1 Wednesday, 5 April 2000

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.31 a.m.

6 JUDGE MUMBA: Would the registrar please call

7 the case.

8 THE REGISTRAR: [Interpretation] Case

9 IT-96-23-T, IT-96-23/1-T, the Prosecutor versus

10 Dragoljub Kunarac, Radomir Kovac, and Zoran Vukovic.

11 JUDGE MUMBA: Good morning, witness. We are

12 continuing our sittings this morning.

13 WITNESS: WITNESS 87 [Resumed]

14 [Witness answered through interpreter]

15 Cross-examined by Ms. Pilipovic:

16 [Interpretation] [Cont'd]

17 Q. Good morning.

18 A. Good morning.

19 Q. Yesterday we left off discussing the night

20 when you were allegedly in the house at Aladza with the

21 presence of Goran and Zaga. Before that evening, did

22 you see Goran at all?

23 A. I don't remember.

24 Q. Do you know his surname?

25 A. No.

1 Q. Do you still stand by the description you

2 gave on the transcript, page 23, tenth line, that he

3 was tall and blond?

4 A. You mean Goran?

5 Q. Yes.

6 A. Yes, I do, as far as I remember.

7 Q. Let us go back to the statement you made?

8 MS. PILIPOVIC: [Interpretation] And I should

9 like to ask the usher to place the statements in front

10 of the witness, please.

11 THE INTERPRETER: Microphone, please.

12 JUDGE MUMBA: Microphone, Counsel.

13 MS. PILIPOVIC: [Interpretation] D32 and D33.

14 Those are the exhibits.

15 Q. Page 4 of the statement, given in 1998, in

16 May, and that is Exhibit D33. Would you take a look at

17 that, please. Could you read the last paragraph on

18 that page.

19 A. "I no longer remember..." Do you mean that

20 paragraph? "I no longer remember whether Zaga raped me

21 on that last time when I was taken to the house in

22 Aladza. I now clearly recall that a man named Goran

23 raped me on that occasion. There were more soldiers in

24 the house this time than usual. They were drinking in

25 the kitchen. Zaga was not present all the time. He

1 kept going in and out."

2 Q. Thank you. Is that your statement?

3 A. Yes, it is.

4 Q. Thank you. You said that on that particular

5 evening, and we agreed that it was around 8.00, that

6 DB, 75, and 50 were with you on that occasion, and you

7 said that you were in the room on the left-hand side of

8 that house. Do you know where number 75 was and with

9 whom?

10 A. No, I don't know.

11 Q. Do you know who DB was with?

12 A. No.

13 Q. Did you talk to DB and number 75 about that

14 particular night, what had happened to them and whether

15 anything happened to them?

16 A. No.

17 Q. Did you tell them what happened to you?

18 A. No.

19 Q. You said that afterwards you were in the

20 right-hand room.

21 A. Yes.

22 Q. Who were you with there?

23 A. With Kunarac. Once with Kunarac and once

24 with an older man whose name I don't know.

25 Q. And who were you with in the workshop?

1 A. I think it was Toljic. Toljic.

2 Q. When did you leave the house at Aladza?

3 A. I think it was the next morning.

4 Q. When you say "morning," what time do you

5 mean?

6 A. Well, I mean that it was before noon, at all

7 events.

8 Q. Who did you leave with?

9 A. I left with number 75 and DB and 190, and I

10 remember -- I don't remember who else was with us very

11 well, but I do remember Pero Elez. I remember he was

12 with us, but I don't remember the others.

13 Q. Do you remember who drove the car?

14 A. No.

15 Q. Do you remember what the car looked like?

16 A. No.

17 Q. I'm now going to go back to your statement,

18 D32, page 11, the second paragraph from the top, and it

19 begins with "That happened ..."

20 A. This was about the 20th of August, 1992.

21 That night there was an electricity cut. There were

22 detonations and the windows broke in the house.

23 Everybody went for shelter under the tables. This was

24 in the night, after 9.00 and before midnight. It was

25 too dark for me to see anything. I heard that all the

1 mosques in Foca had been destroyed on that occasion."

2 Q. Are you sure that that was the 20th of

3 August?

4 A. No, I'm not.

5 Q. When did you hear that the mosques had been

6 destroyed?

7 A. How do you mean when did I hear?

8 Q. When did you hear -- you said, "I heard that

9 all the mosques -- I have heard that every mosque in

10 Foca was destroyed."

11 A. I don't remember now whether it was that

12 night or some other time.

13 Q. If I say that it was the 2nd of August, would

14 you agree? Because that was when the Aladza mosque was

15 destroyed.

16 A. I couldn't really say. I don't remember any

17 more.

18 Q. You said that you were raped by several

19 soldiers.

20 A. Yes.

21 Q. Were you injured in any way?

22 A. What injuries do you mean? What kind?

23 Q. Physical.

24 A. No.

25 Q. Were you in pain?

1 A. I don't remember.

2 Q. You've said that you were raped in the house

3 at the bus-stop yesterday.

4 A. Yes.

5 Q. Can you describe where that house was?

6 A. I really couldn't say. I was taken to that

7 house only once, and I can't remember any more where it

8 was.

9 Q. How did you get to the house? How did you

10 get to the house?

11 A. Unfortunately, I can't remember that either.

12 Q. And who took you there?

13 A. I think it was Kunarac.

14 Q. Who was with you?

15 A. Apart from Kunarac, I don't remember the

16 other people, but I think there were two more men,

17 although I'm not quite sure, and of the girls there was

18 DB, number 50.

19 Q. If you went by car, what kind of car did you

20 go there in; and if you went on foot, tell us that.

21 A. I don't remember the car we were taken in.

22 Q. The two men who were with Kunarac, what did

23 they look like? Could you describe them?

24 A. No. I can't remember.

25 Q. What about their age? How old were they?

1 A. I can't be certain of that either.

2 Q. How were they dressed?

3 A. I don't remember that either.

4 Q. Did you do anything in that house?

5 A. I don't remember.

6 Q. On that occasion, DB and number 50, were they

7 with you all the time?

8 A. How do you mean with me?

9 Q. In that house, were all three of you there

10 all the time together?

11 A. Yes, I think we were.

12 Q. How long did you spend in that house?

13 A. Well, I couldn't say. I think we came back

14 that same night, but I'm not quite sure.

15 Q. Was Kunarac in the house with you all the

16 time and with those two soldiers?

17 A. Yes.

18 Q. What happened to you that night?

19 A. What do you mean? How do you mean?

20 Q. In the house. You were there with the three

21 of them. Did anything happen to you?

22 A. Yes. I know that I was raped by Kunarac. I

23 also know that number 50 was raped by Kunarac as well.

24 I don't know about DB.

25 Q. As you stated that you came to Partizan

1 sometime around the 16th or 17th, and you said that you

2 left Partizan from Aladza on the 3rd of August in the

3 morning, when was that in respect to that period? Were

4 you in the house during that period at that time or

5 later on?

6 A. You mean the house at the bus-stop. I was

7 there before I was in the house at Aladza.

8 Q. I now have to remark that in the statements

9 you gave in 1996 and 1998, which are Exhibits D32 and

10 D33, you never recount that particular event.

11 A. Which event do you mean?

12 Q. The event in the house by the bus-stop.

13 A. I think that I did mention that in the

14 statement I gave in 1999 -- 1998. I beg your pardon.

15 Yes. The last paragraph on page 6.

16 Q. I've found page 6.

17 A. Yes. It's the last paragraph on the page.

18 Q. Could you read it out to me, please?

19 A. "Kunarac and his soldiers took me to another

20 house, not just the one in Aladza. This was an older

21 house, or maybe it was just built in the old style,

22 near the bus station and it was a bit remote. Kunarac

23 himself took me there. I cannot say if this house

24 belonged to a Muslim or not. I was taken to this house

25 only once."

1 Q. You described the house here.

2 A. Yes.

3 Q. You said that it was an old-style house.

4 A. Yes. I think that's the impression I got.

5 Q. But you didn't say who you were there with.

6 A. No.

7 Q. So you said that you stayed in that house

8 until what time?

9 A. Well, I don't know exactly what time. I

10 think we were returned the same night.

11 Q. When you gave this statement in 1998, did you

12 know that Kunarac was already at the detention unit,

13 the UN detention unit?

14 A. I don't remember that.

15 Q. Did anybody tell you that?

16 A. Tell me what?

17 Q. That he was in detention, or did you learn

18 that through the media?

19 A. I learnt this through the media.

20 Q. When did you learn about this?

21 A. Well, I don't remember that.

22 Q. Could that have been March 1998?

23 A. I really don't know.

24 Q. Did you see it on television?

25 A. I don't remember. I think it was on

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1 television, yes.

2 Q. When you went to Karaman's House, who took

3 you there?

4 A. I remember Pero Elez, although he wasn't

5 alone, but I don't remember the other people with him.

6 Q. I would like to point out once again that

7 yesterday in the transcript, page 131, line 22, you

8 said, "I don't remember many things any more."

9 A. Yes. That's right.

10 Q. Is that your testimony?

11 A. Well, I don't know exactly where that was, to

12 begin with, but it's true that I don't remember many

13 things because eight years have gone by since then.

14 Q. Who was with you when you went off to

15 Karaman's House? Of the women, I mean.

16 A. Number 75 was with me, DB, and 190.

17 Q. You said that you were taken by Pero Elez.

18 A. Yes.

19 Q. Who was with him of the men?

20 A. I think there were two other men, but I don't

21 remember that very well, who they were, their names.

22 Q. According to your 1996 statement, and it is

23 D32, you did not state that Kunarac was with you in

24 Karaman's House.

25 A. Well, perhaps not.

1 Q. In the statement of 1998, you further stated

2 that he raped you in that house.

3 A. Yes.

4 Q. Could you tell me when that occurred?

5 A. What do you mean?

6 Q. After you arrived at Karaman's House.

7 A. I couldn't say. I don't remember exactly.

8 Q. Who was in the house when he came?

9 A. I know that we were there, us girls. Which

10 one of the soldiers was there, I don't remember.

11 Q. Was your sister there?

12 A. Yes, she was.

13 Q. You said that Kunarac took you into a room.

14 A. Yes.

15 Q. Into which room?

16 A. The room on the storey above.

17 Q. And how many rooms were on that floor?

18 A. I think there were two smaller ones and one

19 larger one which wasn't cleaned up.

20 Q. Did you talk to your sister about that

21 event?

22 A. No.

23 Q. How long did you stay in that room with

24 Kunarac?

25 A. Well, I can't remember.

1 Q. How was Kunarac dressed?

2 A. I don't remember.

3 Q. You said that you were raped on that

4 occasion.

5 A. Yes.

6 Q. In your statement, you say that the arm was

7 in a plaster cast.

8 A. I don't think I said his arm was in a plaster

9 cast, I just said that I remember that part of his

10 body, something was in a cast. I remember that.

11 Q. Did he take his clothes off on the occasion?

12 A. Well, I don't remember, but he must have.

13 Q. I'm now going to remind you that in your

14 statement of 1996 you said, on page 9, the following.

15 It is the last paragraph, the one-but-last paragraph,

16 and you're describing events, and then you state: "In

17 that house..." It is the last paragraph.

18 A. "In that house I never saw members of Cosa's

19 Guards. Kunarac never took me to any other house

20 except this one. The first two times he did not rape

21 me. He only raped me the third time.

22 Q. Could you explain the difference in your

23 statements? In 1996 you said that you were only taken

24 to the house in Aladza, not another house, and then

25 later on you explained that you were taken to this

1 house by the bus stop.

2 A. Well, I think the simple reason is that I

3 couldn't remember everything the first time. I think

4 that's the only reason.

5 Q. I should like to refer you to your 1998

6 statement once again, and page 4 of that statement. It

7 is the first paragraph.

8 A. "I no longer remember whether Zaga raped me

9 that last time when I was taken to the house in

10 Aladza. Now I clearly remember that a man raped me by

11 the name of Goran.

12 Q. Thank you. How can you explain these

13 differences in your statement?

14 A. What do you mean?

15 Q. Well, you said that in 1996 you remembered

16 things better but that you did not remember this other

17 house except the house in Aladza.

18 A. Yes, that's correct, but I probably recalled

19 that later on.

20 Q. You said that in Karaman's House you were

21 there with your sister.

22 A. Yes.

23 Q. After Kunarac left the room, did you talk to

24 your sister at all?

25 A. No.

1 Q. Did Kunarac talk to your sister on that

2 occasion?

3 A. I don't remember.

4 Q. Let me remind you. Was he out on the terrace

5 with her, talking to her?

6 A. I don't remember.

7 Q. Was that during the night or during the day?

8 A. Well, I don't remember, but I don't think it

9 was night-time, although I can't be certain.

10 Q. How was Kunarac dressed on the occasion?

11 A. I don't remember.

12 Q. Did he have any characteristic features on

13 him?

14 A. Well, the only characteristic thing was that

15 he had a plastic cast or a bandage on a part of his

16 body; that's all.

17 Q. During your stay in the Aladza house, were DB

18 and number 75 there all the time?

19 A. You mean in the house?

20 Q. Yes.

21 A. Well, I don't know.

22 Q. Were DB and number 75 able to see Kunarac on

23 that night?

24 A. I don't know.

25 Q. You said that you came there together with

1 them.

2 A. Yes.

3 Q. Was Kunarac in the house the whole time while

4 you were there?

5 A. I don't remember.

6 Q. After that night, did you go to Miljevina?

7 A. I think it was the next morning.

8 Q. Will you agree with me, in view of the fact

9 that you came to the house -- that you came to Partizan

10 at about the 16th, 17th, that you went to Miljevina on

11 the 3rd, and that you spent 15 days in Partizan?

12 A. Well, according to the dates that you have

13 just stated, yes, but I don't remember the exact dates

14 very well, and I can't assess time very well. I don't

15 know how much time actually passed.

16 Q. Does the name -- nickname Konta mean anything

17 to you? The surname is Kontic, the nickname is Konta.

18 A. No.

19 Q. Did you talk to any of your colleagues about

20 that individual?

21 A. No.

22 Q. Does the surname Radovic mean anything to

23 you?

24 A. No.

25 Q. Does the surname Dragan Stankovic, Dragec,

1 mean anything to you?

2 A. Well, the name and surname, no, it doesn't,

3 but the nickname does, yes.

4 Q. Did he ever take you out of the house?

5 A. I don't remember that. I think that he used

6 to come to Klanfa's apartment, but I don't remember if

7 he actually took me out or not.

8 Q. I just have one more event to go through with

9 you at Partizan. You said that while you were at

10 Partizan that there was a woman journalist who came

11 there.

12 A. Yes.

13 Q. Did you talk to her?

14 A. No.

15 Q. Did your sister talk to her?

16 A. I don't know that.

17 Q. May I refer you to page 10 of your statement

18 of 1996. It is the fifth paragraph, which begins "I

19 remember ..."

20 A. Yes, I found it. "I remember that Dragan

21 Kunarac one day brought a woman journalist to

22 Partizan. She wanted to talk to the girls about

23 whether or not we were being abused. We all knew that

24 she was not a real reporter but was one of them. I

25 said that we were not being abused. Kunarac was

1 standing right beside her. How could I say anything?"

2 Q. Thank you. I'd now like you to go back to

3 page 4 of the 1998 statement of the 4th and 5th of

4 May.

5 A. Yes, I found it.

6 Q. And it begins with -- the paragraph is

7 paragraph 6, and it begins --

8 A. "A female journalist came to Partizan, which I

9 described on page 11 of my earlier statement. I do not

10 remember when this was. I don't know if it was close

11 in time to when I was taken to Miljevina. I did not

12 talk to the journalist. I know that my sister spoke to

13 the journalist. I'm not sure if number 75 spoke with

14 the journalist. Kunarac was not present when the

15 journalist was questioning the women. I remember my

16 sister telling the journalist that Kunarac used to come

17 and take us out to various flats."

18 Q. Thank you. Now you yourself have seen that

19 those two statements are quite different.

20 A. Well, not quite different, but there are

21 things which do not correspond to both. Today I cannot

22 remember. I do remember the journalist, the woman

23 journalist; I remember her coming. I know that

24 somebody talked to her, although I don't remember

25 talking to her myself. And I don't remember whether

1 Kunarac was actually there or not, and I'm not sure

2 whether my sister talked to her or not, to the

3 journalist. Yes, that's it.

4 Q. You say that Kunarac was present --

5 A. Today, I cannot remember if he was present or

6 not.

7 Q. Do you remember that he used to come to the

8 school at Partizan and that he called out several girls

9 and told them to go with him?

10 A. I remember that Kunarac would come to

11 Partizan and take out girls with him, but today I just

12 cannot remember a concrete occasion and the details,

13 whether he called the girls out by name and then took

14 them out or not.

15 Q. Do you happen to remember whether Kunarac

16 told you that you were going to talk to a journalist?

17 A. I don't remember that.

18 Q. Did you talk about this event with your

19 sister and with number 75?

20 A. No.

21 Q. And I just want to ask you several questions

22 in connection with the house by the bus stop. In

23 relation to Partizan, where was the bus stop located?

24 A. Well, I don't think I could explain that. It

25 wasn't very far away; that's what I can say.

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1 Q. How did you get to that house?

2 A. I don't remember.

3 Q. Did you go by car, perhaps?

4 A. Perhaps, although I'm not sure.

5 Q. You said that Kunarac raped you in that

6 house.

7 A. Yes.

8 Q. Could you explain where this happened, in

9 which room?

10 A. I think it was a room on the first floor,

11 because I remember that I was raped on the upper floor

12 and that I was with Kunarac on the first floor.

13 Q. In order to identify this more closely, do

14 you think you could make a sketch of that house?

15 A. Well, I don't know. I'm not sure. Perhaps I

16 could just tell you where the rooms were on the first

17 floor. I can't remember the second floor that well.

18 Q. Could you make a sketch of the rooms in the

19 house?

20 JUDGE MUMBA: Can the usher please help.

21 A. [The witness complies]

22 THE REGISTRAR: [Interpretation] This document

23 will be marked D35, Defence Exhibit D35.

24 MS. PILIPOVIC: [Interpretation] Could this be

25 tendered into evidence as a Defence Exhibit, please?

1 THE REGISTRAR: [Interpretation] Yes, it is,

2 but I was wondering if you need it for your

3 cross-examination.

4 MS. PILIPOVIC: [Interpretation] Not for the

5 moment. Thank you. As far as I understand, the

6 witness said that this was the room upstairs in this

7 house.

8 A. The room in which Kunarac raped me. Yes,

9 that was a room on the first floor.

10 MS. PILIPOVIC: [Interpretation]

11 Q. I see here there are three rooms. Could you

12 tell us which of these three rooms?

13 A. On the first floor there was a kitchen room

14 and bathroom. On the second floor I think there were

15 two rooms but I'm not sure. And this happened in the

16 room on the first floor.

17 Q. What did the room look like?

18 A. I can't remember that.

19 Q. Were there any things inside?

20 A. Yes. It wasn't empty.

21 Q. Did you talk to other soldiers who were in

22 that house with you at the time?

23 A. No.

24 Q. Did they have conversations among

25 themselves?

1 A. I don't remember.

2 Q. Do you remember any one of them by his

3 nickname or anything particular?

4 A. No.

5 Q. How were they dressed?

6 A. I don't know.

7 Q. Could you please make a sketch of the house

8 in Miljevina as well?

9 A. You mean the layout of the rooms?

10 Q. Yes.

11 A. [The witness complies]

12 THE REGISTRAR: [Interpretation] This second

13 drawing will be marked D36, Defence Exhibit D36.

14 MS. PILIPOVIC: [Interpretation]

15 Q. You said that there were three rooms on the

16 top floor.

17 A. Yes.

18 Q. In which room were you with Kunarac out of

19 these three?

20 A. The one straight ahead when you go up the

21 stairs.

22 Q. As far as I can see, this is the room that is

23 separated from the other two.

24 A. When you go up the stairs, there are two

25 rooms on this side and one this side. So it was this

1 room.

2 Q. That was what I was saying. As for the house

3 near the bus-stop, was 75 in that house with you?

4 A. No.

5 Q. But you told me that 75 and DB were with

6 you.

7 A. No. Fifty and DB.

8 Q. Did you discuss with them who the owner of

9 the house was?

10 A. No.

11 Q. Did anyone perhaps tell you that it was

12 Dr. Reuf Tafro's house?

13 A. No.

14 Q. Did you go to that house previously, before

15 the event that you have described?

16 A. No.

17 Q. Did Tuta take you to that house perhaps?

18 A. No.

19 Q. Did Radulovic take you to that house,

20 perhaps?

21 A. I don't remember Radulovic.

22 MS. PILIPOVIC: [Interpretation] I have no

23 more questions, Your Honour. Thank you.

24 JUDGE MUMBA: The next counsel, if any.

25 Yes, Mr. Kolesar.

1 MR. KOLESAR: [Interpretation] Yes, Your

2 Honour. I have a couple of questions for this

3 witness.

4 JUDGE MUMBA: Yes. Please go ahead.

5 Cross-examined by Mr. Kolesar:

6 Q. Witness, good morning.

7 A. Good morning.

8 Q. Could you tell me, before we start our

9 conversation, and I will have questions only about

10 events linked to the apartment in Lepa Brena used by

11 Kovac, could you tell me, please, during those critical

12 days in 1992, apart from the fact that you were much

13 younger, could you tell me, so that I can have some

14 idea as to your appearance, how tall you were in those

15 days? I don't know if you can understand my question.

16 A. No.

17 Q. Do you remember, October 1992, how tall you

18 were? Could you describe yourself?

19 A. I don't remember exactly how tall I was.

20 Q. Do you remember how much you weighed?

21 A. No.

22 Q. Do you remember what kind of hairstyle you

23 wore, the colour of your hair, the length of your

24 hair?

25 A. My hair was straight. It was roughly

1 shoulder length.

2 Q. And the colour of your hair?

3 A. Dark brown.

4 Q. Did you wear glasses then too?

5 A. No.

6 Q. Thank you. In your statement to the

7 investigators of the Tribunal, the first statement from

8 January 1996, on page 13 -- could you please find page

9 13? You said that in mid-October, the four of you, and

10 you listed the four, were taken from Karaman's House by

11 Gojko, Tuta, and Zeljo to Foca, to an apartment where

12 you spent the night, and in the morning, two soldiers

13 came, Kovac and Kostic, who took you to another

14 apartment on the fourth floor.

15 If you have found that paragraph, would you

16 confirm that that is correct?

17 A. Yes.

18 Q. During the examination-in-chief by the

19 Prosecution, you said that this happened at the end of

20 September or the beginning of October of the same

21 year.

22 A. Yes, though I'm not sure about dates.

23 Q. Do I understand you correctly that you're not

24 sure whether what you said in the statement is correct

25 or what you said in your testimony yesterday?

1 A. No. I mean, I'm not sure about the date.

2 Q. But could you please make a choice between

3 the two dates?

4 A. No, I cannot.

5 Q. You said you were taken to an apartment on

6 the 4th floor. Do you stand by that statement?

7 A. Yes.

8 Q. Could it have been a higher floor, perhaps?

9 A. I think it was the 4th floor.

10 Q. That day when Kovac and Kostic came for you,

11 to take you, as you said, could you describe how they

12 were dressed?

13 A. I cannot be sure about that. I think they

14 wore camouflage uniforms.

15 Q. You said that you spent roughly four months

16 in that apartment.

17 A. Yes. I said "roughly." I'm not sure about

18 that.

19 Q. During that time, during your stay in that

20 apartment, did Kostic and Kovac -- and I'm particularly

21 interested in Kovac -- were they in uniform all the

22 time or did they sometimes wear civilian clothes? And

23 I'm interested in Kovac.

24 A. I'm afraid I can't remember that too well,

25 though I know that when they took us out, they would

1 sometimes wear civilian clothes.

2 Q. Thank you. Now, please tell me, if you can,

3 where were you handed over to Kovac and Kostic, as you

4 told us? In what room and at what spot?

5 A. What do you mean, "handed over"?

6 Q. In your statement you said that the next day,

7 in the morning, two soldiers came, Kostic and Kovac,

8 and that you were handed over to them. I would like

9 you to tell me where this occurred.

10 A. Kovac and Kostic came in the apartment in

11 Ribarsko, and then we went with them, or rather they

12 took us to an apartment.

13 Q. If I understand you correctly, this is the

14 apartment where you had spent the night, the previous

15 night.

16 A. Yes.

17 Q. Before they took you from Karaman's House,

18 did they tell you why they were taking you from

19 Karaman's House to Foca, any one of the three who took

20 you to Foca?

21 A. No.

22 Q. When Kovac and Kostic took you over, did they

23 tell you why they were taking you with them?

24 A. No.

25 Q. Let me remind you that perhaps Kovac told you

1 that he was taking you to their apartment because it

2 would be better there, that they would protect you

3 there, they would not allow any men to come, and that

4 they would look after you.

5 A. I don't remember.

6 Q. And that you would be staying there until

7 conditions were such as to enable you to leave Foca.

8 A. I don't remember that.

9 Q. From the apartment where you spent the night,

10 to the apartment where you were taken -- and that is

11 the apartment, as you say, on the 4th floor -- how did

12 you cover that distance?

13 A. Which apartment are you referring to? I'm

14 referring to the apartment in Lepa Brena used by

15 Kovac.

16 Q. I'm asking you about the other apartment that

17 you mentioned. You said that you spent the night in an

18 apartment in Ribarsko, and that the next day Kovac and

19 Kostic came and took you to an apartment being used by

20 Kovac. So I'm asking you: How did you cover the

21 distance from the first apartment to the apartment

22 where the two of them lived? Was it on foot?

23 A. I think it was on foot.

24 Q. As you were going along the way, were you

25 mistreated, sworn at, physically abused by the two of

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1 them, or did you walk normally?

2 A. On that occasion there was no abuse of any

3 kind.

4 Q. En route from the first apartment to the

5 apartment being used by Kovac and Kostic, did you visit

6 any of the stores along the way, or did one of the two

7 of them go in?

8 A. I cannot remember.

9 MR. KOLESAR: [Interpretation] Could the usher

10 give the witness photographs 407 and 401, Prosecutor's

11 Exhibit number 11, if I remember correctly.

12 JUDGE MUMBA: Confirmation from the

13 Prosecution? Is that the exhibit? The numbers of

14 photographs, is that Exhibit number 11?

15 MS. KUO: Since we haven't seen them, we

16 don't know if they actually correspond.

17 JUDGE MUMBA: Yes. Please, usher, could you

18 show counsel?

19 MS. KUO: Yes, we can confirm that, Your

20 Honour.

21 MR. KOLESAR: [Interpretation] I apologise.

22 Those are not the photographs I wanted. I mentioned

23 the numbers 407 and 401. Yes, yes, that's it.

24 Q. Can you agree with me that that is the

25 photograph shown to you by the Prosecution yesterday,

1 and that on that occasion you confirmed that that was

2 the Lepa Brena building but that you were not sure

3 whether the photograph in which you stayed is shown on

4 the photograph?

5 A. Yes. I said that that was the Lepa Brena

6 building, but I wasn't sure whether that was the exact

7 entrance to the part of the building in which Kovac's

8 flat was.

9 Q. So I understood you correctly. Look at the

10 ground floor, please. There is a wooden door there,

11 and to the right, if you can manage to read the

12 letters, it says: a supermarket.

13 A. I'm afraid I'm unable to see that on the

14 photograph.

15 Q. Regardless of that, in view of the fact that

16 there is a store there, could you tell us where the

17 entrance leading to the apartment used by Kovac was,

18 and in which you stayed, would be in relation to this

19 photograph?

20 A. I cannot be sure. I think it could be to the

21 left, that you would go to the left to find the

22 entrance leading to Klanfa's apartment.

23 Q. So if this is the building, the entrance to

24 Klanfa's apartment would be here to the left?

25 A. Yes, only I must repeat: I'm not sure.

1 Q. Thank you. Do you remember that at the

2 entrance leading to the apartment that there was a

3 lift, an elevator?

4 A. I don't remember that

5 MR. KOLESAR: [Interpretation] I should like

6 to thank the usher. We are done with this photograph

7 for the moment. We don't need it anymore.

8 Q. Could you please tell me what kind of an

9 apartment it was? Was it a one-room, two-room,

10 three-room apartment?

11 A. It had a kitchen and two rooms. A kitchen,

12 two rooms, a bathroom, and a hallway. The rooms were

13 not big.

14 Q. Could you please draw a sketch of that

15 apartment for me?

16 A. [Witness complies]

17 THE REGISTRAR: [Interpretation] This document

18 will be marked Defence Exhibit D37.

19 MR. KOLESAR: [Interpretation]

20 Q. I apologise, but on this sketch there is a

21 space here that I don't understand. Is that the

22 hallway which makes a letter L or L-shaped or ...

23 A. I don't understand what you mean. No. The

24 line in the middle is a mistake. It shouldn't be

25 there.

1 Q. All right. Thank you. Yes. This

2 corresponds to the layout I have of the flat.

3 From this sketch, I can see that there is a

4 terrace or balcony that leads out from the kitchen. Is

5 that right?

6 A. Yes.

7 Q. Could you tell me, please, the window from

8 this large room and the terrace, where do they look out

9 onto?

10 A. They look out onto the street.

11 Q. And the window from this other room?

12 A. I'm not quite sure about that.

13 Q. Could you describe, as you spent some four

14 and a half months in that apartment, tell me about the

15 furnishings, where the furniture was in the flat.

16 Describe that to me, please.

17 A. Well, as far as the kitchen is concerned, I

18 don't remember it very well. I don't remember the

19 kitchen very well, but I think there was what we would

20 say a two-seat sofa -- I can't be sure -- and that

21 there were some other things belonging to kitchens,

22 which you would find in a kitchen.

23 As far as the small room is concerned, I

24 remember that there were two small beds and that it

25 might have been a bunk-bed which had been separated

1 into two beds, but I remember that there was a big sort

2 of cupboard-cum-display cabinet, and that there was a

3 desk there, a writing table.

4 As far as the main room is concerned, there

5 was a corner sofa. I think there was a round glass

6 table in front of it. There was a bed. I don't think

7 it was a display cabinet. It was low, sort of coming

8 up to half the wall. A little sort of sideboard,

9 something like that.

10 Q. Can we say a commode, a chest?

11 A. Yes.

12 Q. When you describe the table, you said a

13 small, low, glass-top table, did you not?

14 A. Yes, I think it was round and I think it had

15 glass. Whether it was actually small and low, how

16 small and how low, I don't really know.

17 Q. And the bathroom? That's all that remains,

18 the bathroom.

19 A. I remember that there was, of course, a

20 bathtub and a toilet seat. I think there was something

21 else there. I think a washing machine, but I'm not

22 quite sure. And I don't remember ...

23 Q. Thank you.

24 MR. KOLESAR: [Interpretation] I should like

25 to tender this into evidence as a Defence Exhibit.

1 Q. Tell me, please, In one of these rooms was

2 there a television set and a video?

3 A. I think there was in the big room.

4 Q. Both a television set and a video?

5 A. I think so, yes.

6 Q. Did you watch a television programme, of

7 course when there was any electricity?

8 A. Yes, I do remember that we watched television

9 sometimes.

10 Q. Did you watch television together with the

11 accused Kovac and Kostic?

12 A. Yes.

13 Q. You have described the layout of the

14 apartment very well. Can you tell me the following

15 now, please: When you arrived in the apartment, the

16 four of you came, the four of you girls and two of

17 them. Who slept where? Could you tell us that,

18 please?

19 A. I don't remember.

20 Q. When you arrived in the apartment, what did

21 you girls bring with you in the way of clothing?

22 A. I don't remember. I couldn't say whether we

23 brought anything with us or not.

24 Q. Was there any clothing in the apartment, any

25 clothes that you could wear, perhaps, in view of your

1 size and age, and if so, were you given these clothes

2 to wear? Were you told that you could wear the

3 clothes?

4 A. I think that there was some clothing, yes,

5 which we could use.

6 Q. And were you allowed to use the clothes?

7 A. Yes.

8 Q. You said, if I heard you properly, that there

9 was a washing machine in the bathroom. Was there?

10 A. Yes, although I'm not quite sure about that.

11 Q. Did you do any washing in any way, your

12 clothes, or were you able to use it?

13 A. Yes, but I would usually wash my things by

14 hand in the bathtub.

15 Q. Why, if it's easier in a washing machine?

16 A. Well, I can't answer that question. I don't

17 know.

18 Q. Was the bathroom available to you girls?

19 Could you use it in the way that bathrooms are used for

20 fully, as bathrooms are intended to be used?

21 A. Yes.

22 Q. In the apartment, did you have all the

23 necessary amenities in the way of personal hygiene and

24 were you able to use these toiletries and things for

25 hygiene?

1 A. I don't remember.

2 Q. Well, was there any soap, washing powder, you

3 know, the basics, the basics to keep clean?

4 A. Well, I think there were some of these

5 things, but how much, I don't remember.

6 Q. Well, it was wartime. I'm sure that there

7 wasn't a profusion of these items, that's for certain,

8 if you will agree.

9 A. Yes.

10 Q. Were you allowed to prepare any food, any

11 meals in the kitchen, and did you have the necessary

12 foodstuffs to prepare meals?

13 A. Yes. When there was food, we were allowed to

14 prepare it.

15 Q. So when there was food and when you did the

16 cooking, did you cook only for yourselves or for the

17 two of them as well?

18 A. For all of us; them as well.

19 Q. When they were in the apartment, when they're

20 not out on an assignment or anywhere else, when you

21 were having your meals, did you all eat at the same

22 table and eat the same food that you said you prepared

23 both for them and for you?

24 A. I don't remember.

25 Q. Well, I have to take note of the fact, once

1 again, that you said you spent about four months in

2 that apartment. Can you then tell me how long the

3 other girls spent in that apartment?

4 A. Two of the girls, I can't be sure exactly

5 when, but a short while after we arrived in Klanfa's

6 apartment, they were taken away. So only myself and AS

7 remained in the apartment. Us two were there together

8 throughout that time in the apartment.

9 Q. During the absence of Kovac, what about the

10 entrance door to the apartment? Was the door locked

11 and did you have keys to be able to lock the door from

12 the inside?

13 A. No, they weren't locked, and we didn't have

14 the key.

15 Q. Let me ask you directly: Did any of the

16 girls go to the neighbours' to borrow some of the

17 necessary foodstuffs, or coffee, sugar, things like

18 that?

19 A. I don't remember.

20 Q. Do you remember that you would go to one of

21 the neighbours, one of the women, to make some coffee

22 when you didn't have any electricity, because she

23 happened to have a wood-fired stove?

24 A. No, I don't remember that.

25 Q. Do you remember that in the same entrance to

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1 the same building, just two floors below, there was a

2 close relative of Kovac's?

3 A. Yes, I think there was.

4 Q. Would she come and visit you, and would you

5 go and visit her in her apartment?

6 A. I don't think she came to visit us, but I

7 think that we went to visit her once, together with

8 Kovac and Kostic.

9 Q. Did she ever get you some foodstuffs from

10 time to time?

11 A. I don't remember.

12 Q. Let me try and remind you: with a basket and

13 a rope. Do you remember that?

14 A. Yes, I do.

15 Q. Well, tell me, please: How did that

16 function?

17 A. Well, I don't remember exactly how this came

18 about the first time and what we did or how we arrived

19 at that, but I think we saw her from the window, or

20 from the terrace, from the balcony. I don't remember

21 exactly, but I know that we were either hungry or

22 something like that, and she talked to us, and she

23 asked us whether we wanted her to help us. I don't

24 remember exactly how we came upon the idea of having a

25 rope, but I remember that she did give us food on that

1 occasion.

2 Q. Was it only once or was it several times?

3 A. I don't remember exactly, but quite possibly

4 it was several times, yes.

5 Q. Did Kovac's mother come to the apartment on

6 occasion and bring you food?

7 A. I don't remember.

8 Q. I'll go back to that question later on, when

9 I link it up to an event that I'm sure you'll remember

10 took place.

11 On the basis of what you have told me so far,

12 can you tell me, in view of everything, of the

13 foregoing -- and I'm sure that you didn't have a good

14 time, that it wasn't good for you anywhere during that

15 period -- but while you were in Kovac's flat, could you

16 tell me whether it was easier and better for you than

17 in the secondary school centre and in Partizan and in

18 Karaman's House?

19 A. Well, as far as all these other places are

20 concerned, there wasn't any difference, because I was

21 raped at all these places, and even at Kovac's

22 apartment, by Kovac himself and by Kostic. So that for

23 me personally, I can make no distinction between those

24 places; there's no difference.

25 Q. In the 40 days that you spent in the

1 apartment, approximately, can you tell me how many

2 times Kovac spent the night in the apartment?

3 A. Well, I couldn't say. I know that at times,

4 because he had to go to the front line, he would be

5 away for a couple of days, but I can't say exactly.

6 Q. Was he absent only to go to the front line,

7 or did he -- was he absent, was he away on two

8 occasions because of other reasons?

9 A. I don't know.

10 Q. And now this brings me to what you mentioned

11 a moment ago and what you recounted earlier on, and

12 that is the following: During Kovac's stay in the

13 apartment, when he was not up at the line, as you say

14 yourself, you told us that you were taken out, you were

15 taken into town. Did I understand you correctly?

16 A. Could you repeat that question, please?

17 Q. Yes, I'll be glad to. When they were not at

18 the front line, or on another assignment, you yourself

19 said that they would -- perhaps ten minutes ago you

20 said this -- that they took you into town. Did I

21 understand you to say that? Is that correct?

22 A. Yes, it is.

23 Q. And what did these outings into town look

24 like? Where did you go? Where were you taken?

25 A. Well, we would be taken to cafes or pubs.

1 Q. Do you remember the names of any of these

2 coffee bars?

3 A. No, I don't remember any of their names.

4 Q. Does the Linea Cafe ring a bell?

5 A. Well, although it does ring a bell, I can't

6 be quite sure.

7 Q. What about Leonardo?

8 A. No.

9 Q. Han?

10 A. What did you say, I'm sorry?

11 Q. Han. I said Han.

12 A. No, that doesn't either.

13 Q. I see. Tell me how often this was.

14 A. I can't be quite sure, once again, but I

15 think this happened about five times, approximately

16 five times.

17 Q. In addition to the fact that you were taken

18 to these cafes and pubs, whose names you don't

19 remember, did you perhaps go visiting with Kovac to his

20 friends' and acquaintances'?

21 A. I don't remember.

22 Q. You don't remember a family named Jojic?

23 A. No.

24 Q. Tell me, please: What was their -- that is

25 to say, when you went into town, what was their

1 attitude towards you, in comparison to, let's say, the

2 other soldiers that were sitting around and the

3 civilians sitting around? Were there ever any

4 incidents or attempts -- that is to say, would they

5 protect you in any way if there was an incident of any

6 kind in these places?

7 A. I don't remember.

8 Q. Yesterday, when you were questioned by the

9 Prosecution, you mentioned that Kovac had been

10 wounded.

11 A. Yes.

12 Q. Do you remember when this occurred?

13 A. No.

14 Q. Do you remember that he had to go to hospital

15 as a result of that wounding?

16 A. I think that is true, yes, that he spent

17 several days in hospital.

18 Q. You said, but let us confirm this -- where

19 was the wound? Where was he wounded? Do you remember?

20 A. I don't remember exactly, but I know that it

21 was the leg, I think, or his ankle, that area. I don't

22 remember which leg it was.

23 Q. When he left hospital, did he have to use a

24 crutch to help him walk?

25 A. I don't remember. I think he did, yes.

1 Q. Do you remember an incident which occurred in

2 the apartment on Christmas Eve, that is, the Christmas

3 Eve of the orthodox Christmas? Do you remember that

4 something happened then?

5 A. Well, I don't know. I can't answer that.

6 Q. I'm asking you about the arrival of a certain

7 Ratko, or Rajko Cicmil, who banged on the door and

8 tried to barge in when only you girls happened to be in

9 the apartment.

10 A. I don't remember that.

11 Q. You don't remember that one of you, maybe it

12 was AS, that she called Kovac's relative who lived two

13 floors below to come and help you out? And don't you

14 remember that he came very soon after that and disarmed

15 this drunken soldier?

16 A. No.

17 Q. Were there any incidents, alarming incidents

18 of this kind, when he was not in the apartment? And

19 I'm thinking about attempts made by some men to storm

20 the apartment and to get access.

21 A. I don't remember.

22 Q. I then take it that you don't remember that

23 on Christmas Eve, his mother came up after that

24 alarming incident, bringing cakes and fruit?

25 A. No, I don't remember.

1 Q. Do you know whether during the time that you

2 were in the apartment that Kovac was under detention in

3 the KP Dom for a certain time?

4 A. I don't remember that.

5 Q. Are you still not able to tell us or

6 calculate how many times he actually spent the night in

7 the apartment?

8 A. No, I can't, although it was frequently.

9 JUDGE MUMBA: Counsel, any more questions?

10 MR. KOLESAR: [Interpretation] I do, Your

11 Honour, but if I may have a moment to look at my

12 notes.

13 Q. In your statement given to the investigators

14 of this Tribunal, and it is on page 13, would you

15 please take a look at page 13, and it is paragraph 5,

16 and it begins: "In that flat, all four of us were

17 raped by Klanfa and Kostic whenever they were in the

18 apartment." Is that correct?

19 A. Yes.

20 Q. That is all you stated to the investigators

21 of the Tribunal connected to the rapes that took place

22 in that apartment to you and your friends during the

23 time that you were in that apartment, if I have read

24 your statement correctly.

25 A. Well, I don't know how the statement sounds,

1 what the statement sounds like now, but I remember very

2 well that I was raped from the first moment I came to

3 Kovac's apartment to the last moment in Kovac's

4 apartment, when I left it.

5 Q. Well, that's what I want to ask you, because

6 you told the Court that you and number 75 were raped by

7 Kovac, and that you know that AS was raped by Jagos,

8 but you couldn't say about AB, and that is something

9 that exists in the transcript. Now, I'm interested in

10 knowing a little more about this. Could you describe

11 this to me in greater detail, Kovac's relationship to

12 you and his conduct towards you, his behaviour towards

13 you and towards number 75?

14 A. I don't know what you mean exactly.

15 Q. Linked to the rapes. Did Kovac rape you and

16 87 all the time while you were in the flat?

17 A. You mean number 75. I don't know about

18 number 75, although I do know that she was raped when

19 we arrived in the apartment. As far as I'm concerned,

20 I can confirm that I was raped by Kovac. As for number

21 75, I couldn't say. I state that once again. I can't

22 actually say. I just know that the first time -- I

23 don't know whether she was raped during the short space

24 of time that she was in the flat or not. I can't say.

25 Q. I'm asking you that not only because yourself

1 but because the other girls, because some of them have

2 already testified. Of course, I'm not going to say

3 what they said, nor do I have the right to do so, it

4 was only my intention to clarify certain points.

5 A. Well, I don't understand you.

6 Q. No. I wasn't asking a question. I was just

7 making a comment and saying why I wanted to hear this

8 from you.

9 MR. KOLESAR: [Interpretation] Your Honour, I

10 think we're coming up to the break. Perhaps, in view

11 of the fact that --

12 JUDGE MUMBA: You still have more questions?

13 MR. KOLESAR: [Interpretation] I do have more

14 questions.

15 JUDGE MUMBA: We'll have a break at

16 1100 hours, and we'll continue these proceedings at

17 1130 hours.

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

19 --- On resuming at 11.30 a.m.

20 JUDGE MUMBA: Before counsel proceeds with

21 cross-examination, I understand from the French

22 interpreters that they had a problem with one answer

23 from the witness. So I would like to find out from

24 them where about is the problem so that we can put it

25 to the witness to answer again, and I would ask

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1 counsel, Kolesar, to understand this. Listen to what

2 the interpreters will say.

3 Perhaps the -- I don't know, because I can't

4 get anything --

5 THE INTERPRETER: The question was whether

6 the door was locked or not.

7 JUDGE MUMBA: The door to what? To which

8 apartment or house?

9 THE INTERPRETER: The door of the apartment

10 used by Kovac. Mr. Kolesar put this question around

11 10.45, whether the door was closed or locked. The

12 witness said that they didn't have a key. So whether

13 it was one of those doors that locks automatically.

14 The question basically is whether the door was locked

15 or not.

16 JUDGE MUMBA: So I will ask counsel, if he

17 has understood that, to repeat the question so that the

18 witness can answer.

19 MR. KOLESAR: [Interpretation] Yes, Your

20 Honour.

21 Q. My question was: At the times when Kovac and

22 Kostic were outside the apartment, when they were not

23 in the apartment, the entrance -- the main door to the

24 apartment, was it locked? And the girls who were in

25 the apartment, were they able to lock and unlock the

1 door from the inside?

2 My question now is rather more detailed, but

3 that is the gist of the question.

4 A. The door of the apartment was locked, and we

5 didn't have a key, and we couldn't open the door.

6 Q. Let me then add to that. In one of the

7 drawers were there other sets of keys that could open

8 the door?

9 A. No.

10 Q. How then could you go to the shop to buy food

11 and cigarettes?

12 A. We never went to the shop to buy food and

13 cigarettes.

14 MR. KOLESAR: [Interpretation] Your Honour, I

15 think we've cleared up the matter now, have we not?

16 JUDGE MUMBA: Yes. Please proceed.

17 MR. KOLESAR: [Interpretation]

18 Q. Let me try to jog your memory by referring to

19 an event. Before you left Karaman's House, in the

20 presence of Tuta, Zelja, and Gojko, was another

21 Montenegrin soldier there who asked you to cross

22 yourself, to make the sign of the cross?

23 A. I cannot remember that.

24 Q. Never mind, then. We can move on.

25 Tell me, please: Where did each of the girls

1 sleep? In which room and in which bed?

2 A. When all four girls were there, for the short

3 while that all four of us were there, I cannot tell

4 you. As for the period when me and AS were in the

5 apartment, I would always stay in the big room, with

6 Kovac, and AS would always be in the smaller room with

7 Kostic.

8 Q. Why can't you answer the first part of my

9 question, that is, for the period when all four of you

10 were in the apartment?

11 A. This was a short period of time. They

12 didn't -- they weren't with us for long, so that I

13 cannot remember where each of us slept.

14 Q. Let us go back again to page 13 of your

15 statement to the Tribunal, to the investigators, dated

16 January 1995 [sic], where, in that same paragraph, third

17 paragraph from the bottom, you refer, with only one

18 sentence, to the event when you were forced to take off

19 your clothes and to dance. In your testimony in court

20 yesterday, you described the event differently. So my

21 question is: How many times were you forced, as a

22 group, to take your clothes off in the presence of the

23 accused Kovac and Kostic?

24 A. As a group, this occurred twice.

25 Q. Will you tell me when it occurred for the

1 first time, and when and where?

2 A. The first time it was in Kovac's apartment,

3 immediately after we arrived at the apartment. The

4 second instance was in an apartment in Gornje Polje;

5 however, when that happened, I am unable to say.

6 Q. When this happened in Kovac's apartment for

7 the first time, which of the girls were present?

8 A. All four of us were present.

9 Q. When you stripped, what did you do?

10 A. I can't remember that exactly. I don't

11 remember that so well. I think I was standing in the

12 corner of the main room, but I can't be sure.

13 Q. I apologise, but I really don't understand

14 what you mean, "in the corner."

15 A. I mean on a bed that was a corner sort of

16 settee.

17 Q. And the second time, who was present, and

18 when did this happen?

19 A. I don't remember when the second time

20 occurred. I don't remember exactly the time or the

21 date. I can't be sure whether all four of us were

22 there, though I do remember that number 75 was with

23 me. I know that we were not alone; there was someone

24 else. But whether all four of us were there, I'm not

25 sure.

1 Q. So you say this was in an apartment in Gornje

2 Polje?

3 A. Yes.

4 Q. Can you describe the event to us on that

5 occasion?

6 A. No.

7 Q. Where were you standing then?

8 A. I think we were standing on the table.

9 Q. What kind of table?

10 A. I don't remember that.

11 Q. And you say that once again you were alone.

12 A. Yes.

13 Q. Where and when? Could you tell me where and

14 when?

15 A. Again, I cannot remember when, though this

16 did happen in Kovac's apartment, in the big room.

17 Q. When you arrived in that apartment -- surely

18 I don't have to identify it every time; you know which

19 apartment I am referring to -- do you know what

20 happened to your sister?

21 A. No.

22 Q. You did not receive any information from

23 anybody about her fate?

24 A. No, I don't remember that.

25 Q. Thank you. You explained here in the Trial

1 Chamber that in fact there were three strippings: two

2 in a group and one that relates to you alone. And in a

3 statement that you made to the investigators, given

4 some time ago, you stated, as we have just read, that

5 all four of you were forced on one occasion to take off

6 your clothes and to dance on a table, to the

7 accompaniment of Muslim music. Which is the truth?

8 A. I don't know what you mean.

9 Q. What you said in court yesterday or what you

10 told the investigators of the Tribunal in January 1995 [sic]?

11 A. I think both statements are true, but the one

12 I gave in the Tribunal is more detailed, because I

13 remembered some additional things.

14 Q. Personally, I think that the statement that

15 you gave to the Tribunal about this event, consisting

16 of three sentences, is less, much less detailed than

17 what you told the Court here yesterday.

18 A. Possibly.

19 Q. But not possibly quite certainly. Far more

20 words are uttered than are contained in the statement

21 you made to the investigators.

22 A. Possibly. I really don't know the exact

23 reason why in my first statement to the Tribunal in

24 1996 I did not speak in greater detail about those

25 events.

1 JUDGE MUMBA: I would like to ask counsel on

2 the explanation of the witness. Counsel, you realise

3 that investigators are different from trial attorneys

4 in the manner they ask questions. So sometimes details

5 are elicited by the way the question is put to the

6 witness either in court or during the taking down of

7 the statement.

8 MR. KOLESAR: [Interpretation] I would agree

9 with you, Your Honour, but the technology used by the

10 investigator depends on the investigator, but the

11 taking of the statement took place much closer to the

12 time of the event, and I would be free to assume that

13 the witness told the investigator what she knew at the

14 time. But let that be, because as you have said, Your

15 Honour, it depends on the method used.

16 Q. Does the name "Panta" mean anything, to you,

17 Panta from Foca?

18 A. It sounds familiar. It does sound familiar,

19 but I can't say anything about it.

20 THE INTERPRETER: Microphone, please.

21 Microphone. Microphone. I'm sorry, we didn't hear

22 that question.

23 JUDGE MUMBA: Can you repeat the question

24 with your microphone on?

25 MR. KOLESAR: [Interpretation]

1 Q. Does the name "Panta" mean anything to you?

2 A. Though it sounds familiar, I can say nothing

3 about it.

4 Q. After you left the territory of Bosnia, or

5 whatever you like to call it, and your arrival in

6 Montenegro, you and AS worked at a time in a coffee bar

7 owned by somebody called Djilas, is that so?

8 A. Yes.

9 Q. While you were working at Djilas's, did this

10 Panta come and visit him?

11 A. I don't remember that.

12 Q. Do you remember that a person came and that

13 through that person you sent a letter to Foca?

14 A. I don't remember that.

15 Q. This was, in fact, a joint letter by you and

16 AS.

17 A. I don't remember that.

18 Q. You don't remember that at the end of the

19 letter there was a heart drawn with an arrow piercing

20 it? An arrow for Klanfa. Finally, something linked to

21 your assertions that you and AS were sold.

22 A. Yes.

23 Q. In a statement, on page 14, that we are

24 referring to, you said that you were in the corridor

25 and eavesdropping on the conversation between Kovac,

1 Kostic, and the two Montenegrins.

2 A. Yes.

3 Q. And where were they?

4 A. In the large room.

5 Q. You also said you didn't see the money

6 exchanging hands.

7 A. Yes.

8 Q. Between the kitchen and the big room there is

9 a hall leading to all the rooms, according to your

10 sketch today.

11 A. Yes.

12 Q. If you could hear from the kitchen what was

13 being said in the big room?

14 A. I don't understand the question.

15 Q. You said they were in the big room

16 negotiating the sale of you for 500 marks and, at that

17 time, you were in the kitchen.

18 A. At the time that we heard it, I think we were

19 in the corridor, in the hall. We didn't hear the whole

20 conversation between them, but we heard the part

21 relating to the money.

22 Q. In that same statement, you said that you

23 were in the corridor -- "I heard them talking in the

24 corridor with Kostic and Kovac," which means that

25 Kostic and Kovac were in the corridor, rather than you

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1 and AS.

2 A. No. They were in the big room and we were in

3 the corridor.

4 Q. So could you please read your statement,

5 page 14, third paragraph? The first two sentences.

6 A. "Sometime before the 25th of February, I

7 remember that the two Montenegrins came to Klanfa's

8 flat. I did not recognise them at this time but I

9 found out their names later. I heard them talking in

10 the lounge to Kostic and Kovac. [redacted] and we

11 were told to go to the kitchen but we were

12 eavesdropping."

13 Q. Please read it out. If you wish to read it

14 out, go on reading. I don't need it any more than

15 that.

16 In view of the fact that you did not see the

17 payments actually being made, are you quite sure that

18 you were sold?

19 A. I have already said that I heard the

20 conversation regarding the amount the Montenegrins

21 would pay for the two of us or how much they should pay

22 for the two of us, but that I personally did not see

23 the money exchanging hands and that I cannot say with

24 certainty that we were sold.

25 Q. Thank you very much, Witness.

1 MR. KOLESAR: [Interpretation] Thank you very

2 much, Your Honours, I have no more questions.

3 JUDGE MUMBA: Mr. Jovanovic.

4 MR. JOVANOVIC: [Interpretation] Yes, Your

5 Honour. With your permission, I would have a couple of

6 questions.

7 Cross-examined by Mr. Jovanovic:

8 Q. Good day to you. I would like to know --

9 just a moment. Something seems to be wrong with the

10 equipment. I think it will be all right now.

11 If I understood you correctly, you saw Zoran

12 Vukovic only twice, in the secondary school for the

13 first time, and the second time when he brought the

14 uniform.

15 A. Yes. The two times that I can recollect.

16 Q. At the moment when you were in Klanfa's flat,

17 let us call it that so we know what we're talking

18 about, at the beginning when the four of you were

19 there ...

20 A. I think that only the two of us were there at

21 the time.

22 Q. I'm sorry, I can't hear you at all. Would

23 you say something, please, so that I can find you? Say

24 just anything, please. Can you hear me? Because I

25 don't seem to be able to hear you.

1 A. Yes, I can hear you.

2 Q. How much time did all four of you spend

3 together in that apartment? Can you tell us?

4 Roughly.

5 A. I can't tell you exactly. I can't tell you

6 exactly. I think the four of us were not there for

7 long together, but I couldn't even tell you roughly for

8 how many days this was. Maybe seven to ten days.

9 Q. At the time when all four of you were in the

10 apartment, did Zoran Vukovic come with that uniform?

11 A. No.

12 Q. Thank you. In that period, did Zoran Vukovic

13 come to the apartment at all during those seven days?

14 A. I think that Zoran Vukovic appeared in the

15 apartment at the time when only I and AS were in it.

16 Q. Thank you.

17 THE REGISTRAR: [Interpretation] The technical

18 booth informs me that the microphone of Mr. Jovanovic

19 is much too loud, so he has to reduce the sound in his

20 headphone so as to avoid the interference, or possibly

21 switch to another channel.

22 MR. JOVANOVIC: [Interpretation] I'm using

23 channel 6. The microphone is close to the minimum, and

24 now I've reduced the volume in the headphones, so I

25 hope it will be all right now.

1 Q. I have prepared for you a host of questions

2 relating to differences that appear in your statements

3 and have to do exclusively with the way in which you

4 identify Zoran Vukovic, how you describe him in one

5 statement and in another, and then again what you told

6 the investigators, that you learnt about him from

7 another witness who has already testified here. But to

8 avoid going through all those details now, because it

9 is all in the record, I'm interested in general terms,

10 for you to tell me how did this come about. This is a

11 description of a man, of an individual; it's not a

12 situation or an occurrence that we may remember or not

13 remember. Someone can change, that is for sure -- more

14 or less hair, dyes his hair and so on -- but his

15 physical constitution can hardly change. So can you

16 give me a general answer as to how these differences

17 occur? Can you explain that to me, please.

18 A. I didn't see Zoran Vukovic many times, and I

19 recollect only two times, so I cannot remember any

20 significant traits regarding his appearance. I could

21 say he was medium height, medium weight, he had

22 light-brown hair, or fair hair, or something like that,

23 but it is all due to the fact that I only saw him a

24 couple of times.

25 MR. JOVANOVIC: [Interpretation]

1 Q. Let me ask you something else. You were very

2 young when this happened to you, and you were very

3 young when you were making your statements to the

4 persons responsible for this. When you made those

5 statements, were you alone? Let me make it clear.

6 Were you being accompanied by a member of your family

7 or an older person?

8 A. No.

9 Q. As we saw here, that sometimes there are very

10 serious contradictions between what you said the first

11 time and the second time. In the course of that

12 questioning, or that interview, did anyone assist you

13 to remember certain details: names, how people were

14 dressed or the list of persons that you named? In one

15 interview you produced a whole list of people, then

16 they disappear later on. What I'm trying to say is:

17 Did anyone lead you through that interview?

18 A. I don't know what you mean by "lead."

19 Q. Did anyone help you recollect something that

20 you may have forgotten?

21 A. No.

22 Q. Did anyone suggest to you the answers you

23 would give, to a point?

24 A. No.

25 Q. Then I have to ask you once again. Tell me,

1 please: How is it possible that there should be such

2 differences?

3 A. I don't know whether I can explain that.

4 Eight years have gone by since those events. Since my

5 first statement it is four years ago; my second

6 statement, six years; the period in between was two

7 years. So I had forgotten some things. But if I am

8 giving a statement covering the whole period, from the

9 beginning until the end, as I have done in court, then

10 there may be things that I recollect on the spur of the

11 moment that I may not have remembered before.

12 Q. If I understand you correctly, whenever you

13 are in a position to recount about those events, you

14 remember more and more details as you go along.

15 A. No, that is not what I meant. It is when I

16 was testifying here in court, I personally had to

17 create an image of that whole period of time, so that I

18 think that it is possible that I may remember something

19 just then, because I had to recount the whole story at

20 once. And not only was I supposed to give you the

21 story, but also to create an image of the whole thing,

22 and maybe that is the reason.

23 Q. Well, if I understand you correctly, what we

24 have heard here from you is the most complete

25 recollection of what happened to you.

1 A. Yes. There are some things that I have

2 forgotten, of course; and quite certainly, as you

3 yourself have said, there are some things that I happen

4 to remember on the spur of the moment.

5 MR. JOVANOVIC: [Interpretation] I have no

6 further questions, Your Honours. Thank you.

7 JUDGE MUMBA: Any re-examination from the

8 Prosecution?

9 MS. KUO: Just very briefly, Your Honours.

10 Re-examined by Ms. Kuo:

11 Q. Witness, while you were detained in Klanfa's

12 apartment, were you permitted any contact with the

13 outside world, such as to locate your family and let

14 them know where you were?

15 A. No. That was not possible.

16 Q. Why was it not possible?

17 A. Firstly, because we were always locked up;

18 second, we didn't have any telephones or anything like

19 that for us to be able to have contact. There were

20 none of these facilities to make any contacts with the

21 outside world.

22 Q. Mr. Kolesar asked you about washing clothing

23 and making coffee. Did you have to do things like that

24 for Kovac and Kostic as well?

25 A. Yes.

1 Q. Did you have to do anything else?

2 A. I'm not sure that I understand you. What do

3 you mean by that?

4 Q. I mean by way of household things that you

5 were forced to do.

6 A. I think they were the usual type of

7 housework: cleaning, washing, that kind of thing.

8 Q. In the first few days when you were detained

9 in Klanfa's apartment, together with 75 and AB, were

10 you constantly and continuously in the apartment, or

11 were you taken out sometimes?

12 A. I can't remember exactly. I know that we

13 were taken out, but I cannot be certain as to where and

14 whether that was then at that time when the four of us

15 were there in that apartment.

16 Q. And during that same time period, were you

17 able to keep track of everybody who came and went into

18 that apartment?

19 A. I don't understand your question.

20 Q. I mean, is it -- you were asked questions

21 about whether somebody could have come into the

22 apartment during that time period. Did you know -- is

23 it possible that there were people that came into the

24 apartment at some point and you did not know about it?

25 A. No. I don't think so.

1 Q. Were there times when you were taken into a

2 room and raped in that apartment?

3 A. As far as the Kovac apartment is concerned,

4 in that apartment I was raped by Kovac and Kostic.

5 There were others who came, but I don't remember. I

6 couldn't say whether I was raped by anyone else or not

7 during the time that the four of us were there.

8 Q. Could you say whether any of those other

9 people were raping the other three girls, any of the

10 other three girls?

11 A. I think they were, yes, but I can't be sure.

12 MS. KUO: I have no further questions.

13 JUDGE MUMBA: Thank you very much, Witness,

14 for giving evidence. You are free; now you can go.

15 [The witness withdrew]

16 MR. RYNEVELD: If I may address the Chamber

17 just prior to calling the next two witnesses. I might

18 indicate to you that there are some additional matters

19 that I'm going to be seeking some assistance from the

20 Chamber as to how you wish me to proceed. Let me

21 explain.

22 The next two witnesses, numbers 127 and 152,

23 are the mothers of AB and AS. As you know, when we

24 have dealt with witnesses, in order to keep protective

25 measures in place, we have shown lists with names

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1 printed on them and numbers corresponding. That works

2 well if the witnesses are literate. The next two

3 witnesses, to my understanding, are totally illiterate,

4 to the extent that they cannot even recognise their own

5 name when written on a piece of paper, or a number.

6 That being so, I'm also concerned, based on

7 personal experience, that although they may be prompted

8 to use only initials, that in the course of giving

9 evidence, I anticipate that they may inadvertently

10 blurt out a name of their daughter or another protected

11 witness's name.

12 That does present a bit of a challenge in

13 order to present the evidence in an open session, and I

14 have a number of alternatives, which is why I'm laying

15 this out for you. One, of course, would be to go into

16 private session when we get to that point. Another

17 would be to call the witnesses in open session and ask

18 them to not use the name of a witness, but then, of

19 course, we will not know -- I'm sorry, not a witness

20 but someone to whom protective measures apply, but that

21 we would have two risks, (A) they may blurt out a name;

22 (B) unless they are shown the name on a statement or

23 piece of paper, that name will not go into evidence.

24 I am willing to try -- well, I'll do whatever

25 the Court wants me to do, but my proposal is that we

1 try to deal with as much of the evidence in open

2 session, and when we get to an area where I know I'm

3 about to ask a question that may inadvertently lead to

4 a risky area, that we might go into private session for

5 two or three questions. That is a possibility, but I'm

6 in your hands as to how you wish to deal with it.

7 JUDGE MUMBA: One of the ways you are

8 proposing is that for the same witness, at times we are

9 in open session, at times in private session, private

10 session meaning closed session.

11 MR. RYNEVELD: Private insofar as no audio.

12 JUDGE MUMBA: Yes.

13 MR. RYNEVELD: I don't care about the

14 curtains being open.

15 JUDGE MUMBA: The witness will be screened,

16 of course.

17 MR. RYNEVELD: The witness will be screened.

18 I'm asking, especially with respect to the first

19 witness, the issue of protective measures for her are

20 not as much of a concern as they are for people whom

21 she may name who are protected witnesses.

22 JUDGE MUMBA: May I make this short. Having

23 talked to your witnesses, yourself and your colleagues

24 as counsel, having been informed and observed that

25 these witnesses cannot read and write, cannot tell

1 them, and all that, would you, as trial attorney,

2 prefer that these two witnesses give evidence in closed

3 session, having mentioned the problems?

4 MR. RYNEVELD: I'm as eager as the Court is

5 to have these matters, as far as possible, in open

6 session. If you could entrust to me to avoid those

7 areas until I get to a point where I anticipate we may

8 run into an area of risk, that may be the best way to

9 do it, and then simply to cut off the audio for those

10 questions.

11 Now, the most -- absolutely the most secure

12 method would be to go into closed session, but we must

13 weigh the balance between protective measures and

14 having these matters heard in open session. So I

15 thought that the most prudent thing for me to do was to

16 outline the difficulties to you and ask for your

17 guidance on the issue.

18 [Trial Chamber deliberates]

19 JUDGE MUMBA: Yes. We will leave it to the

20 trial attorney to indicate when you feel we can go into

21 private session and when you feel we can go into open

22 session. Let's see how it works.

23 MR. RYNEVELD: Thank you. I will do my

24 best. Before the witness is brought in, I wonder

25 whether this one final curtain can be closed. The

1 protective measures, I think, that would be required

2 for this witness would only be face distortion, not

3 voice distortion.

4 Could we call Witness 127, please.

5 JUDGE MUMBA: So to clarify this, I will say

6 that this witness will have face distortion only and

7 sometimes private session.

8 MR. RYNEVELD: Yes. When I get to the point

9 where I anticipate asking questions which are designed

10 to elicit an answer that is the nature of protective

11 measures, I will indicate that to the Court and wait

12 until the issue becomes clear.

13 The difficulty I have, of course, is there

14 may be an instance where a name may be blurted out

15 unintentionally, in which case we'll have to go to

16 redaction.

17 JUDGE MUMBA: Yes. Yes.

18 THE REGISTRAR: [Interpretation] The technical

19 booth needs a five-minute break to make the necessary

20 adjustments.

21 JUDGE HUNT: There is no voice distortion

22 required.

23 THE REGISTRAR: [Interpretation] Indeed.

24 There will be no voice distortion, and that is why the

25 technical booth tells me that they need five minutes.

1 MR. RYNEVELD: I take it that's to undo the

2 voice distortion that was in place for other

3 witnesses.

4 JUDGE MUMBA: Yes. So we'll simply wait for

5 the five minutes.

6 MR. RYNEVELD: May I also raise another issue

7 then while we're awaiting this, and that is the method

8 by which this witness will be sworn and state her

9 name. It may be that someone will have to read the

10 oath, as it were, to her in her language and see if she

11 agrees.

12 JUDGE MUMBA: I think we can do that in

13 private session so that you can lead her as to "Is this

14 your name, so-and-so," private session, then we open.

15 MR. RYNEVELD: So that was my long

16 introductory way of saying perhaps we should start the

17 first couple of minutes in private session.

18 JUDGE MUMBA: Yes. I think it's better that

19 way.

20 MR. RYNEVELD: But nevertheless, someone will

21 still have to read -- I'll still need someone to be

22 able to read the oath to her in B/C/S.

23 JUDGE MUMBA: Oh, we haven't got --

24 MR. RYNEVELD: In B/C/S?

25 JUDGE MUMBA: We haven't got our --

1 MR. RYNEVELD: Oh, we have a translator. Of

2 course. Of course. Sorry. Sometimes I forget that

3 the translation is able to take care of little problems

4 like that.

5 THE REGISTRAR: [Interpretation] The technical

6 booth is now ready. The technician is going to come

7 into the hall to adjust the microphones, I assume.

8 JUDGE MUMBA: Yes. The technicians can come

9 in and do whatever is necessary for us to proceed with

10 this witness, bearing in mind that we'll have a private

11 session first and then we will be changing later.

12 [The witness entered court]

13 [Private session]

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7 (redacted)

8 [Open session]

9 MR. RYNEVELD:

10 Q. Witness, you've heard me make reference to

11 your oldest daughter. From now on I'm going to be

12 referring to your oldest daughter by the initials AB.

13 Do you understand that?

14 A. Yes, I understand. I don't know much about

15 it, though. I said I didn't -- I told you I didn't

16 know much about that, that you were just going to

17 mention my daughter. That's what you said.

18 Q. Yes. All right. When I refer to your

19 daughter from now on in, I will be referring to someone

20 by the initials of AB, okay? Do you understand that?

21 And I don't wish you to mention her name. You can

22 refer to her as your daughter, and we will all

23 understand that you are talking about your eldest

24 daughter. Thank you.

25 Now, you've told us, Witness, that you and

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1 your family lived in Miljevina; is that correct?

2 A. That's correct.

3 Q. And you had lived there for, I understand,

4 about 12 years prior to the outbreak of the war in

5 April of 1992; is that correct?

6 A. That's correct.

7 Q. Now, did something happen in June of 1992

8 affecting your family? And please do not mention any

9 family member names. You can refer to them by their

10 relationship to you, okay?

11 THE INTERPRETER: I'm afraid we did not hear

12 the witness.

13 A. You mean my husband disappearing? Is that

14 what you mean?

15 MR. RYNEVELD:

16 Q. Let's start there. What happened in June of

17 1992? Did some police come to your home?

18 A. Yes.

19 Q. Would you tell us about that, please.

20 A. Can I say how a policeman came to my house,

21 and which policeman? Can I say his name?

22 Q. Absolutely.

23 A. Rade Draskovic.

24 Q. If you remember these names. The only names

25 I want to be careful about is that you don't name your

1 family names, okay? But if you know the names of

2 policemen or soldiers, or anything like that, go ahead

3 and tell us those names. Do you understand that?

4 A. I said that Rade Draskovic turned up and

5 Krsto Skakavac turned up to fetch my husband, and took

6 him off.

7 Q. Yes. And these two individuals, did you know

8 them prior to them coming to your home?

9 A. Yes.

10 Q. How did you know these two policemen?

11 A. (redacted).

12 Q. Do you know what their ethnic origins were?

13 A. Serbs, Chetniks.

14 Q. How were they dressed when they came to your

15 home?

16 A. They had police uniforms.

17 Q. Did they have any weapons with them?

18 A. Yes, they did.

19 Q. Do you remember what kind or whether they

20 were -- well, tell us what you remember about the

21 weapons.

22 A. I don't really remember.

23 Q. Okay. Why did they come to your house?

24 A. They came to take my husband away.

25 Q. Did they give you a reason why they came to

1 take your husband away?

2 A. My husband asked what were they going to do

3 with him, and the answer was, "I have orders to take

4 you to the SUP," and that's what happened.

5 Q. Do I understand you correctly that the SUP is

6 the police headquarters building?

7 A. The police was in Miljevina, and that is

8 where they took them. The police station was there,

9 yes. Even before, in peacetime, the police was there.

10 Q. Okay. And did they in fact take your husband

11 away?

12 A. They took him to the police. That's what

13 they said.

14 Q. Do you know whether your husband was the only

15 man being taken away?

16 A. I heard they took them all, all our men that

17 remained in Miljevina.

18 Q. When you say "our men," do you mean of mixed

19 ethnicity or of any particular ethnicity?

20 A. Muslims. I don't know how else -- what else

21 I would mean when I say "our men."

22 Q. All right. Do you know how many men were

23 taken away in addition to your husband, approximately?

24 A. I heard that 30 of our men were taken away.

25 I don't know exactly. That is what I heard.

1 Q. Do you know who was involved, what kind of

2 people were involved in taking these men away? You've

3 told us about two policemen came to get your husband.

4 How about the other men? Do you know whether they were

5 taken away by policemen or soldiers, or what?

6 A. I told you that I didn't know. I just know

7 who took my husband away.

8 Q. Do you remember any of the names of the other

9 people that took the men away?

10 A. I don't remember.

11 Q. All right. Do you know where the men were

12 taken?

13 A. They said that they took them to the KP Dom

14 in Foca, the prison facility.

15 Q. Do you remember the date that your husband

16 was taken away?

17 A. I don't remember, honestly.

18 Q. Have you ever seen your husband again since

19 he was taken away from you?

20 A. I never saw him again, nor did I hear

21 anything about him.

22 Q. From the time the two policemen came to take

23 him away, you've not heard from or seen your husband

24 since?

25 A. Yes, that is right.

1 MR. RYNEVELD: Excuse me, Your Honours. I

2 just want to reorganise my notes to make sure I'm not

3 getting into a sensitive area.

4 Q. I'm going to ask you to turn now to tell us

5 about your oldest daughter. When your husband was

6 taken away, did your oldest daughter and your other two

7 daughters continue to live with you in Miljevina?

8 A. Yes.

9 Q. Was there a time when you and your daughters

10 also left Miljevina?

11 A. Yes. We left it when we were chased out of

12 Miljevina.

13 Q. What do you mean "chased out"? How did that

14 happen?

15 A. They told us that we all had to leave

16 Miljevina.

17 Q. Who is "they"?

18 A. The Serbs.

19 Q. Do you know which Serbs may have told you

20 that you had to leave Miljevina?

21 A. Pero Elez announced it, but I can't say what

22 his name was. I don't know.

23 Q. When you say "Pero Elez," did you know that

24 name before the war?

25 A. Yes, I knew Pero Elez before the war.

1 Q. How?

2 A. I would see him in Miljevina and people would

3 say, "That was Pero Elez," that's all.

4 Q. Do you know if he was a Muslim or a Serb?

5 A. He was a Serb. As far as I know, he was a

6 Serb.

7 Q. And it was your understanding, if I

8 understand your evidence correctly, that it was Pero

9 Elez who indicated that you had to leave Miljevina? Is

10 that what I heard you say?

11 A. Yes, that is what I said.

12 Q. How far is Miljevina from Buk Bijela?

13 A. I don't even know where Buk Bijela is. All I

14 know is Miljevina.

15 Q. Okay. In Miljevina, are you familiar with

16 the name of a house that belonged to a Mr. Karaman?

17 A. I knew where Karaman's House was.

18 Q. Where was it in Miljevina?

19 A. We called the area Potkosica, something like

20 that. I am not quite sure. I think that is what the

21 area was called where his house was.

22 Q. All right. Now, was there a time when people

23 were looking for your eldest daughter, AB?

24 A. Yes.

25 Q. Can you tell us where you were when people

1 came looking for your eldest daughter, AB?

2 A. In the apartment; in the house.

3 Q. Was this the house where you lived in

4 Miljevina?

5 A. It was.

6 Q. Do you remember when it was that people came

7 looking for your daughter?

8 A. They came in the evening. I don't know what

9 time it was, but it was dark.

10 Q. Do you remember what month?

11 A. I don't remember, I'm afraid.

12 Q. Do you remember the time of year, whether it

13 was spring, or winter, or fall, or summer?

14 A. I think it was September. I'm not sure. I

15 think it was September. I don't know the date,

16 however.

17 Q. Do you remember who came looking for your

18 eldest daughter, AB?

19 A. Jego came, but I don't know his first name or

20 surname. I did give his name in my statement, but I

21 said I'd forgotten it. I can't forget his nickname,

22 however. It's Jego.

23 Q. When Jego came to your apartment, how do you

24 know he was looking for your daughter? What did he

25 say?

1 A. He came under the window and he called out

2 and he -- may I use the name? He called for my

3 daughter, called her out by first and last name to take

4 her out.

5 Q. Thank you. Was she there?

6 A. She was with me, yes.

7 Q. Did she go with him?

8 A. We cried. She cried too. Then he threatened

9 to kill all of us, and he took her away in a car.

10 Q. How long was she gone?

11 A. Two days.

12 Q. You say she was gone for two days, so I'm

13 assuming she came back. How was she brought back or

14 how did she come back?

15 A. She came back. Pero Elez brought her back to

16 the house.

17 Q. Walking or some other means or by car or do

18 you remember?

19 A. By car. By car.

20 MR. RYNEVELD: Might we, at this point, very

21 briefly enter into private session? I'm going to ask a

22 couple of questions that may elicit some answers.

23 JUDGE MUMBA: Yes, please.

24 [Private session]

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24 [Open session]

25 MR. RYNEVELD: Thank you.

1 Q. Witness, talking about Karaman's House, did

2 you speak to other people in the Miljevina area with

3 respect to what was going on in Karaman's House?

4 A. I just heard that there was this house,

5 Karaman's House, where my child was taken. They said

6 that they had opened a brothel there, that it was a

7 brothel in Karaman's House, and they took children

8 there.

9 Q. Who took children there, from your

10 understanding?

11 A. I don't know. I heard that somebody called

12 Zaga from Foca did it. I don't know him though.

13 Q. In any event, your daughter was taken away.

14 She told you that she'd been at Karaman's House, and

15 she was brought back in two days; is that correct?

16 A. Correct.

17 MR. RYNEVELD: Sorry, I didn't get an

18 answer.

19 THE INTERPRETER: "Correct."

20 A. Correct. Correct.

21 MR. RYNEVELD:

22 Q. Now, you've told us about a Mr. Pero Elez and

23 that you knew him before the war. Do you remember

24 anything about a car and loudspeakers that you can tell

25 us about?

1 A. I don't know anything about that. I don't

2 remember.

3 Q. All right. Let's move on to another topic.

4 Did you stay in Miljevina for the rest of your time or

5 did you leave it at some point?

6 A. We left on the 2nd of September. We left

7 Miljevina.

8 Q. Why?

9 JUDGE MUMBA: Could we just have a

10 confirmation, counsel, what year?

11 MR. RYNEVELD: Thank you.

12 Q. You left in what year? Do you remember the

13 year that you left Miljevina?

14 A. 1992.

15 Q. And you say it was the 2nd of September, 1992

16 that you left?

17 MR. RYNEVELD: Sorry, I didn't get the answer

18 translated.

19 A. Yes. Yes.

20 MR. RYNEVELD:

21 Q. Thank you. Tell us about how it was that you

22 left Miljevina.

23 A. They announced that they would transfer us to

24 our people in Foca.

25 Q. Who announced that?

1 A. Pero Elez. I told you.

2 Q. I'm sorry if some of my questions appear to

3 be dumb, but there is a reason for my asking them. So

4 you say Pero Elez -- tell us about how it was that you

5 were informed that you had to leave Miljevina.

6 A. We were informed through that something -- I

7 don't know how to describe it -- that at a certain hour

8 we had to go to Foca.

9 Q. Were you told why?

10 A. That we were going to our people. That they

11 would transfer us to our people.

12 Q. Were you told -- sorry. You weren't

13 finished.

14 A. That we could not go on living in Miljevina

15 with them.

16 Q. Why?

17 A. How do I know? That's what they said, that

18 we couldn't go on living there, that they said that

19 they would expel us.

20 Q. Thank you. Well, were you, in fact, removed

21 or expelled from Miljevina, and if so, how?

22 A. All of us together left Miljevina by buses to

23 Foca.

24 Q. Do you remember how many buses there were?

25 A. As far as I can remember, there were three

1 buses going from Miljevina to Foca.

2 Q. Can you give us an estimate as to how many

3 Muslim people were being expelled, as you put it, from

4 Miljevina on those three buses?

5 A. I heard that it was about 200 something, but

6 I don't know exactly.

7 Q. Where did you go?

8 A. They took us to Partizan, in Foca.

9 Q. Was your eldest daughter, AB, and your two

10 other daughters, with you when you boarded the bus for

11 Partizan?

12 A. Yes.

13 Q. Did you go directly to Partizan that day?

14 A. Yes, we did.

15 Q. What happened when you got there?

16 A. They took us inside. We sat around. Some

17 people were sitting, others were standing, and we

18 stayed there.

19 Q. And how long were you at Partizan?

20 A. As far as I can remember, from 10.00 in the

21 evening until 4.00 or 5.00, but I don't know exactly.

22 Q. Did you sleep there overnight or were you

23 just there a matter of hours?

24 A. We didn't spend the night there; we just

25 spent a couple of hours there.

1 Q. While you were at Partizan, did anything

2 happen to you?

3 A. No one touched us in Partizan, and then they

4 said that we would be going on by buses, and then they

5 searched us.

6 Q. When you say "they searched us," what were

7 they searching for, and who was doing the searching?

8 A. They were looking for money and gold, but I

9 don't know who it was who did the searching. I can't

10 remember who it was.

11 Q. Do you remember any nicknames of the people

12 who did the searching?

13 A. I just know that Nedzo -- now, what was his

14 surname? -- Samardzic. He said, in respect of me,

15 "Take her money and don't search her."

16 Q. Was your money taken?

17 A. It was.

18 Q. Anything else?

19 A. No, they didn't take anything else. I didn't

20 have any gold.

21 Q. Now, when they had taken your money at

22 Partizan, the arrangements were for you to go somewhere

23 else. Now, I think you've told us. I'm going to ask

24 you again where you were told you were going.

25 A. That they would take us to the border, where

1 our people were. But I don't know these things. I was

2 frightened.

3 Q. Yes, I understand that. Did you and your

4 family leave Partizan -- I'm sorry. I'm going to lead

5 you on this. Did you go back on the buses?

6 A. Yes. The buses were going to take us to our

7 people. Some people were left behind. We went towards

8 the buses. They wanted to take my daughter, but I

9 don't know them. And she was crying, and she was

10 saying, "Don't touch me. I'm only 12." And they said,

11 "Don't lie." And I said, "Yes, she's only 12. How

12 can you take my child?" And somehow we got into the

13 bus and they didn't take her.

14 Q. So although they tried to take your daughter

15 as you were getting onto the bus, she managed to get on

16 the bus with you and your two other daughters; is that

17 correct?

18 A. That is correct.

19 Q. And did the buses leave Partizan?

20 A. We all got into the buses and we left

21 Partizan. There were two buses.

22 MR. RYNEVELD: If I may just stop there for a

23 moment. Your Honours, I note the time. I have about

24 three or four questions left that could finish this

25 witness. But I'm in your hands, if you want me to stop

1 now and finish after the break or whether you want me

2 to continue at this point.

3 [Trial Chamber confers]

4 JUDGE MUMBA: Counsel, it's better for us to

5 stick to our time, so we'll have our lunch break and

6 we'll continue the proceedings in the afternoon at 1430

7 hours.

8 MR. RYNEVELD: Thank you, Your Honour.

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

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1 --- On resuming at 2.30 p.m.

2 JUDGE MUMBA: Yes. The Prosecution is

3 continuing examination-in-chief. We are in open

4 session?

5 THE REGISTRAR: [Interpretation] Yes, we are

6 in public session.

7 MR. RYNEVELD: Yes. During the course of my

8 examination, I anticipate it will be necessary to

9 return one more time to private session. I won't do

10 that now; I'll come back to it, to avoid --

11 JUDGE MUMBA: Yes.

12 MR. RYNEVELD:

13 Q. Witness, just before the lunch break, I

14 believe I had asked you about whether at some point,

15 after people tried to get your daughter to go with

16 them, you managed to get her and your other two

17 daughters onto the bus leaving Partizan; is that

18 correct?

19 A. Yes, it is.

20 Q. And did the bus take off, like leave, from

21 Partizan?

22 A. It did.

23 Q. Were your daughters, all of them, aboard with

24 you?

25 A. Yes, they were.

1 Q. Did you get to your destination without

2 stopping, or did something happen on route?

3 A. By the Drina Bridge, the bus was stopped and

4 they took my daughter out of the bus.

5 Q. How far had you managed to get when you got

6 to the Drina River? How far was that away from

7 Partizan?

8 A. Well, I don't know. I can't tell you that.

9 Q. Were you still in Foca?

10 A. Well, by the Drina Bridge. I suppose we were

11 in Foca. I'm not from Foca to know whether that

12 belongs to Foca or not.

13 Q. All right. And how was the bus stopped? How

14 did that happen? Tell us in detail how it was that the

15 bus got stopped and they took your daughter.

16 A. There were two buses. The first passed by.

17 Nobody stopped it. But when the second one came, it

18 was stopped. There was a police car. They got out of

19 the car and came to the bus, the door of the bus, and

20 called us out by name and -- called her out by name and

21 surname. We cried and screamed and tried to see that

22 there was a relative. And I said I didn't see her

23 anymore, and he pointed a gun at my forehead and said

24 he'd kill me, and told me to keep quiet. And that's

25 how they took her out of the bus. I didn't know who it

1 was. I didn't know any of them.

2 Q. Who were in -- I'm sorry. You told us you

3 don't know any of them. Can you tell us -- you say it

4 was --

5 A. I don't know anybody. If I knew somebody, I

6 would tell you their name, but I don't know anybody.

7 Q. I understand that. Was it a police car that

8 you said that overtook the bus and forced it to stop?

9 A. Yes.

10 Q. Could you tell if the people inside that

11 police car were policemen or whether they were

12 soldiers, by their dress?

13 A. I don't know exactly whether they were

14 wearing their uniforms, the police uniforms, or -- I

15 don't know. I don't know how I managed to survive,

16 survive it all. I was so frightened.

17 MR. RYNEVELD: Might we at this point very

18 briefly move into private session again.

19 JUDGE MUMBA: Yes, please.

20 MR. RYNEVELD: And I'll await the signal.

21 [Private session]

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14 [Open session]

15 MR. RYNEVELD: Thank you.

16 Q. Witness, did you recently provide a

17 photograph of your daughter AB when she was still a

18 schoolgirl, just before she was taken away?

19 A. I gave it here when I came here.

20 Q. Yes. That's what I mean by "recently." You

21 brought it in the last few days, did you?

22 A. Yes.

23 Q. That original photograph, did it have more

24 than -- more people on the photograph than just your

25 eldest daughter?

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1 A. That was my eldest daughter and the little

2 one and the middle one, I think.

3 Q. Yes.

4 MR. RYNEVELD: For the information of my

5 friends and the Court, we have redacted the two other

6 people, and we have blown up a photograph provided by

7 this witness. Might she be shown photograph number --

8 what I understand will become Prosecution Exhibit

9 number 195. There are copies for my learned friends

10 and for the court.

11 A. Yes, you can, if you wish to.

12 Q. Do you recognise the person in that

13 photograph?

14 THE REGISTRAR: [Interpretation] This

15 photograph is marked 195, Prosecution exhibit.

16 MR. RYNEVELD:

17 Q. Is that the photograph that you provided of

18 your daughter, AB?

19 A. It is, yes.

20 Q. Can you tell the Court how old she was when

21 this photograph was taken?

22 A. I don't know. I don't know. She went to

23 school.

24 Q. Do you know how long it was before 1992 that

25 this photograph was taken?

1 A. I don't know anything.

2 Q. Have you ever seen your daughter, AB, since

3 she was taken away on the bus?

4 A. No, never.

5 MR. RYNEVELD: Those are my questions. Thank

6 you.

7 JUDGE MUMBA: Prosecution, before you sit

8 down, I just wanted to be clear about the statements.

9 MR. RYNEVELD: Yes.

10 JUDGE MUMBA: Do you wish them produced into

11 evidence or you'll just mark them for identification?

12 MR. RYNEVELD: It is not normally my practice

13 to do so; however, in view of the fact that I've read

14 out from these statements, I think it's now proper that

15 I ask that they be marked as Prosecution exhibits.

16 JUDGE MUMBA: All right. Then they are

17 admitted into evidence. Can we have formally the

18 numbers?

19 THE REGISTRAR: [Interpretation] The witness

20 statement dated 19th of June, 1996, is marked

21 Prosecution Exhibit --

22 THE INTERPRETER: The interpreter is sorry,

23 but has not heard.

24 JUDGE MUMBA: Maybe we should adjourn to

25 allow the witness to calm down.

1 MR. RYNEVELD: Yes. That was going to be my

2 next request while I'm still on my feet. Thank you.

3 JUDGE MUMBA: We will wait outside. Counsel

4 will let us know.

5 MR. RYNEVELD: Thank you.

6 JUDGE MUMBA: The Court will rise.

7 --- Break taken at 2.51 p.m.

8 --- On resuming at 3.13 p.m.

9 JUDGE MUMBA: Yes. Any cross-examination by

10 counsel from the Defence?

11 MR. PRODANOVIC: [Interpretation] Your Honour,

12 I have only one question which I should like to put to

13 the witness. And in view of all these circumstances --

14 before the witness appeared, I had no intention of

15 asking the witness anything at all, but since a detail

16 was mentioned that was not to be found in her

17 statements, I would like to ask her a question about

18 that detail only.

19 JUDGE MUMBA: Yes. Please go ahead.

20 Cross-examined by Mr. Prodanovic:

21 Q. In the statements that you gave, never once

22 did you mention the name of Zaga, that he was the

23 person who came to Partizan to take girls out. On page

24 2 of your statement you listed eight names that your

25 daughter told you about, as coming to take girls out

1 and take to Karaman's House, but you did not mention

2 Zaga. You didn't mention Zaga either in your statement

3 for the investigators of the International Tribunal.

4 My question is: How come you now mention

5 Zaga, whom you didn't know in person but that people

6 had told you about him?

7 A. I heard in peacetime that there was a Zaga

8 from Foca who went around and doing all kinds of

9 things, and that he, during the war, he took girls and

10 took them off to Montenegro. What are you asking me

11 questions for? Leave me alone. You have nothing to do

12 with me. You know what you were doing and what they

13 were doing.

14 JUDGE MUMBA: Witness, please calm down.

15 Counsel was just asking you a question.

16 THE WITNESS: I can't calm down. How can I

17 calm down?

18 MR. PRODANOVIC: [Interpretation] I have no

19 further questions, Your Honour.

20 JUDGE MUMBA: Thank you.

21 Mr. Kolesar?

22 MR. KOLESAR: [Interpretation] Your Honour, I

23 do not wish to ask this witness any questions.

24 JUDGE MUMBA: Mr. Jovanovic?

25 MR. JOVANOVIC: [Interpretation] No, Your

1 Honours, we have no questions.

2 JUDGE MUMBA: The Prosecution?

3 MR. RYNEVELD: No, thank you.

4 JUDGE MUMBA: Thank you very much, Witness,

5 for giving evidence. We have finished. Now you can

6 go.

7 THE WITNESS: Thank you.

8 MR. RYNEVELD: Between witnesses, if I may,

9 there is a housekeeping matter that has arisen, I

10 believe, from the transcript, where the interpreter

11 indicated that they had not heard the exhibit number

12 assigned to that second statement. That was my note

13 just before the break. I read from two statements.

14 The first was part of Exhibit 65, and the second

15 statement, which was -- I believe copies were provided,

16 also dated the 3rd of March, I understand was marked as

17 Exhibit 196, but the transcript doesn't show that.

18 JUDGE MUMBA: Maybe the Registrar can repeat

19 the numbers of the exhibits.

20 [The witness withdrew]

21 THE REGISTRAR: [Interpretation] The first

22 statement was marked 65, and the second statement 196,

23 Prosecution Exhibit 196.

24 MR. RYNEVELD: Thank you. I just wanted the

25 record to reflect that.

1 JUDGE MUMBA: I would also like to remind the

2 registrar that the exhibits, the sketches drawn by our

3 witness, D55, D56, D57, we would like to have the words

4 put in English on the sketches without redrawing them,

5 please.

6 THE REGISTRAR: [Interpretation] Yes. I think

7 we have a problem in the transcript, because these are

8 exhibits --

9 JUDGE MUMBA: D35, D36 --

10 THE REGISTRAR: [Interpretation] Yes. We are

11 talking about Exhibits D35, D36, and D37. We will ask

12 for a translation today.

13 JUDGE MUMBA: Thank you.

14 The Prosecution, any other witness?

15 MR. RYNEVELD: Yes. Thank you, Your Honour.

16 We propose to call next Witness 152. This witness will

17 be similar to the last witness in that, again, she is

18 not able to read, and I would ask again that we go into

19 private session for the first little part, and if the

20 same conditions might apply for the leading of evidence

21 of this witness, I would be grateful.

22 JUDGE MUMBA: Yes. So counsel will be able

23 to indicate when he requires private session, public

24 session, and vice versa, and the registrar will be able

25 to formally inform us accordingly.

1 MR. RYNEVELD: Yes. Sometimes with the last

2 witness I moved into private session, and it may not

3 have been clear during the responses why we did, but

4 it's simply because I didn't know --

5 JUDGE MUMBA: No. Because we have been

6 informed that the next witness, like the last one,

7 cannot read and write.

8 MR. RYNEVELD: Exactly.

9 JUDGE MUMBA: So counsel has to lead her,

10 naming members of her family, if necessary, and even

11 her own name, if necessary.

12 MR. RYNEVELD: Yes. That's what I intend to

13 do. Thank you.

14 [The witness entered court]

15 JUDGE MUMBA: The witness will make her

16 solemn declaration through the usher, please. May the

17 witness stand.

18 WITNESS: WITNESS 152

19 [Witness answered through interpreter]

20 JUDGE MUMBA: You read it to her, then the

21 interpreter will interpret, because she can't read.

22 MR. USHER: I solemnly declare [witness

23 repeats] that I will speak the truth [witness repeats]

24 the whole truth [witness repeats] and nothing but the

25 truth [witness repeats].

1 JUDGE MUMBA: Thank you, Witness. Will you

2 please sit down.

3 MR. RYNEVELD: May I confirm that we are in

4 private session for the first few questions and

5 answers, please.

6 THE REGISTRAR: [Interpretation] We are indeed

7 in private session.

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22 [Open session]

23 THE REGISTRAR: [Interpretation] We are in

24 open session.

25 MR. RYNEVELD: Thank you.

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1 Q. Now, Witness, I'd like you to turn your mind

2 to about April of 1992. At that time, how old was your

3 daughter?

4 A. I don't know the dates.

5 Q. All right.

6 A. Nineteen.

7 Q. Your daughter was nineteen at the time. Is

8 that what you said?

9 A. Yes.

10 Q. Was she living at home?

11 A. She was.

12 Q. And was your daughter employed?

13 A. Yes.

14 Q. Where did she work?

15 A. In a footwear factory.

16 Q. Did that employment end at some point?

17 A. It did.

18 Q. Can you tell us how that came to an end?

19 A. Let me see. When the Chetniks attacked

20 Gorazde, then they stopped working. I don't know the

21 dates.

22 Q. All right. When Gorazde was attacked. Now,

23 you were in Miljevina; is that correct?

24 A. Yes. Yes, it is.

25 Q. Are you able to tell us how far Miljevina is

1 from Gorazde?

2 A. I'm not able to tell you that.

3 Q. All right. But the place where your daughter

4 was employed was not in Gorazde, was it?

5 A. In Miljevina.

6 Q. Yes. Can you tell us a bit more details

7 about how it was that your daughter's employment came

8 to an end and how you found out about that? Tell us

9 what she told you.

10 A. She told me, "Mummy, they won't let us

11 Muslims work any more. What are we going to do now?

12 We'll all die of hunger. They've turned back all the

13 Muslims. They won't let them go to work. The Chetniks

14 turned them back."

15 Q. Did she remain unemployed for a period of

16 time? Did she ever go back to work?

17 A. She did not. She never went back to work.

18 Q. Now, after this incident, was there a time

19 when people came to your village looking for the men,

20 and if so, can you tell us about that?

21 A. Yes. Draskovic Rade came and took all our

22 men from Miljevina.

23 Q. You mentioned this person by name. Did you

24 know him before he came looking for the men?

25 A. I did.

1 Q. How was it that you happened to know him?

2 A. Because he came to take my husband away.

3 Q. How did you know him before he came to take

4 your husband away? Was he a neighbour or was he a

5 friend or someone who was --

6 A. A neighbour. A neighbour. But he was in

7 Novo Naselje and we lived in the Staro Naselje, new and

8 old settlement.

9 Q. And the area where you lived in, was that a

10 Muslim settlement or was it mixed?

11 A. It was mixed: one Muslim, one Serb.

12 Q. And before --

13 A. In the building. Sorry.

14 Q. Before they came to take the men away, can

15 you tell us what relations were like between the

16 Muslims and Serbs in your community?

17 A. Before the war we lived just fine, and when

18 the war started, they knew what they did.

19 Q. Now, this Draskovic Rade that you referred

20 to, do you know whether he was a Muslim or a Serb?

21 A. A Chetnik.

22 Q. And by that, do you mean a Serb?

23 A. A Serb, and then a Chetnik.

24 Q. Do you know how he was dressed when he came?

25 A. He was armed to the teeth. He had a rifle

1 over his shoulder, he was carrying grenades, a stick.

2 That's what he had on him.

3 Q. And underneath all those weapons, what kind

4 of clothing? Could you tell?

5 A. A camouflage uniform was on him.

6 Q. Was he alone or was he in the company of

7 others?

8 A. There was another one with him, but I don't

9 know his name. He stood outside when they came to take

10 my husband.

11 Q. And did they in fact take your husband, or

12 did something else happen?

13 A. No. My husband was sick with fear, so he

14 didn't take him away; he left him alone.

15 Q. Did your husband have a medical condition

16 besides being sick with fear?

17 A. No, he wasn't ill, but when they came to take

18 my child away, he got so frightened, and this resulted

19 in his illness.

20 Q. We'll get to that in a moment. On the day

21 that they came for your husband, they did not take him

22 away; is that correct?

23 A. That is correct. They didn't take him away.

24 Q. Did they take any other men, to your

25 knowledge?

1 A. They did. They took Saban Aljukic, Nedzib

2 Aljukic, Saban Mazija, Atif Hambo, Osman Basic, Kasim

3 Mekic and some others, but I can't remember their

4 names.

5 Q. Do you know who took them?

6 A. Rade Draskovic took them.

7 Q. Do you know where they took them?

8 A. I don't know, but all trace of them was lost.

9 Q. Now, you told us moments ago that your

10 husband became ill on an incident when they came

11 looking for your daughter. When did that occur; do you

12 recall?

13 A. It was in the summer, but I don't know the

14 dates.

15 Q. And was your husband and your daughter at

16 home at the time?

17 A. Yes. We were in home, under house arrest,

18 for five months, and no one was allowed to go anywhere.

19 Q. How was that enforced?

20 A. We didn't dare go anywhere. They told us

21 that we shouldn't go anywhere.

22 Q. So while you were in this period of house

23 arrest, you say they came looking for your daughter.

24 Can you give us as much detail as possible about the

25 incident where they -- and I'll ask you to tell me who

1 "they" is -- came looking for your daughter.

2 A. They would come at night looking for my

3 daughter, unknown men, armed to the teeth.

4 Q. How did you know they were looking for your

5 daughter?

6 A. They asked me where my child was.

7 Q. Did you tell them? I'm sorry, did you hear

8 my question? Did you tell them where your daughter

9 was?

10 A. I don't know where she is. She's gone, I

11 said.

12 Q. No. I'm sorry.

13 A. I kept her in hiding.

14 Q. Thank you. You kept your daughter in hiding

15 at that time from these people that were looking for

16 her?

17 A. Yes.

18 Q. Don't tell us the name, but did they ask for

19 her by name or did they refer to her as "your

20 daughter"?

21 A. By name they asked for her.

22 Q. After being in house arrest for that period

23 of time, did you stay there or did you end up leaving

24 at some point?

25 A. We were there in the house, and they came

1 with buses and we all had to get in and we were taken

2 to the Partizan Hall in Foca.

3 Q. Did your whole family get on the buses?

4 A. It did.

5 Q. So just so that I'm clear, that was you and

6 your husband and your daughter and your two

7 grandchildren; you all got on the buses, did you?

8 A. We were all on the bus.

9 Q. Who told you to leave?

10 A. We were told by Drago Djevic.

11 Q. Was there anyone else with him?

12 A. I don't know. He came to our entrance and

13 told us to pack and that they were going to Gorazde,

14 but on the way there, we stopped at Partizan.

15 Q. All right. We'll get to that in a moment.

16 Did you have locks on your doors and keys to your

17 house?

18 A. I did, but they broke down the door. We had

19 a lock and a proper key.

20 Q. What did you do with the keys?

21 A. I handed the keys over.

22 Q. Why?

23 A. To Drago Djevic. He said he needed the keys

24 for a neighbour, to move him in, and I gave him my

25 keys.

1 Q. I'm going to ask you a few questions about

2 your trip to Partizan in a minute, but before I do

3 that, I want to get back to a time before you left your

4 home. Do you recall an occasion -- first of all, do

5 you know a Radovan Govedarica?

6 A. Yes, I do.

7 Q. And was he a friend or a neighbour

8 acquaintance of yours at this time?

9 A. Well, I don't know what he did. I don't know

10 what to say.

11 Q. Did you see him do something before you left

12 for Partizan?

13 A. I saw him with a dredger. The three men were

14 killed and they were taking them off, and they put some

15 branches over the dredger, and he was the driver of

16 that dredger.

17 Q. I'm sorry. You say that there were three men

18 killed. Can you give us a bit more detail about what

19 you saw?

20 A. I just saw some branches over them, through

21 the window, and Mileva told me that those people had

22 been killed and that they were taking them off. This

23 neighbour of mine, Mileva, told me.

24 Q. I see. This dredger, is it sort of like a

25 tractor with a blade on it or -- I don't know what a

1 dredger is. Tell us what a dredger is.

2 A. Yes. It's got that blade, that shovel blade

3 in front to dig the earth with.

4 Q. I see. Do you remember when it was that you

5 were taken --

6 A. Well, I don't know dates, but it was all in

7 these five months. That's when it was.

8 Q. I know that you are unable to assist us with

9 dates, but do you remember when this was in terms of

10 time or seasons when you were put on the buses and

11 taken via Partizan to Gorazde?

12 A. It was about midsummer thereabouts,

13 midsummer.

14 Q. And is this in 1992?

15 A. I don't know dates. The worst thing is that

16 I don't know dates.

17 Q. Was it still in the same year that war broke

18 out?

19 A. Yes, that same year. That's when it was.

20 Q. You've told us that you and your family

21 boarded the buses and went to Gorazde, but en route you

22 went as far as Partizan; is that correct?

23 A. Yes.

24 Q. And Partizan, that's the Partizan Sports Hall

25 in Foca; is that correct?

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1 A. Yes.

2 Q. Can you tell us what happened when you got to

3 Partizan?

4 A. Well, we got to Partizan and all lined up,

5 and about an hour later Misko Crnogorac, the

6 Montenegrin, came and took my child away.

7 Q. When you were all lined up, what happened to

8 you and the others with you?

9 A. Well, they took gold. They took gold off us

10 and took money.

11 Q. Did you know any of the people who were

12 taking gold and money from you?

13 A. I don't know.

14 Q. The people that were doing the searching for

15 gold and money, can you tell us how they were dressed?

16 A. They were in uniform, military uniform.

17 Q. Do you know what kind of military uniform?

18 Are you able to say? Do you know anything about the

19 colours of uniforms?

20 A. Patterned, camouflaged.

21 Q. You referred to someone as a Montenegrin

22 moments ago. How could you tell that person was a

23 Montenegrin?

24 A. That's what they called him, Crnogorac.

25 Q. And that means Montenegrin, does it? I'm

1 sorry, I don't know your language.

2 A. Well, I don't know where he was from, but

3 that's what they called him. That was his nickname.

4 That's how they said. They said "Misko Crnogorac."

5 Q. All right. Did any of these people -- I'm

6 sorry. Do you know if there are different accents or

7 dialects for people from Foca, or Miljevina, or

8 Montenegro?

9 A. I don't know.

10 Q. Do you know a Gojko Jankovic?

11 A. I don't know.

12 Q. Now, you told us that you were lined up and

13 they took things from you, gold and money. Were you

14 personally searched?

15 A. They didn't search me. They took money from

16 my husband, but they didn't touch me or search me.

17 Q. You also, a few moments ago, referred to your

18 daughter. Can you tell us in some detail what happened

19 concerning her?

20 A. Yes, I can. Misko Crnogorac took (redacted) off to

21 Miljevina, to Karaman's House, and it was called a

22 brothel.

23 Q. To whose house was she taken?

24 A. Karaman's House in Miljevina.

25 Q. And how do you know that's where she was

1 taken?

2 A. A lady, [redacted], and her daughter

3 [redacted] told me.

4 MR. RYNEVELD: All right. I wonder if at

5 this point we should move into private session, and I'm

6 going to ask that the last sentence be entirely

7 redacted.

8 JUDGE MUMBA: Yes. And even the previous one

9 because of the names. So those will be redacted. Can

10 we move into private session?

11 [Private session]

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24 [Open session]

25 THE REGISTRAR: [Interpretation] We are now in

1 open session.

2 MR. RYNEVELD: Thank you. I just want to

3 find my place here.

4 Q. Now, where was your daughter when they came

5 for her at Partizan? Was she standing beside you or

6 was she somewhere else?

7 A. I hid her behind my bag in Partizan.

8 Q. And again, please remember not to name her,

9 but --

10 A. I won't.

11 Q. -- exactly how was it that she was found and

12 taken, and can you describe for us the conversation, if

13 any, that took place when she was taken away?

14 A. He came and wanted my daughter to go back to

15 testify that there had been raped women in Miljevina.

16 Q. And did you have a conversation with him

17 about that?

18 A. I pleaded with him not to take my child away,

19 and he told me, "We'll give your child back," but he

20 never gave her back to me.

21 Q. Was she found?

22 A. Yes.

23 Q. And I think you've told us this person's name

24 before. Was she alone when she was found?

25 A. She was with a girl.

1 Q. And was she then taken away by this

2 individual?

3 A. Yes.

4 Q. Was the other girl taken away as well?

5 A. I don't know about that girl, when she was

6 taken away.

7 Q. Did you see how she was taken away?

8 A. He found her hiding behind my bag and he took

9 her by the hand.

10 Q. Was she put on a bus or in a car, or just led

11 away from your view, or what?

12 A. I don't know how he took her out. I didn't

13 see her anymore. I don't know how she was taken off.

14 Q. Just a few more questions, Witness. After

15 this incident where your daughter was taken away from

16 you from Partizan, I understand you continued on with

17 the bus of women towards Gorazde, did you?

18 A. Yes.

19 Q. Again, please don't mention a place, please

20 do not mention a name, but when did you hear from your

21 daughter next? How long after she was led away did you

22 hear from her again?

23 A. Nine months.

24 Q. Again, do not mention a name and do not

25 mention a place, but when you spoke to her, was it in

1 person or on the telephone?

2 A. On the telephone.

3 Q. And did she tell you where she was taken?

4 A. She didn't want to tell me anything, not to

5 worry me.

6 Q. Did she tell you what had happened to her

7 during those nine months?

8 A. She didn't want to tell me anything about

9 that. She just said, "Don't ask me anything about it,"

10 and that she was -- she was very ill, and I didn't want

11 to ask her anything.

12 Q. Did you find out from other people what had

13 happened to your daughter during those nine months?

14 A. Nobody wanted to tell me anything, but I was

15 conscious of everything. I know what happened to her.

16 I'm quite aware of what happened to her.

17 Q. Were you told by someone what happened to

18 her?

19 A. Nobody told me.

20 Q. Again, do not mention a name, do not mention

21 a place. You have subsequently spoken to your daughter

22 in person; is that correct?

23 A. Yes.

24 Q. Did she tell you at that time what had

25 happened to her?

1 A. No, she didn't tell me anything.

2 MR. RYNEVELD: I believe I may have one

3 question. May I just consult?

4 [Prosecution counsel confer]

5 MR. RYNEVELD:

6 Q. Do not mention a name, do not mention a

7 place, but how long after 1992, that is, the year that

8 the war started, did you next see your daughter in

9 person?

10 A. I saw her two years after she was taken

11 away. When she came to Montenegro, then I talked to

12 her.

13 Q. How did she appear to you?

14 A. Skinny, ill.

15 MR. RYNEVELD: Thank you. Those are my

16 questions.

17 JUDGE MUMBA: Any cross-examination?

18 MR. PRODANOVIC: [Interpretation] No

19 questions, Your Honours.

20 JUDGE MUMBA: Mr. Kolesar?

21 MR. KOLESAR: [Interpretation] No questions,

22 Your Honours.

23 JUDGE MUMBA: Mr. Jovanovic?

24 MR. JOVANOVIC: [Interpretation] I have no

25 questions either, Your Honours.

1 JUDGE MUMBA: As there has been no

2 cross-examination, there can't be re-examination.

3 Thank you very much, Witness, for coming and

4 giving us the evidence. You are now free. You can

5 go.

6 MR. RYNEVELD: Thank you, Your Honour. I

7 note the time. I don't propose to start any new

8 witnesses today, unless you wish me to.

9 JUDGE MUMBA: No. We have reached our time

10 for closing our proceedings for today. We will

11 continue tomorrow at 0930 hours. The Court will rise.

12 --- Whereupon the hearing adjourned

13 at 4 p.m., to be reconvened on

14 Thursday, the 6^th day of April, 2000,

15 at 9.30 a.m.

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