator on B92

25 radio station, and this information that I broadcast over the radio

Page 28431

1 caused hilarious laughter among the majority of journalists, albeit not

2 all of them, because nobody ever spoke in Europe before that time about

3 the arrival of Mujahedin to Bosnia. I'm talking about the summer of

4 1992.

5 I can speak more about this, but I'll make it short.

6 Anyway bin Laden was detected. Beforehand I had some hints, but

7 nothing tangible. I knew that bin Laden was organising his men to help

8 his brethren in Bosnia, his brethren by religion. But I didn't have any

9 solid evidence to that effect. I heard this information in a

10 conversation that I had with a female journalist, a German journalist

11 called Renate Flottau, and I mentioned her in my previous testimony. She

12 was an official correspondent. She was a first-class or a first category

13 journalist. Due to that, she had access to, most of all, the most

14 important political figures in Yugoslavia, and, as far as I know, she

15 even had contact with you and, of course, with

16 President Alija Izetbegovic.

17 So in that conversation, she confirmed to me something that she

18 had already mentioned to one of our former correspondents from Germany -

19 I cannot remember his name at the moment, although he is a prominent

20 journalist, and I apologise for that - so I was the second person who

21 heard this information and made it public; that is to say, I published it

22 in a book about Al Qaeda which was printed in 2002. Nobody including

23 from Bosnia ever refuted this, and Madam Flottau, before she entered the

24 office of President Izetbegovic, told me that she had seen this man, this

25 man two times. She described him as being rather talkative and wanted to

Page 28432

1 attract attention. When I asked her why didn't she publish this because

2 I would have been the happiest person in the world if I had an

3 opportunity to interview him, she said something to the effect that

4 nobody in her editorial office would take it seriously. They would think

5 that that was a case of a lunatic talking about a variety of things. But

6 being a professional journalist, I still find this to be quite odd

7 because I would definitely mention this person in any of my writings.

8 On the other hand, it shows that Madam Flottau was a highly

9 respected journalist in Germany, and I'm sure that if she managed to

10 interview bin Laden, that would stir great excitement all over the world.

11 I'm sure of that.

12 This little detail is important because of the location. She saw

13 him later on conversing with Mr. Izetbegovic. I have to tell you that I

14 don't know whether it was in 1993 or 1994. You'd have to ask

15 Madam Flottau about this. And he wasn't as famous at the time as he was

16 later, but everybody knew about Afghan fighters. And the proof that I

17 was right when I spoke on B92 about this, because about a month later on

18 that same radio, B92, the English press, I think that was "Sunday Times"

19 published an interview on two or three pages with one of the first known

20 leaders of Islamic volunteers. I still cannot remember his name, but I

21 think that he stayed the longest in Bosnia after the war.

22 Now, all of this was something that wasn't taken into

23 consideration during the war, who was in league with whom. This fact

24 relating to bin Laden didn't -- wasn't taken into consideration until the

25 appearance of the information that was conveyed to me by Mrs. Plavsic and

Page 28433

1 I wrote about that in "Nin" magazine; that is to say that the Serbs had

2 bought this videotape from some Croats for about 20- or 30.000 German

3 marks and that was the first time that everybody could see what they

4 were -- what they were doing in Bosnia.

5 However, this tape was only being played after 9/11 on numerous

6 occasions, and it shows some of -- shots from the NATO offensive with

7 El Mujahid Brigade attacking fortified Serbian positions on Mount Ozren.

8 I also find it resentful that Republika Srpska failed to make use of it

9 because, on that occasion, depleted uranium bombs were used, because that

10 was the only way that they could have done anything against the Serbs and

11 I think that this lasted for ten days.

12 Q. We have to -- to leave this subject. We don't have enough time.

13 A. Well, this refers to bin Laden.

14 THE ACCUSED: [Interpretation] Your Excellency, if we have time, I

15 would be glad to hear what Dr. Petrovic has to say about everything.

16 JUDGE KWON: Please bear in mind your motion, Mr. Karadzic. You

17 asked for this witness to be called for certain purpose.

18 Please move on, Mr. Karadzic.

19 THE ACCUSED: [Interpretation] Thank you.

20 MR. KARADZIC: [Interpretation]

21 Q. May I ask you this, Dr. Petrovic: Is it correct that the Bosnian

22 war was not a first war for you. You had some previous experience. And

23 can you tell us which wars you had an opportunity to see and if you can

24 draw any parallels between them.

25 A. Mr. President, from 1979, which is 13 years before the war in

Page 28434

1 Bosnia-Herzegovina, I was a reporter from Nicaragua with a colleague of

2 mine. He was the only freelance journalist from that part of the Europe.

3 Of course, there were journalists from the "Politika" daily, Tanjug,

4 et cetera. That was my first war experience. I witnessed some very

5 turbulent events, such those in Poland, but that was not war. Then in

6 1985, I was in Lebanon. And I was stuck there, if I may say so, for many

7 days, because after ten days upon my arrival, I and my cameraman were

8 arrested and we were kept somewhere in the mountains of Lebanon.

9 After that, I went to Israel because Israel has been in a state

10 of war for decades and I covered various events from Israel, both

11 political ones and conflicts.

12 I also participated in our civil war as a reporter.

13 In a nutshell, I can say that I was present at major points of

14 conflicts such as Vukovar, Stolice at Mount Majevica near -- then in

15 Sarajevo, Dobrovoljacka street, and the environs of Srebrenica. That

16 would be in a nutshell.

17 As for the similarities, after I left Lebanon in 1985, I wrote

18 about my impressions, and in a way, I predicted what was going to happen

19 in Yugoslavia because there was a multi-ethnic situation in Lebanon as

20 well and then the ensuing war, although, let me remind you, that you

21 never declared a state of war in the whole of territory, which in my eyes

22 was a mistake. Wars were often waged according to the Lebanese model.

23 Village A against village B, then village B against village C, and that

24 was endless fighting in which neighbours were killing each other. And

25 for me, that was a striking similarity.

Page 28435

1 Q. Thank you. I'd like to move on to July 1995, but if time remains

2 today, I'd like you to tell us a bit about the Dobrovoljacka street

3 incident.

4 Were you with JNA column that was pulling out?

5 A. Yes, that's true. And you can still find the issue of the "Duga"

6 bi- weekly magazine. I published an article there called: "The war in

7 Sarajevo," with a special chapter called: "The convoy," where I

8 described very much in detail my experience.

9 Q. Thank you. You've made attempts to go to Srebrenica as a

10 journalist in July 1995. Could you tell us very briefly about all the

11 things you had to go through, all the hoops you had to jump through to

12 get there during the war.

13 A. Mr. Nicholls mentioned it. It's already in my evidence from

14 before, but I can repeat briefly. I'm already tired of repeating these

15 things.

16 Any journalists wants to go where the action is, and Srebrenica

17 had been attracting the attention of the international public for years

18 by then. Some people had tried to get into Srebrenica with the Americans

19 when the food was being brought to people in the town.

20 I apologise.

21 On the 11th, I found from the news, like all the other

22 journalists, that Serb had entered Srebrenica. I got in touch with

23 Studio B immediately because I worked as a war reporter throughout the

24 war working with the French television ITN, and I agreed with the

25 editor-in-chief, or, rather, the programming director of Studio B,

Page 28436

1 Mr. Oganovic, but unfortunately did not manage to get a camera from them

2 because it was a rather poor television station that did not have enough

3 equipment, cameras or editing equipment. So, in the end, I took with me

4 an 8-millimetre video camera, the kind tourists have, plus I'm not a

5 professional cameraman and I know nothing about the filming, the quality

6 of the image or anything. It was a disaster that it was the only thing I

7 could do because I could not bring a cameraman. And then I went to the

8 border, to the bridge leading to Bratunac on the Drina river, and I was

9 turned back from there. That was on the 12th. I was turned back because

10 they said the operation was ongoing. It was a war zone. Nobody,

11 including journalists, could get access until the operation is over. And

12 the operations were planned to last for another two weeks and they did.

13 So I went back to Belgrade to the police brigade, and I found

14 Colonel Borovcanin and told him that, among other things, I placed a call

15 to the VRS, a man of whom I have a bad memory, Colonel Milutinovic, who

16 told me, tongue in cheek, Pirocanac, it is not against you personally but

17 we'll arrest anyone who shows up there while the operation is underway.

18 So I asked Borovcanin, whom I knew from before, I had been with him at

19 Mount Majevica and Semizovac, and they knew my professional record. I

20 was a journalist of some renown, if I may say so, and he agreed to take

21 me on the 13th.

22 Mr. Nicholls knows that there was a problem with dates.

23 Sometimes the date indication on the film would disappear when I pressed

24 the wrong button, and it -- but the film shows that I was at the Dutch

25 compound on the 13th. Those are the first images.

Page 28437

1 I must say, Mr. Borovcanin agreed immediately. He didn't put any

2 conditions. He didn't impose any restrictions. He just said, You know

3 your job. You can film anything.

4 And that's exactly what happened. And it was thanks to this

5 honest man, Mr. Borovcanin. Thanks to him the Court has these very

6 valuable images. And I'm not sorry, although I went through hell because

7 of this film. Many images on it have been deleted.

8 Mr. Nicholls mentioned it. Perhaps at one point, this Court

9 received my original film of 28 minutes with a logo of the Studio B and

10 then it disappeared. How could it have disappeared from the locked

11 cupboard of the programming director? That's the only tape that ever

12 disappeared from the Studio B. I'm inclined to think that somebody stole

13 it and sold it, or perhaps the programming director himself who had

14 family connections with the military somehow made it available to the

15 military intelligence. But I dubbed the film on a VHS tape and sent it

16 to some family in Canada, and that saved me because that original film

17 contains all the so-called vanished images from my raw material, and that

18 raw material is also historic, a precedent, because this tape made the

19 rounds among the journalists and the public. I made it available to

20 everyone. But I will perhaps even sue the SENSE agency that works here

21 in the building. They have been using it for years and making money on

22 it. It's time, perhaps, for me to get finally rich, and I believe this

23 Court should be eternally grateful to Mr. Borovcanin that he let me go

24 there without any censorship; because, if they had plans to commit any

25 killings, they would have killed me immediately. I have been saying this

Page 28438

1 for years. They would have liquidated me if they had any criminal plans

2 at the time; or, why would they have engaged somebody from the outside

3 when they could have done the filming themselves?

4 Q. Let's stay a bit with the Colonel Milutinovic. Is that the

5 Colonel Milutinovic who was chief of the army press centre and who made

6 his own films in Srebrenica? And did you understand that perhaps he was

7 protecting his monopoly by refusing you access?

8 A. It turned out that among the NGOs that were helping when the

9 Muslims were leaving for Tuzla, and very soon, 28.000 of them left

10 immediately. There was a journalist, Rohl Havim [phoen]. He simply

11 infiltrated himself there.

12 Q. Can I ask you to speak more slowly so that everything is

13 recorded.

14 A. Among those people, there were at least several western

15 journalists. I was not the only one there. There were several reporters

16 from Serbia who got in. But I was perhaps more of a celebrity than most

17 of them, and perhaps they didn't want me to come more than anyone else.

18 One of these agencies characterised my reporting as hearsay, but they

19 can't understand that it's very difficult to know everything. I know

20 that a lot of material turned up in various trials here gathered by

21 members of the VRS. And that's natural because there was a service

22 responsible for such things in the VRS. How was this filmed during the

23 war? How did it find its way to various lawyers in this Tribunal? We

24 don't know. But he belonged to Mladic's staff, and he had a free hand in

25 many ways. He was a very influential man. Based on the fact that he had

Page 28439

1 influence, you can draw a lot of conclusions but I didn't do that myself.

2 Q. Was there also a Swedish reporter in Srebrenica at the time? I

3 don't know his name, but I see that you mentioned a Swedish reporter in

4 the Tolimir case, page 14485.

5 So it was possible to get there in various ways?

6 A. That's true. I believe there were no less than ten reporters

7 there. I never managed to find out, and due to the trauma I experienced

8 over the Srebrenica case, I didn't properly try. I never managed to

9 write a book about Srebrenica which is a shame. It would have been

10 better than most that had been published. But I heard from various

11 colleagues in Belgrade there had been a Swedish journalist there. I

12 don't remember the name I was told. But if a team were to work on it,

13 they could look through all that was published in the Swedish press at

14 the time, including interviews with Bosnian people who made their way to

15 Sweden, who were sharing their fresh impressions. It was authentic

16 reporting. People had -- were still in shock from all the fighting that

17 was still ongoing, the heat, the travel. You could certainly find his

18 name there.

19 Why did I mention him? In all these texts that I published, I

20 made a claim, making a mistake concerning time. I mentioned

21 24th of July. I described the operation that was never covered in our

22 media; namely, that the Muslims who had descended from Srebrenica

23 regrouped in that area in a -- into a wedge one night. I said

24 21st, 22nd, 24th, but it must have been the 13th or the 14th. And there

25 was a great danger that they could start breaking through, not simply

Page 28440

1 straight to Tuzla but turn right and reach Zvornik, which was a town of

2 strategic importance on the border with Serbia on the Drina river and

3 that would have been a turn-around in the war. That was cause for great

4 fear among the Serbs who were always short of people, and I was told that

5 several thousand of Muslims died then. And your own police brigade

6 suffered the greatest losses that night, lots of dead and wounded.

7 Somebody told me there were 88 dead, and somebody told me those were the

8 highest losses of a professional unit like that through the whole war and

9 lots of others had told me that they barely survived it - that's why I

10 remember it - and the journalist.

11 Q. I'll try to clear up a few things, and I hope you will be able to

12 answer very briefly, perhaps with a yes or no.

13 Is it true that you never felt that the civilian authorities, and

14 Borovcanin and his unit were part of civilian authorities, had any

15 reservations or were trying to prevent your presence in that zone?

16 A. Coming back to what the army said that I shouldn't go there and

17 that if I was found there I would be arrested and my agreement with

18 Borovcanin that I would be able to film that on the sole condition that I

19 should stick to him, not because he wanted to check what I was filming,

20 but in order not to be arrested by the army. I must say that that's what

21 the army told everyone. Nobody ever asked me any questions or tried to

22 stop me from filming, as long as I was near Borovcanin. But it's true

23 that I would have been arrested by the army as soon as I arrived,

24 probably at the border.

25 Q. Do you remember that a few weeks later, in Zepa, there were

Page 28441

1 journalists present, and I personally enabled Peter Arnett from the

2 American TV station, ABC, I think, and do you know that the agency Crna

3 was planning to send foreign journalists into all these areas as soon as

4 the fighting stopped; in other words, did the authorities or the police

5 want journalists there, actually, to avoid mystification?

6 A. I did not go back to that area, but all of us journalists in

7 Belgrade knew that many foreign correspondents had gone to Zepa. We knew

8 these people. They were based in Belgrade. And nobody was hiding

9 anything. And it would have been very stage for journalists to have been

10 allowed to go there and film while there was a genocidal plan in the

11 making. I never had any indication of that from all the talk I had with

12 these people, with these foreign journalists with whom we shared a press

13 centre.

14 Q. You said earlier today and in your earlier testimony, but please

15 confirm once again, Colonel Borovcanin did not impose on you any

16 restrictions, in terms of features you were allowed to film, or your

17 choice of theme and what you could film.

18 Is it true that you had complete freedom in that respect?

19 A. That's correct, Mr. President.

20 It was a relationship of mutual respect and openness based on two

21 prior occasions when we had gotten to know each other at Majevica which

22 was a very important communications hub and there was a lot of fighting

23 around it. Serbs were surrounded, encircled, near the repeater. The

24 photographer from our crew didn't dare to go there, but I went, and I saw

25 those Afghan fighters shouting, Takbir, takbir. It was a frightening

Page 28442

1 sight. There was a very small unit there, but they must have told

2 Borovcanin later about my demeanour, and I didn't make any problems for

3 them in the field. I wrote very honestly about everything, and that was

4 guarantee enough for him. He did not -- did he not worry about me at

5 all, except -- except for not wanting me to get arrested.

6 Q. Please speak more slowly.

7 A. I'm sorry. I hadn't been here in a while.

8 Q. I want to ask you a few things which were the reason why I called

9 you here. Did you meet the journalist called Robert Block?

10 A. My first association concerning him is something that is probably

11 improper to utter here. But, briefly, I would say that he was a

12 dishonourable person and a dishonourable reporter. I saw him for maybe a

13 minute, not longer, in Bratunac. But I think it is very important, if

14 you allow me to continue. In a situation when Milutinovic told me that

15 he was going to arrest me, including all the other journalists, because

16 Milutinovic had nothing personal against me. That was the position of

17 the command. I was completely stunned in that situation because I saw

18 this man in Bratunac, Bratislav Grubacic, who used to work for the Tanjug

19 press centre. I asked Bratislav, How come that you are here? And he

20 answered by saying something which is more than ridiculous, and he knows

21 it was a ridiculous answer, and he said, Well, we were a little bit

22 travelling around Bosnia and we dropped by to see what was going on here.

23 In my opinion, this is a imbicile sentence.

24 I apologise for using this term. And I don't remember us

25 discussing anything else apart from this. Maybe we exchanged a sentence

Page 28443

1 or two more and then they left. They were foreigners but they were never

2 arrested by army. Also important is that in an article by Michael Dobbs,

3 a respectable journalist, published in the foreign policy journals where

4 he analyses the case of Kravica, and I saw that he said in this article

5 that Block had been in Studio B after his arrival, and that he was

6 reviewing my pre-edited material, which is something unheard of. And

7 everything that Block wrote about, starting from the 15th or 16th of

8 July, were mainly lies, because he was the one who set rolling this story

9 about genocide in Srebrenica. I think he was one of the key people

10 entrusted with this task.

11 I cannot give you an exact quote, but I remember him mentioning

12 one thousand people killed in a school in Bratunac which is total

13 rubbish. And later on it turned out to be real rubbish. So that's the

14 kind of journalist that he was. So I despise him. I especially resent

15 his statement that he had visited me in my home. The then-girlfriend of

16 Bratislav Grubacic was there. She was a secretary at the Dutch embassy

17 in Belgrade, and she is today the wife of the ambassador to Zagreb. He

18 was a member of the delegation of the Dutch Royal Institute but she

19 misrepresented her position. That is the story.

20 Q. So his claim that he visited you and that you gave him the tape

21 and that you discussed this topic at all is untrue?

22 A. It is absolutely untrue and dishonourable.

23 JUDGE KWON: Yes, Mr. Nicholls.

24 MR. NICHOLLS: His claim that you gave him the tape. What does

25 that refer to? Can I have a cite, in the last question?

Page 28444

1 I don't recall --

2 JUDGE KWON: Yes, Mr. Karadzic --

3 MR. NICHOLLS: -- Mr. Block saying that Mr. Petrovic-Pirocanac

4 gave him a tape. I may be wrong, but I'd like a cite.

5 JUDGE KWON: Did Mr. Block say that Mr. Petrovic gave the tape to

6 him?

7 THE ACCUSED: [Interpretation] I'm sorry. I think I am mixing up

8 Blasik and Block.

9 THE ACCUSED: [Interpretation]

10 Q. Block stated here that he had been at his home, that he discussed

11 the situation, that he heard something from Mr. Pirocanac. And I'm going

12 to ask Mr. Pirocanac whether that was correct or not, and I apologise to

13 Mr. Nicholls for being inaccurate.

14 MR. KARADZIC: [Interpretation].

15 Q. You can freely speak in Serbian for the sake of our public.

16 A. Your Honours, this is my third testimony in The Hague, and I

17 never told untruth in any of my answers. It is utterly senseless to

18 speak something like that. I would like to state clearly that this man

19 is a liar. He's not telling the truth.

20 The only explanation I can think of is that he is re-telling the

21 story about the journalist whose wife was Dutch and then on the Internet

22 he said that I abruptly ended this conversation. This Dutch journalist

23 is using this raw material also and he is trying to find out what many

24 people in Belgrade found out and claim that I erased some of my footage.

25 But he must know that there is an original programme, and this Court

Page 28445

1 knows that as well because it contains all these missing fragments and

2 probably Block is confusing this situation. It is this Dutch journalist

3 with a local cameraman, and this can be testified to by my family and by

4 this cameraman. But Block never visited me at my home. We just greeted

5 each other in Bratunac, and that was the only time we met, and I really

6 wouldn't wish to have him as a friend. He is a liar.

7 Q. First of all, let us establish the following: So what was

8 broadcast in the programme and what this Court has in its possession

9 contains each and every scene and each and every frame, including

10 everything that is missing from the raw material?

11 A. That is absolutely correct. That's the white house and the two

12 or three seconds before Kravica, which was shot from the moving car.

13 But there's another footage, ten or 15 seconds, about Sandici.

14 There is no dispute about that. And this footage of Kravica and

15 Bela Kuca [phoen] was invaluable for this Court.

16 Q. Mr. Block said here that you had told him that you had enormous

17 problems that even I was angry because you had gone to Srebrenica to

18 shoot your film; is that correct?

19 Did you have any impression that either I personally or our

20 entire leadership, including Mr. Krajisnik, held it against you? Did you

21 have any problems with us?

22 JUDGE KWON: Just let -- let it go for the moment. Yes.

23 THE WITNESS: [Interpretation] Two things. I remember that

24 Studio B was asked by the leadership of Republika Srpska to have the

25 programme shown to them. Someone sent it by bus. I mean, bus was the

Page 28446

1 only way of communicating. It's not really that many people travelled to

2 Bosnia then. So they did not have -- I mean, there were no negative

3 reactions. Absolutely none. No one from the leadership of

4 Republika Srpska reacted in a negative way. I don't know whether you

5 viewed it then. I don't think so. But the other leaders did view it,

6 all the top leaders.

7 Secondly, I interviewed you three times during the war. Our last

8 encounter was in your house in December 1994. In 1995, I didn't see you

9 as all, and, as far as I can remember, I didn't even speak to you. I

10 don't know what the date was when the UNPROFOR soldiers were taken

11 prisoner. I intervened for a Spanish diplomat, but I did not have any

12 contact with you. And everybody would have told me had you minded

13 anything and if you were angry in any way.

14 So that's an absolute lie. I don't know. Nowadays, good

15 journalists can be great liars, although that is pointless.

16 JUDGE KWON: Just a second, Mr. Nicholls. Yes, I'll hear you

17 now, Mr. Nicholls.

18 MR. NICHOLLS: I withdraw it, Your Honour.

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

20 MR. KARADZIC: [Interpretation]

21 Q. Did you hear about me being angry at Milutinovic? And that what

22 I was angry about was because he was doing Mladic a disservice and

23 portraying this as his victory, neglecting Krstic, and I even heard

24 rumours to the effect that he had sold some footage.

25 Did you hear any of that, that perhaps I was angry at him? I

Page 28447

1 spoke about that at an assembly meeting but not because of the actual

2 recording but because of this self-promotion and lack of impartial

3 reporting?

4 A. Mr. President, I really cannot help you with that, as far as the

5 selling of the cassette is concerned. I don't know what people were

6 saying about me as well, that I had sold my things to God knows who. But

7 among the journalists who were following the war in Bosnia-Herzegovina,

8 this was often mentioned, that people from the military were actually

9 doing the recording but I don't have any proof of that.

10 However, I have to say that you were popular among journalists.

11 You were considered to be an open man, and I remember that you criticised

12 the army through that press service of theirs because of the way in which

13 they acted. Often, they were actually doing Mladic himself a disservice.

14 Today I think that that was no accident, that all these disservices were

15 done, and that there were people who had to do things like that to him.

16 Q. I'd like to ask you about these restrictions, as far as

17 journalists were concerned, close to the front line.

18 In these other wars, did you also notice that commanders do not

19 want journalists close to the front line, or was that only the case in

20 our war?

21 A. Mr. President, this behaviour changed during these wars and as

22 time went by; for example, in Lebanon when I first reported, the Israelis

23 wanted you to sign a piece of paper first, taking upon yourself the risk

24 that you did run of being killed at the front line. As far as I can

25 remember, your people did not ask for that, but journalists were

Page 28448

1 everywhere. I know what your position was towards Martin Bell and

2 Christiane Amanpour. Many times, they managed to do things that Serb

3 journalists could not do. Since this is a war where there was no uniform

4 position -- I mean, having a state of war declared throughout the

5 territory, then there were different regional improvisations on the

6 ground. Commanders, officers, the civilian authorities during this state

7 of war, and so on and so forth. So I did not notice any kind of uniform

8 behaviour, except for the fact that you always asked to have everything

9 given to journalists. And that's how I managed to work, too. And it

10 wasn't only me. It was French TV, for instance, TF1. You allowed them

11 to do a great many things.

12 I don't know whether this is a satisfactory answer.

13 Q. Yes, that is what I was interested in, whether it was only we. I

14 know that soldiers were suspicious, and I believe that that's the way in

15 any army. I just want to know whether that was a uniform sort of thing.

16 I wanted to remind you of something that you said in your

17 interview with the OTP on the 28th of February, 2006.

18 THE ACCUSED: [Interpretation] So could we please call up 1D5633.

19 And then the page is 112. The English version. I think it's all in

20 English. I don't even know whether we do have a Serbian version.

21 Yes, it seems that we have the Serbian version too. I don't know

22 whether it's page 112 in Serbian as well. In English, I do know it's

23 page 112, line 17. It starts with line 17 on page 112 in English.

24 So can we take a look at that.

25 There's a reference to Milosevic.

Page 28449

1 MR. NICHOLLS: Your Honour, if I can help Mr. Karadzic, I think

2 it may be page 115 in the English, speaking of e-court pages.

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

4 MR. KARADZIC: [No interpretation]

5 Q. [In English] [As read] "I just can suppose that in this field of

6 Milosevic was still in power. Somebody came and it was astonishing, but

7 what is important also that the leadership of Bosnia, Bosnian Serbs,

8 Krajisnik, and others asked Studio B and me to send them a copy, the same

9 as the next day it was aired. And I remember -- and I know the guy, his

10 name is Zoran - he is now on "Politika" - he could confirm that we sent

11 by bus copy to them, to Pale. They were still together. I don't know if

12 Karadzic saw it but most of them saw it, and there they -- if you ask

13 Krajisnik now if he remembers that, that it was very well done."

14 [Interpretation] So did you get any feedback from the authorities

15 of Republika Srpska to the effect that your work had been done properly

16 and that there were no objections raised?

17 A. Yes, Mr. President. For example, that's a detail that I cannot

18 recall with precision after so many years. But I know that, number one,

19 there was no public reaction; and, secondly, some journalists from Pale.

20 Now was it someone from television or these cameramen who work for

21 foreign crews - there were some cameramen who worked for AP Television

22 and I should also sue them on account of this footage - I don't know who

23 it was who said that to me, but they said that people were satisfied.

24 Just a small correction here. I guess it's my fault when I

25 talked to Mr. Nicholls in Belgrade about this. I see this document here.

Page 28450

1 I think that I made a mistake there. I think that they had seen the

2 programme. Someone from Belgrade had told them about the programme and

3 then the next day, or, rather, the next evening, the cassette was sent to

4 Pale by bus. Zoran was a man who worked on satellite TV. He was in

5 "Politika" then. I don't think he works in "Politika" now. But he is

6 the man who knows about the cassette that went to Pale. There were no

7 negative reactions, absolutely, and the journalist [Realtime transcript

8 read in error "adjournment"] said that they were satisfied. That's what

9 they told me. Perhaps you remember these two journalists from TV AP,

10 dark with a moustache. One of them worked on TV Sarajevo before the war.

11 Q. Radoje something?

12 A. Something like that that.

13 Q. Line 14 in the transcript, it should say "journalist", but over

14 here it says ... it says "adjournment." That is what was typed,

15 "adjournment." It shouldn't be "adjournment." It should be

16 "journalist."

17 So it was journalists who said this to you; right?

18 A. Yes, that's right.

19 THE ACCUSED: [Interpretation] Excellencies, can pages 15 and 16

20 from the interview be admitted. I mean 115 and 116, from the OTP

21 interview.

22 JUDGE KWON: Yes.

23 THE REGISTRAR: Exhibit D2251, Your Honours.

24 THE ACCUSED: [Interpretation] Just a bit of patience, please.

25 [Defence counsel confer]

Page 28451

1 THE ACCUSED: [Interpretation] I would just like to ask you a few

2 more things.

3 Q. So you strolled through Srebrenica. Did you see any buildings

4 that had just been hit or that had just been burned?

5 A. Mr. President, like in my previous statements, I can only repeat

6 what I stated. I have some war experience. I did not see anything like

7 that. I was mainly in the main street, and perhaps I went up to some

8 buildings in the centre, 10 or 15 metres, but these were not fresh

9 traces. There was no smoke rising from buildings that had been set on

10 fire. I just saw some smoke from the destroyed timber factory above

11 Sarajevo. I can't --

12 THE INTERPRETER: Above Srebrenica, interpreter's correction.

13 THE WITNESS: I can't remember the name of that factory. But we

14 could see signs of the initial fighting between the Serbs and Muslim when

15 the Muslims were surrounded, but that was one or two years old. But

16 there were absolutely no fresh traces.

17 I believe that everybody had left, that everybody went to

18 Bratunac down that road and that that was the best that could be done. I

19 even recorded something in the centre, some corpses.

20 MR. KARADZIC: [Interpretation]

21 Q. Did you miss anything? Did you omit to record anything

22 important?

23 A. Mr. President, I did not spend the entire day there. My time was

24 limited because of the minister's visit, so I just managed to stroll a

25 bit. Was it half an hour, an hour. I saw these three corpses, some

Page 28452

1 dogs. You can see that on my footage.

2 As an experienced person, I tried to see whether there were any

3 traces, whether there were any dead, et cetera. Only later on I heard

4 that an elderly lady - I remember her last name was the same as mine,

5 Petrovic. She was 82 or 83. I have a photograph at home - she had had

6 her throat slit when they were fleeing to Bratunac, but did I not see any

7 of that. The mosque was still there. The church was still there. The

8 department store was damaged. I entered an apartment. In the raw

9 material you can even see what is there in that apartment. People left

10 in a hurry. And I recorded the people who were coming back, the Serbs

11 who had fled when the war started. That's how the war in Srebrenica

12 started, this member of parliament who was ambushed. So people were

13 coming back and they were carrying cooking oil and other things coming

14 from US Aid, and I know they were walking from Bratunac, and I

15 interviewed some of them in their houses, for instance. That's like what

16 I saw in the Beqaa valley, Jerusalem Forever, et cetera. There were

17 things like that in Srebrenica, but apart from these two or three dead

18 bodies, I didn't see anything else.

19 Q. Thank you. The white house you recorded that and we have that

20 footage. What was your assessment? How many people were there on the

21 terrace, and did you receive any information to the effect that these

22 persons were crime suspects?

23 A. Yes, Mr. President. That is the footage that was held against me

24 for years. People were saying that I had erased it. That's in the

25 original programme. You saw it just as the Prosecution did and just as

Page 28453

1 the Court did.

2 Let me repeat this once again. I'm recording this, these scenes

3 in this heat, and may I say again that I was terribly shocked by the

4 number of people there. And then these young children, women, elderly

5 men, they're helping them board buses, trucks, and I am recording heaps

6 of old clothing that no one would really want to wear. I'm not a

7 cameraman, and cameraman have a rule, whether they're going to move left

8 or right or whether they're just going to keep the camera still. So I

9 moved to the right and I see this house, and I did not pay any attention

10 to it when I was in the compound. I was interested in people, not the

11 house. And then what I saw in the camera, through the camera, was the

12 terrace combined with wood. It's half of the terrace that I have in my

13 house. Half of my terrace would be, say, ten people. I mean, you can

14 see through it. Can you see it in the camera. They're sitting. As far

15 as I can remember, none of them were standing. So about ten people. I

16 didn't know then but I asked later who those people were. And basically

17 what I heard was that they were being investigated for crimes. I did not

18 pay attention to that because I recorded a lot of other footage as you

19 could see in my report. And that was also filmed. I didn't have a plan

20 then. I didn't really think about it. I was just looking at images. I

21 just wanted to have images for my viewers. That's what you do on TV.

22 You want to have images that are telling. My recording was very poor,

23 but many proved to be invaluable for the Court, and for you.

24 Q. Thank you. Is it true that the film or -- and was it the case in

25 reality that there was no tension, no fear, no coercion, that the

Page 28454

1 situation was quite relaxed, that everybody was moving around freely and

2 looking for something that they wanted to get their hands on? In other

3 words, did you record any fear of Dutch soldiers among the civilians or

4 any other people?

5 A. Mr. President, later on, when the debate started in the

6 Netherlands about whether they had protected those people and should they

7 have offered assistance to the Serbs, I had an opportunity to see those

8 people in various situations. The first one was a discussion between an

9 UNPROFOR officer from Africa and the Serb side about water supply, then I

10 saw a black Dutch soldier who was pushing a wheelchair with an old man,

11 then I saw another one drinking milk straight from the bottle. I even

12 saw some of them who were armed and who were in the background footage of

13 that compound. So some of them kept their weapons. I also filmed the

14 officer whom I asked at the very outset what was going on here, but he

15 told me, You know what's going on. And I say, No, I don't know. I've

16 just come from Belgrade. He was a bit nervous, but I didn't notice, I

17 don't care if it came from the Serbs, but I didn't hear anyone saying

18 anything bad about those people.

19 I also didn't see any triumphalism among the Serbs for entering

20 Srebrenica. I didn't see anyone laughing. The people were simply

21 exhausted, the soldiers, but nobody said anything abusive or bad. So you

22 can partly detect this impression in my footage, which is a good

23 testimony to what was going on.

24 JUDGE KWON: Yes, Mr. Nicholls.

25 MR. NICHOLLS: Sorry, no objection. Just to be clear, I assume

Page 28455

1 Mr. Karadzic was talking about the 13th in his question, because, of

2 course, Mr. Petrovic filmed on 13th and 14th. And in his question, at

3 line 23/24, Mr. Karadzic sort of built in the 14th as well when he said

4 that:

5 "... everyone was moving around freely and looking for something

6 that they wanted to get their hands on."

7 Mr. Petrovic, in his description of the 14th and in his video of

8 the 14th, shows Serb civilians returning once the town has been emptied

9 looking for things to get their hands, going back to houses, taking

10 different items. So, just for clarity, I'm trying to see which days

11 we're talking about and which people.

12 JUDGE KWON: Yes. Thank you, Mr. Nicholls.

13 Yes, Mr. Karadzic, could you be more specific in putting the

14 question.

15 THE ACCUSED: [Interpretation] I don't remember mentioning the

16 14th at all.

17 THE WITNESS: Can I -- can I help?

18 MR. KARADZIC: [Interpretation].

19 Q. Maybe the witness can clarify it for us, what was the date on

20 which he filmed this footage in Srebrenica.

21 A. [Interpretation] Yes, Mr. Nicholls is right. You can see from

22 the footage that the date is there. I was on the 13th in the compound

23 filming the people who were preparing to leave Srebrenica, both those

24 originally from Srebrenica and the refugees.

25 On the 13th, I was filming them en route to Tuzla. And then on

Page 28456

1 the 14th, along with Borovcanin, who was escorting the minister of

2 police, I was in Srebrenica. At that time, the journalists were still

3 banned from coming in, but since I was with Borovcanin I could enter. So

4 Srebrenica itself is the 14th.

5 Q. Well, that's -- it's my mistake because I consider Potocari to be

6 also part of Srebrenica, and the Srebrenica itself was filmed on the

7 14th. Thank you.

8 Now as for the things that you saw on the 13th, were you

9 referring only to what was happening outside the white house, or are you

10 referring to everything that was happening in different places with

11 relation to the civilians?

12 A. Mr. President --

13 Q. I was speaking about these bundles.

14 A. There were things carried by people in their hands. Those were

15 small bundles, and they were preparing to board the buses. But I saw

16 this huge pile, I think it was 6 or 7 metres high, a pile of totally

17 worthless clothing. Not even the vagabonds in Paris would be willing to

18 wear that. I don't know what the reason was. Maybe there was some

19 contagious disease there. But, anyway, those were extremely poor

20 clothing. That's what I saw, and I don't know why it was piled up there.

21 JUDGE KWON: In the previous question, which Mr. Nicholls

22 referred to, you asked as follows:

23 "Was it the case in reality that there was no tension, no fear,

24 no coercion, that the situation was quite relaxed, that everybody was

25 moving around freely and looking for something that they wanted to get

Page 28457

1 their hands on? In other words, did you record any fear of Dutch

2 soldiers among the civilians or any other people?"

3 Were you asking the situation on the 13th in Potocari?

4 THE ACCUSED: [Interpretation] Yes. I'm talking about what we saw

5 in the film. There were no people in Srebrenica on the 14th. They were

6 in Potocari, civilians and the soldiers alike.

7 JUDGE KWON: Did it include the people in the white house as

8 well?

9 THE ACCUSED: [Interpretation] Well, as far as the white house is

10 concerned, I only wanted to hear from him whether he was able to estimate

11 how many people were there and what they were doing on this balcony.

12 JUDGE KWON: Very well. Let us continue, unless Mr. Petrovic has

13 anything to add to what he already said. Thank you.

14 Given the time, shall we take a break now?

15 We'll have a break for half an hour.

16 --- Recess taken at 10.29 a.m.

17 --- On resuming at 11.02 a.m.

18 [Trial Chamber and Registrar confer]

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

20 MR. KARADZIC: [Interpretation]

21 Q. Dr. Petrovic, you mentioned a moment ago that there were a lot of

22 old things heaped somewhere. I'll try to ask my questions so you can

23 answer them with a yes or no.

24 Was there a real danger of contagion?

25 A. Mr. President, I believe so, if you look at the footage and see

Page 28458

1 those old things.

2 THE ACCUSED: [Interpretation] Could we briefly call P194.

3 MR. KARADZIC: [Interpretation]

4 Q. I would like to ask you to clarify, from that point of view, the

5 report you made.

6 THE ACCUSED: [Interpretation] Both the Serbian and the English

7 version, please.

8 MR. KARADZIC: [Interpretation]

9 Q. Do you remember this report?

10 A. Yes it was published by Milomir Maric in a magazine called

11 "Interview," published by the Politika publishing house, but it has not

12 existed since the war.

13 Q. But you authored it?

14 A. Yes, Mr. President.

15 Q. Now, I'm not sure of my knowledge of English, but this heading in

16 English seems to suggest that it refers to a cover-up of the situation.

17 Literally it says, "Whitewashing and begun," and I understand it As the

18 beginning of disinfection of the town and clearing up; whereas in English

19 it sounds like some sort of cover-up. How would you like this heading

20 that you put to be translated?

21 A. Yes, it's obvious that the English term is wrong, "whitewashing."

22 I meant repainting houses. Specifically painting inside the house, and

23 it's important to read the text carefully because then you will see that.

24 There is a passage where I depict one dimension of it in a very

25 documentary way, and it was even misunderstood in Belgrade at a public

Page 28459

1 debate where you were not invited, of course. There was a civilizational

2 component to this conflict that is poorly perceived in the world very

3 often. Let's put it this way: The Christian population uses more pork,

4 whereas the Muslim population tends to use more lamb. And everybody from

5 our part of the world can tell you that Christians frequently find the

6 smell of lamb unpleasant emanating from the walls and inside the house,

7 and Muslims object to the smell of pork. It's a fact.

8 I went to Srebrenica often and I met a lot of people who went

9 back there and they have to do house painting every few years. It's

10 absolutely not about whitewashing. I would say interior house

11 repainting. That was the meaning I meant when I was writing this.

12 Q. I don't know if I'm going to get additional time so I have to

13 hurry up, and I'd like to cover the main things.

14 You were at Sandici, around what time?

15 A. It was sometime in the afternoon, 3.00, 4.00 p.m., as soon as I

16 finished filming inside the compound in Potocari, then we went to

17 Bratunac and went further along that road. It must have been around 3.00

18 or 4.00 p.m. I think you can see it on the footage when it shows the

19 Serbs shooting from the road towards the mountains.

20 THE ACCUSED: [Interpretation] I see Mr. Nicholls on his feet.

21 JUDGE KWON: Yes, Mr. Nicholls.

22 MR. NICHOLLS: No objection. I just notice for the record that

23 the witness is referring to some papers in front of him that appear to be

24 highlighted when answering the questions. I hadn't noticed that before.

25 I don't know what they are. He did tell me that when he met with

Page 28460

1 Mr. Karadzic, that Mr. Karadzic gave him some papers.

2 So I just, for the record, wonder what he is referring to. He

3 looked down and to check his memory, I suppose, about what time he was in

4 Sandici.

5 JUDGE KWON: Yes, Mr. Petrovic, if could you explain that to us.

6 THE WITNESS: [Interpretation] Yes, Your Excellency.

7 This is a summary of my case which contains concern passages

8 where Mr. Karadzic marked or indicated the areas of questioning he would

9 conduct today. I did not have time to consult it regularly, but what we

10 are discussing now does not strictly adhere to what is indicated in my

11 text. I have the English version here, and it is marked which parts of

12 the text Mr. President Karadzic would like to highlight in our discussion

13 today. But if it's a problem I can do without it. It's not a problem.

14 THE ACCUSED: [Interpretation] May I explain?

15 JUDGE KWON: Yes, Mr. Karadzic.

16 THE ACCUSED: [Interpretation] We call it chronology. Those are

17 quotations from everything that the witness has ever said anywhere.

18 Citations. We are not trying to set any ambushes, and it's not unlike

19 what the Prosecution does when they show him 92 ter documents and ask him

20 what stands behind it, and there are references indicated below as to

21 where -- where he said what and at what time.

22 THE WITNESS: [Interpretation] Your Excellency?

23 JUDGE KWON: Yes, Mr. Petrovic.

24 THE WITNESS: [Interpretation] I can provide it to anyone of the

25 parties for inspection.

Page 28461

1 JUDGE KWON: Mr. Nicholls, do you like to take a look?

2 MR. NICHOLLS: I wouldn't mind taking a look. I was just going

3 to ask what it is, whether it's a prior transcript or something created

4 by the Defence or what -- I just don't know what it is. And I would

5 remark that it is not like our practice of 92 ter witnesses to -- I'll

6 leave it at that.

7 JUDGE KWON: Yes. If the usher would help the witness to hand

8 over the document briefly to Mr. Nicholls.

9 And, in the meantime, your evidence would have more probative

10 value if you can testify not relying on that document you prepared.

11 However, if necessary, you can tell us, and take a look at what you

12 prepared.

13 THE WITNESS: [Interpretation] Your Excellency, I have here a few

14 of my own articles that I brought. I have not re-reviewed them. I can

15 provide them as well. I don't need them for these proceedings, but I

16 took them just in case. I don't need them for my testimony here.

17 I can hand this over too.

18 JUDGE KWON: Thank you. It won't be necessary.

19 [Trial Chamber and Registrar confer]

20 THE ACCUSED: [Interpretation] Thank you.

21 I tendered some of those articles. Could we now see 1D5634.

22 It's one of those texts, and perhaps it is in e-court.

23 MR. KARADZIC: [Interpretation]

24 Q. It's your glossary of war-time Sarajevo published in "Nin"

25 magazine or perhaps "Duga" magazine. No, it's "Duga."

Page 28462

1 It's rather a bad copy, but we have a translation.

2 This relates mainly to the Dobrovoljacka street, your description

3 of the incident at Dobrovoljacka street where the military column, which

4 you accompanied as a journalist, was attacked and butchered.

5 A. Yes, Mr. President. This is part of my article published in the

6 "Duga" magazine in May 1992 after this incident which happened on the

7 3rd of May, and it's part of a very long glossary. I believe it's 20

8 type written pages relating this incident involving the military column

9 that I accompanied with the TF 1 French television crew, and we were

10 trying to prepare that report by that evening, so we got out at 1805

11 hours and that saves us, perhaps.

12 Q. It says here, "Dozens of armed civilians, Green Berets." To the

13 best of your knowledge, was the difference between civilians and soldiers

14 during our war not so much in clothing as in whether they were carrying

15 weapons or not?

16 A. Yes, Mr. President. With this French crew, I was in Sarajevo,

17 both in end February and early March and in end April/early May. I was

18 able to observe the rising of this war-time psychosis and the conversion

19 of civilians into armed citizens. A funny, rather hilarious term was in

20 use in Sarajevo at the time, spontaneously organised citizens,

21 quote/unquote, and I noticed that in the incident with the convoy on the

22 3rd of May, 1992, because when they surrounded the car we were in, driven

23 by the French reporter, Louis Beroux [phoen], they had all sorts of

24 weapons, including, state-of-the-art weapons, from pistols and small

25 arms, to Kalashnikovs and hand-made bombs and grenades. And it was all

Page 28463

1 very tense and very dangerous because this was not a regular military

2 unit.

3 Q. If a person like that got killed, and somebody else took their

4 weapon, then a casual observer would say, seeing the body, that it was a

5 civilian, wouldn't he?

6 A. That's correct, Mr. President. That would be the first thing you

7 would think in a situation like that.

8 THE ACCUSED: [Interpretation] May I tender this. We have

9 translation for only two or three of these passages, no more than one

10 page in English.

11 MR. NICHOLLS: Your Honour, I would object until -- to it being

12 other than marked for identification.

13 JUDGE KWON: I'm not sure if we have to admit this in order to

14 understand some meaning of the phrases. But given the position of the

15 Prosecution, we'll mark it for identification.

16 THE REGISTRAR: As MFI D2252, Your Honours.

17 MR. KARADZIC: [Interpretation]

18 Q. Let's go back to the Sandici meadow.

19 In your estimate, how many prisoners did you see at Sandici? How

20 many did your camera record?

21 A. Mr. President, there are many ways to count people in situations

22 involving crowds, such as football matches, et cetera, or riots. At the

23 time I was there, I thought there was enough to fill one bus, around

24 100 people. That's what I would say, and I believe that's what I said in

25 my previous statements and evidence.

Page 28464

1 It's hard to say, but that's the number that stuck in my head.

2 THE ACCUSED: [Interpretation] Could we see 03177 -- or, rather,

3 117. 65 ter 03117.

4 MR. KARADZIC: [Interpretation]

5 Q. In your estimate, is this a smaller or a larger part of what the

6 camera filmed, or are they all of them? All of the people who were at

7 Sandici around 2.00?

8 A. This is a still from my video report. From this angle, you can't

9 see all of them, but there were not many more. Perhaps double of what

10 you can see in the picture, enough to fill a bus. Because this was

11 filmed from lower ground, and some could not be seen in the view-finder,

12 there were a few more than you can see here, I would say.

13 Q. And then you went on towards Konjevic Polje. You stayed there a

14 while. And during that time, Colonel Borovcanin found out about the

15 incident at Kravica; correct? And then you went back.

16 A. Something like that. That's in the same area where these people

17 were, the incident in which one fighter was wounded. Borovcanin found

18 out almost immediately, and then we went back to the hospital for him -

19 for Borovcanin - to see what happened to the soldier.

20 THE ACCUSED: [Interpretation] Your Excellency, do we need to

21 tender this still?

22 JUDGE KWON: Yes. If necessary, we'll admit it.

23 THE REGISTRAR: As Exhibit D2253, Your Honours.

24 JUDGE KWON: Mr. Karadzic, you just have passed the time allotted

25 to you. How much time would you need to conclude your cross-examination?

Page 28465

1 THE ACCUSED: [Interpretation] Well, in line with my submission, I

2 can finish within ten or 15 minutes, but I believe it would be useful for

3 the Trial Chamber if this witness were to tell us a great many things

4 that he knows. But if we are going to stick to what the motion says,

5 then I'll finish within 15 minutes.

6 May I just say something, Excellencies?

7 You see, how 92 bis is deficient. You see how a live person can

8 turn his own statements into a live statement.

9 JUDGE KWON: Please continue. And conclude in 15 minutes.

10 THE ACCUSED: [Interpretation] Has a number been assigned to this

11 image? All right.

12 MR. KARADZIC: [Interpretation]

13 Q. Now, you returned. And you're sure that neither you nor

14 Borovcanin at the time of the incident in Kravica, you were not near

15 Kravica. You were even further away from Sandici towards Konjevic Polje;

16 right?

17 A. Mr. President, if you mean the incident of the wounding of the

18 Serb soldier by the Muslim soldier who had surrendered, we have not seen

19 that at all. That is my recollection. We hadn't seen what happened at

20 all. We just remember that somebody called Borovcanin and that we

21 immediately set out to the hospital in Bratunac so that he could see that

22 soldier. Obviously he cared about that soldier a great deal. It's

23 probably one of his men from his unit, probably with a great deal of

24 experience.

25 Q. Thank you. And then from the car, the camera filmed the

Page 28466

1 warehouse with a certain number of bodies.

2 Do you remember whether the door, whether the door was closed

3 where the bodies had been piled up? I think you testified along those

4 lines. I think you said something like the door was closed, or something

5 like that. Do you remember that?

6 A. Mr. President, if my memory serves me well, I think that I

7 confirmed that during my previous testimonies.

8 You should just know what the situation is when you're filming.

9 I mean, I just held the camera in my hands then as the car was passing.

10 It was one, two, three, probably not more than that. It was only later

11 that I saw that there was a soldier that had been filmed and I saw that

12 the door had been closed, and I was scandalised. Why did many witnesses

13 base their testimony about the number of dead on the basis of an open

14 door? Thank you for putting this question. I have a great deal of

15 difficulty with this, because of the manipulation involved. If we recall

16 the Borovcanin trial in 2007, we will see that until this day date, 2012,

17 the only evidence that the world has, in spite of all the satellite

18 imagery of this world, is only my footage of these few seconds where you

19 can see about 15 or 20 dead persons - that's my estimate - is regards

20 what happened in the hangar.

21 JUDGE KWON: Mr. Nicholls.

22 MR. NICHOLLS: I don't mean to object, but the question was: Was

23 the door opened or closed.

24 JUDGE KWON: Yes.

25 Dr. Petrovic, if you try to answer the question. Mr. Karadzic

Page 28467

1 will ask further questions, if necessary. But did you say your video is

2 the only evidence about what happened in Kravica? I have to tell you

3 that you we have some survivors and other witnesses.

4 Yes, please continue.

5 So did you answer the question, whether door was opened or

6 closed?

7 THE WITNESS: [Interpretation] I do, apologise, Your Excellency.

8 I just wanted to be of assistance.

9 The door was closed.

10 MR. KARADZIC: [Interpretation]

11 Q. Thank you. When you said that this is the only evidence, did you

12 mean that it was the only video material?

13 A. Yes, Mr. President. As far as I know, it's that footage of mine

14 and American satellite images.

15 Q. Thank you. A moment ago, you said that your estimate was - and

16 perhaps if one were to work on this carefully, it could be counted more

17 precisely - there were about 20 bodies on that pile in the warehouse;

18 right?

19 A. Yes, Mr. President. At that moment, I wasn't aware of the

20 number. To this day, I think it's between 15 and 20.

21 Q. Thank you. Later on, you say that you noticed a soldier. Did

22 that soldier behave as if there was still gun-fire near him, or is he

23 behaving as if there is no shooting around him, since you did hear

24 gun-shots from the vicinity of the warehouse?

25 A. Yes, yes. I mean, the later viewing of this footage -- well,

Page 28468

1 it's a bit contradictory the way he is walking around, and I remember

2 that I heard gun-fire a lot along the road. Behind that hangar, as far

3 as I can remember, there is a small river and that is the area where

4 there were exchanges of gun-fire.

5 I find it a bit strange now, but then I wasn't really paying any

6 attention to it. It was too short.

7 Q. Thank you. Had there been shooting in the co-operative itself,

8 do you believe that you would have seen that and that Borovcanin would

9 have perhaps stopped to see what was happening?

10 A. Yes. I mean, had there been shooting, as different sources said,

11 different witnesses said, well, perhaps I did not pass at that moment,

12 but when I was passing, there was was shooting further away from the

13 hangar, not in the hangar that was closed. But have you to know that I

14 am just a witness of that moment, those three seconds.

15 Q. Thank you. Colonel Borovcanin --

16 JUDGE KWON: Just a second, Mr. Karadzic.

17 As to whether you remember the door was closed or open,

18 Dr. Petrovic, shall we upload the -- his transcript. Could you give the

19 number, Mr. Nicholls?

20 MR. NICHOLLS: P00375, Your Honour. It's the Popovic transcript,

21 if that's what you're referring to.

22 JUDGE KWON: Yes. And transcript page 18808.

23 Through Mr. Nicholls, I asked you the question whether you

24 remember seeing the bodies at the time in front of that warehouse.

25 And you answered like this in the middle:

Page 28469

1 "The witness: I didn't give it thought. Not this way. Yes, I

2 saw it in two seconds. I had to register that as I was watching it

3 through the camera's lens, but it was only two seconds long."

4 My question is: In light of this, how do you remember whether

5 the door was closed or open.

6 THE WITNESS: [Interpretation] Your Excellency, as I said

7 previously, I had my eye on the camera. As far as I can remember, that's

8 two or three seconds. One, two, three. Not more than that. I had this

9 image of the terrain where there was fighting. This I viewed later, when

10 I was editing the programme. I probably recollect the editing moments

11 better than the actual moments when I saw all of this, because, for

12 example, I hadn't registered the presence of the soldier at all. It was

13 really just a moment. And it's hard for me to say anything more than

14 that. But it is evident that that is on my film. The door is closed,

15 and the corpses are there.

16 JUDGE KWON: Thank you.

17 Yes, Mr. Karadzic, please continue.

18 THE ACCUSED: [Interpretation] Thank you.

19 MR. KARADZIC: [Interpretation]

20 Q. So then Colonel Borovcanin went to see that soldier of his. Is

21 it correct that the hands of the man had been burned because he had

22 grabbed a barrel of a weapon that had been fired?

23 A. As far as I remember, Mr. President, as I was standing in front

24 of the hospital, I did not go in with Borovcanin, I was told that he had

25 injuries on his hands.

Page 28470

1 I cannot remember exactly whether they had been cut up by a blade

2 or whether there were burns on his hands. It was serious injury. Both

3 would be serious injury, but perhaps it was that barrel.

4 Q. Thank you. I'd like to ask you to identify yet another interview

5 of yours. 1D5636 could we have that called up.

6 You mentioned in your testimony, Colonel Bunel. Is that a

7 colonel of the French army that was part of the NATO force and that

8 criticised the bombing of Serbia? Later on, he was also held accountable

9 because he had warned the Serbs about the targets that would be hit.

10 A. Yes. That is Colonel Bunel, a military intelligence officer of

11 the French army. He was even in prison because he provided information

12 to the Serbs before the bombing. Before that, he served in Bosnia.

13 I interviewed him twice. In the first interview, I didn't know

14 that he had served in Bosnia. That was not our main topic.

15 In the second interview, he told me astonishing things about the

16 Muslims, that the Americans had taken into their base in Tuzla a few

17 months later. That's what he said. So he should be asked about that.

18 Q. And he told you that a few months after the fall of Srebrenica,

19 soldiers, Muslim soldiers, appeared from the woods, they appeared in the

20 American base and that the American army transported them to the

21 United States; right?

22 A. That's right. That's right. For me, that was a shocking

23 statement. However, no one seemed to care either in the Serbian public

24 or in the international public. Later on, I found out, sometime in

25 mid-1996 from people from the Serb diaspora - actually I wanted to shoot

Page 28471

1 a documentary on that subject. I wanted to go to America to find these

2 soldiers - Serbs signalled that a large group of people from Srebrenica

3 had arrived in Virginia. But no one wanted to help me work on a

4 documentary devoted to that topic, so that's the way it turned out.

5 Is it shocking, as I said, that a colonel, a military

6 intelligence man, would say something like, and, on the other hand, no

7 one seemed to care. So these soldiers were hiding in the woods and

8 were -- in these mountains, and they were grouped. And then a

9 photographer from Tuzla actually took pictures of them.

10 Q. Thank you.

11 THE ACCUSED: [Interpretation] Can this be admitted.

12 JUDGE KWON: Mr. Nicholls.

13 MR. NICHOLLS: I have to admit that the relevance is not clear to

14 me. This supposed transport in 1996 of somebody to America. But ...

15 JUDGE KWON: Can you explain the relevance, Mr. Karadzic?

16 THE ACCUSED: [Interpretation] Well, Excellency, perhaps we can

17 find them on the lists of missing persons and they're in Virginia or

18 Salt Lake City. In America, thousands of Muslims are there; inter alia,

19 some from Srebrenica. And the colonel saw them a few months after the

20 fall of Srebrenica. He saw hundreds of soldiers who appeared from the

21 woods in Tuzla.

22 JUDGE KWON: Very well. We will receive it as Exhibit D2254.

23 And please continue. I note the time. It's about the time that you need

24 to conclude.

25 THE ACCUSED: [Interpretation] Excellency, I am just going to put

Page 28472

1 a brief question before my last question.

2 MR. KARADZIC: [Interpretation]

3 Q. When you said that some other journalists viewed your material

4 during the editing at Studio B and described them, is that unusual or

5 impermissible; namely, that other journalists use material that was

6 authored by someone else, another journalist?

7 JUDGE KWON: Yes, Mr. Nicholls.

8 MR. NICHOLLS: Sorry, could I have a cite, I may be wrong, to

9 journalists viewing his material during the editing.

10 He has talked about how people helped him with the editing which

11 was done very quickly, because the -- it was broadcast immediately. I

12 don't recall any testimony or statement that other journalists were

13 present during the editing.

14 THE ACCUSED: [Interpretation] I think that the witness, today --

15 I think that the witness said today that he was angry because his

16 copyright was abused because Robert Block viewed his material in an

17 unauthorised way in the editing rooms of Studio B. If I'm wrong, then I

18 withdraw the question.

19 MR. KARADZIC: [Interpretation]

20 Q. But could the witness kindly tell us whether that was the case?

21 MR. NICHOLLS: [Overlapping speakers]

22 JUDGE KWON: You said during the editing. Did Mr. Block see his

23 video during the editing?

24 Yes.

25 THE WITNESS: [Interpretation] Your Excellency, I mentioned

Page 28473

1 Mr. Block, and only in 2012 I found out from the mentioned article

2 written by Mr. Michael Dobbs, the great American journalist, who told me

3 that Block had seen my materials. If that had been done to

4 Christiane Amanpour or any other of the big names in journalism, he would

5 have been wiped off. That is something that is not permissible at all.

6 Without asking me, he was just rummaging through my material.

7 MR. KARADZIC: [Interpretation]

8 Q. Thank you. Now I'm going to ask you this: You knew this unit,

9 and in your statements, you mentioned this special unit. And you said

10 that we, as the government, were proud of them. Do you agree that we

11 were proud of them because it was competent and because it abided by the

12 rules and regulations and principles. On the other hand, tell me, are

13 you aware of any misdeeds and misconduct on their part?

14 A. I'm going to reiterate it once again, Mr. President, that in my

15 view, and I was in many different situations in war, I think that this

16 was a morally and militarily extremely and competent and excellent unit.

17 There is not even a shadow of any crime committed by them in combat.

18 If they hadn't had these characteristics, I wouldn't have been

19 too keen to be in the same company with them. There is another motive

20 why I looked for them. Christiane Amanpour prepared a report on the

21 Black Swans and amongst them were even some of the Islamic fighters. She

22 made a very pro-Muslim report. She was appraising the way they looked

23 and how they were armed. Her report was a high-technical report because

24 she had some ten people on her crew. I wanted to make a counter-report

25 about our unit made up mainly of professional police officers. They were

Page 28474

1 police officers even before the war, and this was an impeccable unit, and

2 I can say that I am proud that I spent some time with them.

3 Q. Thank you. You mentioned today that Block made a big story of

4 Kravica and that he even introduced the term genocide.

5 Now, having known the entire leadership of the Bosnian Serbs,

6 including myself, do you know whether any Serb official at any level had

7 an inclination or was prepared to think and, let alone, do something

8 towards destroying the Muslims?

9 A. Mr. President, the people know me that I am merciless when it

10 comes to the truth. I am now looking you in the eye, and I am telling

11 you that I would be the first one that would destroy you in my articles

12 had that been the case. I am not such a person, and I believe that the

13 future will correct all the notions and misconceptions.

14 Q. But you were highly critical of President Milosevic; is that

15 correct?

16 A. Yes. Particularly his wife, because she caused a lot of damage

17 to our people. And you can see that proven in a scientific way from my

18 book recently published in Paris.

19 Q. Thank you, Mr. Petrovic.

20 THE ACCUSED: [Interpretation] Your Excellency, with this, I would

21 like to finish my cross-examination.

22 JUDGE KWON: Thank you.

23 Yes, Mr. Nicholls.

24 MR. NICHOLLS: Thank you, Your Honours.

25 Re-examination by Mr. Nicholls:

Page 28475

1 Q. Just a few questions, Dr. Petrovic. First, this Colonel Bunel,

2 Karadzic referred to him being punished. He was, in fact, convicted of

3 treason; is that right?

4 A. That is true, Mr. Nicholls. But imagine treason and a conviction

5 for that passed on someone who only two years later appears on television

6 as a consultant. He spoke on the air about this, and you will admit that

7 this is not a frequent occurrence had he really been a traitor. And it

8 seems that all this was done on orders from some higher levels. I don't

9 think that the French behaved so badly in the bombing of Serbia as the

10 Americans and the others did. He only gave Serbs the information about

11 the targets that were going to be hit.

12 So this whole situation is rather odd. There's no precedent to

13 the effect that a person convicted of treason later on appears on

14 television and in other media.

15 Q. Uh-huh. Going back to your comments about bin Laden being

16 present in Bosnia and meeting with President Izetbegovic, I just want to

17 make this clear. You learned this from a German journalist and the

18 reason she gave you -- that nobody would publish it or take it seriously

19 was that only a lunatic would believe it; is that right? Excuse me.

20 A. Just a slight correction. If he looked like a lunatic who was

21 boasting about his grand motives, but he was dressed in a traditional way

22 and this is how she explained it to me. However, knowing who she was and

23 knowing her biography that she wrote for "Der Spiegel" which is a serious

24 paper. I'm sure that that is her decision to write about it. But,

25 obviously, the editor-in-chief didn't think that that was an interesting

Page 28476

1 topic at the time, because the Germans took part in a large military

2 procession in Bihac, together with Muslims. And she said that

3 Mr. Werner would have been quite happy to see them there. And there are

4 photographs which showed this.

5 Now the point is that the policy was not to tackle this issue at

6 all.

7 Q. Okay. I now want to go back to -- there was some questioning

8 today and you have testified about it before, basically the proposition

9 that -- and you said it today, that Mr. Borovcanin wouldn't invite a

10 journalist with him if there was a plan to murder people and commit

11 crimes, and you said today and you said before that Mr. Borovcanin

12 trusted you; right? He trusted you.

13 A. Yes, sir.

14 Q. I would like to play a video-clip now from the 14th of July.

15 This is from P00667 which is your raw footage, the -- that we

16 copied from you. I will tell Mr. Reid. You should begin at 25:55.

17 [Video-clip played]

18 MR. NICHOLLS: Stop. Can we stop.

19 Q. We stopped at 26:07:1.

20 I just want to make the point, if you recall, in the documentary,

21 Studio B documentary, it's just after this scene that we see the short

22 clip in front of Kravica warehouse; do you remember that?

23 A. Yes.

24 Q. Okay. Let's keep playing on the raw footage.

25 [Video-clip played]

Page 28477

1 MR. NICHOLLS: And we could stop there, 26:55:09.

2 Q. You have testified about this bit of footage before. My question

3 is about this in relation to Mr. Borovcanin's trust of you. Now, here,

4 you're calling Muslims, motherfuckers. You're laughing about the

5 demolishment you see around you. You say:

6 "Is this not your -- fuck, fuck their mothers, what have they

7 brought us, a plague, motherfuckers."

8 So did Mr. Borovcanin also think that Muslims were motherfuckers

9 who brought a plague to Europe, to that -- your part of the country? Is

10 that part of your bond with him?

11 A. Mr. Nicholls, this was a war situation, because you have to

12 establish close bonds with those that you are with. You would have

13 filmed the same thing whether you were on the Muslim side or the Croat

14 side. I don't know why the vocabulary is so important, because this

15 vocabulary is adapted to the situation. I met Mr. Borovcanin previously

16 only twice and this was the third encounter, and we didn't talk much. I

17 spoke more about what I saw what Hezbollah did in the Beqaa valley where

18 they painted all the walls from the scenes of their history and Islam.

19 So I am sitting in this car and this just came out as something -- that's

20 what we are discussing while we were travelling from Bratunac to

21 Srebrenica. I did say those things that I would have never said had the

22 situation been normal, but I didn't attach any importance to this. I

23 don't think that this would discredit me. I wanted to preserve the

24 authenticity of the situation, and I think that it bears no relevance to

25 this case at all.

Page 28478

1 Q. Okay. Thanks. That helps me understand a bit better.

2 You were speaking this way, if I understand you, you were

3 adapting to the situation where you were with Mr. Borovcanin the day

4 after the Kravica warehouse killings, that you were adapting yourself to

5 being with Mr. Borovcanin? That's why you're talking about motherfuckers

6 and a plague?

7 A. I would repeat that I had in mind the things had a been imported

8 from the Middle East that had nothing to do with our European or

9 Christian traditions, and I saw those things on the walls and I made

10 comments. I didn't refer to all the Muslims as bastards. I never said

11 that. I was only reliving my memories from Lebanon where I saw miles and

12 miles of painted walls, and my reaction particularly referred to the

13 Hezbollah, although this is not mentioned here.

14 A director from Belgrade who used to be the husband of

15 Natasa Kandic told me, We didn't want to cause any trouble for you for

16 saying what you said. And he repeated the same thing that I heard today,

17 which surprised me a lot.

18 The whole story about him is a sad story. He, in addition to

19 that, directed some of the footage that I made, and he signed my name as

20 a cameraman. And he told me the same thing about six months ago in

21 Belgrade, so I find it quite strange that you are repeating this today.

22 JUDGE BAIRD: Dr. Petrovic, I would like to have one thing clear:

23 There was a portion of Mr. Nicholls' question that you didn't answer and

24 can you possibly answer it for us, please.

25 Did Borovcanin also think that the Muslims were motherfuckers?

Page 28479

1 Can you answer that at all?

2 THE WITNESS: [Interpretation] I don't have the text in front of

3 me on the screen. I don't know. When shall I start my answer?

4 Your Excellency, as far as I can remember, Mr. Borovcanin, the

5 then-Colonel and now General, never displayed any kind of intolerance

6 towards Muslims. He used to be a school teacher, and I never heard him

7 say anything bad about them, not only during this filming but during

8 these two occasions when we briefly met. So he was not a person who

9 would react in such a manner. I reacted here to the Beqaa valley because

10 I had a feeling that I'm seeing a repetition of that in

11 Bosnia-Herzegovina. But as for Ljubisa Borovcanin, he would never say

12 such a thing in front of me. I don't remember him saying it.

13 JUDGE BAIRD: Thank you.

14 Yes, Mr. Nicholls.

15 MR. NICHOLLS: Thank you.

16 Q. Let me just ask you one follow-up based on this Baqaa valley

17 reference you're talking about, and I see how you say it's reminded you

18 of a repetition in Bosnia-Herzegovina. You remember you were asked about

19 this segment of the video in the Tolimir case. That's at T14456, and

20 when you were asked about the -- this Arabic style, you said you were

21 talking about some details on the walls of the houses that you saw

22 referring, apparently, to Srebrenica. And you actually filmed some of

23 those, is that right, that you were talking about what you had seen?

24 A. Yes, Mr. Nicholls. Even in one piece of the footage when I'm

25 talk to a former fighter who is coming back to his home and at some

Page 28480

1 terrace on the first floor, I believe, the camera shows painting on the

2 walls absolutely in the same style as the Hezbollah does in the

3 Middle East.

4 Q. You say Mr. Borovcanin would never say such things and agree that

5 after you say, This is really demolished, fuck, this is already starting

6 to look like some Arabic style. Mr. Borovcanin says, Yes, yes, yes.

7 So did he agree with you or not about that?

8 A. Well, Mr. Nicholls, you ask me too much after so many years. I

9 don't remember he got involved in that conversation at all. And I was

10 really seeing it that way: The Middle East coming to our homes. It's

11 like the Arabic Spring in Serb territory 20 years earlier.

12 Q. Okay. Could I have P194, please. That's your article

13 Mr. Karadzic showed you a little earlier.

14 And one of the things you said, it's related to this same topic,

15 is that nobody said anything bad. There was nothing unfriendly towards

16 the Muslims. You didn't hear any abusive words, something that to effect

17 today.

18 Could we go -- this should be page 7 of the English -- 6 of the

19 English - excuse me - which should be page 3 of the Serbian original. At

20 the bottom of the page in English I will just quickly read it out:

21 "Demographers will surely be interested in data that there were

22 10.000 children among the refugees. Out of that number, 8.000 were under

23 the age of 3. The 'children of war,' as they call them. 'This is, you

24 know, the concrete work of their hodzas. Fuck them. In total

25 encirclement, with no food, constantly wailing but making kids at the

Page 28481

1 same time. Is that normal? You cannot believe it. Now you tell me

2 what kind of religion is that, Islam.'"

3 And then on the next page in English, same page in the Serbian:

4 "They have produced another corps in the centre of Srebrenica

5 that will attack us again in 15 to 20 years. They had better stay out of

6 our way. Fuck them. One could see that in a Potocari on the first sight

7 each woman had a 'pack of kids hanging on her,' as Jevic put it."

8 Okay, so this is a quote from Jevic, correct? These aren't your

9 words. If you can explain.

10 A. [In English] Should I go?

11 JUDGE KWON: Yes.

12 THE WITNESS: [Interpretation] Mr. Nicholls, I believe that this

13 news report, as distinct from my television report where I did a poor job

14 as a cameraman, is one of the best illustrations of that atmosphere. I

15 don't think there's anybody here who should teach me how these news

16 reports are written. I did it as everybody does it in the world. You

17 come to a war zone, you want to document it. You record faithfully

18 everything you hear. You are right. These are not my words, but they

19 illustrate the atmosphere. I could also overhear the Muslims sitting on

20 the bus where a Muslim woman was saying some interesting things.

21 But let me just remind you, if you have a problem with this

22 number of children, Mr. Vance from the Statement Department said that

23 there were a total of around 40.000 people in Srebrenica, at least 10.000

24 under arms. And this is a fact that a demographer would find curious in

25 that war situation. That is why my report remains a document forever.

Page 28482

1 That was my job, not to iron out or wrap nicely whatever people said. I

2 was a journalist there. What was going on was a conflict, a clash of two

3 civilisations, the Christian and the Muslim one. And in the same

4 situation I would again write the same report because my job was to

5 document, to illustrate.

6 Q. Okay. Can you answer the question now. This is it a quote from

7 Dusko Jevic; right?

8 A. Yes, that's how the man introduced himself to me. I never saw

9 him again.

10 Q. Yeah, and you know -- well, was he a subordinate of Borovcanin in

11 the special police?

12 A. I can answer only in terms of probability. If he was part of the

13 special MUP unit, then he was, because Borovcanin was, at the time, the

14 highest police officer there.

15 Q. Okay. Let's look at page 2 of the English, just to help you

16 remember. Page 1 of the Serbian.

17 You got his name bolded there, "Dusko Jevic and his specials were

18 also giving out food," et cetera. Does that also help you remember?

19 A. [In English] What was the question, please?

20 Q. Does that help you remember that Dusko Jevic was a member of the

21 police?

22 A. Yeah, yeah, yeah.

23 Q. Okay. All right. Now just tell me, that comment there about how

24 the Muslims there are - I don't even know how to put it - breeding too

25 much, having too many children, according to Dusko Jevic, and "They

Page 28483

1 better stay out of our way. Fuck them."

2 How does that fit with what you told Mr. Karadzic on

3 cross-examination that there was no ill-will, no bad atmosphere? Can you

4 explain it, ill will. I mean, is this friendly - I would just like you

5 to explain - compassionate?

6 A. [Interpretation] That situation is a bit different, because that

7 man in the field had been involved in the fighting for a week by then.

8 All I saw on the faces of all the troops there is complete exhaustion.

9 When you are exhausted you don't know what you are saying, because you

10 can't raise that to the level of the level of the leadership of

11 Republika Srpska, Mr. Karadzic and the other leaders. That's nonsense.

12 I was just recording all that came out of the mouths of these people.

13 It's important to know what kind of sentiment prevails because war is a

14 dreadful thing. We all know that. People do and say all sorts of things.

15 I did not want to do any self-censorship. If I had simply thrown out

16 this passage, as I could have, we would not be having this conversation

17 now. I was showing the sentiment on the Serbian side as well, and you

18 see in a lot of my material that there are many things that are difficult

19 to even hear for some American or European person who has never seen war.

20 But my job was to make a report on a war that was still going on where

21 the main fighting was over but there were many more battles ahead, and

22 this man was well aware that there would be a lot more fighting because

23 the Muslims had not surrendered yet. And Mr. Karadzic and others can

24 confirm to you that heavy fighting was still going on. Little is known

25 about that, and information is only now emerging.

Page 28484

1 I was just trying to be very documentary in my approach. If I

2 had known, I would show you some of my reports about Israel and

3 Palestine, what the Palestinians and the Israelis say about each other

4 and how they communicate. I know that this affects you, hits you very

5 hard, you and the entire team, but I saw and heard this in a war, not on

6 the streets of Paris. I was trying to depict the human side of the

7 story, to record my first impressions unfiltered.

8 Q. And you said this, I think, if I understand about this article as

9 well, what you just said. What you've got in this article is what you

10 heard there, what you saw, not what you came up with yourself; right?

11 A. You see, 90 per cent of this text is actually quotation, except

12 that I didn't put quotation marks everywhere. I -- throughout many of

13 the sentences and turned into it a story, otherwise, it would have been a

14 monologue, but all these things I heard from people in the streets,

15 people I was with.

16 Q. Okay. Not to -- sorry, I was speaking too fast.

17 I won't -- not -- to save time I won't bring it up, but there is

18 a section in here called "bacon on the hot plate" or "slanina on the

19 oven" or something, that talks about the need to get the scent of bacon

20 into the walls so it stays forever. Just, what does that mean? You

21 talked about pork and lamb, difference between peoples or something.

22 What does that mean, getting pork into the walls so it stays forever?

23 A. How can I drive it home to you? I tried already in the first

24 part of my testimony when I talked to Mr. Karadzic.

25 Let me give you an example. I come from a part of Serbia, I was

Page 28485

1 born in Belgrade, first of all. But in the area where my parents come

2 from, people eat mostly pork. My parents sometimes brought us roast lamb

3 to Belgrade but my sister, my late sister, never wanted to eat that.

4 That's not how we were raised.

5 Those little episodes about lamb and pork, that concerned a place

6 where a refugee had lived for three years, and it's a very different

7 smell. Any Muslim from Bosnia will tell you they have the same

8 antagonism towards pork. It's maybe a thing that is not very politically

9 correct or very popular to say, but it's true. It's a clash of

10 civilisations. One civilisation prefers pork, the other lamb. If you

11 were a connoisseur or a sociologist, if you were very familiar with that

12 region, you wouldn't need so much explanation. You would notice

13 immediately. As soon as I go travel to Sarajevo I eat lamb. That's what

14 I do. But this man was coming back to a house that used to be his and it

15 suddenly smells of lamb. I was talking about realities. I was not

16 making anything up. And it contributes to getting a better picture of

17 what really happened in that war. It's a sociological picture.

18 Q. [Microphone not activated] Okay, let me look at one other part of

19 the article.

20 JUDGE KWON: Microphone, please.

21 MR. NICHOLLS: Thank you, Your Honour.

22 Q. Let me look at one other part of the article where you are

23 talking about realities, not making anything up. It contributed to

24 getting a better picture. It's page 3 of the English, Serbian page 2.

25 Bottom of the page:

Page 28486

1 "It seems that the first talks about the final elimination of

2 the Srebrenica enclave and about the possibility to free quite a number

3 of brigades tied in the enclave by the -- Oric's army have started at the

4 beginning of the year. The Supreme Command of the RS, led by the

5 president, Karadzic," in bold, "and with Mladic, Milovanovic, Gvero,"

6 et cetera, "along with a few other political figures of the 'so-called

7 Republika Srpska' as foreign media but also some from Belgrade would put

8 it, talked about Srebrenica on several occasions. In February,

9 President Karadzic already had a clear vision on plans of the Main Staff

10 of the VRS which guaranteed taking over Srebrenica."

11 And then in the next paragraph you talk about Mladic getting the

12 green light. Who did you learn that from while you were in Potocari and

13 Srebrenica?

14 JUDGE KWON: Probably he needs to see the next paragraph in

15 B/C/S.

16 MR. NICHOLLS:

17 Q. [Microphone not activated] Do you remember the question?

18 A. [In English] Excuse me, please.

19 Q. Where did you get that information from? Who told you about how

20 these plans had begun and been exercised in the time-line, et cetera?

21 A. [Interpretation] I cannot cite any names, but a number of these

22 officers who were in the field then, including Borovcanin, told me a few

23 things. But I picked up here and there these things, and that article

24 appeared on the 21st of July. When I finished editing my video material

25 I had more time to dedicate to this, to make a chronology of events for

Page 28487

1 myself. Of course, I was not at Pale. I was not able to find all that

2 out. And there is even an error here as to who was part of these units.

3 I had a wrong piece of information. General Gvero was not part of that

4 group. And I cannot tell you the names of all my sources, but these are

5 normal sources for journalists that provide a complete picture, because

6 not a single military operation can be planned within three days.

7 This is a very hastily produced article published in end July.

8 If I had written it in 2006, it would have been different. I may have

9 gotten a few details wrong, but I cannot give you the names. The sources

10 were in the military, of course, but also analysts, analysts from

11 Belgrade and elsewhere. There were many people who followed these

12 events, the Srebrenica operation.

13 Q. Now, let me move on. You talked and it's your interview with me

14 from 2006, I think - we saw at e-court pages 115 and 116 - about how

15 apparently the Bosnian Serb leadership saw the Studio B documentary,

16 asked for a copy, got sent up by bus, and then the feedback you got was

17 that they thought it was very positive and balanced and a good thing.

18 And you said in the interview that Krajisnik, you knew, saw it.

19 So my question is: Try to remember now who was it? Do you have

20 any details you didn't remember before? Do you remember now how you got

21 the message from the Bosnian Serb leadership, if I call it that, that

22 they approved of your video documentary?

23 If you don't remember, that's all right. But I just wonder if

24 you remember now.

25 A. I am willing to assist. Please make no mistake. I'm thinking.

Page 28488

1 Studio B is a city television. They could not see it at Pale at the

2 time. So it must have been somebody from Republika Srpska in Belgrade

3 who saw it and told the people at Pale.

4 I don't remember, although I had interviewed Mr. Krajisnik

5 before, as well as all the other leaders, expect Mladic. He was the only

6 one to whom I never gained access. They said that probably through

7 journalists who -- their own journalists or foreign journalists who are

8 based in Belgrade. They were close to the leadership and they could get

9 interviews from them, and I suppose they told me. One of the journalists

10 told me. But it -- I know that it's not they who told me directly. And

11 we sent the tape to them by bus. Zoran Zaharijevic [phoen] was involved

12 in that. But they were certainly unable to see that footage until we

13 sent them the tape. They couldn't see it on satellite TV, for instance.

14 Q. And did anyone from the Bosnian Serb leadership come down to you

15 and say, Hey, we saw your documentary. There's a pile of bodies in front

16 of a warehouse. Can you tell us more about that? Where is this? What's

17 going on? We're concerned about this pile of corpses in your

18 documentary.

19 A. I can't remember, Mr. Nicholls. I would have remembered if it

20 had been Mr. Krajisnik, especially Mr. Karadzic, from whom I had not

21 heard for long at the time [as interpreted]. None of them contacted me

22 directly. It must have been through our common journalist contacts.

23 Q. Mm-hm.

24 A. That they let me know their reaction through those journalists.

25 Or perhaps they even called Studio B. I can't know that. I was not

Page 28489

1 full-time employed with Studio B. I was just one of their

2 correspondents.

3 Q. Do you know Dragan Cicic?

4 A. I know who that is. He was a journalist for the "Nin" magazine,

5 a leading Serbian weekly. He was not a career journalist. He turned up

6 out of nowhere and started writing for the "Nin" magazine. I never

7 actually talked to the man. We just exchanged hellos around the office

8 when I passed through.

9 Q. You made some pretty serious allegations against Robert Block,

10 calling him a liar, et cetera.

11 A. [In English] Block.

12 Q. Block, yeah.

13 A. Excuse me, [Interpretation] Cicic called him a liar or I? I did

14 call him a liar.

15 Q. You called Robert Block a liar in court today. That's what I'm

16 getting at.

17 A. That's right.

18 Q. And now I'm just going to put it to you: Did you speak with

19 Mr. Block and Dragan Cicic after the Studio B documentary had been aired,

20 after Mr. Block published his article, "Bodies pile up in horror of

21 Srebrenica" in "The Independent," which referred to your article, and

22 expressed that you were angry at him, that he had no right to have used

23 your tape and that it had gotten you in trouble with the authorities in

24 the RS which is completely contrary to what you say about them being

25 pleased with the content?

Page 28490

1 A. Excuse me, for laughing. I would have to have complete amnesia

2 regarding my entire life to accept this. What's funny is that Cicic is

3 turning up in this story because Block was accompanied by Grubacic all

4 the time. That's the first oddity in what you are saying. He was the

5 first one who reviewed my material after reading Michael Dobbs, the

6 article I mentioned in the foreign policy magazine. I don't remember

7 talking to him. If it were just a hello, I could have forgotten, but if

8 I had spoken to him at length -- and can you really imagine that I would

9 tell a foreign journalist that Karadzic and his team were angry with me?

10 I still claim that it's a complete fabrication. I have no reason to

11 claim that he hadn't been with me if he had. I didn't even have to

12 mention the contact I had with him in Bratunac. But I remember

13 absolutely nothing about seeing him in Belgrade, and that's why I call

14 him a liar, because as soon as somebody gets into somebody's place and

15 takes something that doesn't belong to him he both a thief and a liar.

16 Q. Okay. Well, one, you're absolutely sure you remember seeing

17 Robert Block in Belgrade. And I ask you that because his testimony

18 is that -- I mean, excuse me, in Bratunac, when you were there. Because

19 his testimony, I have to be fair, put it to you, in this case, and it has

20 been consistent, was that he never crossed the Drina river into the

21 Republika Srpska, that his reporting was done on the Serbian side of

22 Ljubovija bridge. He was not able to get to Bratunac, even though he

23 tried. So think carefully. Did you see him in Bratunac, or are you

24 making a mistake?

25 A. He was absolutely in Bratunac, but he hadn't crossed the Drina to

Page 28491

1 arrive in Bratunac like I did. He had been there a while, and

2 Braca Grubacic will confirm, if he is honest. They had come from the

3 territory of Republika Srpska, not from Serbia. That's the first thing

4 that he is saying that is untrue. That's what he said to me. We have

5 been travelling around Bosnia for a while, and we are coming now here to

6 see what's going on. That's what he told me. And he was accompanied by

7 somebody who served as his interpreter at the same time and he was

8 collecting stories.

9 First of all, Block was never called here before I mentioned him,

10 and his articles started appearing already on the 16th and 17th July.

11 And they were a serious landmark for all the other journalists reporting

12 on Srebrenica, that 500, 600 people were killed in a school house in

13 Bratunac. A normal person could not invented something like that, could

14 not write something like that. Perhaps he did not say 1500 but he said

15 hundreds. I saw him in Bratunac. Somebody introduced him, and even

16 Ljubisa Borovcanin also said hello to him. I can't remember who

17 accompanied him, but there were four of us standing in the streets of --

18 in Bratunac.

19 Why would Bratislav Grubacic be there in that year? He had a

20 magazine called "VIP," and he was a very well respected source from

21 Serbia for foreign journalists, and he had a lot of political experience,

22 but he was there just as an escort, a journalist escort, to that foreign

23 journalist. Why would I have made up Block's presence there, because I

24 was surprised to see him there as an Englishman. And let me add one

25 thing. He could have been there only thanks to his connections with the

Page 28492

1 regime in Belgrade. Somebody must have intervened with the army to let

2 him through. That was the only way he was able to walk freely around

3 there without any escort. He was not under surveillance. He was only

4 with Grubacic, nobody from the army. Nobody was watching him.

5 Q. You remember him as being an English journalist?

6 A. Well, we say English. It can also be an American who worked for

7 the English. To this day, I don't know whether is he an American. But

8 usually people say English. Maybe he was an American who worked for

9 "The Independent"; right?

10 Q. Let me ask you one question before I think we're -- we're at the

11 break --

12 JUDGE KWON: You have more?

13 MR. NICHOLLS: A little bit, Your Honour, yeah.

14 JUDGE KWON: Very well. We will take a break for an hour and

15 resume at 1.30.

16 THE ACCUSED: [Interpretation] May I suggest that we take a

17 shorter break, because I would just like to ask for ten minutes and then

18 we could finish early today.

19 MR. NICHOLLS: Those representations in the past by Mr. Karadzic

20 about how long he's going to take have not been accurate. And we haven't

21 ever had ended up finishing early when we said we would. I just have to

22 make that observation.

23 [Trial Chamber confers]

24 JUDGE KWON: The Chamber will resume at 1.30.

25 --- Luncheon recess taken at 12.34 p.m.

Page 28493

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

2 JUDGE KWON: Yes, Mr. Nicholls, please continue.

3 MR. NICHOLLS: Thank you, Your Honour.

4 Q. Doctor Pirocanac, I'm going to -- Dr. Petrovic, excuse me --

5 A. [In English] It's okay.

6 Q. I will try to finish off very quickly now. All right. Still on

7 the topic of Mr. Block's statement. He didn't publish it in any articles

8 but his statement that you told him that President Karadzic himself was

9 angry over the footage, speaking of the Studio B footage.

10 You're laughing.

11 A. Yes, that's my answer.

12 Q. Yeah, I'll ask you the question now.

13 Could I have 1D5116, please. This is a Defence document,

14 Mr. Petrovic, Dr. Petrovic. I will let you it was used when Mr. Block

15 testifies [sic] here. This is an e-mail from Dragan Cicic to

16 Mr. Robinson, the attorney working with Mr. Karadzic, and very quickly,

17 Mr. Robinson asked the question, if you see on the seconds paragraph on

18 the bottom pardon:

19 "An issue has come up in Mr. Karadzic's trial relating to your

20 visit with Robert Block to Zoran Petrovic-Pirocanac at his apartment

21 after you reviewed the Studio B footage."

22 And the answer, I'm trying to save time, if you look up,

23 Dragan Cicic writes:

24 "I do remember that Mr. Petrovic-Pirocanac said that he got in

25 trouble with the authorities of Republika Srpska because of his footage.

Page 28494

1 "I do not recall whether he specifically mentioned Dr. Karadzic

2 by name, though did I assume at the time that his reference is included

3 all the people in the leadership of Republika Srpska."

4 So, again, does that jog your memory of meeting not just with

5 Mr. Block but also with Dragan Cicic in your apartment in Belgrade after

6 the tape disappeared from Studio B, and you saying that you got in -- --

7 that the Republika Srpska leadership was angry? Or can you explain why

8 Dragan Cicic says this, if it didn't happen?

9 A. First of all, I live in no apartment. I live in a house that is

10 22 kilometres away from Belgrade. I don't know if you asked about the

11 address of this "apartment" of mine. That is a small detail that would

12 be of interest to you as an investigator.

13 Secondly, I remember another man very well, whom you've never

14 called in. He is quite interesting. He was sitting with me in Studio B.

15 His last name is Schiller. He's from the "Toronto Star" or some other

16 Canadian daily. He sat with me at the editing room. He was with

17 Naser Oric in Srebrenica. He said to me, and he said that he saw Serb

18 heads rolling, as they were cut off. He sat there and watched me edit

19 this TV programme, Schiller, and he looks like that American actor who is

20 a comedian and who has grey hair. I can't remember his name now. But

21 anyway, I remember, Schiller, and I assume I'd remember Block, too. I

22 repeat to you once again, Block. I mean, that looks to me like the story

23 about that Dutch journalist who came to see me at home. He provoked me,

24 and at one moment I said, Well, I don't even want to talk about it

25 anymore. He maltreated me with this raw material. This is before you

Page 28495

1 got the original of my TV programme. So it is only in that context that

2 Block falls into the picture. I mean, if you were to call me people at

3 home while I'm sitting here and ask, Was he ever at our home? I mean, I

4 tell you, I can guarantee that Cicic never came to see me. He said

5 apartment. And I live in no apartment. I live in a big house in a

6 village. So this is not a reliable witness, and this angers me. Sorry

7 about that. But why would this Mr. Nobody, Cicic, and Block invent all

8 of this? I was honest with you. I told you the truth. And Block is in

9 the story about Bratunac. Didn't he publish his story about rumours in

10 Bratunac already on the 16th and 17th; namely, that hundreds of people

11 were killed in the school. That is what they came up with, on the basis

12 of rumours.

13 JUDGE KWON: Just a second, Dr. Petrovic. Can I remind you that

14 it is not Mr. Cicic that referred to your apartment. It is Mr. Robinson

15 that referred to your apartment and all that Mr. Cicic said in this

16 alleged e-mail correspondence is that he remembered that you said that

17 you got in trouble with the authorities of Republika Srpska because of

18 your footage. That's all that he said.

19 THE WITNESS: Yes, Your Excellency, I will clarify.

20 [Interpretation] So, in this letter, Cicic says that I got into

21 trouble with the authorities of Republika Srpska. He is no friend of

22 mine. I never socialised with the man. I would not be confessing to him

23 that Republika Srpska held certain things against me. The truth is quite

24 different, but that has nothing to do with Cicic's inventions. I had

25 trouble with different soldiers from Republika Srpska, and I received

Page 28496

1 threats to the effect that I would be killed because of your report, the

2 one that you see here. But this really has nothing to do with the

3 authorities of Republika Srpska. Indeed, if that were the case, I

4 wouldn't be testifying here now with Mr. Karadzic. Sorry for saying

5 this. This is staged, as the Americans would say, and it's a completely

6 foolish thing. There is no reason for me not to remember him.

7 [In English] "I do not recall whether he specifically mentioned

8 Dr. Karadzic by name, though I did assume at the time that his reference

9 included all the people in the leadership of Republika Srpska."

10 [Interpretation] Your Excellency, once again, I repeat, this is

11 an absolutely. Several times I had this opportunity. I mean, people

12 from French television know about that. I received threats. But these

13 are individuals from Republika Srpska who were not pleased when they saw

14 my report. But the anti-war lobby in Belgrade was not pleased with it

15 either; that is to say that they were both against it. But this really

16 has nothing to do with the leadership of Republika Srpska. Not in any

17 way, not in any point in time.

18 Let me repeat once again. I found out about this only late. I

19 think that I mentioned that at General Tolimir's trial twice.

20 Prominent -- no, they're not prominent. At one point in time,

21 General Mladic prevented someone from killing me. That's what

22 journalists told me. That's one thing. And the other time was that

23 Zeljko Raznjatovic, Arkan, heard that some of his people were talking

24 about that, about this idea of killing me, and he prevented that. And

25 that is why I appear before you today, because I had not been

Page 28497

1 assassinated but this had nothing to do with the leadership of

2 Republika Srpska. I was on excellent terms with them, especially with

3 President Karadzic and madam vice-president, Biljana Plavsic, until she

4 became president.

5 Q. Let me stop you there because I think you have answered the

6 question. I have very little time. All right.

7 JUDGE KWON: Let me ask a further question, Mr. Nicholls.

8 You just stated, Dr. Petrovic, that you had trouble with

9 different soldiers from Republika Srpska. Can you be more specific about

10 that? Who threatened you or for what?

11 THE WITNESS: [Interpretation] Your Excellency, Your Excellencies,

12 I never encountered the people who did that, but I did receive threats

13 from different quarters, journalists included. I remember when one of my

14 woman colleagues when she crossed over to Republika Srpska was asked by

15 some soldiers, Where is that Pirocanac? We're waiting for him.

16 She can confirm that any time, if anyone asks her in Belgrade.

17 Also, there were other sources that I consider to be a warning so

18 that I would be aware what was going on. I established that this had

19 nothing to do with the political levels of Republika Srpska, but many

20 were dissatisfied with my report and it turned out that it was a very

21 important source to find out more about these events.

22 I don't know what the point is of this renowned journalist,

23 quote/unquote, Dragan Cicic to say all of this, or perhaps I've just

24 deleted all this from my memory. But how would that be possible? How is

25 it that I remember Schiller from Canada who was with me during those days

Page 28498

1 precisely? Had Blocked asked me, he could have seen this while sitting

2 next to me. The "Bowl of Stones" is the name of a book that was written

3 by a man who was in Belgrade, and he was there for a month and he saw a

4 lot of people there and then he mocked me and other people later on. He

5 ridiculed us. He watched the material when I was editing it. You can

6 check this. Two men watched the material as I was editing it, so why

7 would I not agree to this third one? I wasn't aware of this until

8 recently, until Michael Dobbs wrote about this, and I trust Michael Dobbs

9 more than I trust this Block.

10 JUDGE KWON: It -- in relation to Mr. Cicic's comment that you

11 got in trouble with the authorities of Republika Srpska, can one not view

12 military leaders as part of authorities of Republika Srpska?

13 THE WITNESS: [Interpretation] Your Excellency, of course. But

14 that had nothing to do with Mladic or with any other senior officers.

15 You have to know that my criticism of Republika Srpska was because it was

16 not all right and proper. It is not that all soldiers on the front line

17 were at war. There were parts that were under poor military control,

18 which, in part, explains what happened in Srebrenica, as revenge, which

19 is impermissible in the military. But there are no leaders involved. I

20 absolutely claim that that is an invention. Even if he had seen me, as

21 he did not, I mean, I only saw the man at the "Nin" office and much later

22 at that. So, in this situation, I did not see him with this Block, and I

23 think that this is a miserable fabrication. I have no reason not to

24 mention them. They are of no significance for Srebrenica at all. They

25 are a small fry, or peanuts, if you will. But I still don't see what the

Page 28499

1 point is of this, and I completely deny their allegations. If you want,

2 we can take a lie detector test.

3 JUDGE KWON: Back to you, Mr. Nicholls.

4 MR. NICHOLLS: [Microphone not activated] Thank you, Your Honour.

5 Q. And after --

6 JUDGE KWON: Microphone, please.

7 MR. NICHOLLS:

8 Q. And after the, as you say, authorities of Republika Srpska

9 requested a copy of the tape, and after it disappeared in unknown ways

10 from Studio B, when we received a copy of your raw data, some of the

11 missing parts were scenes of the bodies in front of the Kravica warehouse

12 and the men on the balcony replaced by the shell casings, among other

13 parts, missing [sic].

14 You've never - and correct me if I'm wrong - been able to explain

15 how it is that coincidentally those are the parts missing from the

16 documentary -- from the documentary that are missing on your raw footage;

17 is that right? You still can't explain that.

18 [Microphone not activated] Is it a coincidence?

19 JUDGE KWON: Just a second. I don't think that your last word

20 was translated because microphone was not activated.

21 MR. NICHOLLS:

22 Q. [Microphone not activated] My question was: Is it a

23 coincidence. I had the wrong -- is it a coincident, was the last part.

24 A. [In English] Mr. Nicholls, here we come again. [Interpretation]

25 For the umpteenth time I'm going to say this now. I'm still astonished

Page 28500

1 by the fact that practically never they used the actual material of the

2 programme but only the raw material, which is unfair, in my view.

3 So if my 8-millimetre cassette, which is not professional, this

4 is an amateur tape, if it is given to, I don't know how many addresses,

5 over a certain period of time, whoever asked me to view this was given

6 opportunity to do so, many journalists from throughout the world who were

7 in our part of the world. We can only assume now what happened. But

8 it's not only that those scenes were deleted that appear in the original,

9 others were as well. You did not mention that at one point in time there

10 is a studio where Radovan Karadzic was, and I was with the Frenchman a

11 year before that, I went to see him, I mean. I already told you I'm not

12 a cameraman. I had that as well, so then there were traces of that as if

13 you will. Then Mr. Blasik saw this in my home, these empty tank shells

14 on my terrace. You will agree with me that it is impossible for me

15 not -- I mean, this situation cannot be resolved. Obviously we are never

16 going to find out what happened, and I'm saying that for the benefit of

17 the public and my own country as well, as I have told you so many times.

18 You have the originals. The Court has the originals, and for

19 years they were considered to be missing pictures, erased pictures. So

20 that exists there and I think that that is what matters the most, for

21 history and for your work. And I assume that someone should say thank

22 you to me at some point for all this. But, no, in Belgrade, to this day,

23 there are manipulations that are bandied about in 2012. Do tell the

24 entire public of the former Yugoslavia once and for all that this footage

25 exists, that you have it. The people on the terrace of the white house

Page 28501

1 and those three seconds by the hanger as we are passing by, I think that

2 this is a huge contribution of mine as a journalist. I wish it could

3 have been even greater, but ...

4 Q. Thank you.

5 MR. NICHOLLS: No further questions.

6 THE ACCUSED: [Interpretation] Excellencies, I believe that the

7 learned Mr. Nicholls brought in a great deal or new material, so I kindly

8 ask for additional time to put additional questions.

9 JUDGE KWON: Could you tell us which is new and what kind of

10 questions you are going to put to the witness.

11 Just first tell us which part of Mr. Nicholls' re-examination

12 introduced new factors.

13 THE ACCUSED: [Interpretation] Hodzas and birth-rate. That is one

14 important thing. Then there are other things as well but this is the

15 most important. And also, the presence of Islam from the Middle East and

16 clashes within the Muslim society itself on account of that.

17 A few brief matters. And I will kindly ask the witness to give

18 yes or no answers and it's not going to be long.

19 JUDGE KWON: Just a second.

20 [Trial Chamber confers]

21 JUDGE KWON: Can I hear from you, Mr. Nicholls.

22 MR. NICHOLLS: I don't want to use any of my time, Your Honours,

23 but I don't believe anything -- that I opened any new doors. I used the

24 article which Mr. Karadzic used, and I don't think I opened any doors and

25 it's not warranted.