Tribunal Criminal Tribunal for the Former Yugoslavia

Page 5389

 1                           Thursday, 27 March 2008 2                           [Open session]

 3                           [The witness entered court]

 4                           --- Upon commencing at 8.30 a.m.

 5                           [The accused entered court]

 6             JUDGE ANTONETTI: [Interpretation] Registrar, kindly call the

 7     case.

 8             THE REGISTRAR:  Good morning, Your Honours.  Good morning to

 9     everyone in the courtroom.  This is case number IT-03-67-T, the

10     Prosecutor versus Vojislav Seselj.

11             JUDGE ANTONETTI: [Interpretation] Today is Thursday, the 27th of

12     March.  I'd like to greet the Prosecutor, the witness, Mr. Seselj, as

13     well as all the other people in the courtroom.

14             I shall ask to move into closed session so that we can take the

15     solemn declaration.

16                           [Private session]

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11 Pages 5390-5391 redacted. Private session.















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 7                           [Open session]

 8             THE REGISTRAR:  Yes, Your Honours.  And we're in open session

 9     now.

10             JUDGE ANTONETTI: [Interpretation] Please sign this sheet is of

11     paper.

12                           Examination by Mr. Marcussen:

13        Q.   And Mr. VS-1015, would you look without -- I think we should just

14     confirm.  Mr. Witness, would you please look at the sheet and just answer

15     yes or no, is it your name and your birth date that's written on this

16     sheet?  Is that correct?

17        A.   Yes.

18             JUDGE ANTONETTI: [Interpretation] Can we have an exhibit number

19     for this document, please.

20             THE REGISTRAR:  Your Honours, this becomes P308 under seal.

21             MR. MARCUSSEN:  And before I begin my questions I would like to

22     apologise to the Court.  I have had since Tuesday with me one of our

23     interns to assist me, Mr. Ola Quarnstrom, and I failed to introduce him

24     initially.

25        Q.   VS-1015, what is your ethnicity?

Page 5393

 1        A.   I'm a Muslim of the Islamic faith.

 2        Q.   Without mentioning the name of your village, could you tell us

 3     what the ethnic composition of your village was?

 4        A.   My village, as far as the ethnic composition goes, was as

 5     follows:  70 per cent Serbs, and the rest were Muslims, perhaps a few

 6     women who were Croatian.

 7        Q.   And how was the relationship between Muslims and Serbs when you

 8     grew up?

 9        A.   Well, it was really good.  There were never any problems, and as

10     far as I know, there were never any Serbs or Muslims that went to court

11     because of some conflict.

12        Q.   Did that change at any point in time?

13        A.   Well, it only changed when the elections took place and just

14     before the war.

15        Q.   And what year was that you think the change took place?

16        A.   As far as I remember that was 1990 or 1991, thereabouts.

17        Q.   Was a police station established in your village at some point?

18        A.   Yes.

19        Q.   When?

20        A.   That was just before -- well, roughly when the killing started,

21     when the war started, but I didn't know who that was, but I learnt

22     through the radio that it was Arkan's attack on Bijeljina when Bijeljina

23     was taken over by those forces.

24        Q.   Just to clarify, the police station was established shortly

25     before the attack on Bijeljina; is that correct?

Page 5394

 1        A.   No.  No, it wasn't.  It was after that when some sort of police

 2     patrols were set up.  They were just Serb patrols.

 3        Q.   Was -- these patrols, was that before the attack on Zvornik?

 4        A.   Yes.

 5        Q.   Were there any Muslims in the patrols or at the police station?

 6        A.   No.

 7             MR. MARCUSSEN:  I'd like us now to go into private session for a

 8     little bit.

 9             JUDGE ANTONETTI: [Interpretation] Yes.

10                           [Private session]

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11 Pages 5395-5396 redacted. Private session.















Page 5397

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17                           [Open session]

18             THE REGISTRAR:  Your Honours, we're back in open session.

19             MR. MARCUSSEN:

20        Q.   VS-1015, at some point did you take your family out from your

21     village?

22        A.   Yes, I did.

23        Q.   When?

24        A.   Well, I don't remember exactly when that was, but it could have

25     been around the 6th of April, thereabouts.  And I saw that something

Page 5398

 1     wasn't right, so I took my wife and two children, and we set off in the

 2     car towards Zvornik and Serbia.  So when I got down to the main road, I

 3     was stopped there by two policemen from my own village.

 4             They stood there and said to me, "You can't go further up to

 5     Zvornik.  The situation isn't good.  You can't go up there."  And I said,

 6     "Well, what am I supposed to do?"  And then they suggested that I go via

 7     a field down to the Drina River and to cross over into Serbia that way

 8     because there were boats ferrying across the river, and I saw women and

 9     children before that who were Serbs were moving off away from Serbia and

10     crossing over there.  I don't know why they were going, but they were

11     going in large numbers, so I, too, went that way.  And I arrived at the

12     Drina River.  I knew some of the locals there.  I recognised them.

13             So I crossed over with some or the of military boat.  It was an

14     olive-green army boat that they had, and they had a motor, it was a motor

15     boat.  So once I crossed over to the other bank into Serbia, the place

16     was Brasina, they directed me to a cultural centre or a building like

17     that.  So I did go there, and they registered me there.  The Red Cross

18     registered me there.  And as I knew the people there, too, they told

19     me -- they said to me, "Well, now you're here.  That's good.  You can go

20     and see a man called Bata."  I don't remember this man's surname.

21     Because Bata or Bato also worked in my firm and we knew each other.

22             So they drove me to this colleague of mine in a car, and I stayed

23     there --

24        Q.   Let me stop you.  Sorry for interrupting you.  Did your family

25     remain in -- on the other side of the river?

Page 5399

 1        A.   No, no.  I said I went with my wife and two children, and my

 2     mother and father stayed in our family home in the village.

 3        Q.   Did -- did you go back to your village?

 4        A.   Well, the following day I went back to my village to get some

 5     things and to see the house, and everything seemed to be normal.  Nothing

 6     special was happening.  So I managed to collect up some goods and return

 7     to Serbia, again crossing over in a boat.  So that that night or the

 8     following day, I don't remember, that's when Zvornik was attacked.

 9        Q.   And at some point did you go back to your village once again?

10        A.   After -- or the next day when Zvornik fell there was a broadcast

11     over Radio Zvornik asking the citizens to come back, the locals to come

12     back and to go back to their workplaces so that work could continue.  And

13     if you didn't go back to work, you'd lose your job.

14        Q.   So did you go back?

15        A.   I did go back, yes.  This same man, Bato, took me to Loznica to

16     Sipacki bridge because the waters of the Drina River were high at the

17     time, so he took me over the bridge into Bosnia.  And just by chance --

18        Q.   Let me stop you and ask you just this:  When you came back did

19     you then continue to go to work?

20        A.   No, no, no.  There was no chance.

21        Q.   Were you at some point arrested?

22        A.   Yes, I was.

23        Q.   Do you remember the date and, if so, what was the date?

24        A.   That was the 7th of May, 1992.

25        Q.   Thank you.

Page 5400

 1        A.   At around 18 --

 2             MR. MARCUSSEN:  And, Your Honours, if we can go into private

 3     session for a little bit.

 4             JUDGE ANTONETTI: [Interpretation] Private session, please.

 5                           [Private session]

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10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15                           [Open session]

16             THE REGISTRAR:  Your Honours, we're back in open session.

17             MR. MARCUSSEN:

18        Q.   VS-1015, after being arrested were you detained in some location?

19        A.   Yes.

20        Q.   What's the name of the location you were detained at?

21        A.   That location is called Ekonomija, but in the -- it belonged to

22     Celopek village.

23        Q.   When you came to Ekonomija did you see any guards there?

24        A.   Yes.

25        Q.   Were they wearing uniforms?

Page 5401

 1        A.   Yes.  They were wearing the old olive-green type of military

 2     uniform.

 3        Q.   At some point did you get information about their status, whether

 4     they were military, whether they were police, whether they were

 5     reservists or something like that?

 6        A.   Later on when I was in detention I learnt that they were just

 7     guards there from some place, Trnovica, by Vitinicki Kiseljak.

 8        Q.   Where were you placed when you first came to Ekonomija?

 9        A.   They put us up in a small room like a guard hut or something like

10     that, 2 by 2 metres.

11        Q.   How long did you stay there?

12        A.   Well, from that evening to the next morning, until about 6.00,

13     6.30, 7.00 a.m.  I don't remember.

14        Q.   And were you asked the next morning to give a statement?

15        A.   Yes.

16        Q.   Who asked you to give a statement?

17        A.   Well, a man came.  He had a camera and was wearing trousers and a

18     camouflage uniform with a T-shirt and a sort of bandanna around his head,

19     and his name was Dragan Toro.  And later on he was referred to as major,

20     Major.  And later on I also learnt when we were in the Ciglana, from him

21     personally, that they -- they called each other by these names or

22     nicknames.  And it is true and correct that his name was Dragan.  Toro

23     was the nickname.  And later on captain and later on again major.

24        Q.   Did you hear from himself that he was called Toro?

25        A.   Not from him personally.  I heard other people calling him that.

Page 5402

 1        Q.   And after you had given a statement were there anyone else

 2     present?

 3        A.   Yes.  We were put up in that room.  (redacted)

 4   (redacted)

 5          He turned on the camera and he started with (redacted) asking him to

 6     provide his particulars, the name, the date of birth, why he was

 7     arrested, why he was there.  And then he asked me the same questions, and

 8     finally he asked (redacted) the same questions.

 9             This lasted maybe two or three minutes altogether.

10        Q.   And were you -- were you searched or was anything taken away from

11     you after you had been -- given your statement?

12        A.   Yes.  They told us to go out, and as we were leaving that little

13     house there were a few other soldiers there, some of whom I can't

14     remember because I was too afraid to remember their faces.  They all wore

15     uniforms.

16             So we went to another -- a bit bigger room, which was their

17     administration with a few offices.  It was yellow.  The facade was

18     yellow.  There were two steps.  There was a terrace.  They told us to go

19     up there.  They took off our shoelaces, our belts, and from me they took

20     away my wristwatch.  There were two soldiers, one of whom was called

21     Sasa, and the other was Pivarski.  That's what I learned subsequently.  I

22     don't know whether those were their proper names or nicknames.  I don't

23     know.

24        Q.   Did -- how did you learn of these nicknames?

25        A.   Well, we learned later on when we were at Ciglana, when they came

Page 5403

 1     and when they --

 2             JUDGE ANTONETTI: [Interpretation] One moment.  I think we'll have

 3     to redact, because we are in open session and he gave some names.

 4             MR. MARCUSSEN:  I don't think there's a concern with the names

 5     per se.  In private session I can explain, but I think the mere mention

 6     of these two names of victims is unproblematic.

 7             THE ACCUSED: [Interpretation] Objection, Your Honour.  I believe

 8     that the Prosecution does not need to explain anything.  We kept on

 9     mentioning those two names all day yesterday, so there's no need to

10     redact or to go into private session.  These men are on trial in

11     Belgrade, or at least one of them in any case.

12             JUDGE ANTONETTI: [Interpretation] Well, everybody agrees.  Let's

13     proceed.

14             MR. MARCUSSEN:

15        Q.   VS-15 [sic], you said you were taken to a building and put in

16     another room.  Were there anybody else in that room when you were let

17     into it?

18        A.   Yes, there were.

19        Q.   How many people were there?

20        A.   As far as I can remember, the way I saw it, that is, and later on

21     the numbers grew, but there was some 17 or 18 people altogether.

22        Q.   How did these people look, please?

23        A.   I suppose that they had arrived a few days before me.  They

24     looked a bit tired.  Some of them were wounded.  They looked scared.  You

25     could see it in their eyes that they were frightened.  When I looked

Page 5404

 1     around me, I could see drops of blood here and there, traces of blood in

 2     any case.

 3        Q.   Thank you.  In the transcript at page 15, line 14, I may have

 4     made a mistake, but it should have been VS-1015.

 5             Did you know any of the people who were in the room at the time

 6     that you got in there?

 7        A.   I knew two elderly people by sight.  They were over 50 years of

 8     age.  I didn't know anybody else.  Only later would I meet them at that

 9     place and in Ciglana and I would learn their names, some of their name at

10     least.

11        Q.   On the day that you were put in this room -- sorry.  No.  On the

12     day you were put in this room, were you mistreated in any way?

13        A.   I believe so.  From then groups of young men started dropping by.

14     They ill-treated us.  They beat us.  They tortured us in various ways.

15     For example, we had to be seated facing the wall with our hands on the

16     back and so on and so forth.

17        Q.   Do you know the name or nicknames of any of those who

18     participated in the beatings?

19        A.   It transpired later on that in these groups, and one of them was

20     referred to as Seselj's men, Seseljevci, the other group was Kraljevo

21     group.  Actually, it was one and the same group because they all hailed

22     from Kraljevo.  I would learn later on that they were Seselj's sabotage

23     group and that their captain was Niski.  That group that I would

24     recognise later on came first.  They started ill-treating us.  They

25     started counting heads and separating us in threes.  Savo was also in

Page 5405

 1     that group together with Dragan Toro, Sasa as well, and the others whom I

 2     can't remember at the moment.

 3        Q.   You say that you later identified one group as being -- you call

 4     it Seselj's group.  Why do you associate this particular group with

 5     Seselj?

 6        A.   It was not that I wanted to associate them, but because of the

 7     incidents at the Ciglana, Captain Niski himself said he was a member of

 8     Seselj's sabotage group and that he was fighting with them, and at one

 9     point he said that he himself, he didn't know what he was fighting for.

10             And later on, Dragan Toro -- just let me concentrate a little.

11     Dragan Toro and Savo also were members, and at Ciglana they would have

12     more contact, all of them, with two, three prisoners who worked there

13     putting up a roof, and they personally repaired their cars.  I don't know

14     whether they crashed their cars or whether their cars got broken.  The

15     names of these people were Jusuf Audispahic and Alija Sibljakovic.  I

16     believe that they were mechanics, so that I heard from them as well that

17     they were that group, that they hailed from Kraljevo, and that would be

18     that.

19        Q.   We're jumping in time, but now that we are on this topic, this

20     was in Ciglana.  Were you doing work at that point in time for this

21     particular group that you're talking about?

22        A.   Yes.  I worked after having been left half dead up there, but

23     luckily enough and praise be to God that I remained alive.  After that

24     they started taking us on to looting campaigns.  Some were taken to work,

25     and the others were taken to Zvornik and Kozluk to collect the materials

Page 5406

 1     and the stuff that they wanted to be taken away.  We knew immediately

 2     where -- where we were being tank and where the stuff was being taken to.

 3        Q.   And was this at the time that the two mechanics worked for the

 4     same group and told you about these men belonging to Seselj's group, that

 5     identified themselves with Seselj?

 6        A.   I did not know it at first.  I was up there incarcerated at

 7     Ekonomija from the 7th to the 12th of May for four or five days, and then

 8     from the 12th of May to the 15th of July, 1992.  And as the time went on,

 9     things became more clear and we learned more and more details.

10        Q.   Thank you.  Going back now to Ekonomija -- I realised we jumped,

11     so we're going back now to talk about Ekonomija.

12             You said there were different groups.  One was Seselj's groups.

13     What was the other group -- other groups that were beating you?

14        A.   Another group came to Ekonomija, the so-called Specials, or at

15     least that's what we heard from the others who were in charge of us.  And

16     I again have to say that they were Seselj's men who were then replaced

17     between the 1st and the 4th of July.  These Specials were being put in

18     our command.  They were policemen from Loznica.

19             That group, and I suppose there were some others, because

20     sometimes they would come all together to beat us and to ill-treat us,

21     and sometimes they came individually or in smaller groups.

22        Q.   The -- the Loznica group was also at -- or the group you later

23     learned was the Loznica group, were they beating you at Ekonomija?

24        A.   Yes.  They came.  I remember there was one person whom I got to

25     know later on.  He was known as Prlje, a sturdy, big man from Loznica

Page 5407

 1     about 30 years of age, and there were a few other policemen together with

 2     him.  One known as Lale came with them.  He was also a policeman, but he

 3     wore a camouflage uniform and a bandanna around his head because he had a

 4     somewhat longer hair.  They came to beat us.  And in that case I

 5     believe --

 6        Q.   And this person Lale came to beat you.  Did he particularly beat

 7     you on a certain occasion?

 8             You nodded your head as if you said yes, but I think you have to

 9     answer, otherwise we cannot see it on --

10        A.   Yes, yes.  He beat me personally, and also (redacted)

11     (redacted) as well.

12             On that day, actually at the moment when he came, there were a

13     few of them, and usually when they entered they would take two or three

14     prisoners, and they would let rip on them, and they did whatever they

15     wanted with them.

16             For example, Lale, on one occasion, turned around and called our

17     names, the names of the three of us, started ill-treating us and beating

18     us, and on that occasion he brought in a stick, a piece of wood some 60

19     or 70 centimetres long, a bit irregular shape.  It was a stake.  And he

20     started beating us with that wooden object.  And I remember it well.  And

21     let me continue and wrap this up.  He was beating us on the stomach, on

22     the head.  I would fall down.  He was beating (redacted) on the head

23     and on the stomach, and he also fell down and then he would stand up.  He

24 also beat (redacted).  And then when everybody else was done, every time they

25     beat us it would last for 10 or 15 minutes according to our estimate.

Page 5408

 1     Sometimes it was shorter.  Sometimes it was longer.  If they had

 2     continued for any time longer I believe that they would have killed some

 3     of us or all of us, but that's how I saw it, that's how I perceived it at

 4     the time when this was all happening.

 5        Q.   When Lale was beating you, did you lose consciousness?

 6        A.   Yes.

 7        Q.   What did he do?

 8        A.   Lale beat me in the stomach with that wooden stake and in the

 9     chest.  I lost consciousness.  I fell down.  There was a tap, a water tap

10     there.  I suppose that that room had been used as a storage.  Its size

11     was 5 by 5 or 5 by 6 metres.

12             There was plastic water bottle that he used to sprinkle water

13     over us to help us come to.

14             I must have been unconscious for a couple of minutes, up to 10

15     minutes, and then I came to.  I stood up and the beating continued.

16        Q.   Thank you.  On the same day -- sorry.  Let me first ask you, are

17     you familiar with a person -- you can just answer yes or no.  Are you

18     familiar with a person who went by the nickname of Bubica?

19        A.   Yes.

20        Q.   Did anything happen to him on the day that you were beaten by

21     Lale?

22        A.   I can't be a hundred per cent sure whether on that evening or on

23     the following day, but it did happen.  I must say that.  It did happen

24     that they stormed into the room.  I believe that it was on the 9th or

25     maybe some other date later on.

Page 5409

 1             They came, headed with Savo and Dragan Toro, and there were other

 2     men with them, and they came directly to Bubica.  That's his nickname,

 3     and I can't remember his name.

 4             They started circling around him.  Savo took off a golden chain

 5     from around Bubica's neck, and he personally put it around his own neck.

 6     And later on since he wore at the time and he continued carrying a pump

 7     gun, it's a hunting rifle with three bullets, he placed that rifle under

 8     his chin and that's how things continued.  And they started -- they

 9     continued ill-treating all of us, but Bubica suffered the most on that

10     occasion.

11             They called the whole thing processing.  So on that occasion

12     Bubica was processed more than the rest of us.

13        Q.   I'd like to move on to the 11th of May.  Did the person that you

14     have mentioned who has the nickname of Niski come to the prisoners that

15     day?

16        A.   I apologise.  Yes.  Yes, he did.

17        Q.   Could you tell us what happened when he came?

18        A.   On that day Niski came and told us that he wanted to transfer us

19     to Ciglana to work there.  He selected -- actually, he counted some 15 or

20     20 men, I can't remember exactly how many.  I was the first whose name

21     was called, and then (redacted) and so on and so forth.

22             (redacted) said that he would also like to go and work, and

23     then the soldier who was with Niski at the time, and I can't remember

24     exactly who it was, it may have been Lala, in any case he said -- and I

25     don't know whether I'll and able to quote him correctly but let me just

Page 5410

 1     try, he said, "You are not going to be able to survive that kind of work.

 2     You can't go to work because you're not up to it."

 3             MR. MARCUSSEN:  And if we could go into private session for a

 4     moment.

 5             JUDGE ANTONETTI: [Interpretation] Mr. Registrar.

 6                           [Private session]

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18                           [Open session]

19             THE REGISTRAR:  Your Honours, we're -- sorry.  We're back in open

20     session.

21             MR. MARCUSSEN:

22        Q.   After Niski had left were you processed again?

23        A.   Yes.

24        Q.   By who?

25        A.   The same people who came with him.  I must say that I never saw

Page 5411

 1     Niski personally beating anybody.  And let me tell you why he was called

 2     Niski.  I don't know.  I suppose that either he hailed from Nis or

 3     something, but also he had another nickname, Captain.  I don't know

 4     whether that was his position.  But later on we would see that he was one

 5     of the leaders of that group that was in charge of us when we worked up

 6     there.  And there these mixed groups would come in, and then they would

 7     be beating us for 10 to 15 minutes.

 8             And I remember that on that day, on the 11th, a woman or a young

 9     girl came.  In any case, she was around 25 years of age, and she also

10     took pleasure in ill-treating us.  She would -- kicked us using karate

11     kicks.

12             It also happened at the time that we would be beaten and kicked.

13     And one person would step aside to help them orientate themselves while

14     they were beating us.

15        Q.   Thank you.  Now, moving on to the morning of the 12th of May.

16     Were -- were anyone taken out of the room that day?

17        A.   Yes.

18        Q.   Who was taken out of the room first?

19        A.   In the morning of that day, around 5.00 or maybe a bit later, as

20     far as I can remember, the door of that detention place opened and Zoks

21     leaned through the door.  That was his nickname.  He called (redacted) to

22     step out.

23            (redacted) followed him outside, and we could hear them shout.  We

24     could hear beating which stopped after a while and then started again

25     after a while, and (redacted) was then returned to the room.

Page 5412

 1             Later on I would learn from (redacted), after he had been beaten

 2     outside, that he had been taken again to that small room where we were

 3     incarcerated at first.

 4             And then he called (redacted) name and (redacted) was taken

 5     outside.  But that was only a few metres behind the door.

 6        Q.   If I can just stop you.  When (redacted) came back into the room,

 7     apart from -- did he tell you what had happened to him?

 8        A.   Not at that time.  He told me later on.  It was simply

 9     impossible.  It all happened so fast, and -- and he was afraid.  He was

10     scared.

11        Q.   Apart from being beaten, did he tell you anything else about what

12     was done to him, or was anything else done to him?

13        A.   Later on when we were at Ciglana, he told me that he had been

14     beaten outside and inside, that they forced him to take off his pants,

15     and they tried to insert a wooden object into his anus.  And then they

16     returned him to our room.

17             That's what he told me.  I'm not claiming that it's true.  I

18     wasn't there, but that's what he told me.

19        Q.   And now getting back to -- you said the next person that was

20     called out was (redacted).  Could you please tell us what happened.

21        A.   Yes.  They called out (redacted) name.  But let me say

22    again Zoks, because I saw this, and he was on his own both with (redacted)

23     and with (redacted) and later in my case.

24             As far as I was able to observe and hear, this was just a few

25     metres behind that door where they started beating him vehemently.  They

Page 5413

 1     were dull thuds, so you could see -- you could hear that they were using

 2     a blunt object.  And you could hear him moaning and groaning.  This went

 3     on for a few minutes.  It was hard to measure the time.  And when I

 4     looked at the door, Zoks was pushing him back inside.  He was falling

 5     down, and I saw his eyes half closed.  And instead of his pupils, I could

 6     see the white of his eyes where his pupils should have been.

 7             He fell down or the floor next to the door, and Zoks yelled,

 8     "(redacted), now you come out."  And I was the next to go out.

 9        Q.   And what happened when you went out?

10        A.   When I went outside, I saw several soldiers, the ones I mentioned

11     before who were there as guards.  They had some automatic weapons, and

12     they were standing still as if they were surprised.  I walked on for some

13     ten metres.  There was some gravel down there.  It was slightly wet

14     because it had been raining that night.

15             Zoks took me forward and brought me to a place where there were

16     some logs on the ground.  They were piled up.  And they were actually oak

17     logs.  They were probably meant for producing something.

18             On that pile of logs a bearded man was sitting there, and he had

19     a pony-tail.  His hair was tied back in a pony-tail.  It was about 10 to

20     12 centimetres long.  And in his hand he was holding a piece of paper.

21             He was wearing black trousers.  They were kind of flared.  And I

22     remember well that on his feet he was wearing black trainers.  We

23     referred to them as zepas.  They were not actually trainers but a sort of

24     footwear worn by elderly women usually.

25             And this bearded person who had a pony-tail was the one who got

Page 5414

 1     into the van with us when they had taken us from my village to Ekonomija.

 2        Q.   Was -- was this particular person referred to in any particular

 3     way by the others who were present?

 4        A.   Later on -- or, rather, now when I was taken out, I'm talking

 5     about myself now, Zoks said to me, "Now Vojvoda is going to put a few

 6     questions to you, and if you don't answer correctly, or if you don't

 7     answer at all, you know what's in store for you."  And then this Vojvoda

 8     said to me, "You know what's in store for you if you don't answer."  And

 9     he asked me a question as follows -- I remember some things very well.  I

10     may be a little bit emotional when I speak about it.  He said --

11             THE INTERPRETER:  Could the witness repeat what this man said?

12             THE WITNESS: [Interpretation] I said, "I don't know who it could

13     be," but I was wondering what Serb would be selling weapons to Muslims if

14     they were going to wage war in the future.  So I didn't know the answer

15     to that question.  And Zoks who was standing behind my back hit me so

16     hard with a hose he was holding in his hands, it was about 60 centimetres

17     long and had a diameter of about 30 millimetres, and at the end it had a

18     bend, and he hit me on my right side.  But I forgot to tell you that

19     before he that said that I had to keep my hands above my head like this

20     and that I shouldn't lower them.

21             So when he hit me like that, he hit me so hard I fell down onto

22     the ground breathless, and I nearly lost consciousness.  I hit the gravel

23     with my head and with my forehead, and it had been raining.  I was almost

24     fainting, but he ordered me to get up again.  And as I was getting up, he

25     would kick me in the back so painfully that I found it very hard.  And I

Page 5415

 1     had to get up, but I had to keep my hands raised.  I couldn't get them

 2     down.

 3             And then Vojvoda kept asking me more questions.  They were always

 4     the same questions, and I didn't know the answers to shows questions.

 5     And then Zoks beat me on both sides, one side and the other.  And then

 6     one time when he kicked me I flew forward, and it was some two metres

 7     away from Vojvoda, and I landed on the logs right next to Vojvoda, and he

 8     said, "Why are you going towards Vojvoda?"  And he grabbed a piece of

 9     wood -- or, rather, it was a piece of a stake, some sort of stake, and he

10     started pushing it into my bottom but through my trousers.  So I don't

11     know whether he really wanted to pierce me through or just to make me get

12     up.

13             And then I got up, and Vojvoda said -- he said the following, he

14     said, "You didn't tell me the answers but your two daughters know.  I

15     will fuck them and they will tell me."

16        Q.   Should we --

17        A.   I apologise.

18        Q.   Should we maybe have a five-minute recess?

19        A.   Yes, please.

20             MR. MARCUSSEN:  We'll take a little break.

21             JUDGE ANTONETTI: [Interpretation] Very well.  We'll have an early

22     break, then, and we'll have a 20-minute break.

23             MR. MARCUSSEN:  Thank you, Your Honours.

24                           --- Recess taken at 9.41 a.m.

25                           --- On resuming at 10.01 a.m.

Page 5416

 1             JUDGE ANTONETTI: [Interpretation] The hearing may resume, and I

 2     will give the floor to the Prosecutor.

 3             MR. MARCUSSEN:  Thank you.

 4        Q.   VS-1015, before we move on, could I just ask you to explain once

 5     again what was the -- the thing that you were hit with when you had to

 6     put your arms up in the air.  I think there might have been a problem in

 7     the translation.  That's why I'm asking you.

 8        A.   Yes.  He was holding a pipe in his hand, a zinc-plated plumbing

 9     pipe which was about 60 to 70 centimetres long.

10        Q.   At page -- just for reference, at page 16, line 13, this tool has

11     been described as a hose, but it would seem that it was a pipe.

12             VS-1015, after this were you taken back into the room where the

13     other detainees were?

14        A.   Yes.  Then Zoks escorted me to the door, and I entered the room

15     where the others were.

16        Q.   Did you -- did you then learn what had happened to (redacted)

17     (redacted)?

18        A.   When I entered the room, I had been near the door before, and

19     (redacted) was even closer to the door, in the corner.  He was lying

20     on the concrete floor with his head facing the wall.  His face was

21     towards the wall.  I thought he was lying down, but the other detainees

22     were looking at me in a strange sort of way.

23        Q.   If I can stop you.

24             MR. MARCUSSEN:  Then could we go into private session.

25                           [Private session]

Page 5417











11 Page 5417 redacted. Private session.















Page 5418

 1   (redacted)

 2                           [Open Session]

 3             THE REGISTRAR:  Your Honours, we're back in open session.

 4             MR. MARCUSSEN:

 5        Q.   VS-15 [sic], on the same day was the person with the nickname of

 6     Bubica also beaten?

 7        A.   Yes.  Bubica was also taken outside, but I didn't see who beat

 8     him because he was outside.  He was taken from those groups behind that

 9     building where we were.  And when they brought him back, he had been so

10     badly beaten up and he was bleeding so badly that he crumpled down on to

11     the floor next to a wall.  I have to say that those walls were not tiled.

12     They were smooth concrete walls.  And when they went back outside, he

13     showed us a sign with his hand.  One arm was broken, but he used the

14     other one, and he couldn't speak, and I think he was asking to be killed

15     because he couldn't take it any more.  That was in the evening, but it's

16     been a long time.  Sixteen years have elapsed.

17        Q.   Thank you.  VS-15 [sic], you mentioned that the person who was

18     beating you had the nickname of Zoks.  When did you learn that he -- that

19     nickname was used about him?

20        A.   We learned that in the Ciglana, the brickworks.  Let me just

21     explain.

22             We had been there for some time in the Ciglana, and we were

23     practically under the patronage of Captain Niski, under his auspices.

24     Dragan Toro, Savo.  I don't know whether Savo was his name or nickname.

25     They were working for him.  And they didn't mistreat us then but on two

Page 5419

 1     occasions when it was done by Pufta and when Zoks came on one occasion.

 2     We certified that this was Seselj's sabotage group and Kraljevac group.

 3     I think they had two names.

 4        Q.   Thank you.  And I believe at page 30, line 13 I again made a

 5     mistake.  It should have been again VS-1015 and not VS-15.

 6             VS-1015, were you taken off to the place where you will to do

 7     work after this?

 8        A.   Yes.

 9        Q.   Do you remember the name or the names of any of the people who

10     went off to do work?

11        A.   I do.  In fact, I mentioned them.  Up to the 15th of July, we had

12     already got to know one another in the Ciglana as workers and colleagues,

13     and I think there was Safet, Kemo, Subasic, Ibrahim, Cinda, Ciciban.

14     That was a young lad of 16.  His nickname was Ciciban.  And there were

15     others whose names I can't recall at present.  There were about 20-odd of

16     us who were taken to Ciglana on the morning of the 12th after what

17     happened to me.

18        Q.   And do you remember the name or names of some of those who

19     remained behind?

20        A.   Well, first of all Bubica stayed behind because he was half dead

21     practically.  Then these two elderly men whom I mentioned stayed behind.

22     And I remember when there was a beating, they looked more like country

23     people, like -- well, they were shouting, "Don't beat us, let us be.

24     I'll give you my oxen," and they mentioned other things as well.  And

25     they were left behind.  And then Jusuf --

Page 5420

 1        Q.   I'm sorry, there seems to be a problem.

 2             JUDGE ANTONETTI: [Interpretation] We're going too fast, maybe?

 3             MR. MARCUSSEN:  I think there's a technical problem.

 4        Q.   No, no, it's a technical issue, VS-1015.  Just wait one minute.

 5                           [Technical difficulties]

 6             VS-1015, I think we need to move on.  So where were you taken to

 7     do work?

 8        A.   To the brickworks known as Ciglana.  That was a company which had

 9     the name of Novi Izvor which encompassed a quarry, the brickworks, and

10     some sort of transport.  All this was part of the Novi Izvor factory

11     which produced bricks and roof tiles.

12        Q.   When you came to the factory were you able to work?

13        A.   On the 12th in the morning when all this took place Captain Niski

14     came back and said that those of us who he picked up should get into a

15     truck to go to work.  I had already cooled down and I couldn't move very

16     well.

17             As I was closer to the door, it turned out later that all those

18     who were in the back of the room went out and they had already got onto

19     the truck and I was the last one to go out.  Someone helped me climb onto

20     the truck.  It was a small truck.  It was a TAM or Zastava, I'm not sure,

21     about two, two and a half tons, and they took us to Ciglana which was

22     about 500 or 70 -- or 700 metres away from the Ekonomija, and it was in

23     the Karakaj neighbourhood, whereas the Ekonomija was in the village of

24     Celopek.

25        Q.   And when you came to Ciglana, could you work -- were you assigned

Page 5421

 1     work on the first day?

 2        A.   When we set out towards the Ciglana, the truck stopped by the

 3     porter's lodge, and someone told us to get out.  My colleagues got off,

 4     but I stayed on the truck because I couldn't raise my legs over the side.

 5     Somebody yelled out, "Why isn't this one getting off?"  My colleague

 6     said, "He can't."  And the soldier who was wearing the same sort of

 7     uniform that the reservists wore, olive-grey, it wasn't camouflage, he

 8     said, "Why haven't they finished you off?  How can you help me?  What

 9     sort of work can you do?"  And then he said to someone that they should

10     get me off the truck.  So they got me off the truck, and then he ordered

11     that another soldier who was wearing a similar uniform to his should take

12     me to a room, and later on I spent time in that room, and later on I

13     learned that this man who was around there for a while was known as Caca.

14     They called him Caca.  That's something like Daddy.

15             They took me to that room.  This man who took me there, judging

16     by his accent came from Serbia, from Vojvodina, they were called Lala.

17     That was a typical nickname from that area.  And he was dark skinned and

18     had receding hair.

19             He and another man took me to that room where they laid me down

20     on the concrete floor.  There was some sort of torn blanket on the floor,

21     and they let me lie down there.  They ordered this man whose nickname was

22     Bego to give me water from time to time, to look in on me, and to give me

23     some sort of meat paste.  It was called bird paste.  And they said if I

24     died, and this is true, if I died they would kill him.  They said it

25     would be all over with him if I died.  And from the porter's lodge which

Page 5422

 1     was next to the road, they brought some sort of towel or rag, and he put

 2     that on my stomach, because from my chest to my groin I was turning black

 3     and blue and swelling up, so that over the next few days I could -- I had

 4     blood in my urine and also when I defecated there was blood.

 5             This person was referred to as Lala.  He said he came from an

 6     area around Beqaj, which is in Vojvodina.

 7        Q.   Thank you.  Later on did you recover enough so that you were able

 8     to start work?  Just for the time being yes or no.

 9        A.   Yes.

10        Q.   We will come back to your work in a little bit, but were you --

11     sorry, I think we need to go into private session.

12             JUDGE ANTONETTI: [Interpretation] Yes, registrar, please.

13                           [Private session]

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 5423











11 Pages 5423-5427 redacted. Private session.















Page 5428

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11                           [Open session]

12             THE REGISTRAR:  Your Honours, we're in open session.

13             JUDGE ANTONETTI: [Interpretation] Very well.  Registrar, in open

14     session can I have the countdown to see how much time the Prosecution has

15     had, please.

16             MR. MARCUSSEN:

17        Q.   VS-1015, did you start to carry out work at Ciglana?

18        A.   After I lay there for a while I recovered a little.  And let me

19     repeat again that the man poured water over me, probably to revive me.

20     Now, whether that succeeded or not, anyway, I felt a bit better over

21     those ten days.  Eight, 10, 12, it doesn't matter, for however long I was

22     there.  But I didn't want to stay there on my own.  I wanted to go out

23     with the others who were going to work.

24        Q.   Okay.  So at some point you started to work.

25             JUDGE ANTONETTI: [Interpretation] Prosecutor, you have half an

Page 5429

 1     hour left.

 2             MR. MARCUSSEN:  Thank you.  And I also realise that I should have

 3     asked for the admission of the document that was shown while we were in

 4     private session.  That was 65 ter number 1306, and I ask that it be

 5     placed under seal.

 6             JUDGE ANTONETTI: [Interpretation] Mr. Registrar, an exhibit

 7     number under seal, please.

 8             THE REGISTRAR:  Exhibit P310 under seal, Your Honours.

 9             MR. MARCUSSEN:

10        Q.   VS-1015, what was the first kind of work you were doing?

11        A.   The first job was that we should go around town and load up some

12     goods and get a truck.  There were two trucks later on or however many

13     they had.  So as far as I was concerned, it was looting because they

14     belonged to the Bosniaks, Muslims, these things.  And there were even

15     some shops belonging to Serbs or some building sites where we took up

16     construction material, and from houses fridges, television sets if they

17     were new.  And let me stress that the Muslim people had the habit of --

18     well, if they had children of a marriageable age, then they would buy new

19     white goods, fridges, televisions, carpets for the marriage.

20             So with Toro, Pufta, Savo, but not Niski.  Now, whether he was

21     their superior, whether he was the main guy or not, he did some other

22     work, I assume.

23        Q.   Later on did you go out on similar trips but with another group?

24     And maybe I should clarify, sorry, led by another group or under the

25     control of another group?

Page 5430

 1        A.   Yes.  And that took place -- let me just mention that.  it lasted

 2     for about 10 to 15 days, maybe more.  But I consider that these people,

 3     the guards who took us over, were from Vojvodina, Novi Sad, and we heard

 4     from them that Caca and his group was the Novi Sad Corps and volunteers

 5     of Mr. Seselj.  That's what they talked about amongst themselves.  Now,

 6     whether they were or were not, I don't know, but that's what they said.

 7     So it's not something that I thought up myself.

 8             So from then until about the 1st -- well, the local guards, the

 9     locals who were guards took over.  And he then from 1st till the 4th of

10     July, I think it was, they had an argument about something.  And these

11     people, if I can refer to them as Seselj's men, had to go, Savo, Niski,

12     Captain Dragan.  He was a major at the time, because they sort of

13     assigned or were given ranks.  That's why this one was captain first and

14     major later on.  That's how they referred to each other.  This one was

15     referred to as major sir.  So they had to go.

16             And in this period from the 1st to the 4th, roughly speaking, of

17     July, there were changes.  They had to leave, and somebody else -- the

18     same people who beat us were to take over led by Prlje, a strongly built

19     young guy, so that we would be under his patronage.  And then they took

20     us to do the work we did outside.

21        Q.   And -- and this -- this second group, where did that group come

22     from?

23        A.   As this man Prlje was from Loznica and I assume his superior,

24     because we could see him deploy people here and there, and then he would

25     come later, and later on I was taken to do looting and so on, so I think

Page 5431

 1     he was their superior, he was from Loznica, and the area around Loznica,

 2     behind the Drina River.

 3        Q.   Thank you.  With this second group did you go to Kozluk?

 4        A.   I went with the second group and that was exactly on the 15th of

 5     July, and that day we went to Batkovici camp, and that was about 9.00.

 6     They called me and (redacted) to go there for something, and then the

 7     previous day at lunch this man Prlje asked me and explained to me that I

 8     was supposed to go where I had left some gold or money and that I would

 9     probably like to see my house again and that some people were interested

10     in that.

11        Q.   Let me just ask you, did you go to Kozluk?

12        A.   Yes, I did.

13        Q.   Were there any inhabitants in Kozluk when you were there?

14        A.   No.  None of the Muslims were there because Kozluk took place on

15     the 26th of June, and my mother was in the people who -- among the people

16     who left.  My wife left on the 4th of June.  She crossed over into Serbia

17     and Subotica and from Subotica further on.

18        Q.   What took place on the 26th of June?

19    A.   Well, on that day they called us up, that is to say (redacted) and me

20     and this Juso who was a mechanic, and they talked about this, that these

21     people were from Kraljevo or wherever, and that he also had a telephone

22     number, Juso had a telephone number belonging to SavaSava left him his

23     telephone number so that he could call him up in Serbia if need be

24     because they had a conflict with the Serbs then.  So they --

25        Q.   Let me stop you again.  What took place in Kozluk on the 26th of

Page 5432

 1     June?

 2        A.   The locals were moved out from Kozluk to Serbia and from Serbia

 3     further on.

 4        Q.   And how do you know that?

 5        A.   I know that -- well, some drivers from those parts came to the

 6     Ciglana, and they talked about it and said that the people of Kozluk had

 7     left, all left then.  And then in Kozluk I was told by Prlje that from

 8     Gornja Sepka people were transported to Loznica and put in Lagator.

 9     Well, Lagator is a sports centre actually, that they were put up there

10     and that they would either leave and go further away or return.  That's

11     what I -- was explained to me when we went to Kozluk to load up the

12     goods.

13        Q.   Thank you.  I'd like to go back a little bit to some specific

14     events at Ciglana.

15             First I'd like to ask you whether the person that you have

16   mentioned a number of times by the name of (redacted), did he have a tattoo

17     which attracted particular attention at Ciglana?

18             THE ACCUSED: [Interpretation] Objection.  Judges, I'm aware of

19     this victim witness, and I didn't intervene earlier on because there were

20     leading questions.  I didn't want to out of respect for the witness, but

21     this has overstepped the limit, and I don't think it should be allowed.

22             The Prosecutor can't ask questions like that.  He should leave

23     the witness to tell his story and then ask who, what, when, how, and so

24     on.

25             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, you're prompting

Page 5433

 1     the answer by asking whether that man had a tattoo.  You should have

 2 asked the question differently.  You should have asked whether (redacted) had

 3     a particular sign that made him different.  But if you say tattoo

 4     straight away, the answer could be yes, yes, he had a tattoo.

 5             MR. MARCUSSEN:  In my respectful submission it is not leading,

 6     and on top of that the accused is saying he's not contesting the

 7     commission of these crimes.  I understand that what is being in dispute

 8     is who committed the crimes, but the accused is saying he is not

 9     contesting the crimes.

10      Q.   But I can also put the question in this way:  VS-15, did (redacted)

11     wear -- were there any signs on (redacted) that caught attention at some

12     point at Ciglana?

13    A.   (redacted) had on both arms tattoos.  Now, I didn't know some things.

14     We were close, but I didn't know about that.  And Pufta was sitting there

15     on one occasion near the porter's lodge with a baseball baton in his hand

16     and called me to come out, and he told me to roll up my sleeves so that

17     he could see what I had.  When he saw that I had nothing, he said, "Aha,

18     it's someone else."  So I suppose he had some information because he

19     asked me to roll up my sleeves.  And then he called out (redacted)

20     came out and then on one arm he found that he had a tattoo of the JNA,

21     when he was in the army, that was on one arm.  On the other arm he had

22     another tattoo with the star and moon sign.

23        Q.   And then what happened?

24        A.   Then he said to him that he should get rid of that and if he

25     failed to take it off his arm he would do it for him with a knife or

Page 5434

 1     whatever.  That's what he told me, because I left straight away.

 2        Q.   And did -- did (redacted) try to remove the tattoo?

 3        A.   He did.  And he asked all of us how he should do it.  We did not

 4     have a solution.  He even asked a nurse, a male nurse, what to do and he

 5     told him it was impossible that the only solution was surgery.  But then

 6     somebody told him that it could be burnt by fire, that it could be

 7     removed by fire.  He tried.  He was afraid to leave it on.  Then we

 8     heated a pate tin to burn his skin to produce a burn, but all the

 9     attempts failed.  Nothing worked and the tattoo remained.

10        Q.   Then what happened?  Did anything happen to the tattoo later?

11        A.   Sometime later, maybe two or three weeks after that, we thought

12     that everything had been forgotten.  However, it happened sometime later

13     that one evening he came back together with Sasa.  They called (redacted)

14     name, and also they called Ismet Cirak's name asking them to come out.

15     They did get out.  They entered another room where I was talking to the

16     policeman who had asked me about the case, and then we could hear screams

17     and shouts and yelling.  And since I was in that room close to a window

18     which was boarded, there was no glass pane on that window, and I could

19     see (redacted) and Sasa by the window.

20             Sasa was banging on the wooden boards, and I replied, and he

21     asked me whether there was any alcohol to be had because he needed it.  I

22   said that I had a shaving lotion called Brion, and I saw (redacted) holding

23     his arm, and then Sasa put that shaving lotion on his arm, and all the

24     time he was saying, "Well, you did well.  You bore it well."

25          Later on (redacted) told me that he was shouting and screaming, that

Page 5435

 1     he was not as firm as he might have been but that he still remained

 2     alive, and if he hadn't been that firm he would have traded as Ismet

 3     Cirak did.

 4        Q.   Let me stop you here.  What had happened to (redacted) arm?

 5       A.   Later on I saw on (redacted) arm that some of the skin was removed

 6     from his arm.  The size of that patch was 4 by 3, as far as I could tell.

 7     I could see the scar, and there was no tattoo any more.  The tattoo had

 8     been removed.

 9        Q.   Were you told who had removed the tattoo?

10    A.   I heard from (redacted) that it was done by Pufta.  Sasa was outside,

11   and he met (redacted) as he was coming out.  (redacted) told me later on --

12        Q.   Sorry, what did (redacted) tell you later on?

13        A.   That Sasa told him, "You fared well, but if you had been yelling

14     louder you would have ended up with Cirak," which I translated as a

15     bullet in the head.

16        Q.   Could you tell us what happened to Cirak when he was taken out of

17     the room together with (redacted)?

18        A.   Cirak was not taken out.  Two men actually carried him.  Pufta

19     was also there.  He was involved, and further away was a car.  I believe

20     that it was Pufta's car.  And they put Cirak's body into the car.  But I

21     could see as they were transporting him some four or five metres away

22     from me that he was bleeding from the left or right-hand side of the

23     neck, and he was holding his thumb on that wound to stop the bleeding.

24     And then he was thrown into the car.  I don't know whether he was thrown

25     into the boot or in the back seat, and they drove him away.

Page 5436

 1             Maybe a minute or two later I could hear a shot.  I could hear

 2     actually four shots fired from a pistol.  I heard it well.  Then they

 3     returned a minute or two later, so that makes me believe that he was

 4     killed from that pistol.  And never again did I see the man after that.

 5        Q.   Where were you standing when you saw Cirak being carried out

 6     bleeding?

 7        A.   I was in the room by the window, as I've told you.  The window

 8     was boarded, but there was an opening between the boards some 10

 9     centimetres wide, so I could see the whole situation very well through

10     that boarded window.

11        Q.   Until what date did you remain in Ciglana?

12        A.   I remained in Ciglana up to the 15th of July, 1992.  On that day

13     we brought a lorry with Prlje from Kozluk, and he said to his driver --

14     actually, to a policeman who was there when we returned from Kozluk, he

15     told him to take his had own black BMW to Loznica, to his sister's

16     husband, and to send the registration plates that would enable him to

17     take that lorry to Serbia, because at the time there were controls of the

18     Serbian authorities on the border between Serbia and Bosnia, which means

19     that after that, our names were noted by another prisoner whose name was

20     Admir.  He took our names on a piece of paper.  This piece of paper was

21     taken to be typed up, and I later saw that paper in Batkovic camp.  Our

22     names were read out from that paper.  Around 1400 or 1500 hours they

23     loaded us onto a bus and they took us to Batkovic camp.

24        Q.   When --

25             JUDGE ANTONETTI: [Interpretation] Mr. Prosecutor, you have 10

Page 5437

 1     minutes left.

 2             MR. MARCUSSEN:  And I'll try to wrap up in less than that.

 3        Q.   VS-1015, before all the events we have discussed today, or before

 4     your arrest, how much did you weigh?

 5        A.   Ninety-six kilos.  And I believe that that's how much I weigh

 6     only after 15 years.  I'm not happy that I weigh that much, but it took

 7     me 15 years to regain that same weight.

 8        Q.   How much did you weigh when you were released from Batkovic?

 9        A.   When I was released from Batkovic I weighed 59 or 60 kilos.  I

10     was weighed in Zimilje [phoen], a place near Bijeljina, when we were

11     working on a farm there.

12        Q.   Had your weight been lower than that?

13        A.   Yes.  It was even lower before that.  But when we were registered

14     by the Red Cross, I believe that it was on the 18th or the 19th of

15     August, or maybe July, I can't remember.  After that we were ill-treated

16     again, and then they started taking us to work.  Fortunately enough the

17     villagers had worked for us.  We were worked in the villages and we were

18     fed well and I would like thank them for that.  Those were the local

19     Serbs who inhabited the environs of Bijeljina.

20        Q.   Until when did you stay in Batkovic?

21        A.   I stayed in Batkovic up to the 21st of July, 2 -- I apologise,

22     1993, when the International Red Cross had us exchanged with Tuzla.

23        Q.   In an effort to ensure that the witness might be able to finish

24     today, I will stop my examination at this point.

25             JUDGE ANTONETTI: [Interpretation] Thank you, Mr. Marcussen.

Page 5438

 1             Very well.  Mr. Seselj, you have the floor.

 2             THE ACCUSED: [Interpretation] I just have to provide a comment to

 3     this tragic, comical words by Mr. Marcussen who decided to stop three or

 4     four minutes before the deadline in order to give us time to finish

 5     today, but you can see very well that we can't finish today unless you

 6     extend today's hearing or if I make a goodwill gesture and save time

 7     today but if you promise me that it will be made up at a later stage when

 8     I need it most.  You did it already once.

 9             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you have two hours

10     and you can finish within two hours.  Otherwise, if you need a few more

11     minutes you would force the witness to stay basically four days, four

12     more days.  So given what he has had to endure, don't add other torments.

13     You are the master here.  You have two hours.  You can use them as you

14     wish.  You can use less time if you want to.

15                           Cross-examination by Mr. Seselj:

16        Q.   [Interpretation] Mr. VS-1015, I do not doubt your story.  I don't

17     doubt what you have been through, but I doubt certain details of that

18     story, so we will dwell upon those particular details.  But first and

19     foremost, I would like us to try and identify this Vojvoda whom you

20     mentioned several times who beat you, who killed (redacted), beat

21     (redacted).  And as far as I understand you, he appeared on several

22     occasions and ill-treated both you and the other detainees.

23             Does the name Himzo Tulic ring a bell?

24        A.   I don't know him personally, but I've heard of him.

25        Q.   Do you know that he was a well-known architect in Zvornik before

Page 5439

 1     the war?

 2        A.   No, I don't.  I don't know the person.  I just heard the name.

 3     The name rings a bell.

 4        Q.   Himzo Tulic is -- is very important because he published a very

 5     important book about crimes over the Zvornik Muslims, and the name is the

 6     Sirat Cuprija of Zvornik, the title of that book.  He provides a photo of

 7     a man, so at the beginning of this cross-examination I would like to ask

 8     you to look at the photo.  The man is depicted from the back, but you can

 9     see a pony-tail.  You can see long hair and a pony-tail.  Could you

10     please look at the photo and tell me, if you can, whether that might be

11     the Vojvoda whom you mentioned on several occasions.

12             THE ACCUSED: [Interpretation] This is the photo that I would like

13     you to show the witness.  Could you put it on the ELMO, please.  Can this

14     be blown up and can it be separated from the rest of the book?  Can you

15     please put it in the centre of the ELMO screen, please.

16             THE WITNESS: [Interpretation] I don't know this man.  I don't

17     think it is that man, because his hair was longer.  As far as I can tell,

18     this man is depicted from the back.  He's wearing a pair of jeans as far

19     as I can tell.

20             I don't think this is a pony-tail.  This is probably the end of a

21     bandanna.  It might be a pony-tail but there was more hair there.  That

22     person sported a beard, not long, maybe two centimetres, and he also had

23     hair not too long but he did sport a pony-tail, and he wore different

24     clothes.  So I wouldn't say that the -- this is the man, that this photo

25     depicts the same man.

Page 5440

 1             MR. SESELJ: [Interpretation]

 2        Q.   Very well.  Can I have the book back.  Himzo got hold of this

 3     photo in one way or another, I don't know how but this is the only photo

 4     that I have and that's why I wanted to show it to you.

 5             Mr. VS-1015, you provided several statements.  Isn't that

 6     correct?

 7        A.   Yes, I did.

 8        Q.   How many statements did you provide to the Muslim authorities

 9     after you were exchanged from Batkovic and went to Tuzla?

10        A.   I did not give any statements to the Muslim authorities at all.

11     The only statement that I gave was given to the Tribunal in 1996, or to

12     be more precise, in July or maybe in June, and the Tribunal has that

13     statement of mine.

14        Q.   Did somebody from the state commission for the collection of

15     facts about war crimes from Tuzla ever spoke to you -- ever speak to you?

16        A.   From Tuzla?  I don't remember.  If somebody had an informal

17     conversation maybe, but I never signed any statements.  I never provided

18     any formal statements.

19             THE ACCUSED: [Interpretation] Can Exhibit number 00218172 be

20     placed on our internal screen that only us in the courtroom can see.  You

21     don't have the document?

22             MR. MARCUSSEN:  As I hope the accused is showing a goodwill

23     effort to let the witness go, I shall be quick and provide a copy of the

24     statement, and maybe a translation.

25             THE ACCUSED: [Interpretation] The witness does not need the

Page 5441

 1     translation, but I suppose the Trial Chamber might find the translation

 2     useful, I suppose.  This is our internal screen, our internal ELMO.

 3             Could the Serbian version be placed on the ELMO, because I am not

 4     sure that this witness speaks English.  Is there a Serbian version?  I

 5     beg your pardon.  Put the Serbian version on the screen, please.

 6             MR. MARCUSSEN:  Maybe I can have the English version back.  We

 7     can put the B/C/S version on the ELMO.  I think that's what the witness

 8     needs to look at.

 9             We need another copy for you, but we'll try to get it.

10             MR. SESELJ: [Interpretation]

11        Q.   Sir, do you now remember this statement of yours?

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 5442

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16                           [Private session]

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 5443

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16                           [Open session]

17             THE REGISTRAR:  Your Honours, we're back in open session.

18             MR. SESELJ: [Interpretation].

19        Q.   Mr. VS-1015, on the 22nd December 1993, not long after your

20     arrival in Tuzla from Batkovic, you provided a statement to the state

21     commission for the collection of facts about war crimes in Tuzla; is that

22     correct?

23        A.   Now I can see that it says Tuzla here, but I don't remember that

24     I provided a statement to anybody at that moment.  Maybe -- we were asked

25     questions just in passing.  I don't see that I signed this, nor do I

Page 5444

 1     remember having provided a statement.  Whichever way you look at it, it

 2     may be the case.  Everything is possible, but I don't remember.

 3        Q.   This statement is signed though.  When the Prosecutor's office

 4     made the photocopy, the photocopy does not include the statement, but it

 5     says here who took the statement, who took the notes of the statement,

 6     and who provided the statement, who provided the statement and signed it,

 7     although the signatures are not clear.  So you did sign the statement,

 8     did you not?

 9        A.   I wouldn't know.

10        Q.   Since you say you don't know I understand that after such a long

11     time and so many years the memory may fail and fade.  It can happen to

12     the best of us, to the younger who were not exposed to such huge trauma,

13     but this statement is important because your memory was still fresh and

14     you recounted what had happened.

15             I believe everything that you stated in this statement, and I

16     could almost sign it myself as being truthful.  Do you believe me that I

17     myself could sign this statement as truthful?

18        A.   I really don't know what it says in here.  I don't know.  It's up

19     to you whether you would want to sign it or not.  It's up to you,

20     Mr. Seselj, but you have not been in a position of a man whose heart had

21     stopped, who no longer trusts even his own eyes.  I suppose that you

22     might be able to do that.  I don't know.

23        Q.   Very well, then.  Can we then look at the whole statement?  Are

24     you ready to read the statement or do you want me to do it for you?  We

25     will go one passage after another, and I will ask you questions.

Page 5445

 1        A.   Very well.

 2        Q.   Maybe you want to read it, because it is your statement, or do

 3     you want me to read it for you?

 4        A.   You go on reading.  Maybe your sight is better.

 5        Q.   If my sight was better I wouldn't be wearing glasses, but I

 6     understand that it has been an exciting day for you so I'll read instead

 7     of you.  The first passage, it says -- these are your particulars.  The

 8     -- General Hoblik [phoen] is not going to see that and it says here that

 9     you want to provide the following statement, and I am going to skip all

10     those things that might identify you, which is the place where you hail

11     from, and certain names.  I will skip those.  When I come to them I will

12     bear that in mind.  I will be careful because I don't want to go back

13     into private session.

14             You stated:  "On the 8th of April Zvornik was occupied, and soon

15     after that on the streets of Zvornik the Serb militia appeared on the

16     streets of Zvornik, the Serb army, and the Chetniks as well.  At that

17     time I was -- I was employed," and I will not mention the name of the

18     company where you worked, "and from that date, the 15th of April, I

19     continued working," and now it says where you worked.  "However, when I

20     and the other Muslims that worked in (redacted) arrived at work, we were

21     addressed by a person," whose name you mention in this statement, "from a

22     neighbouring municipality near Zvornik who worked in the personnel office

23     of that company, and on that occasion he told us that we, the Muslims,

24     could no longer work for security reasons.  From that day on, we no

25     longer worked in that company."

Page 5446

 1             Would this be correct as far as you remember?

 2        A.   Yes.  We came to the gate and they told us there and then that

 3     for security reasons, for our own security, we had to go back, and from

 4     then on we did not work.

 5        Q.   Please, can you tell me when you say Chetniks, who did you refer

 6     to?  Who do you have in mind?

 7        A.   I had in mind people who looked like that.  Not all the Serbs are

 8     Chetniks.  Not even all the Serbs waged the war.  Not all Serbs were

 9     criminals.  I am referring to these men who called themselves Chetniks at

10     the time when Zvornik fell.

11             I have to tell you I was at home, and I did not have any other TV

12     channels other than the Belgrade TV, and on TV -- either on Belgrade TV

13     or Novi Sad TV, one could see people in Zvornik passing through Zvornik

14     sporting those insignia and cockades and so on and so forth.  And this is

15     what I mean when I say Chetniks, and that's how I explain it.

16        Q.   Among the Chetniks were there also locals from Zvornik and the

17     surroundings or just those who had arrived from the other bank of the

18     Drina River?

19        A.   They had arrived from the other bank of the Drina.  There were

20     also some locals but fewer of them.  To -- on the eve of my arrest some

21     people came in a Lada with the inscription "Chetnik" on the car, on the

22     door of the car, and there were loudspeakers mounted on that car.  They

23     were playing songs about General Draza Mihajlovic and about Serbia and

24     typical Serbian songs, and there were insignia all over the place, and

25     that's whom I called Chetniks.

Page 5447

 1        Q.   So whoever sang Chetnik songs you thought was a Chetnik.  Whoever

 2     wore a cockade, you thought that person was a Chetnik.

 3        A.   Well, more or less, yes, that's how it was.  Because when I went

 4     to school in the former Yugoslavia, I learned that's what identified

 5     Chetniks.  I can tell you that there were people who beat us up, who

 6     stood by the side, who may have been Chetniks.  Not all of them beat us.

 7        Q.   Please tell me how you draw a distinction between the Serb army

 8     and Chetniks.

 9        A.   Well, as for the Serb army, they wore camouflage uniforms of

10     various types, but they did not wear those insignia, for example, the

11     double-headed eagle or similar, even older insignia.  I thought these

12     were older forms of the insignia.  And they did their army service

13     normally and they didn't wear the subara caps.  They didn't wear cockades

14     on their subaras.  And in the Ekonomija, this Vojvoda, when he came in to

15     let us go to work, this same man was there but he put on a subara hat.  I

16     know what these subara hats look like.  They were very comfortable.  So

17     other people used to wear them before, the Muslims as well.  And it was

18     on his head, and he had this old-fashioned Serbian sort of clothing, a

19     vest.

20        Q.   Can you describe what a cockade looks like?

21        A.   Well, as I observed, and according to what other people also

22     said, a cockade has some parts at the sides which are like wings.

23     There's a two-headed eagle, and one sort had the sword across.  Another

24     sort had the four letters S.  I don't know which is more correct.  I

25     think it's the swords.

Page 5448

 1        Q.   Do you know that that cockade is today the official coat of arms

 2     of Serbia and that it's on all Serb uniforms, whether military or police

 3     or firefighters' uniforms, on all uniforms?  Are you aware of that?

 4        A.   I know they have something like that, but I haven't really looked

 5     at it carefully.  I don't know that it was transferred from there to the

 6     coat of arms.  That's a matter for Serbia.

 7        Q.   Well, what did the Serbian army look like?  What sort of Serbian

 8     army was it that was separate from the Chetniks?

 9        A.   Well, as I said, but the sound is very loud in my ears when you

10     speak so loudly in the microphone.  The local army around Zvornik, the

11     local people, they were dressed more normally when groups went from my

12     place to attack Zvornik in buses and so on and so forth, in trucks, and

13     so on, and the ones that came from Serbia I assert with full

14     responsibility, and these people came from Serbia, and it turned out that

15     these people are now being tried, they came from Serbia, from Kraljevo.

16             Well, to what extent they were your subordinates I really doesn't

17     know because at that time I didn't know you.  Now I see you and I can

18     look you in the eyes, but that's just by chance.  But if what they said

19     is correct, and I assert with full liability that this Captain Niski,

20     after the incident when that man forced us to eat some sort of baked

21     bread and when he chased that man and those guards away to stop them

22     beating us, I'm telling you the truth to the very best of my ability.  I

23     do apologise if I have made any mistakes, but he said, "Boris, let these

24     people go.  They have been processed and they are working.  I am fighting

25     in Seselj's sabotage units."  I'm looking you right in the eye.  I'm not

Page 5449

 1     lying.  "I don't know who else I'm fighting for."

 2             Whether he said that to that man because he was upset because we

 3     were supposed to be working in the Ciglana first of all, and as I was

 4     able to see the director of Ciglana and Niski cooperated with respect to

 5     work, so when they beat us they said there should be a few people -- or

 6     they said there were a few people unable to work, unfit to work every day

 7     because they had been beaten up.  So when four of them fled, when what

 8  happened in Cirak happened and the four ran away from -- (redacted) we stood

 9     there until 3.00 or 4.00 in the morning waiting to be shot, wondering

10     whether we'd end up alive or dead.  And then they said, "Be careful.

11     Watch out what you're doing."  Niski said that.  And if that's what it

12     says here that he said, and I assert that he did, I would like to meet

13     this Captain Niski.

14             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen.

15             MR. MARCUSSEN:  Just very briefly.  I believe that the -- that

16     the place where the witness worked was mentioned inadvertently when the

17     accused read out from the statement he read out from before.  I have

18     different page numbers, but I have -- the reference I have is page 26,

19     line 4, but it might be a different page, but I think the registrar has

20     identified the right page number.  But it's just that one word.

21             JUDGE ANTONETTI: [Interpretation] It's been done.  It's been

22     done.

23             MR. MARCUSSEN:  Thank you.

24             JUDGE ANTONETTI: [Interpretation] Please resume, Witness.

25             MR. SESELJ: [Interpretation].

Page 5450

 1        Q.   Mr. VS-1015, please respond more briefly, because we still

 2     haven't arrived at the situation you've been speaking about extensively,

 3     and I didn't want to interrupt you.  I don't think I ought to interrupt

 4     you at all, but I do wish to ask you to respond more briefly so that we

 5     can go through everything.

 6             Please tell me, in Zvornik, on the 8th of April, was the JNA

 7     there?

 8        A.   I can't say that because I wasn't there.  My village was some ten

 9     kilometres away from Zvornik, so I couldn't be in Zvornik because I was

10     in Serbia on that day.

11        Q.   So on the 8th of April you weren't in Zvornik at all.  You only

12     heard from someone that the Serb militia, the Serb army, and the Chetniks

13     were there.

14        A.   Yes.

15        Q.   Very well.  I needed confirmation of that.  And did you see any

16     tank units of the JNA around Zvornik?

17        A.   Maybe you remember this well:  There were tanks passing along the

18     main road in front of my house in the direction of Zvornik.  I don't

19     recall the date exactly, but it was before Zvornik fell.  It was the

20     so-called Yugoslav Army.  They were ostensibly Yugoslav, but I saw

21     privately own trucks with Ruma licence plates, and they were soldiers and

22     reservists.  They were all mixed up and they passed through on their way

23     to Zvornik.

24             And when I was taken away to be detained in Celopek, in front of

25     the Celopek cultural club there were hedgehogs.  There was a hedgehog

Page 5451

 1     barricade.  And there were about eight tanks and a self-propelled vehicle

 2     and an APC parked in that courtyard.

 3        Q.   Now I'm going to give you so some precise data and you'll confirm

 4     whether it's correct or not, but let me draw your attention before that

 5     to something else.

 6             I assume you did your regular military service, and even if you

 7     didn't, you must know that in case of an imminent threat of war or a

 8     state of war the JNA has the right to temporarily requisition equipment

 9     from companies, enterprises, and so on, and they were able to requisition

10     a certain number of trucks.

11        A.   Yes, I'm aware of that.

12        Q.   According to my information as early as the 28th of February,

13     1992, a tank battalion, which was part of a whole tank brigade which

14     moved to the area of the Zvornik Corps from the north of Croatia or from

15     Slovenia, maybe from Crtnica [phoen], but I'm not sure, and one battalion

16     of this tank brigade was deployed in Zvornik.  One tank company around

17     the bridge of Karakaj, one company in the village of Celopek, and one

18     company in the village of Pilica.  What do you think about this?  Do you

19     think that this piece of information is correct?

20        A.   Well, these companies which you say that arrived from Croatia,

21     that is correct.  And that they were deployed in the courtyard of the

22     Celopek cultural centre, I don't deny that because -- well, I didn't see

23     what soldiers were there, whether they were young or not.  But in that

24     march, which may have been before or later, those who went from the

25     direction of Bijeljina towards Zvornik there were tanks there where I

Page 5452

 1     know there were young soldiers.  But let me tell you, at that time

 2     whether there were conscripts of 30 or 40 years of age serving in the

 3     JNA.  I'm asking you that.

 4             JUDGE ANTONETTI: [Interpretation] We need to have a break because

 5     we've been sitting for an hour and a half.  We'll now have a 20-minute

 6     break, and we'll resume in 20 minutes.

 7                           --- Recess taken at 11.32 a.m.

 8                           --- On resuming at 11.56 a.m.

 9             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you have the floor.

10             THE INTERPRETER:  Microphone, please.  Microphone.

11             MR. SESELJ: [Interpretation]

12        Q.   We finished off before the break with a question you asked me,

13     where these elderly people of 30, 35, 40, how come they were in the JNA.

14     That's what you asked me.  And let me give you an answer.  I'm going to

15     answer you by posing another question, and it's this:  Do you know that

16     throughout 1991 and the beginning of 1992, from time to time the JNA

17     conducted a mobilisation of its reserve force on the territory of almost

18     the whole of Bosnia-Herzegovina?

19        A.   No.  There were no barracks where I lived, where I was, so I

20     don't know about that.

21        Q.   You don't know about these mobilisation call-ups from time to

22     time?  And the fact is that most of the Serbs responded to the call-up,

23     whereas the Muslims tried to avoid it.

24        A.   Well, I don't know.  Nobody called us up.  Whether anybody called

25     the Serbs in our parts, I don't know.  All I did was ask you a question.

Page 5453

 1     When the column was passing by there were people who were between the

 2     ages of 30 and 40, maybe even older in this mixed column.  Now, when they

 3     were mobilised and who mobilised and all the rest of it, I don't know.

 4     Perhaps there was a law that governed this in the JNA but I didn't know

 5     about it at the time.

 6        Q.   Did you do your military service yourself?

 7        A.   Yes, I did.

 8        Q.   After that did you ever go for any additional military training?

 9        A.   No.

10        Q.   All right.  Fine.  If you don't any military training, you

11     probably don't know how the JNA functioned and this call-up of

12     reservists, but if the JNA really did call up its reservists, isn't it

13     quite logical that in the same JNA column you would have young soldiers

14     who were doing their regular military service and the reservists who had

15     been called up and were slightly older?  That's quite logical.

16        A.   When I said that I saw these people ranging between these ages.

17     Now, what is logical is up to the Court, what they're going to accept and

18     that's all I can say.  I saw the people.  Those were the people.  Now,

19     whether they should have been there or not, I don't know.

20        Q.   All right.  Can we have a look at the document we were looking at

21     a moment ago.  Is it still on our screens?  I don't seem to have it up on

22     e-court.

23             Tell me what button to press, please.  It doesn't seem to be

24     here.  Ah, I can see it now.  Yes.  Thank you.

25             Now, let's look at the third paragraph of that statement of

Page 5454

 1     yours, and I will read it out slowly and then we're going to discuss

 2     certain issues that are of interest there.

 3              "Up until the 7th of May, I was at my home," and then you

 4     mention what village, "when a Chetniks patrol came in front of our house,

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16        Q.   Tell me who you recognised in what you call a Chetnik patrol.

17        A.   I first have to state this:  It says Chetnik patrol there.  Now,

18     if I signed it, I don't usually use -- well, I never mentioned this name

19     "Chetniks" throughout my life, but it seems to say that there.  It's been

20     written down there.  Now, whether he was directly a Chetnik or not,

21     anyway, he was a Serb from my village, and his name was --

22        Q.   You don't have to give us his name.  Now, how many members did

23     the patrol number?

24        A.   There were three of them.

25        Q.   Were they all Serbs from your own place?

Page 5455

 1        A.   No.

 2        Q.   One was from your village, the rest went; is that right?

 3        A.   Yes.

 4        Q.   Now, an additional question.  Was it usual on the Muslim side for

 5     almost all the soldiers in regular conversations to refer to Chetniks and

 6     Chetnik forces and the JNA as a Serbo-Chetnik army and so on and so

 7     forth?

 8        A.   Well, I don't know.  I said that I lived in that place where

 9     there was a mixed population and we got on well as I said, but there was

10     a certain distance in relationships afterwards.  I don't know who behaved

11     like that.  Maybe in places where there was just a single ethnicity, Serb

12     areas or whatever.

13        Q.   I don't think you have to justify yourself for saying Chetnik

14     patrol.  That's nothing rude or insulting.  It's rude if somebody is --

15     it's bad if somebody is a criminal, but it's a nice Serbian tradition

16     which Serbs are proud of, although some people tend and want to denigrate

17     it.  But you don't have to justify yourself for using that expression.

18        A.   I'm not justifying myself.  You said yourself, and I said at the

19     beginning, that not all people are the same.  Not all people are

20     Chetniks, and that not all people committed evil deeds.  But my heart

21     does hurt when I think of those who perpetrated crimes, especially crimes

22     against myself and my family.

23        Q.   Let's move on through the text.  You say that "they loaded us up

24     onto a van and drove us to Celopek where they put us up; i.e., detained

25     us, on the premises of the Ekonomija or the Agricultural Cooperative

Page 5456

 1     Celopek.

 2             Upon entering the room I immediately noticed traces of blood

 3     which led me to conclude that there were some citizens who were detained

 4     in that same room before us and that they had been physically abused

 5     there.  The next day we were moved from this room to another room, which

 6     was a little bigger with a concrete floor, and there were 19 more

 7     civilians inside it.  So that if you add us three, that made a total of

 8     22 people in that one room.  Immediately after that, the Chetniks came

 9     into this room.  I don't know their names or surnames, but they were all

10     from Serbia.  Most of them from Kraljevo, Valjevo, and Loznica, and they

11     wore camouflage uniforms with insignia of the White Eagles.  This

12     insignia was round, in the shape of a badge with the two-headed eagle,

13     and they had white bandannas over their heads.  These Chetniks demanded

14     that while they were filming all this with a camera and with" --

15        A.   Just a moment.  Mr. Seselj, you made a mistake in reading here.

16     The white bandannas or bandages or whatever.

17        Q.   I didn't make a mistake.  I thought it was a printing error.  The

18     typist that typed this out.

19        A.   But you should read what it says.

20        Q.   It said:  "They had white bandannas, povezi," and then there's a

21     typing mistake there, over their heads."

22             So all I did was to skip over these superfluous words which are

23     quite obviously a typo.  Do you agree with that?

24        A.   Yes.

25        Q.   So they had these white bandannas over their heads or scarves

Page 5457

 1     over their heads.  That's the substance of it.  Somebody else wrote this,

 2     not you.  I assume that a typist typed it out.

 3             Now it goes on to say the following:  "These Chetniks demanded

 4     from us that while they filmed us with cameras and to say how we were

 5     members of Alija's Warriors and that we fought at Kula Grad and that we

 6     had been captured as combatants, although we were arrested in our homes

 7     as civilians without weapons.  And that's what we wanted to stress.  We

 8     wanted to stress the truth.  But these Chetniks forbade us to say that."

 9             Is that what you said in your statement?  Is there anything

10     that's superfluous there?

11        A.   Well, that's it.  That's what it was.  And if I say that, then

12     that's how it was.  I don't remember exactly or the exact words, but

13     that's how it was.

14             It says there that all of them, everyone.  They didn't all wear

15     these white scarves over their heads because they would be Arabs and, I

16     apologise for saying that, they would be Arabs if they looked like that.

17        Q.   Well, they're not wearing bandages.  They're wearing these white

18     scarves as a component part of the Arabic national costume.  It can be

19     white, black and white, or red and white.

20        A.   Well, all right, but that's what I said, because as some

21     people -- individuals wore that on their heads, not everyone.

22        Q.   All right.  Can we go on to page 2, because you're not

23     questioning anything there.  So let's start at the beginning there.

24              "In Celopek," that is to say -- and I can't read what it says

25     there.  Can you help me out here?  There's a word here that's not quite

Page 5458

 1     clear.  "In Celopek or the agriculture farm," is that what it says?

 2        A.   Yes, I think so.

 3        Q.    "Together with the others I was detained from the 7th of May to

 4     the 12th of May, 1992.  I was detained.  During all that time, I was

 5     physically abused, and I also personally saw," and then you say who the

 6     two other people are who were also -- who were also abused.  And now I

 7     come to the most important part of your statement:  "Namely, one day you

 8     go on to say, that is, on the 12th of May in the morning, the Chetnik

 9     whom they called Vojvoda and his surname was Repic, and I don't know his

10     first name, together with another Chetnik called Zoks took out," and then

11     they say who they took out and beat.

12             So as far as this Vojvoda is concerned, and this Vojvoda is

13     mentioned in your other statements as well, in this freshest of

14     statements you say that his surname was Repic.  Isn't that right?  So you

15     couldn't have thought that name up, conjured it up.

16        A.   I think that was -- well, there were stories going round what he

17     looked like, so that Repic might be a mistake, meaning Repic -- Repic

18     like a little pony-tail.  I've never actually heard anybody call somebody

19     Repic.  So it was a Vojvoda with this pony-tail, rep, rep being

20     pony-tail, with this man Zoks.  So maybe I said the diminutive of "rep"

21     which is "repic" meaning a small pony-tail.

22        Q.   You signed statement and you state that his surname was Repic,

23     and there's no typo there.  It says:  "His surname is Repic."  And I

24     claim that this is not just by chance because you knew for certain that

25     they called him Repic.  Isn't that right, Mr. VS-1015?

Page 5459

 1        A.   No, that's not quite right, because at that time and in all that

 2     chaos when I gave the statement can you imagine the state I was in and

 3     all the rest of it?  So a mistake could happen, could occur.

 4        Q.   Now, bearing in mind your state and everything you experienced

 5     and lived through, quite possibly you forgot something but that you

 6     fabricated the name of this Chetnik Vojvoda, his surname being Repic.  I

 7     don't believe that.  You couldn't have thought that up.

 8             You said it the way you remembered it.  Isn't that right?

 9        A.   Well, all right.  Maybe that's how it was too.  Maybe somebody

10     talked to us and then the name Repic came up.  So that's how I came to

11     say it.  But once again, I would like to say specifically I can't say I

12     knew it was Repic, that his actual name was Repic 100 per cent.

13        Q.   You didn't know this 100 per cent because Repic is not his

14     surname but his nickname was indeed Repic.  So you heard some other

15     people refer to him and call him by this nickname Repic.  Isn't that

16     right?

17        A.   Well, it could be.

18        Q.   His surname is not Repic.  His name is Dusan Vuckovic, and his

19     nickname was Repic or Pony-tail, and he belonged to the Yellow Wasp

20     formation.  Have you heard about them?

21        A.   Not then.  I heard about them later on, quite a long time after

22     the war, because I didn't stay in Bosnia.  I went off.

23        Q.   And did you hear that already in 1993 in Serbia a group of people

24     were taken to trial for crimes committed against Muslim prisoners and

25     civilians in Zvornik?

Page 5460

 1        A.   Yes.

 2        Q.   Did you hear that one of them was called Dusan Vuckovic and that

 3     his nickname was Repic?

 4        A.   Yes.

 5        Q.   Did you hear that at the time he was convicted to a prison term

 6     and that he spent time in prison doing his sentence?

 7        A.   Yes.

 8        Q.   Did you hear that he was arrested again for other crimes for

 9     which -- which were not known in Serbia in 1993, so he was supposed to be

10     tried again with another group that was being tried in Belgrade?

11        A.   I knew that -- or, rather, I heard about it.

12        Q.   And did you hear that about two years ago this same man, Dusan

13     Vuckovic nicknamed Repic, committed suicide in prison?  I think he hanged

14     himself, anyway he committed suicide.

15        A.   I heard he committed suicide, and you've just told me that he

16     hanged himself.  So, well, if he did what he did, then that's sort of

17     God's retribution.

18        Q.   Well, I agree -- I agree that there is God's retribution and

19     punishment for any crimes that you do in life.  Anyway, we've identified

20     this man and you've heard of him even at the time that you were tortured

21     in Zvornik when you were beaten up and when you had a bad time of it, and

22     you heard after the war that this man was tried and that he committed

23     suicide in prison.

24             Now you've confirmed that you heard all about that, and then

25     somebody suggested to you that in your later statements, and in talking

Page 5461

 1     to The Hague OTP, that you shouldn't mention this surname or nickname

 2     Repic at all.

 3        A.   That's not true.

 4             THE INTERPRETER:  Could the speakers kindly slow down again,

 5     thank you.

 6             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen.

 7             MR. MARCUSSEN:  I do not believe it was the witness's evidence

 8     that he heard the name Repic while he was being tortured.  I don't know

 9     if it's a translation problem.  The witness, I believe, stated that he

10     had not heard the name Repic used at the time he was in the camp, but he

11     only learned it later.  He did not hear it while he were in the camp.  So

12     the question -- the premise on the question is incorrect.

13             THE ACCUSED: [Interpretation] The witness challenged that and

14     denied it, and then he confirmed that he heard people call this man

15     Repic, and I assume that it was properly recorded in the transcript.

16     There's no reason.

17             Well, anyway, everything has been videotaped and so on, so you

18     can check it out and I don't suppose you'll delete this from the tapes.

19             MR. SESELJ: [Interpretation]

20        Q.   Mr. VS-1015, do you know what AID is, AID?

21        A.   Could you repeat that, please?

22        Q.   AID, AID, it's an abbreviation for an organisation of Muslim

23     authorities.

24        A.   I don't know.  This is the first time I hear of it.

25        Q.   The official title is The Agency for Information and

Page 5462

 1     Documentation, AID.  Have you ever heard of the existence of that agency

 2     under Muslim controlled territory in Bosnia and Herzegovina?

 3        A.   No.  I was in detention.  I was incarcerated, and for a long

 4     time, almost 15 months, and I ended up in Batkovici, and then I was

 5     transferred for a few months to the federation and from there I went to

 6     another place, so I have been excluded from all those events in

 7     Bosnia-Herzegovina.

 8        Q.   How long did you live in the federation before you went abroad,

 9     to live abroad?

10        A.   Well, that was from the 21st of July, 1993, when I was exchanged,

11     until the 1st of May, 1994, when I left.

12        Q.   Did any other representatives of the Muslim authorities call you

13     in for interviews, the police, state officials, the same thing, apart

14     from the state commission that you couldn't remember the name of?

15        A.   Well, I don't remember but I don't believe so because I was there

16     for a short period of time.

17        Q.   But you couldn't even remember the representative of the state

18     commission for collecting facts about war crimes you forgot that too, and

19     that was an important moment in your life because it was the first time

20     that you told your entire story to everyone, what happened to you and

21     what happened to the other Muslims who were together with you while you

22     were incarcerated in the area of Zvornik.

23        A.   Is that the document?

24        Q.   That is the document, but you didn't give any statement before

25     this statement.

Page 5463

 1        A.   Well, what are you challenging?  You have the document there.

 2     There's everything that I said.  Now, if I forgot something after so many

 3     years -- now, Mr. Seselj, can you tell me what you did -- you had for

 4     breakfast seven days ago?

 5        Q.   Yes, I can.

 6        A.   What did you have?

 7        Q.   I had muesli with calcium milk and artificial sugar.

 8        A.   Well, in those units you know what you have for breakfast.

 9        Q.   Well, what units?

10        A.   Well, where you've been put up, where you're accommodated, that

11     unit there.  I apologise but that's common knowledge I assume.  And all I

12     wanted to say, Mr. Seselj, that it's been 17 years.  If somebody were to

13     say -- give you a date or something like that, well, you forget.  Can you

14     imagine what a long time that is?

15        Q.   Mr. VS-1015, what we -- the food we're given in Scheveningen is

16     probably not much better than the food you were given when you were

17     incarcerated.  Perhaps it's just worse, and we're forced to make our

18     own -- prepare our own food.

19        A.   Well, I'm sorry.

20        Q.   Well, I'm sorry for everything you lived through and experienced

21     and I said that I consider that everything you told the Muslim

22     authorities is the truth because it was to the best of your recollections

23     when your recollections were fresh.  The problem is that other people

24     added on to your recollections later on with things that you did not see

25     and experience and then through their suggestive methods they made you --

Page 5464

 1     made you say those things, because your memory must have been fresher

 2     five or six months later, whereas now we have much more detailed

 3     recollections suddenly 15 years on which do not correspond to the truth.

 4     And somebody suggested to you to keep quiet about this surname or

 5     nickname Repic.  That's what I wanted to point out to you.

 6        A.   I say with full responsibility that that's not what I wanted I

 7     didn't want to keep quiet about that.  Now how that happened, how that

 8     came too pass, I really can't say.  I can't remember all the details and

 9     that was not my wish.  And I say that full responsibility before this

10     Trial Chamber that I didn't do so intentionally that nobody prevailed

11     upon me to do that.

12        Q.   All right.  I don't want to continue arguing.  I have every

13     respect for the suffering you went through whether you believe me or not,

14     and that is why I don't want to treat you as I would treat perhaps some

15     other witness on the Serb side for whom I had ascertained that he was

16     given false testimony.  So I have every sympathy for the troubles you

17     went through, but do you now confirm that somebody really did refer to

18     this man and call him Repic?  Have I refreshed your memory now, managed

19     to jog it?

20        A.   Well, I don't know.  I say I don't know.  I don't know what

21     happened at the time.  Anyway this man Repic appeared through the stories

22     and what people said and that was how it was expressed in that case.

23             Now, they did address him as Vojvoda, this person Repic.  Zoks

24     referred to him and called him Vojvoda.  He said Vojvoda, sir.  Then he

25     went and to open the door to him, and the soldiers standing next to him,

Page 5465

 1     he said, "The Vojvoda wants to tell you that if you go and work, you'll

 2     stay alive.  He said you have to go to work.  You have to go and work."

 3     And he said, "You can't eat bread free unless you do some work."  And the

 4     word used was leb, l-e-b.  That's the dialect that was used.  I know that

 5     is used in Serbia because in Bosnia-Herzegovina we don't use that same

 6     word.  We say hljeb meaning bread or kruh meaning bread.

 7        Q.   Well, I belive what you're saying.  I'm not questioning that.

 8     But I don't think you understand why your identification of the man is

 9     important, the man called Repic.  It is important to me because The Hague

10     OTP, along with other witnesses, wishes to move this identity to some

11     other person.

12             Now, I agree that this man introduced himself as Vojvoda, and the

13     gang around him did address him as Vojvoda, but he wasn't any Vojvoda,

14     any role Vojvoda.  Do you believe me when I tell you that?  He just liked

15     to call himself Vojvoda, self proclaimed, and he had a name and he had

16     this nickname of Repic.

17        A.   Can I interrupt you?

18        Q.   Go ahead.

19        A.   You've just reminded me of is something.  He wasn't important as

20     far as you're concerned.  I believe you when you say that.  But he was

21     important as far as we were concerned and here's why:  When before

22     that -- when the soldier entered on that 12th into the room and said

23     "Kneel down with your forehead to the floor, on the concrete floor, with

24     your hands behind your backs and you're to wait until Vojvoda makes

25     the -- the Vojvoda makes decision."  And when he entered he said, "And

Page 5466

 1     what are you doing?  Why are you bowing down?  This is not a mosque."

 2     That means that at that point Vojvoda, the so-called Vojvoda as you said,

 3     was even greater than the Vojvoda you would call a Vojvoda whereas you're

 4     denying that he was a real Vojvoda but a false Vojvoda.  But it didn't

 5     matter to us whether he was true or false.  If he did what he did, that's

 6     the name we remembered him by.

 7        Q.   So we're not disputing anything you and I.  I completely agree

 8     with what you say and the crimes that you've described resemble the kind

 9     of things that this person really did do, and his brother testified about

10     that as well, and his brother distanced himself from him during the legal

11     proceedings.  So I'm not questioning the veracity of your story at all.

12     All I'm interested is establishing this identification, identity, because

13     some other witnesses here along with support from the Prosecution are

14     trying to change his identity to accuse somebody else falsely of being

15     Repic.  So that's why I'm insisting on this point.  That's why it's

16     important for me, and that's why we can move on and see what happened to

17     you next.

18             MR. MARCUSSEN:  Well if we move on then that's fine, but I do

19     take issue with the allegation that the Prosecution is trying to

20     influence --

21             THE ACCUSED: [Interpretation] I'm not receiving interpretation.

22     No interpretation at all.

23             JUDGE ANTONETTI: [Interpretation] The Prosecutor was objecting

24     and saying that the Prosecution was not in any way trying to influence

25     the witness.  This is what Mr. Marcussen has told us.

Page 5467

 1             Please proceed.

 2             MR. SESELJ: [Interpretation]

 3        Q.   So we've arrived at this fact then that Repic and this Chetnik

 4     named Zoks took you out and two other men, people, two other Muslims.

 5     That's how I'm going to refer to them, because they were Muslims, not to

 6     have to mention their names.

 7             MR. MARCUSSEN:  It does not reflect the witness evidence.  The

 8     witness said a person named -- referred to as Vojvoda was taken out --

 9     took them out together with another person.  The witness has not

10     confirmed that the name of the person who he refers to Vojvoda is Repic.

11     It's the accused who continues to make that link.  The witness has been

12     quite clear about what his evidence is.  So the question should be put in

13     a way which correctly reflects what the witness's evidence is.

14             JUDGE ANTONETTI: [Interpretation] Mr. Seselj.

15             THE ACCUSED: [Interpretation] These are the witness's words, here

16     they are:  "A Chetniks called Vojvoda, his surname Repic, I do not know

17     his first name, together with the Chetnik that was called Zoks took out

18     both the two other Muslims in front of the building and beat them with

19     various heavy items, heavy objects."  That's what the witness said,

20     "Vojvoda whose surname was Repic."  And that's what it says here and it's

21     quite clear from this document.  So I don't know what English translation

22     you have there.

23             JUDGE ANTONETTI: [Interpretation] Yes, Mr. Marcussen.

24             MR. MARCUSSEN:  Then the question should be put that this is --

25     this is now being quoted from the 1993 statement.  The witness has

Page 5468

 1     explained extensively about this, and his evidence today is different.

 2     So that's where the confusion come in.  When the statement from 1993

 3     which the witness is not standing by today is being cited as his evidence

 4     today confusion arise and that's my point.

 5             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, just a minute.

 6     You're just saying that the witness does not stand by what he said in

 7     1993.  This is not what I understood.  You are interpreting it this way.

 8     The question remains as follows:  Who is this Vojvoda?  In 1993, the

 9     witness says that he was called Repic.  This is what we have.  The

10     accused is telling us that this man Repic is in fact Dusan Vuckovic, who

11     was tried and convicted for that.

12             This is what I understood, but maybe I misunderstood.

13             MR. MARCUSSEN:  Maybe we should not get into submissions in front

14     of the witness if we want to clarify this with him later, but I just say

15     that I -- I don't have the same understanding of the witness evidence.

16     Maybe if there's time for redirect I can also try to clean it up there.

17             JUDGE ANTONETTI: [Interpretation] Please proceed.

18             THE ACCUSED: [Interpretation] I must admit that in this courtroom

19     we've had Prosecutor's who had a much better understanding of things, but

20     before I started I said that I was coming back to this document.  This

21     has to be recorded in the transcript, if not, then it has been video

22     recorded.  I said we're coming back to the documents.  I tried to cut a

23     long story short and confirm what he had already confirmed and we move

24     on.

25             MR. SESELJ: [Interpretation]

Page 5469

 1        Q.   In other words, a Chetnik whom they called Vojvoda, whose surname

 2     was Repic, and whose first name I didn't know, together with another

 3     Chetnik called Zoks took out this man," I don't want to mention his name,

 4     "and in front of the building they beat him with various hard objects.

 5     When they were tired, they put him back into the room."  And this

 6     corresponds to what really happened, doesn't it, sir?

 7        A.   Yes.

 8        Q.    "They did the same with another man."  Again I don't want to

 9     mention his name.  "After them it was my turn.  When I was taken out,

10     they ordered me to lift my arms above my head and they started beating me

11     with an iron rod in the area of my chest and stomach."

12             Does this correspond to the facts, the truthful facts, and the

13     things that you went through?

14        A.   Yes, it does.

15        Q.    "After the beating was over, they put me back in the room.  On

16     the way back to the room I learnt that one of the previous men had

17     succumbed to the beating and died."  And you know who that is.  We don't

18     want to close this session.  We don't want to mention any names, but let

19     me ask you whether this is a fact, whether this is the truth.

20        A.   Yes, it is.

21        Q.    "After an hour, we were assigned to go to Zvornik to a new

22     prison, the so-called New Izvor.  We set out straight away, and the body

23     of the person who had died remained where he died, in that same room."

24             Does this reflect the fact -- the facts?

25        A.   Yes.  He remained behind.  He stayed behind.

Page 5470

 1        Q.    "It was only the following day when the reminder of the

 2     detainees arrived in Zvornik did I learn from a man called Juso, who had

 3     also worked in the same company and whose family name I can't remember,

 4     that the body of the deceased and two other men who had also died, i.e.,

 5     according to Juso, they had been killed from a rifle, were transported to

 6     Zvornik."  And this man who was with you and who died of the beating,

 7     this man from Zvornik, was taken to a village where he was buried.

 8             Does this reflect the facts?

 9        A.   It does not in the way it was worded.  I heard that these two men

10     had been shot and that the man who was buried in Zvornik had succumbed to

11     the wounds similar to the first man.  It's not the same situation.  I

12     didn't say that all of them shot from a rifle.

13        Q.   I am clear on that.  The person who was with you succumbed to the

14     beating wounds.

15        A.   Yes.

16        Q.   And the other two were shot.

17        A.   Yes.

18        Q.   And the three of them were transported to Zvornik, and then the

19     first person who died from beating was transported to the village from

20     which he hailed and where he was buried.

21        A.   Yes.  He was first transported to hospital, and then his father

22     took his body from the hospital and took him to the village.  I suppose

23     that's how it happened.  And then he was buried in the village near

24     Zvornik, I suppose.

25        Q.   So there's nothing in dispute here then.  "On the 16th of May," I

Page 5471

 1     believe it says on the 16th --

 2             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen.

 3             MR. MARCUSSEN:  I think we will have to look into the

 4     translation.  I just wanted to place on record that in the English

 5     translation of the statement I have I cannot see the reference to any

 6     shooting, but if -- I mean I take it the accused has read out correctly

 7     what's in the statement, but there's an issue we will have to come back

 8     to later, but in the interests of time I'm just placing this on the

 9     record so we can sort it out later.

10             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, I did make a note

11     of the fact that we do not know how these people died.  It's you who

12     mentioned the shooting.

13             THE ACCUSED: [Interpretation] Well, occasions I have told you

14     that your translation services are really poor.  It says here, and the

15     witness can confirm it, that the body of the person who died of beating

16     and who was with him, and two other detainees who also died, i.e.,

17     according to Juso, had been killed with a rifle."

18             This is what the original text reads.  How this was translated,

19     God only knows who your translators are and what their intentions are,

20     what hidden agendas they have.

21        Q.   "Those bodies were transported to Zvornik, and the person who

22     succumbed to the beating from Zvornik was transported to his village

23     where he was buried."  This is what the original reads.

24             Is this how you read it, Mr. VS-1015?

25        A.   Yes, there is something to that effect but my sight is really

Page 5472

 1     poor and the copy is not clear and there are things I don't understand.

 2     The copy is rather blurred.  So I was not able to follow all that.  I

 3     could not read all that.  But something to that effect happened.  I don't

 4     know how this was recorded.  I really don't know.

 5        Q.   There's no need for you to help the Prosecutor, not even God can

 6     help him, so entangled they are in the false indictment, but look at the

 7     next passage.  It says they were killed from a rifle.  Do you see that?

 8     Do you see that in the penultimate sentence from that passage?

 9        A.   I have to find the passage.

10        Q.   The first long passage, the penultimate line in that passage.

11     "Killed from a rifle."  This is what it says here.

12        A.   No, I can't find it.

13        Q.   Maybe somebody who speaks Serbian among the registry staff could

14     help you and show you where it says that they were killed from a rifle.

15     I don't see any other way?

16             THE ACCUSED: [Interpretation] Your Honours, can that be done?

17             JUDGE ANTONETTI: [Interpretation] The interpreters interpreted as

18     you said, that they were killed by shooting.  So go ahead.

19             MR. SESELJ: [Interpretation].

20        Q.   The Prosecution is guilty of this confusion, because they say

21     that it doesn't exist.

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 5473

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12             Please proceed, Mr. Seselj.

13             MR. SESELJ: [Interpretation].

14        Q.   It says here that you stated that this person died of old age,

15     and later on you said that he died of a heart attack.

16        A.   I must have forgotten in the meantime.  In any case, I didn't say

17     that he was killed with a rifle.  I stated that he died of old age or

18     natural causes.

19        Q.   These mistakes are quite possible in anybody's memory, and I am

20     not holding it against you.  It does happen that you think that you said

21     one thing and you actually said something else.  Even science can justify

22     such memory errors, so I'm not disputing anything here.

23             Let's move on to the next passage.  "In the Novi Izvor prison in

24     Karakaj I stayed up to the 15th of July, 1992.  Throughout all this time,

25     I was occasionally ill-treated and physically abused.  When I was

Page 5474

 1     interviewed about different circumstances, I allege -- I allegedly stated

 2     that all Serb children should be slaughtered and also spoke about which

 3     Serbs smuggled weapons to the Muslims.  Since I did not know that, I

 4     could not have answered any of those questions either, and that's why I

 5     was beaten with various objects."

 6             Does this reflect the truth?  Does this reflect the facts?

 7        A.   I did not know the answers, and that's why I was beaten.  I had

 8     to spend 10 or 12 days in bed after the beating.

 9        Q.   I'm not disputing that.  I just want you to confirm this.  I'm

10     convinced that this is really what happened.  I'm not disputing that this

11     really happened to you.  And terrible things happened to you, there's no

12     doubt about that in my mind.

13              "I was beaten by a Chetnik whom they called Zoks.  Pufta took

14     out and beat," a name is mentioned here.  I suppose we can mention it in

15     open session because it was mentioned by other witnesses.  If the

16     Prosecution does not object.  If there is an objection, then I will not

17     mention the name.  Can I mention the name of the person without the

18     transcript having to be redacted?  This person was a victim, was killed

19     in Zvornik, and there's no doubt about that.  Can I say his name?

20             MR. MARCUSSEN:  Yes.

21             MR. SESELJ: [Interpretation]

22        Q.   "He beat Cirak Ismet who died of the wounds as a result of the

23     beating.  Pufta is a Chetnik from the -- Serbia, probably from around

24     Valjevo or maybe Kraljevo.  He's a younger man.  He's 19, well built.

25     His hair is something between blonde and black, and his characteristic

Page 5475

 1     feature is that he screams when he beats people.  Zoks is also from

 2     Serbia.  He is tall, thin.  He has curly black hair.  And together with

 3     him was also Dragan called Toro, and he was their captain."

 4             Does all this reflect the facts as you saw them?

 5        A.   Just a moment.  Give me a moment, please.  It's correct about

 6     Pufta, correct about Dragan Toro, and to does correspond with Ismet

 7     Cirak.  And now as to what happened at Ekonomija, that he took people out

 8     at Ekonomija, I don't remember that, but I only know that what he did, he

 9     did to Ismet Cirak.  And I'm talking about Pufta.  And it is true that he

10     was strong, young, that he had a big head, short hair, that he was rather

11     aggressive.  Sometimes he would come in a tracksuit.  Sometimes he would

12     be wearing a uniform when he came.

13        Q.   Let's move on then.  "The aforementioned Pufta took it out on

14     some individuals.  On the right arm of a detainee Muslim he carved out a

15     piece of skin with a tattoo of a moon and star."  Is that correct?

16        A.   Yes, it is.

17        Q.    "On the 15th of July, 1992, 29 of us from Izvor Karakaj were

18     transported to the Batkovic camp together with three other busloads from

19     the so-called Novi Izvor prison in Zvornik.  When we arrived in Batkovic,

20     we were also exposed to various ill-treatment and beatings on the part of

21     the guards there and all those who were either there or who would come to

22     the camp.  Among them, the worst was a person called Velo.  He was the

23     guard's commander, also the guard Glogor, the guard called Major and

24     Zoran Zaric, and the others whose names I cannot remember."  Does all

25     this reflect the truth?

Page 5476

 1        A.   Yes, but let me just correct you.  It's not Glogor but Gligor.

 2     The name is Gligor.

 3        Q.   Yes it must be a typo but here it says Glogor.

 4             "In addition to the physical and psychological abuse in the camp,

 5     we did not have any hygiene facilities.  The circumstances of life were

 6     bad.  The conditions were bad.  We were billeted in the tents when the

 7     temperature outside was 35 degrees, and in the tent the temperature must

 8     have been around 50 degrees Centigrade, and we were not allowed to leave

 9     the tent.

10              "On the 17th of August, 1992, a delegation of the International

11     Red Cross came to Batkovici and then we were registered as detainees.

12     From then on the situation improved a little, and the situation remained

13     as so until the moment when I was exchanged on the 21st of June, 1993.

14              "I have nothing further to add to this except for the fact that

15     my -- this statement contains all of my words.  That's why I recognise

16     the statement as my own, and I sign it, and I would like to add that I am

17     prepared to testify about all this before any court."

18             Does this reflect the truth?

19        A.   Yes, it does reflect the truth, but if something else appeared in

20     the following statements it must have just been an extension of the

21     topics and hence a possible discrepancy, but whatever is in the statement

22     is true, and I don't see how it could have been any worse than it really

23     was.

24        Q.   Mr. VS-1015, terrible things happened to you.  There's no doubt

25     about that.  They could not have been worse.  The only worse thing would

Page 5477

 1     have been if you died.

 2        A.   I can only say that in Ciglana I fell and almost succumbed and to

 3     the illness on 10 or 15 occasions, but let me confirm that people from

 4     Novi Sad whose nicknames was -- nickname was Lala, I would fall down on

 5     the concrete from fear and every time I thought I would die.  But then I

 6     would come to.  To my biggest surprise it was all terrible.  It was

 7     horrendous.  I'm sure that there are even wore things, but I'm really

 8     still at a loss to understand how people can do such things to other

 9     people.  I consider myself a human being and I would like to remain so

10     until the day I die.

11        Q.   Do you believe me when I tell you that I sympathise and empathise

12     with your sufferings, or maybe you think I'm just acting before the Trial

13     Chamber and the Prosecutor's office.

14        A.   I suppose I can believe you.  You've stated it publicly before

15     this Trial Chamber, so I suppose it's true.

16        Q.   I can even tell you that I don't even care what the Trial Chamber

17     or the Prosecution are going to think about me and what the sentence is

18     going to be.  I'm just afraid of God and nobody else.  Do you believe me

19     when I tell you that?

20        A.   I believe you if you put it that way.  I suppose that you are

21     telling the truth.

22        Q.   But, Mr. VS-1015, where in your statement are Seselj's men?  You

23     don't mention my name at all.  You don't mention any Seseljevci men.  You

24     are not talking about Seselj's corps from Novi Sad.  There are no

25     Seselj's sabotage units.  There is none of that.  How come it's not

Page 5478

 1     there, Mr. VS-1015?

 2        A.   I don't know how this came about.  You yourself said how many

 3     years have elapsed.  The date may be there.  I don't know.  How this was,

 4     how fast this was all said and done, I don't know.  Later on I recalled

 5     things.  Things came back to mind.  They surfaced in my memory.  I

 6     haven't made anything up.  I simply extended my statement.  I told you

 7     about this Repic, this Pony-tail.  Perhaps I heard that that was his

 8     nickname when I got out.  If we were to go on talking about details like

 9     this, I might recall something or forget something.  So please

10     understand.  After all these years, after five years, you can't say

11     things in exactly the same way.

12        Q.   Well, I understand that completely, but, Mr. VS-1015, the memory

13     grows weaker in time.  It cannot be added to in time except through

14     imagination or suggestions coming from the outside.

15             You gave a statement on the 22nd of December, 1993, and you were

16     exchanged on the 21st of July, 1993.  So the statement was given five

17     months after your exchange, and that was when your memory was freshest.

18     I assume that in those first few months you relived everything in your

19     dreams at night.  Isn't that true?

20        A.   It could be that way.

21        Q.   You dreamed the people -- of the people who had been killed, had

22     been tortured along with you.  Along with you, you must have dreamed

23     about your torturers also.  Did this happen?

24        A.   Yes.  What do you expect?  Mr. Seselj, when the war was still

25     going on, shells were still landing where I was.  Would you expect me to

Page 5479

 1     sing songs or to think or dream about anything else in that war?  It

 2     wasn't that I got out and then I could dream this or that.  The war was

 3     still going on.  Everything was still dark.

 4             JUDGE LATTANZI: [Interpretation] Witness, we understand all that

 5     very well, but we're trying to shed some light on this aspect.  Here

 6     you're speaking about the Chetniks.  Today during your testimony you

 7     spoke about the Seselj's men.  Do try and remember.  Could it be that you

 8     heard about this after the events that you heard about the fact that the

 9     Chetniks were Seselj's men?  Could it be that you heard it then, or are

10     you sure that during -- that you heard that during the events, that you

11     heard it from those men that they were Seselj's men?  That's my first

12     thing.

13             Second thing I'd like to elicit from you:  At some point in time

14     you said that it was Niski who told you that he was one of Seselj's men.

15     So I didn't quite understand whether you heard it from Niski alone or

16     whether you heard it also from the other men who abused you, who tortured

17     you, because whilst you said that Niski did nothing, that you did not see

18     him torture people.

19             So try to really focus on this, because your testimony today is

20     the most important thing for the Trial Chamber.

21             THE WITNESS: [Interpretation] Why I didn't mention here, it's

22     possible that in that environment I didn't mention it after that, but I

23     say again that Niski said that when he described that incident the last

24     time, and in Ciglana there were two of those men who I mentioned before

25     working as mechanics, and I heard that from Niski himself.  And later on

Page 5480

 1     through the stories of the employees there with whom we socialised and

 2     spent time, they said that they were members of Seselj's sabotage unit.

 3     That's what the man himself said.

 4             I would like to meet up with this Captain Niski.  I don't know

 5     whether he's from Nis or not and whether he's a captain or not, but I

 6     would like to meet him.

 7             Why I didn't say that then?  Well, it was a long time ago and I

 8     may have spoken in haste.  You can see that the statement was only two

 9     pages long.  I was not making the statement before a court.  I just

10     signed what they put down.

11             JUDGE LATTANZI: [Interpretation] Thank you.

12             JUDGE ANTONETTI: [Interpretation] Witness, here's my problem:

13     The War Crimes Commission then sitting in Tuzla, that is five months

14     after your release, met with you.  Well, I was not a member of committee,

15     but I suppose what the committee members wanted to know, who had

16     committed those crimes.  Who were the people responsible for them.

17     Therefore, you gave a statement.

18             We all have this statement here, and in at no time, in no place

19     is there any mention of Seselj's men.  You do indeed speak of the

20     Chetniks, but we find nowhere any mention of Seselj's men.

21             How is it that several years later you suddenly remember things,

22     and there is Zoks, there's Toro, and all these people somehow magically

23     become Seselj's men.

24             What is your explanation for this?

25             THE WITNESS: [Interpretation] I made this statement, which I'm

Page 5481

 1     now seeing for the first time, and where things are written as they were,

 2     but I can hardly remember where -- when this was.  However, the statement

 3     I made to The Hague investigators, this went on for three or four days.

 4     And when we talked then these topics cropped up, and each incident was

 5     dealt with in detail.  So I knew all these things even though I hadn't

 6     said them before.

 7             I state again that Niski said they were Seselj's sabotage unit,

 8     and I say it again.  If I failed to mention it that time I don't know

 9     why, but later on I did say that they belonged to that unit and that they

10     themselves said that before witnesses.  They said it in front of other

11     people.  Other people also know this.  That's how it was.

12             JUDGE ANTONETTI: [Interpretation] This morning, page 59, line 19,

13     you said:  "Seselj, I don't know you."

14             Well, back then when these events that occurred, events you were

15     a victim of, this isn't challenged by no one, had you already heard the

16     name of Seselj?

17             THE WITNESS: [Interpretation] I may have said I don't know him

18     personally.  I did hear about him, and he appeared on television when

19     there were elections in the former Yugoslavia when parties were

20     established.  I think Mr. Seselj would agree he was the leader of a

21     political party.  I don't remember its name.  I think it was the Radicals

22     or something like that, I'm not sure.  And I knew him in that way, but I

23     didn't know him personally.

24             JUDGE ANTONETTI: [Interpretation] Therefore, when Niski told you

25     that this was Seselj's men or Seselj's sabotage unit, you thought that

Page 5482

 1     was logical and true to form?

 2             THE WITNESS: [Interpretation] Yes.  Yes.  Because when he

 3     mentioned that, I immediately concluded that that's how it was, because

 4     he said it.  I'm not saying that Seselj fired shots or killed people.  I

 5     don't know anything about that.  But Seselj's name was mentioned, and

 6     they said they were in his sabotage unit.  He mentioned a sabotage unit.

 7     I repeat.  And if Niski and Dragan Toro and some others hadn't been

 8     there, they would turn up for a day or two and then people would continue

 9     working probably.

10             JUDGE ANTONETTI: [Interpretation] Very well.  Please resume.

11             MR. SESELJ: [Interpretation]

12        Q.   Mr. VS-1015, for years there were anecdotes bandied about in

13     public about Seselj's submarines which can travel down the River Sava as

14     far as Zagreb.  People spoke of Seselj's rockets, of Seselj's air force,

15     but this is the first time I've heard of Seselj's sabotage units.  Nobody

16     ever heard of any such thing until it turned up in your statement.

17     Absolutely nobody ever heard of any sabotage units of Seselj's.  What do

18     you think?

19        A.   Well, I may have mentioned units in my statement, but it was more

20     like a sabotage group.  I may have mentioned this before.  I may have

21     said units.

22             MR. MARCUSSEN:  It's misleading the witness.  The same thing was

23     said yesterday, for example.

24             THE ACCUSED: [Interpretation] It's not misleading at all.  I'm on

25     the right track here, and I'm showing that using the tragedy of this

Page 5483

 1     witness and his sufferings, he has been manipulated.  His sufferings and

 2     his tragedy have been manipulated quite evidently and misused.

 3             MR. SESELJ: [Interpretation]

 4        Q.   Can we again see on the internal screen which the public can't

 5     see a Prosecution document shown to us the day before yesterday.  It's

 6     02208.  It's been admitted into evidence, but I don't know under what

 7     number because I still haven't received the exhibit register.  It's 65

 8     ter 02208, and it was shown in the courtroom the day before yesterday.

 9     Can we see it on our internal screens and not have the name of the person

10     under the drawing identified.  I think you can do that.  Not even this

11     witness needs to know the name of the other witness.

12             Can you zoom in a little bit where we see this building.  Zoom in

13     a little bit where the building is and the floors are marked.

14             You see, a witness who testified here before you spoke about the

15     building you were in.  You may have been there together, but I won't

16     mention his name.  And he said that this administrative building --

17             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen.

18             MR. MARCUSSEN:  This witness was not at that location.  This is a

19     sketch of the Standard factory, and this witness was not at Standard.

20             THE ACCUSED: [Interpretation] But it's possible they were

21     together in the Ciglana, and this is the Standard administrative

22     building, which I'm showing for quite another reason, not to prove that

23     the witness was in that building but to show that another witness here

24     marked who was where in that building on each floor, and the ground

25     floor, which is marked here, it says "Reconnaissance men and sabotage

Page 5484

 1     men."  On the second floor Loznicani, the people from Loznica, and the

 2     military police.  On the second floor prisoners and Seselj's men.

 3             So you see, this witness drew distinction between the sabotage

 4     men and Seselj's men, and you are referring to Seselj's sabotage men.

 5     The problem was caused by someone who suggested to both witnesses that

 6     they should mention Seselj's men and sabotage men.  So one person

 7     mentioned them separately, Seselj's men and sabotage men, and you

 8     compounded the two together.

 9        Q.   What do you say to this, Witness?

10        A.   Well, I wouldn't want to comment on this drawing, on this sketch.

11     I don't know anything about this building.  I know about the Standard

12     building, where it is, but I've never been inside so I can't recognise

13     this.  And what he wrote down, well, that's his business.  I don't want

14     to go into that.  But I have to tell you again.  I may have misspoken

15     when I said units, but this person did say Seselj's sabotage men.  I am

16     sure that that's what he said.  I assert that before all these people.

17     They were called Seselj's men.  They were from Kraljevo.  They said that

18     they would send the loot back to Kraljevo and things like that so that

19     they were constantly referred to as Seselj's men, men from Kraljevo, men

20     from Loznica, and so on.

21             This is something quite different.  This is a quite different

22     location which I've never seen.

23             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, just a minute.  I

24     have my eyes on the stopwatch.  You normally have 25 minutes left.  If

25     the Prosecutor has no redirect, we may continue to 1.30, have another --

Page 5485

 1     an extra 15 minutes and stop.  It all depends on Mr. Marcussen.

 2             Do you have any redirect or not?  If so, I believe we will have

 3     to resume next week.

 4             MR. MARCUSSEN:  I'm willing not to put any questions.  Of course

 5     I have -- it's difficult for me to say what will arise during the next 25

 6     minutes, but at this stage I don't have any questions that I need to put

 7     in redirect.

 8             JUDGE ANTONETTI: [Interpretation] Very well.  Mr. Seselj, please

 9     try and finish up and you will have used up your two hours.

10             THE ACCUSED: [Interpretation] I will certainly complete my

11     examination.  I have never overstepped my time, Mr. President.

12             MR. SESELJ: [Interpretation]

13        Q.   I believe you when you say that one man mentioned sabotage men,

14     Seselj's sabotage men, and so on.  I believe that, Mr. VS-1015, but this

15     did not happen when you were incarcerated.  It happened a few years after

16     that, and that is where we differ.

17        A.   No, no.  That was said in the Ciglana at the gate when Mr. Niski,

18     and I have to reiterate I'm speaking the truth, I never saw him

19     mistreating anyone, and sometimes he even saved people to prevent that

20     monster, I won't even call him a Chetnik, that monster who was

21     mistreating those people from doing it.

22             And there was a man from my village who was a guard there and who

23     protected me, who stopped me from going out at that point.  And when

24     Niski arrived and his car brakes screeched, he must have been passing

25     down excuse me, I'm talking very fast I'll try to calm down.  When he saw

Page 5486

 1     what was going on, the car stopped, he cocked his pistol with his left

 2     hand and pointed at that man and those guards, and he saved those people

 3     from mistreatment, and he ordered them to be washed because they were all

 4     covered in blood.  And then he told that man about those sabotage men and

 5     that's when it started to be mentioned.  So is it clear to you now

 6     Mr. Seselj?  I really don't know what else to say.

 7        Q.   Well, everything is clear to me and I understand your situation

 8     also.  Was your name familiar to you many years before the war?  Did you

 9     hear of me?

10        A.   Well, yes.  Not long before the war, but when the political

11     parties were established.

12        Q.   Did you hear that I was sentenced to eight years in prison as an

13     anti-Communist, a nationalist, and so on in Sarajevo?

14        A.   I didn't hear it at the time.  I may have heard it after the war,

15     six or seven years after the war, but these political things, well, I

16     wasn't really -- I'll not really following the current affairs in Bosnia.

17        Q.   I want to know what you heard of me.  Do you know that I held a

18     rally in Mali Zvornik before the war and that there was an incident at

19     that rally, that some people from Veliki Zvornik came and that they threw

20     stones at us and so on and so forth?

21        A.   I really wouldn't know that.  I don't know.  I was not in Mali

22     Zvornik.  I lived a bit further away from Zvornik.  This must have

23     happened while I did not need to go there because I lived on the other

24     side from Zvornik so this must have been happened unbeknownst to me.

25        Q.   But you must have heard of Seselj's volunteers during the war in

Page 5487

 1     the former Croatian federal unit.  I'm sure that you have heard of the

 2     volunteers of the Serbian Radical Party.  I'm sure that you heard of them

 3     before the war started in Zvornik?

 4        A.   Yes.  There was this war in Croatia and this was aired on TV.

 5     Whatever I could hear I could hear it on TV, on Belgrade 1 or 2.  I had

 6     only these two channels that were available to me.

 7        Q.   And in 1991 you must have heard on St. George's day that I went

 8     to Sarajevo and I was supposed to appear and on a Sarajevo TV show that

 9     was hosted by a Aleksandar Tijanic and Mirjana Bobic-Mojsilovic, it had a

10     large viewing on Yutel.  And then there were demonstrations before the

11     national theatre against my appearance on TV and there were incidents

12     during those demonstrations.  Do you remember that?

13        A.   I am familiar with Tijanic.  The name rings a bell, but again I

14     don't remember that case.  I was a good man.  I was an honest man.  I was

15     a good worker.  I had a firm.  My family was really good and I spent much

16     more time doing other stuff than -- than following politics.  I was never

17     interested in political speeches or shows of political nature.  They all

18     were -- went past me.

19        Q.   There were some shortages before the war.  There were shortages

20     of oil, flour, sugar.  Do you remember that?

21        A.   Yes I do.

22        Q.   Do you remember anecdotes where people would write on the windows

23     of shops, sugar is coming, and then some other people would be replacing

24     it with Seselj's coming?

25        A.   In my village there were only two or three small shops, and those

Page 5488

 1     people who worked in the shops were Serbs and this is not very likely

 2     that somebody would write something like that on a shop with -- in my

 3     village.

 4        Q.   In any case you knew quite a lot about me.  You were familiar

 5     with my name and all of these things and in Zvornik what happened and the

 6     things that you testify about.  I'm sure that you could not have

 7     overheard the name of Seselj's volunteers being mentioned as torturers or

 8     sabotage men?

 9        A.   Now you said it yourself that Seselj's sabotage men weren't

10     mentioned.  They were mentioned.  They were in -- under your control,

11     maybe not, but their name did come up.

12        Q.   That's what I'm saying.  It must have been striking and I'm sure

13     that you could not have ignored that when you provided your statement in

14     1993 to the Muslim authorities.  My name was so well-known amongst

15     Muslims and across the territory of the former Yugoslavia that you could

16     not overheard my name being mentioned.  If anybody mentioned my name

17     during your torture, during your ordeal, I'm sure that you would have

18     told that to the Muslim authorities.  I'm sure they must have even asked

19     you about Seselj and Seselj's volunteers?

20        A.   Nobody asked me anything.  I was only there for a brief time.

21     After the war I crossed -- went across Croatia and further on.  Let me

22     not tell you where I went, I went on foot.  I was never in favour of war.

23     I never participated in any war, and I really wondered all the time and I

24     still keep on wondering how come that I was not guilty of everything,

25     that I was blameless, I still had to go through all that ordeal.  And it

Page 5489

 1     is always like that, only the weak and innocent suffer in -- in wars.

 2        Q.   I agree with you, but Mr. VS-1015 today for the first time you

 3     mentioned that this Caca person from the Novi Sad Corps was also a

 4     Seselj's volunteer.  You never mentioned it to anybody before, either to

 5     The Hague Tribunal in any of the other statements.  You've mentioned this

 6     for the first time today.  How come?

 7        A.   Maybe this was not recorded.  I must have said it.  Maybe it

 8     wasn't recorded.  I was not alone there.  If there are any other

 9     witnesses of these events I'm sure that they will tell you that this Caca

10     existed.  That was his nickname.  Let me describe you:  He was about 50

11     years of age; he has always had his sleeves rolled up; he wore a military

12     blouse and old military trousers of the JNA, olive drab trousers, and

13     this person didn't do any harm to me.  He saved a few of us who were

14     there in sand, lying in the sand when Mr. Zoks cocked a pistol that he

15     was carrying as a souvenir.  It was a long-barrelled pistol, Colt.  He

16     fired shots above our heads and he had ordered us to lie down.

17             I was towards the end of that row of detainees and I was covered

18     with the pebbles.  I thought I was dead.  I could not believe myself that

19     I was alive, and this person Caca came closer to Zoks and told him, "What

20     are you doing?  Leave people alone, they are working."

21             So whatever you want from me, Mr. Seselj, if you get to this

22     Caca, to this Zoks, and the other people who were there, ask them whether

23     that is correct or not.  I'm sure that you will be able to obtain

24     information.  I'm sure that you're willing to get information.  I'm

25     talking about the -- not only about the worst things but also about

Page 5490

 1     things that -- and people who saved us at one point or another.

 2        Q.    I'm not contesting the existence of that person Caca, but I'm

 3     contesting the existence of the Novi Sad Corps of socials volunteers.

 4     Where does this come from?  You had stated that earlier today you said

 5     that Caca belonged to the Novi Sad Corps of Seselj's volunteers?

 6        A.   They were telling us that themselves.  They didn't stay there

 7     long.  They were all constantly on the move.

 8             JUDGE ANTONETTI: [Interpretation] Witness, please speak slower.

 9     You're going too fast.  We need a break between questions and answers.

10     And please try to be more concise in your answer.

11             MR. SESELJ: [Interpretation]

12        Q.   Did you ever hear of the Yellow Wasps in Zvornik?

13        A.   I heard it here -- or before another court actually.

14        Q.   Did you ever hear that the commander of the Yellow Wasps was

15     Vojin Vuckovic also known as Zuco?

16        A.   Possible, but I can't remember.

17        Q.   Yesterday before this Trial Chamber and the Prosecution I

18     provided the statement of this Vojin Vuckovic person that was given to my

19     associates in order to be used in this trial.  In this statement he says,

20     and I'm not going to read his entire statement, I'm just going paraphrase

21     it.  He says in this statement that the Kraljevo group of volunteers

22     consisted of 52 members belonged to the White Eagles, i.e., to the Serb

23     popular renovation movement.  This is not what I said.  But Zuco was

24     there and he knows who the others who were there were and he says that

25     the Kraljevo group belonged to the White Eagles.  Do you think that this

Page 5491

 1     is possible or not?

 2        A.   I really don't know what the person told you.  Again I repeat

 3     Niski told us that.  Look for Niski and ask him.  That's what he said.

 4     And of course that the story was all about that.

 5        Q.   But he says about Niski that he belonged to the Arkan's men.  He

 6     says that the person called Dragan, family name unknown, nickname Niski

 7     belonged to the Serbian volunteers guard.  This is what Zuco says.

 8        A.   What do I know?  We were ill-treated.  That's all I know.  Niski

 9     didn't say I am this and that.  Dragan did not introduce himself to us

10     and said who he belonged to.  That was the whole atmosphere.  That's how

11     things went.

12             Later on when they processed us, when we were working they even

13     removed some of their insignia.  If there were -- had not been other

14     people who beat us in Ciglana, we had even become friends with those

15     people from Seselj's group.  We worked with them and there were no other

16     incidents but the two involving Zoks who shot at us and Pufta who did

17     what he did with these two people, and from then on when Pufta did what

18     he did, then they removed both Zoks and Pufta and during the following

19     days until the moment we were transported to Batkovic they never appeared

20     again.

21        Q.   In his statement Zuco says that the group under Pivarski's

22     command had a total of 16 volunteers and that they did not belong to the

23     Serbian Radical Party.  And Zuco knows.  He was there.  And there is no

24     reason for him to lie because I attacked him a number of times publicly,

25     so there is no reason for him to speak in my favour because I attacked

Page 5492

 1     him so many times.

 2        A.   I'm not testifying against Zuco.  I'm just telling you how it

 3     was.  If you can bring Zuco as your own witness or whatever his name is,

 4     if you can bring him over as your own witness, then he can repeat what

 5     you're claiming here as a witness before this Trial Chamber, and I --

 6     there's nothing for me to object about.

 7        Q.   In his statement he says that Sasa, whom you also mentioned --

 8     you mentioned Sasa, did you not?

 9        A.   Yes, I did.

10        Q.   That this Sasa led a group of some 15 to 20 volunteers from Mali

11     Zvornik and that they also did not belong to the Serbian Radical Party

12     volunteers.  That's what Zuco says.

13        A.   Well, he says what he says.  Now you can actually understand how

14     many people beat us there, how many people went through there, and it is

15     only a miracle that we all survived.

16        Q.   I really can't know how many people beat you.  I can either

17     believe you or not.  And what you said in your first statement in 1993, I

18     believe you, but I'm saying that it was not the Seselj's group that beat

19     you.  We have another statement that deals with Pivarski.  It is only one

20     passage long.  Can this please be put on the ELMO.  We did not see it

21     yesterday.  This is a statement provided by Savo Sinadinovic?

22             JUDGE ANTONETTI: [Interpretation] Listen, we have to finish

23     within a few minutes, especially because we're just sort of repeating the

24     same things over and over.  No need to show the statement.  Put your

25     question.  Say that there is a statement saying this and that, and ask

Page 5493

 1     the witness for an answer.  You've been trying to elicit from the witness

 2     something that he doesn't want to say.  You've been doing this for two

 3     hours.  Now ask a question without speaking about this statement.

 4             THE ACCUSED: [Interpretation] Mr. President, I achieved

 5     everything I wanted from this witness.  If you are not willing to notice

 6     that and if that is not your conclusion that's up to you.  I'm not

 7     interested in that.  I have proven that this witness's suffering, this

 8     witness's ordeal, had been instrumentalised and that his current

 9     statement does not reflect the facts.  The only statement that is

10     truthful is his first statement and everything else was just a build-up

11     from elsewhere.

12             I have nothing personal against this witness.  I have led my

13     counter-evidence.  I've proved what I wanted to prove able sure that the

14     general public will understand that this witness has been

15     instrumentalised for some political goals without any blame of his own.

16     I'm not going ask him any more questions.  I finished my

17     cross-examination.

18             Thank you very much, sir, that you have helped me do what I

19     wanted to do even against your will.

20             THE WITNESS: [Interpretation] Thank you too.

21             JUDGE ANTONETTI: [Interpretation] Witness, I thank you on behalf

22     of the Trial Chamber for your testimony.  Of course you have all our

23     sympathy and compassion for all your sufferings.

24             We have a few seconds left before we adjourn, and I want to tell

25     the parties, the Prosecution and Mr. Seselj, that apparently the witness

Page 5494

 1     scheduled next week will not be testifying.  Therefore, yesterday we

 2     asked for VS-33 could come.  There still has been no answer so far.  We

 3     asked the Prosecution to start the hearing with the viewing of video

 4     clips.

 5             Mr. Marcussen, do you have a specific stance or not?  What about

 6     next week?

 7             MR. MARCUSSEN:  The Prosecution is looking into these options.  I

 8     don't think we have reached any conclusion.  I cannot add anything to

 9     what Mr. Mundis said yesterday, but it might be possible that tomorrow we

10     can inform Your Honours about what we will be in a position to present

11     during next week.

12             JUDGE ANTONETTI: [Interpretation] Very well.  At any rate, the

13     next hearing will take place on Tuesday at 2.15 in the afternoon as

14     scheduled.

15             Thank you.  We shall reconvene on Tuesday.

16                           --- Whereupon the hearing adjourned at 1.26 p.m.,

17                           to be reconvened on Tuesday, the 1st day of April,

18                           2008, at 2.15 p.m.