Tribunal Criminal Tribunal for the Former Yugoslavia

Page 6504

1 Tuesday, 29 May 2001

2 [Open session]

3 [The witness entered court]

4 [The accused entered court]

5 --- Upon commencing at 9.35 a.m.

6 JUDGE HUNT: Call the case, please.

7 THE CLERK: Yes, Your Honour. This is case number IT-97-25-T, the

8 Prosecutor versus Krnojelac.

9 JUDGE HUNT: Sorry for the late beginning. We were trying to

10 organise something of an administrative nature to enable us to have

11 documents for court on Monday mornings. Ms. Kuo.

12 MS. KUO: Thank you, Your Honour.

13 WITNESS: MILADIN MATOVIC [resumed]

14 [Witness answered through interpreter]

15 Cross-examined by Ms. Kuo [continued]:

16 Q. Good morning, Mr. Matovic.

17 A. Good morning.

18 Q. Mr. Matovic, yesterday you told us that you worked with [redacted]

19 [redacted] for several years as colleagues at the KP Dom before the war and

20 you also told us that you saw him at the KP Dom when he was detained

21 there. You spoke freely with [redacted], right, because you had worked

22 together as colleagues?

23 A. Yes. With my colleague [redacted], I worked for about five

24 years on the job of admission and dispatch and censorship. Every day we

25 worked from 8.00 a.m. to 3.00 p.m. and we were exceptionally good

Page 6505

1 colleagues on exceptionally good terms and we substituted for each other

2 whenever necessary and we were ready and willing to help each other out.

3 Sometimes one of them -- one of us would stay in our workplace and let the

4 other go and do whatever business he had to finish.

5 Q. And when you saw him at the KP Dom, although he was a detainee and

6 you were a guard, you still treated each other decently, right?

7 A. Yes, certainly. I never ever regarded him as anything but a good

8 colleague, as usual. Yesterday in my testimony, I said I had worked at

9 the mine with [redacted] for about a year, and while we were working at

10 the mine, I did my best to help him by supplying him with cigarettes,

11 giving him extra bread. I did whatever I could for that colleague of mine

12 and I think he appreciated it and he told me on several occasions that he

13 was grateful.

14 Q. There was never any reason for you to lie to him about anything,

15 was there?

16 A. There was no need for anything of the kind. We were colleagues.

17 Why should I lie to him? Our relationship remained the same or almost the

18 same as before the war.

19 Q. And you've never known [redacted] to lie about anything you may

20 have said or done, right?

21 A. I wouldn't know about that.

22 Q. You never had any quarrels with him that would cause him to lie

23 about you, right?

24 A. I never had a quarrel with him and, as I said, when we were

25 working at the Miljevina mine, with those who worked in the kitchen and

Page 6506

1 served food, I worked together with them, serving cigarettes, and I

2 sometimes took cigarettes in my own name in order to give them to him.

3 Q. Mr. Matovic, isn't it true that while [redacted] was detained

4 at the KP Dom that you told him that Milorad Krnojelac was on the

5 executive board of the SDS?

6 A. I never discussed that topic with [redacted] and, as far as I know,

7 Mr. Milorad Krnojelac has never been a member of any party, and that is

8 the truth. We never, never discussed that topic.

9 Q. [redacted] was never charged with a crime, right?

10 A. Not that I know of. And if he had been, he wouldn't have been

11 able to work in the establishment where he was employed, because anyone

12 with a criminal record or anyone who was involved in criminal proceedings

13 and was older than 25 years old could never find a job in the KP Dom, so

14 I'm not aware that he had a criminal record.

15 Q. And during the time that he was detained at the KP Dom, from 1992

16 until October of 1994, [redacted] was never charged with a crime at

17 that time, was he?

18 A. Not that I know of. I never heard from any one of his colleagues

19 that he had been charged with anything. If there had been an indictment

20 against him, he wouldn't have been allowed to go out to work at the mine,

21 because that's about 15 kilometres away from the town.

22 Q. And the time when he was taken to work at the mine was in late

23 1993, right? About the time that you started accompanying Muslim

24 detainees to work there.

25 A. I think it started sometime in September 1993 and lasted for about

Page 6507

1 a year, starting with September 1993.

2 Q. From 1992 until 1994, the two -- more than two years that Mr.

3 Hajric was detained at KP Dom, there was never any review process for him

4 or other Muslim detainees to be released, was there? They were never

5 taken to an administrative review board or court to be permitted to make

6 the determination if they could be released, right?

7 A. I am not aware that anyone was taken to such a thing. People who

8 were authorised came in to conduct interrogations and deal with that part

9 of work. Whether anyone was found guilty or whether anything was

10 reviewed, I couldn't possibly know because that was not within my purview.

11 Q. Mr. Matovic, yesterday you testified that Radojica Tesovic was the

12 warden of the KP Dom before the war and that, as warden, he was also in

13 charge of the Velecevo women's prison, right?

14 A. Yes. Radojica Tesovic was warden before the war and he was also

15 warden of the women's prison practically, although the formal warden of

16 the women's prison was Suada Kapetanovic, but in a way, the women's prison

17 belonged under the KP Dom so Radojica Tesovic was warden before the war.

18 Q. And during the war, the military took over Velecevo to install a

19 military headquarters, right? So the women prisoners were no longer kept

20 there?

21 A. I don't know anything about Velecevo or why it was taken over. As

22 for women who had been serving their sentences, some of them were

23 transferred to the farm to work and they were under our external security

24 service there. They -- their job was to take care of the cows and hens,

25 to collect eggs, because at that farm, we had pigs, cows and hens.

Page 6508

1 Q. When Mr. Tesovic was warden of the KP Dom, he was in charge of

2 both the Drina Economic Unit and also the prisoners who were being housed

3 there, right? He wasn't simply in charge of the Economic Unit, he was in

4 charge of the entire institution, right?

5 A. Before the war, the warden Radojica Tesovic had under him a

6 director of the Drina Economic Unit. He had his own deputy, he also had

7 an assistant for economic and legal affairs, and you couldn't really say

8 that Radojica Tesovic alone was responsible for everything. As far as the

9 Drina Economic Unit is concerned, its director was also responsible for

10 it.

11 Q. But in other words, Mr. Tesovic was on the top and he supervised

12 the manager of the Economic Unit as well as his deputy and the assistant

13 warden for financial and legal affairs, right? That's what it means to be

14 warden; you're in charge.

15 A. Yes. The director had his own business to attend to, as did

16 others, but the warden was the chief to whom all reports were submitted

17 before the war.

18 Q. Mr. Tesovic was a good warden, wasn't he?

19 A. Mr. Tesovic was head of the rehabilitation service for four years

20 and then he was warden and, in my mind, I cannot find anything bad to say

21 about him. In my memory, he remains as a good warden, a good man.

22 Q. He was always very professional and loyal to the institution,

23 right?

24 A. Yes. He was very professional and he required professionalism

25 from others.

Page 6509

1 Q. If he had learned that any of the guards had mistreated prisoners,

2 he would have taken action to discipline them, right? That's not

3 something he would have tolerated?

4 A. I don't think he was the only one who would have done that.

5 Anyone who was heading that establishment would have done the same, be it

6 Radojica or anyone else.

7 Q. When Mr. Tesovic, at the outbreak of the war, went to Tuzla with

8 the prisoners, there was never any indication that he was deserting,

9 right? I mean, he went there on official business, to take prisoners to

10 safety.

11 A. Mr. Tesovic, Mr. Milutin Tijanic and others who were in the

12 same group took between 98 and 100 prisoners out of the prison and it was

13 uncertain when they were going to come back, and I think that they stayed

14 away for about ten to 15 days. From what I heard from my colleagues who

15 were escorting those prisoners on the way, I know that they had come

16 across various guard posts on the way, through Yugoslavia, et cetera, and

17 when they came to the border crossing near Tuzla, they had to face

18 enormous problems in handing over those prisoners.

19 JUDGE HUNT: Yes, Mr. Bakrac.

20 MR. BAKRAC: [Interpretation] Your Honours, I apologise for

21 interrupting my learned friend. Perhaps the witness should repeat this

22 because there is a mistake in the transcript. The transcript does not

23 reflect what the witness truly said about the length of their trip. It's

24 line 14. I can say what the witness really said but perhaps we should do

25 it another way. Perhaps my learned friend should ask the question again.

Page 6510

1 JUDGE HUNT: It's line 13, actually, but anyway, perhaps if you

2 can ask the question again and see if you get the same or a different

3 answer.

4 MS. KUO:

5 Q. There is a little bit of disagreement about how many

6 days Mr. Tesovic was away. Could you tell us again how many days he was

7 away?

8 A. I already said from ten to 20 days.

9 Q. After --

10 MR. BAKRAC: [Interpretation] Your Honours, it's a mistake again.

11 He said from 15 to 20 days, not ten to 20 days.

12 JUDGE HUNT: Is this something of grave importance, Mr. Bakrac?

13 MR. BAKRAC: [Interpretation] Your Honours, we believe that the

14 transcript should reflect what the witness really said. I wouldn't

15 venture to assess the importance of this. If you think that I should

16 refrain from reacting when I see a mistake on the record --

17 JUDGE HUNT: I would suggest only this, Mr. Bakrac; that when the

18 witness is giving very important evidence, it's not a good idea to

19 interrupt and you can save it up for later. Unless it's important. Yes,

20 you proceed, Ms. Kuo.

21 MS. KUO:

22 Q. So he was gone up to 20 days, right?

23 A. I said between 15 and 20 days.

24 Q. He left at the beginning of the war, right? The war broke out on

25 the 8th of April and he left very shortly, maybe a day or two after that?

Page 6511

1 A. Yes, that's correct, because those of us who stayed behind at the

2 Dom, after we had packed the convicts into Furgon vehicles and sent them

3 away, Mr. Tesovic joined them at Velecevo and went away with them.

4 Q. So he would have returned by the end of April, right?

5 A. I don't know about that, but he was gone for about 15 to 20 days.

6 I wouldn't be able to tell you the date when he returned because, when he

7 came back, he never reported back to us and I had no further contact with

8 Radojica Tesovic.

9 Q. When Mr. Tesovic returned, he was not made warden of the KP Dom,

10 his old position, right?

11 A. I think they couldn't have appointed Radojica Tesovic because they

12 had no idea, no information when he was coming back, and perhaps they were

13 not expecting him to come back at all.

14 Q. When he returned, he was put to work on the farm, doing manual

15 labour, right? Tending to the animals and crops?

16 A. I saw Mr. Tesovic on the farm but what job he had there, I really

17 don't know.

18 Q. He wasn't director of the farm during that time; he was only made

19 director of the farm in September of 1993, right?

20 A. In that period, he certainly wasn't director of the farm, but what

21 other jobs he held, I don't know. Whether he had worked in the security

22 service of the farm, whether he was the rehabilitation officer, I'm not

23 aware, but I know he was not director of the farm.

24 Q. Mr. Milorad Krnojelac was appointed as temporary warden in

25 mid-April of 1992, right?

Page 6512

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Page 6513

1 A. Milorad Krnojelac was appointed temporary warden but I have

2 already stated during my earlier testimony that I never thought of him as

3 a temporary warden, just director of the Drina Economic Unit, because I

4 had occasion to meet with Krnojelac several times in the furniture

5 factory, and he talked with the foremen, discussing production, dispatch

6 of furniture, rehabilitation of the furniture factory, repair of

7 installations, et cetera, because the factory itself was badly damaged by

8 bombing and had more than 1.000 square metres of shattered window panes.

9 And as soon as Milorad Krnojelac took over on his position, I know that he

10 gathered all of us at the furniture factory in the assembly section and

11 told us that the window panes have to be reinstalled; if there was not

12 enough glass, we should use whatever material was available. In any case,

13 we had to start immediately repairing the windows and other damage in the

14 furniture factory.

15 Q. And in fact, when Mr. Krnojelac told you all to start doing that,

16 you did, right? And collectively you repaired the furniture factory?

17 A. We did the repairs together but the furniture factory has still

18 not been completely repaired. We tried to attend to, first, to those

19 areas where production was going on. It would take an investment of about

20 1 million Deutschmarks to do all the repairs that are needed, so great was

21 the damage. But the damage -- but those areas, those sections of the

22 furniture factory where production is located have been repaired.

23 Q. And one last question about the damage there: Was the damage due

24 to shelling or was it damage done from people being inside the factory?

25 You talked about all the window panes being shattered. That was from

Page 6514

1 shelling, from mortars, right?

2 A. Yes. It was from shells, from mortars, because as we were leaving

3 the KP Dom, both Serbs and Muslims, the KP Dom remained in proper

4 condition. After the Muslims came, practically everything that could have

5 been destroyed was destroyed: The windows were broken, the cupboards

6 were all topsy-turvy, the doors were broken; it certainly had

7 nothing to do with the pre-war picture.

8 Q. I'd like to go back to something you said yesterday. You

9 testified that desertion was, as you said, widespread. And by desertion,

10 you meant people who did not want to serve in the army and chose to leave

11 instead, right?

12 A. All of those who had money, all of those who had families outside,

13 all of those who had relatives and friends outside, all of them left, and

14 I consider that to be desertion.

15 Q. And it's also a form of desertion to leave a compulsory work

16 obligation, right? Not just leaving the military itself. If you were

17 assigned to a compulsory work obligation and you left it, you left the

18 town, you would consider that desertion as well, right?

19 A. Desertion, for me, is abandoning work duty. It was not desertion

20 when somebody left that area in order to go to a different country, a

21 different state, so that's what I mean by desertion.

22 Q. You stated yesterday, and actually you talked about it a little

23 bit today as well, that when Mr. Tesovic left Foca to take the prisoners

24 to Tuzla, people weren't sure -- you claimed people weren't sure if he

25 would come back because there was a possibility he would desert.

Page 6515

1 A. Yes, yes. That means that Mr. Radojica Tesovic went to a

2 different state; Montenegro, Serbia, Yugoslavia. These are different

3 states in relation to Bosnia.

4 Q. Had Mr. Tesovic remained outside Bosnia during the war, had he not

5 come back, nothing would have happened to him, right? He would simply

6 have sat out the war.

7 A. I'm not aware of him having left and not coming back and what

8 would have happened to him, but I reckon that had Mr. Radojica Tesovic

9 left without coming back, he would not have come back at all. Like all

10 the rest who have left those parts, nobody really wants to come back ever.

11 Q. And another example -- an example you gave of someone who left and

12 didn't come back was Dr. Cedo Dragovic, who left in August or September

13 of 1992, right? He never came back.

14 A. I did not see him. It's been eight or nine years now. I've never

15 seen Cedo Dragovic since then. In town, that is.

16 Q. But it wasn't the kind of situation where he was hunted down and

17 dragged back and put into prison, right? He was simply allowed to stay

18 away and not participate in the war.

19 A. I said that Cedo Dragovic probably left because his family was out

20 of Yugoslavia, and that's probably why he left, and he had no motive to

21 return to these parts. Everybody who had somewhere elsewhere left.

22 Q. Mr. Matovic, yesterday you told us that your house burned down.

23 Could you tell us when that was?

24 A. My house, I found out that my house burned down sometime around

25 the 12th of April. I left on the 8th of April and I went to the KP Dom

Page 6516

1 and I spent three days there and then I went to the village, to my

2 parents' place, and since roadblocks had already been placed, my wife and

3 two daughters could not have come to me. They went in the opposite

4 direction, that is to say, to my landlady's sister. Now, when I phoned,

5 when I phoned my landlady, my wife didn't answer the phone but she did.

6 She recognised my voice.

7 Q. Mr. Matovic, you told us this yesterday. You phoned your landlady

8 immediately when you reached that village, right, to make sure that your

9 family was okay?

10 A. Yes. I called to see how my wife and daughters were doing.

11 Q. So since you spent three days at the KP Dom, after the 8th of

12 April, that would have been the 11th or possibly the 12th of April when

13 you called home? Right?

14 A. I spent the 8th and 9th and 10th of April in the KP Dom and then I

15 went home. I can't remember the exact date. Could have been the 12th or

16 the 13th. At any rate, when I called, everything had burned down.

17 Everything was in ashes.

18 Q. Had your house just burned down or had it burned down a few days

19 before?

20 A. It is possible, it is possible that my house burned down a day or

21 two earlier, but when I called, they told me that the house had burned

22 down. As for the date, I couldn't have known and they couldn't have known

23 either because the house had been abandoned. We had all left. That is to

24 say that my wife and I and the landlord and the landlady had left the

25 house. And now when that happened, I don't know, but all of this was

Page 6517

1 burned down. The first houses on the territory of the town that had been

2 burned down were Serb houses, the seven houses I enumerated yesterday.

3 Q. So you're telling us since nobody was living there, nobody could

4 have told you who burned those houses down, right? Nobody saw that?

5 A. Indeed, no one saw that. However, people talked and until the

6 present day, I have been socialising with --

7 Q. We are only here to deal with the facts, not with rumours. Your

8 house was part of the row of houses where Milorad Krnojelac's house was as

9 well, right?

10 A. Yes, yes. All these seven houses that had burned down are perhaps

11 within 50 or 100 metres.

12 Q. So they were burned around the same time, I take it?

13 A. The same day. I wanted to say, when you say, Who torched them?

14 the Muslims torched them. If necessary, I can give you the name, but --

15 because I found out later, but if I don't have to, I don't have to.

16 Q. You're a fireman by training. Can you tell us how the houses

17 burned? Were they shelled or was there, were they set on fire?

18 A. When a house is shelled, then it has no walls, no chimneys, and

19 when fire is set to it, then there are only walls, walls remain. So each

20 and every one of these houses was torched, was set on fire. I can say

21 that, beforehand, these houses had not been looted either. After a while,

22 when I came, I know that my pistol, my personal weapon that I kept in my

23 cupboard on a shelf, when I came, when I dug up the rubble a bit with a

24 shovel, I saw my pistol. So had it been looted - the house, that is -

25 probably things like my pistol and technical equipment would have been

Page 6518

1 looted. So the house had been torched.

2 Q. You were not -- you were not able to return immediately when you

3 heard the news, right?

4 A. I did not understand this question. You mean when I heard the

5 news, when I listened to the news?

6 Q. When you learned that your house was burned, you were outside of

7 Foca. You were not able to return to Foca immediately, right? You didn't

8 come back to Foca until --

9 A. I could not return to Foca immediately. When I went for work

10 duty, I went to see my house. That's to say it was around the end of

11 April.

12 Q. When you returned to Foca, you returned because of the work duty,

13 not because your house had been burned, right? The primary reason, what

14 prompted you to come back was because you heard about the compulsory work

15 obligation.

16 A. Yes, that's right. I reported for work duty. But I also wished

17 to see the place where I had lived for so long, where I invested

18 everything I had, all the money I earned. My wife and I, for 20 years we

19 did that, so I wanted to see it.

20 Q. Sir, while you were still outside of Foca, after your house was

21 burned, where did your family live?

22 A. My family lived for a few days at my landlady's sister's place.

23 Then they walked through the hills and went to my parents' place on foot.

24 And when I went to report for work duty, they went with me and we were

25 given two rooms at the hotel and we spent about three months there.

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Page 6520

1 Q. You and your family were given the rooms at the hotel by the

2 military, right? They are the people who assigned you housing?

3 A. These rooms were assigned to me by the municipal authorities

4 because I went and reported that I had nowhere to stay and they gave me

5 these two rooms at the hotel.

6 Q. The Hotel Zelengora is quite a big hotel, right? With many

7 rooms?

8 A. The Hotel Zelengora is not that big a hotel. It's not small

9 either. I can't say exactly. But perhaps three or four storeys, perhaps

10 about 100 rooms. I'm not sure. It's not really a big hotel.

11 Q. And in addition to people like yourselves with their families,

12 there were also soldiers being housed there temporarily, right?

13 A. I am not aware of that, soldiers being housed in the hotel. In

14 the part where I was staying, it was mostly refugees that had been put up

15 and persons who had remained homeless.

16 Q. There was another part of the hotel where there were soldiers and

17 paramilitary units who were housed there, because there was no other

18 housing, right?

19 A. Paramilitary units were perhaps housed in a different part of the

20 hotel but in the part of the hotel where I was staying, there weren't any

21 and I really didn't see them.

22 Q. But there was another part of the hotel?

23 A. Yes. The old part and the new part of the hotel.

24 Q. And the part where you and your family were not staying was being

25 used by the military to house their people, right?

Page 6521

1 A. The military never stayed in that part of the hotel. Refugees

2 stayed there, primarily.

3 Q. Sir, I've already established that there are two different parts

4 of the hotel; the part where the refugees such as yourself stayed -- I'm

5 only talking about the other part. There were soldiers and paramilitary

6 people there, right? That's the only question.

7 A. This other part of the hotel where I was staying, that part of the

8 old hotel --

9 Q. Sir, I'm not talking about that part. I'm talking about the other

10 part.

11 A. May I please just explain what I've been trying to say? This part

12 of the hotel where I was staying, about ten rooms, that is the old part.

13 That's where Bozo Drakul was, I, Mr. Krnojelac, and perhaps only two or

14 three other families. That is the ground floor of the hotel. Whereas

15 this other part, which is within the hotel, that is where refugees were

16 staying, persons from villages whose houses were burned down, mainly

17 people from the country. I don't know whether there were soldiers there

18 as well. I really can't say. However, I could not imagine that the

19 military and the civilian population could be staying at the same hotel.

20 Q. You said you were staying in the old part of the hotel. Who was

21 staying in the new part?

22 A. I've already said that refugees were staying there, that is to

23 say, people who were expelled from villages, whose houses had burned down,

24 and everything else. People who had to flee from combat operations and

25 the Muslims, because these are territories that were burned down.

Page 6522

1 Josanica has over 30 villages so these people had to be put up somewhere.

2 And they were staying in this other part.

3 Q. After your three months at the Zelengora Hotel, you received more

4 permanent housing, right?

5 A. Three months later, I asked for an apartment and after three

6 months, they gave me an apartment and that's the apartment where I live

7 now as well.

8 Q. In other words, your house was never repaired so that you could

9 move back in.

10 A. I've already said that it wasn't my house, that it was Savo

11 Obrenovic's house. I only lived there for 12 years in the ground floor,

12 as a tenant of Savo Obrenovic's.

13 Q. Savo Obrenovic's house was never repaired, was it, during the

14 war?

15 A. Savo Obrenovic's house was repaired because the firm that he

16 worked for, Telekom Foca, or rather, Srbinje, they gave him a loan and his

17 house was repaired.

18 Q. But that was after 1995, right? After Dayton?

19 A. No, that was earlier. 1992, 1993.

20 Q. The apartment that you're living in now, who arranged it for you?

21 A. I went to the municipality and I asked them to pass a formal

22 decision, giving me accommodation somewhere. I couldn't take the hotel

23 any more. I had weighed 80 kilos and my weight went down to 70 kilos, so

24 they gave me this apartment, they sent me to this apartment, the municipal

25 authorities did.

Page 6523

1 Q. Do you know who lived in the apartment before you?

2 A. I know. A worker of ours worked there, Huso Mahmutovic was his

3 name. He worked on the dispatch of furniture. He's in contact with me

4 until the present day. He came to see his apartment, and he let me stay

5 at that apartment.

6 Q. Do you mean a Muslim man?

7 A. Yes, a Muslim.

8 Q. During the war, he left Foca, right?

9 A. He left Foca during the war, and after that, we talked on the

10 phone and he came to see his apartment.

11 Q. Wait. While he was out of his apartment, the municipal

12 authorities gave you and your family his apartment to stay in, right?

13 A. Yes.

14 Q. When you returned to work at the KP Dom, as a result of the

15 compulsory work obligation, you didn't have any more Muslim colleagues

16 working there, right? There were only Serbs working at the KP Dom.

17 A. When I returned to work duty, not a single Muslim was there out of

18 those who had worked on the police force or in the other services at the

19 KP Dom.

20 Q. And there were also colleagues who had worked with you at KP Dom

21 just before the war broke out who left Foca and didn't report to their

22 work obligation, right?

23 A. I am not aware of any colleagues who abandoned work duty and then

24 returned. At any rate, all the colleagues who had worked with me at the

25 KP Dom had left and they did not return. It was natural that Serbs would

Page 6524

1 go with Serbs and Muslims with Muslims because it would be hard for me to

2 remain and work among people as a single individual. For example, if I

3 were to remain among the Muslims. But I'm sure that if any such people

4 had stayed behind, that nothing would have happened to them.

5 Q. My question was whether you had Serb colleagues before the war who

6 did not come back to Foca, who did not come to work at KP Dom, as you

7 did.

8 A. No. All my colleagues who worked with me reported for work duty.

9 Q. Yesterday you talked about army reinforcements, that there were

10 military conscripts who were brought in to work at the KP Dom, as guards

11 or in other positions, who were not professionals before the war. These

12 people were brought in by the military to reinforce the fact that there

13 were fewer guards available to work at the KP Dom, right?

14 A. Yes. We've already said that part of the prison was given to the

15 military and the military was in charge of that part of the prison. It is

16 also true that I found people there who had never worked at the KP Dom who

17 were assigned by the military. Even we who worked there as the police

18 were assigned work duty by the military.

19 Q. So in addition to the military conscripts who were there obviously

20 because of the military, you and other civilian professionals, let's say,

21 were assigned by the military, and you all worked together, right?

22 A. The military assigned us and soldiers they had sent in. But we

23 did not have the same authority. As for Muslim detainees, it was

24 exclusively the military who had authority over them. We, the guards, the

25 police, had the duty, for the most part, to work in the compound, to

Page 6525

1 provide external security, that is to say to do day-to-day work, to take

2 care of breakfast, lunch, dinner, to tour the rooms, to maintain law and

3 order; when we would take people out to work, that we make sure that they

4 had permits, and it was the military only that was in charge of the Muslim

5 detainees.

6 Q. All the tasks that you just described were things that you were

7 professionally trained for, right? In your many years of experience?

8 A. Yes, yes. We policemen did that kind of work for years so we are

9 there to help these people to ensure law and order within the KP Dom, and

10 to provide security in the KP Dom from the outside and within it.

11 Q. Among the military conscripts were those people who did not want

12 to go to the front line, so instead of going to the front line full-time

13 they were assigned to work primarily at the KP Dom and sometimes perhaps

14 going to the front line, right?

15 A. I don't know about that. I know that most people went both to the

16 front line and had work duty. All of us who worked down there went to the

17 front line for four days, then continued our work duty and we sort of

18 changed shifts.

19 Q. Among the military conscripts were people from all walks of life,

20 including lawyers and judges and people who were not professionally

21 trained to be guards like you, right?

22 A. I don't know what they were by occupation. I can speak about the

23 professions of people who worked at the KP Dom but I could not know about

24 the military.

25 Q. You mentioned that everybody or almost everybody went to the front

Page 6526

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Page 6527

1 line, but Mr. Rasevic never went to the front line, right? Your

2 supervisor? He stayed at the KP Dom for the entire war.

3 A. That's true. Mr. Rasevic went to the front line, just as we did.

4 Q. Mr. Rasevic did or did not go to the front line?

5 A. Yes, he did, to the front -- go to the front line.

6 Q. Mr. Todovic did not go to the front line, did he?

7 A. Yes, Mr. Todovic too went to the front line.

8 Q. Mr. Krnojelac did not go to the front line, did he?

9 A. Mr. Krnojelac never went to the front line, and I never saw him.

10 JUDGE HUNT: Ms. Kuo, I don't know whether this is a matter that

11 you are going to investigate but there seems to be a different terminology

12 adopted by different witnesses. This witness has throughout described his

13 job there as a policeman. Most of the others talked about being prison

14 officers. I'm not sure whether there is any real distinction between them

15 and it's not clear, at least not clear to me, whether the conscripts came

16 in there to work as what this witness describes as policemen or as what

17 the other witnesses describe as prison officers. It may be important, it

18 may not, but it is a matter which I think you should inquire into.

19 MS. KUO: I'll do that right now, Your Honour.

20 Q. Sir, you've described yourself as being a policeman there and

21 you've described the duties that you had. Were there people who had other

22 duties who were called prison officers or something else? Or is a

23 policeman, a prison officer, guard, are they all the same thing, just

24 different words for the same job? You're all part of security, in other

25 words.

Page 6528

1 A. I'll try to explain that now. From 1977 when I got my first job,

2 first I had the title of guard, and already in 1992, 1993, this position

3 was changed to that of policeman. So the person filling the position

4 remained the same but the name of the position changed. It used to be

5 guard, nowadays it's policeman. And the same is true not only of myself

6 but of all my colleagues. They are now called policemen. Before, they

7 used to be called guards.

8 Q. And as policemen, you were all part of the security services which

9 was supervised by Mitar Rasevic, right?

10 A. Yes, that is true.

11 Q. The military conscripts that you described who were not policemen

12 before the war but who were present at the KP Dom during the war, did they

13 have similar functions to somebody such as yourself?

14 A. They couldn't have had the same duties or functions because people

15 from outside couldn't know our house rules and regulations. We -- those

16 of us who were there before the war were the only ones who could perform

17 those duties and we knew our, the rules of our service, whereas an

18 outsider couldn't know the rules, nor could they serve as policemen there.

19 Q. What did those military conscripts do, then? What were their

20 functions during the war?

21 A. The military conscripts, as I said, were in charge of ethnic

22 Muslims. They brought them, they took them away, they escorted them.

23 That was their job.

24 Q. Brought them from the outside to the KP Dom? Is that what you

25 mean?

Page 6529

1 A. Yes. The army brought them from outside.

2 Q. And took them away from the KP Dom, right?

3 A. Yes, certainly. It was the army, or rather, the military police

4 who brought in and took away Muslim detainees.

5 Q. But they were also -- I'd like to get this cleared up.

6 Because you talked about reinforcements and the word "reinforcement"

7 implies that they are there to fill in because there is a shortage. Isn't

8 it true that there were military conscripts who were brought in to fill in

9 the shortage of guards because the Muslim guards were no longer working

10 there, or rather, the Muslim policemen at the KP Dom were no longer there?

11 That's what they were, the military conscripts were doing, right? I mean,

12 they were permanently, during the war, assigned to work inside the KP Dom

13 because there was a shortage of policemen due to the fact that the Muslims

14 had left.

15 A. They came but they stood guard outside. Whenever we could

16 withdraw our professional policemen from the front line, we wouldn't need

17 them to secure the compound any more. We did it ourselves with our own

18 men.

19 Q. During the time from 1992 to 1993, there were people such as the

20 former lawyer, judge, Slavisa Prodanovic, who was assigned as a policeman

21 at the KP Dom, right, even though he had never worked there before?

22 A. Slavisa Prodanovic was there sometime at the beginning but for a

23 very short while and he was engaged by the army, but for a very short

24 while, as I say.

25 Q. While he was there, he was functioning as a security officer, a

Page 6530

1 police officer, a policeman, just like you, right?

2 A. He could not have been a policeman like I was because I had worked

3 there before and I had passed many exams and Slavisa Prodanovic, on the

4 other hand, as many other soldiers who were assigned there to fill in

5 those positions until my colleagues came back, they worked on the external

6 security.

7 Q. And external security means that they are standing outside the

8 perimeter of the KP Dom to make sure that no prisoners escape and also

9 that nobody from the outside gains access into the KP Dom, right?

10 A. Yes. External security has the objective to prevent anyone from

11 coming in without permission or to prevent escapes.

12 Q. Yesterday you told us about three gates at the KP Dom and I'd like

13 to ask the usher to show you Exhibit 6 -- P6 rather, and this is a diagram

14 of the KP Dom. I'd like for you to show us where those three gates are.

15 You told us gate 1 was the main entrance, gate 2 was the furniture factory

16 entrance, and gate 3 was the boiler room. So let's just start with

17 gate 1. Could you show us where that is?

18 A. This here is gate number 2. Just give me a second. There is a

19 very -- this is very small.

20 JUDGE HUNT: Can you record it on the transcript after each one.

21 MS. KUO: I'll do that, Your Honour.

22 A. Here is the metalwork shop.

23 JUDGE HUNT: Sir, just think to yourself. We don't want to hear

24 what you're thinking about it. When you've worked out where the three

25 gates are, you tell us you're ready and then we will ask you to point to

Page 6531

1 them one at a time and we will have it recorded on the transcript where

2 you point.

3 A. Number 1.

4 MS. KUO: Okay.

5 Q. The witness pointed to the main entrance to the KP Dom where other

6 witnesses have indicated pedestrian traffic goes in and out.

7 A. Here is gate number 3, in this area.

8 MS. KUO: The witness is pointing to the -- on the diagram, the

9 left side of the KP Dom perimeter, directly to the left of the furniture

10 factory, and there is an entrance that some witnesses have described as

11 where the trucks might come in and out to take things from the furniture

12 factory.

13 Q. Could you point again to gate number 2 so I can get that on the

14 record.

15 A. Here is gate number 2.

16 MS. KUO: Gate number 2 is at the front of the KP Dom on the

17 right, lower right-hand side of the diagram where witnesses have described

18 as being a vehicle entrance, and that is to the right side of the bridge.

19 I'm sorry, my colleague has just corrected me. I had mixed up

20 gates 2 and 3. Because gate 2 was described yesterday as being the

21 furniture factory and gate 3 is the boiler, and I described gate 2 as

22 being the furniture factory.

23 Q. Gate -- when you point to gate 3, could you show us where the

24 boiler room is? The witness is pointing to a -- the boiler room facility,

25 which is directly to the left of the gate that he described. Is the

Page 6532

1 boiler room inside or outside the perimeter of the KP Dom? Could you just

2 show us where the perimeter of the KP Dom runs?

3 A. The boiler room is located on the other side of the wall of the KP

4 Dom. This here is the wall. This is watchtower number 6, watchtower

5 number 3. This is the gate. This is the boiler room. This is the

6 silo.

7 MS. KUO: The witness pointed to guard post number 6, which is

8 directly on the top of the diagram, and there is a line that goes straight

9 down and then that's guard post number 3, and the gate number 3 is

10 directly in the middle of that.

11 Q. Could you tell us what that gate was used for primarily? On what

12 occasions would it be opened?

13 A. Gate number 3 was used only when the factory was in operation, and

14 when it was necessary to take out the waste. That's when we used gate

15 number 3. And sometimes there was no power in the gate and we had to open

16 the door manually. This area here has some sort of boiler or how shall I

17 call it, and a vehicle cannot pass through this area above the boiler

18 room.

19 Q. And you were assigned to which gate?

20 A. I worked at gate number 2.

21 Q. When would that gate be opened?

22 A. This gate was always opened to let in vehicles carrying food for

23 the quartermaster, to let out trucks with furniture, et cetera. It was

24 used daily.

25 Q. But for vehicles, right?

Page 6533

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Page 6534

1 A. Yes, for vehicles, because vans would come in and have furniture

2 loaded onto them. Here, this area here, is the channel where the vans

3 would park. This part of the building is where the furniture was taken

4 out from to be loaded onto vehicles, and here is the fireman's office.

5 This round area here is the water reservoir. In case we were cut off from

6 the water mains, we had backup for fire fighting purposes in this

7 reservoir.

8 MS. KUO: The witness is pointing to the right of gate number 2.

9 There is a circle indicated within what looks like a rectangular

10 structure. The circle is what he indicated as being the water reservoir

11 and the structure itself is where the fire inspector office was.

12 Q. Right?

13 A. Yes. And the fire fighting equipment. The water pump, hoses,

14 hydrants and all the other equipment was housed in this little cabin

15 here.

16 MS. KUO: And directly above that on the diagram is a rectangular

17 area and that's where the witness indicated that the vehicles would stop

18 to load and unload.

19 Q. Correct?

20 A. Here, right. There is a canal. This area here is the fence, an

21 iron fence. This part here is the road, about two metres wide, leading to

22 the loading zone in front of the furniture factory where timber was loaded

23 and unloaded. And this road was used exclusively to go to the furniture

24 factory. The entrance to the furniture factory, one staircase and another

25 entrance, also with a staircase. There is an entrance to the furniture

Page 6535

1 factory here as well.

2 MS. KUO: The witness indicated the road going to the furniture

3 factory as being directly as you go in through gate number 2 and you go

4 forward and then you make a left. There is a road that runs between the

5 courtyard where the prisoners quarters are located and the furniture

6 factory itself.

7 Q. Sir, was the furniture factory located within the perimeters of

8 the KP Dom? You said there was a wall between the courtyard and -- or,

9 rather, a fence between the courtyard and the furniture factory. Was the

10 furniture factory actually inside the KP Dom security perimeter?

11 A. The furniture factory was within the compound of the KP Dom. This

12 here is the wall. Watchtower 5. We cannot see watchtower 4 in this

13 corner. Watchtower 7; watchtower 3; watchtower 6. So the furniture

14 factory was in the compound. This zone here is between the furniture

15 factory and the wall. The distance between them is about two to three

16 metres.

17 This area here which I just pointed out, this iron fence, it

18 separates the furniture factory from economic installations and the

19 compound and the courtyard. This area here is the football field, and the

20 basketball field here in this area.

21 MS. KUO: The football and basketball fields, the witness

22 indicated as being an open space which is about the centre of the KP Dom,

23 to the left and below the area where the iron fence and the road to the

24 furniture factory runs. And the witness also indicated that the perimeter

25 wall of the KP Dom runs to the -- above and to the right of the furniture

Page 6536

1 factory, thus enclosing the furniture factory within the KP Dom compound.

2 Q. And sir before we leave this diagram, can you show us where your

3 area of patrol was when you were assigned to patrol gate 2 and the

4 furniture factory? Where would you -- where was your physical area of

5 control?

6 A. At the furniture factory, well, I controlled the area from the

7 packing zone; then, on the lower floor, the engraving section; and then

8 upstairs, upholstery, tailor's shop, locksmiths, then assembly line,

9 tailoring fittings one and two. So my area covered this entire area of

10 the factory within the compound when it was in operation. And both

11 Muslims and Serbs worked there. As required, I would also patrol and tour

12 this area as well, from the economic installations up to the loading zone.

13 MS. KUO: The witness indicated his area of patrol inside the

14 factory as being the entire factory which ranges from -- it's an L-shaped

15 structure -- going from the loading zone up, in the diagram, to the left

16 past the words that say "furniture factory" and to the end of that

17 structure on the left-hand side. And then when he said he also patrolled

18 a certain area, that was, he indicated, the road that led into the

19 furniture factory.

20 Q. Could you explain to us what you meant by the areas of economic

21 structure? I didn't understand. Economic installations. What is that?

22 A. I meant the prisoners' quarters, those two buildings, from those

23 buildings up to gate number 3. I meant those buildings. Building 1 and

24 building 2. That's what I meant. So this area from the gate, because

25 here there is also an iron fence, one smaller fence and one larger fence.

Page 6537

1 Here in this area of the compound which separates the inner compound from

2 the compound which includes the factory.

3 Q. So if you were patrolling external security, where -- what is

4 considered external security?

5 A. External security, where I worked, my job was to patrol from gate

6 number 2 up to watchtower 5, because what is not drawn here is a

7 furniture shop and showroom and there is also a guard's booth, two by two,

8 where a guard stood here at the gate. His patrolling area was from

9 watchtower 5 up until here, until the cinema hall. This area was covered

10 by the policemen, from the cinema hall to watchtower 5.

11 MS. KUO: The witness indicated as watchtower 5, the corner

12 watchtower in the bottom right-hand corner of the diagram.

13 Q. And you said -- do you mean that there was somebody whose post was

14 from watchtower 5 to the cinema, just that area, back and forth? Is that

15 what you meant?

16 A. Yes, although I have to say that this gate here is slightly more

17 inside relative to the building so you don't really have a view from this

18 part here.

19 Q. The gate that you indicated was gate number 2. Sir, since we have

20 the diagram here, could you show us precisely which part was military and

21 which part was civilian?

22 A. At the outset, the military secured this area from the metalwork

23 shop and outside the administration buildings, this area here was secured

24 by the army. The army also --

25 Q. Let me just put that on the record. You indicated the area from

Page 6538

1 the metalwork shop, and you indicated the courtyard of the metalwork shop

2 and then you pointed to the front of the administrative building, the side

3 that faces the Drina River, all the way to both wings of the

4 administrative building. You said at the outset. When was that? That

5 was April and May, the first part of May, 1992, right?

6 A. That was in April up until the middle of May when paramilitary

7 units left.

8 Q. And after that, the military didn't patrol that part? It was

9 turned over to people like yourself, right, to patrol?

10 A. Yes. I said they left, but a certain number of soldiers who were

11 assigned by the army remained, and they continued to patrol, although the

12 greatest part of the work was turned over to us policemen and we also

13 controlled the external security.

14 MS. KUO: Your Honours, it's 11.00.

15 JUDGE HUNT: Thank you. We will adjourn and resume at 11.30.

16 --- Recess taken at 11.00 a.m.

17 --- On resuming at 11.31 a.m.

18 JUDGE HUNT: Ms. Kuo.

19 MS. KUO: Thank you, Your Honour.

20 Q. Mr. Matovic, before the break you told us that when the army left

21 in mid-May, they -- a number of soldiers assigned by the army remained and

22 that they continued to patrol. They continued to patrol the external

23 security, right?

24 A. I said that the paramilitaries had left in mid-May. However, we

25 who remained were -- there were members of the army and I was actually

Page 6539

1 referring to our people who worked at the KP Dom. I meant that they had

2 remained, providing external and internal security.

3 Q. But in mid-May, when the paramilitaries left, there were no

4 regular military people sent in to serve the function that the

5 paramilitaries had done before, right?

6 A. The military police came. They brought people and took them

7 away. We provided security, we who were employed there. So we were

8 there attached to the army.

9 Q. The military conscripts, such as Slavisa Prodanovic, provided

10 external security in that wall area that you described and pointed out for

11 us on the ELMO, or the diagram, right? The different watchtowers, et

12 cetera; they provided security on that outside wall, right?

13 A. Slavisa Prodanovic stood guard in front of the building by the

14 metal plant. Slavisa Prodanovic -- well, this is where the gate is, and

15 then the metalwork shop, so Slavisa was providing security for this area

16 here, in front of the entrance to the guard building.

17 Q. The area that you pointed out is between the main entrance to the

18 KP Dom, what you described as gate 1 earlier, and then directly to the

19 left of it, the gate which is the entrance into the metalwork shop?

20 A. Yes.

21 Q. Thank you. Did you -- you didn't work only during the daytime,

22 right? You worked in the evenings as well?

23 A. I worked very, very briefly, perhaps only a few shifts, precisely

24 in this area that I pointed out in front of gate number 2, so in front of

25 gate number 2, to the cinema and to number 5, and this part in front of

Page 6540

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Page 6541

1 the restaurant.

2 Q. During the evenings when you worked the evening shifts, did you --

3 did people come and go through that gate 2?

4 A. Through this door, no one ever came in through that door except

5 for vehicles that were loading and unloading furniture, and the vehicle

6 that brought food for the kitchen.

7 Q. My question was whether in the evenings, at night-time, that gate

8 was used.

9 A. Never. It was never used in the evening, this gate.

10 Q. We are done with this diagram. Let me ask you this: When -- you

11 said you only worked very briefly on those night shifts. When was that?

12 What month?

13 A. I think from mid-May until the end of May, around those dates,

14 when I was transferred to the factory, that is.

15 Q. After you were transferred to the factory, you worked only day

16 shifts, correct?

17 A. After I was transferred to the furniture factory, I worked only

18 day shifts.

19 Q. The population at the KP Dom changed quite a bit during 1992 and

20 1993, right? At the very beginning of the war, when most of the prisoners

21 were taken away or fled, the population from before the war was reduced to

22 maybe 25 or so prisoners, right?

23 A. I'm not aware of that.

24 Q. You told us yesterday that most of the prisoners who were there

25 before the war either fled because the gates were opened and they were

Page 6542

1 free to leave or the ones who weren't -- who didn't leave were taken away

2 to safety somewhere else, like Tuzla, right?

3 A. Yes, yes. I said that the number of people who remained was about

4 ten, about ten convicts at the KP Dom. As for this number that you're

5 mentioning, perhaps they may have been transferred to the farm.

6 Q. Very well. If ten is what you're aware of, that's the number that

7 I'll refer to. After you started your compulsory work at the KP Dom,

8 let's say in the month of May and the beginning of June, the population at

9 the KP Dom gradually increased as a result of Muslim detainees being

10 brought in, right?

11 A. People who dodged work duty were also brought to the KP Dom, and

12 also detained Serbs. As for these detainees, I don't know about them

13 because I had very little contact with gates and the building. I worked

14 elsewhere.

15 Q. The people, the number of people dodging work duty who were

16 brought into the KP Dom was only a handful, right? I mean, not even

17 enough to fill a room. Because they shared a room with those who violated

18 military rules, right?

19 A. The convicts who remained from before the war were in Room number

20 19 whereas these persons who were brought into custody by the military

21 stayed in Room 21. Believe me, I don't know the number but there could be

22 quite a few of them brought in during the day and when the military police

23 would come, they would take them to the front and that's the way it

24 happened almost every day.

25 Q. But -- and that population, those who were brought in by the

Page 6543

1 military, the Serbs brought in by the military as a result of dodging

2 their work duty or as a result of military violation, those people stayed

3 for only a short period of time, so short that they couldn't even be

4 assigned to work, right? You told us that yesterday.

5 A. They would stay there briefly, a day or two or three, depending on

6 the punishment that had been meted out to them.

7 Q. The vast majority of the people who were brought in during the

8 months of May and the first part of June, who filled those other four

9 rooms that you mentioned, and perhaps more, were Muslim detainees, right?

10 The people that you told us the military police brought in.

11 A. The military police brought them in, but I'm not aware of this. I

12 told you that I did not have any contact with the buildings. The guards,

13 or rather, the policemen who worked in the compound in buildings 1 and 2,

14 had insight into this. I took care of the people I took out to work.

15 That is to say, six to eight Muslims and perhaps the same number of Serbs.

16 And my main task was to provide security for these premises.

17 Q. You gave us a number yesterday of between 500 and 550 people. In

18 about mid-June, that number began to decrease as Muslims were taken out,

19 right?

20 A. I said that the number ranged between 500 and 550 persons. I did

21 not say that they were taken out. I had heard from the Muslims who had

22 worked with me that if somebody would come in or if they would be taken

23 for an exchange, they would inform me of this at the working place.

24 Q. Sir, what I'm asking you is about the numbers of people brought

25 there who were in the KP Dom. It's a fact, isn't it, that the numbers of

Page 6544

1 people increased from May until mid-June? That's just a fact, right? The

2 number went up.

3 A. From May until mid-June, the number went up and that is a fact,

4 and it is a fact that the military police brought them in.

5 Q. Yes. And then after, from mid-June through to the end of

6 September or October, the numbers started to go down, right?

7 A. The numbers started going down. People were taken for exchanges.

8 Q. Yes. And yesterday you told us that there were roll calls taken

9 every day, right?

10 A. Roll calls? I never said that. I took the roll call in the

11 furniture factory. The people I was providing security for. I could not

12 take the roll call. I said that the guards who worked in the building

13 took the roll calls there.

14 Q. Sir, I'm not saying that you took the roll call. Please listen

15 very carefully to the question before you jump to conclusions about what I

16 asked you. I asked you about roll calls being taken. I didn't ask about

17 you taking roll calls. Roll calls were taken of the detainees in the KP

18 Dom every single day, right? By somebody.

19 A. Roll calls were not taken individually. People were counted.

20 Guards came, lined up every room. That is to say when there would be

21 these evening lineups, a guard would walk into the room, they would line

22 up, he'd count them, and then that number would be recorded.

23 Q. Let's call them lineups, then. The number was recorded every

24 evening in these notebooks that you described yesterday, right?

25 A. Every evening after the lineup, the number of the room would be

Page 6545

1 recorded and the number of people in that room.

2 Q. Where were these notebooks kept?

3 A. These were regular writing pads, regular notebooks, and then, at

4 subsequent stages, they were destroyed.

5 Q. During the time that they were being used, where were they kept?

6 I'm not talking about archiving. We mean at the time when somebody, every

7 evening, is making a notation in them, where were they kept?

8 A. The guard of the building kept this notebook in his own drawer.

9 Q. And where was the drawer located? In what building or room?

10 A. Building number 1 and building number 2 had their own guards. On

11 the ground floor, as soon as you enter the building, on the right-hand

12 side there is an office. There was a desk there too. So it was in that

13 desk. After the guard would complete all the lineups of all the rooms,

14 then he would register the number and then he would tell the officer on

15 duty in the KP Dom what the number was, and the notebook would remain in

16 his drawer in the desk.

17 Q. When you said building number 1 and building number 2, you meant

18 the prisoner quarters building 1 and prisoner quarters building 2, right?

19 A. Yes, where both Serbs and Muslims were detained.

20 Q. There was one notebook for building 1 and one notebook for

21 building 2, right?

22 A. Yes. That is to say that guards would keep these notebooks in

23 both buildings.

24 Q. But the -- the notebook was not personal to a particular guard; it

25 was kept in the desk of the particular prisoner quarter building, and

Page 6546

1 whoever was on duty that night and taking this -- and making this list

2 would take that same notebook, write down the number, write down the room,

3 and then put it back into that same desk drawer, right? That was the

4 procedure?

5 A. Yes. Every guard who was on duty would write this down and the

6 notebook would remain in the desk.

7 Q. You talked about an officer on duty. What do you mean? Was there

8 one officer who was in charge of all the guards on that particular shift?

9 Is that who you mean?

10 A. The duty officer of the KP Dom is the one who gathered all this

11 other information. He was in charge. He would tour the premises, inside

12 and outside, and see the other people who were on duty. We, the

13 policemen, had our own boss who we addressed for whatever we needed.

14 Q. Was the officer on duty always the same person or did that

15 rotate?

16 A. The duty officer was never the same. They took turns. At first,

17 they worked from 6.00 until 1800 hours and then from 1800 hours until 6.00

18 a.m., and then they would take a break, so it depended, because people had

19 to go to front line too. So it was not possible for there to be one, two

20 three, four persons on duty, so people changed practically every day.

21 Q. The duty officer was one from among people like yourselves, right,

22 who were assigned there during the war to work as policemen?

23 A. The duty officer of the KP Dom, I was not duty officer of the KP

24 Dom but I was duty officer of the furniture factory.

25 Q. Listen carefully to my question. I'm not asking about you

Page 6547

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Page 6548

1 personally any more, okay? The question was just: The duty officer was

2 always somebody -- he wasn't somebody who was brought in from the outside,

3 it was always someone from among the group of people, like yourselves, who

4 were assigned as a work obligation to the KP Dom, right?

5 A. Yes. All policemen who were assigned there could be the duty

6 officer of the KP Dom too. However, I wanted to explain this word to you,

7 duty officer. Practically all posts have this duty officer word

8 involved. At the gate, then the duty fireman, the duty patrolman, the

9 duty officer in the compound. Everybody is called the such and such

10 person on duty.

11 Q. You described yesterday how the staff met every day, and that was,

12 I believe, in the morning?

13 A. If you mean work meetings of the staff, there would be meetings in

14 the morning, in the afternoon, in the evening and -- but people would meet

15 up and socialise as well.

16 Q. The work meetings that you described, who participated in those?

17 Were they only security officers, or rather, policemen like yourselves, or

18 was it a larger group of people?

19 A. These were not work meetings in terms of sitting down and

20 discussing work. It was only socialising really. I mean, after shifts,

21 we would meet up for coffee, socialise, nothing more than that.

22 Q. During these informal meetings, if you will, you discussed what

23 was happening at the KP Dom, right?

24 A. At least when I was there, we never talked about that. Whether

25 other colleagues did, I don't know.

Page 6549

1 Q. You met sometimes three times a day and you never discussed what

2 was happening at the KP Dom? Ever?

3 A. There was no need for me to meet with someone three times. If we

4 would end our shift, we'd go for a little walk, take a coffee and that's

5 it. There was no need for us to talk about the KP Dom. We were all

6 professionals. We know how to do our work. We did our work. At the KP

7 Dom, most of us were really fed up so we wanted to discuss nicer things.

8 Q. What were you fed up with?

9 A. You mean the work at the KP Dom?

10 Q. You said that most of you were fed up. You said, "most of us were

11 really fed up so we wanted to discuss nicer things." What were you fed up

12 with?

13 A. Well, I think that if a person spends 12 hours at his working

14 place and then when he gets out, why would he discuss the KP Dom? I don't

15 think anybody will want to do that. We'd go and play soccer football.

16 We'd take a walk to our families.

17 Q. Sir, please don't answer something that I didn't ask. The

18 question was about these work meetings. I'm using your word. You said,

19 "If you mean work meetings of the staff, there would be meetings in the

20 morning, in the afternoon, in the evening, but people would meet up and

21 socialise as well."

22 So I'm not talking about after you're done with work and you go

23 home to your family and I'm not talking about when you meet friends on the

24 weekend and play football. I'm talking about when you meet your

25 colleagues at the KP Dom during breaks or during meetings. Are you saying

Page 6550

1 that you never, ever discussed anything that happened at the KP Dom? Is

2 that what you're testifying?

3 A. I don't know about my colleagues. I've already said. At the

4 working place where I worked, I was on my own, providing security for the

5 factory. I had no one to talk to except for the Serbs and the Muslims

6 who were up there.

7 Q. Sir, again--

8 JUDGE HUNT: Just one moment. Sir, you're being asked about a

9 statement you made and I'll read to you the statement you made. "At the

10 KP Dom, most of us were really fed up so we wanted to discuss nicer

11 things." Now it's in relation to that statement you're being asked to

12 explain. What was it that you were fed up with at the KP Dom?

13 A. I think that I've been clear. It was exhausting work at the KP

14 Dom for 12 hours, and people who worked before the war worked for eight

15 hours. It's not easy to take a night shift from 6.00 p.m. until 6.00

16 a.m., and you can't get any sleep either. And I don't see how a person

17 wouldn't get fed up with that. And I don't see how someone wouldn't find

18 that hard.

19 MS. KUO:

20 Q. Sir, you've just told us that, after about a month, you were

21 switched to day shift. You were no longer working night shift. You were

22 no longer fed up with the night shift because you were no longer working

23 night shifts. What were you fed up with?

24 A. I'm not saying that I was fed up. I was saying that colleagues

25 who worked, who worked on night shifts really, because every second or

Page 6551

1 third shift meant 12 hours, and that was really unbearable.

2 Q. Let's move on. Sir, you told us that you never saw anybody being

3 beaten at the KP Dom, and you stand by that statement, correct?

4 A. I never saw anyone beating anyone.

5 Q. And in fact, in a statement that you gave to the Defence

6 investigator, Mr. Dundjer, in February of this year, you said, "Had I seen

7 -- I'll read the whole quote. It's from paragraph 14 of your statement:

8 "I did not see a single Muslim either beaten up or having some injuries,

9 because, had I seen it or learned about it, I and most of my other

10 colleagues would have opposed such behaviour." Do you stand by that

11 statement?

12 A. I stand by that statement until the present day. When I do my

13 job, if I were to see someone beating someone else, I would certainly

14 intervene, and I would report that to my superior.

15 Q. And your superior was Mitar Rasevic, right?

16 A. My superior was Mitar Rasevic in the security service.

17 Q. Did Mitar Rasevic have the ability to discipline a guard?

18 A. Yes. In the event of any abuse of authority, he could call a

19 person to task. If a person overstepped his authority or was guilty of

20 violation or used a rubber baton against regulations, he could have been

21 subjected to disciplinary proceedings.

22 Q. The disciplinary proceedings would include the possibility of

23 losing his job, being fined, or some other -- or being demoted, let's say,

24 right?

25 A. Depending on the seriousness of the violation, a punishment would

Page 6552

1 be meted out. It could be a suspension from work, it could be a fine, and

2 it could be even dismissal.

3 Q. Mitar Rasevic was not the only person who had the ability to

4 impose these disciplinary measures, right? The warden, for example, was

5 also in a position to do that?

6 A. All disciplinary proceedings that were instituted after the proper

7 procedure were forwarded to Mitar Rasevic, my superior, and he would

8 forward it on to the protocol service, and I don't know what happened with

9 it after that stage.

10 Q. You said "protocol service." Was that a service within the KP Dom

11 that dealt with discipline?

12 A. Yes. The legal service processed all such reports and statements,

13 and if there was reason to suspect a violation, all those reports would be

14 forwarded on, and in such a case at the KP Dom, since we now have a deputy

15 warden, he is the one responsible for the security service.

16 Q. And you mentioned that at the present day - since you're still

17 working at the KP Dom, you know this - there is a deputy warden, and there

18 is a warden as well, right?

19 A. Yes. There is a warden and his deputy.

20 Q. The reports you said would be forwarded to the deputy warden but

21 the deputy warden also then reports to the warden, right, in the present

22 day?

23 A. I don't know whether he decides alone or reports to the warden,

24 but in any case, that's the procedure. That's how it would go.

25 Q. Yesterday, you were asked by Defence counsel whether there were

Page 6553

1 any orders given to mistreat the Muslim detainees. You said there were

2 none. And you also said, and I'll quote, "If ordered, I would never do

3 any such thing." I understand that you've said there were no such orders,

4 but had you disobeyed an order like that -- if you had received an order

5 to beat a detainee, and you in your -- using your conscience, decided, "I

6 can't do that, I will not do that," as you said, what would have been

7 the consequences?

8 A. First of all, I've never been in a situation like that, where I

9 would be ordered to do such a thing. And if I were to be, I would not

10 comply, regardless of the consequences. But I never even heard of anyone

11 losing their job or -- because he slapped or hit a prisoner who offered

12 active resistance or broke house rules, et cetera.

13 Q. Again, please answer -- listen to the question and answer the

14 question that I asked, not the question you think I asked, okay? My

15 question was: What would have been the consequences if you had disobeyed

16 the order? You told us yesterday, "If I had received such an order, I

17 would never do any such thing." That's an understandable position for

18 somebody with a conscience. But my question is: What would have happened

19 to you? What would the consequences have been? Please tell us that.

20 A. I cannot assume even what would have happened because I can't

21 believe that anyone would issue such an order.

22 Q. You, yesterday, gave us this hypothetical situation yourself, sir,

23 that if you had been ordered it - and we know you were not - but if you

24 were, that you would have disobeyed the order. And my question is what

25 were the consequences of disobeying an order?

Page 6554

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Page 6555

1 A. Well, it depends. Let's assume that an order was issued, like in

2 this case, an order was issued to do something and that something was not

3 done, then a disciplinary measure would have been taken, and as I said

4 earlier, there are several of those disciplinary measures. Because

5 failure to perform one's work duties, being late for work, leaving

6 work early, et cetera, all such violations are punished by fines usually.

7 In the event of an escape of a prisoner from a compound across the wall, I

8 suppose I would lose my job.

9 Q. So basically what you've told us in your statement from yesterday

10 was that because you have a conscience, you're a human being with a

11 conscience and you know right from wrong, that you would exercise your

12 conscience and not do anything that you knew was wrong, even if someone

13 ordered you to do it, and even if you would have to face disciplinary

14 measures, right? Because that's the kind of person you are.

15 A. If something like that was ordered, I would take my own employment

16 record and go away. I wouldn't even wait to be discharged. But I would

17 never do it of my own free will and I would never obey a thing like that.

18 Q. Sir, at some point when you were working as part of your work

19 obligation, you were in a position to escort detainees whenever they

20 received visitors, correct?

21 A. I never escorted a convict who had a visitor.

22 Q. Do you know Dzevad Lojo, the director of research and development

23 at Maglic?

24 A. I know of such a person and I seem to remember that he was at one

25 point director of the mine in Miljevina.

Page 6556

1 Q. Well, there are two -- there are two different people with the

2 same name. The Dzevad Lojo that I'm referring to was the director of

3 research and development at Maglic. The person who was the director of

4 mines had the same name but was a different person. The Dzevad -- my

5 question is about Dzevad Lojo, the director of research and development at

6 Maglic. He was detained at some point at the KP Dom, right?

7 A. I saw him, I know he was down there. But I saw him, at most, once

8 or twice.

9 Q. And at one point, early on, Milorad Krnojelac was using one of the

10 visitor rooms on the ground floor of the administrative building as an

11 office, right? Before the warden's office upstairs was fixed up.

12 A. I'm not aware that there were any visits in that particular

13 period.

14 Q. Isn't it true that at some point you escorted Dzevad Lojo to see

15 Milorad Krnojelac in one of those visitor rooms downstairs? There

16 was a request for a meeting and you were the person on duty who brought

17 Mr. Lojo to see Mr. Krnojelac, right?

18 A. I said that I knew Dzevad Lojo as director of the dark coal mine

19 and I saw him just once or twice in passing on my way to the furniture

20 factory, but I never escorted Dzevad Lojo or anyone else to receive a

21 visitor, nor am I aware that there were any visits in that period.

22 Q. I'm not asking you about a visitor. I asked you about Mr.

23 Krnojelac. Mr. Krnojelac was working at the KP Dom. At some point he

24 used one of the visitor rooms as an office and he met some of the Muslim

25 detainees there. And at some point you personally escorted Dzevad Lojo

Page 6557

1 from Maglic, not from the mine, but you escorted this particular detainee

2 to see Mr. Krnojelac, right? Just for a meeting.

3 A. That's not true. I can say that with certainty.

4 Q. You say that you never escorted any Muslim detainee to a meeting

5 with Mr. Krnojelac?

6 A. No. Why would I? Because Mr. Krnojelac was in charge of Serb

7 prisoners and of the Drina Economic Unit. It must be a mistake. It has

8 to be a mistake of some kind.

9 Q. It has to be a mistake that any Muslim detainee ever met with

10 Mr. Krnojelac, right?

11 A. I'm not saying it's a mistake, but at least as far as I remember,

12 none of them ever came to see Milorad Krnojelac.

13 Q. What I'm trying to pin down is, based on what you've told us, and

14 you've repeated throughout your testimony, that Mr. Krnojelac had nothing

15 to do with Muslim detainees, it would be inconceivable for you that he

16 would ever meet with Muslim detainees, right? And if anyone said that

17 that happened, you'd say how can that be? Right?

18 A. The army was in charge of detainees of Muslim ethnicity, and I

19 already told you who Mr. Krnojelac was, so I really don't know about

20 this. Although I personally would not consider that wrong even if anyone

21 had met with...

22 Q. Met with whom? We didn't get the last part of the translation?

23 Maybe you could repeat.

24 THE INTERPRETER: The witness did not say anything after "with."

25 MS. KUO:

Page 6558

1 Q. Your last sentence trailed off and you said, "Although I

2 personally would not consider that wrong even if anyone had met with..."

3 A. Even if anyone had met with any one of them, be they Croat, Serb

4 or Muslim, because I think it is human and humane to talk to them.

5 Whoever wanted such an interview, it should have been possible.

6 Q. Yesterday you told us about the food situation, and it's clear

7 that not the -- the eating area was not big enough for everybody to eat at

8 the same time, and so the usual practice was for the Muslim detainees to

9 eat first, right? And followed by the Serbs.

10 A. Within our compound, there is a canteen, that is the kitchen, and

11 two dining halls, and it is true that it was the Muslims who had their

12 meals first, and the Serbs came after, because there were -- there was not

13 enough cutlery and plates and other stuff, so they couldn't take their

14 meals at the same time. And it needed more time to prepare the tables

15 again.

16 Q. You also described yesterday that whenever a doctor visited, you

17 would go around to the furniture factory and ask if anybody wanted to see

18 the doctor. You only asked in the furniture factory and never went into

19 the prisoner quarters, buildings 1 and 2, to ask people in the rooms if

20 they needed to see the doctor, right?

21 A. I worked at the furniture factory and I would be informed by the

22 duty officer from the building that the doctor had come, and it was not my

23 job to go to the building, because I was advised by them, because every

24 building had their -- had its duty officer, the policeman on duty, who

25 would pass this information on.

Page 6559

1 Q. You also told us yesterday that sometimes the detainees had two

2 blankets but you never actually went into the prisoner quarters and saw

3 that for yourself, right? Because that wasn't part of your work duty.

4 A. I didn't go but the Muslims who worked with me would talk to me

5 every morning, and they would tell me how many blankets they had. This

6 work detail who worked up there consisted of people who were really close

7 to me and we were real friends. They could tell me everything and so they

8 told me about those blankets. They told me they had two each, and some

9 people had more than two.

10 Q. Could you give me the names of some of the people? I don't

11 remember if you did this yesterday, the people who worked at the furniture

12 factory, the Muslims. The ones who you said told you this.

13 A. Of course. For instance, there was Saban Muratovic, who worked at

14 the tailor's shop, [redacted], Ivan Soldan,

15 [redacted]. So that's basically that group of people who worked

16 with me. And several Serbs as well.

17 Q. Okay. Thank you. I'd like to show you some photographs that you

18 were shown yesterday, and ask you a few questions. This is from Exhibit

19 D4/3 and it's photographs A39 and A40.

20 The -- you identified this yesterday as being the coffee room as

21 it exists now. During the war, it didn't look quite like that, did it? I

22 mean, in the intervening eight or so years, it's been cleaned up quite

23 a bit and repainted and restocked, right?

24 A. Can we start with photo A39? This is the -- this is the bar which

25 existed even before. The wash basin and electrical stove. And there were

Page 6560

1 three tables near the entrance, each had four chairs.

2 Q. Sir --

3 A. And we see that on the picture below as well.

4 Q. My question is focused on the condition. Everything in this

5 picture in A39 looks very tidy and clean and repainted. You've told us

6 that when you first got to the KP Dom after the war broke out, that

7 everything was a mess. So my question is, from that time until this

8 picture was taken, things were cleaned up quite a bit, right?

9 A. It was redone and cleaned up. It used to be all upside down and

10 shattered and broken but it was all put back into order and tidied up.

11 Q. And this -- let's go to the photograph under it, A40. It's the

12 same room from a different viewpoint isn't it? Or is that a different

13 room?

14 A. That's the same room, photographed from a different angle. The

15 photographer was standing in front of the bar as opposed to behind the bar

16 on the previous picture. Here you can see how it was all redone and

17 renovated.

18 Q. Thank you. This was not the only room in the KP Dom that was

19 redone, repainted, fixed up, right?

20 A. And speaking of that, we are now renovating all the rooms,

21 repainting them --

22 Q. Sir, again, please answer my question. Don't answer something I

23 didn't ask. The question was, during the intervening years since the

24 outbreak of the war, not only this room was renovated and cleaned up, but

25 other rooms as well, right? Maybe not completely but, generally, there

Page 6561

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Page 6562

1 was a big effort when people came to the KP Dom for you all to clean

2 things up so it was manageable and pleasant to be in, right?

3 A. I don't have the transcript on the monitor.

4 Q. It's not necessary, sir.

5 A. I said earlier that with the arrival of Milorad Krnojelac, we

6 started renovating and cleaning up and fixing all rooms and areas,

7 depending on the resources available, and it's true that it was not the

8 only room that was redone. We cleaned up other rooms as well, because the

9 way we found it, it was destroyed, broken. It was a mess.

10 Q. During the year and a half that Milorad Krnojelac was at the KP

11 Dom, would you say he did a pretty good job fixing and cleaning things up,

12 from the physical premises point of view?

13 A. I think that Mr. Milorad Krnojelac did a pretty good job, as far

14 as he could, and his greatest contribution is that he fixed the windows on

15 prisoners' quarters where most window panes had been shattered. He

16 started repairing all rooms with water installations such as kitchens,

17 bathrooms, toilets. He started supplying the KP Dom with firewood and

18 food. Whatever was produced at the KP Dom, Milorad Krnojelac transported

19 outside in order to exchange it for detergents, toiletries, food, et

20 cetera.

21 Q. Among the physical improvements was the repainting of certain

22 areas, right? Even while Mr. Krnojelac was there.

23 A. Not only the rooms. What he insisted on most of all was

24 improvement of conditions for detainees and prisoners and all those people

25 who were in the prisoners' quarters, because painting, repainting rooms,

Page 6563

1 was secondary to what Milorad Krnojelac did in this respect.

2 Q. But he repainted not only the prisoners' quarters but also the

3 areas that the staff would have -- be exposed to, right? In the

4 administrative building?

5 A. First and foremost, work was done on the prisoners' quarters and

6 the compound, and our quarters came second. In the first place,

7 prisoners' quarters were repaired and fixed. They were given priority.

8 Q. But once they were fixed, Milorad Krnojelac also made sure that

9 the guards' quarters were cleaned up, too, right? Including being

10 painted?

11 A. The guards repainted their rooms within the compound as well.

12 When all the other repainting was done. That was done not by a courtesy

13 of Milorad Krnojelac, it was something that my superior, the superior of

14 all guards, took care that our rooms be cleaned up and fixed just as all

15 the others, because we belonged to the security service.

16 Q. Your rooms would also include common, shared areas like where the

17 lockers were, offices; that kind of thing, right?

18 A. Our premises?

19 Q. You said your rooms, and I wanted to clarify what your rooms

20 referred to. You don't mean the rooms where you were -- what rooms did

21 you mean?

22 A. I meant offices within the KP Dom where policemen were on guard

23 duty; building 1, building 2, the fire fighting department. I meant

24 places like that, where people are on duty in four shifts, right now.

25 Q. So in other words, there was paint available even during wartime,

Page 6564

1 right?

2 A. Well, this existed during the war. We just whitewashed the

3 buildings. We just had to make do. What else can be done?

4 Q. With the assistance of the usher, I'd like to have you shown

5 Exhibit P18, photograph 7461 and then 7464.

6 This particular door on photograph 7461 is located in one of the

7 administrative offices, right? On the first floor. You identified it for

8 us yesterday.

9 A. I think that this door, I think that this door is upstairs,

10 because I saw this picture, this photograph, this door, on the first

11 floor, where our service was, and where people would take a rest after

12 their shifts would end. This is the situation that we found when we came

13 on the 24th, 26th of May. This is the situation that we found.

14 Q. You're saying that this graffiti with BiH on it remained on

15 this door throughout the war, from the time you say the Muslims were

16 there until 1996, when this picture was taken? Nobody whitewashed that

17 door or painted over it?

18 A. Everything was painted after -- after people came to the KP Dom,

19 renovations started and practically all the doors were replaced and the

20 rooms were painted.

21 Q. So after people came in 1992, after the war broke out, this

22 particular door with this particular graffiti was not there any more? It

23 was replaced by a clean door?

24 A. Yes, I didn't see it any longer.

25 Q. Let's see the next photograph, then, 7464. You identified this

Page 6565

1 for us yesterday. Was this graffiti also cleaned up during the 1992, 1993

2 renovation?

3 A. This is also on the first floor. These are lockers where the

4 policemen kept their equipment. This cupboard here belongs to this

5 office, and this is where the archives are. Then also this big cupboard

6 was used for changing clothes. This is the hall of the administration

7 building where the police force was. These premises have been renovated

8 now, but in this room, until the present day, things haven't been fixed,

9 because there is no employee working there, so things have been put back

10 into their respective places, but --

11 Q. Again I'm only asking you to look at the top photograph because

12 I'm focusing on the graffiti. You testified yesterday that this graffiti

13 was there when you came to the KP Dom in 1992. Was it part of

14 what you described as being cleaned up during 1992 and 1993?

15 A. Yes, cleaned up and repainted. All the lockers were repainted.

16 Q. In 1992 and 1993, right?

17 A. Yes, yes. They were painted then.

18 Q. Thank you. Mr. Matovic, Mr. Krnojelac -- you knew Mr. Krnojelac

19 as a neighbour, right? Your houses were destroyed around the same time,

20 close to each other. And you actually -- you said you were at the Hotel

21 Zelengora, in a small part of it, together with his family, for a few

22 months, right?

23 A. Yes, I knew Mr. Krnojelac. I have known him since 1981, 1982, as

24 I said, however, this was just an acquaintance. We did not visit each

25 other's homes or we didn't call on each other. We never had any coffee

Page 6566

1 together either at my place or at Krnojelac's place. Then we met up at

2 the Zelengora Hotel, Krnojelac and I and Bozo Drakul, due to the

3 same misfortunes that had befallen us; me, Krnojelac, and Bozo Drakul.

4 Q. When Mr. Krnojelac was staying at the Hotel Zelengora, I assume

5 his wife was there as well, right?

6 A. Yes, his wife was there.

7 Q. Were any of his four sons staying there as well?

8 A. Believe me, I would see them but whether they were staying in one

9 room or the other room, I don't know, but I did see them. At any rate,

10 they were all there.

11 Q. You're aware that at least two of his sons were active in the

12 military at that time, right?

13 A. I know that his son Mika -- I think his name is Mika Krnojelac,

14 was in the military and was seriously wounded and lost both of his legs.

15 Q. Was he one of the people that you saw coming and going from the

16 Hotel Zelengora?

17 A. No, no. I did not see him going into the hotel or out of the

18 hotel except when he came to his mother and father, to this part where we

19 were staying.

20 Q. Let me rephrase it. You actually saw him inside the hotel, even

21 if you didn't actually see him come or go?

22 A. In front of the hotel.

23 Q. You told us that Milorad Krnojelac was in charge of procurement,

24 and by that, you mean that he brought supplies from the outside, such as

25 food and toiletries and supplies, right?

Page 6567

1 A. I didn't see Milorad Krnojelac bringing this in. It was probably

2 other people who were driving these vehicles and bringing these things in,

3 but I know that Milorad travelled and provided for all of this, but who

4 did the driving, I guess it was one of the drivers. At any rate, he went

5 quite often, providing for these supplies, food, detergents, everything

6 that could be obtained at the time. Milorad tried to provide this through

7 the Red Cross, through people in Serbia, people say that he even went from

8 one house to another, from one company to another, seeking assistance so

9 that we could be fed as well as the convicted, detained and imprisoned

10 persons.

11 Q. You didn't actually ever speak with Mr. Krnojelac about these

12 things, right? You only heard it from other people?

13 A. When I went to work, one day we met in the street. Milorad said

14 to me only that he was assigned down there as temporary warden. As for

15 other things, Milorad and I never really -- I mean, I was not in a

16 position until the present day - after all, I've been working at the KP

17 Dom as a police sergeant, but my warden, deputy warden, my supervisor, are

18 beyond my reach. I never socialised with them. I would only talk to them

19 when one of them would call me in.

20 Q. My question was about Milorad Krnojelac. You told us that he was

21 going from company to company, asking for supplies, going to particular

22 places. You don't actually know those things, right, because Milorad

23 Krnojelac himself never told you those things?

24 A. Well, Milorad didn't say that to me verbatim, but the driver

25 told me. After all, I worked at this place, and I would see a truck full

Page 6568

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Page 6569

1 of food coming in and, of course, when I would ask the driver, he would

2 tell me who provided these supplies and who made it possible.

3 Q. And once the supplies reached the KP Dom, they were distributed to

4 the detainees without regard to whether they were Serb civilian prisoners,

5 Serb military detainees, or Muslim detainees, right? It made no

6 difference?

7 A. Regardless of who was doing his time or who was in the KP Dom,

8 everything that was there - food, clothes, footwear, toiletries - all of

9 it was divided up equally. At least from that point of view, no

10 distinction was made.

11 Q. You told us yesterday that you brought a group of Muslim detainees

12 to repair Milorad Krnojelac's house. And in a statement to Defence

13 investigators, you stated, in the next to last paragraph, "I also know

14 that the crisis command ordered that detained Muslims had to go to clear

15 away the facilities destroyed in the town and to repair the houses burned

16 by Muslim units at the beginning of combative actions. Thus, I took a

17 group of Muslim detainees to repair Milorad Krnojelac's house and left

18 them there without any guard." There are a few things I'd like to ask you

19 about that statement. First of all, do you stand by it today?

20 A. I stand by my words. It is correct that a few times I took a few,

21 I can't remember how many, prisoners. I remember Telo, and I think that

22 his son was there too. I would take them, I would take some food, and I

23 would leave them at Milorad Krnojelac's house. I would hand them over to

24 his son or to the craftsman who was in charge of the construction at that

25 house. I would go back. When the work would be over, if we were not in a

Page 6570

1 position to go and to drive them ourselves, usually Milorad's son or

2 somebody else would drive them back. I also know for sure that Milorad

3 Krnojelac's wife, although she is of different ethnicity - I know she is a

4 Croat - in addition to the food that we brought for them from the KP Dom,

5 she prepared food for them every day and gave them cigarettes and gave

6 them fruit juice.

7 Q. Sir, you told us this yesterday, we don't need to repeat it. When

8 you said in your statement, "I left them there without any guard," you did

9 leave them in the care or in the custody of Milorad Krnojelac's son or a

10 craftsman from the KP Dom, right? And those people were the ones guarding

11 the detainees at that point?

12 A. No, no. They were not guarding them. They were working with

13 them. But as I said, I would hand them over. I would say, Hello, I

14 brought these people here. I'm going and they are staying. They worked

15 together. They were not in charge of this group or in charge of guarding

16 this group that I brought in.

17 Q. This group of people you brought, you gave us a few names. They

18 are not the same people who worked at the furniture factory, right? It's

19 a different group of people?

20 A. Telo, Telo, I think Mustafa is his name, also came to the

21 furniture factory from time to time, I think. For example, for some

22 things that were to be done on Milorad Krnojelac's house, and then doors

23 and windows were worked on there so he would come and join this group at

24 the furniture factory too.

25 Q. When you said you sometimes left the detainees at Milorad

Page 6571

1 Krnojelac's house with a craftsman, was that a craftsman from the KP Dom?

2 A. No, no. No worker from the KP Dom ever did this. Only the person

3 who would drive them there would go there and come back, but there were

4 civilian craftsmen who were working on the house.

5 Q. While the Muslim detainees were at Milorad Krnojelac's house,

6 working, they were still technically detained and in the custody of

7 the KP Dom, right? They were not free to leave and go anywhere else.

8 A. They were doing time at the KP Dom, but I really don't know

9 whether they could go to the kiosk or get something to eat or drink or

10 something. They would come to the KP Dom at night. But I was not there

11 with them at that time so I can't say anything.

12 Q. I'm sorry, there is a statement here that they would come to the

13 KP Dom at night. Who are you talking about? Do you mean that the workers

14 would come home -- come home -- go back to the KP Dom in the evening to

15 spend the night and then perhaps be brought back during the day again to

16 work? That's what you meant, right?

17 A. No. I said that they, while they worked on Milorad Krnojelac's

18 house, they could go to a shop and get a drink or something perhaps. I

19 don't know. I'm just assuming that. I imagine that no one stopped them

20 from doing that. They worked in the afternoon and then, yes, they would

21 come to the KP Dom to sleep there during the night, yes. I also know that

22 on one occasion, Mustafa Telo addressed me personally and asked to work on

23 those days when Mrs. Milorad Krnojelac did not want work to be done on the

24 house due to certain religious holidays, whatever. They just asked to go

25 out and work regardless of the fact that it was a Saturday or a Sunday

Page 6572

1 or a holiday.

2 Q. If the Muslim detainees, while working on Milorad Krnojelac's

3 house, had run away, somebody from the KP Dom would have been responsible

4 for that escape. That would count as an escape, right?

5 A. Somebody would probably be responsible, but the person who would

6 take them there would be responsible for him.

7 Q. And those times when you took the person or the group, you would

8 be held responsible if somebody escaped, right?

9 A. I would not be responsible because I did not leave of my own free

10 will. It's probably my superior who would be held responsible, the one

11 who sent me to take them there.

12 Q. You never took any Muslim detainees to fix Savo Obrenovic's

13 house, right, the one that you lived in before it was destroyed during

14 the war?

15 A. I never went over there. I never took anyone.

16 Q. You told us his house was rebuilt as a result of a loan from his

17 company and that means that no Muslim detainees from KP Dom were used to

18 fix it up, right?

19 A. It was not necessary for Muslims to renovate these houses, because

20 the company where my landlord Savo worked and where my landlady Mila

21 worked -- I mean, they turned to their company and their company found

22 workers who they paid so that this house could be rebuilt from the very

23 foundations to the roof, because these companies were doing well. They

24 are still doing well.

25 Q. Thank you. With the assistance of the usher, I'd like to have the

Page 6573

1 witness shown Exhibit P3 and bring his attention to page 2, item 47.

2 Mr. Matovic, at item number 47 is your name and birth date,

3 right?

4 A. Yes.

5 Q. And next to that are a number of dates. There is a beginning date

6 and an ending date, and there are three sets of beginning and ending

7 dates. I want to ask you some questions about that. The first beginning

8 date is 26th of April, 1992, and then the end date for that first period

9 is 30 September, 1992. Was there anything significant about the 30th of

10 September 1992 in terms of your assignment at the KP Dom?

11 A. Nothing significant happened in this period while I worked there.

12 I said that I spent a certain period at the gate and then I spent that

13 entire period at the furniture factory, and nothing significant happened,

14 at least not as far as I know.

15 Q. Let me ask you this way: The 26th of April, 1992 is when you

16 began your work obligation at the KP Dom, right?

17 A. Yes, yes. I came on the 24th. I can safely say that these

18 records are wrong, because I said that I came on the 24th and I see that

19 what it says here is the 26th. So there are mistakes in records, too.

20 Q. All right. And then you stayed at the KP Dom under your work

21 obligation until what period -- until what date?

22 A. I stayed at work duty until the 30th of September, 1992. That was

23 my work obligation. Until then, I had it interrupted by going to the

24 front. Then I went to the Miljevina mine. At any rate --

25 Q. Did you -- the day after the 30th of September, that is October

Page 6574

1 1st of 1992, were you no longer at the KP Dom? Or did you continue

2 working there but you started to sometimes go to the front?

3 A. I continued working there all the time. However, I would go to

4 the front as well.

5 Q. And then on the 2nd of September, 1993 is when you came back

6 full-time to the KP Dom and were assigned to the Miljevina mine, right?

7 A. Yes, yes, yes, from September -- that is to say from September

8 until 1994, I don't know exactly, but I spent about a year at the mine,

9 together with my colleague.

10 Q. And then the third set of dates, the time that you've identified

11 as when you're at the Miljevina mine, goes from 2nd September, 1993, to 12

12 January, 1994. Then there is another time that starts from 16th January,

13 1994 to October 31st of 1994. What happened during that time?

14 A. I'm so sorry, I see that there is a period missing here. I'll

15 have to explain this a bit. I went to the mine towards the end of

16 September, 1993.

17 MS. KUO: It's 1.00, so perhaps we can have your explanation of

18 that after the lunch break.

19 JUDGE HUNT: We will come back to that at 2.30, thank you very

20 much. We will adjourn now.

21 --- Luncheon recess taken at 1.00 p.m.

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Page 6576

1 --- On resuming at 2.31 p.m.

2 JUDGE HUNT: Ms. Kuo.

3 MS. KUO:

4 Q. Good afternoon, Mr. Matovic. Just before the lunch break you

5 started to explain --

6 A. Good afternoon.

7 Q. You started to explain the dates for the third set of dates on the

8 sheet of paper before you. Would you like to explain now? You said there

9 was a time period missing.

10 A. What's missing is the period from 1992 to 1993, which I also spent

11 doing my work duty at the KP Dom on the same job, and simultaneously, I

12 went to the front line in the area of Nekopi. And later, when I

13 returned, I went to the Miljevina mine to work, so these dates here are

14 not quite accurate because there is a period missing.

15 Q. Was it the 1st of October, 1992, when you began to go to the front

16 line every so often, or were you going to the front line already

17 throughout the summer of 1992?

18 A. In the summer of 1992, I didn't go. I went to the front line from

19 October. I went to the front line and simultaneously I had my work duty.

20 Q. So that may explain the gap, even though, as you say, more

21 correctly it should say that from the 1st of October, 1992, until the 1st

22 of September, 1993, that you were still assigned to the KP Dom and working

23 there but on occasion were going to the front line; is that right?

24 A. Yes. On occasion, I went to the front line for tours of four or

25 five, maybe up to seven days, with 20 or 21 day intervals. And after my

Page 6577

1 tour on the front line, I would start again on my usual work duty.

2 Q. So that the period of time at the front lines was four or five

3 days and then the usual work duty at the KP Dom was 20 or 21 days, and

4 then back to the font line for four to seven days, that pattern; is that

5 right?

6 A. Yes. We went there in three or four shifts.

7 Q. When you say three or four shifts, do you mean that the other

8 policemen and you went -- you were divided into about three or four groups

9 and you all went as a group to the front line; is that what you meant by

10 shifts?

11 A. I meant that one group comprised about ten policemen who went away

12 for about ten days. Then another group would come to replace us, so we

13 took turns. And in a month, there would be three such turns.

14 Q. You mentioned earlier that Mitar Rasevic also went to the front

15 line. Did he also participate in these shifts? Was he part of the ten in

16 a group?

17 A. Mr. Mitar Rasevic also went to the front line but we never went

18 together. That never happened. But I know that he also went to the front

19 line just as the other policemen.

20 Q. But he went as regularly as you've described the other policemen

21 went, right?

22 A. Regularly, yes, just as the other policemen.

23 Q. When he was at the front line, who took over his

24 responsibilities?

25 A. When he would be away at the front line, the commander, the

Page 6578

1 sergeant would stay behind. It was usually his deputy, Miro Prodanovic,

2 who substituted for him.

3 Q. You testified also that Savo Todovic went to the front line. Did

4 he also go regularly like the policemen did? Or did he go on a different

5 schedule?

6 A. He went on a different schedule and I saw him only once. How many

7 days he stayed up there and with whom, I don't know.

8 Q. You say you saw him once. Do you mean once at the front line when

9 you were there?

10 A. I saw him outside the KP Dom when he was preparing to go but I

11 didn't see him on the front line because I was not in the same group with

12 him.

13 Q. You were -- do you remember if you were working in July 1993 when

14 a particular prisoner escaped from the metalwork shop?

15 A. Yes. I remember. That was -- I don't know exactly what month it

16 was. It was June or maybe July. A prisoner named Zekovic escaped. I

17 remember that well.

18 Q. And you've told us earlier that if somebody were responsible for a

19 detainee escaping, that person could lose his job, right? So when

20 Mr. Zekovic escaped, all the policemen were very nervous about that,

21 right?

22 A. Mr. Zekovic worked in the metalwork shop without any security. At

23 that time, there was no one around out of the policemen guarding those

24 five, six or seven prisoners who worked there, with only their foreman

25 present. None of the police were on duty there.

Page 6579

1 Q. If somebody in that wartime situation, under a work obligation,

2 were to lose his job, what it would mean is he would be sent to the front

3 line full-time, right? Instead of rotating back home every three or four

4 weeks? That would be the result of losing the job?

5 A. I don't know whether anyone would be sent to the front line if he

6 lost his job. I don't know whether he would be given another job

7 somewhere else perhaps. I don't know whether that would be sufficient

8 grounds for sending him to the front line.

9 Q. Between the time that Mr. Zekovic escaped or it was discovered

10 that he had left the KP Dom and the time that he was brought back the next

11 day, the people -- the staff at the KP Dom were very much afraid that they

12 might be blamed for his escape, right? That's quite natural.

13 A. When we found out that Mr. Zekovic had escaped, of course, the

14 staff was concerned, but not for fear of losing their jobs or for fear of

15 any sanction but because Mr. Zekovic could well step on a mine and get

16 killed because all areas around town were mined, both by Serb and Muslim

17 soldiers.

18 Q. So you were afraid for his safety; is that what you're saying?

19 A. Yes. We were concerned for Mr. Zekovic. We were worried about

20 all the things that might happen to him when he was out of the KP Dom.

21 Q. When Mr. Zekovic was captured the next day, there -- well, in the

22 meantime, there was a -- there was word sent out into Foca and the

23 surrounding villages that a detainee had escaped and for people to be on

24 the lookout for him, right?

25 A. When Mr. Zekovic escaped, this was reported to surrounding

Page 6580

1 villages and word was sent out to stop him lest he be exposed to mines

2 because I personally remember the time when he was caught and brought

3 back, it was me with a colleague of mine, who went to see Mr. Zekovic, to

4 fetch him, rather, in a -- from a place called Kopilovi which was about

5 15 kilometres away.

6 Q. And at that time, you were with Miro Prodanovic, right? Miro

7 Prodanovic was the colleague you referred to?

8 A. Yes, that's correct, Miro Prodanovic and myself went. I drove the

9 car and Miro came with me because the locals notified the local police and

10 the local police notified us and we went to fetch Mr. Zekovic.

11 Q. In what capacity were you there with Miro Prodanovic? Mr. Zekovic

12 didn't work in the furniture factory, so why were you the person to go

13 with Prodanovic?

14 A. I worked at the furniture factory, and since there was no one else

15 to drive that special vehicle, the Mariah, and since I worked as a

16 driver of that vehicle before the war, the man on duty, I believe it was

17 Veljko Kovac, called me and told me to take that car and go and fetch him

18 because he was captured up there in that village, and that we should bring

19 him back to the KP Dom.

20 Q. When you got there, you learned the story of how Mr. Zekovic

21 was captured, right? That he told someone that he was going to go buy

22 cows?

23 A. I don't know the details but it was, I believe, the policeman

24 Jovan Milic and some other policemen who brought me and we didn't discuss

25 those details with those local policemen. In the village of Kopilovi,

Page 6581

1 villagers had started to gather, knowing that Mr. Zekovic had been

2 captured and that he was there.

3 Q. Isn't it true that, when you arrived, Mr. Prodanovic taunted and

4 provoked Mr. Zekovic by saying, "So you're off to buy some cows?" Isn't

5 that right?

6 A. There was no taunting by Mr. Prodanovic or anyone else. When we

7 came, policeman Milic just told us to get him into the car and to get away

8 as quickly as we can because the villagers were starting to -- that they

9 were rather unhappy and there was danger of them attacking Mr. Zekovic.

10 Q. There is no reason for Ekrem Zekovic to have singled you out as

11 somebody who would mistreat him, right? You never mistreated him or had

12 any quarrels with him before this time?

13 A. Until that moment, I had only seen Mr. Zekovic in passing when he

14 was on his way to work in the metalwork shop. There was never any

15 mistreatment on my part, nor did Mr. Zekovic allow any of that. But when

16 we came back, we started discussing if Mr. Zekovic had any grounds for

17 complaint. Perhaps I was making more noise than normal because I thought

18 that Mr. Zekovic had been entrusted with our confidence. By escaping,

19 he exposed himself to danger, but not only himself but also the people who

20 went to search for him. Perhaps I had raised my voice a little. Really,

21 I'm not a man who shouts normally but when we got to that village, I just

22 told my colleague Prodanovic just open that door, and he pushed him in and

23 we closed the door of the car and went away.

24 Q. Isn't it true that when you and Mr. Prodanovic arrived, you hit

25 Mr. Zekovic in the face so hard that he fell onto the asphalt? You did

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Page 6583

1 that, didn't you?

2 A. Believe me, I would never do any such thing. Perhaps I pushed him

3 most forcefully than usual into the car, but Mr. Prodanovic and I had to

4 drive 15 kilometres back and, if I had wanted to, I could have stopped the

5 car halfway and beaten him up, if I had wanted to. Maybe Mr. Zekovic had

6 mistaken that push for a blow but I -- I can't believe that he would have

7 said to this Trial Chamber that I had done that.

8 Q. Isn't it true that the civilian police officer who was there

9 reacted to what you did to Mr. Zekovic, by saying, "You don't have to use

10 force"? Because Mr. Zekovic wasn't resisting at all.

11 A. The policeman who was there, I told you already I knew only Jovan

12 Milic, and Jovan Milic told us, "Just get him into the car and drive

13 away," to avoid any unpleasantness because I had already explained that

14 villagers had started to gather and discontent was rising among them and

15 they were almost ready to start beating him themselves.

16 Q. When you drove back to Foca from that village, isn't it true that

17 the civilian police officers got into the Mariah vehicle with you and

18 that you dropped them off at the police station in Foca before going back

19 to KP Dom?

20 A. The police had their own vehicle. It was only me, Miro

21 Prodanovic, and Zekovic who went back, who drove away, and in our van we

22 passed through the gate into the KP Dom. The policemen didn't come with

23 us. They didn't go back with us.

24 Q. So you never stopped by the police station before you went back to

25 KP Dom?

Page 6584

1 A. No. We went straight to the KP Dom.

2 Q. You reached the KP Dom, Burilo, Milenko Burilo, who was a guard

3 there, was present, right, at the front entrance?

4 A. When we arrived at the KP Dom, I, as the driver of that special

5 vehicle, let Miro Prodanovic and Zekovic get out, and I drove my vehicle

6 back to the garage to park it, and what happened from that moment on, I

7 really don't know.

8 Q. So you wouldn't know whether Burilo beat up Ekrem Zekovic at the

9 entrance to the KP Dom, would you, because you weren't there?

10 A. I wasn't there. I had gone to park my car elsewhere and I wasn't

11 outside the KP Dom entrance any more.

12 Q. The next day, isn't it true that all the detainees and all the

13 guards were lined up so that they could all be lectured about Ekrem

14 Zekovic's escape?

15 A. The next day, I was working at the factory from 7.00 a.m. to 3.00

16 p.m. I don't know what time it was exactly when Mr. Krnojelac came to

17 tour the factory, to see the -- how the production was going, to see how

18 we were doing, and to have a discussion with his colleagues - that is,

19 heads of production - about some loading of furniture. I talked to

20 Krnojelac then and, when I headed for the exit from the building, I saw

21 through the window that the convicts were gathered outside the canteen in

22 the compound. I don't know why they were there. I didn't know it at the

23 time. But I heard later from the detainees who worked in my factory that

24 they had been lined up by Savo Todovic, that Savo Todovic said that

25 nothing like that should happen again, that nobody would ever escape

Page 6585

1 again, that it was dangerous, that they could get killed by mines, and

2 that they should take a look at Mr. Zekovic, because he came back safely

3 and nothing had happened to him after all.

4 Q. You're saying that the Muslim detainees who worked at the

5 furniture factory were not in the furniture factory at that time because

6 they were lined up outside, right?

7 A. The detainees who worked at the furniture factory were there. I

8 heard it from them. And that's how I know what Savo had explained to

9 them. At that moment when it was going on, I was with Milorad Krnojelac

10 and with the foreman.

11 Q. You knew before you heard the lineup outside that the Muslim

12 detainees who were supposed to be working at the furniture factory weren't

13 there that day, right? You knew that they were somewhere else because

14 they weren't at the furniture factory. They had to be somewhere else.

15 A. That second day, before they came, they were lined up there. I

16 said that, after that day, when they were absent from the factory, the

17 next day, they told me what it was all about.

18 Q. You -- I'd like to have the Exhibit P6 shown to the witness

19 again.

20 And I'd like for you to show us if a person were going from the

21 administrative building to the furniture factory, what route would the

22 person take?

23 A. I, together with those foremen from the furniture factory, went

24 across the compound right here, and we would come into the furniture

25 factory here; although there is also another entrance through this gate, a

Page 6586

1 small door through which you could also enter the factory from gate number

2 2. The lineup was outside the administration building here. More

3 specifically, outside the canteen. There is -- there are stairs nearby,

4 Savo was standing on the stairs, and I was here at the furniture factory,

5 watching it from a window.

6 Q. Just let me put on the record what you've indicated. When I asked

7 you about the route from the administrative building to the furniture

8 factory, you started at the administrative building and indicated across

9 the courtyard in the KP Dom to the right where there is an entrance or a

10 doorway or a pathway between the courtyard of the compound into the road

11 leading to the furniture factory, and then you went up just a little bit

12 and there appears to be an entrance on the right, and that is the entrance

13 into the furniture factory. So that would be the route from the

14 administrative building into the furniture factory.

15 The alternative route that you indicated would be through -- from

16 the outside of the KP Dom through gate 2, going up in the diagram and then

17 again to the same entrance doorway into the furniture factory. Those are

18 the only two entrances possible, right?

19 A. Yes.

20 Q. Thank you. I'd like to go back to something just before the

21 break. You talked about the detainees who were taken to work on

22 Mr. Milorad Krnojelac's house and sometimes you would leave them in the

23 care of a craftsman who was not employed by the KP Dom. What was his

24 name?

25 A. I'm afraid to get the name wrong. He might be [redacted]. He

Page 6587

1 sort of [redacted] work on that house, did some repairs himself, and he

2 [redacted].

3 Q. I'd like to ask you about a man named Nurko Nisic. Did you know

4 him?

5 A. No.

6 Q. You've told us that you never saw anybody being beaten. You claim

7 that you never heard about detainees being beaten inside the KP Dom?

8 A. I said that I never saw anyone beating anyone, but I did hear from

9 the Muslim detainees precisely about this Zekovic, that this Milenko

10 Burilo beat him up at the entrance by the gate. That's what I heard but

11 I really did not see anyone beating anyone.

12 Q. Was Milenko Burilo ever disciplined for beating Mr. Zekovic?

13 A. Believe me, I don't know. I'm not aware of that. I can't give

14 any assessment of this nature. I said that I heard that he had beat him,

15 but whether it's true or not, I don't know.

16 Q. I'm asking you the question because if you hear about an incident

17 like that, you've told us that you disapprove of incidents like that. You

18 heard about it and it would be quite natural for you to be curious about

19 whether anything happened to him or if there was a follow-up on it. And

20 so he was never punished, the guard Burilo, he was never punished for

21 beating up Zekovic, right?

22 A. Had I seen this, had I found out the actual truth, I would have

23 reacted in that way, with my superiors too, but I never saw this. I was

24 never on the same shift with Burilo and we never worked together. I don't

25 know.

Page 6588

1 Q. You told us yesterday that Todovic was appointed by the military

2 to come work at the KP Dom, to be in charge of the Muslim detainees. When

3 you gave a statement to Defence investigators in February of this year,

4 you never once mentioned Savo Todovic's name, did you?

5 A. I did not mention Savo Todovic's name for the following reasons:

6 I only heard that from others that Savo Todovic had been appointed, from

7 colleagues too, and I would really feel embarrassed to state something

8 that would not be the truth. I saw on television that Savo Todovic was

9 mentioned and I'm saying that now, that Savo Todovic, as far as the

10 Muslims and my colleagues knew, he was in charge. It is for that reason

11 that I did not mention this earlier in my statement.

12 Q. Sir, you said you saw on television that Savo Todovic was

13 mentioned. Do you mean that that was during television coverage of this

14 very trial?

15 A. I mean, how should I put this? This is some programmes about The

16 Hague Tribunal, witnesses of Muslim ethnicity who testified here mentioned

17 the name of Savo Todovic, and that he was in charge.

18 Q. So it was after you saw this television programme saying that

19 Muslim witnesses had talked about Savo Todovic that -- you saw the

20 programme after you gave the statement already to the Defence

21 investigators, right?

22 A. I gave a statement, I gave a statement earlier on. Sometime in

23 the month of September. That is to say this year.

24 Q. Do you mean September or February?

25 A. I think it was the month of February.

Page 6589

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Page 6590

1 Q. And at that time, you had not yet seen any television programme

2 that mentioned Savo Todovic, right?

3 A. At that time, I did not, no.

4 Q. And when you gave the statement, can you tell us whether you

5 contacted the Defence investigator, Mr. Dundjer, or whether he and Ms.

6 Rada Sestovic-Krnojelac contacted you?

7 A. I found out that Defence was being prepared for Mr. Milorad

8 Krnojelac, and I reported myself. I thought that I should say the truth,

9 if that was important, and this lady, Mrs. Rada Krnojelac, and she

10 contacted me and then I came to the Cafe Gong and then I made this

11 statement of mine in front of her and this Mr. Dundjer.

12 Q. At the time you gave your statement, you knew that the purpose of

13 your statement was to help Mr. Krnojelac in preparing his defence, right?

14 A. When I gave the statement, it is only natural that the point is to

15 help to prove the real truth, not only about Mr. Krnojelac but about

16 anyone. If anybody needed that kind of statement that would help him, I

17 would certainly volunteer, regardless of whether it's a Serb, Croat or a

18 Muslim. It is a humane and human thing to do, to tell the truth.

19 Q. And not once in your statement of 16 paragraphs did you ever

20 mention Savo Todovic as being in charge of the military part of KP Dom,

21 did you?

22 A. Well, I wasn't sure. I said when I gave my statement, I wasn't

23 sure that Savo Todovic was the only person in charge. When I heard from

24 my colleagues and also from these detained Muslims and also from my

25 colleagues who testified before me, why should I not say this, that Savo

Page 6591

1 Todovic was in charge of the detained Muslims?

2 Q. So you, sir, do not actually know whether Savo Todovic was in

3 charge or not. You're only repeating what your colleagues who testified

4 for the Defence told you, right?

5 A. I know, I know now that Savo Todovic had control over the Muslim

6 detainees and that he had been appointed by the military.

7 Q. During the time that you yourself were at KP Dom, working external

8 security, driving that Mariah vehicle, being there every single day at the

9 furniture factory, it never once was apparent to you that Savo Todovic was

10 in charge; isn't that right?

11 A. These people who worked in the factory said that Savo Todovic was

12 in charge of them, and the permits he signed for work in the factory and

13 elsewhere, that went through the military and through Savo Todovic.

14 Q. He was in charge of the working, of the work crews, but during the

15 entire time that you worked at the KP Dom during the war, you never saw or

16 heard anything that led you to believe that Savo Todovic was in charge,

17 right? Because otherwise, you would have told the Defence investigators

18 in February. That was information that would have been important, but you

19 never saw with your own eyes or heard with your own ears that he, while

20 you were there, that he was in charge; isn't that the truth?

21 A. Well, I stated in my previous statement here that Savo Todovic,

22 when Zekovic escaped, and when he brought everyone together within the

23 compound, that meant that he was the man who was in charge of the detained

24 Muslims, because probably had it been someone else, somebody else would

25 have made that speech, not Savo Todovic.

Page 6592

1 Q. I'm talking about your statement in February of this year, not

2 about your testimony in the courtroom today or yesterday. In the

3 statement you gave in February, you never once mentioned that Savo Todovic

4 was in charge. If you won't answer that, I can ask Defence counsel to

5 stipulate to it. In fact, that's true.

6 A. Probably, probably.

7 MS. KUO: I'd like to have Defence counsel agree that the

8 statement that was given on the 24th of February, 2001, never once

9 contains any mention of Savo Todovic.

10 JUDGE HUNT: Mr. Bakrac?

11 MR. BAKRAC: [Interpretation] Your Honour, the Defence agrees, and

12 that was accepted by the witness too. He said that he did not mention the

13 name of Savo Todovic, so there is nothing controversial about this.

14 JUDGE HUNT: Mr. Bakrac, you're not here to address us on the

15 merits of the case or on the witness's credit. He clearly has only said

16 probably he did not and that is why you're asked to agree. Now, you

17 either agree or you don't agree. I gather you do agree. That's all we

18 want to hear at this stage. You'll have ample opportunity later to

19 address us on all of the matters you are very keen to tell us about.

20 Yes, you proceed, Ms. Kuo.

21 MS. KUO: Thank you, Your Honour.

22 Q. Mr. Matovic, in August and September of 1993, not long after Ekrem

23 Zekovic's escape, there were some major personnel changes at the KP Dom;

24 isn't that right? Zoran Sekulovic replaced Milorad Krnojelac as the

25 warden, right?

Page 6593

1 A. Yes. Mr. Zoran Sekulovic came as warden, Milutin Tijanic came

2 as deputy, and for the -- and Radojica Tesovic came as director of the

3 Drina Economic Unit.

4 Q. What was Zoran Sekulovic's background, professionally?

5 A. Believe me, I don't know what he was by profession but I know that

6 when he was appointed to this particular job, that he was working in some

7 newspaper publishing house so, as far as I know, he was some kind of a

8 political scientist.

9 Q. When Mr. Sekulovic came, things changed in the KP Dom in terms of

10 discipline of the staff, right? The rules were more strictly enforced

11 upon his arrival?

12 A. As for discipline, discipline wasn't lacking earlier either, but

13 when Mr. Tijanic came as warden, discipline was improved because,

14 according to the KP Dom establishment, the deputy warden is the person who

15 is in charge of security in the KP Dom.

16 Q. The transcript -- it may be that there was an error in the

17 translation, but it shows that you said when Mr. Tijanic came as warden.

18 You meant when Mr. Tijanic came as deputy warden, right?

19 A. Yes, deputy warden.

20 Q. Mr. Tijanic, before the war, was previously in charge of

21 rehabilitation, right?

22 A. Mr. Tijanic, before the war, was head of the rehabilitation

23 service, and the deputy was Alija Berberkic.

24 Q. Where was Mr. Tijanic during the war, do you know? He wasn't

25 working at KP Dom any more, was he?

Page 6594

1 A. Mr. Tijanic did not work in the KP Dom and where he was, I really

2 don't know.

3 Q. Mr. Tesovic returned as the manager of the Drina Economic Unit,

4 right?

5 A. Mr. Tesovic came to the Drina Economic Unit together with

6 Sekulovic and Tijanic.

7 Q. And around that same time, Savo Todovic became the assistant

8 warden for legal and financial affairs, right?

9 A. Savo Todovic was in charge of detained persons of Muslim

10 ethnicity, and then he also stayed on as the lawyer of the legal and

11 financial service. That's what it was called. Legal and financial

12 affairs. The assistant warden for legal and financial affairs, yes,

13 that's right.

14 MS. KUO: Thank you. No further questions.

15 JUDGE HUNT: Re-examination, Mr. Bakrac?

16 MR. BAKRAC: [Interpretation] Yes, Your Honour, I would just like

17 to try to clarify certain matters with the witness.

18 Re-examined by Mr. Bakrac:

19 Q. [Interpretation] Did I understand you correctly, was it already in

20 1992 and 1993 that you heard from detained Muslims and colleagues that

21 Savo Todovic was in charge of that part of the prison, or rather, for

22 Muslim detainees?

23 A. Yes. I said that I heard about that from my colleagues who worked

24 together with me and also from Muslims who were detained and who were

25 working in the factory, but I already said all of this.

Page 6595

1 Q. If I've understood you correctly, after you gave your statement,

2 you heard that this was confirmed by other persons as well. Is that why

3 you decided to speak here of your own knowledge that you had in 1992?

4 A. Yes, exclusively.

5 MS. KUO: I have to object because, even if this is redirect,

6 these are grossly misleading -- misleading questions, I started to say,

7 but leading questions, in any event.

8 JUDGE HUNT: They certainly are, Mr. Bakrac. You can ask him a

9 question to which he can give an answer. The only answer he can give to

10 your questions are a yes or a no. That means it's a leading question.

11 MR. BAKRAC: [Interpretation]

12 Q. Sir, try to explain this to us once again because we have a

13 problem with interpretation. We have heard this. We have heard what you

14 said. Tell us once again now, why did you not say this in your statement

15 in February and why did you say it today? I don't even think that it was

16 my question. You added this to something else and then I asked you about

17 this. The Defence is interested in why you said it yesterday during the

18 examination-in-chief.

19 A. Well, it was hard, in that period when I gave my statement, to

20 mention something like this. I did not want to. I did not have the

21 courage to say this the first. But when I saw that this was known and

22 that others had said it and I came here to testify, why wouldn't I testify

23 about it too?

24 Q. Is it only for the sake of testifying or did you know this in 1992

25 or 1993?

Page 6596

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Page 6597

1 A. I knew it in 1992. I said that I knew it in 1992, that Savo

2 Todovic was in charge of detained Muslim persons on behalf of the army.

3 Q. Tell me, you said that when Savo Todovic lined people up a day

4 after Zekovic's escape, that Milorad Krnojelac was at the furniture

5 factory. Do you know whether Milorad Krnojelac was still warden of the KP

6 Dom at that time?

7 A. Milorad Krnojelac, I can't remember whether he was warden of the

8 KP Dom in that period, but I know that he was in charge of the Drina

9 Economic Unit and that he was in the furniture factory because of the

10 production of products and because of the loading of furniture into

11 trucks. Milorad Krnojelac at first was appointed temporary warden.

12 Q. You've already told us about this. Is there anything new that

13 you'd like to say?

14 A. Well --

15 JUDGE HUNT: Stop both of you, please. Neither of you are waiting

16 until the translation is finished. Now, please, just take it quietly -

17 we've got the time - and watch the screen for the typing to finish.

18 MR. BAKRAC: [Interpretation]

19 Q. Sir, what you said to us is already in the transcript. If you

20 have anything new to add, I'm not going to interrupt you, I'm just asking

21 you whether, when Zekovic was caught, whether you knew that Milorad

22 Krnojelac was still warden in the KP Dom.

23 A. I think that Milorad Krnojelac was still warden in that period.

24 That was the month of June, 1992.

25 Q. When Zekovic was lined up, or rather, when Savo Todovic lined up

Page 6598

1 the prisoners -- actually, where was Milorad Krnojelac? Was he still at

2 the factory or had he gone to the administration building, do you know?

3 A. I knew -- I said that I was touring the factory together with

4 Mr. Krnojelac. Mr. Krnojelac went to the gate number 2 and I stayed at

5 the furniture factory.

6 Q. You said that in the apartment -- that you were staying at the

7 apartment of a certain Huso Mahmutovic. Does he own that apartment or did

8 he only have the tenant's right to that apartment?

9 A. The apartment is owned by the KP Dom and Huso Mahmutovic bears

10 the tenant's right for that apartment.

11 Q. Did you, from Huso Mahmutovic -- I'm sorry, no; did you get it

12 from the KP Dom as owner for temporary use or has it been allocated to you

13 on a permanent basis?

14 A. I got the apartment for temporary use from the municipal

15 authorities, although perhaps two or three years ago, Huso Mahmutovic came

16 to see his apartment and we sat there at my place, we had a cup of coffee,

17 and we agreed on the further use of his apartment, because the same Huso

18 Mahmutovic has a house in Sarajevo and does not intend to return.

19 Q. You talked about persons who on the 10th, or rather, convicted

20 persons, prisoners who were transferred on the 10th of August from the KP

21 Dom to Velecevo. Did they spend a certain amount of time at Velecevo

22 or did they go to Montenegro directly on that day and then further on to

23 Serbia?

24 A. If we are talking about detainees of Muslim ethnicity, they went

25 immediately in the Furgon trucks to Montenegro. As for the Serbs, they

Page 6599

1 went to work at the farm.

2 Q. You are trying to say to us that they did not spend some time at

3 Velecevo but that, under the fighting that went on until the 16th, they

4 went to Montenegro, or are you unaware of this?

5 A. I am aware that the Muslim and the Serb authorities agreed on the

6 transport of these detained Muslims in Furgon trucks, that they could have

7 safe conduct, and go to Montenegro. That is what I know. And that is

8 what I heard from these colleagues who were transporting these detainees,

9 or rather, prisoners.

10 Q. Yesterday you said to us that you were appointed to work

11 obligation by the military authorities and you brought us this decision in

12 writing from the municipal authority of national defence. Were other

13 persons also appointed to guard duty by such decisions taken by the

14 military authorities?

15 A. Yes.

16 Q. Was Mitar Rasevic also appointed by the military authorities

17 according to such a decision regarding work obligation?

18 A. Yes, Mitar Rasevic was also appointed because work obligation

19 was assigned by the military and we were all duty-bound to respond to this

20 call-up.

21 Q. Yesterday, you said that Mitar Rasevic reported -- or rather,

22 repeat this to us: Who did Mitar Rasevic report to if he did submit

23 reports? You said that you didn't know but you made assumptions. Tell us

24 who did he report to?

25 A. Before the war, I know that reports were submitted. For instance,

Page 6600

1 I as a policeman, I submitted reports to my chief, my superior. My

2 superior submitted reports to his chief, the warden, and the warden would

3 forward that report to the Ministry of Justice. However, in this case,

4 Mitar Rasevic, I don't really know to whom he could have submitted his

5 reports because, at that time, the Ministry of Justice was not

6 functioning. As regards those Serb convicts, I think he reported to the

7 warden.

8 Q. Could you please tell me in peace time, did the commander of the

9 guard ever report directly to the Ministry of Justice?

10 A. No. I said already, it never happened. He submitted his reports

11 to the warden and the warden would notify in writing the Ministry of

12 Justice.

13 Q. You're now talking about the period before the war?

14 A. Yes.

15 MR. BAKRAC: [Interpretation] Thank you. No further questions.

16 JUDGE HUNT: Thank you, sir, for coming here to give evidence and

17 for the evidence which you gave. You are now free to leave.

18 THE WITNESS: [Interpretation] Thank you, Your Honours.

19 [The witness withdrew]

20 MS. UERTZ-RETZLAFF: Your Honour.

21 JUDGE HUNT: Yes?

22 MS. UERTZ-RETZLAFF: Before the next witness is brought in, I

23 would like to inform you and the Defence about a letter that we received

24 from the Bosnian -- Bosnia and Herzegovina embassy in relation to the

25 document ID D4. That's a document that was not yet entered into evidence.

Page 6601

1 It's a document related to the Drina -- the Foca Brigade of the Muslim

2 army, and of -- it relates to Mr. Rasim Halilagic, when he joined this

3 unit and when this unit was established, and we received now an answer.

4 JUDGE HUNT: Are you going to tender the letter?

5 MS. UERTZ-RETZLAFF: I just wanted to read this part right into

6 the record.

7 JUDGE HUNT: All right. Yes. You go ahead, please, Ms.

8 Uertz-Retzlaff.

9 MS. UERTZ-RETZLAFF: The embassy informed us that they believe

10 that the document is authentic, although they were not able to check with

11 the author of the document, but they believe it is authentic. But in

12 relation to the date, 6 of April, 1992, they say the following: "As for 6

13 April 1992 and Rasim Halilagic's joining the Army of Bosnia and

14 Herzegovina, the local authorities think that the document is authentic,

15 because this is the date the membership of the Army of Bosnia and

16 Herzegovina was regarded official regardless of one's joining the Army at

17 a later point of time. The official date the Army of Bosnia and

18 Herzegovina was formed is 15 April 1992."

19 JUDGE HUNT: You mean the fact that he may have joined even later

20 than the 15th of April, he's regarded as having joined on the 6th of

21 April?

22 MS. UERTZ-RETZLAFF: Yes, that is what they say.

23 JUDGE HUNT: I don't quite follow the logic but nevertheless that

24 should be satisfactory from Mr. Bakrac's point of view.

25 Well, Mr. Bakrac, what do you want to do about ID D4?

Page 6602

1 MR. BAKRAC: [Interpretation] I apologise, my microphone wasn't

2 on. Your Honours, ID D4 was tendered into evidence. It hasn't been done

3 pending verification but now, after verification, we would like to tender

4 this document.

5 JUDGE HUNT: Any objection, Ms. Uertz-Retzlaff?

6 MS. UERTZ-RETZLAFF: No, Your Honour.

7 JUDGE HUNT: Very well. That will be Exhibit D4/5. Thank you.

8 [The witness entered court]

9 JUDGE HUNT: Sir, would you please take the solemn declaration in

10 the document which the usher is showing you.

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

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

13 WITNESS: MILOSAV KRSMANOVIC

14 [Witness answered through interpreter]

15 JUDGE HUNT: Sit down, please, sir. Mr. Vasic.

16 MR. VASIC: [Interpretation] Thank you, Your Honours.

17 Examined by Mr. Vasic:

18 Q. [Interpretation] Good afternoon, sir.

19 A. Good afternoon.

20 Q. Could you please tell us your name first.

21 A. Milosav Krsmanovic.

22 Q. Sir, I would like to ask you at the outset, since we speak the

23 same language, to make a brief pause when I have asked my question, to

24 allow for interpretation because there are many other participants in

25 these proceedings and they need to hear both my question and your answer.

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Page 6604

1 Perhaps the wisest thing to do would be for you to follow the cursor on

2 the monitor and, when you see it stop, you can start answering. Did you

3 understand me?

4 A. Yes.

5 Q. Sir, tell us your birth date.

6 A. The 11th February, 1951.

7 Q. Where were you born? Your place of birth?

8 A. I was born in the village of Kozarevina, Foca.

9 Q. Where did you finish primary school?

10 A. In the villages of Slatina and Godijevno.

11 Q. Did you do your military service? And when?

12 A. Yes. In 1970.

13 Q. Where?

14 A. In Donja Crkva and Gornji Milanovac in Yugoslavia, presently

15 Serbia.

16 Q. Where did you get your training as a driver?

17 A. In the army.

18 Q. Do you have a licence and for which type of vehicle do you have a

19 driver's licence?

20 A. I have a licence for driving passenger, freight vehicles and

21 trailers.

22 Q. Are you married?

23 A. I'm married.

24 Q. Do you have any children?

25 A. Yes, I have two children; a son and a daughter.

Page 6605

1 Q. When did you get your first job and where?

2 A. I got employed in 1972 at Partizanski Put in Belgrade.

3 Q. Until when did you work in the Partizanski Put enterprise in

4 Belgrade?

5 A. Until the end of 1975.

6 Q. And after 1975, where did you work?

7 A. I went back to Foca and worked as a taxi driver for 20 months.

8 Q. You said you worked for 20 months as a taxi driver, and where did

9 you find work after that?

10 A. At that time, the Focatrans company was established as a hauler

11 company, and that's where I started working.

12 Q. Did you leave Focatrans, later, and went to work for another

13 employer?

14 A. I left Focatrans in 1986 and found work in the KP Dom Foca, or

15 rather, the Drina Economic Unit, but it was attached, it was part of the

16 KP Dom.

17 Q. You said you got a job in the Drina Economic Unit. What was that

18 job?

19 A. My position was that of a driver of freight vehicles.

20 Q. Within the Drina Economic Unit, in which segment of this economic

21 unit did you work as a driver of freight vehicles at that time?

22 A. I was a driver in the transport unit of the commercial

23 department.

24 Q. You said you left Focatrans in 1986 to start working in the KP Dom

25 Foca. Why did you leave Focatrans and go to work in the KP Dom?

Page 6606

1 A. The situation was very difficult at that time in that company, in

2 Focatrans. Whereas the Drina Economic Unit was doing good business.

3 Perhaps the best in that area.

4 Q. Thank you. Can you please tell me, in 1992, in which part of Foca

5 did you live?

6 A. I lived in Donje Polje, not far away from my company in Borisa

7 Kidrica street.

8 Q. You said not far away from my company. You meant the KP Dom?

9 A. Yes.

10 Q. Can you tell me, when did you stop going to work; do you remember

11 that?

12 A. On the 8th of April, 1992, I came to work. However, outside the

13 building, there were just a few people who told me that no one is working

14 because there were roadblocks all around.

15 Q. Do you remember what time of day it was? Do you remember what

16 time it was when you came to work on that 8th of April, 1992?

17 A. It was 7.00 in the morning.

18 Q. You said that some people told you no one was working because

19 there were roadblocks around. Did you see any roadblocks yourself when

20 you were coming to work?

21 A. Yes. There was one roadblock. Passage across the bridge opposite

22 the KP Dom was obstructed by a truck. The truck was standing across the

23 road.

24 Q. Where was your family at the time, your wife and children? I mean

25 when you went to work on the 8th of April.

Page 6607

1 A. They stayed at the apartment.

2 Q. Can you tell me what you did next after you had come to the KP Dom

3 and heard from those people that no one was working?

4 A. I went straight back home. I didn't see what else I could do. In

5 fact, I wanted to see what to do next.

6 Q. What did you decide to do with your family?

7 A. My wife was seized by panic. She wanted me to get us out of

8 there, anywhere. I didn't know what to do at that moment and I decided

9 to walk through the town, to pass through on foot. So I set out towards

10 the centre of town and came across a roadblock not far away from my

11 apartment nearby the cafe called Bor. There at the roadblock, I found

12 people almost all of whom I recognised because they were my neighbours.

13 Q. You said you knew them. Can you remember now any of their names,

14 the names of people you saw that day at the roadblock near the Cafe Bor?

15 A. Yes. I remember. There were two brothers, Raho and I forget his

16 brother's name, and the last name was Hazi something. There was Eso

17 Hadzic, who used to be a taxi driver at the same time when I was one, and

18 we were good colleagues.

19 Q. Thank you. Tell me, what happened when you came across that

20 roadblock?

21 A. I asked them if I could pass through. They said, "No problem.

22 Anyone is free to pass through." However, I asked them to let me through

23 in my car and together with my family. I told them that my children were

24 with me. Eso then told me to wait for five or ten minutes while he goes

25 and inquires with someone. So that's what I did. Perhaps ten or 15

Page 6608

1 minutes later, he came back from the cafe, and he said, "You may go

2 through, just hurry it up."

3 Q. Those people who were at the roadblock, who were manning the

4 roadblock, were they armed?

5 A. Yes. All of them had automatic rifles and they were wearing

6 various uniforms; some of them had police uniforms on, others had

7 camouflage military uniforms.

8 Q. You said Mr. Hadzic had told you that you may go through and to

9 hurry up. What did you do next?

10 A. I went back home. I had the same car that I still have. It's a

11 Zastava 128, Skala. I gathered my family, put them in the car and also

12 took a few things, and set out. I had no problem at the roadblock. They

13 let me climb on to the pavement and bypass the truck that was standing

14 there.

15 Q. In which direction did you go?

16 A. I headed for my home village, Kozarevina, which is 17 or 18

17 kilometres away, but in a place called Aladza, after a kilometre or so, I

18 came across another roadblock.

19 Q. Who manned this roadblock in the neighbourhood called Aladza?

20 A. I didn't know those people, except for one maybe.

21 Q. What happened when you came across this roadblock?

22 A. They asked me where I was going. And when I answered, one of them

23 approached me and told me to get out of the car. And then he asked me to

24 open my trunk, which I did. They searched me, they searched the vehicle,

25 they searched my family, and after that, they let me through.

Page 6609

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Page 6610

1 Q. Thank you, sir.

2 A. They were decent.

3 MR. VASIC: [Interpretation] I was just going to say, Your Honours,

4 I think it's 4.00, perhaps this is a good time to adjourn.

5 JUDGE HUNT: I think you're right. We will adjourn now until 9.30

6 in the morning.

7 --- Whereupon the hearing adjourned at

8 4.00 p.m., to be reconvened on Wednesday the 30th

9 day of May, 2001, at 9.30 a.m.

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