1 Wednesday, 2 November 2005
2 [Open session]
3 --- Upon commencing at 9.05 a.m.
4 [The accused entered court]
5 JUDGE AGIUS: Is there a problem or what?
6 I do notice, incidentally, that there is much more light than
7 usual. It's either in the anticipation of all the wisdom that we expect
8 to hear, but there is more light than usual here. So if it's -- provided
9 it's not annoying you, we can carry on. It's not annoying me.
10 Can we start or not? The transcript is rolling, or scrolling, so
11 that means we can start.
12 So, Madam Registrar -- one moment.
13 Yes. Basically, because I was following on the main monitor, our
14 laptops are -- seem to be switched off. The relative -- the monitor
15 accompanying the laptops are switched on, but not the -- can we in the
16 meantime proceed, not to waste time, using the main monitors, Mr. Jones
17 and Mr. Wubben?
18 MR. JONES: Yes. I think what happened is everyone's computers
19 got switched off when the lights went off. We've switched ours back on
20 and rebooted, and so we're now okay, and I presume that probably that
21 would work for Your Honours as well.
22 JUDGE AGIUS: It may be that we have to do that too. All right.
23 Okay. But it's not a problem. There will only be a discrepancy in the
24 lines when it comes to transcript. Otherwise, we should be able to -- out
25 of range, it says, but ... Set monitor to ... I don't know if this is
1 going to work, but ... All right. In the meantime, I'll start working,
3 Could you call the case, please, Madam Registrar.
4 THE REGISTRAR: Good morning, Your Honours. This is the case
5 number IT-03-68-T, the Prosecutor versus Naser Oric.
6 JUDGE AGIUS: I thank you, Madam Registrar.
7 Mr. Oric, can you follow the proceedings in your own language.
8 THE ACCUSED: [Interpretation] Good morning, Your Honours,
9 distinguished gentlemen. Yes, I can follow the proceedings in my own
11 JUDGE AGIUS: Thank you, Mr. Oric. Please sit down.
12 And appearances for the Prosecution.
13 MR. WUBBEN: Good morning, Your Honours, and also good morning to
14 my learned friends of the Defence. My name is Jan Wubben, lead counsel
15 for the Prosecution. I'm here together with co-counsel, Ms. Patricia
16 Sellers, Ms. Joanne Richardson, and our case manager, Ms. Donnica
18 JUDGE AGIUS: I thank you so much, Mr. Wubben, and good morning to
19 you and your team.
20 Appearances for Naser Oric.
21 MS. VIDOVIC: [Interpretation] Good morning, Your Honours; good
22 morning to my learned colleagues from the OTP. My name is Vasvija Vidovic
23 and together with Mr. John Jones, I appear for Mr. Naser Oric. With us
24 are our legal assistant, Ms. Jasmina Cosic, and our CaseMap manager,
25 Mr. Geoff Roberts.
1 JUDGE AGIUS: Thank you, Ms. Vidovic, and good morning to you and
2 your team as well.
3 Any preliminaries?
4 MR. WUBBEN: No, Your Honour.
5 JUDGE AGIUS: None?
6 MS. VIDOVIC: [Interpretation] No.
7 JUDGE AGIUS: The only thing I wanted to tell you, that from the
8 information I am receiving, the documents that were supposed to be handed
9 over to your expert in Sarajevo have been handed over way back on
10 the 25th, I think, of October. However, it seems that your expert gave
11 the indication to Ms. Thompson that he might need more than the one month
12 that you had told us. So if you can exert some pressure on him to try and
13 stick to that month, I think that would be extremely useful. But the
14 procedure and protocol that we laid out, to my knowledge, went --
15 everything went smoothly, ran smoothly, and I will have the final report
16 soon, okay, when Ms. Thompson comes back. But I just wanted you to know
17 about this.
18 So let's bring the witness in.
19 What happened to the electricity? Are we on the main electricity
20 or are we on a -- what do you call it?
21 [Trial Chamber and registrar confer]
22 JUDGE AGIUS: No, no, we don't have the transcript on the
23 LiveNote. We don't have that. And that's because we have to put in a
24 password which we don't have. I mean, it's -- they need to come over and
25 put in the password, yes, key in the password.
1 [The witness entered court]
2 JUDGE AGIUS: To us, it's not creating problems, but if it creates
3 problems to any of you, please let us know.
4 There he is. Basically, we are here and we need ...
5 Yes, Mr. Sacirovic. Good morning to you. Welcome back.
6 THE WITNESS: [Interpretation] Good morning, Your Honours.
7 JUDGE AGIUS: Two things: If there are problems with
8 interpretation at any time, please let us know immediately; and second is
9 that you are still testifying pursuant to your solemn undertaking.
10 Ms. Richardson will continue with her cross-examination.
11 Ms. Richardson, please, and good morning to you.
12 MS. RICHARDSON: Good morning, Your Honours, and good morning to
13 members of the Defence team, and good morning, Mr. Sacirovic.
14 WITNESS: MUSTAFA SACIROVIC [Resumed]
15 [Witness answered through interpreter]
16 Cross-examined by Ms. Richardson: [Continued]
17 Q. I'd like to go over, just briefly, with you this morning some
18 information that you gave on examination-in-chief.
19 MS. RICHARDSON: And Your Honour, at this time, I would ask that
20 the witness be given Prosecution's Exhibit P458.
21 And if I could have the usher's assistance in showing the witness
22 B/C/S ERN number 0359310, and in the English it is page 5, and it
23 continues on page 6 in the English version. And this is the date,
24 December 5th, 1992. It's page 7 in the handwritten of the B/C/S.
25 Q. Now, Mr. Sacirovic, yesterday you indicated when you were asked on
1 examination-in-chief by Mr. Jones about whether or not you knew a
2 Mr. Mahmut?
3 JUDGE AGIUS: Mahmut Jugovic.
4 MS. RICHARDSON: Jugovic.
5 Q. And you indicate -- thank you, Your Honour. You indicated that
6 you did not know him. That would be correct, wouldn't it?
7 A. Yes.
8 Q. Now, it says here that, if you're looking at the B/C/S version, it
9 states here that he resides in the department store. And you also
10 indicated that you yourself was a refugee. Could you tell us whether or
11 not refugees resided in the department store in Srebrenica.
12 A. I did not say that I stayed at this address. I stayed in some
13 miners' cottages that are some 200 metres away from the department store.
14 JUDGE AGIUS: I think there is a problem with interpretation,
15 because Ms. Richardson never suggested that you said that you had resided
16 here. It's about Mahmut Jugovic. She is saying that according to this
17 document, Mahmut Jugovic resided in Robna Kuca, that's the department
18 store, and she is asking you whether you are aware that at any time,
19 refugees were staying -- were living in the department store, not whether
20 you lived there; whether refugees lived there.
21 THE WITNESS: [Interpretation] Yes. I am aware of that. Not only
22 in the department store, but virtually in all the buildings. There were
23 refugees in all the buildings in Srebrenica.
24 MS. RICHARDSON: Thank you, Your Honour.
25 Q. And when you yourself arrived in Srebrenica as a refugee, I take
1 it, how did you locate a place to live? How did you go about finding a
3 A. I arrived from Pale on foot. The War Presidency told me that
4 there was a room in an apartment available, or rather, it was like a
5 bed-sitter that was available in the miners' cottages belonging to the
6 lead mines, lead and zinc mines.
7 Q. And when you say the War Presidency, you're talking about Hajrudin
8 Avdic, the president?
9 A. Yes, because he was my superior.
10 Q. And so he told you this place was available and that you could
11 live there?
12 A. Yes. They put me up there.
13 Q. And did you live there with anyone else?
14 A. No. I was on my own.
15 Q. Now, I would direct your attention to the second part of this
16 entry, what is in relation to the second part, page 7 of the English, and
17 the B/C/S is 03593132. And it begins on page 7 and continues on page 8.
18 I would like to ask you specifically about what is stated here in this
20 Now, the entry does mention that there is a dispute over a fitted
21 carpet. When I say dispute, just take it to mean strictly what is being
22 stated here, that a -- there has been a report filed about carpet being
23 taken. And could you tell us if carpet, whether fitted or not, was
24 something of -- a valuable commodity to refugees?
25 A. Let me tell you that I don't know what this is all about. I never
1 knew Mahmut Jugovic and I have no idea what this is about.
2 Q. Mr. Sacirovic, we are very short on time today, so if you could
3 listen to my questions carefully. I'm not asking whether or not you knew
4 what it was about. My question was specifically regarding the possession
5 of carpet by a refugee.
6 My question is: Would this be considered something valuable to a
7 refugee who had nothing?
8 A. I wouldn't be able to answer that question. Probably it did mean
9 something to them, but whatever I said would merely be speculation.
10 Q. All right. And based on -- well, let me ask you this: Refugees
11 came to Srebrenica. They didn't come with beds or any type of furniture
12 wherein they could sleep, for them to sleep on?
13 A. Yes.
14 Q. And would you agree that carpet is something that would have been
15 able to be placed on a floor to enable someone to sleep on it?
16 A. Well, yes. In that sense. But otherwise, it is not really of any
17 high value, in pecuniary terms.
18 Q. But during those times, when there was very little -- when the
19 refugees came to Srebrenica with very little, you would agree that a piece
20 of carpet which they could use to sleep on would be very valuable to them?
21 A. Well, I don't know what sort of value a piece of carpet could
23 Q. All right. Fine.
24 JUDGE AGIUS: Let's move to something else, Ms. Richardson.
25 MS. RICHARDSON: I was about to move.
1 JUDGE AGIUS: Because at the end of the day, where does it --
2 MS. RICHARDSON: Your Honour, I was about to move on. Thank you.
3 Q. It also states here that clothes and shoes -- clothes and shoes
4 which were used for exchange for grain.
5 Now, my question to you is: Did people in Srebrenica, the
6 refugees and other people who lived there, frequently exchange goods with
7 each other?
8 A. I assure you that I know nothing about this. This was not within
9 the scope of my research.
10 Q. My question is: To your knowledge, having lived in Srebrenica for
11 a lengthy period of time, if people, the people of Srebrenica, the
12 refugees and others, exchanged goods among themselves. Yes or no?
13 A. There were such exchanges, but I assure you that I wasn't
14 interested in them. I was busy doing other things.
15 Q. Thank you.
16 A. What they exchanged, when, and how, I assure you, I know nothing
17 about this.
18 Q. Thank you. I believe you answered my question.
19 Now, on that same page - it's page 8 of the English, and it's the
20 same page of the B/C/S; it's page 9, and it's 03593132 - there is a
21 reference here to a Dr. Ejub. Now, you testified that you spent a
22 substantial amount of time in the hospital. Could you tell us if there
23 was a Dr. Ejub in the hospital.
24 A. Yes.
25 Q. Thank you. I have no further questions on this document.
1 And Dr. Ejub is Ejub Alic; that would be correct, wouldn't it?
2 A. Yes. I know Ejub. He was of rather short stature,
3 broad-shouldered, but I wouldn't like to make a mistake, so that's why I
4 can't tell you for a fact that his last name was Alic.
5 Q. And he did treat people as a doctor in the Srebrenica hospital?
6 A. Yes.
7 Q. You mentioned yesterday that you came to Srebrenica as a result of
8 being called by the president of the War Presidency.
9 A. Yes.
10 Q. And you proceeded to conduct interviews. And I'd like to ask you
11 about the interview that you conducted with Ahmo Tihic.
12 Firstly, let me first determine this: In that interview, we saw
13 you were carrying a weapon. Could you tell us, without -- we don't have
14 that much time, so I won't show you the interview again, but I believe you
15 can probably remember since you were shown yesterday. You had a weapon.
16 Could you tell us what type of a weapon you carried?
17 A. It was my weapon.
18 Q. And where did you get it?
19 A. I bought the weapon.
20 Q. For how much, and from whom?
21 A. I bought the weapon in early 1992, in Sabac.
22 Q. And from whom?
23 A. I bought it from some Serbs who had been on the Vukovar
24 battlefront. I knew that there was a war going on there. I knew that
25 there was a war to break out here. That's why I bought myself a weapon.
1 Q. And what kind of a weapon did you have?
2 A. It was a semi-automatic rifle of Chinese make.
3 Q. And when in 1992? Do you remember what month you purchased this
5 A. In January.
6 Q. Did you have a licence to carry the weapon?
7 A. No, I didn't. Licences were not issued for such types of weapons.
8 JUDGE AGIUS: One moment. If, Madam Vidovic, if you think that
9 the way he has answered this question could in any way expose him to
10 criminal proceedings in his country now, please tell me and we'll go into
11 private session. Yes.
12 MS. VIDOVIC: [Interpretation] I assure you that it would not, for
13 several reasons. One of them is the statute of limitations.
14 JUDGE AGIUS: Let's go ahead.
15 MS. RICHARDSON: Thank you, Your Honour.
16 JUDGE AGIUS: If at any time, Mr. Sacirovic, you are asked
17 questions that if you answer, you could possibly incriminate yourself, you
18 can ask us to exempt you from answering such questions. You do not have
19 an automatic right to be -- to get such exemption.
20 THE WITNESS: [Interpretation] Thank you, Your Honour.
21 JUDGE AGIUS: Yes, Ms. Richardson. I apologise to you for
22 interrupting you, but ...
23 MS. RICHARDSON: Not at all, Your Honour. This is an important
25 Q. Mr. Sacirovic, you stated that you carried this weapon with you
1 when you visited the field, and you also stated that in that video that we
2 saw of Ahmo Tihic, when you were interviewing him, that there was a video
3 operator. Could you tell us if -- I believe his name is Gujic, and please
4 correct me if I'm wrong.
5 A. No. With Ahmo Tihic, there was cameraman Sabahudin Gluhic.
6 Q. And was he the only cameraman that was part of the commission on
7 gathering data on war crimes?
8 A. Yes, he was the only one.
9 Q. And did he also carry a weapon when you went into the field to
10 speak with fighters and civilians?
11 A. No.
12 Q. And how many members of your team would routinely go into the
13 field to interview civilians and fighters?
14 A. Three of them. Edhem Vranjkovina, Sabahudin Gluhic, and I. From
15 time to time, they would go on their own, if I was busy and if they were
16 to film something that was close by. But for the most part, we functioned
17 as a team.
18 Q. And did Mr. Vranjkovina carry a weapon as well?
19 A. Yes.
20 Q. And what kind of weapon did he carry?
21 A. Vranjkovina carried an automatic rifle which he was issued with in
22 the police building. The weapon was in the police station even before the
23 war, because he used to be an active-duty policeman.
24 Q. And when you went into the field, and I believe you said most
25 frequently it would be the three of you, so was anyone else accompanying
1 you to the sites of the civilians and the fighters, other than the three
2 of you?
3 A. No. There was nobody else in our team except for the three of us.
4 Someone might have joined us in the field out of sheer curiosity.
5 Otherwise, the three of us made up the team that was authorised to do the
6 thing that we did.
7 Q. And how did you go about locating -- well, I'll rephrase the
9 You testified that you would routinely go into the field a number
10 of times and you went to different villages in the Srebrenica area. Could
11 you explain to us how it was that you came about making a decision about
12 where, meaning which village, which village to visit to take reports and
14 A. Ms. Prosecutor, we did not make the selection. It was Mr. Avdic,
15 president of the War Presidency, who made the selection, and then we
16 merely implemented his assignment.
17 Q. And he would tell you exactly where to go, what village to go to?
18 A. Yes.
19 Q. And he would tell you where the civilians and the fighters were
21 A. Yes. He told us what had to be done, and circumstances
22 permitting, we did what we were required to do. If the circumstances were
23 not permitting it, like if there was shelling going on or any active
24 fighting, we would come back.
25 Q. And how often -- I'll rephrase the question.
1 How did he go about telling you where to go? Was it in -- was it
2 verbal, verbally, or was it in writing?
3 A. He would mostly do it in writing. He'd write down that we had to
4 film factories, destroyed villages, and so on. And we would act upon
5 these written documents.
6 Q. Now, a number of the civilians you interviewed, we saw yesterday,
7 were in the forest areas were in the forest areas. Could you tell us how
8 it was you knew exactly what area they were located in?
9 A. First of all, the information reached the president of the War
10 Presidency, who would then inform us where we had to go. He would tell us
11 that we had to reach a certain area, enter a wooded area, and interview
12 these people. We would then go to the given village, where the locals
13 were able to tell us where we had to go on further.
14 Q. I see. So the locals -- well, correct me if I'm wrong: The
15 locals would tell you exactly where the people were located; is that it?
16 A. That's how it was for the most part. For example, if there was a
17 village on the ground, such as Biljeg, where Ahmo Tihic was, the president
18 of the Presidency would say, "There's a group up there at Biljeg. Go up
19 and see if they're there." Because people would arrive in the village --
20 people would arrive in Srebrenica and provide information as to where
21 those people were, in the woods and in camps.
22 Q. And yourself and the other members of the team, were you familiar
23 with the terrain of Srebrenica? Did you have any trouble finding the
24 location of the people? Did you need a guide?
25 A. We didn't need a guide because, you know what, Edhem Vranjkovina
1 was born in those parts, precisely where we were filming those women.
2 Sabahudin Gluhic was also born in the Srebrenica area and I wasn't born
3 far. So that we knew all the villages. Mr. Vranjkovina had been a
4 policeman and a hunter, and for him it was no problem to locate a certain
6 Q. And when you arrived, for instance, at a certain place, Biljeg, I
7 take it you -- Biljeg is a fairly large area? Would you describe it as
9 A. Well, you know what, it's a hill, like a mountain. And there are
10 woods there. I can't tell you the surface area in square miles or
11 kilometres, so I can't say exactly what the surface area is or how big it
12 is. It's a wooded area.
13 Q. Okay. But you knew exactly what part of the woods to find Ahmo
15 A. It was Edhem Vranjkovina who knew that, because he was very
16 familiar with that terrain.
17 Q. All right. And during the videotaping of, for instance, the video
18 that we saw of Ahmo Tihic, could you tell us how it was -- well, first,
19 tell us what type of video equipment that was used, and tell us how it was
21 A. Well, let me tell you: A video camera was used. The owner was
22 Sabahudin Gluhic. The batteries were powered in the post office, where
23 there was a kind of improvised mini powerplant, and there was an
24 accumulator there and that was used to fill the batteries for the camera.
25 Q. And how many videotapes do you think you made over a period of
1 1992 and 1993 of civilians and fighters?
2 A. Many. Many tapes were used.
3 Q. And those tapes were made in Srebrenica, as well as in the field?
4 A. Yes. Both in Srebrenica and in the field, and they were all
5 submitted to the president of the War Presidency for safekeeping.
6 Q. Did you also film events in Srebrenica, such as celebrations and
7 other type of events, in 1992, 1993, 1994, and 1995?
8 A. There were various kinds of filming. When the UN forces came in,
9 it was easier to breathe, and it was possible to organise something very
10 simple, some kind of sports, games, and things like that. So we did film
11 those kinds of events too.
12 Q. Now, getting back to the interview that you had with Ahmo Tihic,
13 you mentioned yesterday that on the tape that was shown to us, you
14 addressed Ahmo Tihic as the platoon commander, and you said that you
15 chose --
16 JUDGE AGIUS: Yes. I know what the objection is. It wasn't Ahmo
17 Tihic who was --
18 MS. RICHARDSON: Yes, Your Honour.
19 JUDGE AGIUS: -- platoon commander; it was another young man
20 sitting next to him.
21 MS. RICHARDSON: Yes, Your Honour. I stand corrected.
22 JUDGE AGIUS: I would guess that's what you were going to say.
23 MR. JONES: Yes.
24 MS. RICHARDSON: Thank you, Your Honour.
25 Q. You addressed one of the individuals during your interview of Ahmo
1 Tihic as the platoon commander, which I take it is a very specific
2 military title or position, is it not?
3 A. No. You know what, when I would see someone who was dejected, who
4 was depressed, I did this kind of automatically, mechanically, like: Oh,
5 are you the platoon commander? He wasn't a platoon commander. You can
6 see from the tape itself that he was a young man full of misery. He was
7 lost, more or less.
8 Q. Well, when you addressed him as platoon commander, he didn't
9 correct you, did he? On the tape, we did not see him --
10 A. He didn't correct me, because he probably wasn't even fully
11 conscious of what I'd said. He was traumatised.
12 Q. Or he didn't correct you because you were correct; isn't that a
14 A. No. I was not correct. He was no platoon commander. It was just
15 something I said.
16 Q. Now, you also testified that you interviewed the fighters, and of
17 course you interviewed them about what was going on on the front line. Do
18 you recall that evidence yesterday?
19 A. Yes.
20 Q. And when you received this information, you took it back to
21 Srebrenica; is that correct?
22 A. Yes.
23 Q. And you gave this information to Mr. Hajrudin Avdic, the president
24 of the War Presidency; correct?
25 A. Well, you see, information about the camps -- yes. But as for
1 notes of interviews with the fighters, I didn't write anything down; I
2 simply handed in the videotapes. I didn't hand in any written notes in
3 connection with the fighters at Biljeg, only the videotape, because there
4 was no need, and I didn't have an order or an assignment to interview
5 them. I interviewed them out of pure curiosity, asking whether they were
6 being shelled, whether there were any attacks, and so on. Just like when
7 you meet someone today, you ask them how they're doing, how their family
8 is, and so on.
9 Q. You also testified that you spent a substantial amount of time in
10 the hospital interviewing the fighters; isn't that correct?
11 A. In the hospital, I didn't interview only fighters; I interviewed
12 the wounded. I did not distinguish or have a mandate to distinguish
13 between fighters and others. All those in the hospital were simply the
15 Q. That's what you termed them, as wounded, but you were, were you
16 not, once you began interviewing this person, able to determine whether
17 they had taken part in any fighting?
18 A. Yes. I would learn whether the man had been at a front line
19 somewhere or at home or out in the fields. I wasn't given the assignment
20 of interviewing wounded fighters in particular, but I collected
21 information from all wounded, in order to learn the truth about what had
22 happened, to find out where and how they had been wounded.
23 Q. But in addition to finding out how they were wounded, you also
24 received information, did you not, about what the Serbs were engaged in,
25 for example, shelling, use of artillery?
1 A. Yes. I obtained such information from what side the shooting
2 came, what kind of weapons were used and so on.
3 Q. And indeed, it was from that series of -- those series of
4 interviews over a period of time you were able to confirm yesterday on
5 examination-in-chief a number of the documents regarding the build-up of
6 Serb artillery, where they were located, et cetera?
7 A. I don't really understand your question. Could you please repeat
9 Q. Indeed. Yesterday you were asked a series of questions about the
10 build-up of Serb -- the Serb military in the area of Srebrenica and the
11 Bratunac municipality. Do you recall that?
12 A. Yes.
13 Q. And you testified that one of the ways you learned about the
14 information that had been shown to you and presented to you in documents
15 was because you had interviewed fighters in the hospital, or the wounded
16 in the hospital?
17 A. Yes. I interviewed the wounded in hospital, and I had the most
18 up-to-date information as to what kind of weapons had been used, the
19 weapons that caused the wounding, and so on.
20 Q. All right.
21 A. So it was based on information collected on the spot in hospital.
22 That's how I learnt what kind of weapons the Serbs were using to target
24 Q. And I take it this was very important information, was it not?
25 A. Well, let me tell you: At that time, the situation was very
1 confused. It was critical.
2 Q. Mr. Sacirovic, my question is -- I hate to interrupt you, but if
3 you could answer my question. Was that information about what the Serbs
4 were engaged in militarily important information?
5 A. Yes.
6 Q. And it was important information for all of -- for the organs in
7 Srebrenica? And the organs, by that I mean the War Presidency.
8 A. Yes.
9 Q. And I take it you transferred this information to the War
10 Presidency because it was important.
11 A. To the president of the War Presidency.
12 Q. Indeed. Now, you also testified that you received some of the
13 information via a radio.
14 A. Yes. We heard that information on the Serbian radio. We used an
15 improvised transistor radio, which the electricians made by taking out the
16 motor-powering windscreen wipers on a car and then they would take
17 something from a spinning wheel, a part from a spinning wheel, and this
18 wheel would be used to generate electricity for the transistor radio. And
19 we would listen to the broadcasts of Serbian Radio Bratunac. Sometimes in
20 the afternoon or the evening, whenever they were transmitting their news
21 broadcasts, and a group of us would gather around the transistor radio to
22 hear what they were saying.
23 Q. And where was this transistor radio located? What building?
24 A. There were several people who had those transistor radios. They
25 were just ordinary transistor radios, like the ones that every household
1 has. And they would take it outside, into the park, and they would turn
2 this wheel to power it, and people would gather around to listen.
3 Q. So with this transistor radio, were you only able to listen to
4 what was broadcast publicly or were you also able to listen to what the
5 Serbs were discussing, the different Serb units, among themselves?
6 A. No. No. It was just an ordinary transistor, where you would tune
7 in to a particular station and then listen. You'd tune in to Serb Radio
8 Bratunac. It wasn't a radio station of the kind you mean. They were just
9 ordinary transistor radios, like the ones you can buy any day, anywhere.
10 Q. And the radio that you're -- the news that you heard, are you
11 saying that it was in regards to the Serb build-up in the area? Was it
12 military information?
13 A. The information included both military and the civilian
14 information. Very often, they would say they were receiving
15 reinforcements, probably in order to raise the morale of their men, saying
16 that certain units had arrived from Serbia as reinforcements, and so on.
17 Q. Now, the times that you went into the field, you indicated that
18 you carried a weapon and so did the other member of your team, just in
19 case of attacks, I take it. Were you ever attacked or ambushed?
20 A. Well, you know, we were very cautious. If the situation was at
21 all dangerous, we would delay the filming. We would postpone it. So
22 there was never an occasion when we were in real danger. We were very
23 careful about that. It was better to go back than to expose our lives to
25 Q. Well, my question was: Were you ever attacked? Did you ever have
1 cause to use your weapon or the other person that you were with, against
2 being attacked by Serbs, that is, of course?
3 A. No, never.
4 Q. Now, I'd like to get back, just briefly, to --
5 A. No, no, never. We never had any occasion to use our weapons. We
6 never ran into an ambush and had to use the weapons.
7 Q. Getting back briefly to what you testified to yesterday about your
8 appointment by the president of the War Presidency.
9 I'd like to talk to you about the other people. I think you've
10 already mentioned two, two others, who were cameramen. Was there also a
11 female there working with you?
12 A. No. No. In our team, there was no woman. There were just the
13 three of us.
14 Q. All right. Now, you were -- your team, that is, the commission
15 for collecting data on war crimes, was under the communication and
16 information division of the War Presidency. It was a department within
17 the War Presidency. Would that be correct?
18 A. Yes.
19 Q. And this department was supervised by Hamed Alic, the entire
21 A. Yes.
22 Q. Now, let's talk about the other individuals in the department of
23 communication and information. Are you familiar with Ibrahim Becirovic?
24 A. I do know Ibrahim Becirovic, but I don't know what role he played.
25 Q. All right. Were you aware that he operated -- that he operated a
1 radio and that individuals seeking to contact members of their family in
2 Tuzla and other areas were able to speak to them over this radio in
4 A. No, I'm not aware of that. I know that Hamed Alic was in charge
5 of that radio station, which was located in the Srebrenica post office in
7 Q. So, well, did you have occasion to see Mr. Becirovic at all in
9 A. Yes. I remember him vaguely. I don't really know him very well.
10 He is the brother of Ramiz Becirovic, and that's why I know who he is.
11 But I don't really know him really well, and his role is something I
12 really don't know about.
13 Q. So you don't know what he did in Srebrenica during 1992 and 1993?
14 A. No.
15 Q. Now, other than the three members of your commission, were you
16 aware of other members, individuals, who worked under Hamed Alic as part
17 of the communication and information system, or department?
18 A. I'm not aware of that. The decision on my appointment was signed
19 by the president of the War Presidency, Mr. Hajrudin Avdic. The service
20 for communications and information was also subordinate to the War
21 Presidency, but I always took the information I obtained to Mr. Avdic
23 Q. I understand that. I'm seeking to determine whether or not you
24 were aware of other members working under the communication and
25 information system supervised by Mr. Hamed Alic.
1 So my question is: With respect to other people, other than those
2 of your commission, were there other people being supervised by Hamed Alic
3 under the department of communication and information service?
4 A. Madam Prosecutor, I really don't know.
5 Q. Okay. Now, you indicated or testified that Mr. Hamed Alic
6 maintained an office in the same building, the same floor, as you did; is
7 that correct?
8 A. No. Hamed Alic had his office in the municipal -- or rather, in
9 the post office building - excuse me - whereas my office was in the
10 municipal building. The distance between the post office and the
11 municipal building is 400 or 500 metres. Hajrudin - excuse me - Hamed
12 Alic did not have an office in the municipal building, but in the post
13 office building.
14 Q. Yes. I misspoke. I do recall that you did say that he had an
15 office in the PTT building.
16 Now, it was Mr. Hajrudin Avdic who had an office in the municipal
17 building, where you worked; is that correct?
18 A. Yes, on the same floor. It was the second floor.
19 Q. On the second floor. Who else occupied the second floor, other
20 than yourself and Hamed Alic?
21 A. Dzemaludin Becirovic and Hamdija Fejzic were there quite often. I
22 would drop by quite often, as well as my team, and that was the part of
23 the municipal building that I remember.
24 Q. Okay. I take it that you were often out of the office during the
25 times that you were interviewing people in the field and in the hospital
1 as well?
2 A. I would go to the office quite often, although I would not spend a
3 full eight hours there. I would hand in my documentation over there and
4 that would be our point of departure for me and my team when we would go
5 out into the field. Therefore, although I spent most of my time out in
6 the field, I also spent some time in the office. Whenever I was in town,
7 I was there.
8 Q. And you also spent some time when you were in town at the
9 hospital, as you testified before, a substantial amount of time, I believe
10 you stated.
11 A. Well, yes. As soon as I found out about the arrival of new
12 wounded, I would go over there.
13 Q. And who else was in the PTT building with Hamed Alic?
14 A. I only know about Hamed Alic being there. Occasionally, I would
15 go to visit Hamed Alic in the post office building, but I would go
16 directly to his office, where the radio was.
17 Q. Were you aware that the Srebrenica Territorial Defence also
18 occupied that office, that building?
19 A. No, I was not.
20 Q. Okay. Did you run into Ramiz Beckovic [sic] or Osman Osmanovic in
21 that building whenever you visited?
22 A. No, I didn't. I saw Ramiz Becirovic in Opetci, in his hometown in
23 Suceska, whereas for Ramiz, I never saw him at all. I wasn't aware of
24 anyone -- or rather, I didn't know anyone who was there except for Hamed
1 Q. And I take it you're familiar with Ramiz Becirovic. Do you know
2 what his role was in Srebrenica during 1992 and 1993?
3 A. I didn't know what his role was. I told you that I got to know
4 Ramiz Becirovic when I went into the field in the month of August and it
5 was in Opetci in Suceska, his native village. That was where I met him,
6 in his house, because he hails from Opetci. We were going there to film a
7 school that was destroyed by shelling in Kamenica, and that was how I got
8 to meet him.
9 Q. Do you know Osman Osmanovic?
10 A. No.
11 Q. And I take it you did not go to the PTT building very often?
12 A. I would go there from time to time, when necessary. I wasn't
13 there every day.
14 Q. Did you go once a week, twice a week, once a month?
15 A. It depended. Sometimes once fortnightly, once monthly, but I
16 would not stay there for too long. Whenever I went there, I simply had to
17 consult Hamed on a matter, and that would be the whole purpose of my visit
18 to the post office.
19 Q. And during that time that you visited the post office, I take it
20 this is not where the briefings that you said you attended with Mirzet
21 Halilovic took place.
22 A. No.
23 Q. Those briefings that you testified to yesterday or the day before,
24 that took place with Mr. Bogilovic and Mirzet Halilovic and yourself, took
25 place in the building you worked in, the municipal building; is that
2 A. Yes. In the office of the president of the War Presidency,
3 Mr. Hajrudin Avdic.
4 Q. I'd like to talk to you about those meetings that you testified
5 about. You testified that meetings were held and that during those
6 meetings Mirzet Halilovic was present and you also brought his report.
7 And that is Mirzet Halilovic being the commander of the military police.
8 Do you recall that evidence?
9 A. Yes.
10 Q. And during that -- how often would you say you attended briefings
11 where Mirzet Halilovic was present, Mr. Bogilovic -- and Mr. Bogilovic
12 A. Quite often. I already told you that Becir Bogilovic was wounded
13 and he came to the municipal building but rarely. But Mirzet Halilovic
14 and Nurija Jusufovic did come. Mirzet Halilovic was the chief of the
15 military police, whereas Nurija Jusufovic was the commander of the
16 civilian police. They delivered their reports to the president of the War
17 Presidency, as did I. To be precise, I believe we had an exact time when
18 we had to hand them over. That was at 9.00 in the morning. And then we
19 would receive assignments, if any. If, for instance, my commission had to
20 go somewhere, we would receive an order signed by the president, and the
21 same probably went for Mr. Mirzet Halilovic and Nurija Jusufovic, either
22 or both of them.
23 Q. We're going to get back to those meetings in a moment. You said
24 that Mr. Bogilovic was wounded. Can you tell us if you know how he was
25 wounded, where? Where, not meaning the part of the body, but what area
1 was he in when he was wounded.
2 A. He was wounded in the leg. I cannot vouch whether it was the left
3 or the right leg. I only know for a fact that he was wounded.
4 Q. I'm sorry. I actually didn't mean the part of the body, but do
5 you know how he was wounded?
6 A. I'm not aware of that. I don't know how and where he was wounded.
7 I don't know.
8 Q. And other than the function that he served on the War Presidency,
9 do you know if he had any other function in Srebrenica, Mr. Bogilovic?
10 A. Bogilovic was a member of the War Presidency and chief of the
11 civilian and military police in Srebrenica in the period from -- to 1993.
12 THE INTERPRETER: Could the witness repeat from which year,
14 JUDGE AGIUS: Yes. The interpreters did not catch which period
15 this -- it starts from. In other words, until 1993, but from which year?
16 THE WITNESS: [Interpretation] From 1992, Your Honour.
17 JUDGE AGIUS: Thank you.
18 MS. RICHARDSON:
19 Q. And as far as you know, he didn't carry out any other activities
20 that were not related to those of the War Presidency?
21 A. Except for the fact that he administered the two police
22 departments, civilian and military police, he was member of the War
23 Presidency. He had under his jurisdiction the two commanders of the
24 civilian and military police, Mirzet Halilovic and Nurija Jusufovic.
25 Q. Did you see an order where Mr. Becirovic was made the chief of the
1 military police, subordinating Mirzet Halilovic to him?
2 A. I knew that there was an order, or rather, a decision by the
3 president of the War Presidency, Mr. Hajrudin Avdic, whereby Becir
4 Becirovic was appointed chief of the civilian and military police in
5 Srebrenica. I saw the decision with my own eyes. It was appended, along
6 with all the other decisions, on the announcement board in the corridor of
7 the municipal building.
8 Q. And what other announcements did you see there, in addition to
9 this one?
10 A. Among others, there was the decision appointing me into the
11 commission, the decision whereby Hamed Alic ran the communications and
12 information service, and so on. I cannot recall all the decisions. These
13 are the ones I remember. All the decisions adopted would be appended on
14 the board.
15 Q. And was this board -- where was this board located?
16 A. It was located in the corridor of the municipal building, but it
17 was downstairs, on the first floor.
18 Q. Did you see any orders regarding the OS Staff?
19 A. No.
20 Q. Now, you said you attended meetings where Mr. Jusufovic was
21 present and Mr. Halilovic, as well as Mr. Bogilovic, and you handed in
22 reports. Did you review the reports handed in by Mirzet Halilovic?
23 A. Yes.
24 Q. And what did those reports say?
25 A. I saw the reports, but I did not read anybody else's reports.
1 After all, it was not within my possibility to read anybody else's
2 reports. I would hand in my reports and take any assignments or orders
3 that were there for me. I did not linger there. I was not a politician
4 or a member of the War Presidency. I was an operative member of staff who
5 had to act upon the orders given. Therefore, I did not read reports from
6 either the civilian or the military police, or the ones submitted by Hamed
7 Alic. They were not within my reach.
8 Q. Now, in addition to being the commander of the military police,
9 did Mirzet Halilovic engage in any other function during 1992 or into
11 A. In early 1992, I saw him at Pale, where he had his own
12 self-organised group of fighters. I don't know about any other functions
13 he may have had.
14 Q. And the group of fighters that he had in Pale, do you remember how
15 many men this included?
16 A. At the time I was there, I believe he had 20 to 25 men in his
18 Q. And he was the leader of the group; correct?
19 A. Yes.
20 Q. And after he was called to Srebrenica to be appointed the
21 commander of the military police, did this group continue to exist, the
22 group of men from Pale? Do you know?
23 A. I assure you that I know nothing about the later developments,
24 because I went over to Srebrenica.
25 Q. So you don't know if this group continued to exist and whether or
1 not there was another leader or whether they engaged in fighting in the
2 Srebrenica, Bratunac municipality?
3 A. I assure you that I do not know what happened to the group later
5 Q. Did you attend any War Presidency meetings during the time that
6 you were in Srebrenica, 1992 and 1993 specifically?
7 A. No, because I was not a member of the War Presidency. Only
8 sometimes, if there was an order of the president of the War Presidency to
9 film a meeting, I would go over there -- rather, I wouldn't go there
10 myself; instead, our cameraman, Sabahudin Gluhic, would go there. They
11 didn't even need Vranjkovina to go over there. They only needed the
12 cameraman, Gluhic, to film the meeting, according to the president's
13 orders. He would simply say, "We need a cameraman tomorrow," and we would
14 act upon his order.
15 Q. And I believe you testified that the War Presidency did have
17 A. Yes. But quite rarely, because of the situation on the ground.
18 And, as I've already indicated, that when there was need for a meeting to
19 be filmed, the president would issue an order accordingly. The meetings
20 could not be held as per normal, because the circumstances did not permit
22 Q. Well, given the fact that you were not a member of the War
23 Presidency, and you just testified that you were not invited, it's a
24 likelihood, is it not, that there were meetings of the War Presidency that
25 you were not aware of?
1 JUDGE AGIUS: Yes, Mr. Jones.
2 MR. JONES: Surely firstly that's an invitation to speculation,
3 since he said that he didn't attend such meetings, and particularly when
4 it's put that there was a likelihood that there were meetings of which he
5 was unaware. That's obviously going to be an invitation for him to
6 speculate about something he doesn't know.
7 MS. RICHARDSON: Your Honour, I believe the witness has testified
8 that -- about the lack of meetings. So -- and he's also testified that he
9 was not present on a number of other occasions. So I think logic dictates
10 that there could have been meetings held outside of his presence that he
11 did not know of, and I think that's a fair question to put to the witness.
12 JUDGE AGIUS: Yes. Go ahead. Go ahead. Could you please repeat
13 the question.
14 The important thing is, Mr. Sacirovic, that you do not speculate.
15 You just answer the question if you are in a position to answer it. If
16 you're not aware of any such other meetings, then you are to tell us, "I'm
17 not aware of any such other meetings." Otherwise, if you are aware, more
18 or less you give us an indication of what your knowledge consists of, but
19 not beyond that.
20 I will read out Ms. --
21 THE WITNESS: [Interpretation] Thank you, Your Honour. At no time
22 did I wish to speculate. I simply want to tell the truth. I am aware of
23 the fact that I have given a solemn oath. I only wish to clarify matters
24 to you, Your Honours, the OTP, and the Defence, and to present the actual
25 truth of what had happened in Srebrenica. And at all times, I wish to
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
1 give accurate and truthful answers, without distinguishing between the
3 JUDGE AGIUS: I do not doubt that at any moment, Mr. Sacirovic.
4 Now, the question that Ms. Richardson is putting to you is the
5 following: You have told us of your knowledge about some meetings of the
6 War Presidency for which your troop were invited to film part of the
7 proceedings. So those meetings you are aware of. Are you aware also of
8 other meetings of the War Presidency that you or your group were not
9 invited to, but which you are still aware of as having taken place? If
10 you are, could you give us an indication of where we stand, how many of
11 such meetings of the War Presidency. This is basically what
12 Ms. Richardson is trying to seek from you.
13 THE WITNESS: [Interpretation] Your Honours, distinguished ladies
14 and gentlemen from the Defence and the OTP, I knew only of those meetings
15 for which the president would issue us an order to send a cameraman over.
16 There were only several such meetings. For the rest, I did not know
17 whether or when they took place.
18 MS. RICHARDSON: Thank you, Your Honour.
19 JUDGE AGIUS: Do you want to pursue the matter any further?
20 MS. RICHARDSON: No, indeed, Your Honour, that answers the
22 JUDGE AGIUS: -- You may, of course, but I don't think it's the
24 MS. RICHARDSON: No.
25 JUDGE AGIUS: I think it's the case of moving to the next
2 MS. RICHARDSON: Indeed, Your Honour.
3 Q. Now, Mr. Sacirovic, were you aware of whether or not the president
4 of the War Presidency, Mr. Avdic, met with members of the armed forces of
6 A. No, I was not aware of that. I was not even aware of any armed
7 forces. I was only aware of armed groups.
8 Q. And when you came to Srebrenica in June, I believe, of 1992, were
9 you aware that there were different Territorial Defence groups from the
10 various areas who had been put under the command of Naser Oric?
11 A. I did not arrive in Srebrenica in June. I arrived in early July
13 Q. Excuse me. Thank you.
14 A. However, I do know that Hakija Meholjic had a group, that Akif
15 Ustic had a group, and that almost every village had its own
16 self-organised group. I was not able to meet with all these people and
17 groups at once. I got to know them gradually, as I received assignments
18 and went out into the field. But there were organised groups, as such.
19 Q. Now, you testified --
20 JUDGE AGIUS: One moment, Ms. Richardson, because he hasn't
21 answered your question completely, at least.
22 The question that Ms. Richardson asked you, Mr. Sacirovic, had two
23 matters to be addressed. One was whether you were aware that there were
24 different Territorial Defence groups from various areas, and I think more
25 or less you have answered that.
1 But Ms. Richardson also, in her question, had qualified these
2 different Territorial Defence groups from various areas as being the ones
3 that had been put under the command of Naser Oric, and that part of the
4 question you did not answer.
5 So I repeat the question: You are aware of the existence of a
6 number of Territorial Defence groups from various areas. Are you aware
7 also that these had been put at any time under the command of Naser Oric,
8 but when you first arrived in July of 1992 in Srebrenica?
9 Yes, Mr. Jones.
10 MR. JONES: Yes. And the witness certainly didn't accept the
11 existence of a number of Territorial Defence groups.
12 JUDGE AGIUS: No.
13 MR. JONES: He was very specific that it was armed groups.
14 JUDGE AGIUS: I grant you that, certainly, Mr. Jones.
15 MR. JONES: And then if Ms. Richardson wishes to put to him that
16 they were under the command of Naser Oric, that's fine. He did answer
17 these questions in examination-in-chief.
18 JUDGE AGIUS: Yes, but she has put her --
19 MR. JONES: It's a question he's already answered in
20 examination-in-chief. But if she wishes to put it directly, then fine,
21 but let's have the case being put to him.
22 JUDGE AGIUS: It is also related to the time of his arrival in
24 So when you first arrived in Srebrenica in July of 1992, were you
25 aware of the existence of groups from various areas having been put under
1 the command of Naser Oric or not?
2 THE WITNESS: [Interpretation] Your Honour, as far as I know, not a
3 single group was under the command of Naser Oric except for a group of 20
4 to 30 fighters who were with Naser. Not a single group was under Naser
5 Oric's command in that period.
6 JUDGE AGIUS: Yes.
7 Ms. Richardson.
8 And thank you, Mr. Jones.
9 MS. RICHARDSON: Thank you, Your Honour.
10 Q. Now, just getting back, just briefly, to the bulletin board you
11 said existed in the municipal building. Did that bulletin board list the
12 members of the War Presidency, and if so, did it list Naser Oric as a
13 member of the War Presidency?
14 A. I'm not aware of that.
15 Q. And I take it --
16 JUDGE AGIUS: This is a little bit vague and it's because of the
17 way you put the question. It's not the witness's fault.
18 MS. RICHARDSON: Your Honour, I can rephrase the question.
19 JUDGE AGIUS: Because I think you ought to, because one question
20 is whether on the bulletin board there was ever posted the list of members
21 of the War Presidency. And secondly, if there was, and you're tying it up
22 to the existence of this notice, did the name of Naser Oric appear on it
23 as a member of the War Presidency. So I think there are two questions.
24 MS. RICHARDSON: There are two questions, and I'll separate
25 them --
1 JUDGE AGIUS: And I don't know which one he answered.
2 MS. RICHARDSON: Indeed. Indeed. Which is always the problem
3 when you put more than one.
4 Q. First, Mr. Sacirovic, did you see on the bulletin board a notice
5 or a document indicating the members of the War Presidency?
6 A. No, I didn't.
7 JUDGE AGIUS: All right. And therefore the second part --
8 MS. RICHARDSON: Indeed, Your Honour. Indeed. And I'm not sure
9 what time the break will be today.
10 JUDGE AGIUS: Any time it is convenient for you. We will break
11 now, if you want to.
12 MS. RICHARDSON: Yes, this is fine.
13 JUDGE AGIUS: All right. So we'll have a 30-minute break starting
14 from now. Thank you.
15 --- Recess taken at 10.30 a.m.
16 --- On resuming at 11.07 a.m.
17 JUDGE AGIUS: Yes, Ms. Richardson.
18 MS. RICHARDSON: Yes, Your Honour. I apologise. Thank you.
19 Q. Now, Mr. Sacirovic, before the break, we were discussing -- you
20 were giving evidence about having seen an order from the War Presidency in
21 the municipal building, and I asked whether or not you had seen an order
22 where Naser Oric was appointed to the War Presidency, and you said no.
23 MS. RICHARDSON: Your Honour, at this time I would like the
24 witness to be shown Prosecution's Exhibit 42. 42E, I have it as.
25 JUDGE AGIUS: It's not on my list.
1 MS. RICHARDSON: Your Honour, it is on Sanction, and I could be
3 JUDGE AGIUS: Okay, but I just remark that it's not on my list;
4 that's all. It would be on other lists.
5 MS. RICHARDSON: Your Honour, I believe the Defence used is it,
6 but I may be mistaken.
7 JUDGE AGIUS: I don't know. I don't remember.
8 MS. RICHARDSON: I can't remember myself, but it is on Sanction
9 and I can --
10 JUDGE AGIUS: Yes, it was used as the third document by the
12 MS. RICHARDSON: Yes. I believe it is on Sanction now.
13 I believe we have if now.
14 JUDGE AGIUS: Yes, we are seeing, but I want to know what the
15 witness is seeing.
16 MS. RICHARDSON:
17 Q. Do you recall, Mr. Sacirovic, having seen this document yesterday?
18 JUDGE AGIUS: Is it in his language, Madam Usher?
19 A. Yes, I can see it, Your Honour.
20 MS. RICHARDSON:
21 Q. I just have two questions for you with respect to this document.
22 As you look at article number 4, do you see the name Naser Oric there?
23 A. Yes.
24 Q. And it does state that he has been appointed a member of the War
25 Presidency, does it not, along with the other individuals listed?
1 A. Yes.
2 Q. Now, you mentioned already to us that you knew Mr. Hajrudin Avdic.
3 Did you know Hamdija Fejzic?
4 A. Yes.
5 Q. And were you aware of his position on the War Presidency, as
6 stated here, that he was the executive -- he was the chairman of the
7 Executive Committee?
8 A. Yes.
9 Q. And Resid Efendic, and I don't want to belabour the point: Did
10 you know him and did he actually work as the secretary of the War
12 A. I remember him very vaguely. I knew him only a little.
13 Q. Fair enough. And of course you mentioned Becir Bogilovic. Did
14 you also know Jusuf Halilovic?
15 A. Yes.
16 Q. And it states that he was the commander of the civilian protection
17 staff. Do you recall that being his role?
18 A. Yes.
19 Q. Now, with respect to Mr. Bogilovic, it states under Article 10,
20 that's page 2 of the English, that he was appointed the chief of the
21 public security station. Now, and this document on its face speaks for
22 itself, but there's no information here, just for the record, that he is
23 also the commander of the military police and the civilian police. It
24 just simply states, if you agree with me, that he's the chief of the
25 public security station.
1 A. In Article 10, it says that Becir Bogilovic is appointed chief of
2 the public security service. The civilian and military police fell within
3 its competence. The word "chief" means that he was the commander.
4 Q. I understand, but that's not in this document, is it, what you've
5 just told us?
6 JUDGE AGIUS: He's telling you that it is implied, basically.
7 MS. RICHARDSON: No, no. I'm just establishing for the record
8 that --
9 JUDGE AGIUS: Yes, go ahead.
10 MS. RICHARDSON: Indeed. Okay. Your Honour, I have another
12 JUDGE AGIUS: Because I think it's clear, what he's telling you.
13 He agrees with you, but he's also telling you that basically the public
14 security service, that's how it was translated to us, not station, covered
15 both, according to him.
16 MS. RICHARDSON: Indeed.
17 Q. Now, the information you gave us about the fact that the
18 civilian - excuse me - the public security service covered both civilian
19 and military police, where did you get that information?
20 A. I knew that because when I handed in my reports to Mr. Hajrudin
21 Avdic, I saw Becir on occasion handing in his reports, and that's when I
22 saw that he was competent to hand in reports for both the civilian and the
23 military police. In his absence, Commander Nurija Jusufovic brought in
24 reports concerning the civilian police, and Mirzet Halilovic did the same
25 for the military police. And these were the two branches falling within
1 the competence of Becir Bogilovic.
2 Q. So that -- so that we all understand your testimony: It's that
3 because he handed in the reports for Mirzet Halilovic and the -- and
4 Mr. Jusufovic, that this was why you assumed that he was the person over
5 the military and the civilian police?
6 A. Madam Prosecutor, that's not a reason; that's a fact. Becir
7 Bogilovic was the superior of Becir Bogilovic [as interpreted] and Nurija
8 Jusufovic. He was their chief.
9 Q. You didn't see this on any documents anywhere?
10 THE INTERPRETER: Interpreter's correction, Mirzet Halilovic.
11 A. I didn't see that in the document. I know that from practice. I
12 knew that from the situation. Because I was there in Srebrenica. I was
13 in the municipal building. I was present during conversations. And I can
14 assert with certainty that Becir Bogilovic was the superior of both Mirzet
15 Halilovic and Nurija Jusufovic.
16 Q. I take it that prior to your being made president of the
17 commission, prior to the war, you had not worked with or been a member of
18 the War Presidency in the past, had you?
19 A. Neither before nor after.
20 Q. So whatever information you have is not based on your -- I'll
21 withdraw that question.
22 MS. RICHARDSON: Thank you. I'm actually finished with that
23 document. If Madam Usher could remove it from the witness at this time.
24 Q. Now, you testified that Mr. Naser Oric -- that the groups, in
25 fact, had not -- were all independent and they were not organised; is that
2 A. Every group was self-organised and they were not under the command
3 of Naser Oric.
4 Q. All right.
5 MS. RICHARDSON: At this time, Your Honour, I'd like Prosecution's
6 Exhibit 73 be put to the witness, and I will also be using 74 and
7 Prosecution's Exhibit 4E as well. So the first document to be shown to
8 the witness is Prosecution's Exhibit 73, and it will be on Sanction.
9 Q. Now, Mr. Sacirovic, if you just look at this document, it's dated
10 May 20th. It's from the Republic of Bosnia and Herzegovina, Srebrenica
11 Territorial Staff. There is a decision, the Srebrenica municipal TO staff
12 is hereby formed.
13 Now, I would just like to ask you first: On May 20th - excuse
14 me - I'll rephrase.
15 Were you aware that on May 20th the Srebrenica municipal TO staff
16 had been formed?
17 A. No.
18 Q. And have you ever seen this document before?
19 A. No.
20 Q. Okay. Reading further, the following -- under II: "The following
21 shall be appointed to the Srebrenica TO staff." It lists Naser Oric from
22 Potocari, as Commander of the Srebrenica TO staff. It also goes on to
23 list Akif Ustic, Zulfo Tursunovic, Hamdija Fejzic, Sevket Dzozic, Becir
24 Bogilovic, and Ahmo Tihic. Now, I believe you testified that you know
25 Zulfo Tursunovic, you know Becir Bogilovic, and of course you know Ahmo
1 Tihic. You testified that you also know Hamdija Fejzic. Did you know
2 Sevket Dzozic?
3 A. No.
4 Q. Akif Ustic, he was from Srebrenica, and he had a group of his own,
5 did he not?
6 A. Yes.
7 Q. And you also testified that that's the same for Zulfo Tursunovic?
8 A. Yes.
9 Q. And Hamdija Fejzic, were you aware whether or not he was a member
10 of the Bajramovici group?
11 A. No.
12 Q. Do you know if he was from Bajramovici?
13 A. Yes.
14 Q. And on the second page, it states, under III: "The decision shall
15 enter into force on the day of its adoption." I won't belabour all of the
16 information. But the very last sentence reads, and I'll just go down to
17 the last two lines: "A single military command of all armed groups shall
18 be formed under the name of Srebrenica TO," and it is signed by the
19 Commander, Srebrenica TO staff. And the word "Naser" appears, and there's
20 a stamp on the original. There is a recording clerk, who is Hamdija
22 Were you aware that Naser Oric had been made commander of the
23 Srebrenica TO staff, including all of these other groups?
24 A. No.
25 Q. Thank you.
1 MS. RICHARDSON: Now, if the usher could show the witness P74.
2 This document, for the record, is also dated the 20th of May, Bajramovici,
3 1992, Republic of Bosnia and Herzegovina, Srebrenica TO territorial staff.
4 It says "a decision." Decision, under I, Becir Bogilovic, from
5 Srebrenica, a policeman, the former commander of the Srebrenica SJB public
6 security station, is appointed temporary police commander in the town of
8 Q. Now, first off, did you know about this decision from,
9 specifically, the territorial staff, involving Mr. Bogilovic?
10 A. No.
11 Q. Now, to what's -- I'll rephrase.
12 Under the statement of reasons, I will go down to the -- three
13 lines from the paragraph itself. It says that: "Bogilovic shall be
14 temporarily accountable for his work to the Srebrenica TO staff to the
15 above bodies once they have been set up, and to the authorised
16 institutions in Tuzla and Sarajevo when they too have been set up."
17 So were you aware that he, Mr. Bogilovic, would be accountable to
18 the TO staff in any capacity?
19 A. No.
20 Q. All right. I'd like to show you the next document, Prosecution's
21 Exhibit 4E. For the record, it is Republic of Bosnia and Herzegovina,
22 Srebrenica TO, Srebrenica, the 15th of June, 1992.
23 JUDGE AGIUS: 4E. E to me means English, no?
24 MS. RICHARDSON: Yes. Your Honour, it does.
25 JUDGE AGIUS: All right. So I could --
1 MS. RICHARDSON: I should write E and I'm repeating what I see
3 JUDGE AGIUS: I could live with that. It saves me having to try
4 and understand Serbo-Croat.
5 MS. RICHARDSON: Thank you, Your Honour.
6 JUDGE AGIUS: But I want to make sure that the witness is being
7 shown something different.
8 MS. RICHARDSON: Indeed, Your Honour. And the witness should be
9 shown ERN 01239504.
10 Q. Now, Mr. Sacirovic, have you seen this document before?
11 A. No.
12 Q. And I will read the order itself, which is signed by Naser and
13 there's a stamp on the original. It says "Commander Srebrenica TO. With
14 the aim of confronting the aggressor and engaging in a struggle for
15 liberation" --
16 JUDGE AGIUS: One moment. Do we have it on Sanction or not.
17 MS. RICHARDSON: We're working on it, Your Honour. I'll take a
19 JUDGE AGIUS: In the meantime, you can start reading, I think.
20 MS. RICHARDSON: All right. Okay
21 Q. "All" -- "With the aim of confronting the aggressor and engaging in
22 the struggle for liberation, all the local leaders of self-organised armed
23 groups are ordered to immediately commence developing the organisation and
24 establishment of the Srebrenica TO units, in particular...", and then it
25 lists: "Srebrenica" TO to be organised by Naser Oric, Potocari, Suceska,
1 Omasce TO," et cetera.
2 And I would draw your attention to number 10. "Services to be
3 attached to Srebrenica TO." Do you see that? Under A it says "war
4 hospital to be set up by Avdo Hasanovic."
5 A. Yes, yes, I see it.
6 Q. Thank you. Now, you spent a lot of time in the hospital. Was
7 Mr. Avdo Huseinovic the head of the hospital or the director of the
8 Srebrenica hospital?
9 A. I'm not aware of that.
10 Q. But he was working in the hospital, was he not, one of the
12 A. Yes. He did work in the hospital. I don't know about him being
13 some kind of head or chief.
14 Q. All right. Fair enough. Now, under number -- under B it
15 says: "Signals and information service to be set up by Hamed Halilovic."
16 Thank you. Hamid Alic, Your Honour. I stand corrected.
17 Were you aware that the Srebrenica TO established a signals and
18 information set-up information service which was head up -- or set up by
19 Hamed Alic?
20 A. I'm not aware of that. On my arrival from Pale to Srebrenica, in
21 July, I found Hamed Alic already performing that duty. The rest I'm not
22 aware of, who appointed him or when. That I'm not aware of.
23 Q. But you were aware that he worked for the War Presidency, but you
24 were not aware that he was also part of the Srebrenica TO, as a member,
25 who would be heading up the signals and information service?
1 A. Yes.
2 Q. Okay. Now, C --
3 MR. JONES: The interpretation is still going. I heard the
4 witness saying yes while the interpretation is still going.
5 JUDGE AGIUS: Thank you for pointing that out. Let's make sure
6 that we've got it all right.
7 I will repeat to you the question, please, Mr. Sacirovic, and then
8 you answer slowly, and make sure that first the interpretation exercise
9 has come to an end.
10 "But you were aware," asked -- said Ms. Richardson, "that he
11 worked for the War Presidency, but you were not aware that he was also
12 part of the Srebrenica TO, as a member, who would be heading up the
13 signals and information service?"
14 And we are, of course, talking about Hamed Alic. What is your
15 answer to that?
16 THE WITNESS: [Interpretation] Your Honour, I am aware that Hamed
17 Alic worked for the War Presidency of Srebrenica municipality. I'm not,
18 however, aware of him working for some kind of Territorial Defence Staff
19 of Srebrenica.
20 MS. RICHARDSON: Yes. Thank you very much.
21 JUDGE AGIUS: Ms. Richardson.
22 Is that all right with both of you?
23 MR. JONES: Yes. I think that's much clearer.
24 MS. RICHARDSON: Indeed, indeed. And with respect to C, at the
25 VP, which is the military -- abbreviation for military police, firing
1 positions, that's what it says in English, the organisation to be carried
2 out by Mirzet Halilovic.
3 Q. Now, based on what you previously told us, that Mirzet Halilovic
4 was the chief of police, did you know that he was also a member or part of
5 the Srebrenica TO and elected to be someone who would organise the
6 military police?
7 A. What it says here under C is "VP." I believe that's some kind of
8 military police. I'm not, however, aware of Mirzet Halilovic being
9 included in the Srebrenica TO. I do know that he was appointed commander
10 of the military police by the War Presidency of Srebrenica municipality.
11 Q. Thank you. I don't have any questions on that document. Madam
12 Usher can take it.
13 MS. RICHARDSON: If I could have the usher's assistance again in
14 showing document P79. Thank you.
15 Q. Now, Mr. Sacirovic, just for the record, this document is from the
16 Republic of Bosnia and Herzegovina, operations staff of the armed forces,
17 Srebrenica. It is dated Srebrenica, 19th September, 1992. It is to the
18 War Presidency of the municipality. And the subject matter is draft
19 decision regarding the set-up of departments and appointing chiefs of
20 these departments in the operations staff of the armed forces of
22 JUDGE AGIUS: Yes, Ms. Vidovic.
23 MS. VIDOVIC: [Interpretation] Your Honours, I believe I have
24 already reacted by asking that the translation of this document be
25 corrected. It should be placed on the ELMO, because in the Bosnian
1 version, it states "proposal," whereas in the English version it is "draft
2 decision." The word "proposal" has nothing to do with the English
3 translation of the -- as it states here, "draft decision," and I would
4 kindly ask the interpreters to confirm this. I've already drawn attention
5 of the Prosecutor to this, but they have not corrected it.
6 Your Honours, it substantially changes the contents of the
8 JUDGE AGIUS: Do you want to discuss this in the presence of the
9 witness or in his absence?
10 MS. RICHARDSON: Your Honour, I'm short on time today, and perhaps
11 we can just place it on the ELMO. We can revisit the issue when we have
12 more time.
13 JUDGE AGIUS: All right. In any case, he's going to see the B/C/S
15 MS. RICHARDSON: Yes, that's fine.
16 JUDGE AGIUS: And keep in mind what has been suggested by
17 Ms. Vidovic.
18 MS. RICHARDSON: Yes, Your Honour, indeed.
19 JUDGE AGIUS: That basically we're talking of a proposal.
20 MS. RICHARDSON: Yes.
21 JUDGE AGIUS: All right. Thank you.
22 Thank you, Ms. Vidovic.
23 MS. RICHARDSON: And I believe the English will be on Sanction in
24 a moment.
25 Q. Now, under number 8, you see the name Hamed Alic, and it's the
1 department for communication. Do you see that?
2 A. Yes.
3 Q. Now, the -- you're not aware, Mr. Sacirovic, whether or not the
4 Srebrenica War Presidency had to approve these members as submitted here
5 of the Operations Staff of the Armed Forces, are you?
6 A. I'm not aware of that.
7 MS. RICHARDSON: I don't have any other questions. Thank you,
8 Madam Usher, for placing this document. If I could just have a moment.
9 At this time I would like the witness to be shown Prosecution's
10 Exhibit P84. Sorry. We will be, for the English, we will be referring to
11 ERN 03090721. Just a moment, Your Honour. And for the B/C/S,
12 ERN 02115063. At least that's the beginning portion. And it should start
13 with the date November 3rd, 1992, meeting of the Armed Forces Staff.
14 JUDGE AGIUS: Yes. I think it will be easier if you gave us the
15 page number in the English version, Ms. Richardson.
16 MS. RICHARDSON: Yes, Your Honour. I'll do so right now.
17 JUDGE AGIUS: Yes, I know, but we have been seeing different pages
18 on Sanction, so ...
19 MS. RICHARDSON: Yes. Your Honour, it is on Sanction.
20 JUDGE AGIUS: Yes. But on Sanction we have the 7th November, and
21 you said the 3rd November, if I --
22 MS. RICHARDSON: It's the 3rd of November. So we need to go
23 forward one page on Sanction. Pardon me.
24 JUDGE AGIUS: I think it's the previous page, page 16 we need to
25 see. And then it's another one.
1 MS. RICHARDSON: Your Honour --
2 JUDGE AGIUS: I could see -- I could see it referring --
3 MS. RICHARDSON: The date is at the very bottom, last page, yes.
4 Q. So now, Mr. Sacirovic, I hope everyone has it now and can follow.
5 Do you see the date 3rd November, meeting of the Armed Forces Staff?
6 A. Yes, I see it.
7 Q. Now, it does state that -- well, first I should ask you: Have you
8 ever attended any meetings of the Armed Forces Staff of Srebrenica during
9 your time there?
10 A. No.
11 Q. Well, let me refer you to a portion of this page, which talks
12 about the work of communication and information service. The sentence
13 reads, at least in English: "As for the work of the communication and
14 information service," and you may need to turn to the next page,
15 ERN 02115064, because ... It states: "In fact, it consists" and I'll wait
16 until you can see it. It says -- on the previous page, it says: "As for
17 the work of the communication and information service," and then it
18 states: "In fact, it consists of two services, the communication service
19 operating within the Armed Forces, and the information service."
20 Something that's illegible. "It is believed that a special commission of
21 the War Presidency must be formed for the communication and information
22 service for information regarding war destruction..."
23 Do you see that portion?
24 JUDGE AGIUS: Yes. Let him -- we just want to know whether --
25 because we've been waiting for you to say whether you can see it on that
1 page or not, whether you've read it or not. Have you found it or not yet?
2 It's at the top of the page. That page has a number, which is 02115064.
3 And this is at the very top of it.
4 THE WITNESS: [Interpretation] Yes, Your Honour.
5 JUDGE AGIUS: Ms. Vidovic, I'm sorry I cut you off, but I wanted
6 to make sure that he had the right page in front of him.
7 MS. VIDOVIC: [Interpretation] Your Honour, we will get back to
8 this in our re-examination.
9 JUDGE AGIUS: Okay. Thank you.
10 Yes, your question, Ms. Richardson.
11 MS. RICHARDSON: Yes, Your Honour. I'm moving, Your Honour.
12 Q. Now, with respect to this information here, you testified
13 yesterday that -- and you were shown Defence Exhibit 862, that in fact a
14 document which was signed by -- a document -- I'll rephrase the question.
15 Yesterday you were asked about whether or not Nijaz Masic had been
16 approved or appointed by the communication and information service for --
17 and that his work involved collecting information about genocide
18 perpetrated by the occupiers against Muslims, Croats, and other ethnic
19 groups. I'm just paraphrasing from the document. But do you recall
20 seeing that document?
21 A. Madam Prosecutor, this is the first time I see this document, and
22 I repeat that I am not aware of Nijaz Masic's role, as I indicated earlier
23 in my testimony.
24 MS. RICHARDSON: Your Honour, if I may --
25 JUDGE AGIUS: Yes. I think he has misunderstood your question.
1 MS. RICHARDSON: Indeed, and I will show him the document with
2 what he's looking at.
3 JUDGE AGIUS: Yes. It's the document that we showed you --
4 MS. RICHARDSON: [Speakers overlapping: Cannot distinguish between
6 JUDGE AGIUS: -- yesterday or the day before. You remember we
7 showed you a document in which it was stated that Nijaz Masic was being
8 appointed to conduct investigations on genocide. Do you remember that?
9 And you told us that you didn't know anything about it.
10 THE WITNESS: [Interpretation] That's what I'm stating right now.
11 I truly don't know anything about it, Your Honour.
12 JUDGE AGIUS: The question was about that document. I mean, do
13 you remember seeing that document yesterday?
14 MR. JONES: It was actually Monday.
15 JUDGE AGIUS: All right. On Monday. It was Monday, in fact,
16 because I referred to it yesterday, then.
17 THE WITNESS: [Interpretation] Yes, Your Honour, I do recall seeing
18 the document, but I am not familiar with it.
19 MS. RICHARDSON: All right.
20 JUDGE AGIUS: Yes, Ms. Richardson.
21 MS. RICHARDSON: Your Honour, I'll move to another subject matter.
22 Q. Now, if you can --
23 MS. RICHARDSON: If the usher could render her assistance again
24 and show the witness, with the same Prosecution exhibit, page
25 ERN 02115071. And for -- in the English version I believe it's
1 ERN 03090726. And we'll bring it up on the ELMO. I believe it's page 21.
2 If we could put the section that states -- the portion that begins
3 right -- that -- the first sentence is: "The military police belong to
4 the Armed Forces and not the War Presidency." So it's ERN 02115071.
5 JUDGE AGIUS: Yes. It's the previous page, the previous page.
6 MS. RICHARDSON: The English is on Sanction.
7 Q. Now, Mr. Sacirovic, you said that you've never attended meetings,
8 and I take it also you are not aware of whether or not the -- you
9 testified previously -- let me rephrase.
10 You testified previously that you were not aware of whether or not
11 Mr. Alic met with the OS Staff and had any meetings with them. That would
12 be correct, wouldn't it?
13 A. Yes. I'm not aware of that.
14 Q. Right. Now, just for the record, and you don't need to turn to
15 this, but the meeting is dated 9 November 1992. It says: "Minutes of the
16 joint meeting of the War Presidency and the Srebrenica Armed Forces." And
17 it is ERN 03090723. And the B/C/S is 02115068. I don't need that to be
18 shown the witness, but I'd like you to look at the page that's before you.
19 Now, were you aware that there was a discussion held and it was
20 stated in the meeting that the military police belonged to the Armed
21 Forces and not the War Presidency?
22 JUDGE AGIUS: Yes, Mr. Jones. And I know exactly what you're
23 going to say.
24 MR. JONES: Yes. I don't think it's a fair question for the
25 witness, unless he's aware that this is the note of what one person
1 appears to have said. When it's put that way, that this was stated at the
2 meeting, it's as if it were the consensus of the whole meeting or that it
3 was agreed upon. He has a right to see in context that this is --
4 JUDGE AGIUS: Yes, I agree 100 per cent with you. I think you
5 have to put to the witness that there is one individual who is stated
6 five, six lines above -- actually, it's on the previous page, and it's
7 that individual who is making this statement, Zulfo, in other words.
8 MS. RICHARDSON: I believe I said it was stated. So I will
9 rephrase the question and say one person.
10 JUDGE AGIUS: But it was stated, in other words, it can have a
11 completely different connotation. I mean, that's why I'm agreeing with
12 Mr. Jones.
13 MS. RICHARDSON: That's fair enough, Your Honour.
14 Q. So, Mr. Sacirovic, in this -- in the minutes of this meeting that
15 we're reviewing, it is stated by the last person, and that is indicated on
16 03090725, and of the B/C/S it's 02115070, and it's stated by Zulfo: "We
17 have past regulation until freedom is achieved. Let us punish" a word is
18 crossed out, "offenders. The court cannot pass final judgement. It has
19 not been formed properly as it is a preventive task."
20 And then he goes on to say: "The military police belong to the
21 Armed Forces."
22 And it goes on to say, the next line, that: "The military police
23 belong to the Armed Forces and not to the War Presidency."
24 JUDGE AGIUS: Yes, Ms. Vidovic, what's the problem?
25 MS. VIDOVIC: [Interpretation] Your Honour, it has to do with
1 translation. I'm not sure if this -- what the Prosecutor said was
2 interpreted properly, but it seems as if Zulfo had said, "We had received
3 rules for the internal police," whereas it says here Zulfo says that he --
4 the rules ought to be passed, need to be passed, whereas through
5 interpretation into Bosnian, it seemed as if the rules for the military
6 police had been adopted.
7 Could the witness please look at the document. Either the
8 Prosecutor misspoke when she was reading or the interpretation was wrong.
9 JUDGE AGIUS: No. The Prosecutor was reading correctly. It's
10 maybe a question of misinterpretation. However, the witness has got the
11 text in B/C/S, the original text in B/C/S, and he can read it for himself.
12 And it is obvious from it that there is no indication that a decision had
13 already been taken, or regulations had already been passed.
14 MS. RICHARDSON: Indeed, and my question, Your Honour, is
15 specifically with respect to that one sentence, not --
16 JUDGE AGIUS: Yes, yes.
17 MS. RICHARDSON: -- what comes before.
18 JUDGE AGIUS: Go ahead.
19 MS. RICHARDSON:
20 Q. So my question, Mr. Sacirovic: Had you heard or learned that the
21 military police indeed reported to or belonged to the Armed Forces and not
22 the War Presidency?
23 A. Madam Prosecutor, I have never heard this. The military police
24 was exclusively subordinated to the War Presidency of Srebrenica
1 Q. Mr. Sacirovic, if an order existed that was signed by Naser Oric
2 ordering the military police, would that - the fact that he, Naser Oric,
3 has issued an order to the military police - change your position?
4 A. Madam Prosecutor, Naser Oric could not have issued an order
5 changing any titles. I repeat: The military police was subordinated to
6 the president of the War Presidency of Srebrenica municipality, and Naser
7 Oric could not have played any role in this.
8 Q. If you look further down, under the same page, I believe it's
9 still on the same page, under "information," it has Hamed, and from that
10 name, it is stated: "We have collected much information. So far we have
11 sent 120 reports. Until mid-September, we worked both for the military
12 police - excuse me - military and the civilian authorities. We have to
13 procure oil and generator parts ourselves. Communication and information
14 must be separated."
15 Now, again, I believe you previously testified that you were not
16 aware that the information Hamed Alic worked both for the War Presidency
17 and the Armed Forces. Now, based on a reading of what's stated in the
18 minute, is it now clear to you that indeed Hamed Alic reported both to the
19 military and the civilian authorities?
20 A. Madam Prosecutor, as far as I know, Hamed Alic reported -- or
21 rather, submitted his reports only to the War Presidency, and not to any
22 armed forces, to my knowledge.
23 Q. So but having read what's in the minutes, does this change your
24 position, that there is a possibility, at the very least, that he reported
25 both to the Armed Forces and to the War Presidency?
1 A. No. This does not change my position at all. I categorically
2 state that Hamed Alic submitted his reports exclusively to the War
3 Presidency of Srebrenica municipality, or to be more precise, to the
4 president of the War Presidency, Mr. Hajrudin Avdic.
5 Q. Did you have a discussion with Mr. Hamed Alic about whether he
6 submitted any official reports to the Armed Forces of Srebrenica?
7 A. I had never heard Hamed Alic utter the words "Armed Forces," let
8 alone -- or rather, and I only saw him submitting reports to the president
9 of the War Presidency, Mr. --
10 THE INTERPRETER: Could the witness please repeat the last part
11 that he stated.
12 JUDGE AGIUS: Yes. Mr. Sacirovic, the interpreters couldn't catch
13 up with you, the final part of your testimony. You said: "I had never
14 heard Hamed Alic utter the words Armed Forces, let alone, or rather, and I
15 only saw him submitting reports to the president of the War Presidency."
16 And then you said something else, but the interpreters didn't
17 catch it. What was it?
18 THE WITNESS: [Interpretation] Your Honour, I said that Hamed Alic
19 was subordinated to and submitted his reports solely to the War
20 Presidency, that's to say, Mr. Hajrudin Avdic. That was what I stated.
21 JUDGE AGIUS: All right. Thank you.
22 MS. RICHARDSON:
23 Q. So in response to my question, the answer is no, Mr. Hamed Alic
24 never spoke to you about submitting reports to the Armed Forces of
1 A. Madam Prosecutor, I am not aware at all that there were Armed
2 Forces of Srebrenica in existence at the time. I only know that there
3 were armed groups around Srebrenica.
4 Q. Okay. Now, further down the page, it says "commission." Do you
5 see that portion?
6 A. Yes, I do.
7 Q. And just before that, Nijaz Masic states: "For the first two and
8 a half months the service worked well. Now a new man has to be
9 appointed - information. Likewise, a commission for collecting and
10 processing information on war casualties must be formed."
11 And then it goes on, commission, and there are five names listed.
12 It says Becir, Masic, Osman, Avdo, Fadil. Do you see that? It should
13 probably be at the end of your page, the B/C/S, list of five names.
14 A. Yes, I do see that.
15 Q. Now, yesterday you testified that -- well, you were shown Defence
16 Exhibit 263. And perhaps we can show the witness this document again.
17 Now, if you look at Roman numeral -- well, I should first read
18 into the record what this document is titled. "Republic of
19 Bosnia-Herzegovina, Srebrenica municipality, War Presidency, Srebrenica,
20 12 November, 1992." It states: "A War Presidency of the Srebrenica
21 municipality at a meeting held on the 9th November 1992 adopted the
22 following decision." It says: "Decision on the establishment of a
23 commission." I: "A commission is to be formed of the follow composition:
24 Nijaz Masic, Avdo Huseinovic, Fadil Mujic [phoen]," and it lists Nijaz
25 Masic as the chair and the other two as member.
1 Now, having read the minutes of -- the joint minutes that I just
2 read to you about the commission, does the information from the minutes
3 and this decision, are they not very similar, in that it appears as though
4 this is an order that came out of the commission that was proposed?
5 A. I assure you that I have no idea what this is about.
6 Q. That's fine. Thank you.
7 MS. RICHARDSON: I have no further questions on that document.
8 Perhaps you can keep P484 -- P84, excuse me, with the witness. I do have
9 some other questions.
10 Q. Now, just to complete a series of questions from this document.
11 You previously testified that Mirzet Halilovic was the commander of the
12 military police and that at one point he was removed and he was replaced
13 by Atif Krzic. Do you remember your evidence?
14 A. Yes.
15 MS. RICHARDSON: If I could have the usher's assistance in showing
16 the ERN page, B/C/S firstly, 02115077. And in the English, 030907 -- 0.
17 It's possibly found on page 25 or 26.
18 JUDGE AGIUS: For the record, and also to help us, what's the
19 exact --
20 MS. RICHARDSON: Yes, Your Honour.
21 JUDGE AGIUS: -- ERN number in the English?
22 MS. RICHARDSON: In English it's 03090730.
23 JUDGE AGIUS: 730.
24 MS. RICHARDSON: And it's the meeting is dated -- the minutes,
25 minutes of the Srebrenica OS Staff meeting held on the 22nd of November,
2 JUDGE AGIUS: Thank you, Ms. Richardson.
3 MS. RICHARDSON: Okay. It is on Sanction.
4 Q. Now, I'd like you to take a look at number 5. It
5 says: "Miscellaneous: Reorganisation of the VP," which is abbreviation
6 for the military police. Do you see that?
7 A. Yes.
8 Q. Okay. Now, if you would --
9 MS. RICHARDSON: I do need the usher's assistance again. I
10 apologise. But I need the witness to be shown ERN 02115079, which is a
11 couple of pages after the document he's shown. And for the English
12 it's 03097033.
13 Q. Now, do you see the name Mirzet Halilovic, resignation,
14 unanimously accepted?
15 A. I see some things and I don't see some other things, because these
16 documents are not very clear.
17 Q. All right. Well, let's perhaps start with the name. Do you see
18 the name Mirzet Halilovic? It's probably towards the middle portion of
19 the page.
20 JUDGE AGIUS: Do you see the Roman numerals VI? It's three lines
21 above that.
22 THE WITNESS: [Interpretation] Yes, I do.
23 Q. Thank you, Your Honour.
24 Q. Having located the name, it says: "Resignation unanimously
25 accepted." And the second line states: "K Atif unanimously, one against,
1 one abstained."
2 Now, having read this, is this consistent with what you told us,
3 that Mirzet Halilovic was replaced as the chief of military police,
4 command of the military police, and he was replaced by Atif Kurtic?
5 A. Not Kurtic. Krgic. [phoen]
6 Q. Thank you so much, yes. And is that correct, he was replaced by
7 Mr. Krgic?
8 A. Mirzet Halilovic was replaced, but the usual procedure anywhere in
9 the world, if somebody makes a mistake, whether a politician or any kind
10 of official, it's suggested to that person that he should resign.
11 Q. Thank you. Now, I'd like this document to remain with the
12 witness, and I would like the witness to be shown document --
13 Prosecution's Exhibit 14, P14.
14 Q. And Mr. Sacirovic, I do need for the record your answer to my
15 questions that Krgic replaced Mirzet Halilovic, a simple yes or no.
16 A. Yes.
17 Q. Now, before you review the document that's being placed before
18 you, Mr. Sacirovic, if you could just -- could I have your attention,
19 please. I'd like to ask you a question before you review that document.
20 My question is whether you were aware that Naser Oric was also
21 meeting with members of the War Presidency, including Mr. Hajrudin Avdic.
22 A. I wasn't aware of that.
23 Q. And you stated that the War Presidency was the highest organ in
24 Srebrenica. Do you remember that?
25 A. Yes.
1 Q. Now, if you could look at the document that's before you, and just
2 for the record, I will read what's stated in this document. "Republic of
3 Bosnia and Herzegovina, Srebrenica Armed Forces Staff, Srebrenica, the
4 22nd of December, 1992." And it's to the president of the War Presidency.
5 And it states: "Further to a conclusion adopted at a meeting of
6 the Srebrenica OS Staff on the 22nd of December, 1992, the Srebrenica
7 OS Staff issues the following order: To convene a session of the War
8 Presidency and the Srebrenica OS Staff on the 23rd of December at 10.00,
9 1000 hours. The president of the War Presidency shall be duty-bound to
10 ensure a quorum for the meeting by the beginning of the meeting at the
11 appointed time."
12 And it is signed Commander Naser Oric, commander of the Srebrenica
14 Now, having read this document, does it appear to you that
15 Mr. Oric himself ordered -- sent an order to the War Presidency?
16 A. No.
17 Q. This document does not state that this is an order sent to the War
18 Presidency from Naser Oric?
19 A. Who was Naser to send an order to the president of the War
20 Presidency? I don't believe this.
21 Q. My question --
22 A. This is the first time I've seen this document.
23 Q. Thank you. And since this is the first time you've seen this
24 document, my question to you is this document, does it not on its face
25 state that Naser Oric ordered the War Presidency to convene a meeting?
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
1 A. It says here that the president of the War Presidency is obliged.
2 I don't know how you formulate it, but this document, I don't know who
3 signed it. It says here "Naser Oric," but I don't believe this document.
4 Look here, it couldn't have --
5 Q. Mr. Sacirovic --
6 JUDGE AGIUS: Wait, wait, wait.
7 Yes, Mr. Jones.
8 MR. JONES: Your Honour, either my learned friend is making a
9 submission or the question has been answered. If it's a submission, then
10 of course --
11 JUDGE AGIUS: I think it has been answered.
12 MR. JONES: -- on the face of the document --
13 JUDGE AGIUS: No, no, no.
14 MR. JONES: -- Prosecution is free to make whatever submission
15 they like. If she actually wants an answer from the witness, he
16 said he doesn't believe this document and doesn't find it credible, and
17 there's nothing more really which he can add to that.
18 JUDGE AGIUS: He's answered. He acknowledges that on the face of
19 it it appears to be an order.
20 MS. RICHARDSON: Your Honour, I'm about to move on to my next
22 JUDGE AGIUS: Okay. Go ahead.
23 MS. RICHARDSON: Thank you.
24 JUDGE AGIUS: But I think he has answered.
25 MS. RICHARDSON: And I am moving on to my next question. He's
1 stated what he already has.
2 Q. Now, Mr. Sacirovic, I would ask the usher's assistance to show you
3 ERN number -- of P84, ERN of the B/C/S is the ERN 02115100. And in the
4 English it is 03090747, and it will be placed on Sanction as well.
5 Now, the date from the meeting is the 23rd of December, joint
6 session of the SOS Staff Armed Forces and the RP, RP, the abbreviation
7 which I'm sure you know, Mr. Sacirovic, is for the War Presidency. Do you
8 see that?
9 A. Yes.
10 Q. And it does appear from what's stated here that the War Presidency
11 in fact followed the order, whether you agree that it was an order or not,
12 from the document itself, which Naser Oric ordered that the War Presidency
13 convene a meeting with the OS Staff, dated the 23rd of December, does it
14 appear to you, from the 23rd of December in this document, that a joint
15 session was indeed held with the Armed Forces and the War Presidency?
16 A. Madam Prosecutor, I can testify and speak only about the truth and
17 about facts that I know. But these minutes you're showing me is something
18 I'm absolutely not familiar with. And believe me, I have nothing to do
19 with these. This is the first time I've come across these things, and I
20 simply have no answer to this. I don't know. I did not participate in
21 this. I wasn't a participant. I don't know what kind of minutes these
22 are. These documents are unfamiliar to me, and that's my response to all
23 your questions concerning these documents you're showing me right now.
24 Q. Okay. Perhaps you could confirm for us, since we are establishing
25 a record, that there is, from what it appears to be from P84 on this page,
1 that a joint session of the Armed Forces and the War Presidency did occur
2 on the 23rd of December, 1992, from the document itself.
3 JUDGE AGIUS: Do you really need the witness to confirm that?
4 MS. RICHARDSON: Your Honour, I could move on.
5 JUDGE AGIUS: He knows nothing about it. Wait. Stop. Stop,
6 Mr. Sacirovic.
7 At this point, he's made his position very clear. At this point,
8 I think the rest becomes a submission on your part.
9 MS. RICHARDSON: Your Honour, I can move on.
10 JUDGE AGIUS: As I see it, at least. If you don't agree with me,
11 of course you can --
12 MS. RICHARDSON: Again, I am establishing a record here, and so
13 that's the purpose behind my question, taking into consideration, of
14 course, what the witness has said. Thank you.
15 JUDGE AGIUS: I think so.
16 MS. RICHARDSON:
17 Q. Okay. Mr. Sacirovic, I would ask that you be shown Defence
18 Exhibit -- it was the map that was shown to you yesterday. If I could
19 just check with my case manager, I'll get the exhibit number.
20 JUDGE AGIUS: I think it was 88 -- 88 -- 877 -- 877.
21 MS. RICHARDSON: Thank you, Your Honour.
22 JUDGE AGIUS: D, of course, not P.
23 MS. RICHARDSON: D, indeed.
24 Q. Now, Mr. Sacirovic, if you could assist us with pointing to the
25 map that you previously used, and again, for the record, it's D877, to the
1 areas where you visited and spoke with civilians and fighters in the
2 field. And perhaps you can use a pen --
3 JUDGE AGIUS: Yes, exactly. Give him a different coloured pen,
4 please, and he will mark these by small circles.
5 MS. RICHARDSON:
6 Q. Now, if you could just list the names -- circle the villages, and
7 just say for the record the ones you're circling.
8 A. We'll start with Srebrenica, shall we?
9 JUDGE AGIUS: Yes, go ahead.
10 MS. RICHARDSON:
11 Q. Yes, please. Please.
12 A. This pen isn't working.
13 Q. Okay. I have a blue pen.
14 A. [Marks].
15 JUDGE AGIUS: Yes. For the record, the witness puts a circle on
16 the map to -- at 10.00, 10.00 in respect to Srebrenica.
17 THE WITNESS: [Interpretation] Do I need to draw now?
18 JUDGE AGIUS: No, no, no, no. Just mark the places and tell us
19 the names, please. So the first one was Srebrenica.
20 THE WITNESS: [Interpretation] Second, Bajramovici.
21 JUDGE AGIUS: For the record, the next circle, or the next marking
22 that the witness puts on the map is on Bajramovici.
24 THE WITNESS: [Interpretation] Lipovac.
25 JUDGE AGIUS: Next circle is Lipovac. Put the circle, please.
1 THE WITNESS: [Interpretation] Suceska, Bektici.
2 JUDGE AGIUS: One moment. Near Lipovac, please put a circle. I
3 don't see it.
4 THE WITNESS: [Interpretation] I apologise.
5 JUDGE AGIUS: It's okay. And then next circle is at Suceska. And
6 the other one is in can you repeat the name, because the focussing on the
7 map is -- doesn't --
8 A. Bektici. Staroglavice.
9 JUDGE AGIUS: Then another elliptic circle on -- can we have-- can
10 we zoom in and --
11 THE WITNESS: [Interpretation] Staroglavice. Bucinovici.
12 JUDGE AGIUS: Next one is Bucinovici.
13 THE WITNESS: [Interpretation] Brakovci.
14 JUDGE AGIUS: Brakovci.
15 THE WITNESS: [Interpretation] Opetci.
16 JUDGE AGIUS: Opetci.
17 THE WITNESS: [Interpretation] Podgaj.
18 JUDGE AGIUS: Podgaj.
19 THE WITNESS: [Interpretation] Bukovica.
20 JUDGE AGIUS: Bukovica.
21 THE WITNESS: [Interpretation] Diljka.
22 JUDGE AGIUS: Diljka.
23 THE WITNESS: [Interpretation] Slatina.
24 JUDGE AGIUS: Slatina.
25 THE WITNESS: [Interpretation] Susnjari, Jaglici, and Lupoglav,
1 Brosevici, Pale, Milacevici, Bljeceva, Budak, Potocari, Joseva and these
2 villages, Kutlici. That's already in Srebrenica, to the west of
3 Srebrenica. And then further on, up here, Skenderovici, Mocevici. I'm
4 looking for ... But it's not here on this map --
5 MS. RICHARDSON:
6 Q. You could just --
7 A. -- where Ahmo Tihic was.
8 Q. If you could just locate where you think it should be. If there
9 is a place missing from the map, put the initial of the name of the
10 village. That would be appreciated.
11 A. Just let me take a good look. I can't find Biljeg here.
12 Q. Yes. Because perhaps it's not on that map. It may be further
13 down. But --
14 A. Probably. Probably, yes. You probably can't see it on this map.
15 I was here as well, south of Srebrenica. These are the villages where I
16 went on the ground.
17 Q. All right. Did you go to Pale and Cizmici as well? I'm sorry.
18 You've indicated Pale. I apologise. Did you go to the area of Cizmici?
19 A. Yes.
20 Q. Could you circle that. It may not be on the map, so --
21 A. Well, that's in Bljeceva. It's in here, Cizmici. You can't see
22 Cizmici on the map, but it's a hamlet near the village of Bljeceva.
23 Q. At some point did you go to Glogova? And of course this would be
24 after Glogova had been liberated by the Muslim forces.
25 A. I think I went there only once, in 1993.
1 Q. If you could just circle it. And it's on the record that you went
2 there in 1993.
3 A. [Marks].
4 Q. And what about Kravica and Andici [phoen]?
5 A. I went to Kravica once in 1993. Just a moment.
6 Q. And any of the surrounding Kravica area did you visit as well?
7 A. No, I didn't.
8 Q. All right. Thank you. Now, with respect to the Joseva you
9 indicated on the map, now, that's the Joseva that's in the vicinity of
10 Srebrenica, and that's in the Fojhar area region?
11 A. Yes.
12 Q. And do you know individuals from Joseva?
13 A. I know some by sight, because my uncle was a refugee in Joseva for
14 a time. In almost all of these villages I've indicated, there were
15 refugees from neighbouring municipalities, such as Bratunac and Vlasenica.
16 Q. And from Joseva, the individuals you know -- I think you found
17 another place.
18 MS. RICHARDSON: For the record, Your Honour, it's being circled.
19 JUDGE AGIUS: Yes. For the record, the witness has now --
21 THE WITNESS: [Interpretation] All the villages in this circle are
22 villages I passed through and visited. There's not a single village in
23 this area --
24 JUDGE AGIUS: Yes. To continue his -- also circled Borkovici and
25 what looks like Bustahovina [phoen]. He also encircles Fojhar.
1 THE WITNESS: [Interpretation] Babuljice too.
2 JUDGE AGIUS: Yeah. But if we continue like this, we are going to
3 circle each and every place-name on this map.
4 MS. RICHARDSON: Yes, Your Honour. I believe the witness has
5 indicated sort of the wider region that he --
6 JUDGE AGIUS: If you are happy with what he has indicated so far,
7 let's move.
8 MS. RICHARDSON: Yes, I think we're happy with that for so far.
9 JUDGE AGIUS: Because I --
10 MS. RICHARDSON: The name ended -- and we are short on time.
11 Q. The name Salkic from Joseva, which is close to Srebrenica, are you
12 familiar with that family name?
13 A. All that was in the free territory. Excuse me.
14 Q. I don't know if you heard my question.
15 JUDGE AGIUS: I don't think so.
16 MS. RICHARDSON:
17 Q. The name --
18 THE INTERPRETER: The witness is listening to the interpretation.
19 Thank you. That's why there's a delay. He cannot answer right away.
20 MS. RICHARDSON: I see. Of course. Thank you.
21 JUDGE AGIUS: What we want to know, Mr. Sacirovic, is if you know
22 from the village of Joseva, or Joseva, anyone by the name of Salkic.
23 THE WITNESS: [Interpretation] Your Honours, believe me, I don't
24 know. I don't know them.
25 JUDGE AGIUS: Yes, Ms. Richardson.
1 MS. RICHARDSON: Thank you, Your Honour.
2 Q. Now, just briefly getting back to the subject matter of Mirzet
3 Halilovic. Do you recall how many members -- well, I'll rephrase the
5 Did there come a time that you visited the police building that
6 housed both the civilian and the military police?
7 A. I never visited that building.
8 Q. Mirzet Halilovic, as the commander of the military police, I take
9 it he had men under his command?
10 A. Yes.
11 Q. And do you know how many men were under him?
12 A. I can't tell precisely whether it was 10 or 15. They were not in
13 uniform. They were unarmed. Mirzet was the only one who had a uniform,
14 probably, and you couldn't distinguish them from the other civilians.
15 Because Srebrenica was overcrowded with civilians throughout this period.
16 So it was very hard to identify persons.
17 Q. And you didn't know them all, the ones who worked under Mirzet
18 Halilovic, the military police officers?
19 A. I knew practically only Mirzet Halilovic among the military
20 police. I don't know the others.
21 MS. RICHARDSON: Your Honour, at this time I would like the
22 witness to be shown a new document. And I think there's going to be a
23 break soon.
24 JUDGE AGIUS: Yes, but go ahead.
25 MS. RICHARDSON: All right.
1 JUDGE AGIUS: Unless you prefer the break now.
2 MS. RICHARDSON: Just let me just speak to my case manager.
3 JUDGE AGIUS: Yes, of course.
4 [Prosecution counsel confer]
5 MS. RICHARDSON: All right. Your Honour. I'll ask one question
6 of this document. It's ERN 03720894, up to 03720896. And the B/C/S is
7 03720895 to 896. And while this is being distributed:
8 Q. Mr. Sacirovic, you said that Mirzet Halilovic wore a uniform.
9 Could you tell us what kind of uniform he wore when you saw him?
10 A. He wore a camouflage uniform. Believe me, I don't know where he
11 got it from, but he did have a camouflage uniform.
12 Q. All right. Now, what you're being shown, just for the record,
13 military police, it says "copies," and I'm reading of course from the
14 English version, Armed Forces of the Bosnia-Herzegovina, military police
15 station, Srebrenica, list of military police staff. It says family name,
16 year of birth, date of entry on duty. The first name listed is Mirzet
17 Halilovic, 1964, 18th of April, 1992. And it goes on to list 67
18 individuals that are made up of part of the military staff.
19 And I believe you already testified you were not familiar with the
20 other police officers, military police officers, that is.
21 A. Yes.
22 Q. Just for the record, this document is signed by Mirzet Halilovic,
23 and it's dated the 31st of July, 1992.
24 Thank you. I don't have any other questions.
25 MS. RICHARDSON: And Your Honour, I think this is a good time to
1 take a break. We do need a P number, thank you.
2 JUDGE AGIUS: Yes, of course. This document, which consists of
3 two -- three pages in B/C/S and two pages in English is being tendered and
4 marked as Prosecution Exhibit P5?
5 THE REGISTRAR: P 590, Your Honour.
6 JUDGE AGIUS: Yes, Mr. Jones.
7 MR. JONES: Yes. Could I just note for the record, Your Honour,
8 the witness wasn't asked any meaningful question about this exhibit.
9 JUDGE AGIUS: All right.
10 MR. JONES: But surely if the purpose is to tender documents
11 through exhibits, it was merely a question he had already answered was
12 reiterated with this document in front of him. It wasn't --
13 JUDGE AGIUS: Well, basically, as I take it, he's being shown a
14 list of 67 persons in consideration -- or in view of the fact that he had
15 said that he didn't know anyone.
16 MS. RICHARDSON: Thank you, Your Honour.
17 JUDGE AGIUS: That's basically it, and I would leave it at that,
18 Mr. Jones.
19 Yes. We'll have a 20 -- how are you for time.
20 MS. RICHARDSON: Your Honour, I'm moving quickly and I'm still
21 hopeful that I could be done by the end of the session, and if I go over,
22 it will be no more than ten minutes for Thursday.
23 JUDGE AGIUS: No, no. But there would be a re-examination, of
25 MS. RICHARDSON: We need to do it by 11.00, yes.
1 JUDGE AGIUS: But the important thing is that we can then continue
2 tomorrow, if necessary. But please try to finish --
3 MS. RICHARDSON: Yes, I am moving, Your Honour.
4 JUDGE AGIUS: Because tomorrow I am -- I have a personal problem
5 that I have to attend to.
6 MS. RICHARDSON: Yes, Your Honour. I have kept that in mind and
7 I'm moving quickly.
8 JUDGE AGIUS: Thank you. We'll have 25-minute break.
9 Well, I mean, the witness wishes to finish today. I would be very
10 cooperative, of course, and I'm sure my colleagues would be cooperative as
11 well, but we seem to have the final say, but we don't. So in other words,
12 I mean, you have to sit down now, these 25 minutes, and see if you can
13 manage to finish cross-examination and redirect today, in which case we
14 can send him home. Otherwise he will have to return tomorrow.
15 See amongst -- I mean ... We are trying to help you.
16 --- Recess taken at 12.32 p.m.
17 --- On resuming at 1.01 p.m.
18 JUDGE AGIUS: Yes, Ms. Richardson.
19 MS. RICHARDSON: Thank you, Your Honour.
20 JUDGE AGIUS: Can you tell us what you have decided amongst
22 MS. RICHARDSON: Yes, Your Honour. [Microphone not activated].
23 JUDGE AGIUS: Microphone.
24 MS. RICHARDSON: Thank you. I apologise.
25 It was indicated by the Defence, Mr. Jones, that he needed about
1 five minutes so far. Of course, that's based on what I cover next. And
2 I'm going to really try to be done within the next 30 minutes.
3 JUDGE AGIUS: I thank you.
4 MS. RICHARDSON: I going to really try to do that.
5 JUDGE AGIUS: Thank you.
6 MR. JONES: May I say quickly, it is a substantial qualification,
7 however. If anything substantive in terms of exhibits comes up, it
8 follows that obviously --
9 JUDGE AGIUS: If we don't finish, it will not be a major tragedy,
10 expect maybe for him, because I'm sitting at 8.00 in the morning tomorrow
11 here, so -- and I'll finish at 9.00, and then, if necessary we continue,
12 but -- so I'll be here before you tomorrow.
13 Yes, Ms. Richardson.
14 MS. RICHARDSON: Thank you, Your Honour.
15 Q. Mr. Sacirovic, before the break we were discussing Mirzet
16 Halilovic, and --
17 A. Yes.
18 Q. Did he ever wear a cowboy hat with his uniform when you saw him?
19 A. Yes, occasionally.
20 Q. And did he have a reputation of sorts of being a violent person or
21 any kind of violent behaviour?
22 A. One could put it that way, yes.
23 Q. Now, you were asked yesterday about -- perhaps I should do this.
24 MS. RICHARDSON: Your Honour, at this time I'd like the usher's
25 assistance in showing Mr. Sacirovic a document, and this is a new
1 document, and it is 03721052. And we are handing out copies.
2 Q. If you could take a look at that, Mr. Sacirovic. It's from the
3 Republic of BiH Army, Command of the 280th East Bosnian Light Brigade. It
4 is dated the 6th of December, 1994. It's title submits a characteristic
5 of the nominee for medal of resistance, and it is about Mirzet Halilovic,
6 who was born in 1964, in Budak, Srebrenica. And I take it this
7 information is correct about Mr. Halilovic, of what you knew of him? Just
8 the first part.
9 A. Some of the information contained here as to his being with Naser
10 and this business of the medal of resistance, that's something I'm not
11 sure about.
12 Q. We'll get to that in a minute. So let's talk about what is stated
13 firstly in the beginning portion, and that he was born in Srebrenica, in
14 Budak, in 1964. This is what you knew of him; is this correct?
15 A. I don't know when he was born.
16 Q. All right. And do you know if he was stationed as a reserve
17 police officer or if he was a reserve police officer in Potocari at any
19 A. No.
20 Q. No, you don't know; or no, the information isn't correct?
21 A. I don't know.
22 Q. Okay. And to what's the -- and I take it you were referring to
23 his involvement with Naser as an organiser of the resistance movement that
24 stood up to the Chetniks in the first clash and he was chosen to be
25 Naser's deputy. Do you know if that's true or not? If you don't know,
1 just say "I don't know."
2 A. I don't know.
3 Q. All right. Further in the document, it says: "As soon as the war
4 broke out, the Chetnik issued an ultimatum on the 17th of April, 1992,
5 that we lay down our weapons and with his group he went to Pale, where he
6 was chosen to be company commander."
7 Now, you told us before he was in Pale and that he was the leader
8 of a group. Would that be correct? Is that similar to what you know of
10 A. Yes.
11 Q. Now, it also states that he took part in the sabotage action in
12 Potocari against Arkan's men. And I believe you testified that Naser Oric
13 was also -- or was involved in the sabotage of Arkan's men. Do you know
14 if Mr. Mirzet Halilovic was also involved?
15 A. I'm not aware of that.
16 Q. And further down on the page, it says: "From the 4th of July,
17 1992, he was the military police commander." And I believe you already
18 told us when you arrived in Srebrenica, Mirzet was also contacted to
19 become the military police commander.
20 A. Yes. He was the commander of the military police in Srebrenica.
21 Q. And it also states that he took, he, meaning Mirzet Halilovic,
22 took part in major combat actions such as those at Brezani, Fakovici,
23 Provranje [phoen] and the liberation of Sase, Bjelovac, Olavica [phoen].
24 Do you know if he took part in any of the various battles or action,
25 combat actions listed here?
1 A. I'm not aware of that.
2 Q. But these battles did take place? You are aware that these
3 actions did take place?
4 A. There were actions of defence. I am not aware of any offensive
6 Q. Okay. Now, it says further down: "During his service in the
7 police, he was permanently exposed to danger because in addition to --
8 because in addition to performing the task in the town itself, he and his
9 combatants had to be on the front line too at any time, day or night, to
10 perform the assigned task. He had travelled sometimes as far as 20
11 kilometres or further to our front line in Purica Brdo [phoen], or the
12 line in Suceska. And he had to perform his task in a good and correct
14 Are you familiar with whether or not -- well, it does say that he
15 performed his task in town, so do you agree that part of his task as a
16 military commander, military police commander, that he had various tasks
17 to perform in Srebrenica?
18 A. The question is not quite clear to me. I know that he had tasks
19 within Srebrenica. I am not aware of him performing any tasks outside
21 Q. All right. That's fine. So you're not aware of whether or not he
22 was present at the front line engaged as a fighter?
23 A. No, I'm not aware of that.
24 Q. And towards the end, it states that a big and crucial battle for
25 him occurred in the region of Jezero, wherein an assault with several of
1 his fellow men against a stronghold he aimed to destroy he suffered heavy
2 wounds inflicted by a grenade that fell in his vicinity and he died at the
4 Now, is that how Mr. Mirzet Halilovic died, if you know?
5 A. I don't know how Mr. Halilovic got killed. I only heard that he
6 got killed, but I am not aware of the time period or the circumstances
7 surrounding his death.
8 Q. Thank you. Now, if we could have an exhibit number, and I would
9 appreciate it if the usher could remove this document from the witness.
10 JUDGE AGIUS: Yes, Ms. Richardson. This document, which consists
11 of one page in B/C/S, bearing ERN 03721052, and the corresponding
12 translation thereof into English, consisting of two pages, is being
13 tendered and marked as Prosecution Exhibit P951.
14 MS. RICHARDSON: Thank you, Your Honour.
15 Q. Now, Mr. Sacirovic, you testified that you observed and you
16 filmed, or was part of an interview where Serb civilians were in
17 Srebrenica and that they were exchanged. Do you remember that testimony?
18 And we watched a video of you interviewing them.
19 A. Yes.
20 Q. Do you know whether -- where those people were from exactly? I
21 think you said it could have been from Karno.
22 A. They were from the villages to the east of Srebrenica. The
23 village of Karno, that was the information I received during my interview.
24 It's a very small village that cannot be found on the map.
25 Q. And was it a Muslim - excuse me - was it a Serb village or was it
1 a mixed village?
2 A. I believe it was a Serb village. But let me tell you, all these
3 villages were mixed. Some had a Muslim majority, others a Serb majority.
4 But for the most part, they were mixed. As for the village of Karno, I am
5 not sure whether it was a Muslim or a Serb village.
6 MS. RICHARDSON: Your Honour, I'm being advised that there needs
7 to be a correction to the transcript, and it's page 78, line 9, where the
8 exhibit number is entered as 951 and I believe it's 591.
9 JUDGE AGIUS: Thank you, Mr. Wubben, and thank you,
10 Ms. Richardson. That's correct. It's being marked as Prosecution exhibit
11 5 -- P591 and not 951 as is shown on the transcript.
12 MS. RICHARDSON: Thank you, Your Honour.
13 Q. Mr. Sacirovic, do you know how it was these Serb civilians were --
14 why it was they were taken prisoner and ended up in Srebrenica, in the
15 town of Srebrenica?
16 A. I don't know when they were taken prisoner, why or by whom. I
17 only know that Nurija Jusufovic came to me and told me that the chief had
18 ordered that we should go and film the exchange of prisoners, and that's
19 what you saw on the video footage.
20 Q. Do you know who it was that was exchanging them, who it was on the
21 Muslim side, and whether or not this person was negotiating with the Serb
22 side? Do you have any information of that nature?
23 A. The prisoners were taken for exchange by the commander of the
24 civilian police, Nurija Jusufovic. We made this video footage, as ordered
25 by the chief. They were taken further for the exchange, but I don't know
1 whether they were in fact exchanged or where. I completed my part of the
2 job and went back.
3 Q. Now, you -- could you tell us if, having lived in -- I believe you
4 were born in Hranca and you lived in Glogova. Did you --
5 A. Yes.
6 Q. Did you frequently visit the Serbian side, across from the Drina
7 River, to engage in any type of business activity, such as shopping or
8 working or anything of that nature?
9 JUDGE AGIUS: When? Which period of time are you referring to?
10 MS. RICHARDSON: Thank you, Your Honour.
11 Q. Before the war.
12 A. Yes. Before the war, as I said, in January 1992, I went to Sabac,
13 bought a gun -- bought a rifle and returned.
14 Q. And even -- that wasn't the only time you visited, I take it,
15 during your lifetime.
16 A. To Serbia? Well, before the war I went to Serbia several times.
17 Q. And not only you, but the civilian population in your area,
18 Glogova, the villages that are close to the Drina, I take it that people
19 would frequently go to Serbia and people from Serbia would come to the
20 Bosnian side as well.
21 A. Well, it was a free country. People could go wherever they wanted
22 to go. There were people from Bosnia who worked in Serbia. There were
23 people from Serbia who worked in Bosnia or Croatia. All these were
24 republics of the former Yugoslavia. There was freedom of movement for
25 everyone who wanted to move about.
1 Q. So there was an integration of the Muslims from the Bosnian side
2 of the Drina, as well as the Serbs from the Serb side, across? Your lives
4 A. Before the war, yes.
5 Q. Indeed. And so it would not be an unusual occurrence for a
6 Bosnian, a Bosniak, someone of Muslim ethnicity, from the Bosnian side, to
7 use Serb words, and I take it the same is true, that for a Serb from the
8 Serbian side, it would not be unusual for them to use a Bosniak word or a
9 word used by Muslims, because they had been so integrated over the years.
10 JUDGE AGIUS: Yes, Mr. Jones.
11 MR. JONES: Yes. Your Honour, I think that question is so vague
12 that the witness couldn't possibly answer. If we're talking about the
13 Ekavian dialect and the Ijekavian dialect, then perhaps the witness can be
14 asked about that, but which words is my learned friend referring to.
15 MS. RICHARDSON: First of all, Your Honour, let me say, I don't
16 think counsel should suggest to me what I am asking him about. It is my
17 cross-examination, and I am seeking to elicit from him whether or not
18 there was an intermingling of various phrases or language, and if I would
19 suggest counsel not suggest to the witness where I'm going.
20 JUDGE AGIUS: He hasn't suggested. I think it was obvious from
21 your question, in any case.
22 MS. RICHARDSON: Well --
23 JUDGE AGIUS: But I think you should proceed and take it in --
24 take it in parts.
25 MS. RICHARDSON: Okay.
1 JUDGE AGIUS: Okay.
2 MS. RICHARDSON:
3 Q. So let me ask this, having heard the exchange, Mr. Sacirovic: It
4 wouldn't be unusual, I take it, for the Muslims from the Bosnian side of
5 the Drina to use some Serb words?
6 A. The Muslims from Bosnia and Herzegovina speak the Ijekavian
7 accent, for the most part, whereas in Serbia they use the Ekavian variant,
8 which is why one can always know whether a person comes from across the
9 Drina River, that is, from Serbia, or from Bosnia-Herzegovina. Therefore,
10 there is a difference in the language or in the accent, as it were. There
11 was a big difference.
12 Q. And I do understand that in general there was a big difference,
13 but --
14 JUDGE AGIUS: He hasn't answered your question.
15 MS. RICHARDSON: Yes. I'm going to try to do that.
16 Q. I'm asking if there were phrases or words that the Muslim Bosniaks
17 may have adopted from the Serbs because they had been -- their lives were
18 so integrated.
19 A. No.
20 Q. So it's unheard of for a Muslim from the Bosnian -- a Bosniak
21 village aside of the Drina to ever use a Serb word? Not the entire
22 dialect; a word or a phrase.
23 A. There is the following possibility, if this is a Bosniak Muslim --
24 a Bosnian Muslim or a Bosniak. Even the Serbs speak the Ijekavian dialect
25 if they were from Bosnia-Herzegovina. However, if a person had been
1 living in Belgrade for 10 or 15 years, then it was only normal for the
2 person to use the Ekavian dialect. I am not aware of any other such
4 Q. Mr. Sacirovic, I would ask you to answer the question that I'm
5 asking. I'm not asking about the dialect in its totality. I'm asking
6 about a word or a phrase from the dialect that a Muslim would adopt
7 because he would have been associating with Serbs for all of his life.
8 A. Let me tell you: Yes, such phrases were possible. One could not
9 rule that out. But I don't know what you're asking me specifically about.
10 I don't find your question clear.
11 Q. I believe you have answered the question. So the answer is yes,
12 that that's -- that was the case, that Muslims would or could use Serb
13 words or phrases because their lives had been so integrated throughout the
15 A. My answer to you was yes, if the person had spent a longer period
16 of time in Serbia, it was natural for that person to adopt the dialect.
17 Q. Of course. Thank you. You did answer my question.
18 Now I would like to ask you -- move on to another area and get
19 back to the work of your commission. You testified that the work of your
20 commission also entailed documenting all war crimes, not just those
21 committed by Serbs against Muslims. Would that be correct?
22 A. Yes, that's correct.
23 Q. And with that in mind, did you visit any -- well, did you hear --
24 I should ask: Did you hear about crimes committed by Muslims against
25 Serbs during 1992, 1993, and up until the time you left Srebrenica in
2 A. No, I'm not aware of that.
3 Q. So not one person indicated to you -- when I say "person," not any
4 of the Muslims you came in contact indicated to you that crimes were being
5 committed against Serb civilians?
6 A. I did not have occasion to hear that.
7 Q. Well, did you hear about civilians being killed in the actions
8 orchestrated by the Muslims' fighters?
9 A. No.
10 Q. When you interviewed the fighters, did they talk to you about the
11 casualties on the Serb side?
12 A. No. I didn't even ask them about it. It simply wasn't my task.
13 Q. I understand that.
14 A. I did not talk much to the fighters. I was more interested in the
15 civilian population. I wanted to know when and where a crime was
16 committed. It is true that we were collecting information about any
17 crimes committed by any side. However, I simply did not have the
18 opportunity, Madam Prosecutor. I was cut off. I did not have access to
19 the territory to -- eye-witnesses who on the other side who would be able
20 to provide information on a war crime committed by the Muslim side, if
21 any. And I assure you that I would have done my task in that case just as
22 I did for the other side.
23 Q. Thank you. Now, did you visit Kravica in January of 1993,
24 after - thank you - after there had been an action by the Muslim fighters
25 on January 7th of 1993?
1 A. No. I visited Kravica sometime on the 8th, 9th, or 10th of March,
2 1993, when the French general Philippe Morillon was about to arrive and we
3 had an order to go to Konjevic Polje on the occasion of his arrival.
4 However, because of the Serbian shelling attack, I came down to Kravica
5 and by the time I reached the centre of Kravica, the shelling started and
6 I ordered my team to return as soon as possible because there were clashes
7 down there. It was dangerous. And that was the only time I spent in
8 Kravica and Glogova. It was later on that I came to Konjevic Polje and
9 Glogova. At that point in time, we were not allowed to go further.
10 Q. And during the time that you did visit Kravica and Glogova, these
11 were the periods that it was in the hands of the Muslims; is that correct?
12 A. Yes.
13 JUDGE AGIUS: Let's assume -- let assume it.
14 MS. RICHARDSON: Yes, Your Honour. Thank you.
15 JUDGE AGIUS: Might as well do that.
16 MS. RICHARDSON: Yes.
17 Q. And when you arrived at these places, even though you didn't --
18 when I say "places," give an example, Glogova and Kravica, even though you
19 didn't stay long, did you notice that the houses and some of the buildings
20 had been damaged?
21 A. Some houses were torched and damaged. That's true. But I went
22 along the asphalt road. I was with my team. There were many people
23 fleeing from Konjevic Polje in the direction of Bratunac and Glogova and
24 were directed to go to Srebrenica. Chaos prevailed already at that time.
25 It was an emergency situation. As I heard the explosions and I saw what
1 was going on, I ordered the members of my team to go back, because it was
2 not safe. And that's how we returned to Srebrenica.
3 Q. And you said that houses were torched. Were they -- those houses
4 that you observed that had been torched, was this in Kravica or Glogova?
5 Do you remember?
6 A. Let me tell you this: The houses in Glogova were razed to the
7 ground, all of them; 100 per cent of them were razed to the ground. As
8 for Kravica, I did not pass through the entire village. I only arrived to
9 the centre, and I saw maybe some dozens of houses. Some of them were
10 singed, a bit burnt; others were not. However, I was not in a position to
11 observe these matters. Had the situation been safe, I would have filmed
12 all of this, including General Morillon's arrival. However, the
13 circumstances prevailing at the time did not permit us to do so, and we
14 had to return.
15 Q. So even if -- I'll rephrase the question. When you listened to
16 the radio - you were telling us earlier that you had a transistor radio
17 and would listen to the Serb news, et cetera - did you hear that the Serbs
18 were stating that a number of their civilians had been killed in this
19 region? And by "the region," I mean had been killed in Kravica or had
20 been killed in Glogova or Jezestica during 1992 and 1993, or in Rakovici.
21 Did you hear any of that on the radio?
22 A. While I was listening to the radio, and I listened only
23 occasionally, I did not hear the Serb radio broadcasting that information.
24 I did not have occasion to hear that.
25 Q. And you were asked -- I just -- one more question with respect to
1 damage to Serb property or killing of Serb civilians. You were shown an
2 exhibit, and I believe it was Exhibit 294. And part of that exhibit
3 included information regarding property damage that had occurred in
4 various areas. And I'm not going to go through all of it right now, but
5 it claimed Jezestica, Kravica, et cetera. So is it your position that you
6 were not in a position to confirm the information about the damage of the
8 A. I was not in a position to do that. I wasn't there. And if I had
9 no evidence, I can't assert that. It would be wrong. So I don't know
10 anything about that.
11 Q. And I take it that, again, you didn't speak to anyone in
12 Srebrenica or hear about Serb houses being burned in Jezestica and other
13 areas in the region?
14 A. No.
15 Q. You were asked about whether or not you know Kemo. I believe his
16 name is Kemal Mehmedovic, and I probably didn't pronounce it correctly.
17 Do you recall that testimony when you were asked by Mr. Jones?
18 A. Yes. I recall that. He asked me about Kemal Mehmedovic. There
19 are many people nicknamed Kemo but I do know Kemal Mehmedovic.
20 Q. And you know him from Pale, I take it?
21 A. Yes. He hails from Pale, and I spent almost two months there.
22 Q. And during the two months that you were in Pale, did you -- did
23 you come in contact with him?
24 A. We would see each other occasionally, but we weren't really close
25 friends. I'm acquainted with the man.
1 Q. And during that period of time, do you know if he was part of any
2 of the fighting groups that you've discussed, perhaps under Mirzet
3 Halilovic, or anyone else?
4 A. No. At that time, he did not belong to any group. They had a
5 tractor, they had horses, and he and his father worked in the village. I
6 didn't observe him belonging to any armed group in the area during the
7 time I was in Pale. As for later, when I went to Srebrenica, I don't know
8 where he went or what he did, or anything else about him.
9 Q. And while in Srebrenica, did you happen to hear of a story
10 involving Kemo where he was carrying around the head of a Serb individual?
11 A. This is the first time I've heard of that.
12 Q. This was the first time you've heard of it today in this courtroom
13 or did you hear of it after the war?
14 A. This is the first time, now, in the courtroom, that I've heard
15 about Kemo carrying around a head.
16 Q. Okay. Thank you. I would -- just one other question with respect
17 to the military police. Did you -- you said you knew Mirzet Halilovic and
18 he had other policemen under him. Did you talk to those other policemen
19 at any point in time during the time that you were in Srebrenica?
20 A. No. In my previous testimony, I have already said I didn't know
21 these men and they were not in uniform, so it was hard to identify them.
22 I only knew Mirzet Halilovic, and the reason I knew him was that I would
23 come across him in the building of the Srebrenica municipality, when he
24 came to report to the War Presidency president, Mr. Avdic. As for the
25 rest, it did not fall within the domain of my office. And Srebrenica was
1 overcrowded, and you couldn't tell who was who.
2 Q. Of course. Now, when you testified previously about the Serb
3 civilians being exchanged, did you have occasion to visit the prison in
4 Srebrenica, either the police station, where there was detention cells, or
5 the other prison? Did you know that there were Serb prisoners being held
6 there in perhaps October or in January and February of 1993? Did you know
7 about that?
8 A. No, Madam Prosecutor. The only prisoners I knew existed in
9 Srebrenica were the ones I interviewed. Nurija Jusufovic, the commander
10 of the civilian police, came to me and said, "The president of the War
11 Presidency has ordered that we go and film those civilian prisoners of
12 war." They were people who were poor, poor people, in a miserable state.
13 I went and I filmed them, and that was all. As for others, for the first
14 time I have heard this, and I cannot tell you anything about that.
15 JUDGE AGIUS: Yes, Ms. Vidovic.
16 MS. VIDOVIC: [Interpretation] Your Honours, a correction. The
17 witness did say "poor people." He did not say -- he did not use those
18 other words, "in a miserable condition." I don't think the interpreters
19 should add to what the witness said. He only said "poor people."
20 THE WITNESS: [Interpretation] I did say poor people, because we
21 were all poor people. When you look at the tape, they were no different
22 from me or the rest of us. You saw how thin we all were. We were all
23 poor, all in the same situation.
24 JUDGE AGIUS: All right. Thank you, Madam Vidovic.
25 Ms. Richardson.
1 MS. RICHARDSON: Yes, Your Honour.
2 JUDGE AGIUS: Incidentally, I'm informed that we definitely have
3 to stop at 1345 because this courtroom is needed by another team for other
4 purposes at 1350.
5 MS. RICHARDSON: Your Honour, I will not be done, so ...
6 JUDGE AGIUS: Then we will --
7 MS. RICHARDSON: Yes, thank you.
8 Q. Now, you testified you didn't know about the Serb prisoners. Did
9 you hear any rumours in Srebrenica that prisoners were being held there,
10 other than the ones that you observed?
11 A. Believe me, had I heard about it, I would have done whatever was
12 within my ability to do. I didn't even know about these prisoners that I
13 interviewed until Nurija Jusufovic came and told me that the president of
14 the War Presidency had ordered that we go and film them. I didn't know
15 about any other prisoners apart from the ones I interviewed. I didn't
16 know any other prisoners existed in Srebrenica. That's what I know.
17 Q. So when is the first time you heard that there were other Serb
18 prisoners in Srebrenica? Is it only as you arrived in the Tribunal this
19 week, or did you hear about this at some later date -- some earlier date,
20 excuse me?
21 A. This is the first time I've heard there were other Serb prisoners
22 in Srebrenica, apart from the group I interviewed. It's only here in
23 The Hague that I've heard, and I've heard it from you, that there were
24 other Serb prisoners in Srebrenica. I don't know of any others, apart
25 from the ones I interviewed.
1 Q. So would you be surprised to learn that there are Serb
2 prisoners -- that there were Serb prisoners and that they were beaten
3 while they were held in detention in Srebrenica and that perhaps some may
4 have died there? Would that surprise you?
5 A. Yes. As a person, I would have been surprised, yes.
6 Q. Now, you testified that you had contact with Hamed Salihovic. Or I
7 should say: Did you have contact with Hamed Salihovic?
8 A. I did have contact with Hamed Salihovic in 1994, while I was
9 secretary of the War Presidency of Bratunac municipality. At the time,
10 Hamed Salihovic was a president of some kind of subregion on paper, and we
11 would discuss whether this subregion of Vlasenica, Bratunac, Zvornik,
12 Srebrenica, could come to life, start functioning. But I assert with full
13 responsibility that this was not possible. It could never begin
14 functioning because of the situation we were in, the occupation, the daily
15 shelling, the fact that people were being killed on a daily basis. Hamed
16 Salihovic, at that time, was the most influential political figure in the
17 area, and that's what I know about him.
18 Q. In 1992 and 1993, were you aware of what type of role or the
19 various tasks Mr. Hamed Salihovic had in Srebrenica?
20 A. Believe me, I'm not aware of any other role of Hamed Salihovic
21 during the war, up until 1994. When I met him in 1994, in the office of
22 the president of the War Presidency of Bratunac municipality, he told me
23 that before the war he had worked in the Srebrenica public security
24 service. That's when I got to know him a bit better. The CSB. Before
25 that, I didn't know Hamed Salihovic.
1 Q. And did he talk to you about the fact that -- well, I'll rephrase.
2 And you don't know whether or not he was involved with the
3 prisoners in Srebrenica in August -- in October of 1992 or into 1993? You
4 wouldn't know that, I take it.
5 A. I'm not aware of that.
6 Q. In fact, you weren't even aware that there were prisoners;
8 A. Yes, that's correct. I didn't know there were any other
9 prisoners, or any prisoners at all, until Nurija came and told me to film
10 those people who were going to be exchanged.
11 MS. RICHARDSON: Your Honour, I think this is an opportune time to
13 JUDGE AGIUS: I thank you, Ms. Richardson.
14 Mr. Sacirovic, we have to stop here, because our time is over and
15 this courtroom is needed by another Trial Chamber. We will continue and
16 finish tomorrow morning. You won't be here for long. And I think the VW
17 section can proceed with the preparations to repatriate the witness, at
18 the earliest possible opportunity. So I thank you, and we'll meet again
20 Tomorrow I am having a sitting myself at 8.00, separate from this
21 case, and I hope to finish by 9.00. I hope -- I'll make an effort to
22 finish by 9.00, but it's the Seselj case. It doesn't make a difference if
23 it's this courtroom or another courtroom. The question is: I don't know
24 for sure that I will manage to finish by 9.00. But I will make a big
25 effort to finish by 9.00 so that we can then start immediately after and
1 finish with this witness. All right?
2 MS. RICHARDSON: Yes, Your Honour.
3 JUDGE AGIUS: Thank you so much.
4 --- Whereupon the hearing adjourned at 1.46 p.m.,
5 to be reconvened on Thursday, the 3rd day of
6 November, 2005, at 1.46 p.m.