Tribunal Criminal Tribunal for the Former Yugoslavia

Page 20500

1 Friday, 9 May 2003

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.13 a.m.

5 JUDGE MAY: Yes, Mr. Groome.

6 MR. GROOME: Your Honour, the Prosecution calls Mr. Dzemail

7 Becirevic.

8 [The witness entered court]

9 JUDGE MAY: Let the witness take the declaration.

10 THE WITNESS: [Interpretation] I solemnly declare that I will speak

11 the truth, the whole truth, and nothing but the truth.


13 [Witness answered through interpreter]

14 JUDGE MAY: If you'd like to take a seat.

15 THE WITNESS: [Interpretation] Thank you.

16 MR. GROOME: Your Honour, this is a witness whose statement we

17 intend to tender under provisions of 92 bis. I'd ask if we could have an

18 exhibit number assigned for that purpose.

19 THE REGISTRAR: Prosecution Exhibit 442, Your Honours.

20 MR. GROOME: Your Honour, Prosecution Exhibit 442 contains

21 Mr. Becirevic's account of the events in Bratunac municipality prior to

22 and during the takeover of Bratunac in April of 1991. At that time, he

23 was the chief of the National Secretariat for Defence of the municipality.

24 He describes the removal of weapons from the stores of the Territorial

25 Defence. He gives a brief account of the development of and interaction

Page 20501

1 between the SDS party and the SDA party and Miroslav Deronjic's

2 significant role in the political and military developments in the

3 Bratunac area.

4 The statement goes on to describe the events surrounding the

5 mobilisation or call-up during the war in Croatia and the build-up of the

6 JNA resources in the area of Bratunac upon their withdrawal from Croatia.

7 He describes the founding of their respective Crisis Staffs in

8 1991. Mr. Becirevic's statement goes on to describe the wounding and

9 killing of several Muslims in an ambush in the area of Kravica. It goes

10 on to describe the establishment by Mr. Deronjic of a separate police

11 force and the provision of military training for Serbs by the JNA.

12 Prosecution Exhibit 442 continues with the actual takeover of the

13 municipality in mid-April of 1992 and describes the appearance of Arkan's

14 Tigers. In the statement, Mr. Becirevic goes on to describe seeing

15 Mr. Deronjic in a camouflage uniform riding in a JNA armoured personnel

16 carrier in the area of Konjevic Polje. The statement describes the fierce

17 battle that ensued in this area.

18 The statement continues with the description of a

19 counter-offensive launched from Serbia in the Bratunac area in January of

20 1993 after the Muslim forces took the area of Cerska. It describes troops

21 coming from Ljubovija and Bajina Basta in Serbia, an offensive that lasted

22 until the 15th of March, 1993.

23 We will seek at this stage to ask Mr. Becirevic some additional

24 matters not contained in his statement, as well as I seek his comment on a

25 number of exhibits.

Page 20502

1 Examined by Mr. Groome:

2 Q. Sir, my first question to you is: When were you demobilised?

3 A. Your Honour, I served in the Yugoslav People's Army from 1980 to

4 1981. And as for my involvement in the Army of the Republic of Bosnia and

5 Herzegovina, I served from end April 1992 to 1995, after the fall of

6 Srebrenica, when I managed to get out of Srebrenica and go to Tuzla.

7 That's when I was demobilised.

8 Q. What was your profession after you were demobilised, immediately

9 after?

10 A. Immediately after my demobilisation, I continued for a couple of

11 months to work in the military court in Tuzla as an investigative judge up

12 until the end of the state of war in Bosnia and Herzegovina, when the

13 military court was abolished, whereupon I continued to work in a civilian

14 court, the higher court of Tuzla, to be precise.

15 Q. And what is your current profession?

16 A. I am a lawyer, and I currently have my own private law practice in

17 Sarajevo.

18 Q. Sir, in paragraph 4 of your statement, which is now Prosecution

19 Exhibit 442, you describe the removal of weapons from the Territorial

20 Defence building in Bratunac. My question to you in supplement to your

21 statement is: Did you personally witness any of the removal of these

22 weapons?

23 A. Yes. I saw with my own eyes when the Yugoslav People's Army

24 arrived in 1989. At the time, I was working for an enterprise called

25 Duhan, a tobacco factory in Bratunac, and the factory was located directly

Page 20503

1 opposite military depots. The depots held all the weaponry of the

2 Territorial Defence of Bratunac, and the entire population of Bratunac

3 contributed to the purchase of those weapons. In 1989, as I said, the

4 Yugoslav People's Army arrived with about a dozen military vehicles and

5 trucks, and all these arms were taken out and transported to Ljubovija in

6 Serbia. I know nothing further about the fate of those arms.

7 So the distance between the enterprise where I was working from

8 the depots was barely 50 metres, and more importantly, from my office I

9 could see what was going on, and I even went outside to look. Nobody

10 offered any resistance when these weapons were being removed.

11 Q. If I might draw your attention now to paragraph 5 of your

12 statement. You describe yourself as one of the first to organise and join

13 the SDA party in Bratunac. Could I ask you to simply list the other

14 significant members of the SDA party in Bratunac in -- at the time of its

15 founding.

16 A. It was Nezid Muratovic, Dzevad Gusic, Dubicic Nijaz, Semsudin

17 Durakovic, Abid Sirucic, and myself who set up the SDA, or rather, made a

18 motion, an initiative for its establishment.

19 Q. And again, your statement deals in detail with the founding and

20 membership of the SDS party. What I would ask you to deal with now is:

21 Are you familiar with a part of that party or a committee on that party

22 called the Initiative Board? And if so, I would ask you to list the names

23 of the members of that board.

24 A. That body was called the Initiative Council or the Initiative

25 Board of the Party of Democratic Action, and I just enumerated the people

Page 20504

1 who were on that board. I can also mention Hasan Smailovic as a member,

2 Safet Dzanic --

3 Q. Sir --

4 A. -- and some others.

5 Q. -- I'm actually asking now about the other party, the SDS party,

6 not the SDA party.

7 A. As for the SDS, the first founding members were Miroslav Deronjic,

8 Jovan Nikolic, Nedjo Nikolic, Zoran Tesic, Zoran Radic, and some other

9 Serbs whom I mentioned in my statement as having established the SDS party

10 in Bratunac.

11 Q. Mr. Deronjic, what -- can you describe for us, during the period

12 relevant to your testimony, can you describe what positions he held in the

13 SDS party in Bratunac.

14 A. Your Honours, Miroslav Deronjic, apart from being the president of

15 the SDS in Bratunac, also occupied the position of president of the SDS

16 Crisis Staff of Bratunac. He was also president of the war commissioner's

17 office for Bratunac and discharged a number of other functions. He was a

18 member of a commission whose exclusive task - and this was a three-member

19 commission - was to dispose of and allocate funds from the SDS account.

20 Q. Sir, I'd ask you to comment on what knowledge you have regarding

21 the relationship between the SDS board in Bratunac and the SDS leadership

22 in Sarajevo at that time.

23 A. The SDS party in Bratunac received orders directly from the SDS in

24 Sarajevo, and I remember very clearly that whenever we from the SDA tried

25 to agree with the Bratunac SDS on some sort of division of authority after

Page 20505

1 the first democratic election, and whenever we would manage to reach an

2 agreement, the SDS would ask for a timeout of one or two days for somebody

3 to go to Sarajevo, to talk to Radovan Karadzic, the president of the SDS

4 for Bosnia and Herzegovina. So they got instructions from Radovan

5 Karadzic. But whenever we would resume talks to agree on the further

6 division of authority, they would ignore us and renege on the agreement

7 that we had reached.

8 Q. Sir, can you give us the names of some of the members of the

9 Bratunac SDS that actually travelled to Sarajevo in the manner you've

10 described?

11 A. Your Honours, first of all, it was Miroslav Deronjic, Radoljub

12 Djukanovic, president of the executive board of the Bratunac Municipal

13 Assembly, where I was a member too; then there was also Zoran Tesic and

14 Jovan Nikolic. So these are the people who often went to Sarajevo to the

15 head office of the SDS for consultations.

16 MR. GROOME: Your Honour, the Prosecution has a binder of ten

17 exhibits it would seek to use with this witness. Could I ask that an

18 exhibit number be assigned.

19 THE REGISTRAR: Prosecution Exhibit 443.


21 Q. Sir, I'm going to ask that you take a look at a document. It is

22 Prosecution Exhibit 443, tab 2. My question to you is: Have you had a

23 chance to review this prior to your testimony this morning, and do you

24 recognise any of the names that are listed on this document?

25 A. Your Honours, I did not have occasion to see this document before

Page 20506

1 starting my testimony. As for the names listed here, I know all these

2 people personally. The signatory of this document is the president of the

3 executive board of the SDS for Bosnia and Herzegovina, Rajko Dukic,

4 general manager of the bauxite mine in Milici. It belonged to Konjevic

5 Polje municipality previously and then became a separate municipality.

6 In 1991, which is the date of this document, these people were

7 authorised to allocate SDS funds. I see the first name on the list,

8 Milenko Katanic. He is a clerk in the municipal administration of

9 Bratunac. I knew him personally because I also worked in the municipal

10 administration. There was also Miroslav Deronjic, president of the SDS

11 and president of the Crisis Staff, and Zoran Radic, also a member of the

12 Crisis Staff and of the SDS executive board for Bratunac municipality.

13 MR. GROOME: Thank you. I'm finished with that exhibit.

14 Q. Sir, your statement is quite a detailed one, and there is a matter

15 of which you have an awful lot of personal knowledge, that is, the -- the

16 Muslim community's reaction to a mobilisation order. It's dealt with in

17 great detail in your statement and it's also been the subject of testimony

18 by other witnesses, so I will not go into it at this point. But I would

19 ask you one question regarding it, and the particular aspect of it I would

20 like to ask you about here is there came a time when there was an attempt

21 to remove a list of reservists that was in your custody; is that correct?

22 A. Yes, that is correct, Your Honours.

23 Q. My question to you is: What knowledge do you have with respect to

24 were other municipalities -- were similar attempts made to obtain

25 possession of that -- a similar list from other municipalities?

Page 20507

1 A. Your Honours, I do know that in other municipalities as well there

2 were attempts to take away these military files by force, in

3 municipalities where Bosniaks were a majority.

4 Q. Sir, I want to draw your attention now to the area of Kravica and

5 specifically to a number -- or to an event that occurred there. Do you

6 know the event that I'm speaking about?

7 A. Your Honours, the Prosecutor probably means the events that had to

8 do with the killing in Kravica on the 3rd of September, 1991, when there

9 was an ambush in the evening. Four Bosniaks were attacked for no reason

10 whatsoever, and they were moving along the road from Konjevic Polje

11 towards Glogova -- rather, Bratunac. At a curve, from a rock in the

12 village of Kajici near Kravica, they were ambushed. In that ambush, two

13 young men were killed and two were seriously wounded. The murderers who

14 had committed the killing are from Kravica; Radinko Milanovic, nicknamed

15 Mali Raso, and the other one is Marko Markovic from Cerska, municipality

16 of Ljubovija, Serbia. So they are the direct perpetrators of the crime,

17 upon instructions of the SDS from Bratunac in order to cause tensions

18 between the Bosniaks and the Serbs in the municipality of Bratunac.

19 Q. Sir, what was the consequence of this event?

20 A. Your Honours, after this killing, the Bosniak people was

21 frightened. There was an escalation of tensions in the municipality of

22 Bratunac. The following day, the road was closed temporarily. People

23 came from Sarajevo - they had to come from Sarajevo, from the Presidency,

24 from the MUP of Bosnia-Herzegovina, top people - in order to try to ease

25 the tensions, because there was a danger of having a war break out then in

Page 20508

1 the territory of Bosnia and Herzegovina. From the Presidency, Ganic came,

2 as well as Nikola Koljevic. They came by helicopter to Bratunac to try to

3 calm down the situation in the municipality. It was agreed that these two

4 delegations go to Kravica together and that they try to establish how this

5 killing occurred. Finally, Koljevic went on his own to Kravica without

6 allowing a proper investigation and without making it possible for the

7 perpetrators to be found immediately; that is to say, they forbade the

8 legal authorities of the MUP from Bratunac to come and investigate who

9 committed the crime and who organised the murder.

10 After that, there were replacements, or rather, a resignation of

11 the head of the MUP and the commander of the police were forced. Nezid

12 Muratovic was in this position then as head of MUP, and Nikola Mandic was

13 commander of the police force. After them --

14 Q. Was one of the consequences, as you describe in your statement,

15 that Serbs left the area and also the appearance of artillery on the Serb

16 side of the border in Ljubovija?

17 A. Your Honours, after that, that was one of the consequences too,

18 that the moving out of Serbs to Ljubovija was staged. Allegedly after

19 this killing that they had committed, there was some kind of danger

20 looming over the Serbs in Bratunac. After that --

21 Q. At that time were patrols initiated by both the Muslim community

22 and the Serb community as tensions rose?

23 A. Your Honours, it was agreed with the top echelons of the B & H MUP

24 to reinforce the reserve MUP force by Serbs and Bosniaks so that these

25 tensions would be eased. However, every village, Bosniak and Serb, at the

Page 20509

1 time had to have guards in the evening because there was fear from having

2 some groups, paramilitary groups, coming in from Serbia and attacking

3 people.

4 Q. During this time period, did you become aware of arms being

5 distributed to the Serb community, members of the Serb community?

6 A. Your Honours, I learned that, after these events, weapons were

7 being distributed and that also what started was the mass proliferation of

8 weapons from Serbia. In the region of Voljavica, in the village of

9 Pobrdje, an attempt was made to get weapons from Ljubovija there by boats.

10 This was prevented at a given point in time, but it nevertheless continued

11 later, that is to say, the supply of weapons. And one of the Serbs who

12 took part in the supply of weapons was arrested, handed over to the MUP in

13 Bratunac, but the next day he was released, which is to say that the MUP

14 -- or rather, individual employees of the MUP took part in this arming of

15 Serbs in Bratunac from Serbia.

16 Q. Can you briefly describe what, if any, arms were possessed by the

17 Muslim community and any attempts to distribute them.

18 A. Your Honours, the Muslim community at that time did not have any

19 weapons whatsoever. As I've already said, the arms of the TO were taken

20 by the JNA. And as for privately owned weapons, there were some hunting

21 guns that some Bosniaks had. At that time, an attempt was made to obtain

22 weapons. Serbs themselves were selling trophy weapons at high prices,

23 those that they had been issued themselves, the so-called Dobosari, the

24 PAP rifles, and they were selling them at a high price to Bosniaks. But

25 this was only done by people who wanted to earn a profit in this way.

Page 20510

1 Q. Sir, I'm going to ask you to now take a look at Prosecution

2 Exhibit 443, tab 3. It's a book of minutes.

3 MR. GROOME: I would note for the Chamber that I will simply be

4 seeking to mark this for identification and complete its foundation with

5 another witness.

6 Q. Sir, this document, it's a lengthy document, purporting to be a

7 book of minutes of meetings held in Bratunac. Have you had, in the last

8 few days, an opportunity to read this book of minutes thoroughly?

9 A. This is a book of minutes on the establishment of the illegal

10 Assembly of Bratunac, that is to say, of the Serb Municipality of

11 Bratunac.

12 Q. Did you have a chance to read the events -- read the book of

13 minutes and the events described in it?

14 A. Your Honours, I did not have an opportunity of seeing this minutes

15 earlier, but I do know that a Serb Municipality of the Municipality of

16 Bratunac was established in December 1991. The government -- or rather,

17 the executive committee --

18 JUDGE MAY: Could you please, Mr. Becirevic, just concentrate on

19 what counsel is asking you and just limit your questions -- your answers,

20 if you would, to those questions.


22 Q. Earlier this week, did you have an opportunity to read what you

23 have before you now?

24 A. Your Honours, yes.

25 Q. Of the events described in that book of minutes of which you have

Page 20511












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 20512

1 personal knowledge, are they accurately reflected?

2 A. Yes, they are fully well-described here, because I knew, Your

3 Honours, that the SDS had established a Serb Assembly of Bratunac --

4 Q. Sir --

5 A. -- as well as a government --

6 Q. -- I want to now draw your attention -- in your statement you talk

7 about JNA military presence in Ljubovija. My question to you is: Were

8 you able to see the military resources assembled in Ljubovija? And if so,

9 could you please describe with as much detail as possible what those

10 resources were.

11 A. Your Honours, I personally saw artillery being positioned on the

12 other side of the Drina, in the region of Ljubovija, namely, in the region

13 of Krs. These were tanks, Howitzers, and other heavy artillery pieces

14 whose barrels were aimed at the municipality of Bratunac in

15 Bosnia-Herzegovina, and this was common knowledge among all the citizens

16 of the municipality of Bratunac. Everybody could see this with their very

17 own eyes, and so could I, since I worked --

18 Q. Can you please approximate for us the number of tanks that you saw

19 and the number of Howitzers that you saw.

20 A. Your Honours, at Krs itself, which is 2 kilometres away from

21 Bratunac on the other side of the Drina, only at one place there were at

22 least two heavy weapons, a tank and an APC, with their barrels pointing at

23 settlements in the Bratunac municipality. At another point, facing

24 Voljavica and Bjelavica, there were a few artillery pieces whose barrels

25 were pointing at Bratunac and the settlements around Bratunac.

Page 20513

1 Q. I'd like to now draw your attention to March of 1992. During that

2 period of time, did you become aware that members of the Serb community

3 were being secretly trained in military matters by the Yugoslav People's

4 Army?

5 A. Your Honours, I knew that full well because I had that type of a

6 job. Citizens who were Bosniaks came to see me every day, and they

7 expressed their dissatisfaction over the fact that training was taking

8 place in the village of Vranesevici, training of Serb forces by officers

9 of the Yugoslav People's Army. After such pressures exerted upon the

10 leadership of the Bratunac municipality by the citizens - and I was part

11 of the leadership - I and the president of the municipality of Bratunac,

12 the Municipal Assembly of Bratunac, personally went to the corps command

13 of the Yugoslav People's Army in Tuzla and we asked the commander,

14 Jankovic, and his assistant to tell us what kind of unit this was and also

15 what the possibilities were for having it removed from that village.

16 Q. When you went to the headquarters of the Tuzla Corps, who

17 specifically did you speak with?

18 A. Specifically we talked to Jankovic. We were received by Jankovic

19 and his assistant Gavric, who I personally knew from earlier on, because

20 he came to see me at the secretariat when he came to mobilise wartime

21 units that he needed in 1991 for the war in Croatia.

22 Q. What did they tell you in response to your complaint about the

23 secret training by the officers of the JNA?

24 A. They said to us, quite literally, Your Honours, that right then

25 they didn't know what kind of unit this was and that they, within two

Page 20514

1 days, would send two officers, Sadic and Simic, to come to Bratunac and to

2 go to the actual site with us so that we would inspect this locality and

3 see what kind of unit this was. Two days later, when they were supposed

4 to come to Bratunac, they simply didn't show up. We telephoned them. The

5 president spoke personally, and I was right next to him in his office

6 because I was greatly interested in this. Gavric answered the telephone

7 and he said that they had established that this was not any unit from the

8 area of responsibility of the Tuzla Corps or was it a unit from the

9 Sarajevo-Romanija Corps of the JNA. Rather, this was a unit that had come

10 from Yugoslavia, and they had no authority whatsoever over that unit and

11 they could not help us on that score.

12 Q. Sir, the area where this training was being conducted, was it

13 under the area of responsibility of the Tuzla Corps?

14 A. Yes, this was in the area of responsibility of the Tuzla Corps,

15 but before the war there had never been any JNA unit stationed there.

16 Q. Sir, I'm now going to ask that you take a look at a series of two

17 documents that were generated in the third week of April 1992. The first

18 one is Prosecution Exhibit 443, tab 4. I'm going to ask that you read two

19 sentences, first a sentence under number 1 and then the sentence under

20 number 3, and then comment on that.

21 A. Your Honours, this is an order on the establishment of Territorial

22 Defence staffs that was signed by the Crisis Staff of the Serb

23 Municipality of Bratunac. Article 1: "Defence tasks in the territory of

24 the Serbian Municipality of Bratunac shall be taken over by the

25 Territorial Defence of the Serb Municipality of Bratunac."

Page 20515

1 3: "All decisions related to the use of the Territorial Defence

2 shall be made by the Crisis Staff upon suggestions made by the commander

3 of the Serbian Territorial Defence."

4 My comment would be as follows, Your Honours: At that time, I was

5 in the municipality of Bratunac. I worked there. I worked there until

6 the 17th of April, 1992, and I did not have an opportunity of

7 familiarising myself with this document; that is to say, that all of this

8 was done secretly at the time.

9 Q. Sir --

10 A. This --

11 Q. -- based upon your observations and experience from that time

12 period, is there a connection between what's contained in this document

13 and the training of people by the JNA that you've just described?

14 A. Your Honours, it can be seen indeed that there is a link between

15 the training that was being carried out in Vranesevici and this order that

16 was issued by the Crisis Staff of the Serb Municipality of Bratunac.

17 Q. Sir, I'm going to ask you now to take a look at a document from

18 the 16th of April, 1992. It's tab 5 of Prosecution Exhibit 443. I'd ask

19 you to take a look at this document. I'd ask you: Do you recognise the

20 seal on the document? And then finally, if you would summarise its

21 contents for us.

22 A. Your Honours, I did not have the opportunity of seeing this

23 document before either, but I can state here that I am familiar with the

24 stamp affixed by the Serb Municipality of Bratunac, this Serb Municipality

25 being established in December 1991 although there was a legal Municipal

Page 20516

1 Assembly of Bratunac. This means that by this order everything had been

2 prepared in order to occupy Bratunac, and the actual occupation took place

3 a day later.

4 Q. Would I be correct in saying that this document deals with the

5 mobilisation of members of the Serb community to create a defence force?

6 A. The first item here shows that a decision was passed on the

7 general mobilisation of the Serb people. And this was done on the basis

8 of a decision of the Presidency of the Serb people of the Republic of

9 Bosnia-Herzegovina, so the staff or the Serb Municipality proclaimed

10 general mobilisation on that day for all citizens who were ethnic Serbs

11 and who were of age.

12 Q. Sir, you just referred to a takeover, I believe, on the next day.

13 So I would draw your attention now to the 17th of April. Can you describe

14 -- did there come a time during the course of that day that you saw men

15 you believed to be members of Arkan's Tigers?

16 A. Your Honours, on the 17th of April, 1992 I went to work and I

17 arrived in the Municipal Assembly of Bratunac, that is to say, that I had

18 intended to work on that day, to continue working. As I was passing by

19 Fontana in Bratunac, I noticed some people who I did not know and who were

20 armed. However, before that, on TV, I saw the occupation of Bijeljina on

21 the 31st of March, 1992 and Zvornik on the 8th of April, 1992, so I

22 noticed paramilitary formations that had come from Serbia. These were

23 Arkan's men, Seselj's men, and members of the Yugoslav army. That is to

24 say, that there were three types of uniforms and men wearing these

25 uniforms were guarding the entrance to the Fontana Hotel. I asked around

Page 20517

1 and I established that a meeting was being held there regarding the

2 surrender of the municipality of Bratunac, and the legal organs of the MUP

3 of Bosnia-Herzegovina were also supposed to hand over the municipality of

4 Bratunac to these paramilitaries who had come from Serbia. They had

5 different insignia. I noticed --

6 JUDGE MAY: Just wait a minute. We have read your statement, Mr.

7 Becirevic, and counsel are just asking you some additional questions, So

8 just wait until he asks you.

9 Yes.


11 Q. Sir, I want to ask you: Of the paramilitary units that you are

12 describing as being from Serbia, can you simply just list the ones that

13 you were able to recognise.

14 A. That's right. That's right. Your Honours, I recognised Arkan's

15 men, Seselj's men, and there were some people who were wearing the

16 uniforms of the Yugoslav People's Army.

17 Q. The three groups that you have mentioned, were they intermingled

18 among each other or did they seem to be separate in their location and in

19 their interaction?

20 A. Your Honours, they were intermingled. Their objective was to

21 guard the people who were attending the negotiations, the meeting, at the

22 Fontana Hotel.

23 Q. Around this time period, were you shown a copy of a proclamation

24 of -- relating to what was going on in Bratunac?

25 A. Your Honours, I had the opportunity of receiving a copy of this

Page 20518

1 proclamation issued by the Yugoslav People's Army. The proclamation said

2 that the legal authorities are being respected and that all faiths are

3 being respected. An ironical sentence was added, that one loves one's

4 brother no matter what faith that brother has.

5 What was also asked for was the surrender of weapons, the

6 surrender of weapons by Bosniak paramilitaries, the way they called them,

7 Bosniak paramilitary forces --

8 Q. Sir --

9 A. -- the signature said.

10 Q. -- I'd like to now ask that you take a look at Prosecution Exhibit

11 443, tab 6. This document concerns the disarming of citizens. My

12 question to you is: Do you recognise the signature on this document?

13 A. Your Honours, this signature is one I cannot recognise. However,

14 I know that such a decision was passed on the disarming of citizens who

15 possess weapons, citizens of the municipality of Bratunac. This was

16 issued by the Crisis Staff of the Serb Municipality of Bratunac.

17 Q. And around this time period, were there activities by the forces

18 -- the Serb forces in town consistent with disarming of -- the disarming

19 of the Muslim community? Simply yes or no, if possible.

20 A. Your Honours, yes. Yes.

21 MR. GROOME: I'm going to now ask that the witness be shown tab 7

22 of Prosecution Exhibit 443.

23 Q. Sir, this is another document related to Bratunac, issued on the

24 16th of June, 1992. I'd ask you to look down the names listed on this

25 document, and if you would identify which names you are familiar with and

Page 20519

1 which names you -- if there are any that you are not familiar with, please

2 indicate.

3 A. Your Honours, there are five names here. Of those, I know number

4 2, Miroslav Deronjic, number 3, Zoran Tesic - he was the secretary of the

5 SDS - I know Jovan Nikolic, and Stanko Petrovic. So the four of them, I

6 knew them all personally. I cooperated and worked with them. As for the

7 first name, Dragan -- Dr. Dragan Djokanovic, I never saw him.

8 Q. Sir, this document concerns the establishment of a Municipal War

9 Presidency. To your knowledge, was such a War Presidency established in

10 Bratunac?

11 A. Yes. I do know that a War Presidency was set up by the Serb

12 Municipality of Bratunac.

13 Q. Sir, I'd ask you now to take a look at tab 8 of Prosecution

14 Exhibit 443. It's a document dated the very next day, the 17th of June,

15 1992. Would you tell us who is the author of this document.

16 A. Your Honours, the author of this document is the president of the

17 Presidency, Dr. Radovan Karadzic. And he confirms the appointment of the

18 members of the War Presidency for the Serbian Municipality of Bratunac by

19 way of this document.

20 Q. Sir, on the 17th of April, 1992, is it true that you left the town

21 of Bratunac and went to Konjevic Polje, where you remained until the 15th

22 of March, 1993?

23 A. Your Honours, on that particular day, when I saw what was going on

24 in Bratunac, that the units had turned up there, I barely managed to

25 escape and went to my native Konjevic Polje area, where I stayed until the

Page 20520

1 15th of March, 1993.

2 Q. Now, sir, your statement deals in some detail with the events of

3 Glogova. My question to you is: After what happened in Glogova, was

4 there an event in Konjevic Polje where members of Koljevic -- or people in

5 the community of Konjevic Polje blocked JNA forces as they were attempting

6 to leave Bosnia? If so, I'd ask you to briefly describe what occurred

7 between the people of Konjevic Polje and the JNA.

8 A. Your Honours, we received an order to the effect that the Konjevic

9 Polje-Bratunac road, or Konjevic Polje-Drinjaca road be kept open up until

10 the 19th of May, 1992 -- or rather, this period of time was pinpointed by

11 the Presidency of Bosnia-Herzegovina and was extended for a three-day

12 period. So we kept the road open, in fact, until the 22nd of May, 1992.

13 Q. And on the 22nd of May, 1992, did you and other members of your

14 community block the road to passing JNA traffic?

15 A. We did not block the road on the 22nd because the JNA had already

16 left Central Bosnia-Herzegovina and was moving towards Serbia. However,

17 many units stayed behind. They just changed their insignia. They stayed

18 behind on the territory of Bosnia-Herzegovina to fight there.

19 Q. Did there come a time when a blockade was set up in Konjevic

20 Polje?

21 A. Yes.

22 Q. On what day?

23 A. Your Honours, at one particular point -- or rather, on the 22nd --

24 JUDGE MAY: You were asked -- just listen to what counsel ask.


Page 20521

1 Q. On what date, sir?

2 A. The 29th was when the road was closed, the 29th of May, 1992.

3 Q. Would it be fair to say that, in the months following this, that

4 there was substantial fighting and attacks in the area of Konjevic Polje?

5 A. Your Honours, yes, that is right. There was substantial fighting

6 in the area.

7 Q. During the course of this fighting, did you have opportunity to

8 see aircraft involved in this fighting?

9 A. Your Honours, planes belonging to the Yugoslav People's Army

10 overflew the area on a daily basis and shelled the area with heavy bombs

11 that were referred to as Krmace in Konjevic Polje, Cerska, and Kamenica,

12 which made a separate enclave surrounded on all sides.

13 Q. During this time period after the official withdrawal of the

14 Yugoslav People's Army, were you aware of participation in these -- in

15 these war activities by members of the now renamed Yugoslav Army?

16 A. Yes, Your Honours, I was aware of that. I knew that those units

17 had just changed their uniforms, or rather, insignia, but that they had

18 the weapons they did before to carry on the war in Bosnia-Herzegovina, to

19 attack the territory of Konjevic Polje.

20 Q. During this period of time, were there any other units that you

21 could identify or wore some distinctive uniform that you could see?

22 A. During the attack, Your Honours, of the area around Konjevic

23 Polje, Cerska, and Kamenica, in addition to the Yugoslav People's Army

24 units and the local Serb units, also taking part in the area were the

25 so-called Red Berets, or rather, Arkan's and Seselj's men, and they were

Page 20522












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13 English transcripts.













Page 20523

1 fighting to gain control of the area.

2 Q. I want to now draw your attention to January of 1993. Was there a

3 major offensive by Serb forces during that time period in the Bratunac

4 area?

5 A. Your Honours, the Serb forces launched an all-out heavy offensive

6 in the free areas of Bratunac and Srebrenica from the 13th of January

7 onwards right up until the 17th of April, 1993, when the territory was

8 occupied and the people forced to withdraw to the Srebrenica enclave.

9 Q. Were you able to learn from where the forces that were -- you were

10 opposing, where they were coming from?

11 A. Your Honours, I was able to learn this, that the units in fact

12 were coming from Serbia and that they had crossed the bridge at Zvornik,

13 they had crossed the bridge, the Ljubovija bridge at Bratunac, they had

14 also crossed the bridge at Bajina Basta, so that from three flanks, three

15 corps arrived and, together with the forces of the Bosnian Serbs, they

16 attacked the free territory of the Army of Bosnia-Herzegovina.

17 Q. During this time period, did you see aircraft involved? If so,

18 would you describe the type of aircraft for us.

19 A. Yes, Your Honours, I did see aircraft flying over the area from

20 the direction of Serbia, and they were shooting and targeting the free

21 territory at random, which was Konjevic Polje and Cerska at that time, and

22 similarly they used helicopters who were flying at a very low altitude

23 and, with guided missiles and bombs, they targeted the positions of the BH

24 army.

25 Q. And I want to now move on to March of 1993. Did there come a time

Page 20524

1 when the Serb forces were successful and the members of the Muslim

2 community in this pocket, as well as the soldiers defending them, withdrew

3 to the area of Srebrenica?

4 A. Your Honours, the civilians from Cerska Kamenica gathered together

5 in Konjevic Polje, and all of them after that were forced to withdraw in

6 the direction of Srebrenica, and that was on the 15th of March, 1993.

7 Q. Can you tell us approximately how many civilians were in this

8 group?

9 A. Your Honours, from Cerska and Kamenica, about 5.000 civilians came

10 in. And from Konjevic Polje, at least 5.000 civilians had to withdraw as

11 well, so that from these three enclaves, there were at least 10.000

12 civilians who were having to be on the move towards Srebrenica.

13 Q. And in this group, how many soldiers were -- were part of that

14 group?

15 A. Your Honours, in that group were the remnants of the BH army, the

16 stragglers who were broken up by the enemy forces, and there were

17 approximately 100 to 150 people holding this line for the civilians to

18 ensure that they did not remain in the encirclement.

19 Q. Sir, I'm going to now ask you -- moving to a different subject,

20 ask you to take a look at Prosecution Exhibit 443, tab 10. It will be

21 displayed on the television monitor in front of you.

22 Do you recognise the site depicted in this photograph?

23 A. Your Honours, yes, I do recognise this. These are the grounds of

24 a religious site, the mosque, in fact, in Konjevic Polje, my native town.

25 And the mosque itself in the course of 1993, more exactly on the 15th of

Page 20525

1 March of that year, without any reason whatsoever was destroyed by tanks.

2 It was attacked. And quite simply, it was attacked and targeted by tank

3 shells and grenades. Two or three months later, when I went back to my

4 native town, all I saw was a mass of rubble. That was all that was left

5 of the mosque.

6 Q. Sir --

7 A. It was in ruins. And what I can see here now on the photograph --

8 Q. -- were you present when this mosque was fired upon?

9 A. Your Honours, I was present -- actually, I was just a couple of

10 hundred metres away when the tanks arrived, to within 50 metres of the

11 mosque, and they pointed their barrels in the direction of the mosque and

12 started shooting at the mosque, and it was bullet-ridden by these shells

13 from the tank.

14 Q. The tanks that damaged the mosque, were you able to identify what

15 unit or what army they were from?

16 A. Your Honours, they were tanks belonging to the Yugoslav People's

17 Army. They were olive-green in colour, and they were tanks which we

18 referred to as the 84s, the tank 84.

19 Q. When did you observe these tanks fire upon the mosque?

20 A. Your Honours, the date was the 15th of March, which was the last

21 time we were in the area, on the 15th of March, 1993.

22 Q. Now, at that time, the Yugoslav People's Army no longer existed.

23 It had divided into two armies. This particular tank that you saw fire at

24 the mosque, which of the two armies formerly known as the Yugoslav

25 People's Army, did it belong to?

Page 20526

1 A. The tank belonged to the joint forces who were attacking Konjevic

2 Polje, that is to say, the Yugoslav army and the Bosnian Serb forces.

3 They pooled their efforts to attack Konjevic Polje, so it belonged to both

4 of them.

5 Q. Sir, now, you -- you said that this group of people moved to

6 Srebrenica. Can you tell us the date on which you arrived in Srebrenica?

7 A. Well, I left on the 15th of March, 1993, and the next day, the

8 16th, I was in the centre of town of Srebrenica, together with all the

9 other people that had come in from the surrounding areas.

10 Q. Not counting the 10.000 people that you've told us went to this

11 area, can you approximate for us how many people were in Srebrenica when

12 you arrived.

13 A. Your Honours, in Srebrenica there were at least 40.000 civilians

14 who had congregated there from all occupied territories around Srebrenica,

15 and all of them came to that small space of several kilometres.

16 Q. Can I ask you to briefly describe the living conditions in

17 Srebrenica at that period of time.

18 A. Your Honours, at that time when I arrived in Srebrenica, quite

19 literally the people were out on the streets. They were lying around,

20 women, children. At every 10 metres somebody had made a fire because it

21 was cold. The weather was cold and people tried to keep warm by making

22 fires. There was not enough room to put up these people anywhere in the

23 buildings because most of the residential buildings had been destroyed

24 anyway. So Srebrenica had no water at that time, no electricity, because

25 the inflow of water and electricity had been cut off by the aggressor

Page 20527

1 forces.

2 Q. Now, during the period of time when you were in Srebrenica

3 enclave, can you describe for us what knowledge you have with respect to

4 humanitarian convoys destined for Srebrenica and whether or not they were

5 able to reach Srebrenica.

6 A. Your Honours, upon my arrival in Srebrenica, I learnt that before

7 that they had managed to bring in two or three convoys of humanitarian

8 aid. When we arrived on the scene, several more convoys arrived, and two

9 and a half thousand civilians were leaving towards Tuzla. But those

10 convoys, the ones that were supposed to arrive after the demilitisation of

11 Srebrenica, at least once a week, they were stopped by the Serbian forces

12 at Bratunac and Ljubovija and they were not permitted free passage to

13 Srebrenica to bring in the food, clothing, and everything else that the

14 people needed there, because the people were quite literally hungry in

15 Srebrenica.

16 Q. Sir, just to clarify a point in that last answer. Convoys taking

17 people from Srebrenica out in the direction of Tuzla, were they stopped or

18 were they allowed to pass?

19 A. Well, the convoys were stopped, and the aid did not reach

20 Srebrenica. From some other convoys that had --

21 Q. Sir, I'm asking you about the outgoing convoys carrying people

22 from Srebrenica to the area of Tuzla. Were those convoys impeded or

23 prevented from leaving Srebrenica?

24 A. As far as those convoys were concerned, outgoing convoys, they

25 were not stopped by the Serb forces. However, the civilians in Srebrenica

Page 20528

1 did stop the convoys because they endeavoured at any price to become part

2 of the convoys and leave Srebrenica. So it was the civilians that stopped

3 the convoys, civilians wanting to flee the area.

4 Q. Sir, would I be correct in saying that from April 1993 until the

5 beginning of 1995, that military activity in the area of Srebrenica was at

6 a minimum, compared to what it was at other times?

7 A. Your Honours --

8 JUDGE MAY: I'm trying to follow that. Military activity by who

9 do you mean?

10 MR. GROOME: By both forces. I guess --

11 JUDGE MAY: Fighting you mean.

12 MR. GROOME: Fighting, yes.

13 Q. What was the level of fighting between that period -- or comparing

14 that period to before April 1993 and after the start of 1995?

15 A. Your Honours, yes. The fighting was of low intensity. There was

16 hardly any fighting at all, actually, except for a few sporadic incidents

17 that took place.

18 Q. Was there a change in this at the beginning of 1995?

19 A. Your Honours, at the beginning of 1995, there was constant

20 provocation from the units who held Srebrenica in an encirclement, under

21 siege. Reconnaissance took place every day by the airplanes that flew

22 overhead from the direction of Serbia, and there was systematic

23 preparation for the ultimate and final occupation of Srebrenica.

24 Q. Did there come a time when you and a large group of other men in

25 Srebrenica make a decision to leave the enclave?

Page 20529

1 A. Your Honours, yes. That happened on the 11th of July, 1995, when

2 there was no saving Srebrenica or the people in it. And we took that

3 decision. We decided to try on that day to break through from Bulja

4 [phoen] towards Tuzla through hostile enemy territory.

5 Q. What did you fear would happen if Srebrenica fell?

6 A. Your Honours, first of all, I myself and my fellow fighters were

7 afraid that if we fell into enemy hands we would be liquidated straight

8 away, summarily, without any court or trial. And that's why we decided --

9 Q. Sir, this fear, was it based on any factual event that had

10 occurred prior to this time?

11 A. Your Honours, it was precisely our fear that was based on the

12 events that had taken place in April and May 1992, previous events, when

13 the enemy forces of the aggressor from Serbia stormed Bratunac and,

14 without a single bullet having been fired on the Bosnian side, in just the

15 space of a month and a half, about 1.000 civilians were killed, women and

16 children, in Bratunac. And in the Vuk Karadzic school itself, 500

17 civilians. And we knew very well that if that's the fate they suffered,

18 people who had given no resistance at all, we could only imagine what

19 would happen to us after having fought for three or four years.

20 Q. Can you approximate for us how many people were in the column of

21 -- that accompanied you.

22 A. Your Honours, it is my rough estimate that the column numbered

23 between 15 -- 12 to 15 thousand men, and it stretched for about 10 to 15

24 kilometres in its movement towards Tuzla.

25 Q. Sir, I'm going to ask you -- or I will conclude my questions to

Page 20530

1 you by asking you just to simply look at some photographs which will be

2 displayed on the monitor in front of you.

3 The next one is Prosecution Exhibit 443, tab 8. Do you recognise

4 the -- or, I'm sorry, tab 9. Do you recognise what's depicted in that

5 photograph?

6 A. Your Honours, I do recognise this photograph. It is a religious

7 site, a mosque, in fact, that was in Glogova. And it was destroyed and

8 brought into the aspect you see it now between the 9th and 10th of May,

9 1992.

10 Q. And finally, sir, I'd ask you to take a look at an exhibit

11 previously tendered. That exhibit is Prosecution Exhibit 440, tab 3. Do

12 you recognise the location depicted in this photograph?

13 A. Your Honours, yes, I do. I recognise this photograph too. Once

14 again, it is a religious site, a mosque, which before the war was situated

15 in Bratunac, the centre of town in fact, and it is no longer in existence

16 today.

17 MR. GROOME: Your Honour, I have no further questions. In the

18 interest of time, I did not work with all of the exhibits. Perhaps at the

19 end of the cross-examination, I could advise the Court which exhibits we

20 would seek to withdraw.

21 JUDGE KWON: Before the cross-examination, I have one question to

22 the Prosecution.

23 If the usher can kindly put two B/C/S versions of tab 8, of this.

24 The English version of this tab, at the end of it, it says ERN number 3134

25 is a copy of the same document.

Page 20531

1 Put two so that we can see the two pages at the same time. This

2 is the confirmation of war commission by Mr. Karadzic. But if you look at

3 those two pages, the document number, which is handwritten, looks

4 different, and the signature of Mr. Karadzic is different, and the stamp

5 is different. If you help us with that, help us why there should be two

6 versions of the B/C/S version and why Mr. Karadzic signed twice.

7 MR. GROOME: Your Honour, I'm not sure --

8 JUDGE KWON: You can tell us later, after the adjournment.

9 MR. GROOME: Yes. I'd look into the providence of the documents

10 and report to the Court.


12 [Trial Chamber confers]

13 JUDGE MAY: Yes. Let the usher return.

14 What we'll do is this: We started a quarter of an hour later

15 today, so we'll sit throughout the day a quarter of an hour later.

16 Yes, Mr. Milosevic. You've got a quarter of an hour or so before

17 the adjournment.

18 THE ACCUSED: [Interpretation] Let us just clear up one thing

19 before, Mr. May. This witness was introduced yesterday as a 92 bis

20 witness; is that right?

21 JUDGE MAY: Yes.

22 THE ACCUSED: [Interpretation] And as you see, in addition to the

23 fact that he was introduced together with all these papers as a 92 bis

24 witness, he was examined, according to your mathematics, for an additional

25 hour and a half. How much time will you give me?

Page 20532

1 JUDGE MAY: He was examined for an hour and ten minutes, in fact.

2 We'll take that into account. Just let me consider for a moment.

3 [Trial Chamber confers]

4 JUDGE MAY: Yes. Two hours.

5 Cross-examined by Mr. Milosevic:

6 Q. [Interpretation] Mr. Becirevic, according to the information that

7 you referred to, you in fact convened the Initiative Board for the

8 establishment of the SDA in Bratunac; is that right?

9 A. Yes.

10 Q. Was that meeting held in June 1990 in Voljavica in the reading

11 hole of the Podrinje club? Tell me just yes or no.

12 A. Yes.

13 Q. Is it correct that the Initiative Board, in addition to you and

14 the people you already enumerated, consisted of the chief Imam of the

15 Bratunac community, Mustafa Mujkanovic, as well as Nezid Muratovic,

16 professor of history from Trban [phoen], you said also another man,

17 Semsudin Durakovic, construction engineer, Hasan Smailovic, director of

18 the veterinary station, Safet Dzanic, Mehmetovic, Abid Sirucic, Hasim

19 Ibrahimovic from Bleceva [phoen], Azem Dzanic from Bratunac; is that

20 correct?

21 THE INTERPRETER: The interpreter missed a couple of names.

22 THE WITNESS: [Interpretation] Yes, I mentioned most of them

23 already in my testimony.

24 MR. MILOSEVIC: [Interpretation]

25 Q. Did I make any mistake in listing the names?

Page 20533












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 20534

1 A. You made a slight mistake in the names.

2 Q. You mean in the pronunciation?

3 A. Yes.

4 Q. How about this chief, Imam Mujkanovic? Was he there together with

5 you?

6 A. Yes.

7 Q. Speak up, please. How did you fail to mention such a prominent

8 member of the board?

9 A. I didn't do it deliberately. I may not have recalled him at the

10 moment. There is no dispute about that.

11 Q. I know you didn't do it deliberately.

12 Is it true that the founding assembly of the SDA in Bratunac - we

13 were talking about the Initiative Board until now - was held on the 1st

14 September, 1990, nine-zero, at the town stadium, in front of 10.000

15 people? Is that correct?

16 A. Yes. There's no mistake there.

17 Q. Is it also true that you were the general secretary of the SDA of

18 Bratunac? Correct?

19 A. Correct.

20 Q. Is it correct that you were a member of the War Presidency for the

21 Bratunac municipality and that you became president at a meeting held in

22 Konjevic Polje on the 16th of July, 1992?

23 A. Correct, but it happened only after the crimes committed in

24 Bratunac.

25 Q. I want just yes or no answers in order not to waste time. We'll

Page 20535

1 see about the crimes later.

2 Is it true that you were the president of the War Presidency in

3 Bratunac?

4 A. I was president of the War Presidency for Konjevic Polje, not

5 Bratunac.

6 Q. But you were the president of the War Presidency personally.

7 A. Yes, but for Konjevic Polje.

8 Q. Is it true that in 1992 you were personally and very directly

9 involved in the formation of the Patriotic League in Bratunac?

10 A. That's not correct.

11 Q. Fine. Is it true that the Patriotic League, Patriotic People's

12 League was established in February 1992 at a meeting held at the local

13 commune of Voljavica which you attended and were involved in the work of

14 the Presidency. Is that correct?

15 A. That's true. I attended.

16 Q. So you were there when the Patriotic League was formed in February

17 1992 and you said a moment ago you were not involved in its establishment.

18 A. I attended the meeting.

19 Q. As an observer?

20 A. I attended more as an observer.

21 Q. But also president of the War Presidency.

22 A. I wasn't in that job at the time.

23 Q. Is it true that after the establishment of the Patriotic League,

24 together with Captain Velid Sabic, former officer and deserter from the

25 JNA, you embarked upon the setting up of the Patriotic League for Konjevic

Page 20536

1 Polje?

2 A. Yes. We were forced to do it.

3 Q. I'm not going into what you were forced to do and what you

4 weren't. Serbs too may have been forced to defend themselves but you have

5 another explanation nevertheless.

6 Is it true that that man became chief of staff and you became

7 assistant?

8 A. Correct.

9 Q. Is it true on the 8th of April, 1992 you transferred all the

10 powers in Konjevic Polje to the so-called Konjevic Polje Crisis Staff?

11 A. Correct.

12 Q. Is it true that immediately after the establishment of the Crisis

13 Staff, you set up a group of volunteers which you sent to Kula Grad in

14 Zvornik to fight Serbs?

15 A. It was only an attempt to help the people who were trying to

16 defend --

17 Q. Give me just yes or no answers, because you gave an oath here and

18 I heard that you were a lawyer. Is it true you set up a group of

19 volunteers you sent to Kula Grad to fight Serbs?

20 A. I was one of the organisers.

21 Q. One of the organisers. Okay. Is it true that on the 15th of

22 April, 1992 you put yourself at the disposal of the Armed Forces of the

23 BH, Bosnia and Herzegovina?

24 I apologise to the interpreters. I was just warned. I'll repeat

25 my question.

Page 20537

1 Is it true that on the 15th of April, 1992 you put yourself at the

2 orders and service of the armed forces of the Republic of Bosnia and

3 Herzegovina? Is that correct, the date?

4 A. The date is formally correct, but in actual fact, this happened

5 later.

6 Q. So we have a formal date and an actual date.

7 A. It actually happened on the 27th.

8 Q. Okay. Tell me, is it true that as a major of the Army of Bosnia

9 and Herzegovina, you occupied the position of assistant commander for

10 morale and religious affairs in the 8th Operative Group of Srebrenica?

11 A. That is not true. I never held that rank in the army.

12 JUDGE MAY: It's been put that you were a major. Is that part

13 correct or not?

14 THE WITNESS: [Interpretation] That's not correct, Your Honours.

15 MR. MILOSEVIC: [Interpretation]

16 Q. Very well. Were you assistant commander for morale and religious

17 affairs in the 8th Operative Group of Srebrenica?

18 A. I was not assistant commander in the 8th Operative Group. I was

19 assistant commander in a brigade. That's quite a difference.

20 Q. Assistant commander for what, for religious issues?

21 A. For morale and religious issues.

22 Q. I'll tell you later about what that involves. Were you under the

23 direct command of Naser Oric?

24 A. I wasn't under his direct command. I was under the direct command

25 of Veiz Sabic.

Page 20538

1 Q. All right. I will give you an exhibit. First of all, I'll read

2 this out, and this is an exhibit, the document I got from the opposite

3 side, numbered 01837194, Opinion and Proposal of the Commander of the 8th

4 Operative Group of Srebrenica. And it says in the document: "Dzemail

5 Becirevic put himself at the disposal of the Armed Forces of Bosnia and

6 Herzegovina as of the 15th of April, 1992." It says "15/4/92." I'm

7 reading "April." "Engaged in the armed forces of the RBH as of the 16th

8 of April, 1992, occupied the position of assistant commander for morale,

9 LPD, and religious issues. He is hereby admitted into active military

10 duty, and I hereby propose that he be promoted into major. He deserves

11 special credit for resisting the enemy together with Veiz Sabic. During

12 the war, he occupied the position of president of the Presidency of -- the

13 War Presidency of Konjevic Polje from July 1992 to January 1993, whereas

14 on the 23rd of January, 1994 he was elected president of the local

15 commune."

16 JUDGE MAY: Mr. Milosevic, it's impossible for him to take all

17 that in. Let him look at the document.

18 THE ACCUSED: [Interpretation] You could also put it on the -- oh,

19 I see Mr. Groome already has it.

20 THE INTERPRETER: The interpreters would also be grateful to have

21 it somewhere.

22 JUDGE MAY: Do you have a copy for the interpreters? So much the

23 better, but I suspect we haven't. We've got not a copy for anybody.

24 Just have a look at that, Mr. Becirevic, and tell us about it.

25 Just let the witness see it and then it can be put on the ELMO.

Page 20539

1 Yes.

2 THE ACCUSED: [Interpretation] Can we go on?

3 JUDGE MAY: No. Wait a minute. Can you help us about that

4 document?

5 THE INTERPRETER: Microphone for Judge May, please.

6 JUDGE MAY: I'm sorry. Can you help us with that document?

7 THE WITNESS: [Interpretation] Your Honours, I put myself at the

8 disposal of the Army of Bosnia and Herzegovina on the 27th, not the 15th

9 of April, 1992. And as for these positions that I occupied in Konjevic

10 Polje, none of that is in dispute. In Srebrenica --

11 JUDGE MAY: Yes, go on. In Srebrenica ...?

12 THE WITNESS: [Interpretation] In Srebrenica, I was assistant

13 commander for morale and religious issues in the 284th East Bosnian Light

14 Brigade, which acted on the axis of Konjevic Polje to Cerska Kamenica.

15 Those were my responsibilities in that brigade.

16 MR. MILOSEVIC: [Interpretation]

17 Q. What was the strength of that brigade?

18 A. That brigade had about 1.000 men on paper. Out of that number,

19 one in three or four men had a weapon.

20 Q. We've already heard similar descriptions. I don't know what you

21 used to kill all those Serbs and raze so many Serb villages to the ground

22 if only one in three or four of you was armed,

23 JUDGE MAY: No. Wait a minute. I just want to clarify this

24 document you've shown the witness.

25 What is that document, Mr. Becirevic? Can you help us as to what

Page 20540

1 it is?

2 THE WITNESS: [Interpretation] Believe me, Your Honours, I see this

3 for the very first time. I can see the signature of the commander of the

4 8th Operative Group, but I don't remember that I personally proposed

5 myself for promotion into whatever rank. I was, by rank, senior

6 lieutenant, and in order to be promoted, I either had to apply first or

7 somebody had to propose me for promotion into major.

8 THE ACCUSED: [Interpretation] All right, Mr. May. Since this is a

9 document of their 8th Operative Group signed by Naser Oric, I think it can

10 be admitted as an exhibit, unless you absolutely refuse.

11 JUDGE MAY: Yes. We will admit that as an exhibit. If the usher

12 would like to go and get it, yes. Give it the next number, please.

13 THE REGISTRAR: Defence Exhibit 129.

14 JUDGE KWON: It should be 131, in my calculation.

15 THE REGISTRAR: You're correct, Your Honour. Defence Exhibit 131.

16 MR. MILOSEVIC: [Interpretation]

17 Q. This morning, in this abbreviated examination-in-chief, but also

18 on page 6 in paragraph 5 of your statement, you describe how on the 17th

19 of April, 1992 outside Fontana Hotel in Bratunac you saw some "Arkan's

20 men, Seselj's men wearing special uniforms --" I'm reading from your

21 statement. Let me look up this page 6 of your statement because --

22 "I saw three soldiers outside the entrance, their guns at the ready,

23 wearing special uniforms, bandannas," and so on. How come you're saying

24 today, since you claim you saw some paramilitaries, how do you know who

25 they were and how come you are mentioning JNA as well today, which is not

Page 20541

1 in the statement?

2 MR. GROOME: Your Honour, I'd ask that the statement be put before

3 the witness. He does identify the members of that paramilitary group in

4 his statement.


6 JUDGE KWON: If you could give the number of the paragraph.

7 MR. GROOME: It is paragraph 20 on the numbered version, Your

8 Honour.

9 MR. MILOSEVIC: [Interpretation]

10 Q. All right. Let's move on.

11 JUDGE MAY: No. Let the witness find his way around. You can't

12 let him not deal with matters which you put to him.

13 Do you see that, Mr. Becirevic? Have you got the point?

14 THE WITNESS: [Interpretation] Yes.

15 JUDGE MAY: Yes. Very well. Keep the statement there.

16 We're going to adjourn now for 20 minutes.

17 Mr. Becirevic, in this adjournment and any others there may be

18 during your evidence, would you remember not to speak to anybody about it

19 until it's over, and that does include members of the Prosecution team.

20 We'll adjourn now for 20 minutes.

21 --- Recess taken at 10.46 a.m.

22 --- On resuming at 11.09 a.m.

23 JUDGE MAY: Yes, Mr. Milosevic.

24 MR. MILOSEVIC: [Interpretation]

25 Q. Let's just clarify one thing. In your statement, you mentioned

Page 20542

1 what I read out to you, that is to say, on page 6, 17th of April, a group

2 of Arkan's men arrived in Bratunac from Serbia. "They entered the hotel

3 and took it over. I saw three soldiers outside the front door holding

4 their weapons at the ready. They had special uniforms which I recognised

5 from television reports, they wore a special bandana around their heads,"

6 and so on and so forth, "but I'm sure they were from Arkan's group."

7 You don't mention the JNA here. You don't mention Seselj's men at

8 all. You now mention the JNA, Seselj's men, Arkan's men, even the Red

9 Berets. And here you talk about bandannas around their heads. Did you

10 invent all of this?

11 A. Your Honours, I did not invent anything. I was in Bratunac on

12 that day, and I saw these paramilitary formations that had come from

13 Serbia with different uniforms and insignia that they had on their

14 sleeves.

15 Q. Do you know, Mr. Becirevic, that even the Serb volunteer guard,

16 Arkan's guard, was not in Bratunac at all? It was some group of criminals

17 from Bijeljina.

18 A. Your Honours, this is not correct, because all of us in

19 Bosnia-Herzegovina watched television and saw what Arkan's men did in

20 Bijeljina.

21 Q. You're talking about Bratunac. You're talking about Bratunac, not

22 Bijeljina.

23 A. But such groups entered Bratunac on the 17th of April as well and

24 occupied it.

25 Q. Are you saying such groups or those groups?

Page 20543

1 A. Groups that wore the same uniform and the same insignia. Those

2 that took Bijeljina were in Bratunac on the 17th of April, 1992 as well.

3 Q. All right. All right. Do you know who Nijaz Masic is?

4 A. Your Honours, I know Nijaz Masic. He's a professor who worked at

5 the high school in Bratunac.

6 Q. All right. He wrote a book that is entitled "The Truth About

7 Bratunac."

8 A. It is correct that he wrote that book.

9 Q. You knew him personally, I assume. You know him personally?

10 A. I do know him personally.

11 Q. In the book, he says, as a matter of fact, that some commission

12 had been set up of the War Presidency of the Municipality of Bratunac with

13 its seat in Srebrenica consisting of the following persons: Dzemail

14 Becirevic, Selmo Ibisevic and Nijaz Masic. So together with you he was a

15 member of this commission consisting of three members.

16 A. I don't know what kind of war commission you're talking about.

17 This was a commission that had as its objective to get out of Srebrenica

18 and to reach Tuzla. However, it never succeeded in this intention of

19 theirs because in the first attempt made to that effect the Serb forces

20 ambushed them and they had to return and people were even killed.

21 Q. All right. So you didn't finish that job, but I just wanted to

22 establish your immediate connection to Nijaz Masic, the work you did

23 together.

24 Now, since you've mentioned all of this, everything you saw on the

25 17th of April, now let us leave aside the differences concerning what it

Page 20544












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Page 20545

1 says -- between what you said here and what it says in the statement.

2 Give me a precise answer to the following question: Is it correct that on

3 the 17th of April, 1992 you were not in Bratunac at all or in Hrncici and

4 that therefore you could not see either Arkan's men or Seselj's men or

5 soldiers or anybody else or anything else. You could not feel endangered

6 in any way at all because you were not in Bratunac on the 17th of April.

7 A. Your Honours, the truth is that on the 17th of April, 1992 I was

8 in Bratunac. There are witnesses as to who I came to Bratunac with and

9 who I returned with, and there are also Serbs who I found in my office,

10 one of my clerks.

11 Q. All right. All right, Mr. Becirevic. I'm going to read a

12 paragraph from page 65 of Nijaz Masic's book, in which it says quite

13 literally --

14 THE ACCUSED: [Interpretation] Mr. May, this has been marked by

15 02060087, 65, page 65 of the book, that is. I am going to read this

16 paragraph. "In the night between the 27th and 28th of April, 1992, with

17 Aganovic Brdo there was a new meeting of armed prominent persons from

18 Konjevic Polje. At this meeting the citizens of Konjevic Polje were

19 familiarised with the demand made --"

20 Am I reading too fast for the interpreters?

21 THE INTERPRETER: The interpreters say yes.

22 THE ACCUSED: [Interpretation] "At the meeting the citizens of

23 Konjevic Polje were familiarised with the demand made by the Chetniks and

24 their following intentions. A decision was reached to establish contact

25 with Cerska as soon as possible and to prevent the surrender of weapons in

Page 20546

1 that area and in this way create a united front against the aggressor."

2 MR. MILOSEVIC: [Interpretation]

3 Q. Now, please, pay attention to the following sentence. I'm not

4 omitting anything: "Velid Sabic and Dzemail Becirevic familiarised the

5 persons present with their visit -- their travel made on the 17th of

6 April, 1992 to Tuzla, where they were received by Fuad Hadziabdic and he

7 said to them that he could not help them with arming along with the

8 recommendation," et cetera, et cetera. And then it comes to the following

9 page.

10 So at that meeting you told people about your trip, about your

11 travel to --

12 JUDGE MAY: Let the witness answer these passages, if you're going

13 to put them to him.

14 What is suggested by this author, as you've heard, Mr. Becirevic,

15 is that you, on the 17th of April, travelled to Tuzla to try and get help.

16 Is the author right about that or not?

17 THE WITNESS: [Interpretation] Your Honour, I am going to answer

18 this question. On the 17th of April, I was in Bratunac until 12.00. When

19 I saw what was going on in Bratunac, that Bratunac would be occupied, from

20 Bratunac I made a telephone call to my superior, Fuad Hadziabdic, and I

21 asked him what to do. I said some military people came here, some

22 paramilitary forces, they've occupied the town, it's almost fallen into

23 their hands. And he answered me, quite literally, "Over the telephone I

24 cannot give you any kind of answer or assistance. Therefore, try to come

25 with Velid Sabic --" because I told him that Velid Sabic was there too.

Page 20547

1 And he said, come with him to Tuzla and we are going to agree on all of

2 this. And then at 12.00 I left Bratunac. I came to Konjevic Polje.

3 Around 1500 hours, we set out for Tuzla. We arrived in Tuzla. We

4 met only for about 15 minutes with this Fuad. He was the Assistant

5 Minister for National Defence for the Tuzla region. He can confirm that.

6 He said to us that he could not help us, he could not help Bratunac and

7 the people of Bratunac. He said that Tuzla was in danger as well and that

8 Tuzla needed help too.

9 He said, "Go back there. Go back to these people in Konjevic

10 Polje. Let the army leave. Try to engage in partisan warfare when the

11 time comes. Until the army leaves, you cannot take any kind of action."

12 So around 1700 hours, we returned. There are witnesses. There is a

13 lawyer, Salcin Dzamic, who we found in Tuzla and who asked us, "Where are

14 you going back to? Do you know that Bratunac fell today at 3.00?" We

15 said we had been in Bratunac until 12.00. "But never mind. We're going

16 back there again because the people are waiting for us there. We are

17 going to help the people."

18 So in the evening we returned to Konjevic Polje. That is the

19 truth. And I have hundreds of witnesses.

20 MR. MILOSEVIC: [Interpretation]

21 Q. All right. So it is not being contested that on the 17th of

22 April, 1992 you and Velid Sabic went to Tuzla and that you were received

23 there by Fuad Hadziabdic and he said that he could not help you and all of

24 this happened at this lightning speed that you've referred to. And how

25 far is the distance between Bratunac and Tuzla?

Page 20548

1 A. First of all, let me tell the Honourable Trial Chamber that from

2 Bratunac to Konjevic Polje it takes about 20 minutes by car, and from

3 Konjevic Polje to Tuzla we went along the following road: Milici, where

4 we were stopped by the Serb police, and they searched us, and then we went

5 via Vlasenica, Tisce, Kladanj, we reached Tuzla. We were down there for

6 about half an hour or an hour.

7 Q. Tell me, how long does one travel from Bratunac via Konjevic

8 Polje, Kladanj, and so on, all these places you mentioned, to Tuzla?

9 A. About an hour and a half or two by car.

10 Q. So you need two hours to arrive in Tuzla without anybody detaining

11 you along the way, and you had been stopped.

12 A. Yes, but we were just searched at two checkpoints.

13 Q. And you did all of that within this short span of time that you

14 described.

15 THE ACCUSED: [Interpretation] Mr. May, could you please take this

16 page, which is marked by this number of the opposite side, would you

17 please take it into evidence?

18 JUDGE MAY: I doubt if it's evidence because it's what somebody

19 has written in a book. So I doubt it's evidence.

20 But let the witness see it.

21 THE ACCUSED: [Interpretation] Well, he confirmed what it says in

22 the book. That is precisely what I'm saying, that on that day he was in

23 Tuzla.

24 THE WITNESS: [Interpretation] Your Honours, I have hundreds of

25 witnesses who are going to confirm that on that day I was in Bratunac

Page 20549

1 until 12.00, that I was in my office, that Gavric, my clerk, saw me and

2 said to me, "What are you waiting for here? Run away. See that --"


4 [Trial Chamber confers]

5 JUDGE MAY: Yes. We're not going to admit that page. You've

6 heard what the witness says about it. In fact, there doesn't seem to be

7 much dispute about what you allege. He says he went to Tuzla that

8 afternoon but was in Bratunac in the morning.

9 THE ACCUSED: [Interpretation] All right.

10 MR. MILOSEVIC: [Interpretation]

11 Q. And it's not disputed that during the night between the 27th and

12 28th of April at this meeting at Aganovic Brdo, together with a few armed

13 men from Konjevic Polje, that you told them about your trip to Tuzla on

14 the 17th and the meeting with Hadziabdic; is that right?

15 A. It is not disputed that on the 27th in the evening we were at

16 Aganovic Brdo, and it is quite clear why we met there; because we were

17 expelled from our homes.

18 Q. All right. Am I right further on when I say that you established

19 the 114th East Bosnian Brigade from Konjevic Polje, which became a part of

20 the 284th East Bosnian Light Brigade?

21 A. It is correct, Your Honours, that I am one of the participants,

22 and that the commander of that brigade was a former officer of the

23 Yugoslav army Sabic Velid.

24 Q. All right. Is it correct that you were within the command of that

25 brigade?

Page 20550

1 A. It is correct that I was assistant commander for morale in that

2 brigade.

3 Q. The command of this unit consisted of the following persons, as it

4 says on page 101 of this book, and it also has been marked by the other

5 side as 06260106, was Velid Sabic, commander; then Suljic, deputy; Ejub

6 Dedic, chief of staff; Fehim Hasanovic; Ismet Celikovic; Nail Jusupovic;

7 Mehmedalija Mehic; Fadil Muminovic; Fadil Dedic; Dzemail Becirevic - you,

8 that is - Enes Ibrahimovic; Ismet Mujanovic; Hajrudin Turnadzic; and Avdo

9 Majstorovic.

10 JUDGE MAY: He can't be expected to take all these names in.

11 Did you get those names and is it right that they were -- formed

12 part of the brigade, or would you like any of them repeated?

13 THE WITNESS: [Interpretation] Your Honours, there is no need. I

14 know most of these people, and they were in the brigade, 284 EB

15 Srebrenica, and I was one of the members too, of course, of this top

16 command of this brigade in Srebrenica.

17 MR. MILOSEVIC: [Interpretation]

18 Q. So that is what I -- what I described as the top command of that

19 brigade.

20 A. Yes. That's not disputed.

21 Q. All right. Now, tell me, do you know, Mr. Becirevic, that the

22 State Commission for War Crimes and Genocide of the Federal Republic of

23 Yugoslavia, in its memorandum on war crimes and genocide in Eastern

24 Bosnia, the municipalities of Bratunac, Skelani, and Srebrenica, dated the

25 month of April 1993, you were -- put you on the list as one of the

Page 20551

1 organisers of the genocide against the Serb people under the column of

2 "Officials and Organisers"?

3 A. I'm not aware of that. But Dzemail Becirevic has a well-known

4 address. Right now I live in Sarajevo. I often travel to Bratunac. I am

5 an Assemblyman in the Municipal Assembly of Bratunac, and that kind of

6 question was put to me in 1997, when I was a candidate for vice-president

7 of the Assembly and I was told that allegedly I had committed some kind of

8 war crimes, and then the international community said to these persons who

9 had raised this question that they should present evidence to that effect,

10 and they were given a deadline, a 30-day deadline. If they have anything

11 to say against me, they could go ahead. Since then it's been six years,

12 and I am still at everybody's disposal. My address is well-known. If

13 they have anything, let them go ahead with it, but they have to prove it.

14 I have been called here first and foremost to testify about the aggression

15 that had been carried out against Bosnia-Herzegovina, namely, the

16 municipality of Bratunac.

17 JUDGE MAY: Yes.

18 THE ACCUSED: [Interpretation] Mr. May, lest you interrupt me in my

19 efforts to indicate by way of questions what crimes were committed and the

20 number of victims and also how many villages were razed to the ground and

21 torched in the municipality of Bratunac, I wish to tender into evidence

22 this document.

23 JUDGE MAY: Which one?

24 THE ACCUSED: [Interpretation] I have indicated that particular

25 document several times in its entirety. I wish to draw your attention

Page 20552

1 to --

2 JUDGE MAY: Mr. Milosevic, which is the document that you're

3 asking to admit?

4 THE ACCUSED: [Interpretation] The memorandum about war crimes and

5 the crime of genocide in Eastern Bosnia in the municipalities of Bratunac,

6 Skelani, and Srebrenica committed against the Serb people from April 1992

7 until April 1993. This was compiled by the Yugoslav State Committee for

8 War Crimes and Genocide, and the date is April 1993. On this page, which

9 the --

10 JUDGE MAY: Just a moment. I suppose one course, Mr. Groome - I

11 mean, maybe you have an objection - may be to mark it for identification

12 purposes.

13 MR. GROOME: Your Honour, I would not oppose marking it for

14 identification. I would object, on behalf of the Prosecution, to its

15 introduction in evidence.

16 JUDGE MAY: It would seem reasonable to mark it for

17 identification.

18 Yes, we will do that and get a number for it, please.

19 THE REGISTRAR: Defence Exhibit 132, marked for identification.

20 THE ACCUSED: [Interpretation] Very well. Before you mark it for

21 identification, I would just like to inform you that the title page of the

22 document is 01975, and it is the number provided by the opposite side.

23 The page is the one I mentioned to Mr. Becirevic, and it is 00678851, and

24 the title there is "A list of war criminals in the territory of Bratunac,

25 Srebrenica, Milici, Vlasenica, and Skelani for which evidence and proof

Page 20553

1 exists that they are in Srebrenica." And under number 14, we find the

2 name of Becirevic Dzemail, born in 1960 in Bratunac. So here you have the

3 document in its entirety for you to see for yourselves. As the opposite

4 side does have this document, I assume that it has certain

5 responsibilities with respect to those war crimes.

6 MR. GROOME: Your Honour, if I may be heard briefly.


8 MR. GROOME: This is another one of several commissions funded and

9 organised by respected members of the conflict that investigated crimes

10 during the war and issued these reports. Just as the Prosecution has

11 never sought to admit the results of these commissions as evidence of --

12 that Mr. Milosevic is guilty of war crimes, the Prosecution opposes that

13 they're introduced as evidence of that somebody else has committed any

14 crimes.

15 The Prosecution received these reports from respective members of

16 the party. In light of our obligations under Rule 68, a full copy of that

17 was provided to the accused so that he could use it in his questioning of

18 the witness. But it's the Prosecution's position that these documents in

19 and of themselves do not bear sufficient reliability or credibility to be

20 introduced into evidence for the proof of the facts that they assert.

21 JUDGE MAY: Well, at this stage the exhibit will be simply marked

22 for identification purposes. If in due course evidence is produced to

23 support it, then of course we'll reconsider whether it should be

24 introduced fully or not.

25 Let me hand it back.

Page 20554

1 THE ACCUSED: [Interpretation] Very well. I have an excerpt from

2 the criminal files of those accused of war crimes in Bosnia-Herzegovina in

3 1992 to 1995. I've extracted page 76 from that document, and it includes

4 a number of individuals.

5 MR. MILOSEVIC: [Interpretation].

6 Q. I'll just read out what has to do with you, Mr. Becirevic, and

7 that is this: It says: "Becirevic Dzemail, born in 1960 in Bratunac,

8 secretary of the SDA in Bratunac, responsible for preparing to attack

9 military formations in Bratunac against the civilian population of Serbian

10 villages and settlements -- Bratunac settlement, Konjevic Polje, and

11 others. And between May and December 1992 a mass and individual killings

12 and took place of civilians, including women, children, elderly persons,

13 sick people, disabled people, and so on. And most of the houses and

14 villages were then looted, burnt to the ground, or destroyed. In the

15 course of these attacks, without any military need, the civilian

16 population was mistreated, massacred, and tortured, taken off to prisons

17 and camps, and displaced in the efforts of ethnic cleansing of the area."

18 So these are all excerpts from criminal files against the

19 perpetrators of war crimes committed against the Serbian people in

20 Bosnia-Herzegovina. I've just read out this brief extract, which

21 indicates that this took place --

22 JUDGE MAY: Yes. Let the witness --

23 MR. MILOSEVIC: [Interpretation]

24 Q. -- and mentions the witness.

25 JUDGE MAY: Let the witness see the document, and then he can

Page 20555












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13 English transcripts.













Page 20556

1 answer.

2 Who is it who makes these allegations, Mr. Milosevic? Can you

3 help us with that?

4 THE ACCUSED: [Interpretation] It says there, the heading, it is

5 "The excerpt from criminal files by the organs of Bosnia-Herzegovina," or

6 rather, I suppose that they are the authorities -- the competent

7 authorities in the area -- in the Republic of Serbia.

8 JUDGE MAY: [Microphone not activated] now, Mr. Becirevic, you can

9 look at that document -- You could look at that document and see what it

10 says. You can comment upon the document, and you can also deal with the

11 allegation that you took part in organising attacks on villages which

12 resulted in them being razed to the ground.

13 THE WITNESS: [Interpretation] Your Honours, the allegations made

14 by the accused are absolutely not true. First of all, I have been called

15 here to testify about the organisation, aggression against

16 Bosnia-Herzegovina, in specific terms the Bratunac municipality, the

17 aggression itself and the genocide that was committed.

18 JUDGE MAY: We know why you've come here and what you've said, so

19 there's no need to repeat that. But obviously these allegations are being

20 made and you should have a chance to deal with them. Is there a word of

21 truth in anything that's written there?

22 THE WITNESS: [Interpretation] Your Honours, there is not a word of

23 truth in all this, because at that material time I was in Konjevic Polje

24 and Konjevic Polje exclusively waged defensive operations. That is to

25 say, there were daily attacks launched against it precisely from the

Page 20557

1 opposite side, so how could we attack somebody when we were actually under

2 a total encirclement and siege from the 17th of April right up to the time

3 we were expelled towards Srebrenica. Konjevic Polje had no exits

4 anywhere. So this is not correct.

5 JUDGE MAY: Very well.

6 Mr. Groome, again, marked for identification, unless you have any

7 objection.

8 MR. GROOME: No, Your Honour, no objection to that.

9 JUDGE MAY: Very well. We'll mark it for identification.

10 MR. MILOSEVIC: [Interpretation]

11 Q. We'll come to quite specific and concrete questions,

12 Mr. Becirevic, but tell me first this --

13 JUDGE MAY: Wait a moment. We're just going to have an exhibit

14 number.

15 THE REGISTRAR: Defence Exhibit 133, marked for identification.

16 MR. MILOSEVIC: [Interpretation]

17 Q. Is it true and correct that you personally were involved in the

18 activities to arm, train, and form the Muslim military commands and units

19 in the villages of Sandici, Locici, Urkovici, Pervani, Kamenica, Pobrdje

20 and Nova Kasaba?

21 A. Your Honours, that is not correct.

22 Q. Is it also true and correct that those villages are the most

23 populous and largest part of the Bratunac municipality in which 99 per

24 cent of the population are Muslims?

25 A. The local community of Konjevic Polje before the war, according to

Page 20558

1 the population census, numbered 5.600 inhabitants and it was one of the

2 largest local communities in the Bratunac municipality. The only local

3 community, in fact, which offered an organised -- organised defence to the

4 aggressor. All the other local communities where the Muslim people were

5 in the majority, in the space of one and a half months, were razed to the

6 ground. That is to say, ethnic cleansing took place and during that one

7 and a half months about 1.000 women and children were killed, and

8 civilians.

9 Q. Yes, you've already said that. What I'm asking you is this --

10 would you please answer my question. There's no need to repeat your

11 testimony, which does not relate to my question. So you were the head of

12 the Wartime Presidency in Konjevic Polje but you say -- yet you say that

13 you were not the organiser of the activities to train and establish Muslim

14 military commands in those villages. Is that what you're claiming?

15 A. I'm claiming that I did not take part in any kind of training

16 because I was an ordinary soldier in the former JNA, so that I am not a

17 military expert in any way.

18 Q. I'm talking about organisation. I'm not saying that you trained

19 them and showed them how to assemble or disassemble a rifle or anything

20 like that or hold rifle practice.

21 But another question: Is it true that it was precisely you,

22 together with this man Rahid Sabic, who brought Nurif Rizvanovic to those

23 parts who was also a former officer and in fact deserter of the JNA who

24 was otherwise a native of Glogova. You brought him exclusively in order

25 to implement military training and attack the Serbs.

Page 20559

1 A. That's not true. We were not able to bring him in at all. What

2 we could say is that you probably slipped him into the area, because he

3 arrived in the month of August and he came from Tuzla with a unit to the

4 Konjevic Polje area. Part of the unit stayed on in Konjevic Polje,

5 whereas the rest of the unit went on to Srebrenica. So how could we have

6 brought him in? We were under a total siege, so how would we bring in

7 anybody from Tuzla?

8 Q. So you mean what you want to say that the Serbs brought him, this

9 Rizvanovic, who brought with him 500 soldiers from all parts of

10 Bosnia-Herzegovina?

11 A. They let him pass through. They let him pass over 100 kilometres

12 of Serb territory to arrive in Konjevic Polje. I don't know what their

13 aim in doing that was.

14 Q. Well, as of 1992, together with you and all the rest, he was very

15 prominent in perpetrating war crimes and genocide against the Serbian

16 population there, precisely this man called Rizvanovic.

17 A. Your Honours, that is not true.

18 Q. So he didn't fight in Konjevic Polje and commit war crimes against

19 Serbian civilians in that whole encirclement?

20 A. He came to help his own people because he originated from Glogova

21 and it was his aim to go back to his native region and help the people of

22 Glogova. That was what he wanted to do.

23 Q. Well, he said he was from Glogova. And is it true that this man

24 Rizvanovic, due to the power fight, clashed with Naser Oric who later

25 liquidated him, precisely in this clash and power struggle that they had?

Page 20560

1 And I'm talking about the Muslim forces in Eastern Bosnia.

2 A. As to the details of this alleged clash between them, power

3 struggle between them, I don't know. But Nurif Rizvanovic, when he left

4 for Srebrenica, lost his life at the enemy lines, that is to say, the Serb

5 front. Now, how he lost his life, I really can't say. I don't know the

6 details.

7 Q. All right. If you don't know the details, I won't pursue the

8 issue. But tell me this: Before the conflict in the Bratunac

9 municipality, you were the secretary of the Secretariat for National

10 Defence in Bratunac municipality. And that is what it says on page 2 of

11 your statement, paragraph 2; is that correct?

12 A. Yes, it is.

13 Q. On page 2, paragraph 4 of your statement, you speak about arming

14 the Territorial Defence of Bratunac and the weapons they had; is that

15 right?

16 A. Let me just take a look. What page and paragraph did you say?

17 Q. Page 2, paragraph 4 of your statement speaks about arming the

18 Territorial Defence of Bratunac; right?

19 A. Your Honours, I speak about how the weapons were taken over from

20 the Territorial Defence of Bratunac by the JNA.

21 Q. You say that in 1989 those weapons were removed. Did I follow you

22 correctly? So you were talking about the year 1989 when the weapons were

23 transferred from Bratunac. Are you sure about that?

24 A. Yes, I am.

25 Q. In 1989?

Page 20561

1 A. The Yugoslav army collected up all the weapons and took it across

2 the bridge, the Ljubovija bridge into Serbia. Where the weapons ended up,

3 I don't know.

4 Q. Well, I assume that the JNA in 1989 was throughout the territory

5 of the SFRY, Bratunac, Ljubovija, and any other place because it was

6 within the borders of the Socialist Federal Republic of Yugoslavia.

7 A. I didn't say anything. I just said that they collected up all the

8 weapons and took it away.

9 Q. Were you the secretary of the Secretariat for National Defence in

10 1989?

11 A. No, I wasn't. I told you where I was at the time and where I was

12 working.

13 Q. Well, then you must know, even if you weren't in that position,

14 you must have known that something like that -- you could have been aware

15 only in 1990 when the Federal Presidency decided to displace the arms from

16 the Territorial Defence to store it in the JNA barracks and depots. The

17 Federal Assembly in full composition in 1990 made that decision, and you

18 must have known about it. That is, to transfer the TO weapons to the JNA

19 barracks and depots because it was safer and more secure there. Do you

20 know about that?

21 A. We knew that a decision of that kind was taken and that the

22 weapons were collected up in Bratunac. I know that because I saw it with

23 my own eyes. I saw the weapons being taken away. So that is not being

24 contested. You're denying that?

25 Q. I don't know anything about it. I'm asking you on the basis of my

Page 20562

1 information, Mr. Becirevic. You worked as the defence secretary. I

2 assume you were aware of a decision taken by the Presidency of Yugoslavia

3 according to which the weapons of the Territorial Defence should be placed

4 under you -- JNA warehouse protection.

5 JUDGE MAY: He's answered that. Move on to something else.

6 MR. MILOSEVIC: [Interpretation]

7 Q. You also say that the weapons were supposed to be transferred to

8 the barracks of the Tuzla Corps but that the trucks in fact took the

9 direction of Serbia; is that right?

10 A. I just said that during that period of time I was working in a

11 socially owned company and that I was only 50 metres away from that

12 particular place and that I was 10 metres away from the trucks when they

13 loaded up the weapons and took them off.

14 Q. All right. Were you an escort for that weapons transport?

15 A. No. Why would I have been?

16 Q. Well, how do you know the weapons weren't taken to Tuzla but

17 somewhere to Serbia?

18 A. They took the direction of Ljubovija. Where it ended up, I don't

19 know, I can't say.

20 Q. Well, you're in fact saying -- you in fact say on that same page

21 that there was a barracks in Ljubovija. You talk about that particular

22 barracks; right? Have you ever been to the Ljubovija barracks?

23 A. I've never been to the Ljubovija barracks but I just said that the

24 weapons were taken in the direction of Ljubovija, towards Ljubovija.

25 Q. But you say that you don't know what kind of unit was stationed

Page 20563

1 there at all; is that right?

2 A. I said that there was a barracks there and that it was common

3 knowledge that it was JNA barracks.

4 Q. Well, that was the only army that existed in the SFRY, as far as I

5 know, so that's no secret.

6 A. Well, it's not a secret, and it's not being contested either.

7 Q. So you didn't know what kind of unit this was nor what type and

8 quantity of ammunition the unit had at its disposal or anything about its

9 strength. Am I right when I say that? That particular unit in Ljubovija,

10 that's the one that I'm referring to.

11 A. No, I wasn't there, so I couldn't know what kind of unit it was,

12 how many men it numbered, but what I did see was that it was from the

13 positions at Ljubovija, and I'm talking about 1991, that the barrels were

14 turned and pointed towards Bratunac, and that was common knowledge.

15 Q. All right. We'll clear that up in due course. Now, as you say

16 you know nothing about the unit, how come you say that in the barracks in

17 1991 a tank unit arrived of some kind, and prior to that you say that you

18 know nothing about the unit or its weapons?

19 A. What I'm telling you is this: I saw with my very own eyes that

20 the tanks, their barrels, were turned towards --

21 Q. But you say that some unit arrived. How can you know that the

22 tanks weren't there beforehand at the Ljubovija barracks, already in

23 place? Because you say a tank unit turned up in 1991. How do you know

24 they weren't already there?

25 A. Well, reinforcements were sent from other areas to the territory

Page 20564

1 of Ljubovija. And once again, as I say, their barrels were turned towards

2 Bratunac.

3 Q. You've shown us some documents here and you speak about the

4 establishment of the Serbian Municipality of Bratunac. That's right,

5 isn't it?

6 A. Yes.

7 Q. Then you go on to say that their barrels were pointed to some

8 forces in Ljubovija -- or rather, that the Yugoslav People's Army's

9 barrels were turned to Bratunac. And you say that the JNA assisted the

10 Serbs. That's right, isn't it?

11 A. In 1991, in December of that year, the Serb Municipality of

12 Bratunac was established, although the legal municipality of Bratunac was

13 already in existence. A government was set up, a Serb government,

14 although Bratunac already had the executive board of its own legal

15 government. So all the preparations had been concluded on the part of the

16 Serbs in Bratunac.

17 Q. Now, Mr. Becirevic, the preparations that were completed and so

18 on, I'm not asking you that now. You mentioned tanks, you mentioned

19 Howitzers, you mentioned their barrels being turned towards Bratunac. Did

20 those Howitzers and tanks shoot at the Bratunac municipality?

21 A. In 1991 and in the spring of 1992, they did not open fire. But it

22 was sufficient for the people to see their barrels turned towards Bratunac

23 and the area around Bratunac. This instilled fear in the population.

24 Q. So this explanation that there was some deployment of JNA forces

25 in the barracks in Ljubovija, which had existed for decades there, your

Page 20565

1 explanation is to instil fear in the population. But you say they did not

2 shoot. So all those tanks and barrels were never used. They never opened

3 fire towards the Bratunac municipality. Did they open fire across the

4 Drina River at all?

5 A. No, they did not. But it was enough for their barrels to be

6 turned towards Bratunac. That was a clear indication of what was in store

7 for the population.

8 Q. All right. As we have Serbs and Muslims living in Bratunac, then

9 both these ethnic groups must have been afraid of the gun barrels pointed

10 at them. I don't think a shell can choose what ethnic group it's going to

11 shoot at.

12 A. I didn't know they were shooting.

13 Q. Since you didn't say they opened fire, let us not dwell on it.

14 Tell me one thing: On page 3, paragraph 8, you explained that

15 Bratunac, according to the census in 1991, had 33.500 inhabitants. Out of

16 that, 11.300 Serbs.

17 THE ACCUSED: [Interpretation] Shall I repeat my question?

18 JUDGE MAY: Yes.

19 MR. MILOSEVIC: [Interpretation]

20 Q. You say that according to the census in 1991, there were 33.500

21 inhabitants in Bratunac, out of which 64 per cent Bosnians, 33 per cent

22 Serbs, and the rest were others. Is that so?

23 A. Yes, that's the figure from the 1991 census.

24 Q. All right. On page 2, paragraph 5, you say that in end 1989 you

25 started feeling tensions and that you - I suppose that means Muslims -

Page 20566












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Page 20567

1 started hearing Serb propaganda about Serbs being driven out, but you say

2 that the real truth was that people were leaving Bratunac in search for

3 jobs. Is that what you stated?

4 A. Your Honours, this is an indisputable fact that there was an

5 attempt by the Serbian propaganda to present it as Serbs leaving Bratunac

6 under pressure, under duress, but later events showed that they were in

7 fact leaving for economic reasons.

8 Q. So you say that they were leaving in order to look for jobs

9 elsewhere. Is that what you're saying?

10 A. Yes.

11 Q. On page 2, in the third paragraph, you say, "But Serbs held

12 leading and managerial positions."

13 A. Yes. I meant public enterprises, about 20 of them that existed in

14 Bratunac. And all the major posts, in fact 80 per cent of them, were held

15 by Serbs.

16 Q. We've heard that before. You say that members of the Serb

17 community, which was twice smaller than the Muslim community, held all the

18 managerial positions and that Serbs were not being driven out. They were,

19 rather, leaving in order to look for jobs elsewhere.

20 A. I meant public enterprises where key positions were held by Serbs

21 in 80 per cent of all cases.

22 Q. You are a law graduate and you worked in the municipal

23 administration. Do you know that, for instance, in the 1931 census 50 per

24 cent of the population were Serbs in Bratunac, Muslims were a minority?

25 A. I do not know this piece of information. In 1991, I was in the

Page 20568

1 commission for the census and that is why I quoted that information. What

2 was the case 50 years ago, I really don't know.

3 Q. All right. Are you aware that immediately after the Second World

4 War, for reasons which this Tribunal does not find interesting --

5 JUDGE MAY: [Previous translation continues]... 51, so he's not

6 going to do the Second World War. Let's move on.

7 THE ACCUSED: [Interpretation] I know. And I was just going to say

8 that these are the reasons which do not meet with your interest. But I

9 suppose that Mr. Becirevic, who says he is a law graduate, knows that in

10 1959, after Serbs returned to the lands from which they were driven out,

11 their number rose to over 50 per cent of the total population in Bratunac.

12 MR. MILOSEVIC: [Interpretation]

13 Q. Do you know that?

14 JUDGE MAY: He's dealt with that. He says he doesn't know about

15 these figures, and I don't see what the relevance of them is. So let's

16 move on.

17 MR. MILOSEVIC: [Interpretation]

18 Q. Well, then, from 50 per cent, over that period, their number

19 dropped to 30 per cent but Serbs held all the key positions.

20 JUDGE MAY: [Previous translation continues]... not in evidence.

21 MR. MILOSEVIC: [Interpretation]

22 Q. Do you know who is Sead Djordjic?

23 A. I do.

24 Q. Is it true that he was the director of Vihor enterprise?

25 A. I'll be happy to answer this question. We are talking about

Page 20569

1 socially owned enterprises which have to be distinguished from private

2 enterprises. You are a lawyer, just as I am by education, and you must

3 know that in socially owned enterprises such as Vihor was, it was the

4 workers who decided who the director would be. There were both Serbs and

5 Muslims in those posts, but only the most capable people remained, those

6 who were able to make sure that workers got their wages.

7 Q. I'm only asking you to confirm this data, nothing else, because we

8 have heard talk about some sort of discrimination against Muslims.

9 Okay. He was director of Vihor. Was Fahro Djordjic director of

10 the Kaolin factory?

11 A. I'm telling you that it was workers who put these people in those

12 positions, because they managed to provide their wages from month to

13 month.

14 Q. I'm not asking you who appointed them, the workers' council or

15 somebody else. I'm just asking you: Were these people indeed directors

16 of those enterprises?

17 A. They were, but they were only because they were capable people who

18 ensured wages for both Serbs and Muslims.

19 Q. I'm sure they were. That's not what we are discussing. Was Mujo

20 Mujicic the director of the ceramics factory? Just tell me yes or no.

21 A. My answer is the same. Yes; the workers decided it.

22 Q. Was Edo Ahmic director of the cardboard factory?

23 A. I was talking about public enterprises. And if you want to

24 insist, that was the ratio.

25 Q. I'm also talking about socially owned enterprises. Kaolin

Page 20570

1 factory, the cardboard factory, all of them were socially owned. Was

2 Cazim Avdic director of Feros?

3 A. That was in Srebrenica, I don't want to talk about it.

4 Q. Was Enver Hekic director of the Autotransport hauling enterprise?

5 A. I don't know that.

6 Q. Rifat Besic, was he director of the timber factory in Bratunac?

7 A. You are referring to enterprises which I --

8 JUDGE MAY: This is a war crimes trial on which immensely serious

9 charges are brought. Does it matter who was in charge of the cardboard

10 factory? What does it matter?

11 THE ACCUSED: [Interpretation] Mr. May, it matters precisely

12 because it is insinuated here that there was some sort of discrimination

13 against Muslims, and I took the trouble of looking up --

14 JUDGE MAY: Very well. But you could put it shortly. We don't

15 need this kind of detail.

16 You see -- I mean, are you saying that there was discrimination

17 against Muslims in Bratunac before the conflict broke out? Is that what

18 you say?

19 THE WITNESS: [Interpretation] Your Honours, as far as public

20 enterprises are concerned, yes, there was. And here is an example: Out

21 of four --

22 JUDGE MAY: Let me interrupt you to try and shorten this.

23 Is it true, as the accused has put, that there were Muslims who

24 were in charge of these enterprises?

25 THE WITNESS: [Interpretation] Your Honours, talking about socially

Page 20571

1 owned enterprises, I answered this question. But there was discrimination

2 in public enterprises, where all the key positions were held by Serbs.

3 MR. MILOSEVIC: [Interpretation]

4 Q. What do you call public enterprises? You mean the street sweeping

5 service.

6 A. Let me answer. There were two banks in Bratunac.

7 Q. Why would bank be a public enterprise and a mine isn't?

8 A. The mine is in Srebrenica. Let us take the social accounting

9 service, the post office, the four key public enterprises, the SDK, the

10 social accountancy service through which all funds were transferred. All

11 these positions were held by Serbs.

12 Q. What does it matter who was the director of the post office, Serb

13 or Muslim?

14 Since I enumerated these, I can enumerate more enterprises in

15 Bratunac, not just a few, as Mr. May puts it, but almost all of them

16 managed by Muslims. What kind of managerial or other domination of Serbs

17 in Bratunac are you talking about? Is it true that the majority of

18 general managers in Bratunac were Muslims, an overwhelming majority?

19 A. That is not true. And I have already answered. I am talking here

20 about public companies. There were about 20 of them. And we Muslims

21 demanded that they be split half/half after the elections in 1990, and we

22 never managed to get that.

23 Q. All right, Mr. Becirevic. I know, and I understand your demand,

24 but I considered it as an absolutely unprincipled thing.

25 Is it true that Nijaz Dubicic was president of the municipal

Page 20572

1 administration in Bratunac?

2 A. That's true, but it's also true that Radoljub Djukanovic was

3 president of the executive board.

4 Q. I'm asking you who the president of the municipality was. I'm not

5 asking about the executive board. And you are answering me yes, but the

6 other one was president of the executive board.

7 A. That was according to the electoral results.

8 Q. So he was a Muslim. Was Senad Hadzic chief of police in Bratunac?

9 A. His name is Senad Hodzic. But the commander was, again, Mandic

10 Nikola.

11 Q. You're answering me again that the commander was a Serb.

12 A. Because that's how it was. One was Serb, one was Muslim, the

13 chief and deputy.

14 Q. And what was that in Kravica you were telling me about?

15 A. In Stajici.

16 Q. Yes. And both key people in the police were replaced after that

17 incident, both the Serb and the Muslim.

18 A. Yes.

19 Q. So president of the police, chief of the SUP, head of the

20 municipal administration for -- municipal section for civil defence and

21 protection. You were the secretary, is that true?

22 A. I was the secretary.

23 Q. It boils down to the same thing. Is it true that the chief of the

24 staff for National Defence was Sead Mujicic?

25 A. Let me just tell you: The executive board consisted of three

Page 20573

1 Muslims and three Serbs. Can you imagine how they operated? It was

2 consistently obstructed. Why? Because of the SDS.

3 Q. Okay. Obviously it was the SDS which is to blame for everything

4 and the SDA is not to blame for anything.

5 All right. Tell me now: Is it true that you in fact made up this

6 domination of Serbs in managerial positions?

7 A. I didn't make anything up; It's a fact.

8 Q. I read you a list of Muslim names, people who were managers.

9 JUDGE MAY: We've now exhausted this topic. Let's move on to

10 something else.

11 MR. MILOSEVIC: [Interpretation]

12 Q. Okay. Is it true that you made up also the economic reasons for

13 which Serbs left Bratunac?

14 A. I didn't make it up. There was a conference held, attended by a

15 thousand citizens, both Serbs and Muslims, which noted and concluded that

16 there is no emigration of Serbs under pressure. All the emigration was

17 due to other reasons. Every second house in my own place, Konjevic Polje,

18 has men working in Switzerland.

19 Q. So they went for economic reasons.

20 A. It was not the Muslims who expelled them, in any case.

21 Q. And then you go on to say in your statement, "From the Party of

22 Democratic Action, we tried to make certain decisions such as decisions to

23 replace directors of certain public enterprises because all of them were

24 Serbs after the elections." That means you decided to replace people

25 because they were Serbs.

Page 20574

1 A. We were not in a position to make such decisions. It was up to

2 the Municipal Assembly to decide. But since the Municipal Assembly had

3 its work completely blocked, not a single decision it made after its

4 establishment could pass without the approval of the SDS.

5 Q. I am just quoting. Those are the last lines on page 3: "In the

6 course of the meetings that followed, we in the SDA tried to make some

7 decisions such as to change some of the managers of public enterprises in

8 town because they were all Serbs."

9 You tell me now that you were not making such decisions. Why did

10 you want to replace them? Because they were no good or because they were

11 Serbs? You told me that the only criterion for being a general manager

12 was ability and skill, and in the same breath you tell me here in the

13 statement that you wanted to replace them because they were Serbs?

14 A. It was not up to us, in any case. The Assembly was to decide on

15 that. But the Serbs did not like it. They wanted their situation to

16 remain on status quo.

17 Q. Was their main deficiency that they were Serbs?

18 A. No, we're not talking about the skill of a person - for instance,

19 director of the SDK - if that man gave all the funds to the SDS.

20 Q. How can a director of a section for payment transactions give

21 funds to somebody to whom these funds are not due?

22 A. That, unfortunately, did happen in the beginning of 1992, and

23 documents clearly show that people who paid contributions into their

24 pension funds, as was established after the war, had these funds diverted.

25 These funds never reached Tuzla, where they were supposed to go.

Page 20575

1 Q. We have no evidence of who stole money from a branch of the SDK.

2 This is a totally different issue. We have many other issues to discuss

3 and time is short. If there was a thief who stole the money, it's a

4 completely different matter.

5 You say that the tensions grew more intense when Serbs who passed

6 on buses through Bratunac put up my pictures in the windows.

7 A. That's true. That was the case with all vehicles coming from the

8 direction of Ljubovija. Your photograph was in the windows of all

9 vehicles, and that caused discontent among Muslims. Some windows were

10 shattered and so on. There were incidents.

11 Q. You followed the newspapers, I suppose, since you are a lawyer,

12 didn't you? Are you aware that I made statements in newspapers, and I may

13 have been the only politician in Yugoslavia at the time who publicly asked

14 that his photograph not be put up anywhere because those times were

15 already past and new times prevailed?

16 A. I never read anything of the sort. All I know is that your

17 pictures were put up in Bratunac on all public buildings, institutions, in

18 offices, whereas you were not head of state in Bosnia and Herzegovina at

19 the time.

20 Q. Of course I was not. I'm not claiming otherwise.

21 You say on page 3, paragraph 2 that the Serbian Democratic Party

22 in Bratunac was set up in November 1990; is that so? Doesn't that show --

23 since we were trying to establish a moment ago when the SDA was set up,

24 doesn't this show that the SDS was established five months later, after

25 the establishment of the SDA?

Page 20576

1 A. That is not correct. What is referred to here are founding

2 assembly meetings. The SDA founding assembly was on the 1st of September,

3 1990, and the SDS founding assembly followed immediately. The initiatives

4 for setting up the party were in May or June.

5 Q. I'm only reading what you wrote on page 3, paragraph 2: "The SDS

6 party was organised in Bratunac in October or November 1990."

7 A. You mean the founding assembly?

8 Q. Five months after the establishment of SDA. We have dates for

9 both parties, and the difference is five months.

10 A. That is not so. You misunderstood. This is about a founding

11 assembly.

12 Q. You said you attended the founding assembly meeting of the SDS.

13 A. Yes.

14 Q. And you only remember part of the speech held by Velibor Ostojic,

15 who claimed that Muslims in Bosnia had a plan to connect Bosnia with

16 Sandzak, Sandzak being a part of Serbia; isn't that so? Is that what you

17 said?

18 A. Yes. What is in dispute here?

19 Q. Are you saying that you did not put up your own proposal for

20 linking up with Sandzak? Do you know that the Patriotic People's League,

21 which you must know, having been their official, had staffs for the entire

22 territory of Bosnia-Herzegovina, including one for Sandzak and one for

23 Kosovo, although Sandzak and Kosovo are parts of Serbia? Are these facts

24 correct or not?

25 A. They're partly correct.

Page 20577












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Page 20578

1 Q. Oh, partly correct. Now, tell me, since you and some other

2 witnesses explained that actually Arkan, with his 25 men who came to

3 Bijeljina, carried out an aggression against Bosnia-Herzegovina, let's

4 leave it aside. I mean, if that is a state, that 25 men can carry out an

5 aggression against, let's leave that aside. But do you know how many

6 Muslims, how many thousands of Muslims from Sandzak fought in the ranks of

7 the Army of Bosnia-Herzegovina against the Serbs in Bosnia-Herzegovina?

8 A. I'm not aware of these figures, how many people from Sandzak came

9 to fight on the side of the Army of Bosnia-Herzegovina.

10 Q. Were they sent by some kind of government from Serbia to be

11 volunteers in the BH army?

12 JUDGE MAY: This has nothing to do with the witness's evidence.

13 Now, let's move on to another topic, which is...

14 MR. MILOSEVIC: [Interpretation]

15 Q. On page 4 of the statement, you say that on the 27th of August,

16 1991 you personally, as secretary for the Secretariat for National

17 Defence, hid the military conscript's records, put them away in a safe

18 place. Why did you do that?

19 A. I acted upon instructions of the Ministry of Defence from Sarajevo

20 because we received information that the Yugoslav People's Army would come

21 to seize these records from the secretariat by force.

22 Q. Do you know that these records were supposed to be taken over by

23 the army according to a decision passed by the Presidency of the SFRY?

24 A. That's not correct, because I would have had to receive such an

25 order. It would have had to come to my desk or to the desk of the

Page 20579

1 president of the municipality or the president of the executive council.

2 One of the three of us would have had to receive such an order, but we

3 never did receive any such order. It was only the members of the Crisis

4 Staff of the SDS came to my office and asked me by way of an ultimatum

5 that I hand them over these records and it's only natural that I could not

6 do that.

7 Q. At the same time --

8 JUDGE MAY: I'm stopping you. One at a time, please. You must

9 remember the interpreters.

10 MR. MILOSEVIC: [Interpretation]

11 Q. At the same time, you were telling Muslims not to respond to

12 call-ups, military call-ups.

13 A. That's correct, but that was in 1991, when the war in Croatia was

14 on, and I knew that these young men were being sent to the front line in

15 Croatia. I knew that personally.

16 Q. But you were head of the Secretariat for National Defence and you

17 didn't want people to go into the army and so on and so forth. So you

18 obstructed your very own work, didn't you? If you were warning Muslims

19 not to answer the call-up, why didn't you warn the Serbs too not to answer

20 the call-up?

21 A. Believe me, Your Honours, it was the Crisis Staff of the SDS that

22 came to me and asked me by way of ultimatum to hand over the records, and

23 they said to me, "If you Muslims don't want to wage war in Croatia, give

24 me the records of the Serbs. They want to wage war and they want to carry

25 out mobilisation." I could not meet such a request of the SDS Municipal

Page 20580

1 Staff.

2 Q. Very well. But at the same time, you present this activity of

3 yours as some kind of anti-war obstruction of mobilisation and hiding

4 military records; is that right?

5 A. My objective was precisely that these innocent young men do not go

6 to fight the war in Croatia, so I stand by the fact that I acted upon

7 instructions of the Ministry of Defence. So my objective was to stop this

8 mobilisation.

9 Q. Very well. These were the instructions of the Ministry of Defence

10 of Bosnia-Herzegovina.

11 A. Yes.

12 Q. But at the same time, you worked on arming the Muslim population

13 of Bratunac; is that right, Mr. Becirevic?

14 A. That is not correct.

15 Q. Well, here is a document for you. It is the centre of public

16 security from Tuzla, that is to say, Bosnia-Herzegovina, where it says:

17 "0303-766. By way of operative work in the field, on the 31st of August

18 and on the 1st of September this year, that is to say, 1991, we have

19 received several pieces of information." So you see, this is 1991. There

20 is no war; there is no conflict; there is no nothing. This is mid-1991.

21 "We received several pieces of information which indicate that in the

22 municipalities of Bratunac and Srebrenica there is an increasingly present

23 illegal procurement and distribution of weapons and ammunition as well as

24 the spreading of rumours, misinformation, disturbing the public law and

25 order, setting up armed patrols and barricades. We have been informed by

Page 20581

1 our sources Dzanic Azem, member of the Party of Democratic Action in

2 Bratunac, together with Becirevic Dzemail, secretary of the Secretariat

3 for National Defence of Bratunac, a certain Safet, director of the

4 veterinary station in Bratunac, with the knowledge of Kavazbasic Mirsad,

5 president of the municipal committee of the Party of Democratic Action,

6 Munisovic Nezir [phoen], head of the public security station in Bratunac,

7 and other members of the leadership of this party used an official car,

8 licence number ZV - that's Zvornik - 26200, owned by the Municipal

9 Secretariat for National Defence of Bratunac is bringing weapons in from

10 Sarajevo and then they are taking over these weapons from the headquarters

11 of the Party of Democratic Action and distributing these weapons to

12 persons of Muslim ethnicity in the territory of this municipality. So two

13 months ago --" I don't know "24 pistols were transferred in this way, and

14 later they were sold at a price of 15.000 dinars per piece. And then a

15 number of persons, together with Sead Hadziabdic, owner of the Royal

16 Restaurant, sold these weapons to Dzanic, yet another Dzanic, a Muslim, at

17 the price of 1.500 Deutschmark in Drinjaca, municipality of Zvornik."

18 Now, this is illegible, with a person nicknamed Taran in Konjevic

19 Polje, a restaurant owner, also Abdic Nezad and Siranovic [phoen] --

20 JUDGE MAY: I'm going to stop you. You can't just read out

21 documents at great length. The witness is giving evidence and he must be

22 able to deal with them.

23 It's alleged, you see, in this document, and we'll hear where the

24 accused got it from, but it's alleged that you, in September 1991, were

25 introducing weapons into Bratunac from Sarajevo and distributing them. Is

Page 20582

1 there any truth in that?

2 THE WITNESS: [Interpretation] Your Honours, there is no truth in

3 this. From Sarajevo to Bratunac is about 145 kilometres. Imagine someone

4 going into that kind of thing, transporting weapons from Sarajevo, where

5 there are dozens of police patrols along the way. And whoever would

6 transport this would be arrested, and nobody would allow oneself to do

7 such a thing. And imagine using a small Yugo car for that. This is a

8 small car. I never did any such thing.

9 MR. MILOSEVIC: [Interpretation]

10 Q. Well, that's the way it usually is done. Civilian cars, things

11 like that. This was a vehicle of your secretariat, and this is a document

12 of the public security centre of Tuzla.

13 THE ACCUSED: [Interpretation] And, please, I would like to have it

14 admitted into evidence.

15 THE WITNESS: [Interpretation] Well, I just want to say if this was

16 their report, why didn't they stop this? Why didn't they stop this

17 delivery? Why didn't they show the evidence and proof? These are pure

18 insinuations. This has nothing to do with the truth.

19 JUDGE MAY: Let the witness see the document.

20 THE ACCUSED: [Interpretation] Let him have a look. Let him have a

21 look at this document.

22 MR. MILOSEVIC: [Interpretation]

23 Q. Read it. It's all there, and it's all nicely highlighted, all the

24 things I asked you about. Since I am giving you the document in its

25 entirety, you can read everything that it says.

Page 20583

1 A. So I answered this question. There's no truth in this, no truth

2 whatsoever.

3 JUDGE MAY: Very well. Mr. Groome, marked for identification?

4 MR. GROOME: Yes, Your Honour.

5 JUDGE MAY: Is this a document which the Prosecution handed over,

6 in fact, or is it one the accused --

7 MR. GROOME: It was one that was handed over by the Prosecution,

8 but I have no idea of its providence. I could investigate that for the

9 Chamber.

10 THE ACCUSED: [Interpretation] I have read it out exactly as it

11 stands, Mr. May. And since there is a translation of this document, you

12 can compare, and it's theirs.

13 JUDGE MAY: We'll give it a number marked for identification.

14 THE REGISTRAR: Your Honours, Defence Exhibit 134, marked for

15 identification.

16 MR. MILOSEVIC: [Interpretation]

17 Q. So, Mr. Becirevic, do you continue to claim that in the summer of

18 1991 you were not involved in the illegal arming of Muslims in the

19 municipality of Bratunac?

20 A. It is not correct that I was involved in such efforts.

21 Q. All right. Is it correct that this entire farce, with the theft

22 and concealing of military records on the 27th of August was not anti-war

23 but it was simply aimed at opening up a new front in Bosnia?

24 A. That's not correct. On our part, we who hid this -- these

25 military records, we said what our objective was. And the objective of

Page 20584

1 the Crisis Staff of the SDS was completely contrary to that. I spoke

2 about that. I really don't want to go into it any further. If necessary,

3 I can go into the details.

4 Q. Mr. Becirevic, since you were assistant commander for religious

5 affairs, did you read the Islamic declaration? Have you read the Islamic

6 declaration of Mr. Izetbegovic?

7 A. No, I haven't. And as far as religious affairs are concerned,

8 religious matters, within my field of work I had a man who was strictly in

9 charge of that. But I dealt with other matters in the unit.

10 Q. This obstruction of carrying out the functions -- or rather, this

11 hiding of records and this arming of Muslims, wasn't all of that

12 assistance to the spectre of the Ustasha movement that rose in Croatia and

13 it is with their assistance that you actually did what you did to the Serb

14 minority in Bratunac and in this way you ensured your supremacy?

15 THE WITNESS: [Interpretation] Your Honours, I have no idea what

16 he's talking about. Bringing up the independent state of Croatia? I

17 mean, this was in the Second World War, as far as I know.

18 MR. MILOSEVIC: [Interpretation]

19 Q. Well, wasn't this repeated in the beginning of the 1990s?

20 JUDGE MAY: We won't go into that sort of argument.

21 Yes, you've got five minutes left, Mr. Milosevic.

22 THE ACCUSED: [Interpretation] Mr. May, I have an hour and 45

23 minutes after the break, because I examined him only for 15 minutes.

24 JUDGE MAY: In fact, you've got longer than five minutes. You've

25 got five minutes until the break and then I think you've got another 20

Page 20585

1 minutes. Yes.

2 THE ACCUSED: [Interpretation] Well, then we didn't understand each

3 other.

4 MR. MILOSEVIC: [Interpretation]

5 Q. Didn't you say yourself on page 4, in paragraph 4 that you went to

6 see the Minister of Defence of Bosnia-Herzegovina, Jerko Doko?

7 A. It is correct that I went.

8 Q. And he told you then what you were supposed to do with the records

9 of military conscripts and how you should obstruct the army.

10 A. It wasn't Jerko who received me. He wasn't at work then. But I

11 was received by Munib Bisic, his assistant.

12 Q. All right Munib Bisic, a Muslim, and Jerko Doko is a Croat; isn't

13 that right?

14 A. These are legal representatives of the Ministry of Defence.

15 Q. Legal representatives. And you're a legal representative too, and

16 you as a Muslim are the legal representative that obstructed his very own

17 function, and he concealed the military records that was in his hands on

18 the basis of his official duty.

19 A. I hid it from the Yugoslav army who wanted to take it out of my

20 province of work, nothing else.

21 Q. What did the Yugoslav army want to do with these documents?

22 A. What was I supposed to do if they took these documents?

23 Q. What do you care about that? You're not the superior of the

24 Yugoslav People's Army. As secretary for the Secretariat for National

25 Defence in a municipality like Bratunac, you're not their superior.

Page 20586

1 JUDGE MAY: You must slow this down. You must both remember the

2 interpreters.

3 MR. MILOSEVIC: [Interpretation]

4 Q. All right. Is it correct that you were advised when you went to

5 the ministry that you should keep the records in a secret place?

6 A. I was told that these records should not fall into the hands of

7 the Yugoslav army.

8 Q. All right. And why didn't you give the Serbs the documents that

9 pertained to the Serbs only when they asked you for it?

10 A. Because physically this documentation could not be split up,

11 because it was filed in alphabetical order and they came with the Yugoslav

12 army on that day to take it away and they asked for this to be done

13 immediately and it could not have been done immediately.

14 Q. All right. But isn't it true that they only asked you for their

15 parts of the files, the records?

16 A. On that day, they asked so that the Yugoslav People's Army would

17 not go back without having done anything. They said, "Give us at least

18 the documents pertaining to Serbs." But physically it could not have been

19 done that day.

20 Q. Isn't it correct that all the incidents on the 27th of August,

21 1991 would have been overcome only if you had given the Serbs their very

22 own records, the records they asked for? Also, it doesn't have to do with

23 lists only. It is --

24 JUDGE MAY: He can't answer that, as to what would have happened.

25 He's answered that you couldn't split them up.

Page 20587

1 MR. MILOSEVIC: [Interpretation]

2 Q. Is it correct that these records were not compiled according to

3 certain lists, the way you are trying to portray it now, or rather, every

4 military conscript has a file of his own?

5 A. Every conscript has a file of his own, but the files are in

6 alphabetical order, so one could not know who is a Serb and who is a

7 Muslim. And in this big file that weighed about 30 kilogrammes, there

8 were about 50 or 100 military files respectively, so one file had to be

9 looked at at a time, so this required at least seven days.

10 Q. How many military conscripts were there in the municipality of

11 Bratunac, please?

12 A. All military conscripts, all who would serve their military

13 service?

14 Q. How many of them were there? How many did you have in your

15 records in the municipality of Bratunac?

16 A. I didn't count, but all the Muslims and Serbs were on this list of

17 the municipality of Bratunac.

18 Q. I am not bringing that into question at all, that there were

19 Muslims and Serbs on this list. I'm asking you about the files, the

20 records. How many files, records, did you have in total? This is an

21 elementary figure which you should be aware of.

22 A. I didn't do any counting. And believe me, I do not know this

23 particular figure, what the overall number was.

24 Q. I don't believe that, that you are not aware of that. But let's

25 proceed.

Page 20588

1 On page 6, paragraph 2, you say that the Serbs from Kravica and

2 Bratunac, after the killing of two Muslims, evacuated women and children

3 to Ljubovija because they were afraid that the Muslims would seek revenge;

4 is that right?

5 A. This was staged, this moving out, because nobody was threatened by

6 the Muslims.

7 JUDGE MAY: This will be a sensible moment to stop. We're moving

8 on to another topic.

9 We'll adjourn, 20 minutes.

10 --- Recess taken at 12.30 p.m.

11 --- On resuming at 12.55 p.m.

12 JUDGE MAY: Mr. Milosevic, you were told you could have two hours.

13 You've had one hour, 40 minutes. You can have another 25 minutes, an

14 extra five.

15 THE ACCUSED: [Interpretation] And there's no possibility of

16 extending that time, is there?

17 JUDGE MAY: Let us move on.

18 THE ACCUSED: [Interpretation] Very well. Then I'll try and make

19 it brief.

20 MR. MILOSEVIC: [Interpretation]

21 Q. Mr. Becirevic, would you please give me short answers, yourself.

22 You say that you launched an attack on Kravica and that you did so because

23 you were hungry. That's what you say on page 3, paragraph 4, of your

24 statement. Is that right?

25 A. For me to give -- be able to give you yes or no answers, I have to

Page 20589












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Page 20590

1 actually explain a bit, expound. But as you just want to hear yes or no,

2 I'm not going to be able to say either, give you a yes or no answer.

3 JUDGE MAY: Just very briefly, why -- did you attack Kravica and

4 why did you do it?

5 THE WITNESS: [Interpretation] Your Honours, on the 17th of April,

6 1992 -- or rather, from that date up until the 7th of January, we were

7 under a complete siege, and it was precisely because of that complete

8 siege we had no possibility of having any assistance in the way of food,

9 clothing, or anything else brought in to us.

10 JUDGE MAY: Very well. Thank you.

11 Yes.

12 MR. MILOSEVIC: [Interpretation]

13 Q. You also said that on that occasion - and I'm quoting you - you

14 say, "We decided to set up a corridor for the women and children wishing

15 to leave the village. Once we'd entered the village, we just came across

16 soldiers who had decided to stay on and fight." Is that what you said?

17 A. Yes.

18 Q. Now, tell me this, please: What date did you launch your attack

19 on Kravica?

20 A. The beginning of January, 1993.

21 Q. You did that on the 7th of January, 1993; isn't that so,

22 Mr. Becirevic?

23 A. Yes, that is so.

24 Q. Well, do you know that the 7th of January is precisely Orthodox

25 Christmas, so you attacked the place for the Orthodox Christmas?

Page 20591

1 A. That's how it turned out.

2 Q. Oh, I see. That's how it turned out, did it?

3 Now, is it also true that in addition to Kravica, on that same day

4 you attacked the other hamlets, Brana, Bacici [phoen], Popovici, Mandici

5 [phoen] and so on, Popravdici, which make up an area of about 2.300

6 inhabitants together with Kravica, which is where the older Serb school is

7 located, which was erected in 1864; is that right?

8 A. Yes.

9 Q. So you attacked the Serbs on their Christmas. You say you left a

10 corridor open for women and children and that it was just the soldiers who

11 remained.

12 Now, do you know, for instance, that you slaughtered Mara Bozic,

13 born in 1909, a lady who was born in 1909, her throat was cut; Kristina

14 Eric, another elderly woman; Risto Popovic, born in 1920, a man; Vaso

15 Nikolic, born in 1920; Mitar Nikolic, 1927. Those are their dates of

16 birth. Ljubica Obacki, another woman, born in 1918; Vladimir Stojanovic,

17 born in 1915; and so on and so forth. You killed them, you slit their

18 throats, you slit the throats of elderly men and women, and only three

19 soldiers were killed, only three military-able men, in fact, not to say

20 soldiers. Men of fighting age. Is that right, or not?

21 A. Well, I don't know the names. I can't tell you. You can read out

22 any number of names you like, I don't know the people.

23 Q. So you don't know who the people were whose throats were slit in

24 Kravica, that they were all elderly people, men and women?

25 A. I don't know that that was what happened at all.

Page 20592

1 Q. All right. And is it true that in the attack, in addition to you,

2 there was Naser Oric taking part, Zulfo Tursunovic, Ferid Hodzic, Becir

3 Mehanic [phoen], Bajra Osmanovic nicknamed Mis [phoen] or mouse, Nedjad

4 Bektic [phoen], Hadija Mehulic [phoen], Veiz Sabic, Nedjad Set [phoen],

5 and so on?

6 JUDGE MAY: Just reading out a list of names makes it quite

7 impossible for the witness to answer.

8 But more seriously, what is alleged is that --

9 Wait a moment. He can deal with the allegation you make.

10 What is suggested is that, during the attack, the throats of old

11 people were cut. Now, is there any truth in that?

12 THE WITNESS: [Interpretation] Your Honours, there's no truth in

13 that whatsoever.

14 MR. MILOSEVIC: [Interpretation]

15 Q. Well, there are facts and figures about all these persons killed,

16 Mr. Becirevic.

17 A. I wasn't there for me to be able to have seen that with my own

18 eyes.

19 Q. So you didn't participate in the attack on Kravica.

20 A. No, I did not take part in the attack on Kravica.

21 Q. Tell me this, then, please: On that same day, in addition to

22 Kravica, did you also attack the village of Siljkovici?

23 A. That belonged to the area of the Kravica local community.

24 Q. And all that belongs to Konjevic Polje, does it not, that general

25 area?

Page 20593

1 A. But from that place called Kravica, for a full eight months, on a

2 daily basis dozens of women and children were killed in Konjevic Polje.

3 So Kravica is the place from which most of the grenades, shell -- tank

4 shells, Howitzer attacks and so on were launched.

5 Q. So in addition to those tanks and Howitzers, you stormed the place

6 and slaughtered these elderly people, and Siljkovici was another place you

7 attacked on Christmas Day; isn't that right? Is it right or not?

8 A. That was a military operation of the classical type, in a counter

9 onslaught, a counterattack on the forces of the Bosnian Serbs, and quite

10 normally this was done in military fashion.

11 Q. So you consider that to be military fashion, do you? All right.

12 On the 16th of January, did you attack the village of Cosici,

13 where you also slaughtered 15 Serbs?

14 A. I don't know of that village at all.

15 Q. On that same day, did you attack the village of Kusici and killed

16 a further 20 Serbs there too?

17 A. Those villages are around the Srebrenica area. I don't know them.

18 Q. Did you attack Skelani and kill 13 Serbs?

19 A. Once again, the Srebrenica municipality, which I don't know about.

20 Q. So you didn't take part in that?

21 A. I was only in Konjevic Polje and defended Konjevic Polje. That's

22 all.

23 Q. All right, tell me this, please: I'm asking you about the rest of

24 the villages in the Bratunac area. Did you take part on the Bljeceva

25 attack on the 6th of May, 1992?

Page 20594

1 A. It's got nothing to do with the free territories of Konjevic

2 Polje. That is a local community which gravitated towards Srebrenica. So

3 the forces from Konjevic Polje were not able to do anything of the sort

4 because of Kravica.

5 Q. So you know nothing about how Kosana Zekic, an old lady in the

6 village of Bijena [phoen] was slaughtered on the 6th of May along with

7 three other Serbs. Radojko Milosevic was burnt alive.

8 A. Well, those villages are not around Konjevic Polje, so don't ask

9 me about them.

10 Q. And do you know that the 6th of May is once again a religious

11 holiday? It is St. George's Day, Djurdjevdan.

12 A. Let me state again they are all villages around Srebrenica and I

13 have nothing to do with them.

14 Q. Did you take part in the attack on the village of Oparci on the

15 1st of June, 1992?

16 A. Never heard of the village of Oparci.

17 Q. And what about the attack on the village of Metaljka on the 2nd of

18 June 1992? Did you take part in that?

19 A. That's Cers Gordi [phoen], Vlasenica municipality. Once again, we

20 have nothing to do with that. No forces from Konjevic Polje at all.

21 Q. What about Ferid Hodzic from Cerska? Do you know about him? He

22 completely destroyed the village.

23 A. I did see Ferid Hodzic during the siege of Konjevic Polje in

24 Cerska, so I know the man. I can say I know him.

25 Q. Did you take part in the attack on the Rupovo Brdo village on the

Page 20595

1 10th of June, 1992?

2 A. Once again, the Vlasenica municipality, with which I or the units

3 from Konjevic Polje had nothing to do.

4 Q. All right. Who did they have something to do with, the units from

5 Konjevic Polje? Only with the village of Kravica, nobody else?

6 A. Well, if you want an exact answer, they had things to do with the

7 Milici unit, which is the Semiser [phoen] region, and in that region no

8 Serb village was burnt to the ground. There was the Drina River there on

9 the opposite side, so that the people they did have contact with was

10 Kravica.

11 Q. So your responsibility only stretched to Kravica, to include

12 Kravica; right?

13 A. If you were to look at the Konjevic Polje units and the Kravica

14 and so on, I see no responsibility there at all.

15 Q. You mean the old lady and the old men you slaughtered? That's no

16 -- you have no military accountability and responsibility for that?

17 A. The units from Konjevic Polje never perpetrated those acts.

18 Q. All right. Did you take part in the attack on the village of

19 Ratkovici?

20 A. Once again, you're mentioning a village around Srebrenica with

21 which I have nothing to do.

22 JUDGE MAY: You're wasting your time and ours going over these

23 matters which are outside the witness's knowledge. If it's relevant, you

24 will be allowed to call evidence about these matters. But it's no good

25 trying to attack the witness with matters which he knows nothing about.

Page 20596

1 THE ACCUSED: [Interpretation] Well, Mr. May, in view of the post

2 he held and the region concerned, it is my assumption that he did know

3 about it. The fact that he says he doesn't know about it is quite another

4 matter.

5 JUDGE MAY: You've heard what he says and you're -- you are bound

6 by his answer. He doesn't know about it. Now, let's move on.

7 THE ACCUSED: [Interpretation] Well, I am moving on, Mr. May, and I

8 will prove that he had every knowledge of that.

9 MR. MILOSEVIC: [Interpretation]

10 Q. Did you take part in the attack on the Serbian village of Loznica

11 on the 28th of June, 1992?

12 A. Once again you're asking a question about something that the units

13 in Konjevic Polje had nothing to do with.

14 Q. And the village of Brezane? Anything to do with that?

15 A. Well, do you know how far that is from Konjevic Polje?

16 Q. And the village of Zagone?

17 A. Once again, the same answer; nothing to do with that. Konjevic

18 Polje has nothing to do with that.

19 Q. All right. Did you take part in the attack on the Serbian village

20 of Krnjici?

21 A. That's far away somewhere again. So my answer is the same as to

22 your other questions.

23 Q. So you know nothing about the attacks on these villages. You and

24 your colleagues in the headquarters, the staff, you didn't dovetail your

25 actions and have anything to do with those villages?

Page 20597

1 A. Mr. Accused, you must understand that Konjevic Polje was a

2 separate enclave, quite separate from the Srebrenica enclave, and it

3 really did have nothing to do, have any contacts with them in the course

4 of 1992, right until these areas fell, and the demilitarised zone of

5 Srebrenica was set up.

6 Q. What about the village of Zalazje, an attack there when 39 Serbs

7 were killed and slaughtered?

8 A. My answer is the same. Konjevic Polje is a long way away, 30

9 kilometres away and has nothing to do with that.

10 Q. How about the attack on Laducic [phoen]? Do you know anything

11 about that?

12 A. Kravica separated the enclave of Konjevic Polje from the free

13 territories around Srebrenica, so that any attempt to pass through that

14 terrain was sanctioned, that is to say, there were ambushes set up by the

15 Bosnian Serb forces.

16 Q. Did you take part in the attack on the Erzestica village on the

17 2nd of August when 55 houses were set alight and Serbs killed there?

18 A. Once again, this came under the responsibility of the Srebrenica

19 units and we from Konjevic Polje had nothing to do physically with the

20 village of Erzestica and the people who were there will be able to bear

21 this out.

22 JUDGE MAY: Why don't you read out all the remaining attacks which

23 you allege and the witness can deal with that, rather than this

24 time-wasting.

25 THE ACCUSED: [Interpretation] Very well.

Page 20598

1 MR. MILOSEVIC: [Interpretation]

2 Q. A moment ago you said that you had some military operations

3 underway in Milici; right?

4 A. No, I didn't say that. I said we just had a defence line up

5 there.

6 Q. All right. You call it a defence line. On the 24th of September,

7 did you in fact, in the Serbian village Podravinja, kill 31 Serbs from the

8 village?

9 A. The accused is once again saying the same thing. As you're not

10 from the area, I can't answer that question. Konjevic Polje did not have

11 a defence line towards Podravinja because, once again, that is some 30 to

12 40 kilometres away and is in between the forces of the Bosnian Serbs and

13 the other side.

14 Q. All right, Mr. Becirevic. Could you then tell me at least how

15 many Serbs were killed at your hand and by your hand?

16 A. Thank God by my hand not a single Serb was killed. Now, how many

17 Bosniaks fell victim to the Serbs, and in Bratunac in the space of one

18 month the figure was 1.000 women, children, and elderly persons without

19 setting up any resistance, and that would have happened in Konjevic Polje

20 had there not been resistance on the 29th of May, 1992 when the units of

21 the Yugoslav People's Army, together with the paramilitary formations and

22 local Serbs, suffered their first defeat in the Bratunac municipality. Up

23 until then, the Serb forces came upon no resistance whatsoever and were

24 able to perform ethnic cleansing, expel the population from those areas,

25 and killed, as I said, 1.000 people.

Page 20599

1 Q. I asked you about your own responsibility and accountability and,

2 according to my information, you are responsible for the killing of 68

3 civilians in Kravica on Christmas Day 1993 and 20 civilians in Donji

4 Magasici and Bozici. Is that true or is it not, Mr. Becirevic? You

5 didn't question or challenge Kravica. Now I'm asking you whether you're

6 responsible for the killing of 68 civilians in Kravica on Christmas Day

7 1993?

8 A. No, I did not take part in that at all. That is not true, and I

9 can prove where I was on that particular day. So that's got nothing to do

10 with me.

11 Q. All right. And are you responsible for the killing of these

12 detainees, amongst them Milutin Milosevic, the chief of MUP? Are you

13 responsible for that particular killing?

14 A. I don't know what killing you're talking about. Milutin Milosevic

15 led a unit of the Yugoslav People's Army and paramilitary formations in

16 the attack on Konjevic Polje on the 29th of May, and in the fighting

17 Milutin Milosevic lost his life. He was killed at Konjevic Polje. So

18 nobody went to Bratunac at all to attack Bratunac. It was Milutin

19 Milosevic who came with his units, with the units of the JNA, to cleanse

20 Konjevic Polje of the people and to kill the people there. That's the

21 truth.

22 Q. All right. And tell me this, please: As you say that he was

23 killed in the fighting, killed in battle, isn't it true that your fighters

24 captured Milutin Milosevic alive, that they tortured him, killed him, and

25 left him there?

Page 20600

1 A. Believe me when I say that I was told that Milutin was killed in

2 battle and that he had a loudspeaker with him at the time and that he

3 spoke over the loudspeaker. He said, "You should kill and set fire to

4 everything and not well-to-do houses because they're full of booty."

5 That's what Milutin said and Milutin Berisic [phoen]. They had a

6 loudspeaker in their hands and that's how they led the attack from the

7 Kravica direction towards Konjevic Polje on that particular day.

8 Q. And do you know, for example, that in the report by Masovjetski --

9 that's his famous report where he says that he was in fact killed by the

10 Serbs so as to blame the Muslims, be able to blame the Muslims for that

11 killing. Now, who's lying? We'll leave it up to others to determine.

12 JUDGE MAY: I've stopped you. The witness can't answer about that

13 report, and he's dealt with the death of this man. He's given his

14 evidence about it.

15 MR. MILOSEVIC: [Interpretation]

16 Q. All right, Mr. Becirevic. In paragraph 4, page 7, you speak about

17 an event where allegedly the JNA came to Konjevic Polje in order to disarm

18 your Muslim forces; is that so?

19 A. Just let me find it. Which paragraph?

20 Q. Page 7, paragraph 4.

21 A. I didn't find it, actually, but I know what you're talking about.

22 I know that the Yugoslav People's Army on the 27th of April in the morning

23 came into Konjevic Polje, encircled it, and demanded a handover of all

24 weapons. On that day I saw with my own eyes Miroslav Deronjic dressed in

25 uniform, who had come into my village, Hrncici, asking that Muslims turn

Page 20601












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13 English transcripts.













Page 20602

1 over their weapons to Serbs and saying that nothing would happen to them

2 in return.

3 Q. I'm asking you about something in your statement, and you are now

4 mentioning a person who was not a JNA member. He was a member of the

5 Bratunac TO.

6 In the same paragraph where you say that allegedly the JNA came to

7 Konjevic Polje to disarm your Muslim forces, you say that you were not

8 putting up resistance because there were only a few of you men with arms.

9 A. We were not putting up resistance because we had nothing to put up

10 resistance with, whereas they came with APCs and we couldn't resist such

11 force.

12 Q. Okay, Mr. Becirevic. You say in the same paragraph, "The Serbs

13 who had come on armoured personnel carriers, trucks with a huge amount of

14 weapons, thus broke through our defences." That's what you say. "They

15 tried to encircle the village and during that operation two of our men

16 were killed and two were wounded. Since dark was falling, they decided to

17 retreat." Is that what you stated?

18 A. Yes. That's the truth.

19 Q. Fine. Then explain, since you say you were not putting up

20 resistance and that only a few of you had weapons, while saying at the

21 same time that unbelievably strong Serb forces managed to break through

22 your defences, how is that possible? How come they broke through your

23 defences when they didn't even manage to encircle the village? At the

24 same time, you were not putting up resistance and you had two men killed

25 and 1992 men wounded.

Page 20603

1 A. I was referring to fighters who withdrew from the village when

2 these forces came, and there was no resistance from our side.

3 Q. But you say they broke through your defences.

4 A. There were no defences. They came into those villages without

5 encountering any resistance. Nobody fired a single round. Their only

6 intention was to seize the weapons peacefully.

7 Q. Okay. You say they did not manage to encircle the village. How

8 come they didn't manage, if you were not putting up any resistance?

9 A. They came into every village and hamlet on APCs.

10 Q. But aren't you saying that those strong Serb forces drove away

11 their wounded on APCs?

12 A. Not Serb wounded. What is curious is they collected those wounded

13 Bosniaks who had been wounded by Serb forces and they drove them to

14 Bratunac and Ljubovija for treatment. They drove them away. That's what

15 I was talking about.

16 JUDGE MAY: Your time is almost up, you should be warned. You've

17 got two more questions.

18 MR. MILOSEVIC: [Interpretation]

19 Q. All right. How can you claim all this about these monstrously

20 strong Serb forces? How can you say all that you've just said and assert

21 that in this all-out attack on Konjevic Polje you had 11 casualties,

22 whereas these monstrous Serb forces, monstrously strong forces, had 44

23 wounded?

24 A. I was talking about the 29th of May, when we put up resistance to

25 those strong Serb forces for the first time. First of all, it was the JNA

Page 20604

1 who aggressed Konjevic Polje, together with people from -- veterans from

2 Vukovar and local forces. We put up resistance because we had seen what

3 happened in Hranca, Glogova, in a school in a neighbouring village where

4 500 civilians were killed. That's why we started to put up resistance.

5 They didn't allow these forces to come in.

6 Q. I'm not questioning the reasons why you fought there. You are

7 representing the Muslim side as unarmed civilians with only a couple of

8 men under arms, and the result, which you don't deny, is that those forces

9 had 44 casualties, that is, four times more men killed than you did. How

10 come those unarmed people succeeded in killing 44 soldiers of those Serb

11 forces which were allegedly attacking you?

12 A. Your Honour, this is really the truth: We were attacked by five

13 tank, five APCs. There was more support from artillery from Serb

14 positions. Many barrels were trained on Konjevic Polje, which was

15 defended exclusively by people armed with light infantry weapons. On that

16 morning we were lucky enough to capture one APC, which had been on a

17 reconnaissance mission, and we trained the barrel of this APC towards the

18 attackers. That was the success we had scored. I think that was the

19 first defeat suffered by the JNA in Bratunac municipality. And it was

20 inflicted on them by these defenders who did not allow themselves to share

21 the fate of other surrounding villages.

22 THE ACCUSED: [Interpretation] What is the problem, Mr. May?

23 JUDGE MAY: Mr. Tapuskovic.

24 THE ACCUSED: [Interpretation] Just one more question, please.

25 JUDGE MAY: You've had plenty of time and you've wasted much of

Page 20605

1 it.

2 Questioned by Mr. Tapuskovic:

3 Q. [Interpretation] Witness, during your examination-in-chief you

4 mentioned the Red Berets today, didn't you?

5 A. Yes, Your Honours. I mentioned them too.

6 Q. You then mentioned convoys coming from Srebrenica towards Tuzla.

7 A. Yes.

8 Q. You mentioned the aviation coming from the direction of Serbia.

9 A. Yes, on a daily basis.

10 Q. You mentioned about a thousand or more civilians killed.

11 A. Yes, over a month, in Bratunac and the surrounding area.

12 Q. You also mentioned 12 to 15 thousand people killed in a column of

13 moving people.

14 A. Yes.

15 Q. But you failed to mention all that when you gave your statement on

16 the 24th of January, 1994 and more recently this year. Why didn't you

17 mention that?

18 A. The last time I was here I spoke about everything in detail.

19 These are the facts that I presented the last time I spoke to the

20 investigators here in The Hague.

21 MR. TAPUSKOVIC: [Interpretation] While Mr. Groome was questioning,

22 I didn't make any objections, but all these things are not contained in

23 the statement. If something is introduced under Rule 92 bis, I don't

24 think we should go beyond that Rule. Otherwise, the cross-examination is

25 prejudiced. That would be my objection as amicus curiae. I believe that

Page 20606

1 the examination-in-chief should stay within the scope of the statement

2 provided to you and to the opposing party and not go beyond it.

3 JUDGE KWON: No, I don't think so. Part of this evidence was

4 introduced by way of 92 bis, but the other part was given live.

5 MR. TAPUSKOVIC: [Interpretation] All right. I understand.

6 JUDGE MAY: The reason is that there may be something which the

7 witness doesn't mention in his statement which may be important which he

8 mentions when he comes here. Experience shows that this does happen.

9 Yes.

10 MR. TAPUSKOVIC: [Interpretation] I agree. I agree with you

11 completely. But it does prejudice my preparation for cross-examination to

12 a certain extent. However, I appreciate your opinion.

13 Q. Still, Witness, is it true that on the 1st of September, 1991 the

14 anniversary of the establishment of Bratunac village was celebrated?

15 A. Believe me, I don't remember the date.

16 Q. But was there a celebration of the anniversary?

17 A. I didn't participate in that. I claim that under full

18 responsibility. I doubt it very much that anybody could celebrate

19 anything, because we had serious problems in Bratunac.

20 Q. Did you hear that in Bratunac a gathering of 10.000 people was

21 addressed by Nurif?

22 A. I heard that Nurif made a speech at that rally, but I don't know

23 anything else.

24 Q. Do you know that he finished with these words: "Allah Imanet and

25 see you on the battlefield next year"? Did you hear him say that before

Page 20607

1 10.000 people?

2 A. He is a former JNA officer. He probably had information to that

3 effect, and that's why he made the statement. I can't make any further


5 Q. Thank you. Regarding your statement - paragraph 4, Your Honours -

6 you said in the first sentence: "Before the war, in the municipality

7 there were no JNA barracks. We only had the weapons which belonged to the

8 Territorial Defence." Is that so?

9 A. It's true that in Bratunac there were no barracks whatsoever and

10 the only weapons were those belonging to the TO, which the JNA later

11 removed from those depots.

12 Q. All right. You then go on to say, "That included mortars,

13 recoilless guns," and you also mentioned here "rocket launchers, automatic

14 rifles, and a lot of explosives such as grenades and mines." Is that so?

15 A. That was what the report said. I never entered those depots, but

16 from the reports, these weapons were enough to arm a brigade. That's what

17 I know.

18 Q. I'd like to ask you this first: These TO units throughout

19 Yugoslavia, you as an educated man, a lawyer, do you know when this

20 practice started wherein every municipality and every village received

21 weapons of this sort?

22 A. I know that these weapons belonged to the people of Bratunac

23 municipality, and it was the people of Bratunac municipality contributed

24 funds for the purchase of these weapons. However, the Yugoslav People's

25 Army collected the weapons and took them away.

Page 20608

1 Q. One thing remains unclear: You've said it happened in 1989.

2 A. I said that, to the best of my recollection. It was a long time

3 before the democratic elections held in 1990, in any case.

4 Q. But here on page 2, paragraph 8, you talk about the elections and

5 the establishment of the Municipal Assembly; is that so?

6 A. Yes.

7 Q. And you were secretary for National Defence.

8 A. Yes.

9 Q. And Sabit Mujkic was commander of the Territorial Defence, and you

10 say here that you demanded that certain decisions be made on the

11 replacement of general managers. If this was indeed removed in 1989, did

12 you raise this issue before the Assembly, the issue of the Territorial

13 Defence lacking any weapons whatsoever?

14 A. When I took over that job, that post, those weapons were not

15 there. Even if I had raised the issue, I knew it would not be returned by

16 the JNA, so it made no sense.

17 Q. Now, please pay attention to paragraph 27. When this column of

18 the JNA arrived, you didn't know how to cope with it. You didn't know

19 what to do at first.

20 A. Do you know what weapons I'm talking about here?

21 Q. Just tell me, did you indeed say that you didn't know what to do

22 at first?

23 A. That's true.

24 Q. And then somebody remembered that in the neighbouring commune

25 there was a hand-held rocket launcher. Is that the same sort of hand-held

Page 20609

1 rocket launcher that everybody in the TO had?

2 A. Yes, that was a Zolja hand-held rocket launcher located in Cerska.

3 On the 29th of May, 1992 we had nothing to stop these tanks with and they

4 broke into Konjevic Polje. It was our good fortune that they torched --

5 that we torched a truck that was in the middle of the road and blocked

6 their passage, and then somebody remembered that in the neighbouring

7 populated area there was this Zolja rocket launcher.

8 Q. I'd like to finish quickly. So somebody remembered that in the

9 neighbouring commune you had this weapon, and you used it to destroy the

10 first tank, not the APC.

11 A. Yes. We used the rocket launcher, whereas the APC was transferred

12 to the hill to fight the infantry.

13 Q. Tell me one more thing: When you removed the records of

14 conscripts from the administration, did you also collect the entire

15 weaponry of the Territorial Defence along with the records?

16 A. I didn't. All that was left in the Secretariat for National

17 Defence when I came there were these papers, the records.

18 Q. Thank you. Thank you, Witness.

19 MR. GROOME: Just a couple of questions.

20 Re-examined by Mr. Groome:

21 Q. Sir, this attack that we're talking about now, would it be fair to

22 say that by the 29th of May your village was completely surrounded by Serb

23 forces?

24 A. Your Honours, our village was encircled from all sides until the

25 29th of May. All the villages in Bratunac municipality were ethnically

Page 20610

1 cleansed. Konjevic Polje was the only one still standing, and that's why

2 they attacked it, to finish us off, to finish what they had already done

3 in all the other local communes.

4 Q. The accused put to you correctly that Mr. Deronjic was not

5 officially a member of the JNA. My question to you is: On the initial

6 attack on your village, did you see Mr. Deronjic in the company of JNA

7 troops?

8 A. Your Honours, Deronjic was accompanying the JNA on the 27th of

9 April when they took over the weapons and barged into our village.

10 Deronjic was also present on the 29th of May, carrying a loudspeaker, as

11 well as Milutin Milosevic. They were accompanying the JNA together.

12 Q. My question to you is: When you saw Mr. Deronjic in the company

13 of the JNA, where precisely was he?

14 A. The first time they entered, on the 27th of April, Deronjic was on

15 top of an APC when --

16 MR. GROOME: I have no further questions of this witness, Your

17 Honour.

18 I do have some information with respect to Judge Kwon's query and

19 with respect to Defence Exhibit 134.

20 JUDGE MAY: Let us allow the witness to go.

21 Mr. Becirevic, thank you for coming to the Tribunal to give your

22 evidence. It's now concluded. You are free to go.

23 THE WITNESS: [Interpretation] Thank you.

24 [The witness withdrew]

25 JUDGE MAY: Yes, Mr. Groome.

Page 20611

1 MR. GROOME: Your Honour, with respect to Prosecution Exhibit 443,

2 tab 8, as Judge Kwon pointed out, part of that exhibit were two letters

3 that appear in some ways to be identical but yet there seem to be some

4 differences, namely the stamp and the handwriting seems to be different.

5 I just -- I do have some information regarding the providence of them, and

6 we will be filing an exhibit, as I referenced, I believe, two weeks ago

7 with respect to where these documents came from.

8 Both of these documents came from the same place at the same time.

9 They were received from the Republika Srpska National Assembly building,

10 the archive, and they were tendered to us by Ms. Rajka Stanisic, the

11 administrator of the Assembly and the person responsible for that archive.

12 That was done with the consent of the RS government, and they were turned

13 over to us on the 2nd of February, 1998.

14 As Your Honours will notice, the evidence record numbers of the

15 two documents are consecutive, indicating that they were taken into

16 possession at the same time. Members of our staff have some ideas why

17 there are two originally executed copies, but rather than speculate on

18 that, if the Court thinks it is an issue, we can seek to have a statement

19 from Mrs. Stanisic, the keeper of these records, as to how there are two

20 copies.

21 I would point out to Your Honours that similar documents in -- in

22 double copies exist for the municipalities of Zvornik and a few -- and at

23 least one other municipality, the name escapes me at the moment. But it

24 seems to have been not irregular that two copies exist.

25 One matter that I would point out: That Mrs. Stanisic was

Page 20612












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13 English transcripts.













Page 20613

1 responsible for not only the Assembly archive but also the archive of the

2 Presidency, and that may be one possible explanation as to why two copies

3 exist.

4 Now, with respect to D134, that was provided to the Office of the

5 Prosecutor in November of 2002 in cooperation -- In cooperation with the

6 Republika Srpska government, members of our staff were allowed to look at

7 documents in the records of the Republika Srpska intelligence security

8 service, and that document was found in that collection. The author of

9 the document or anything else about the origination of the document, I'm

10 unable to provide at this time.

11 Your Honour, just in terms of taking stock, the Prosecution did

12 not play an intercept, tab 1 of 443. Tab 3, we ask that it be simply

13 marked for identification. And remainder of the exhibits, 2 and 4 through

14 10, the Prosecution is formally tendering.

15 JUDGE MAY: Very well.

16 [Trial Chamber and registrar confer]

17 JUDGE MAY: Tab 1 is withdrawn. The remainder, of course, are

18 admitted, one marked for identification.

19 Now, Mr. Groome, the next witness is Mr. Banjanovic. We will sit

20 until 2.00. Normally one wouldn't want to start another witness. I don't

21 know if it's a matter for you. We will admit his statement under Rule 92

22 bis. Of course, we're not sitting for the next week. Do you want to make

23 a start or leave it until next week?

24 MR. GROOME: If it's all right with the Court, we would wish to

25 make a start.

Page 20614

1 JUDGE MAY: Very well, since you're under the pressure of time.

2 MR. GROOME: Your Honour, perhaps while we're waiting, could I ask

3 that exhibit numbers be assigned to both the 92 bis package and a binder

4 of nine exhibits that we will use with this witness?

5 JUDGE MAY: Yes, certainly. I'm not sure if we've got the

6 exhibits.

7 Yes, can we give them the numbers.

8 THE REGISTRAR: Your Honours, Rule 92 bis statement is

9 Prosecutor's Exhibit 444, and the exhibits tab 1 to 9 will be Prosecutor's

10 Exhibit 445.

11 [The witness entered court]

12 JUDGE MAY: If you'd like to take the declaration.

13 THE WITNESS: [Interpretation] I solemnly declare that I will speak

14 the truth, the whole truth, and nothing but the truth.


16 [Witness answered through interpreter]

17 JUDGE MAY: If you'd like to take a seat now.

18 THE WITNESS: [Interpretation] Thank you.

19 Examined by Mr. Groome:

20 Q. Sir, I'd ask you to state your name.

21 A. Fadil Banjanovic.

22 Q. Sir, the Chamber has accepted your verified statement, the

23 statement you verified in front of a registrar last week -- or this week,

24 I'm sorry, as Prosecution Exhibit 444, so I will be dealing with just

25 particular aspects of your testimony.

Page 20615

1 I would ask that we begin your testimony by having you look at

2 Prosecution Exhibit 445, tab 1, and ask you, do you recognise that

3 document?

4 A. Yes.

5 Q. Is that a summary of your educational and professional background?

6 A. Yes.

7 Q. Thank you. Mr. Banjanovic, the Chamber has heard from other

8 witnesses from the Zvornik municipality about some of the events leading

9 up to the outbreak of hostilities there. I want to draw your attention to

10 the middle of April, and I'd ask you to focus on the situation in your

11 municipality, and would you be -- in your village. I'd ask you to begin

12 by telling us what was the name of the village that you lived in at that

13 time.

14 A. Kozluk, the municipality of Zvornik.

15 Q. And where was Kozluk with respect to the downtown area of Zvornik

16 municipality?

17 A. Kozluk is on the Drina River in Bosnia-Herzegovina, on the road

18 leading from Zvornik to Bijeljina.

19 Q. And approximately how many kilometres outside of Zvornik is it?

20 A. About 20 kilometres.

21 Q. And can you also help orient the Chamber. Approximately how --

22 are you familiar with the village of Celopek? And if so, where is that

23 with respect to Kozluk?

24 A. Celopek is one of the Serb villages in the municipality of

25 Zvornik, and it is on the road from Zvornik to Bijeljina, towards Kozluk.

Page 20616

1 That's where Celopek is.

2 Q. Now, if I can return to my initial question to you: At the time

3 that hostilities broke out in the Zvornik municipality by the middle of

4 April, can you please characterise your situation in your commune of

5 Kozluk.

6 A. Well, Kozluk was a multi-ethnic community, and it was quite

7 peaceful. While, for example, in the surrounding villages, there were

8 quite a few clashes and hostilities.

9 Q. What was your position within the commune of Kozluk?

10 A. At that time, I was an ordinary citizen.

11 Q. Drawing your attention to the beginning of the 5th of April, did

12 you make a written announcement to the citizens of Kozluk, encouraging

13 them to remain peaceful and to try to avoid confrontation?

14 A. Yes.

15 Q. I'm going to ask that you take a look at Prosecution Exhibit 445,

16 tab 2. I'm handing the original to you. A copy of this will be visible

17 on the screens in the courtroom. Is that the announcement that you made?

18 A. Yes.

19 Q. And is that your signature at the bottom?

20 A. Yes.

21 Q. I'd ask you just to read paragraphs 4 and then paragraph 8.

22 A. "We call on the local population not to further undermine trust

23 already significantly undermined and to preserve co-existence and a life

24 together."

25 Q. And if you would, paragraph 8.

Page 20617

1 A. "We call upon all citizens to gather tomorrow at 1800 hours for a

2 rally, a peace rally that will be held at the centre of Kozluk, which will

3 be attended also by the citizens of the local communes of Tabanci,

4 Malesic, Rijic, and Skocic."

5 Q. And did such a peace rally take place?

6 A. Yes.

7 Q. Once again, to avoid confrontation, did the -- did citizens of

8 Kozluk surrender their weapons upon the demand of local Serb authorities

9 of Zvornik?

10 A. Yes.

11 Q. I'm going to ask that you take a look at Prosecution Exhibit 445,

12 tab 3. I'm handing -- having the original handed to you. Can you please

13 describe for us what is this exhibit.

14 A. This involves the citizens of Kozluk, both Bosniaks and Serbs. 90

15 per cent of them are hunters who had their own hunting guns.

16 Q. Is that your signature on the last page of this document?

17 A. Yes.

18 Q. Without going through the specific weapons that are detailed on

19 that document, can you just generally characterise the type of weapons

20 that were turned over and memorialised on that receipt.

21 A. We handed the weapons over through a commission that consisted of

22 a few citizens of Kozluk. The weapons were registered. They were

23 German-made, and also there were a few pistols that were privately owned

24 and duly registered.

25 Q. Sir, I will ask you some questions about whether or not an attack

Page 20618

1 occurred on Kozluk. My question to you for this -- at this stage is

2 simply: Was there an attack on Kozluk, and can you give us the date that

3 that attack began?

4 A. There was shooting often around Kozluk, and large-scale national

5 tensions were on the rise. Big military and paramilitary units passed

6 through there and the situation was tense, generally speaking. During the

7 night between the 20th and 21st, a staged attack took place against

8 Kozluk, carried out by various formations from the surrounding places.

9 Q. Sir, I will ask you some detailed questions about that. But what

10 I'm interested in now is the period of time between April and the 20th of

11 June. During that time period, was there any outright violence in the

12 village of Kozluk during that period of time?

13 A. Yes.

14 Q. Can you describe it or characterise it to the extent of that

15 violence?

16 A. Well, this was pressure against the citizens themselves who were

17 trying to live peacefully. These pressures had to do with the

18 increasingly frequent shooting that took place. Grenades were thrown.

19 There was intimidation. Military, paramilitary, and other units went on

20 with incursions into Kozluk itself.

21 Q. Towards the latter part of May, the Yugoslav People's Army

22 formally withdrew from Bosnia-Herzegovina. Were you in a position in

23 Kozluk to see any of those troops as they withdrew from Bosnia?

24 A. In that period, we were totally surrounded. Long columns of

25 military vehicles went through Kozluk. They involved tanks, APCs, trucks

Page 20619

1 with JNA insignia, with a five-pointed star and the flag. What we found

2 strange was that this was no longer the Yugoslav People's Army, the one

3 where I did my military service. In these vehicles and on these vehicles

4 one could see men with fur hats, cockades, wearing beards, who were

5 shouting, throwing bottles in the centre of Kozluk, stopping vehicles, and

6 also satisfying their physiological needs on the road itself. This was

7 not the Yugoslav People's Army where I had done my military service and

8 where other people had done their military service. Many columns were

9 moving along the road between Zvornik and Bijeljina.

10 Q. Sir, during this period of time, after the beginning of April and

11 up until the 20th of June, could members of the Kozluk community, could

12 they travel down to the town of Zvornik? Would they be permitted to do

13 so?

14 A. No.

15 Q. Were they permitted to travel to Tuzla?

16 A. No.

17 Q. Was there any place that people in Kozluk could go if they wanted

18 -- if they chose to leave Kozluk?

19 A. Yes.

20 Q. Where was that?

21 A. It was Loznica, and other places in Serbia, with special passes

22 issued by the authorities in Zvornik.

23 Q. How was that communicated to the people of Kozluk?

24 A. Well, quite simply, we were surrounded. Serb guards and

25 barricades from neighbouring villages were all around us. The Serb police

Page 20620

1 that was in Kozluk could issue passes for those citizens who wished to go

2 to Serbia. However, major financial resources were required for that.

3 Q. Now, did some people from Kozluk in fact leave Kozluk and go to

4 Serbia or through Serbia?

5 A. Yes.

6 Q. Did there come a time when the situation surrounding Kozluk became

7 significantly, or so dangerous that you yourself wished to leave Kozluk?

8 A. Yes.

9 Q. And were there other people in Kozluk who had a similar desire?

10 A. Those people who remained in Kozluk were subjected to all-out

11 pressure. Most people wanted to leave Kozluk peacefully.

12 Q. Was it your intention to permanently leave Kozluk or leave until

13 the security situation stabilised and it was safe to return?

14 A. We wanted to leave temporarily because we were totally surrounded,

15 unarmed. We had surrendered our weapons and our life was in danger. Some

16 people had already been killed in Kozluk.

17 Q. You've described the village as coming under attack between the

18 20th and the 21st of June. I'd ask you to describe the situation in

19 Kozluk between the 20th and the 25th of June.

20 A. The situation was disastrous. One could no longer speak of

21 co-existence, tolerance, because long columns of vehicles were passing

22 through the village. There was shooting coming from all sides. The

23 frontline was nearby, so paramilitary formations often came to Kozluk

24 wanting to take away younger persons and to commit other crimes. The

25 situation was unbearable.

Page 20621

1 Q. I'm going to draw your attention to the morning of the 26th of

2 June. On that morning, were there vehicles -- military vehicles

3 positioned in the area of Kozluk?

4 A. When I got up in the morning, I saw a large concentration of

5 people in the centre of Kozluk, and I saw a large number of military

6 vehicles.

7 Q. Can you describe what types of military vehicles you saw.

8 A. In the centre of Kozluk itself, three tanks were deployed. There

9 were several military personnel carriers, trucks, and all of this was in

10 the centre of Kozluk, near the culture centre, and the barrels were aimed

11 at houses where people lived.

12 Q. Do you know two men by the name of Branko Grujic and Jovo

13 Mijatovic?

14 A. Brano Grujic was the mayor of the municipality of Zvornik and he

15 was supposed to be the mayor of all citizens, Brano Grujic was.

16 Jovo Mijatovic was our member of parliament. He was elected by

17 all of us and he was in the higher authorities.

18 JUDGE KWON: Mr. Grujic, is he also called Branko, rather than

19 Brano?

20 THE WITNESS: [Interpretation] We know him as Brano Grujic.


22 Q. Were you summoned to a meeting with these two men on the 26th of

23 June, 1992?

24 A. Yes. A Serb policeman came to pick me up, and he took me to the

25 police station in Kozluk.

Page 20622

1 Q. Can you summarise for us what was said to you at the meeting with

2 these two men.

3 A. When I came to the police station in Kozluk, in the police there

4 were several local policemen, there were a few men in uniform, in military

5 uniform, and I saw the mayor, Brano Grujic, and Mijatovic, the MP.

6 Q. Can I ask you to focus for the moment on what exactly did they say

7 to you during the course of that meeting.

8 A. It was not a meeting. Quite simply, Brano Grujic said to me that

9 "Within 60 minutes I have to gather together all the people and that we

10 have to leave Kozluk urgently." I asked him, "Go where?" And he said

11 that we would be going towards Serbia. I asked him -- I mean, we had no

12 vehicles, we had no fuel, and he said to me that everything was ready and

13 that within one hour's time everything would be in the centre of Kozluk;

14 the buses and trucks.

15 Q. Now, you've said that he said "everyone." Did he literally mean

16 every person living in Kozluk?

17 A. This order applied exclusively to the Bosniaks.

18 Q. And did he mean literally every Bosniak living in Kozluk?

19 A. Yes.

20 Q. Can you --

21 JUDGE MAY: Just -- we are a bit past time. When you get to a

22 convenient moment, Mr. Groome.

23 MR. GROOME: Just one more question, Your Honour, I think would be

24 a good place to break.

25 Q. Can you just briefly describe what was going on in Kozluk at the

Page 20623












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Page 20624

1 time that you were meeting with them. When you returned to where you

2 lived in Kozluk, can you describe what was happening in the village.

3 A. Next to every house there were two or three military personnel

4 standing there. Kozluk has more than 1.000 houses, so there were more

5 than 1.000 soldiers, or rather, military persons, belonging to the police

6 or soldiers in military uniforms, and a large number of people generally

7 wearing different types of uniforms, with masks on their heads, gloves on,

8 and these were in fact paramilitary units. And they pushed the people

9 back like sheep towards the centre of Kozluk. They shot, they set fire to

10 certain houses and facilities, and in the process they wounded several of

11 the local people. I realised that this was no peaceful exit. We were

12 becoming hostages.

13 MR. GROOME: Thank you. I'll continue my examination a week from

14 Monday.

15 JUDGE MAY: Mr. Banjanovic, we have to adjourn now because it is

16 the time when we do adjourn. We are not sitting next week as a court, the

17 reason being that we have allowed the accused more preparation time next

18 week. That's the reason that we are not sitting. I'm sorry that your

19 evidence has been broken up and you will have to come back. But would you

20 be back, please, on Monday week to continue your evidence.

21 During this adjournment and any others there may be, don't speak

22 to anybody about your evidence until it's over and don't let anybody speak

23 to you about it. That includes members of the Prosecution team.

24 Although, you can, of course, speak to them about your travel arrangements

25 and the like.

Page 20625

1 We'll adjourn.

2 --- Whereupon the hearing adjourned

3 at 2.05 p.m., to be reconvened on Monday

4 the 19th day of May, 2003, at 9.00 a.m.