Page 18594
1 Monday, 3 December 2007
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.04 a.m.
5 JUDGE AGIUS: Good morning, Madam Registrar. Would you call the
6 case, please.
7 THE REGISTRAR: Good morning, Your Honours. This is the case
8 number IT-05-88-T, the Prosecutor versus Vujadin Popovic et al.
9 JUDGE AGIUS: Thank you. All the accused are present.
10 Prosecution is Mr. McCloskey and Mr. Nicholls. From the Defence teams I
11 notice the absence of Mr. Meek, Mr. Bourgon and Mr. Josse.
12 All right. Any preliminaries? Yes, Mr. Nicholls?
13 MR. NICHOLLS: Good morning, Your Honours. Good morning to my
14 friends.
15 I think the only preliminary is that Mr. Blaszczyk we planned to
16 have testify today regarding what we've called the road book, the
17 locations on the Petrovic video. Two short preliminaries. One, I think
18 my estimate was off. I said two hours of direct. I think it's going to
19 take me quite a bit longer than that probably most of the day and I've
20 told my friends that. And the second is that I believe we need the
21 response to the 65 ter motion.
22 JUDGE AGIUS: Yes. Obviously, I was coming to that actually first
23 and foremost. What's the position, Mr. Lazarevic? I see he's interested
24 in intervening.
25 MR. LAZAREVIC: Yes, Your Honour, I will make a response on behalf
Page 18595
1 of Mr. Borovcanin Defence. The Prosecution, in its motion dated 27th
2 November 2007, requested five exhibits to be added to their 65 ter list.
3 JUDGE AGIUS: Yes.
4 MR. LAZAREVIC: For three of these, our team or, rather,
5 Mr. Borovcanin's Defence takes no position. These are reports pertaining
6 to the location and procedure for seizure of a video. I will read the ERN
7 numbers for the record. It's 0606-0071 for B/C/S version, and 0606-0073
8 in English. The next one is 0606-0070 in B/C/S and 0606-0072. It's a
9 receipt for the temporary seizure of a video. The third one is V000-7149.
10 It's a videotape of the Srebrenica events. It's more or less the same as
11 the video we already have in the evidence.
12 As for the first two exhibits proposed by the Prosecution, I will
13 refer to the first one as road book. These are still frames from the
14 Petrovic video and the other one is interactive road book CD, so I'll call
15 it interactive CD. We oppose to the admission of these two documents or
16 rather these two exhibits to Rule 65 Prosecution list for the following
17 reasons. First of all, we believe that the probative value of these two
18 evidence is not sufficient to justify the -- their admissibility to Rule
19 65 ter list of the Prosecution. These two exhibits were made recently by
20 the Office of the Prosecutor so their probative value is a very relative
21 one. These are not documents generated during the events covered by the
22 indictment. These are Prosecution-made exhibits which were made very
23 recently and for this reason, their probative value is not that high.
24 On the other hand, we submit that these two exhibits are
25 repetitive to other exhibits in this case. First, these are still frames
Page 18596
1 from the Petrovic video. We have seen Petrovic video many times in this
2 courtroom and I believe that we will also be able to see it on many other
3 occasions, so I do believe that it's already contained in the evidence of
4 this case.
5 The Trial Chamber at the very beginning of this case was on site
6 visit and, Your Honours were able to see all these locations, your
7 attention was directed towards some specific places there, and thus I
8 believe that Your Honours are very familiar with all these locations, with
9 all these -- and furthermore, these two -- these two exhibits are
10 repetitive to each other. They both contain same photographs and same
11 still frames from the very same video, and I believe that the Prosecution
12 has not shown good cause to admit it on to their 65 ter list.
13 JUDGE KWON: So Mr. Lazarevic, can I take it that you are not
14 challenging those photos are stills from that video?
15 MR. LAZAREVIC: By all means, Your Honour you are perfectly right.
16 These are all still frames from that video and there is no doubt about it.
17 JUDGE AGIUS: Thank you. Do you wish to comment, Mr. Nicholls?
18 MR. NICHOLLS: Yes, briefly, Your Honour. I think my friend's
19 really made two objections, one that this evidence would be cumulative and
20 two that the probative value would be low, and Your Honours, I don't think
21 either of those objections are a valid reason to reject this evidence out
22 of hand before you've seen it and heard it. First of all, this exhibit,
23 this demonstrative exhibit, was -- has been sometime in the making. It
24 was begun in 2006 and we gave copies as we worked on it to the Defence and
25 to Mr. Lazarevic so he could review it and we talked about it together and
Page 18597
1 I haven't heard any objection as to the accuracy of the locations marked
2 in this exhibit. What it is intended to do is to show Your Honours, when
3 you see a still or a part of the Petrovic video, where that photo, where
4 that portion of the film was actually taken and I think that will be very
5 useful because watching the video, it is sometimes difficult to tell
6 exactly where one is.
7 Mr. Blaszczyk is a very experienced investigator on this case.
8 He's been up and down that road. I'll proffer he'll testify many, many
9 times. And he spent a long time working out on this video where different
10 portions were taken and he used GPS technology to map it precisely and
11 that's what we want to show you is where different portions of these
12 videos were taken. And it's important because for a lot of this video
13 which we'll learn from the next witness, Mr. Petrovic, Mr. Borovcanin was
14 present in the vehicle while the video was being taken. I don't think the
15 evidence is cumulative because true these are stills from the video but
16 there were also stills taken of the same locations showing where we are
17 because the video stills are sometimes -- sometimes parts of the video are
18 blurry or it's difficult to tell exactly where one is.
19 The exhibits, the book and the CD are not cumulative to each other
20 because although they contain the same photos, the CD allows the person
21 operating it to see left and right and up and down and move around and
22 gives a much better perspective than just the flat photographic book can.
23 It's true that Your Honours went on a site visit a long time ago at the
24 beginning of this case and I think that's a good reason to admit this
25 evidence, because it will allow Your Honours, I hope, to remember
Page 18598
1 different places because we have more current photographs in here of the
2 locations which Your Honours saw as well as the corresponding photos from
3 the video which was taken in 1995.
4 The other reason I think it's important to put this in in this
5 format is Mr. Petrovic, who actually shot the video, based on his
6 interview is unable to tell where all of these places were that he was
7 shooting so we can't hear it all just from him. He said in his interview
8 that he wasn't sure where some of these places are that he filmed, he
9 wasn't that familiar with the area and he actually said in part of his
10 interview that he went back recently and tried to figure out where he had
11 been shooting different scenes and he couldn't do it. So I think this is
12 the only way and the best way to provide you with an overview of that
13 important piece of evidence, the video, and to show you the directions
14 that were taken during the video, the precise places where we stopped, and
15 later where different people are on the video at different times of the
16 day on the 13th and the 14th of July. So I don't think it's cumulative.
17 Of course, at the end after you've heard the evidence and at the end of
18 the case when you weigh all the evidence you'll be able to assign it
19 whatever probative value you think it deserves, but I don't think now is
20 the time to reject it out of hand. Thank you.
21 JUDGE AGIUS: Okay. I thank you. Thank you, Mr. Nicholls.
22 Mr. Lazarevic, if you look at the Prosecution motion of the 27th November
23 and precisely the part where the first of these five documents sought to
24 be included in the 65 ter list is described, there is also a comment made
25 there, namely that -- I'm going to read it: "A substantially similar
Page 18599
1 rough draft of the road book was disclosed in the late 2006 and the
2 Defence were told that an improved -- an improved version of the road book
3 was being produced."
4 I haven't heard you comment on this because I suppose it does
5 carry some weight.
6 MR. LAZAREVIC: Well, because -- yes, Your Honour, I did not
7 comment and that is true. I mean, the Prosecution did provide us with a
8 copy of this draft material, not just one but on two or three occasions
9 because this material was changed on quite a number of occasions. Last
10 one that we received, and this is the one I believe that the Prosecution
11 wishes to admit to their 65 ter list, we received on Friday afternoon if
12 I'm not wrong. My colleague will tell more. There are some changes. I
13 cannot say these are significant changes. I have to be fair to the
14 Prosecution. These are not significant changes comparing to the previous
15 draft, but they did provide us with this. However, what I'm suggesting is
16 that some of these photographs containing this evidence are made last
17 year, I think, and I don't see how can they assist the Trial Chamber. I
18 mean, these are photographs of some, well, some houses, some meadows and
19 things like that as they look now. These are not -- part of them are
20 still frames from the video while the other part are photographs taken
21 right now.
22 JUDGE AGIUS: Okay. Thank you, Mr. Lazarevic. Does anyone else
23 wish to comment on the Prosecution motion? Yes, Mr. Nicholls?
24 MR. NICHOLLS: Could I just say, Your Honour, and I thank my
25 friend for pointing it out the changes were very minor as we went along
Page 18600
1 with this. They weren't new photos, new material; it was mainly
2 reordering it to try to put it in a more logical manner using the same
3 photos and changing some of the text underneath the photos, the
4 explanations but it's the same book.
5 JUDGE AGIUS: Thank you. Any further comments? None. I need to
6 confer with my colleagues.
7 [Trial Chamber confers]
8 JUDGE AGIUS: We are unanimous here in disagreeing with you,
9 Mr. Lazarevic and agreeing totally with the submission of the Prosecution,
10 that the inclusion of all these five documents, particularly the first two
11 probably, of these five documents, are important for a better
12 understanding of the video that eventually we will be seeing.
13 So they are -- the Prosecution request is being acceded to, and
14 these will be included in the 65 ter list. As to probative value, the
15 important sense of the word, as you put it, Mr. Nicholls, this is
16 ultimately a matter that will have to be tended to, addressed, by the
17 Trial Chamber at the appropriate time and not now. Thank you.
18 All right. Can we bring in Mr. Blaszczyk? Or something else?
19 One moment, Madam Usher.
20 MR. NICHOLLS: Sorry, Your Honour, just the last three exhibits, I
21 don't want to speak for my friend but I believe at this point there is no
22 objection to the documents.
23 JUDGE AGIUS: No, no. What we were admitting is the five of them,
24 not just the two.
25 MR. NICHOLLS: Sorry.
Page 18601
1 JUDGE AGIUS: As far as the last three are concerned, we noted
2 that Mr. Lazarevic took no position.
3 MR. NICHOLLS: Thank you.
4 JUDGE AGIUS: Judge Kwon anticipated what I was going to come to.
5 Mr. Ostojic and Mr. Nicholls, Mr. Ostojic hadn't finished his
6 cross-examination, and I took this motion to mean that this will come up
7 during re-examination.
8 [The witness entered court]
9 JUDGE AGIUS: Or is it going to be further testimony? I don't see
10 it as a further testimony.
11 [Trial Chamber confers]
12 JUDGE AGIUS: In other words, do you plan to have Mr. Blaszczyk
13 finish the previous testimony on that chapter and then summon him again on
14 this new chapter or were you going to deal with this matter during
15 re-examination?
16 MR. NICHOLLS: What -- I spoke to my friend about this yesterday,
17 Your Honour. What I intended to do, if it pleases the Trial Chamber is
18 now start with the road book and finish the road book hopefully today and
19 then when we have time at the end, Mr. Ostojic would finish his
20 cross-examination on the Drina Corps and any re-examination would take
21 place after we conclude this chapter.
22 JUDGE AGIUS: All right.
23 Agreed, Mr. Ostojic? Because this concerns you more than anyone
24 else for the time being.
25 MR. OSTOJIC: Thank you, Mr. President. If it's acceptable to you
Page 18602
1 I could work with that.
2 JUDGE AGIUS: For us it's neither fish nor fowl.
3 MR. OSTOJIC: Nor for me, Your Honour.
4 JUDGE AGIUS: So we are not having breakfast this morning.
5 Good morning, Mr. Blaszczyk.
6 THE WITNESS: Yes, good morning, Mr. President.
7 JUDGE AGIUS: Yes. We are going to open a new chapter today in
8 your testimony, as you are most probably or definitely aware but then at
9 some later point in time during the day we'll return to the Drina Corps
10 collection recovery, where Mr. Ostojic has still got to finish his
11 cross-examination. So I think for this purpose, I need to administer the
12 oath again to you. Madam Usher.
13 THE WITNESS: I solemnly declare that I will speak the truth, the
14 whole truth and nothing but the truth.
15 WITNESS: TOMASZ BLASZCZYK [Resumed]
16 JUDGE AGIUS: I thank you, sir. Please make yourself comfortable.
17 Mr. Nicholls.
18 MR. NICHOLLS: Thank you, Your Honours.
19 Examination by Mr. Nicholls: [Continued]
20 Q. Good morning.
21 A. Good morning, sir.
22 Q. Their Honours have been passed out copies of the book you made, 65
23 ter 2986. Mr. Blaszczyk, could you please briefly, very briefly, describe
24 what this book is and the -- what it shows us?
25 A. Your Honours, in February 2006, the witness Zoran Petrovic was
Page 18603
1 interviewed and during this interview he made available this raw material
2 he had recorded in Srebrenica area in July 1995. We made a copy of this
3 raw material for our purpose and then from the copied material, we got the
4 stills from this copied materials, we collected the stills in this road
5 book and also we found a location where the stills were -- where the
6 footage was recorded and we made our own pictures and also we attached to
7 this book for comparison purposes of course.
8 Q. Thank you. And can you just briefly tell us the different
9 versions of the Petrovic video that we have that are relevant to this
10 book?
11 A. We received a few version of the Petrovic video. We received a
12 Petrovic video, I mean the copy of the Petrovic video from BBC in 2002 and
13 we received in fact we copied raw material, Petrovic video, from him
14 during his interview in 2006, in February 2006, and also we have a copy of
15 Petrovic video which was handed over to us by the Ministry of Defence,
16 Bosnia-Herzegovina, in 2007.
17 Q. And could you just tell the Trial Chamber about the Studio B
18 footage, what we call the Studio B footage of the Petrovic video?
19 A. The Studio B footage of the Petrovic video, this is -- it was
20 broadcasted by the Serbian television in 1995, I believe it was July 1995,
21 and consists of the material which had been recorded by Mr. Petrovic
22 during his visit in Srebrenica area in July 1995, and we received a copy
23 of this broadcast from Studio B from Mr. Borovcanin during his interview
24 in 2002. He handed over this copy to us. And also, during the interview
25 with Mr. Petrovic, Zoran Petrovic, we received also a copy of the same
Page 18604
1 broadcast.
2 Q. And just to be clear, the Studio B footage is different because it
3 was edited material for broadcast, it's not exactly the same as the raw
4 material; is that right?
5 A. Yes, you are right. This is not exactly the same material. It
6 was edited material in the studio but consists, of course, the footage
7 from Petrovic, the raw material from the Petrovic video.
8 Q. I'd like to show you quickly a couple of documents, the first one
9 is 2988. This is the 26th of June -- 22nd of June, excuse me, 1996,
10 report on television footage from Srebrenica, a Main Staff document. Can
11 you just tell us what this document is? I think you'd already referred to
12 it.
13 A. This is report on television footage from Srebrenica signed by the
14 Colonel Milovan Milutinovic regarding the raw material recorded by
15 Zoran Petrovic, Pirocanac during operation in Srebrenica in July 1995.
16 Q. Okay.
17 A. How to [indiscernible] this raw material.
18 Q. Thank you. Could you just tell us again when did we receive this
19 document in the OTP?
20 A. The first time, in fact, OTP team had access to the archive of
21 army to the Ministry of Defence, Ministry of Defence Bosnia and
22 Herzegovina in Banja Luka in October of 2006, and during this -- these
23 meetings, you know, during this access to the archive, they located and
24 they scanned this document and when we received the scanned document here
25 in The Hague we requested the Ministry of Defence to send us the original
Page 18605
1 copy of this document.
2 Q. Okay?
3 A. And we received the original, the copy, the original document in,
4 I believe it was January 2007.
5 Q. Okay. Now, if we could have 2989, please?
6 JUDGE AGIUS: Mr. Nicholls, perhaps it's better to clarify this
7 now rather than later, if the witness can explain it. The name of
8 Zoran Petrovic, as we know him here, is Zoran Pirocanac and the witness
9 also mentioned both surnames, family names, Zoran Petrovic, Pirocanac. If
10 you could explain what the position is?
11 MR. NICHOLLS: Yes.
12 Q. Could you please explain --
13 JUDGE AGIUS: Whether he's Petrovic, whether he's both, whether
14 he's just Pirocanac.
15 MR. NICHOLLS:
16 Q. Yes, please explain.
17 A. Zoran Petrovic also use the nickname of Pirocanac or name of
18 Pirocanac. And he -- mostly he was both names, Petrovic, Pirocanac.
19 JUDGE AGIUS: Thank you.
20 MR. NICHOLLS:
21 Q. Just while we are on this document, who is this who signed it,
22 Colonel Milutinovic?
23 A. Colonel Milutinovic was the head of information department from
24 the Main Staff of army of Republika Srpska.
25 Q. Thank you. Now, if we could go to 2989, please. This is dated
Page 18606
1 24th of June 1996 and it's a receipt for a videotape. Just tell us very
2 simply what this document is.
3 A. This is also receipt for temporarily seized object regarding the
4 same tape which had mentioned in the previous document and we received
5 first the copy of this document along with a copy of the previous document
6 and later on, we received the original of these documents. The document
7 has been signed, I believe, by Ljubisa Beara.
8 Q. Okay. Thank you. I'm through with those two.
9 Now, I'd like you to explain a little bit more before we start
10 going through the book, how you actually took the photos which were taken,
11 the contemporary photos, up and down the road and matched them to the
12 stills from the Petrovic video. What did you actually do to make sure you
13 were getting photos of the correct locations?
14 A. Okay. Before I went on mission in -- to Bosnia-Herzegovina to
15 locate all these places, Petrovic video, we printed out the stills from
16 the Petrovic video, we took with us also the copy of high quality
17 recordings of Petrovic video, together with portable recorder, player,
18 with us, and we went to the places where the video had been recorded by
19 Petrovic. And when we were on the places, on this area of Srebrenica,
20 Potocari, Sandici, Lolici, Pervani, we were driving in the same road which
21 was used by Mr. Pirocanac/Petrovic and Mr. Borovcanin and we stopped all
22 these places. We compared the surrounding topographics with the stills we
23 had printed and with the video we had with us, and also we compare the
24 area which was located by us with the surrounding houses, with the curve,
25 with the made-up of the roads on the spot.
Page 18607
1 Q. Thank you. And besides this mission where were you putting
2 together photos for the road book, how familiar are you with those roads
3 in Srebrenica and Potocari, Kravica, Zeleni Jadar? How many times have
4 you been in this area yourself?
5 A. I can say I'm very familiar with this area. I've been there many
6 times, I don't know exactly how many but about 40, 50 probably.
7 Q. And if you could just tell us briefly who else was on that mission
8 with you.
9 A. Together with me on mission went also Zoran Lasic, our video
10 assistant and who made the copy of raw material of Petrovic and who was
11 also involved in this project, and in one day I believe Mr. Nicholls also
12 attended this trip.
13 Q. Okay. And can you just tell us, and we are nearly done with this
14 part, about how you used a GPS device while you were locating the
15 different places?
16 A. When we spotted the location which was depicted in Petrovic stills
17 we took the photos of these locations and also we recorded the GPS
18 readings of this particular location and we used, in fact we used two GPS
19 devices because we wanted to be sure that the readings is correct.
20 Q. I believe Your Honours have a copy of the book now. Do you have
21 your copy?
22 A. Yes.
23 Q. If we could just look at this now.
24 MR. NICHOLLS: Your Honours, what I plan to do soon is watch the
25 video and stop it at appropriate places and have the witness explain how
Page 18608
1 the photos and the stills are related to the newer photos. That will be
2 done in Sanction and we'll have the transcript of the video as we follow.
3 So I think it's best to use the hard copies of the book rather than to try
4 to switch back and forth from e-court because each time we have to get out
5 of Sanction and then try to find where we were again in the film so if
6 that's all right.
7 JUDGE AGIUS: And I think it will educate us better because later
8 on that's how we'll have to do it in any case.
9 MR. NICHOLLS: Yes, Your Honours, thank you.
10 Q. Now, briefly, Mr. Blaszczyk, could you just explain, it's pretty
11 self explanatory, we've got maps on the first five pages. Can you just
12 tell us what those maps show?
13 A. On the first pages we attached the three maps of
14 Bosnia-Herzegovina and the detailed maps of the area where the Petrovic
15 video had been recorded, the maps were created in BIC [sic] unit here in
16 The Hague by its officer and also we attached satellite image of the same
17 area.
18 Q. Okay. Now, it says, in the transcript, BIC unit. I think it's
19 GIS unit. Can you tell us very quickly what that is, GIS?
20 A. Of course, this is GIS unit, this is geographical information
21 system unit.
22 Q. Okay. Now, if we can just go to pages 6 and 7, this is chapter 1,
23 Potocari. And again, quite self explanatory but can you just tell us what
24 these numbered positions refer to on page 7 on the map?
25 A. This is a map of -- NATO map for Bosnia-Herzegovina, and on the
Page 18609
1 map also with the help with the assistance of GIS unit, I plotted the
2 location using the GPS readings we taken in our mission in May in
3 Bosnia-Herzegovina in these locations.
4 Q. Okay.
5 A. And I would like to say that this is chapter 1, and for each
6 chapter --
7 JUDGE AGIUS: One moment.
8 [Trial Chamber confers]
9 JUDGE AGIUS: All right. Let's proceed. Sorry for the
10 interruption but we needed to discuss something.
11 MR. NICHOLLS: Thank you.
12 Q. If you could continue, Mr. Blaszczyk, you were just saying for
13 each chapter and then you stopped. You had something to say.
14 A. I think I should say that I divided this book for five chapters,
15 and each chapter started from the map, detailed map, of the particular
16 area where the footage was recorded by Mr. Petrovic, Pirocanac.
17 Q. Okay. And if we could turn to pages 8 and 9, just so that we all
18 understand the way the book is set up, can you -- on the left we've got
19 the Petrovic video still, on the right we've got a photo taken in June by
20 you and the video assistant. Could you please explain the information on
21 these pages and the way you've set it up?
22 A. In each chapter, after the map, detailed map of the area, the
23 particular area, the map is followed by the page with the still or stills
24 from the Petrovic video, and these pages with the stills of the Petrovic
25 video is also followed by the recent picture -- recent picture -- the
Page 18610
1 picture made by us during our mission in Bosnia-Herzegovina, the picture
2 of the same area which was depicted in the previous page.
3 Q. And the counter underneath the photo on the Petrovic video, that
4 is from the original -- the copy of his original raw footage in the high 8
5 format, is that right?
6 A. Yeah. You are right. We used the counter of the digital recorder
7 device we used to copy the raw material from Petrovic and below also I
8 attached the information, the location where the stills was taken and the
9 position on the map, on the previous map of the same location which is
10 depicted on this picture or pictures.
11 Q. And here we've got 0:00:37:13 and is it right this that this means
12 we are at 37 seconds and actually at frame 13 of that 37th second? In
13 other words, it's not -- that is the last two digits refer to the actual
14 frame that was used on the videotape?
15 A. Yes, you are right. This is the counter from the digital recorder
16 device.
17 MR. NICHOLLS: Now, Your Honours, I should say that nearly every
18 time this is played on a different player, whether it's in a CD or
19 electronic, the counter may be a little bit different. When we loaded the
20 entire video, the same video, into Sanction, unfortunately, it's about
21 exactly four seconds ahead when you play it in Sanction. This is the most
22 precise numbering, which is on the tape which we'll be putting into
23 evidence but the exact still will -- may be about four seconds off if
24 you're playing it in Sanction. And I think now, Ms. Stewart, if we could
25 start playing the video which is 65 ter 2054, Your Honours. This is the
Page 18611
1 copy made during the interview of Mr. Petrovic, the copy of his raw
2 material which he brought to the video. And if we could -- stop at 41, 8.
3 [Videotape played]
4 MR. NICHOLLS: I think we went past it. If we could stop and just
5 go back a bit. That's -- forward a bit. Okay. That's close. We are at
6 36.9.
7 Q. What is the building here?
8 A. This is Dutch UNPROFOR base in Potocari, but it's not exactly the
9 same picture as we had on the page 8 of this road book but it's very
10 similar. We are coming to this picture.
11 Q. That's fine. It's 41.9?
12 A. Yeah.
13 Q. And this is heading in the direction now --
14 A. The car and the cameraman is reading to the direction of
15 Srebrenica. And on the page 8 we have the same still, we can see almost
16 the same still we can see on the screen. And on the right side, on the
17 page number 9, we have the picture taken by me and Zoran Lasic during our
18 mission and depict also the same -- the same building.
19 Q. And what is the date that this video was taken?
20 A. The video was taken on the 13 of July, 1995.
21 Q. Thank you.
22 [Videotape played]
23 MR. NICHOLLS: All right. Your Honours, this will speed up a
24 bit. There is more detail in the beginning in Potocari and we won't be
25 going through every page at this same pace.
Page 18612
1 Q. Okay. We are at 53.8. Could you just tell us what we see here on
2 page 10 of the book and we are at picture A.
3 A. We see the group of the people marching towards Bratunac, in
4 direction of Srebrenica, and this still was also recorded on the 13th of
5 July 1995 by Zoran Petrovic as another stills from the same location in
6 Potocari.
7 MR. NICHOLLS: If we could continue to about 102?
8 [Videotape played]
9 MR. NICHOLLS: Stop.
10 Q. All right. We went -- we are now at about picture B on page 10.
11 Could you tell us why you selected that one and labelled the Feros
12 building in the picture?
13 A. I selected this picture because in the background we can see the
14 building who is very recognisable, you know, from the spot, on the spot,
15 when you are in Potocari you can see this building. It's still in the
16 same shape. We called it Feros building. And we can see that people
17 walking also from direction of Srebrenica towards Bratunac.
18 MR. NICHOLLS: We'll play a little bit more.
19 [Videotape played]
20 MR. NICHOLLS: Thank you.
21 JUDGE AGIUS: I think if you want to refer to what's in page C,
22 you need to go back but I don't know -- I don't know whether you intended
23 to skip it purposely.
24 MR. NICHOLLS: I was going to skip that one, Your Honour.
25 JUDGE AGIUS: All right. Then I misunderstood you before. Okay.
Page 18613
1 MR. NICHOLLS:
2 Q. Now we've stopped at picture D and we've just gone through picture
3 C, we can see the sequence on the counters. Can you just tell us why you
4 selected this photo we see on page 10, photo D, from the original stills?
5 A. Yeah, these two photos are selected from this part of the video we
6 just played and it showed a group of the people walking from Srebrenica
7 direction towards Bratunac on the left side of the road looking towards
8 Srebrenica. It's also locations Potocari, also Dutch UNPROFOR base.
9 Q. And now, just as we are beginning to see how you set up the book,
10 can you show us on page 11 why you selected these photos and labelled them
11 and how you came to the conclusion that where we have A, B, C and D on
12 page 11, the markings in photo 3, that these correspond to the photos A,
13 B, C and D on page 10?
14 A. On the page 11 I put the picture of -- taken along the road from
15 former Dutch UNPROFOR base and the Feros building. And on the picture 2
16 and on picture 3 we can see the Feros building which is also depicted on
17 the stills from Petrovic book, on the picture, on the still B, from the
18 page 10.
19 Q. And so we can see, then, just if I understand you, that where
20 these photos, where this bit of video was taken was really directly in
21 front of and passing by the Feros building towards Bratunac?
22 A. Yes, you're correct.
23 MR. NICHOLLS: If we could continue playing now.
24 [Videotape played]
25 MR. NICHOLLS:
Page 18614
1 Q. All right. Thank you. We are now at approximately the photo A on
2 page 12. Can you just tell us -- and we see there witness van Duijn
3 speaking. Can you tell us where we are in these series of photos on page
4 12 and 13?
5 A. In this photo, we are in the Dutch APC check-point. It was
6 located -- this check-point was located about 50 metres north of the
7 express bus compound in Potocari, and almost in the front of the blue
8 building.
9 MR. NICHOLLS: Okay. If we could continue now.
10 [Videotape played]
11 MR. NICHOLLS:
12 Q. Okay. We are right now at about photo B on page 12 and we can see
13 the hill in the background. Again, can you tell us how you were able to
14 tell where this spot was?
15 A. With the same location what was the previous still, this is in
16 Potocari, about 50 metres from the bus compound in Potocari, north from --
17 of the express bus compound and the hills in the background are the same
18 hills which are depicted on the page 13 on my photos from 2006. And when
19 we played this part of the video, we could also notice the buildings of
20 Zinc Factory in Potocari, and part of the bus compound.
21 MR. NICHOLLS: Play, please.
22 [Videotape played]
23 MR. NICHOLLS: Thank you.
24 Q. Now, approximately at the last photo on page 12, photo D, we see
25 the woman walking towards Bratunac and the two UN APCs. Can you just tell
Page 18615
1 us about this concrete strip which we see on the right side of the photo
2 coming up to the UPC on the right?
3 A. This is a small bridge which is crossing the creek, the creek who
4 is passing the road from Budak area towards Potocari, to the left side.
5 Q. And where is that part of the little bridge over the drainage
6 creek, where would that be on the photo on page 13?
7 A. This is exactly on the right side, actually in the middle of this
8 photo, in the bottom of the middle of this photo we see the small bridge.
9 Q. Finally, that building on the left we see on page 13, can you tell
10 us about that building, the big white and brown brick building behind the
11 fence?
12 A. This is quite new building. It was built after the war in
13 Bosnia-Herzegovina, after 1995, I believe after 2000, 2003. And in the
14 background we can see also on this picture from page 13 the Zinc Factory
15 and Energoinvest factory and part of the bus on the left side behind the
16 new building, the part of the bus compound in Potocari.
17 MR. NICHOLLS: All right. If we could now play for a while and go
18 to page 14 and 15.
19 [Videotape played]
20 MR. NICHOLLS:
21 Q. Okay. We stopped at 7.27 on the Sanction, just a little bit past
22 the photo F on page 14, and you've got this location labelled as the blue
23 building and its yard opposite the Feros building. Can you just tell us
24 about these two pages, pages 14 and 15 of the book, where we are in the
25 video sequence we've just seen?
Page 18616
1 A. The stills from the page 14 were taken from the part of the video
2 we had played just recently, right now. And it was recorded on -- in the
3 yard of the blue building which is located in opposite of Feros building
4 on the road in Potocari and about, from this Feros building, distance to
5 the white house which is also located across from the DutchBat is about
6 100 metres towards Bratunac. And on the page 15, I made -- we made the
7 recent picture of the same area, I think it's very visible here that it's
8 the same building, the blue building and its surroundings and on the page,
9 the page 15, on the picture 4, I made a picture also of remains of the
10 fence which we can see on few stills from the page 14, on still B, still E
11 or still F. And the white house in relation to this blue building is
12 located about 100 metres towards Bratunac.
13 MR. NICHOLLS: Okay. Let's continue, please.
14 [Videotape played]
15 MR. NICHOLLS:
16 Q. Okay. We are on pages 16 and 17, now stopped at approximately
17 picture A on page 16 and we just noticed from the camera scenes that the
18 cameraman, Zoran Petrovic, was walking with his camera and the camera was
19 filming the ground as he walked. Where are we now?
20 A. Right now we are in the front of outside of the white house in
21 Potocari.
22 Q. And again, approximately -- this is -- you said about
23 approximately how long -- how far away is this from the blue building?
24 A. A very short distance. We could see how the cameraman left the
25 yard of the blue building and walked towards white house. He recorded a
Page 18617
1 group of the people in front of the white house. It was about 100, 150
2 metres.
3 MR. NICHOLLS: Okay. If we could just play now some more, please?
4 [Videotape played]
5 MR. NICHOLLS:
6 Q. We are now at just about, we've continued and we are now at
7 picture D on 16 -- excuse me, picture B. What do we see here?
8 A. We see the gate of the white house and the pile of the belongings
9 in front of the gate.
10 MR. NICHOLLS: If we could continue playing, please?
11 [Videotape played]
12 THE WITNESS: See the same group of the people which had been
13 recorded on the picture A from page 16.
14 MR. NICHOLLS:
15 Q. And then just as we've seen the camera pan this group of people
16 with Mr. Borovcanin and Mr. Kingori are just in the road near the
17 belongings; is that right?
18 A. Yes, that's correct.
19 Q. This is page 16, picture C. Continue, please.
20 [Videotape played]
21 MR. NICHOLLS: Okay. Stop. Thanks. Can we go to that? Stop
22 here.
23 Q. We are now at approximately picture 16 D and we will get to it and
24 we saw that the next frame is a picture of a large shell. Can you just
25 tell us what's happened here?
Page 18618
1 A. This is -- we see again the picture of the gate of the white house
2 located in Potocari, and when we have the frame of the white house gate
3 and the belongings in front of the white house, we got the picture of the
4 big shell. This is not recorded in Potocari, this frame but according to
5 the witness Petrovic it was recorded over later on probably at his house.
6 Q. And have you ever seen that shell yourself?
7 A. Yes. I seen the shell by myself when I went together with witness
8 Petrovic to his house in Belgrade to collect his raw material from his
9 house, he showed me the shell on his balcony. It's the same shell. Looks
10 the same and probably is the same one.
11 Q. Did he say it was the same or is that your conclusion from looking
12 at it?
13 A. He -- he told me that this is the same shell and what he's
14 recorded on his raw material.
15 Q. All right. Now, if we could look at -- this is quite self
16 explanatory but page 17 you've got B and D and A and C marked. This shows
17 the locations of the group of people in A and C as well as the pile of
18 belongings; is that right?
19 A. Yes. On the page 17, on the picture number 1, we see I marked
20 with B and D the location of the stills from the page 16 B and D, and A,
21 C, the location of the group of the people which are depicted on the
22 stills A, C, from page 16. And the second picture, this is a picture
23 taken from the position of A, C.
24 Q. Okay. You're talking about picture 2?
25 A. Yes.
Page 18619
1 Q. So if you're at position A, C, where Mr. Borovcanin and
2 Mr. Kingori are, you can look across the road at the Feros building; is
3 that right?
4 A. It's correct. When we look across, this is the Feros building and
5 we see part of the road.
6 Q. Okay. I'd like to now play a different clip. This is from Studio
7 B.
8 MR. NICHOLLS: Your Honours, this is the Studio B footage. It's
9 actually taken from our trial video because there it's got the captioning
10 already. Thank you.
11 [Videotape played]
12 MR. NICHOLLS: And I should say that was 65 ter 2011, the Studio B
13 footage which contains the close-up of the men on the balcony.
14 Q. Now, can you just tell us about the comparison clip before we
15 watch it that was put together of the raw material, which we received from
16 Mr. Petrovic, which contains the shell, compared to the Studio B material,
17 broadcast in Belgrade on 17 July 1995, which shows zoom up to the men on
18 the balcony.
19 A. Yes. We compared the raw material we received, we copied, from
20 Mr. Petrovic, and the Studio B broadcast material we received from
21 Mr. Borovcanin, and we played both of the clips together and we could see
22 that the clips are fit to each other and except the part where we see on
23 the raw material, the copied raw material, the shell from the balcony of
24 Mr. Borovcanin [sic] which was recorded over at later stage.
25 Q. Before we play that, could we just look at pages 18 and 19 of the
Page 18620
1 book?
2 A. On the --
3 Q. And just very simply --
4 JUDGE AGIUS: Yes, Mr. Lazarevic?
5 MR. LAZAREVIC: I could be wrong but here in the transcript we do
6 have on page 27, line 5 and 6, the shell from the balcony of
7 Mr. Borovcanin. I don't know whether I understood this properly but I
8 don't remember Mr. Borovcanin having any shells on his balcony.
9 THE WITNESS: No, of course this is the shell from the balcony of
10 Mr. Pirocanac, Petrovic.
11 JUDGE AGIUS: Thank you, Mr. Lazarevic, and Mr. Blaszczyk.
12 MR. NICHOLLS: Thank you.
13 Q. Now, I think it's quite obvious but just to be clear, on pages 18
14 and 19, we've got pictures of the men crowded on the balcony. This is the
15 first time in the book on the left-hand side where we've got images not
16 from the Petrovic video which he gave us but from the Studio B and it's
17 got the logo there; is that right?
18 A. Yeah, this is correct. We attached on this page, on page 18, the
19 stills from the Studio B broadcast which are not visible on the raw
20 material handed over to us by Mr. Petrovic.
21 Q. Thank you. Now, what I'd like to do, Your Honours, is play 2991,
22 which is a split-screen showing the two segments together.
23 [Videotape played]
24 MR. NICHOLLS: And on the right-hand side is the Petrovic video.
25 On the left will be the Studio B.
Page 18621
1 [Videotapes played]
2 THE WITNESS: On these two clips, on the right side we have the
3 clip from Petrovic raw material and on the left side we have Studio B
4 broadcast clip and we can compare how these two clips are fit to each
5 other.
6 MR. NICHOLLS:
7 Q. And other than about a one or two second gap, they come back to
8 the same footage at the end after the --
9 A. Yes.
10 Q. Thank you.
11 MR. NICHOLLS: That ends chapter 1. Your Honours, what I'd like
12 to do now, if I may, is --
13 JUDGE AGIUS: I don't know if I'm reading your mind. Are you
14 thinking of having the break now and continuing immediately after or
15 starting and having the break regularly.
16 MR. NICHOLLS: No, Your Honours I wanted now Mr. Blaszczyk to show
17 the way the CD part of Potocari works. The CD only has two sections
18 Potocari and the road, it doesn't have all the parts of the --
19 JUDGE AGIUS: Okay.
20 MR. NICHOLLS:
21 Q. So if you can hopefully this will work. We tried it on Friday.
22 Mr. Blaszczyk should be able to operate it from the laptop. And can you
23 just talk us through the way this works when you use the controls at
24 first?
25 A. Okay. Maybe I will tell that to this road book I attached also
Page 18622
1 the CD with presentation, with multi-media presentation of two chapters of
2 this road book, and we are using the computer software to play this CD,
3 and this is media quick player, QuickTime player, sorry, and we can use
4 this button, the button on the bottom, to control of this presentation.
5 The first button to the right, this is information button. Pressing this
6 button, we can mark all the area which is link to another picture or
7 stills. This is button marked with plus, we can zoom in -- I'm sorry, we
8 can zoom in -- we can zoom in the present picture, if you want. This is
9 zoom out. And the button on the left, we can go to the previous page.
10 Q. Okay.
11 A. And pressing the right button of mouse, we see the map of
12 Bosnia-Herzegovina with the marked area of Bratunac and Srebrenica. We
13 can also use this information button to see if everything is marked here
14 correctly. Pressing on this field, the link, we are coming to the map
15 closer to more detailed map of this area, come in again we have again more
16 detailed map of Bratunac area divided with two rectangles of Potocari and
17 also Sandici and Kravica area. We can go in and we have detailed map of
18 the area of Potocari. All these circles here with sign, we can see
19 pressing the button on the right and link to another view, another picture
20 or stills.
21 Q. Okay. Can you just -- these are the same still photos that we
22 have in the book. Can you just show us what you've included here?
23 A. Yeah. This presentation includes the same stills from Petrovic
24 video we use in the road book and the pictures we made in our mission in
25 this area in 2006. And we can, with this software, we can easily move
Page 18623
1 through these pictures and to have better view or better understanding of
2 the area where the --
3 Q. Okay. If you could go through and just show us what you've
4 included in here perhaps in the same order that we've just -- that you've
5 included it in chapter 1?
6 A. Okay. We start with the same order. Okay. We are in front of
7 the white house right -- I'm sorry, in front on the white house, we have
8 overview of this area. I'm heading towards direction of Bratunac. We see
9 the Dutch base compound in front of us. We are moving slowly towards
10 direction of Srebrenica. We are passing the Feros building which is
11 located across the road from white house. This road heading to
12 Srebrenica. Here we have link to another picture, extending picture, you
13 know, from the blue -- in the front of the blue building towards
14 Srebrenica.
15 On this -- on this picture, we marked the links to the stills from
16 Petrovic video and we located the place where the stills were taken.
17 This group of people are walking towards Srebrenica, towards,
18 sorry, Bratunac, from Srebrenica direction, and they on the road between
19 blue building and white house.
20 We have the group on the left side of the road, the same road. We
21 can see the group of the people walking from direction of Srebrenica
22 towards Bratunac. This is also in the same area. This is the blue
23 building and white house.
24 In front we see -- in front of us we see the building of Feros
25 company. We can press the link to the picture from the stills from
Page 18624
1 Petrovic video. We can see in the background the same building.
2 This picture was taken from the front of the white house. Now,
3 this link take us to the picture of the white house.
4 Q. And if we could go to this link you've got here on the road just
5 by the white house.
6 A. Yeah. We can press the link here. We see the picture, we see the
7 still from the Petrovic video, the group of the people including
8 Mr. Borovcanin and Major Kingori.
9 This link take us to the still from Petrovic video as well, in
10 front of the gate.
11 And we are coming to the balcony of the white house.
12 As I said at the beginning, we can use these buttons in the bottom
13 to zoom in and move closer.
14 Q. Okay. Thank you. Are there any other links of Potocari you
15 wanted to show?
16 A. Yes. We are in the yard of the blue building. We see the
17 location of the blue building in relation to the DutchBat, behind the
18 Feros building.
19 And this link can take us to the still from the Petrovic video.
20 We can compare the blue building from this still and the blue building
21 from our recent picture.
22 MR. NICHOLLS: I think that's a good time, Your Honour.
23 JUDGE AGIUS: We'll have a 25-minute break. Thank you.
24 --- Recess taken at 10.29 a.m.
25 --- On resuming at 10.59 a.m.
Page 18625
1 JUDGE AGIUS: We are at page 20, if we are going back to the road
2 book.
3 MR. NICHOLLS: Yes, Your Honour. Thank you.
4 Q. Mr. Blaszczyk, I think we've pretty much covered maybe not every
5 single link but pretty much covered the Potocari portion of the CD; is
6 that right?
7 A. Yes.
8 Q. Just before we leave Potocari and move on, if I could -- I'd just
9 like to show one overview to remind us where the area we've been looking
10 at is. If I could have 65 ter 1517, this was not on my exhibit list for
11 Mr. Blaszczyk. I e-mailed my friends last night that I might be using
12 this aerial. While it's loading, Mr. Blaszczyk, this is an aerial image
13 of Potocari dated 13 July. Thank you. And without going over it again,
14 can you just show us, we see here we've got marked the Feros building
15 which you pointed out to us and the white house, the Zinc Factory and the
16 UN base and you've explained how the filming began heading towards
17 Srebrenica passing the UN base. Can you just indicate, it's not marked on
18 here, where the blue building is and the -- just the area where we -- of
19 the video we have been seeing and the pictures we have been seeing.
20 JUDGE AGIUS: It's already all marked. I don't know why you are
21 asking to mark it again.
22 MR. NICHOLLS: No, just if he -- it was only the blue building I
23 didn't see marked, Your Honour.
24 JUDGE AGIUS: Oh, I see. Okay.
25 THE WITNESS: This is the blue building.
Page 18626
1 MR. NICHOLLS:
2 Q. Okay. You've made a red X over the blue building and just if you
3 can tell us approximately how far Mr. Petrovic, based on the video we saw
4 and the stills, how far toward Srebrenica we got before the film stopped
5 at the white house?
6 A. Mr. Petrovic, he stopped his car, I mean Mr. Borovcanin together
7 with Mr. Petrovic, they stopped the car on the way between the white house
8 and the blue building, a distance of about 100, 150 metres.
9 JUDGE AGIUS: All right. Next to that X that he's marked, could
10 you -- could he write blue building or BB?
11 THE WITNESS: [Marks]
12 JUDGE AGIUS: Thank you.
13 MR. NICHOLLS: Thank you, I think this covers the area.
14 Q. Could you just please --
15 JUDGE AGIUS: Yes, Mr. Lazarevic?
16 MR. LAZAREVIC: Well, I would just like if my colleague could
17 handle this, I believe that Mr. Blaszczyk is now starting giving evidence
18 about where Mr. Petrovic and Mr. Borovcanin were stopping their cars and
19 things like that. I would like to avoid this kind of evidence with this
20 witness.
21 MR. NICHOLLS: I think it's pretty clear from the video where the
22 car stops and where we see the camera outside. We don't know the exact
23 parking spot. I'm not presenting exactly where it was. I think it's fine
24 that Mr. Blaszczyk just stated it's in the vicinity between the blue
25 building and the white house based on his viewing of the video and his
Page 18627
1 knowledge of the area.
2 JUDGE AGIUS: It's not precise exactly where the car stopped, just
3 gave an indication of an area. And in any case, you can deal with that on
4 cross-examination, if you wish so, Mr. Lazarevic. No big deal.
5 Yes, go ahead.
6 MR. NICHOLLS: Thank you, I'm done with that. We could mark it,
7 please.
8 Q. If could you sign and date it, Mr. Blaszczyk?
9 A. [Marks]
10 MR. NICHOLLS: Thank you. I've finished with that.
11 Q. Now, if we could just look at page 21 of the book, quite self
12 explanatory but here we have got marked the locations of the stills in
13 this chapter which you've titled on the road Sandici, Pervani, Kravica; is
14 that right?
15 A. Yes, this is correct.
16 Q. Now, if we could go to pages 22 and 23, please, which you've
17 called a panorama of Sandici meadow, it's surroundings and the area.
18 These are clearly not from the Petrovic video. Could you just explain
19 what you've done here very quickly?
20 A. I would like to show the Sandici area and its surroundings, it's
21 quite complicated for people who have been there only once or never
22 before. And I would like to show the location of the particular objects I
23 will refer to in future, like the destroyed house in Sandici meadow, like
24 the destroyed white house opposite Sandici meadow, and Sandici meadow
25 itself.
Page 18628
1 Q. Thank you. Now, if we could turn to pages 24 and 25, and we can
2 start watching the video which will start shortly.
3 [Videotape played]
4 MR. NICHOLLS:
5 Q. Slightly blurry on this frame but we stopped at page 24, the only
6 picture on that page. Maybe we can get it slightly sharper. No. It's
7 sharper when it plays. Can you tell us where we are here on Sandici
8 meadow, Mr. Blaszczyk?
9 A. We are exactly on Sandici meadow, this still was taken at Sandici
10 meadow, in the background we see the house which is located in Sandici
11 meadow. I made a picture of the same location on the page the picture is
12 marked as the picture 1 on the page 25, we see the same building,
13 destroyed house. In the picture, from the page 25, and the still from 24,
14 and behind we see the same fields.
15 Q. Okay. And was that house -- we can see it's in fairly similar
16 condition still as it was in -- on July 13th, 1995?
17 A. Yes.
18 Q. And could we now go to pages 26 and 27? And just to be clear,
19 Mr. Blaszczyk, could you explain how the picture of the man calling out on
20 page 26, we see him in A, B and C, these are not in exact sequence as
21 we'll see them on the video, but you've grouped them together here; is
22 that right? Could you explain that?
23 A. Yes, I did it because in the meantime, the cameraman
24 Zoran Petrovic who recorded this footage, he pointed camera on this man
25 calling other people from the wood and he moved camera to another object
Page 18629
1 and again he came back to the same object, to the same man.
2 MR. NICHOLLS: Okay. If we could play now?
3 [Videotape played]
4 MR. NICHOLLS:
5 Q. Again, we stopped at just about picture C on page 26 and you've
6 marked on page 27 in picture 1 where these photos are from. This is just
7 about in the middle of Sandici meadow; is that right?
8 A. Yeah, this is correct and also I made the picture from Sandici
9 meadow in the direction of the destroyed white house showing the distance
10 between the Sandici meadow, the location I spotted, and destroyed white
11 house across the road from Sandici meadow, and also I marked the direction
12 Kravica and Konjevic Polje.
13 Q. Okay. Now, if we could look at pages 28 and pages 29 of the book,
14 we see here pictures of the armoured vehicles on page 28, a truck which we
15 had gone past just a moment ago. And I notice that on page 29, you have
16 not marked the location of the tank, I'll call it, we see in page 28 D.
17 Why is that not marked on page 29?
18 A. I didn't mark the location of the tank from the still from the
19 still D, and the truck from still C from the page 28 because I wasn't sure
20 which place these two vehicles were located at that time. I saw the
21 picture, I know that this is in Sandici meadow, I couldn't locate the
22 place, the exact place.
23 Q. Okay. Thank you. Now, if we could continue playing?
24 [Videotape played]
25 MR. NICHOLLS:
Page 18630
1 Q. Just while it's playing there is a blank spot here and some
2 voiceover. Can you tell us what's happening here?
3 A. This is recorded over part of the Petrovic raw material. We can
4 hear the voice of Mr. Petrovic.
5 [Videotape played]
6 MR. NICHOLLS: If we could back up a tiny bit, please? Okay.
7 Stop. Thank you.
8 Q. We now have gone past photo A and we are at photo B on page 30,
9 Mr. Borovcanin talking to the two uniformed men and actually we see the
10 date stamp now of 13 July 1995 and the time stamp. That's on the original
11 raw material from Mr. Petrovic. If we look on page 31, you've labelled
12 and marked where this scene is taking place. Can you just explain how you
13 arrived at that conclusion and then we'll watch the next sequence where
14 the camera sweeps.
15 A. I mark the location of these two men and Mr. Borovcanin, watching
16 the video, Petrovic video, very carefully on the spot in Sandici meadow in
17 this location. And in this picture, in this particular picture, which is
18 also the still which is also the picture here, the still B on page 13 on
19 the left corner, top of the corner, you see the part -- probably the part
20 of destroyed white house. And later on, please notice when the cameraman
21 is moving the camera, directing the camera from two men and Mr. Borovcanin
22 to the Sandici meadow you will see that the camera is passing the road and
23 showing us the location of Sandici meadow. And based on this one I just
24 located this place.
25 Q. And just so we know, how, in your mind, how precise is this
Page 18631
1 location on page 31 where you've marked A and B where Mr. Borovcanin is at
2 this moment of the film?
3 A. I believe this is precise. I can be mistaken by one, two metres,
4 maybe three metres, but no more.
5 MR. NICHOLLS: Okay. Now if we could play the film and watch the
6 camera sweep over the road to the meadow.
7 [Videotape played]
8 MR. NICHOLLS: Back one frame. Thank you.
9 Q. All right. We saw the camera cross the road now to the meadow and
10 that is we are now looking at page 32 of the book, photos A, B and C shows
11 the camera zooming in at the group of men sitting down in the meadow with
12 some armed men around them. And I should say, Your Honours, there is a
13 typo in the counter for photo B. It says 11.54.10 and I believe we
14 noticed yesterday when we were viewing that should be 44.
15 Page 33, you've marked the location of these men sitting on the
16 ground with the armed men around them. Can you just tell us about how you
17 came to that conclusion?
18 A. Watching the video, the footage of Petrovic footage I noticed in
19 Sandici, above the Sandici meadow, the small house is also visible, the
20 small house on the still A from the page 32 above the Sandici meadow and I
21 noticed it's the same house when I was over there in Sandici meadow in
22 2006.
23 Q. Okay. Now, the photo taken on page 33, I can see that it's a
24 compilation but when those photos were taken, where was the person taking
25 the photograph standing? What's behind his back?
Page 18632
1 A. This is a compilation done by our video assistant Zoran Lasic who
2 made a lot of photos on this area, compiled the photos in one panorama
3 view.
4 Q. This is taken from across the road, where the white house is
5 facing towards --
6 A. Yeah, the picture is taken from across the road exactly in the
7 front of the destroyed white house across the road from Sandici meadow.
8 Q. Okay. If we could go now to pages 34 and 35 and play the tape,
9 please?
10 [Videotape played]
11 MR. NICHOLLS:
12 Q. All right. This is close to approximately 34 C, picture 34 C.
13 We've seen the shooting and the moving of these vehicles as they fire into
14 the hills. Can you tell us how you just were able to tell which direction
15 the -- these army vehicles were moving and army or MUP vehicles were
16 moving and where they were on the road which you've marked on page 35?
17 A. As we see on the picture C, from the page -- of the still C from
18 the page 34, the armed vehicles are moving towards Konjevic Polje. I
19 located this place. This place is in Pervani, it's approximately about
20 2800 metres from Sandici meadow on the road leading towards Konjevic
21 Polje, and I located, I spotted this place, you know, through the
22 topographic features, like the hills in the background and made up of the
23 roads.
24 Q. Okay. And that road between Sandici meadow and Konjevic Polje,
25 it's got various parts which are curved and straight and some banked
Page 18633
1 walls. Did you use any of those features?
2 A. Yes, yes. Yes, I did.
3 Q. Okay. So then again, we've now, Mr. Petrovic and Mr. Borovcanin
4 have left Sandici and are heading towards Konjevic Polje when we get to
5 this portion of the video.
6 A. Watching the video, we see that Mr. Borovcanin together with
7 Mr. Petrovic left the Sandici and they were heading Konjevic Polje.
8 Q. Okay. If we could continue to play, please?
9 [Videotape played]
10 MR. NICHOLLS: Can I stop for one second?
11 Q. We could hear some music from the video there playing. It's not
12 very clear. It's clearer when you play the video by itself. Can you tell
13 us where that music was coming from, if you know, if you found that out?
14 A. This music is coming from -- probably from the car of
15 Mr. Borovcanin.
16 Q. Okay. If we can continue, please?
17 [Videotape played]
18 MR. NICHOLLS:
19 Q. All right. The sequence we just saw of several minutes, were on
20 pages 36 and 37 of the book, we saw the houses in A, B and C on page 36,
21 and the firing on -- excuse me, photo D. And then you've identified
22 several houses on page 37 and marked which ones they are. And also marked
23 where we are on the road. Now, 3100 metres from Sandici meadow, still
24 heading towards Konjevic Polje. Can you just explain how you were able to
25 match up this area?
Page 18634
1 A. We moved a little bit further down along the road to Konjevic
2 Polje and 300 metres, about 300 metres from the previous location, we
3 spotted the houses which were depicted on Petrovic stills, and we see
4 these houses on page 36 on the stills A, B and C. We located these houses
5 and we came to conclusion that from the video that these two APC, two
6 armed vehicles were parked next to these houses on the road leading
7 towards Konjevic Polje. It's also Pervani area.
8 Q. Just very briefly, we can see that the house in photo A on page 36
9 and the house in photo A on 37, there's been some restoration work going
10 on. How are you able to tell that these were the same houses?
11 A. We can compare the pictures, the stills from 1995 and the pictures
12 done in 2006 and we can see the same features like the windows, like the
13 doors of the house.
14 Q. And did you also --
15 A. Very similar. Of course, it was renovated after that but it is
16 visible it is the same house.
17 Q. Did you also look at the position of these houses relative to each
18 other along the road?
19 A. Yes, of course, I did.
20 Q. Now we will be going to the next two pages, 38 and 39 and we'll
21 play the video and catch up to here. Before we play it, on page 38 we see
22 two houses which you've labelled as damaged -- and which you've labelled
23 as a damaged house, the second one and the location now is 2.000 metres
24 from Sandici meadow on the road leading from Konjevic Polje towards
25 Sandici and Bratunac. So now, if I'm right, at this point, Mr. Petrovic
Page 18635
1 is heading back, he's made a U-turn, he's heading back from the direction
2 of Konjevic Polje towards Sandici meadow; is that right?
3 A. Yes, you are correct. This is the first footage when -- on
4 Petrovic video when we see that Mr. Petrovic is coming back to Sandici
5 meadow.
6 Q. Okay.
7 JUDGE AGIUS: Yes, Mr. Lazarevic?
8 MR. LAZAREVIC: I'll have to object. This is leading question. I
9 mean obviously at this point, Mr. Petrovic is heading back, he's made a
10 U-turn, this kind of -- this is basically my colleague giving evidence. I
11 would like him to avoid this kind of question with the witness.
12 THE WITNESS: He made that conclusion. He can ask him.
13 JUDGE AGIUS: Yes. Mr. Nicholls.
14 MR. NICHOLLS: It was leading. If there is an objection, I'll
15 stop. I was just trying to move it along. It's written here and so it's
16 clear.
17 JUDGE AGIUS: But you've got the message from Mr. Lazarevic.
18 MR. NICHOLLS: I've got the message, Your Honours. Thank you.
19 Q. Okay. Before we play the clip, could you please explain the
20 direction we are going in, we've talked about it but how you concluded
21 that?
22 A. We see from the later clips that Mr. Borovcanin -- Mr. Petrovic is
23 heading towards Sandici meadow and on this area we spotted the house which
24 is very similar to the house from this clip depicted on the -- on stills A
25 and B from the page 38. The previous houses was already rebuilt after the
Page 18636
1 war is -- has totally different shape but this house which we found is
2 almost the same which we see on the stills on A and B, I mean the match
3 house from picture 1 and 2 from page 39 and also the curve of the road is
4 very similar to the curve. It's the same as on the picture B and A on the
5 page 38.
6 Q. And were you able, from looking at the video, to determine where,
7 what portion of the road, Mr. Petrovic and Mr. Borovcanin made their
8 U-turn or were you not able to figure that out exactly?
9 A. No, I wasn't able in which point they turn around because as we
10 see it this place is located about 1.000 metres from the previous location
11 and we had the previous clips with armoured vehicles.
12 Q. Okay.
13 A. But this is the first footage recorded by Mr. Petrovic on the way
14 back to Sandici meadow after the footage we see in -- with armed vehicles.
15 Q. Okay. If we could play the video now, please?
16 [Videotape played]
17 MR. NICHOLLS:
18 Q. And then we can move on but this is the same section you've
19 captured on page 38; is that right?
20 A. Yes. This is correct, the same two houses.
21 Q. Okay. We can continue now in the same direction and look at pages
22 40 and 41, please.
23 [Videotape played]
24 MR. NICHOLLS:
25 Q. All right. It came back quite quickly and we are on page 40 now.
Page 18637
1 We just passed the man standing against the retaining wall in photo A of
2 page 40 and we are now seeing the second man in military uniform in photo
3 B of page 40. Could you tell us where this location is and how you
4 determined the location?
5 A. This location is located in Lolici area. This is about 900 metres
6 from Sandici meadow on the road leading from Konjevic Polje towards
7 Sandici and Bratunac. I managed to locate this road by passing this road
8 several times and also I know that on this road on the left side of the
9 road we have two retaining walls. The first one is in the Lolici area and
10 another one is about few hundred metres before we reach Sandici meadow on
11 the left side also and we can see that this is the wall from Lolici area.
12 Q. Thank you. Continue, if you have --
13 A. Yes, and of course, I compare also topography, topographic view of
14 the surrounding hills.
15 Q. Okay. All right. If we could continue playing the video and we
16 would be on pages 42 and 43 now.
17 [Videotape played]
18 MR. NICHOLLS:
19 Q. All right. Now, this sequence still heading towards Sandici, we
20 saw several men without stopping all the way along, we saw the man in
21 photo A, flashing past the camera on page 42. If we look at photo B, on
22 page 42, we can see there were two men there crouching behind the barrier
23 looking towards the woods. The fourth man we see in this sequence is in
24 photo C of 42 also crouching by the barrier. If I'm correct about this,
25 Mr. Blaszczyk. And then it's difficult to see and it's difficult to see
Page 18638
1 on the video but right where we stopped on photo D of page 42, how many or
2 what is that up towards the -- just standing in front of the house we see
3 ahead on the road?
4 A. When you watch very carefully this part of the video you can see
5 that we can see two men standing behind the barrier in front of the car
6 heading towards Sandici and Bratunac.
7 Q. Now, I won't ask you any leading questions. Can you explain how
8 you have marked the locations of photos A, B, C and D as you have on
9 photos 1 and 2 on page 43? You've got a straight-on shot and you've got
10 an overview. If could you explain that to us first.
11 A. I drove the same road which was used by Mr. Petrovic and
12 Mr. Borovcanin, and I passed the same barriers on the right side of the
13 road leading to Sandici meadow. It was just before the Sandici meadow,
14 about 400 metres from Sandici meadow, and I compare the video clip and the
15 stills from the video, this video, the Petrovic video, with the features
16 on the road and I marked the location, quite a few locations of these men
17 depicted on the page 42.
18 Q. Okay. Now, on page 43, we see on the left side we don't see it on
19 the video but we see a retaining wall. Is that the second retaining wall
20 were you discussing a moment ago?
21 A. Yeah. This is correct. This is the second retaining wall. The
22 first one is Lolici and then we are coming to another one, last one before
23 the Sandici meadow.
24 Q. Okay. And -- continue.
25 A. And in the corner of the picture 1 from the page 43, I attach also
Page 18639
1 the overview of the area and I marked a few locations in this picture,
2 these overview pictures, Sandici -- like Sandici meadow, destroyed white
3 house, Kravica warehouse is further down, and to showing how the men were
4 posted at that time in relation to Sandici meadow and destroyed white
5 house. I know that Kravica warehouse is not very well visible here but is
6 visible from the place where he took the pictures when we zoom in the
7 picture we can see very easily Kravica warehouse.
8 Q. Okay. And again it's fairly self explanatory but you've marked an
9 area with a white X. Can you just tell us what that is, how you came to
10 pick that spot?
11 A. This spot was pointed to me by the member of the federal
12 commission for the missing person as the place where the exhumation took
13 place, exhumation of the people from Srebrenica, and exhumation was
14 conducted in June 2004 by the federal commission. And I also saw the
15 pictures and I believe video from this exhumation, and it was conducted
16 exactly in this place behind the barrier down.
17 Q. If we could continue playing, please, the video?
18 [Videotape played]
19 MR. NICHOLLS:
20 Q. All right. That's good. If we go to pages 44 and 45 it's very
21 difficult to stop exactly on it, you've got a man who flashes by the
22 camera marked on pages 44 on photo A, and you've marked the location on
23 page 45. Do you have anything to add to what's clear from your markings
24 here?
25 A. When Petrovic passed the curve which is visible on the page 43, he
Page 18640
1 stopped the car over there and from the -- while passing the curve, he
2 recorded also the man which is depicted on the still from the page 44.
3 Q. Okay.
4 A. Probably this -- I am pretty sure that the two men depicted on
5 page 20 -- 42, on still D, they are the men from page 44, still A, and the
6 man from page 46, still A and B.
7 Q. Okay. I see. Now, we stopped right at the man in still B on page
8 46. I think we can continue playing a little bit now until we get to the
9 next man.
10 [Videotape played]
11 MR. NICHOLLS:
12 Q. All right. So now we've seen the man who is in 46 A and B, he
13 starts off shouting for people to come out of the hills and then we've
14 seen the armed man on page 46 C. And on page 47, you've got two overviews
15 where you've marked the locations of these men. Could you explain that,
16 please, where we are?
17 A. We are about 200 metres from Sandici meadow along the road
18 Konjevic Polje-Bratunac, direction Konjevic Polje. We stopped -- actually
19 the stills were taken from Petrovic with video which was recorded in this
20 location, it was before the curve, before they reached the Sandici meadow
21 again. And watching this video and comparing the features from the video,
22 I mean the features of the terrain over there, from the video, and from
23 life when I was there together with my colleague, I spotted the places
24 where the two men depicted on the stills A, B and C were standing. And on
25 the right side on the page 47, I just attached the first photo, the photo
Page 18641
1 1 is the overview of the area with the marks where these two guys were
2 standing and also I pointed, I marked the location of destroyed white
3 house and Sandici meadow. In the second picture, this is panorama
4 picture, maybe it's not reflect exactly the shape of the road because here
5 we see that the road is like cycling, and leading towards Konjevic Polje,
6 but this is straight road with two bends on the left and on the right side
7 because it was impossible to create a picture which could reflect the real
8 stage.
9 Q. Okay. So just if I can lead for one point, I'll stop if I get an
10 objection. It's that the photo on page 47, 2, the curve appears to be
11 more pronounced than it is in reality because you created this panorama
12 shot; is that right?
13 A. Yes, it's right, it's too bent.
14 Q. And I think now we can just continue, please.
15 [Videotape played]
16 MR. NICHOLLS:
17 Q. Okay. We are on pages 48 and 49. We have just seen a sequence
18 where Mr. Petrovic has been outside the car filming men, Mr. Borovcanin
19 and others, on the road. Can you tell us where we are here and whether we
20 are closer or moving closer or not towards Sandici meadow and what we've
21 called the destroyed white house?
22 A. In this footage, in these stills from the Petrovic footage, we are
23 getting closer to Sandici meadow. It's about 100, 150 metres from Sandici
24 meadow. We see the people walking down from Sandici meadow towards
25 Konjevic Polje. And also, I just located this place by comparing the
Page 18642
1 stills we took from Petrovic footage and playing the footage itself on the
2 spot. I compare the hills, the road and the features on the road and on
3 the hills.
4 Q. All right. Thank you. I think we can keep playing now.
5 [Videotape played]
6 MR. NICHOLLS:
7 Q. Sorry, on page 50 now, we've gone slightly past it but the men in
8 photos A and B on page 50 who we see one crouching under the bush and one
9 pointing his gun over the barrier, and we see on page 51 a barrier on a
10 curve of the road heading towards the destroyed white house, can you just
11 tell us a little bit how you were able to tell where these two men are?
12 A. I spotted this location, this location is located about 100 metres
13 from Sandici meadow on the road Konjevic Polje-Bratunac, direction
14 Konjevic Polje. And the men, the two men, they are standing behind a --
15 the barrier actually that is -- behind the barrier there is creek, also
16 the creek is visible in the Petrovic video. I made the stills of the
17 creek on the still C and I spotted this location, this is depicted on
18 picture 1, picture 2, on the page 51, and picture 3, I made the picture,
19 we made the picture of the creek below the road. And also the fourth
20 picture, this is overview of the area with marked location of these men,
21 and relation to this location to the location of Sandici meadow, destroyed
22 white house and Kravica warehouse, and as I said again, before the Kravica
23 warehouse it's not very well visible here on this picture but when you
24 zoom in this picture on the computer, you could see the Kravica warehouse.
25 Q. If we could continue just a little bit, please?
Page 18643
1 [Videotape played]
2 MR. NICHOLLS:
3 Q. Thank you. Now, at page 52, photo B, on the original footage it's
4 not particularly clear right on that frame, but it's clear in the photo,
5 Mr. Borovcanin speaking to a man wearing a blue helmet. Just again tell
6 us how you know where we are? You've marked it on page 53.
7 A. As before, I compared the location which I found with two men who
8 were standing behind the barrier and pointing the guns towards the creek,
9 and I see that Mr. Borovcanin is standing about 50 metres maybe or 30, 50,
10 30 metres from these men and it's also located on the road leading towards
11 Kravica and Bratunac. And we can notice on the picture B that the car,
12 from the page 52, that the car used by Mr. Borovcanin - we know that this
13 car was used by Mr. Borovcanin from his statement and also from the
14 statement of his driver - this car is heading towards direction of
15 Bratunac.
16 Q. All right. Well, there is -- looks like there is two cars in B
17 which one are you referring to?
18 A. I'm referring to the grey-silver car.
19 Q. Okay. Thank you. Okay. We are now going to play some more
20 segment and go, I think, straight through pages 54 and 55 and continue on
21 through 56 and 57. And then I'll ask you to come back and explain these
22 locations. Thank you.
23 [Videotape played]
24 MR. NICHOLLS:
25 Q. All right. Now, let's go back to page 54 and 55, please. We've
Page 18644
1 seen the men, we can see on page 54 just now on the video walking up, up a
2 path, past some white pillars around the corner of a white building and we
3 saw the man with the back-pack head down the -- and in the direction of
4 the road there. Can you tell us what we've got depicted here and how you
5 were able to determine where this sequence of the men walking out of the
6 woods took place?
7 A. From the recordings and from the still that we see that the
8 recording was done in the destroyed white house located across the road
9 from Sandici meadow. We see that the men were walking through the path
10 leading from the north direction -- from the south direction towards the
11 destroyed white house, passing the white house. And later on we can see
12 that the people are passing the road towards Sandici meadow. The Sandici
13 meadow is about 100 metres located from this destroyed white house here.
14 We can compare the parts, poles of the house, we see very good the poles
15 are visible on picture 2 on page 55 of the house. We can see from the
16 recordings that the people are passing these poles.
17 Q. Now, if we look at page 54, picture C, the man with the back-pack
18 coming around a corner, you've marked his location on page 55 and picture
19 1 as a kind of the front corner of the white house heading down towards
20 the Kravica-Konjevic Polje road. How did you determine that? Just that
21 particular man's location?
22 A. I just followed the recording of Mr. Petrovic and I recognised the
23 wall and the poles of the house depicted on picture 1 from page 55 and
24 this is visible that the man is turning across the corner, behind the
25 corner of this house, from the left -- from the left side of the house.
Page 18645
1 Q. Okay.
2 A. And on the still C, we can see part of the road and probably bus
3 parked on the road and behind -- across this road there is Sandici meadow.
4 Q. Thank you. If we could now look at pages 56 and 57, very similar
5 the way you've marked this on page 57, the location of the men and boys in
6 photos A through E or A through F, excuse me, on page 56. I think your
7 explanation is probably -- well, just, can you please tell me how you came
8 to this conclusion, this sequence?
9 A. This explanation would be the same like the previous one. It's
10 visible the poles of the house on the destroyed white house located across
11 the road of -- from Sandici meadow and from -- from the recordings we can
12 get more details of this house and also the path.
13 Q. Okay. And when were you there, did you walk up and down any of
14 these paths or across the road to the meadow and recreate this path?
15 A. Yes, I did. I did it several times.
16 Q. If we could continue, please, with some video?
17 [Videotape played]
18 MR. NICHOLLS: Stop, sorry.
19 Q. We saw one second of a photo of President Karadzic there. Do you
20 know how -- do you have any explanation why that's on the tape?
21 A. It's also recorded over on the original tape, but Mr. Petrovic I
22 think he will explain by himself when he will testify in this Court.
23 Q. And continue playing.
24 [Videotape played]
25 MR. NICHOLLS:
Page 18646
1 Q. Thank you. We have just seen, we are at page 58 and photos A and
2 B we see the man with the leather jacket who asks for water walking down a
3 path and across the road and then the direction he's going is shown in
4 photo C on page 58 and we see the back end of a parked bus. Can you just
5 tell us where this man was walking in the clip we just saw?
6 A. This man used the same path which had been used by the previous
7 men. He's walking along the white destroyed house located across the road
8 from Sandici meadow. He's -- he's turning in the front of the house we
9 see he's turning first right and left, crossing the road and going towards
10 Sandici meadow.
11 Q. Could we continue, please, playing the video for a little while?
12 [Videotape played]
13 MR. NICHOLLS: Can we stop? Sorry.
14 Q. Now we are at counter 24.10.3, a couple of men in camouflage
15 uniform sitting down by the road and one of them looks quickly away from
16 the camera. Are these -- is the location of these men put in the book
17 anywhere?
18 A. No. I didn't put the location of these men on this road book
19 because I wouldn't able to spot the place where they were sitting. I
20 believe that this is in Sandici meadow, close to Sandici meadow, but I
21 couldn't locate the place.
22 Q. Thank you. Continue.
23 [Videotape played]
24 THE WITNESS: I have some assumption but when I wasn't sure I
25 didn't want to attach it to the book.
Page 18647
1 [Videotape played]
2 MR. NICHOLLS:
3 Q. Okay. We can stop there. That's the next section we see on the
4 raw footage which we obtained from Mr. Petrovic, and that is the end of
5 this chapter. What I'd like to do now, Your Honours, before we leave this
6 section of the road is play the Studio B footage. We have a clip from the
7 Kravica warehouse and we are at pages 60 and 61, excuse me, of the book
8 now.
9 JUDGE AGIUS: One moment, Mr. Nicholls. You said Studio B but
10 this is what we see is Petrovic footage here as well. Is --
11 MR. NICHOLLS: I can explain that, Your Honour. You're quite
12 correct. This is the Studio B footage. It's taken from our trial video
13 compilation. So that is a bit misleading. It's the Studio B broadcast
14 segment which will be -- it will have the Studio B logo in the corner of
15 the screen but you're correct it's been labelled this way because he is
16 the one who took the film.
17 JUDGE AGIUS: Okay. All right.
18 MR. NICHOLLS: Thank you.
19 [Videotape played]
20 MR. NICHOLLS: And now if we can play the slow motion of the same
21 clip just so that -- to remind us of what the buildings look like.
22 [Videotape played]
23 MR. NICHOLLS: Okay. Thank you.
24 Q. If we can look now at pages 60 and 61 in your book, Mr. Blaszczyk,
25 you've got the two stills showing two parts of the Kravica warehouse from
Page 18648
1 the Studio B footage on page 60 and you've made some photos and labels on
2 page 61 of the Kravica warehouse. Can you explain to us these locations?
3 A. This is Kravica warehouse, the warehouse is located in the village
4 of Kravica. And on the page 60 I attached the stills from Studio B
5 broadcast from edited material of Petrovic footage. This material, these
6 stills, this clip, is not visible in the raw material, in the copied raw
7 material we received from Mr. Petrovic. It was also recorded over
8 somehow. And of course, the place is very known to everybody but I made a
9 picture of this Kravica warehouse on the right -- on the page 61, I marked
10 the location of the first still which was taken on the west door of
11 Kravica warehouse and as on the page 1 and page -- sorry, on picture 1
12 from the page 61 and on picture 3 on the page 61 as the location A. And
13 on the page -- on the page 61, on the picture 2 I marked the location
14 where the bus is stopping on the still from Studio B broadcast, on still B
15 from the page 60.
16 Q. Now -- and then just to give us an idea, how many times have you
17 personally been to the Kravica warehouse location?
18 A. It's many times. Difficult to say how many but every time when
19 I'm in this area I'm passing this warehouse. It could be 50, 60 and more.
20 And this warehouse was described by the witness Jean-Rene Ruez during his
21 testimony in this trial in details.
22 Q. Okay. That's the end of chapter 2, Your Honours, that segment of
23 the video we've covered. Mr. Blaszczyk has created a similar CD
24 presentation for this area of chapter 2 which I'd like him to quickly run
25 us through and show how it works and that's the last part that's on the
Page 18649
1 CD. The rest of the book is not contained on the CD.
2 A. We are again with presentation --
3 Q. Sorry, Mr. Blaszczyk, if you can, try to -- it will come up in a
4 minute, try to quickly take us through in the same general order that
5 you've got the -- as the video was taken as and as you've laid out the
6 pictures in this chapter of the book.
7 A. Yes, of course. We are entering the area --
8 Q. Sorry, it's not on our screens, yet. We'll have to -- okay. Now
9 it's -- I think it's working now. Okay.
10 A. We see the map of the area of Bratunac, Srebrenica, Kravica and
11 Sandici. We are coming to the more detailed map of the area of Sandici.
12 On this map, I marked the locations which were depicted on the stills from
13 Petrovic video and located by me during my mission in this area. We link
14 to the area of Sandici, from the recent picture.
15 This is the link to the still from Petrovic, taken from Petrovic
16 video. We can compare the house depicted on this still and the house from
17 the recent picture.
18 Also to help ourselves we can use the information button here to
19 mark the link fields. We have the still from Petrovic video taken in July
20 1995, 13th of July 1995.
21 Also, the still from Petrovic video above the -- on the hill we
22 can see the small house over here.
23 Q. And, excuse me, just to be clear, that's different from the --
24 that earlier damaged house which you showed us, that small -- you've
25 labeled that one the small house, the earlier one you labelled the
Page 18650
1 destroyed house which is closer to the meadow, correct?
2 A. Yeah, this is correct but this house, this small house, is also
3 marked in my road book. We can see the same house on this picture. We
4 can compare the area.
5 We can get another view of the same area from another position.
6 And the same area from the hill above the road leading towards
7 Konjevic Polje.
8 We see the white house across the road, destroyed white house
9 across the road.
10 On this still from Petrovic video we see part of the car. I
11 recognised this car as the car used by Mr. Borovcanin and Petrovic. We
12 see that the car is headed towards Konjevic Polje at this point. We see
13 the aerial used by the radio from this car.
14 Following the sequence from the Petrovic video, we can see that
15 Mr. Petrovic is following the armed vehicles. The first footage with
16 armed vehicles we located in -- it was recorded in Pervani area.
17 We can link to the still from 1995. We can zoom in and we can see
18 the hills in the background and also compare the road.
19 From the recordings we see that armed vehicles moved towards
20 Konjevic Polje, about 300 metres, the place is located by me. Also here
21 we have the link from the picture to the still from the Petrovic video.
22 And the first footage, on the way back, was recorded in this area.
23 This is the house which is visible also on the still from Petrovic
24 video.
25 And the car in Petrovic is passing the wall in Lolici.
Page 18651
1 I'm slowly moving this picture towards direction of Sandici and
2 Bratunac.
3 Here is the link to the still from Petrovic video.
4 Here is the link to the second still from Petrovic video of the
5 man standing and walking towards the wall.
6 We are coming to the area quite close to the Sandici meadow.
7 This is the links to the stills from Petrovic video depicted the
8 men along the road and behind the barrier. This is the first man before
9 we reaching the road. It's very hard to see this man on the recording but
10 he's visible. We have two men crouching behind the barrier and watching
11 towards south. The fourth man.
12 And link to the Petrovic still and now I think we can see two men
13 standing on the right side of the road.
14 Q. Could we go back to that photo -- could we go back to the still
15 that you just showed us the link? What's that on the dash board of the
16 car, if you can see on the inside on the dash board?
17 A. Yes, this is a hand set, Motorola hand set.
18 Q. Okay. Thank you.
19 A. We are slowly approaching the area of Sandici. I took Your
20 Honours to the overview of this area. Here we have destroyed white house
21 across the Sandici meadow, Sandici meadow itself.
22 The previous picture a still from Petrovic video.
23 And as we see from the recordings, Petrovic recordings, Petrovic
24 got this point before the Sandici meadow, he stopped the car somewhere
25 here and he recorded these two men.
Page 18652
1 You can compare the curve of the road here, from the recording and
2 from the still as well.
3 We see two men also looking towards creek, to the south direction,
4 and we see the red car and behind this red car we can see also the
5 silver-grey car used by Mr. Borovcanin and Mr. Petrovic. The area is
6 located this about 100 metres, 150 metres, maybe 200 metres from the
7 Sandici meadow. The Sandici meadow is on the left side of the road.
8 We are getting -- we are in front of the destroyed white house
9 right now and we can see the same area but from different perspective.
10 We have more accurate picture of the car used by Mr. Borovcanin
11 and Mr. Petrovic.
12 We are going to the hill above the Sandici meadow, to see the
13 landscape to see the overview of Sandici meadow, its surroundings.
14 MR. NICHOLLS: Your Honours, I'm not sure if it's time. We could
15 try to finish the presentation off quite quickly afterwards.
16 JUDGE AGIUS: Unless there is a serious objection, we could try to
17 finish this presentation. No, what I mean to say is this presentation
18 that he is going through now. I know there are two other parts over there
19 and those are not supported by -- so how long -- how much longer do you
20 think you need to finish this presentation now?
21 MR. NICHOLLS: Probably I would defer to Mr. Blaszczyk who knows
22 it better than me but I would say 10 to 15 minutes.
23 JUDGE AGIUS: No, no. Then we have the break. Then we have the
24 break.
25 MR. NICHOLLS: The Kravica section takes a little bit more time
Page 18653
1 and then it will be finished.
2 JUDGE AGIUS: Then we will have the break now. Agreed?
3 MR. NICHOLLS: Thank you.
4 JUDGE AGIUS: We'll have a 25-minute break now. Thank you.
5 --- Recess taken at 12.31 p.m.
6 --- On resuming at 1.00 p.m.
7 JUDGE AGIUS: Go ahead, Mr. Nicholls.
8 MR. NICHOLLS: Thank you.
9 Q. Now, Mr. Blaszczyk, if you could -- as quickly as you think you
10 can, show us the remaining links for the Sandici meadow area and then we
11 can move to the Kravica portion of your -- of your interactive CD. Before
12 we do that, can you tell me, if you know which software was used to
13 actually create the CD which we are looking at? I know we are playing it
14 in QuickTime, but do you know which was used to make it?
15 A. To be honest, not really because it was created with the help of
16 video assistant, Mr. Zoran Lasic.
17 Q. All right. Thank you. We'll look into that. If you could just
18 show us whichever remaining links we need to see and then we can move to
19 Kravica.
20 A. Okay, we are going to the link with the view of the white house,
21 the left side of the destroyed white house across the road from Sandici
22 meadow. In the previously we seen this house in this location here,
23 marked here.
24 And this is the link to the still from 1995, from Petrovic video.
25 Another link. Here we see the poles of the white destroyed house.
Page 18654
1 The same poles right here.
2 And here we see the corner of this destroyed white house with the
3 man with the back-pack passing this corner.
4 I think we -- I think we have seen most of the probably everything
5 from the Kravica -- from the Sandici meadow.
6 Q. That's fine. Thank you.
7 A. And the next stop is Kravica warehouse. It's not visible on the
8 copied raw material of Mr. Petrovic but this is brought -- it was
9 broadcasted by Studio B in 1995, July 1995.
10 Q. One question before you show us that. Just when we finished this
11 section of the video, there was a shot of a rations box with a 1997 date
12 on it. Can you tell us anything about why that is there in the video?
13 A. Yes. It was also recorded over by Mr. Petrovic somehow. I think
14 he will explain the best how it was over-recorded.
15 Q. Thank you.
16 A. And we are coming to Kravica. One in front of the Kravica
17 warehouse. We see the west door of Kravica warehouse.
18 Q. Just to be very clear, west door means heading towards -- that's
19 the Sandici end?
20 A. Yes, the west door is heading towards Sandici, the closest door to
21 Sandici meadow. This is the road leading to Sandici and Konjevic Polje.
22 Q. And while we are here, could you just do one spin around so that
23 you could show Their Honours and my friends how we have the entire length
24 of the warehouse and how close it is to the road.
25 A. Yes, of course. On the left side of this screen we see the road
Page 18655
1 now is heading towards Bratunac. It's visible from this point how close
2 is the warehouse located in relation to the road.
3 Q. Thank you. And what can you -- please continue.
4 A. And we can link to the picture, to the still from Studio B
5 broadcast.
6 Q. Maybe could you show the button which shows us where all the
7 fields are because that one is not marked well.
8 A. Yes, it this one is unfortunately not marked well. I can press
9 the information button here. We see there are additional blue fields
10 here. This is the links to the pictures, to the stills from Studio B
11 broadcast.
12 We see the west door of the warehouse in Kravica.
13 We see the middle of Kravica warehouse and the bus. Also this is
14 a still from Studio B broadcast.
15 We can enter through the west door to Kravica warehouse, to the
16 room in Kravica warehouse.
17 Q. Now, this room, if you'll recall, we had two witnesses, PW-111 and
18 PW-156, you've just entered the west door of the Sandici end. Was that
19 the one that was identified by survivor 156 or 111, if you recall?
20 A. This room was identified by the survivor PW-156.
21 Q. Can you just explain what we have here?
22 A. Just I went to another corner, to another end of the -- this room.
23 And we are the same room but we look at this room from different
24 perspective. And as witness, protected witness PW-156 described, he was
25 located somewhere here.
Page 18656
1 Q. And you're indicating that rectangular area marked at the end
2 corner of the building, we can see an outline?
3 A. Yes, exactly, according to the witness in July 1995, it was a kind
4 of booth, this corner.
5 MR. LAZAREVIC: I apologise, maybe I should have intervened
6 earlier but really I don't feel it's appropriate for this witness to
7 comment on other witness's --
8 MR. NICHOLLS: Your Honour, if I may, the only intention is to
9 provide Your Honours to link it up to the earlier testimony. It's pretty
10 clear in the transcript just where we are in the house.
11 JUDGE AGIUS: Then he could have restricted himself that this is
12 relevant for the testimony of PW-whatever he is, and leave it at that.
13 MR. NICHOLLS: All right.
14 THE WITNESS: Okay. We can see this room inside. We are leaving
15 this room.
16 MR. NICHOLLS:
17 Q. Before we leave it, if you can, you've been there several times,
18 can you tell us, it's a bit difficult to gain a perspective as you're
19 turning around, what are the approximate -- what are the dimensions,
20 interior dimensions, of this Sandici-end room?
21 A. It's about 260 square metres, and it had been measured first by
22 the forensic team as far as I remember in September 1996 and also I
23 confirmed by my measurement.
24 Q. Okay.
25 A. We are going out from the white house, we are leaving this -- I'm
Page 18657
1 so sorry, of course, from the warehouse, we are leaving this room. We
2 are, again, in front of the west door. We are coming closer to the east
3 part of warehouse in Kravica. We see -- this is east part of the Kravica
4 warehouse. It was described by the Witness PW-111. We can see also the
5 eastern corner of Kravica warehouse and backyard of the Kravica warehouse.
6 They are the buildings attached to this complex of Kravica warehouse.
7 Q. Thank you. If you could just finish spinning us around 360 here,
8 we can get to that wooden -- that funny wooden structure there and the
9 road again.
10 A. Behind the trees we have the road, now leading to Konjevic
11 Polje -- Sandici-Konjevic Polje.
12 Q. Okay. Thank you very much. I think you've explained all the
13 features of the CD presentation for that chapter.
14 A. Yes, I did. I would like to add that this is representation
15 regarding only the first two chapters of this road book, and relating to
16 13 of July 1995.
17 Q. Thank you. If we can continue with the video now where we left
18 off, Your Honours, it will go quicker now because it's less complicated.
19 There aren't men along roads and curves to try to explain. It will go
20 quite a bit quicker now.
21 [Videotape played]
22 MR. NICHOLLS:
23 Q. Okay. I think we probably recognise that building. We don't need
24 to go back to it. Can you just tell us where we are now, which direction
25 are we heading in and where are we?
Page 18658
1 A. We are passing the DutchBat compound in Potocari. The car is
2 driving towards direction of Srebrenica. And this is recording from 14 of
3 July, 1995.
4 Q. Thank you. Please continue.
5 [Videotape played]
6 MR. NICHOLLS: If we could stop there at 26.11.
7 Q. This will continue but on the Studio B edited footage, what do we
8 see at this point after we hear that music and passing the man leading the
9 horse or the donkey?
10 A. After this footage, we see the footage from the clips from Kravica
11 warehouse with dead bodies in front of the Kravica warehouse. And yeah,
12 this is visible that this footage was recorded on the 14th of July and
13 that Kravica warehouse footage was recorded day before, on the 13th of
14 July.
15 Q. Okay.
16 A. It was edited at Studio B.
17 Q. Okay. If we can continue, please.
18 [Videotape played]
19 MR. NICHOLLS: If we could go back a couple frames? This is not
20 in the books, Your Honours.
21 Q. But what's this building that we are passing on the right side at
22 27.16?
23 A. This is building located in Srebrenica was used by UN, by
24 DutchBat.
25 Q. Thank you.
Page 18659
1 [Videotape played]
2 MR. NICHOLLS:
3 Q. Again, just 27.32.5, what is this -- where are we here with this
4 handwritten sign?
5 A. We are on the street in Srebrenica. This is the police station in
6 Srebrenica.
7 Q. Okay.
8 A. In fact, it was -- this is the police station established by the
9 Serbs.
10 [Videotape played]
11 MR. NICHOLLS:
12 Q. All right. There aren't so many -- we haven't put so many photos
13 in the still book here but this is on page 64 and 65, the big department
14 store. Can you just tell us where this is in downtown Srebrenica?
15 A. This is exactly in the centre of Srebrenica. I think this is
16 the -- these two pictures are -- these two buildings are the most
17 recognisable buildings in the town. Is department store Srebrenicanka and
18 municipality building on the right side of this picture. And recorded --
19 the recording which we have seen right now was done on this street leading
20 to the Srebrenicanka department store from direction of Potocari.
21 Q. Thank you.
22 We can continue with the video.
23 [Videotape played]
24 MR. NICHOLLS: If we can go back to the scene of these men walking
25 up the street from behind?
Page 18660
1 [Videotape played]
2 MR. NICHOLLS:
3 Q. It's difficult to see here on this video still playing it in
4 Sanction, but the patch on the left arm of the man in the middle, have you
5 been able to tell what patch that is, what that signifies?
6 A. Yes, I've seen better quality picture still from this video and
7 this is the patch of the Drina Wolves unit.
8 MR. NICHOLLS: Continue, please. Sorry, I should have said for
9 the record we were at approximately 39.41. Thank you.
10 [Videotape played]
11 MR. NICHOLLS: It's playing a little bit choppy at the moment but
12 we can stop here at 41.12.5 just for Your Honours to know, here we are the
13 date and time stamp showing the 14th of July.
14 We can continue.
15 [Videotape played]
16 MR. NICHOLLS:
17 Q. All right. Mr. Blaszczyk we've now -- you could say we have left
18 Srebrenica and come to Zeleni Jadar wood factory, chapter 4 of your book.
19 Could you just -- and this is shown mostly on pages 70 and 71, the photos
20 showing the location and we'll watch this clip in a minute. I think it's
21 quite clear from your video still you've selected and the current
22 photograph on page 71, looking at photo A on page 70 and photo A on page
23 71. Can you just tell us where we are and what we see here?
24 A. Yes, we are in Zeleni Jadar wood factory on the page 70 on the
25 stills A, we see the building, wood factory in Zeleni Jadar. On the page
Page 18661
1 71, we see the current picture of the same building. And on the page B
2 from the sequences when we play the footage, we see that the people are
3 working inside the factory.
4 Q. Okay. I think you could say that in 70 B, who are the people in
5 that photo?
6 A. In the first man in front of us, from -- this is Tomo Kovac, the
7 former Minister of Interior of Republika Srpska. The second man in the
8 middle is Dragomir Vasic and the last one is Mr. Borovcanin.
9 MR. NICHOLLS: Play the video now, please.
10 JUDGE AGIUS: Yes, one moment.
11 MR. LAZAREVIC: I apologise, first I would like to see whether
12 Mr. Nicholls would finish with his testimony today because there is one
13 issue that I would like to raise before the Trial Chamber. It would take
14 literally two minutes just to make sure that I'm going to have them.
15 JUDGE AGIUS: We have about five minutes left.
16 MR. NICHOLLS: Your Honour, there is approximately 20 minutes, a
17 little bit less than 20 minutes of video left which won't require too much
18 intervention by me but I think it's important to see it before Mr.
19 Petrovic comes. So, no, we won't finish today but we'll finish quite
20 quickly tomorrow afternoon.
21 JUDGE AGIUS: So why don't we stop here and we'll start the wood
22 factory tomorrow again.
23 MR. NICHOLLS: That's a good idea. Thank you.
24 JUDGE AGIUS: I think so.
25 Okay, Mr. Blaszczyk, we haven't finished yet. We'll continue
Page 18662
1 tomorrow in the afternoon at 2.15. And, hopefully, then we should finish
2 with you, with cross-examinations too.
3 THE WITNESS: Thank you, Your Honour.
4 JUDGE AGIUS: Thank you.
5 JUDGE AGIUS: Yes, Mr. Lazarevic?
6 MR. LAZAREVIC: Yes, Your Honour, I believe I'll have to wait, and
7 allow Mr. Blaszczyk to leave the courtroom.
8 [The witness stands down]
9 Mr. Blaszczyk was testifying today in the capacity of the witness.
10 He made a solemn declaration. He didn't finish with his testimony today.
11 We are aware of the situation that Mr. Petrovic is right here in The
12 Hague, and it appears that Mr. Blaszczyk was also present when
13 Mr. Petrovic was giving his interview to the Office of the Prosecution.
14 So, I would just like to raise this issue before the Trial Chamber because
15 we would vigorously oppose to a situation that Mr. Blaszczyk and
16 Mr. Petrovic meet before Mr. Petrovic finishes his testimony. I'm fully
17 aware that this particular witness is chief investigator in the
18 Prosecution, but right now he's a witness before the Tribunal so he should
19 be prevented of discussing the gist of his testimony with another
20 witness. Just I would like to raise this for the Trial Chamber.
21 JUDGE AGIUS: Thank you, Mr. Lazarevic. Who is going to deal with
22 this? Yes, go ahead.
23 MR. NICHOLLS: Could we have one moment, Your Honour?
24 JUDGE AGIUS: Yes, certainly.
25 [Prosecution counsel confer]
Page 18663
1 MR. NICHOLLS: Thank you, Your Honours, for that moment.
2 I can understand in principle what my friend is saying. Our
3 strong preference, I have not yet met Mr. Petrovic since he's arrived
4 here, would be to meet with him with Mr. Tomasz Blaszczyk, as the
5 investigator. Mr. Blaszczyk was involved in the interview with
6 Mr. Petrovic and knows him and the Court is aware that we had some
7 difficulty or was not easy at the beginning getting Mr. Petrovic to agree
8 to come here and I think it could be helpful. I don't really see what the
9 problem is. Of course, the testimony of both witnesses is related since
10 it covers the same video. However, Mr. Blaszczyk has testified to is very
11 straightforward. We would not be discussing his testimony at all between
12 myself and Mr. Blaszczyk or Mr. Petrovic. He would simply assist me as
13 investigator does in the proofing. I think especially the nature of this
14 type of testimony, where he is just talking about places he's identified
15 in the video and where he's been is not -- I don't see any risk of
16 corruption of these two meeting, and I would much prefer that
17 Mr. Blaszczyk be available for the proofing this afternoon. It's not -- I
18 just don't see the problem.
19 JUDGE AGIUS: And also take an active part? In other words?
20 Because the proofing will be done by you, presumably --
21 MR. NICHOLLS: It is by me. He might ask questions. He probably
22 doesn't need to, really, but he would --
23 JUDGE AGIUS: But can he follow the proofing without being present
24 in the same room?
25 MR. NICHOLLS: Yes, but it's more that I think it will -- it's
Page 18664
1 more his presence that I want. I need a -- I always have a witness with
2 me whenever I talk to anybody, and he knows the witness, Mr. Petrovic, who
3 is coming and they have -- as I said he's been to his home and all of that
4 and I think it would be helpful to me, and I just can't imagine where the
5 problem is going to be. Any cross-examination is still to come and
6 anything can be asked about what's talked about but we won't be discussing
7 Mr. Blaszczyk's testimony at all during that proofing.
8 JUDGE AGIUS: Okay. Mr. Lazarevic, do you wish to comment
9 further?
10 MR. LAZAREVIC: Yes, I believe we were all very carefully
11 listening to what Mr. Blaszczyk said. He made quite a lot of comments,
12 his own comments, about certain parts of this video and, basically, I
13 think that same rule should apply to any witness, whether it's an
14 investigator of the OTP or any other witness.
15 JUDGE AGIUS: Okay. Thank you.
16 MR. LAZAREVIC: Basically they are discussing the same events.
17 [Trial Chamber confers]
18 JUDGE AGIUS: Yes. We are all in agreement here on how it should
19 go. Judge Prost will be explaining to you exactly how you will be
20 proceeding during the proofing session.
21 JUDGE PROST: Taking into account the submissions that were made
22 and the Prosecution's point relating to the relationship such as it may be
23 between Mr. Blaszczyk and the -- Mr. Petrovic, we would prefer if
24 Mr. Blaszczyk is present only at the commencement of the interview to
25 greet the witness, to have any preliminary non-substantive discussions and
Page 18665
1 then he leaves when the actual substantive proofing session takes place
2 for the remainder of that process.
3 JUDGE AGIUS: In addition, I would add that if at any time during
4 the proofing session you need to consult Mr. Blaszczyk, you can, of
5 course, interrupt the proofing and go and consult Mr. Blaszczyk.
6 MR. NICHOLLS: Thank you.
7 JUDGE AGIUS: Okay. That's the end for today. Could you convey
8 our apologies to -- all right. Okay. Yes, Mr. Lazarevic?
9 MR. LAZAREVIC: Well, Your Honours, I really cannot say anything.
10 We are fine with Your Honour's ruling, just to make sure that it's all
11 done in proper way, I believe it should be maybe recorded.
12 JUDGE AGIUS: Okay. Thank you. We stand adjourned until tomorrow
13 at 2.15.
14 --- Whereupon the hearing adjourned at 1.50 p.m.,
15 to be reconvened on Tuesday, the 4th day of
16 December, 2007, at 2.15 p.m.
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