Tribunal Criminal Tribunal for the Former Yugoslavia

Page 981




4 Tuesday, 21th May 1996

5 (10.00 a.m.)

6 THE PRESIDING JUDGE: Mr. Niemann, would you call -----

7 MR. NIEMANN: Your Honour, I just wanted to mention a couple of brief

8 matters.

9 THE PRESIDING JUDGE: I thought we were hearing from Dr. Greve.

10 MR. NIEMANN: Yes.

11 THE PRESIDING JUDGE: Is it "Dr." or "Judge" or "Miss".

12 MR. NIEMANN: Dr. Greve, yes. Mr. Tieger will take over in a short

13 moment. There are a couple of matters I wanted to mention, if I may?

14 Firstly, your Honours, we would just like to notify a change in the

15 order of witnesses. I mentioned it to the Defence, but the witness

16 Medunjanin, Anes Medunjanin -----

17 THE PRESIDING JUDGE: What number is that on your witness list?

18 MR. NIEMANN: Currently No. 11, your Honour. This witness is not

19 available. We have not been able to make contact with the witness at

20 the moment; we expect to be able to do so but we have not been able

21 to at the moment. So we are seeking to replace that witness spot No.

22 11 by the witness Jerko Doko. He is currently No. 16.

23 THE PRESIDING JUDGE: I see, he is No. 16 now.

24 MR NIEMANN: The witness Mirsad Mujadzic, currently No. 14, we seek to put

25 him following the witness Semenovic.

Page 982


2 MR. NIEMANN: Semenovic, your Honour, and that witness is No. 10.

3 THE PRESIDING JUDGE: So 14 will go before 10?

4 MR. NIEMANN: After 10.

5 THE PRESIDING JUDGE: After 10, OK. So, we have just saved three to five

6 hours! I am sorry, I am just joking.

7 MR. NIEMANN: Probably.

8 THE PRESIDING JUDGE: In the scheme of things, it is not tremendously

9 important. OK. Is there anything else?

10 MR. NIEMANN: Yes, your Honour, there is. Your Honours, we received a

11 notice that next week this Chamber is, apparently, going to be used

12 for a matter on Tuesday morning, and there is another matter on

13 Wednesday morning and so we will not be sitting until Wednesday

14 afternoon. We have also heard there is to be, not a deferral

15 hearing, a Rule 61 hearing, set for sometime in June/July which,

16 apparently, may take as long as 10 days

17 We are becoming somewhat concerned, your Honours, that with

18 respect to next week, we have witnesses here who are arriving today

19 we cannot stop who were planning to give evidence early next week who

20 will probably be pushed right back to the end of next week or maybe

21 into the next week because of these changes.

22 I am just wondering, your Honours, is there any possibility that

23 we could sit somewhere else or that other matters could be placed

24 somewhere else in the building? I just raise it because it will

25 seriously lengthen the trial if these interruptions are to come as

Page 983

1 regularly as they have been up until now.

2 THE PRESIDING JUDGE: We have - at the close of testimony today, I will

3 talk to you about our schedule next week, but since you have raised

4 it, yes, you are right, there is a deferral hearing set for Tuesday

5 28th in the morning.

6 With respect to using another location, believe me, Mr. Niemann,

7 I have lost sleep over the schedule, not the length of time that the

8 Prosecutor is taking, but the number of intrusions that I know that

9 we will have on this trial. There is a possibility of using the

10 room that we used for pretrial, but there are logistical problems,

11 equipment problems, money problems; believe me, I am very sympathetic

12 to the desire of everyone to proceed as quickly as possible and we

13 are doing the best that we can, but we just have other matters, this

14 Chamber has other matters, it has to hear. As far as the other Trial

15 Chamber, I will not speak for the other Trial Chamber, but perhaps

16 they do have matters that are coming up as well.

17 We have one courtroom and it took us a while to get this

18 courtroom, but at least we have it and that is all that we have at

19 the moment. We will do the best that we can. You are perfectly

20 correct in raising that concern because I have asked you to present

21 your case more efficiently and more expeditiously, and then there are

22 all these intrusions into the schedule that have nothing to do with

23 the Prosecution. You are right and correct. We will do the best

24 that we can. I will inform you at the close of the testimony today

25 regarding our schedule for next week.

Page 984

1 MR. NIEMANN: Thank you.

2 THE PRESIDING JUDGE: Mr. Tieger, will you call Dr. Greve?

3 DR. GREVE recalled

4 Examined by MR. TIEGER, continued

5 THE PRESIDING JUDGE: Dr. Greve, you may be seated, please. You are still

6 under oath; you understand that?



9 MR. TIEGER: Dr. Greve, before the adjournment yesterday, we were speaking

10 about the dissemination of propaganda related to Serbian nationalism

11 and Serbian imperilment. In that connection, I wonder if I might ask

12 Exhibit 85 to be brought to the witness's attention very quickly?

13 (Handed). Can we have that document focused on the top of the page,

14 please? Dr. Greve, do you see the date indicated on the article

15 entitled the "The Glory of all Serbian Glories"?

16 A. Yes, I do and I forget yesterday to mention that this has been

17 wrongly translated as 1st June; it should actually be 1st July. I

18 recognise this because it is the celebration of St. Vitus Day. That

19 is, I do not read Serbo Croatian myself, so I am unable to read the

20 original text, but St. Vitus Day is celebrated on 28th June, so it

21 has to be 1st July. It was checked with the translators, it is 1st

22 July, so that is a mistake, unfortunately, in the document presented.

23 I also have to apologise. I made a bad guess yesterday when I

24 equated Prince Lazar with St. Vitus. The correct version (and I

25 checked this this morning) is that Prince Lazar, the prince, the

Page 985

1 Serbian prince who is so well respected and celebrated in Serbian

2 history, died on 15th June, that is, on the day of St. Vitus. That

3 is why they celebrate him and St. Vitus at the same day. The reason

4 also why I wanted, of course, to correct my own bad guess of

5 yesterday -- I did say it was a guess and I am happy I did say that

6 at least -- is also because it brings attention to a fact that

7 confused me during my study of Prijedor area, and that is the

8 distinction between the Julian and the Gregorian calendar.

9 As you will know, we all use (or most of the world today uses)

10 the Gregorian calendar. It was initially the Julian calendar which

11 was adopted by Emperor Julius Caesar before Christ, adopted by the

12 Christian world 325 AD and revised by Pope Grego, I think it was

13 XIII, in 1582, because there was not full correspondence between the

14 solar year and the year of the calendar. So although we have leap

15 years to compensate, we had three leap years too much in 400 years.

16 So in 1582, 10 days were crossed out of the calendar; some call

17 it the Gregorian calendar; some call it the revised Julian calendar.

18 But the significance of this is that th

19 orthodox church with reference to celebration of religious feast

20 use reference to the old and not revised Julian calendar.

21 That is, sometimes I came across witnesses who gave me a date,

22 for instance, of Petrovdan which varied with a fortnight from what

23 others said and I was, it made me insecure, and I wondered if they

24 were that mistaken when they were referring to these holidays. But

25 the truth is that in the year 1992, which is our focus, there is a

Page 986

1 fortnight between the Julian calendar and our Gregorian calendar.

2 That is, 1st January 1992 in the Julian calendar comes on 14th

3 January 1992 in the Gregorian calendar. So there is a difference

4 and, if I may say so, if it comes to reference to feasts, it may be

5 useful to ask according to which calendar if a date is used.

6 Q. Dr. Greve, I would like to move now to 1990: Following the breakdown

7 of the communist system in Yugoslavia, were democratic elections held

8 in 1990?

9 A. Yes, they were.

10 Q. In opstina of Prijedor, which were the main political parties

11 involved in that election?

12 A. It was the SDA, the party of Democrat Action; it was the SDS, the

13 Serbian Democratic Party; it was the HDZ which was the Croatian

14 Democratic Union, and there were some leftist parties, the

15 Reformists, the Liberals, etc., and Ante Markovic actually had his

16 founding ceremony for the Reformist party held in Prijedor.

17 Q. Who were among the leaders in Prijedor in the SDA?

18 A. There were several leaders in the SDA. Actually, their names have

19 been referred to when it comes to sources mainly by witnesses, but

20 some of them are also reported in the later newspaper articles; among

21 them Muhamed Cehajic who became the Lord Mayor; Mirsad Mujadzic who

22 was from the Ljubija area; Hilmija Hopovac who was from that same

23 area. I do also know a number of names from the Kozarac area, but

24 only from witness statements, and I have not had these names

25 confirmed from other sources.

Page 987

1 Q. Who were among the leaders of the SDS?

2 A. Among the leaders of the SDS were Srdo Srdic; it was Simo Miskovic;

3 it was Milan Stakic; it was Miko Kovacevic; it was Simo Drljaca and

4 Slobodan Kuruzovic.

5 Q. Those are names we will be hearing about further in the testimony?

6 A. Yes, these are all names that is being mentioned in all the public

7 reports as well, so their names, I have heard them both from

8 witnesses and from the local media; many of them have given

9 interviews, that is.

10 Q. What was the outcome of the elections in Prijedor in 1990?

11 A. The outcome of the election, let me immediately mention, there is a

12 local Assembly in Prijedor which has 90 seats. According to the

13 votes, the seats were distributed with 28 seats for the SDS, the

14 Serbian party, with 30 seats for the SDA, the Muslim party, and two

15 seats for the HDZ, the Croat party, and 30 seats for other parties.

16 That is a considerable amount of seats were distributed to

17 parties that did not link so much to any particular group and, of

18 course, this was the first ever free election in a multi-party

19 system. So it was a very young democracy that went to throw their

20 ballot.

21 Q. Did this plurality victory by the SDA mean they were in a position to

22 fill all appointed political positions with its members?

23 A. For (1) democracy means to distribute this according to the vote. So

24 it was, of course, reflected the composition of the Assembly as other

25 political positions were reflecting the position between the parties;

Page 988

1 but also it is my understanding that Tito's Yugoslavia was built on

2 very elaborate keys for the division of positions according to ethnic

3 groups, so that all of them would be represented.

4 Q. So after the election, the appointed positions to be filled were to

5 be distributed among the parties?

6 A. That is correct.

7 Q. Were all the positions immediately filled?

8 A. No, not all of them, that is to say, there were no positions that

9 were left vacant, but they were not immediate changes in all of them,

10 according to the outcome of the election.

11 Q. Were some of the positions filled within a reasonable amount of time

12 after the election?

13 A. Yes, they were. That is, essentially, the political position.

14 Q. As time went on, were the remaining positions agreed upon? Was there

15 a consensus reached on which party member should occupy which

16 appointed position?

17 A. Not without some bickering, but eventually they were, yes,

18 distributed.

19 Q. Did the bickering that took place in the Assembly decrease, remain

20 the same or increase over time?

21 A. It may have been quite difficult immediately and it has to be kept in

22 mind that it is an enormous step for any one society to move from a

23 totalitarian communist regime to become a democracy. One cannot just

24 click fingers and it is done with that; it is a process

25 it has to do with learning. I think it was difficult from the very

Page 989

1 start, but as ethnic hatred or propaganda started it became even more

2 difficult.

3 Q. As time went on, did the Serbs in Prijedor begin to establish their

4 own separate political structure outside of the existing democratic

5 institutions?

6 A. Yes, they did, and that was also in the light of what happened

7 outside the opstina as such.

8 Q. Was a separate Assembly or any other institution established by the

9 Serbs in Prijedor?

10 A. Yes, actually there was a separate Assembly set up. Initially, people

11 did not know much about it. Later, we have received documents that

12 verify this. But what witnesses told us, or told me, reported, was

13 that there were some kind of meetings, they considered it to be

14 peculiar meetings, among the Serb politicians. They were not so sure

15 if this was just meetings so that they would prepare themselves

16 before they came into the Assembly or if it was some kind of a

17 separate structure, but they were wondering. Essentially, they were

18 sort of not too keen on knowing what this exactly was.

19 Q. Was the establishment of this separate Serbian Assembly an

20 independent act by local Serbian political authorities or was it done

21 at someone else's direction?

22 A. Well, this was happening in co-operation between the local Serbs and

23 the central SDS, Serbian party, administration and the separate

24 Serbian structures that at this time were being developed.

25 MR. TIEGER: Your Honour, may I have these documents marked, please, for

Page 990

1 identification as Exhibit 91? (Handed)

2 (To the witness): Dr. Greve, what is this document?

3 A. This is again an article from Kozarski Vjesnik, this time dated 28th

4 April 1994. The caption is how Dr. Milomir Stakic, first Chairman of

5 the Serbian Municipal Assembly of Prijedor, saw the events of 30th

6 April and after.

7 MR. TIEGER: Your Honour, I tender that document for admission.

8 THE PRESIDING JUDGE: Any objection to Prosecution 91?

9 MR. ORIE: No objection, your Honour.

10 THE PRESIDING JUDGE: Exhibit 91 will be admitted.

11 MR. TIEGER (To the witness): Dr. Greve, let me direct your attention to

12 that portion of the article you just indicated at the top of page 1.

13 At the top of the page, does it indicate that Dr. Milomir Stakic was

14 the first Chairman of the Serbian Municipal Assembly of Prijedor,

15 the institution to which you were just referring?

16 A. Yes, and I hasten to add he was the Vice, he was the Deputy Mayor in

17 the official structure.

18 Q. Now directing your attention to paragraph (3), you see the sentence

19 in the approximate middle of the paragraph that begins, "On the

20 direction"?

21 A. Yes.

22 Q. Does that article indicate at whose direction the separate Serbian

23 Assembly of Prijedor was established?

24 A. Yes, it indicates that this was established at the direction of the

25 SDS, Srpska Demokrastka Stranka, which is the Serbian Democratic

Page 991

1 Party.

2 Q. Was that the local SDS?

3 A. No, no, this is the SDS.

4 Q. The central office of the SDS?

5 A. That is the way I would look at it, yes.

6 THE PRESIDING JUDGE: Where is the central office then of the SDS?

7 A. In Bosnia-Herzegovina -- at the time that would be in Sarajevo.

8 THE PRESIDING JUDGE: I am sorry, Mr. Tieger.

9 MR. TIEGER: No, your Honour, that is fine. (To the witness): In addition

10 to the establishment of a separate Municipal Assembly outside the

11 democratic government, was any other separate institution created by

12 Serb officials in Prijedor?

13 A. Yes, particularly, in particular, there was the setup of a separate

14 police, and the main source of the information about the separate

15 police is again the interview that was given about a year after by

16 head of the Serbian police, Simo Drljaca. When he was promoted to

17 become the vice Minister of Interior, he was explaining how he had

18 been working. He used the word or it is translated as "illegally",

19 how he was setting up an illegal entity of Serbian police working on

20 this for months or half a year approximately prior to 30th April

21 1992. That was a complete structure for the police.

22 MR. TIEGER: In that connection, may I have these documents marked for

23 identification as Exhibit 92? (To the witness): Dr. Greve, what is

24 this document?

25 A. It is the article from Kozarski Vjesnik dated 9th April 1994 (sic)

Page 992

1 which is an interview with Simo Drljaca, then Deputy Minister of

2 Interior, of the Serb Republic.

3 Q. Looking at, you said April 9th, 1994?

4 A. I am sorry, it is 1993.

5 Q. That contains an interview with Simo Drljaca?

6 A. It does.

7 MR. TIEGER: I tender that for admission.

8 THE PRESIDING JUDGE: Any objection?

9 MR. ORIE: No objection.

10 THE PRESIDING JUDGE: Exhibit 92 will be admitted.

11 MR. TIEGER (To the witness): Dr. Greve, can I direct your attention then

12 to the top of the first page of that article? On April 9th, 1993,

13 what was Simo Drljaca's position within the declared Serb Republic?

14 A. He was designated Deputy Minister of Interior.

15 Q. In 1992 what was his position?

16 A. In 1992, from 30th April onwards, he was head of police.

17 Q. Directing your attention to the second line of this article -- let me

18 direct your attention first to the first line. Does the interview

19 with Simo Drljaca indicate who selected him to set up these illegal

20 police stations?

21 A. Yes, it is indicated that it was done by the Serb Democratic Party,

22 the SDS.

23 Q. Does the article indicate when that work began?

24 A. Yes, it does.

25 Q. How long before the takeover?

Page 993

1 A. Six months before the takeover.

2 Q. As a result of Simo Drljaca's efforts to establish an illegal police

3 force, how many stations were created manned by how many officers?

4 A. A force of 1,775 well-armed men in 13 police stations, is his

5 figures.

6 Q. Was the establishment of this illegal Police Force by Serb officials

7 done in co-operation with any other group in Prijedor other than the

8 SDS?

9 A. Yes, with the army, and that was at the time the JNA, the army of the

10 Yugoslavian people.

11 MR. TIEGER: May I have this document marked as exhibit 93 for

12 identification, please? (Handed). (To the witness): Dr. Greve, what

13 is that document?

14 A. It is another newspaper article from Kozarski Vjesnik dated 19th

15 November 1993. It is headlined "21 November, the day of Security

16 Services of Republica Srpska".

17 MR. TIEGER: I tender that document for admission.

18 THE PRESIDING JUDGE: Any objection?

19 MR. ORIE: No objection, your Honour.

20 THE PRESIDING JUDGE: 93 will be admitted.

21 MR. TIEGER (To the witness): Dr. Greve, may I direct your attention then

22 to the third paragraph of that article? Does the article also

23 confirm the establishment of illegal Serbian police stations?

24 A. Yes, it does. It refers to 30 illegal Serbian police stations.

25 Q. Does the article also indicate who participated in the establishment

Page 994

1 of the illegal police stations and the takeover of power?

2 A. Yes, it states explicitly that all the preparations had been carried

3 out in an exemplary co-operation with the Serbian army, and this was

4 still the JNA.

5 Q. Look at the top of the page, the event which prompted this article

6 was what?

7 A. It is a celebration, actually it celebrates, and again it links the

8 celebration of the police to the celebration of the day of the Arch

9 Angel Mihajlo.

10 Q. Were the police, the Serbian police, in Prijedor closely linked to

11 Serbian officials outside the opstina?

12 A. Yes, they were, and again our best source is head of police, Simo

13 Drljaca, head of police at 30th April 1992, because he is confirming

14 that he worked closely with the central authorities in Banja Luka,

15 and that they again took the orders straight from what is called

16 Ministry of Interior.

17 MR. TIEGER: May I have the previous exhibit, Exhibit 92, presented to the

18 witness?

19 THE PRESIDING JUDGE: That will be the Minister of Interior of the

20 Republika Srpska?

21 A. Yes, but I hasten, or I should immediately add that one may be

22 slightly confused with the wording "Republic" in this context. We

23 will, I think, explain it in detail a little later, but the Republika

24 Srpska was never declared as an independent state; it was always said

25 that it was one, it was one federal unit within the great Serbian

Page 995

1 state with Serbia proper and with these four areas that had been

2 taken under Serb control in Croatia. So it is not to be confused

3 with an independent state.

4 Q. You say that it was said that it was a unit of Serbia, it was said by

5 persons in the Republic of Srpska that it was a unit of Serbia?

6 A. It was proclaimed, when they proclaimed Republika Srpska, or actually

7 they started with proclaiming, and we will have the documentation

8 coming, they started with proclaiming Republic of the Serbian people

9 in Bosnia and Herzegovina, and they were pointing out at

10 that point that they did not want to become a state, but they

11 declared to be in statehood with.

12 Q. I have a feeling that I am getting ahead of this story, and so I

13 will retreat. The question that I had though really related to not

14 what was the intention of the Republic of Srpske vis-a-vis the

15 relationship with Serbia, but the reaction of Serbia to that

16 proclamation, not an official proclamation but at least the position

17 taken by the Republik of Srpska, but we will get to that later.

18 A. Well, I may, if it can of any assistance -----

19 THE PRESIDING JUDGE: I do not know whether Mr. Tieger would enjoy that,

20 interrupting his direct.

21 MR. TIEGER: I have no objection whatsoever in disrupting .....

22 THE PRESIDING JUDGE: We will hear it in tandem. We will hear it at the

23 appropriate time.

24 THE WITNESS: But I may give you, your Honour, one indication, and that is

25 when this separate structure is being set up, it is with full

Page 996

1 co-operation of the JNA, that is, the army of the country with which

2 they want to belong in statehood. Of course, there is still a

3 linkage between the Serb Republic and the Republic of

4 Bosnia-Herzegovina, but even after the breach when Bosnia-Herzegovina

5 becomes independent or declares independence in early April 1992 and

6 up to the Serbs are taking power in Prijedor, there are at least 24

7 days, and in this period the JNA exists and it fully cooperates.

8 JUDGE STEPHEN: At this time was the Belgrade government calling itself

9 Serbia, Serbian, or did it still call itself Yugoslavia?

10 A. The Socialist Federal Republic of Yugoslavia.

11 Q. So the references we just seen to Serbian co-operation or the Serbian

12 army really is a misnomer, is it?

13 A. Well, this, of course, is a newspaper article when they are

14 communicating with the local people, and then it is perhaps

15 considered convenient to use the then new names. That is perhaps

16 the way I have tended to read it.


18 THE PRESIDING JUDGE: Mr. Tieger, do you know where you are?

19 MR. TIEGER: Yes, thank you, your Honour. (To the witness): Just to

20 clarify the chronology a bit, Simo Drljaca was the man designated by

21 the SDS in Prijedor to establish the illegal police stations in 1991?

22 A. That is correct.

23 Q. Then after the military takeover of Prijedor he became the Chief of

24 Police?

25 A. That is correct.

Page 997

1 Q. It was thereafter that he was appointed, promoted to the position of

2 Deputy Minister of the Interior?

3 A. That is also correct.

4 Q. What is the relationship between the Ministry of the Interior and the

5 police department?

6 A. If I may say a few general words about this? It has to be kept in

7 mind that what we are seeing is an old totalitarian regime that is

8 changing to become more democratic. In the old communist setting,

9 one of the key ministries were the Ministry of Interior and the

10 Ministry of Interior would be the one in charge of both the secret

11 police, state police and public security police issues. The Ministry

12 of Justice would, in comparison, be a tiny and not so important

13 entity.

14 Q. I had asked you about the connection between the police in Prijedor

15 and Serbian entities outside the opstina. Can I ask you to look at

16 the bottom of page 2 of Exhibit 92? Looking at that document, the

17 interview with Simo Drljaca, then the Deputy Minister of the

18 Interior, does he indicate the relationship between the police in

19 Prijedor and entities outside ---

20 A. Yes.

21 Q. -- that is the Serbian police, excuse me?

22 A. Yes. He is actually at this time he is answering to some criticism,

23 and he is saying that if something, quoting the last sentence in the

24 paragraph, "If something was not done correctly, then I should be

25 replaced and not they because they executed my orders and those from

Page 998

1 the chief of the central police headquarters in Banja Luka and the

2 Minister of the Interior".

3 Q. You mentioned that the separate Serbian Assembly of Prijedor was

4 established at the direction of the central office of the SDS. I

5 would like to discuss the links between that separate Assembly in

6 Prijedor and the separate Serbian structures outside of Prijedor. In

7 that connection, may I have this marked as Exhibit 94 for

8 identification? (Handed) What is that document, Dr. Greve?

9 A. This is a decision dated 17th January 1992. It states that it is a

10 decision to unite with the autonomous region of Bosanska Krajina and

11 article (1) states that -----

12 Q. Doctor, before you proceed with the document, I would like to tender

13 that for admission.

14 THE PRESIDING JUDGE: Any objection to Exhibit 94?

15 MR. ORIE: No objection.

16 THE PRESIDING JUDGE: 94 will be admitted.

17 MR. TIEGER: Can the document be placed on the screen, please? (To the

18 witness): Dr. Greve, you indicated that this was a decision reached

19 on January 17th 1992?

20 A. That is correct.

21 Q. Again that decision was -----

22 A. It is a decision to unite with the autonomous region of Bosanska

23 Krajina.

24 Q. It is a decision by which institution to unite with the autonomous

25 region?

Page 999

1 A. The Serbian People's Assembly in Prijedor municipality.

2 Q. It was signed by the individual you referred to earlier, Dr. Milomir

3 Stakic?

4 A. That is correct.

5 Q. As Chairman of the Serbian People's Assembly?

6 A. That is correct.

7 Q. At the time he was also the Vice President of the democratically

8 elected Assembly in Prijedor?

9 A. That is also correct.

10 Q. Dr. Greve, what was the autonomous region of Bosanska Krajina that is

11 referred to in this document?

12 A. At this time it was a region similar to the regions previously

13 proclaimed in Croatia as SAOs, Serbian autonomous -- Srpska Autonomna

14 Oblast, that is, Serbian autonomous districts. Krajina, I should

15 say, is an area to be divided by the border between Croatia and

16 Bosnia-Herzegovina, so you have one region of Krajina in Croatia and

17 another region of Krajina in Bosnia-Herzegovina. For what reason

18 they already existed a sole, an autonomous region of Krajina. That

19 is why one is using now a different name for the autonomous region on

20 the Bosnian side of Krajina; it is called a region and not an

21 "oblast".

22 Q. Was the autonomous region part of the democratically elected

23 government within Bosnia-Herzegovina?

24 A. No, it was not. It was set up and step by step moved further away to

25 be completely autonomous from the government in Bosnia and

Page 1000

1 Herzegovina.

2 Q. What was the first step in the creation of this separate autonomous

3 region?

4 A. I may, perhaps, say that before any steps were taken, there were no

5 such thing as total regional structures. There were two main

6 Chambers of Commerce in north western Bosnia-Herzegovina, and there

7 were some financial co-operation and there were some association of

8 municipalities to do co-ordinated planning and trade, which was

9 obviously very good and very welcome. But then at one point, that

10 is, late April 1991, late April 1991, there was a change in this

11 structure, and the autonomous region of Krajina, Bosnian Krajina,

12 becomes an entity which also takes upon it to have some military

13 independence. That is firmly objected to by the government in the

14 Republic of Bosnia-Herzegovina. It is not yet -- the Republic is not

15 yet independent, but still the legal authorities all seated in

16 Sarajevo and they object to this creation.

17 Only in September 1991, there is a formal declaration of

18 independence for the ARK, Autonomous Region Krajina, which is the

19 entity located within Bosnia-Herzegovina in contra-distinction to the

20 South Krajina on the other side of the border, that is, inside

21 Croatia. So it is two entities with the name "Krajina" because the

22 area is not so naturally divided in a sense, the name is found in

23 both areas.

24 Q. In April 1991 when an association of municipalities in the Krajina

25 region took on some military aspects rather than purely economic

Page 1001

1 co-operative aspects, did it call itself the autonomous region at

2 that time or did it continue to call itself an association of

3 municipalities?

4 A. It was moving towards autonomy already at that time.

5 Q. Was it known as the autonomous region of Krajina or was it known as

6 the association of municipalities in April when it took on these

7 military aspects?

8 A. I am perhaps not exactly sure of that, because I think at this time I

9 think it called itself autonomous region of Bosanska Krajina, but it

10 left out the name "Bosanska" later -- but I may be mistaken on this.

11 MR. TIEGER: Let me have, if I may, this document marked as Exhibit 95 for

12 identification.

13 JUDGE STEPHEN: Can I ask you, I hope this is idle curiosity but we have

14 come across "Bosanska" in a number of place names, has it got a

15 meaning?

16 A. Yes, it means "Bosnian".


18 JUDGE STEPHEN: Thank you.

19 A. And that is the reason, and that adds to some confusion, or it did on

20 my part: At a later stage one of the things that the separate

21 Serbian structure is eager to do is to cross out the reference to

22 anything that is Bosnian. So when it is called Bosanska Krajina, it

23 becomes "Krajina"; if a city is named Bosanska Novi, Bosanski

24 Gradica, it changes the name, leaves out "Bosnian".

25 MR. TIEGER (To the witness): Dr. Greve, can I ask you to look at Exhibit

Page 1002

1 95 marked for identification? What is that exhibit?

2 A. That is again a translation of a newspaper article which appeared in

3 the newspaper, Oslobodenje, which is printed in Sarajevo. It is

4 dated 24th May 1991.

5 MR. TIEGER: I tender that for admission.

6 THE PRESIDING JUDGE: Any objection?

7 MR. ORIE: No objections, your Honour.

8 THE PRESIDING JUDGE: 95 will be admitted.

9 MR. TIEGER: If that could be placed on the screen, please?

10 (To the witness): Does this document indicate the reaction to the

11 establishment of a separate association in the Krajina region at that

12 time?

13 A. Yes, it is noting that the SDA, the party of Democratic Action, that

14 is, the one associated with the Muslims in Banja Luka, are strongly

15 opposed to the idea of creating what they call a state within a

16 state.

17 THE PRESIDING JUDGE: Dr. Greve, I have a question, I guess, a confusion,

18 about how this operated from a practical point of view. You had a

19 General Assembly in Prijedor. The SDA received not the majority but

20 received the largest number of votes of 30 seats, I guess, out of 90.

21 Then you say there were 30 others. I do not know how these others

22 aligned with the SDA. But when the SDS was developing these

23 relationships with other areas in Bosnia-Herzegovina, for example,

24 the relationship with Krajina, what was the reaction of the leaders

25 in the General Assembly? Did the SDS continue to participate in the

Page 1003

1 Assembly in Prijedor and at the same time try to create an autonomous

2 state of Bosnian Serbs in Prijedor and align with other areas of

3 Bosnia-Herzegovina that were predominantly Serb? What was the

4 reaction within the General Assembly? It would seem to me that the

5 SDA and other parties would respond within the Assembly.

6 A. Your Honour, unfortunately, most of those key people from other

7 parties than the SDS

8 -- from other parties than the Serbian parties and outside the Serbian

9 group are dead, meaning that we have not been able to question them

10 about this particular issue, but the information we had which is

11 second-hand, I admit, is that people did not fully understand this.

12 It was in a sense so much happening in Eastern Europe in general,

13 confusion; transition; communism breaking down; it was combined with

14 financial crisis; democracy was being established; republics were

15 considering to leave the Federation; people were confused. They were

16 not used to be tuned into political thinking like people in a

17 democracy, that is, it always used to be decided by the party what

18 was to be the line of the country.

19 So many people, it seems to me from secondary sources, I admit,

20 did not really feel that they knew enough about the situation to be

21 really alerted in time. They were taken by surprise. They saw that

22 certain things were happening, but to a degree their reaction was

23 more that this was peculiar than that this was dangerous. But when

24 it came to the independent or autonomous regions, as we will come to

25 Prijedor through its Assembly, the elected Assembly refused to join

Page 1004

1 this entity. But all parties remained within the elected Assembly,

2 but it became more and more difficult to operate in that Assembly as

3 previously indicated.

4 If I also may answer your first question, which was, what about

5 the 30 votes which were distributed between different other parties?

6 As indicated, Reformists and the Liberal Party which were some, what

7 shall I say, reawakened communist parties -- maybe that is not the

8 right way to describe them -- it is leftist parties, and people would

9 join them from different groups, and the mere fact that one-third of

10 the population did not vote along the lines of these three main

11 parties, that is, being associated with specific ethnic groups,

12 indicates that, perhaps, people did not think that ethnic groups had

13 anything really to do in politics at this time.

14 Many Serbs, and they will blame this afterwards both in

15 newspaper articles and according to also Serb people with whom we

16 have been speaking, had voted for other parties than the SDS, the

17 Serbian Democrat Party. But eventually it became no more acceptable

18 for a Serb not to be of true Serbian nationalist thinking, that was

19 also to join the party.

20 There are actually decisions made in the independent region of

21 Krajina to the effect that to be a real Serb and have any

22 leading position or be entrusted, one should be a party member and

23 know that guidance of the Serb people was firmly taken care of by the

24 SDS.

25 MR. TIEGER: Referring to this association or entity that was established

Page 1005

1 in April of '91, was that constitutionally challenged?

2 A. Yes, it was.

3 Q. May I have this document marked as Exhibit 96 for identification,

4 please? (Document handed). (To the witness): What is that document,

5 Dr. Greve?

6 A. It is a ruling which is published in the official gazette of the

7 Socialist Republic of Bosnia-Herzegovina which is still within the

8 former Yugoslavia.

9 MR. TIEGER: I tender that for admission.

10 THE PRESIDING JUDGE: Is there any objection?

11 MR. ORIE: No objection, your Honour.

12 MR. TIEGER: May that be placed on the screen, please?

13 THE PRESIDING JUDGE: Exhibit 96 will be admitted.

14 MR. TIEGER (To the witness): Dr. Greve, looking at the top of the page,

15 that is a decision by which institution?

16 A. The constitutional court of Bosnia-Herzegovina.

17 Q. On what date?

18 A. At the session held on 1st November 1991.

19 Q. The ruling concerns which institution as indicated in that first

20 paragraph?

21 A. It concerns the Association of Bosanska Krajina municipalities.

22 Q. And focuses on the agreement to join the association of Bosanska

23 Krajina municipalities?

24 A. Yes, it does.

25 Q. The ruling by the constitutional court is what?

Page 1006

1 A. It is that this decision will be null and void.

2 Q. That ruling was on November 1st 1991?

3 A. That is correct.

4 Q. By that time, had the Association of Bosanska Krajina municipalities

5 become the autonomous region of Krajina?

6 A. Yes, it had in September.

7 Q. Dr. Greve, I would like to ask you which municipalities in the area

8 joined the autonomous region, and it might be helpful if I had

9 Exhibit 73 displayed to you.

10 THE PRESIDING JUDGE: Is this the entire decision while we are locating

11 73?

12 MR. TIEGER: Yes, your Honour, not what is depicted on the screen, of

13 course.

14 THE PRESIDING JUDGE: I was just wondering whether there is any reasoning

15 or rationale. All I see is a declaration it is null and void.

16 MR. TIEGER: It is contained in the documents which has been tendered.

17 THE PRESIDING JUDGE: You are offering the entire decision?

18 MR. TIEGER: Yes.

19 THE WITNESS: That is the so-called justification that is added on the

20 following pages.

21 MR. TIEGER (To the witness): Dr. Greve, does this map assist you in

22 indicating the municipalities which joined the autonomous regions?

23 A. Yes, I am just waiting to get on the screen the exact -- yes. What

24 we can see is, if we start to the west of Prijedor, we see Bosanski

25 Novi which joined; to the north of Prijedor we see Bosanski Djubica

Page 1007

1 which joined; we see Bosanski Gradiska which joined; and I am afraid

2 I cannot read on my screen -- oh, I can -- it is Srbac which joined;

3 it is Prnjavor which joined; it is Laktasi which joined; Banja Luka

4 joining; Celinac joining, and I skip Kotor Varos which did not join,

5 Skender Vakuf joining; Mrkonjic Grad joining; Sipovo, and then I move

6 further south, I mention Kljuc which joined; Sipovo joined; Kupres

7 joined; Glamoc joined; Bosanski Grahovo, Titov Drvar joined and

8 Bosanski Petrovac joined. In what is called Bosanski Kupres the

9 river Una comes done along this border and flows through Bosanski

10 Kupres.

11 So there was a part of Bosanski Kupres which was referred to as

12 Kupres, now "Una", the part which is to the east of the River Una,

13 which was Serb controlled, and that part also associated itself. But

14 important to point out in this context is, perhaps, that Prijedor

15 became isolated with three other or two other provinces in the area.

16 Sanski Most did not join. Prijedor did not join, that is, the

17 legally elected Assembly of Prijedor did not join, and Kotor Varos

18 did not join.

19 Q. What eventually happened to Prijedor, Sanski Most and Kotor Varos?

20 A. They were all ethnically cleansed, so-called, by violent means and

21 force and they then joined.

22 Q. Did Serbian authorities also form a separate political entity on the

23 republic level as well as the Municipal and regional level?

24 A. Yes, they did.

25 Q. What was that entity called?

Page 1008

1 A. First of all, it was the politicians that were participants in the

2 legal parliament in Sarajevo, in the Republic of Bosnia-Herzegovina.

3 They together with other representatives of the Serb people on 9th

4 January 1992, 9th January 1992, declared a republic, but again a

5 republic as being a federal unit wanting to be in statehood with what

6 I, for reasons of convenience, call Serbia proper and the autonomous

7 Serb areas in Croatia, and they formed what was called at the time

8 the Republic of the Serbian People in Bosnia and Herzegovina -- a

9 name which was changed on 28th February to be the Serbian Republic of

10 Bosnia-Herzegovina, a name which was changed again on 12th August

11 1992 to be Republika Srpska. There was no other main changes than

12 this change in name, so the entity is the same whatever the name it

13 is referred to. It only has a difference in time.

14 Q. Did the separate Serbian Assembly in November or in October call for

15 the holding of a plebiscite?

16 A. Yes, it did, 21st October it decided to ask for that.

17 Q. May I have this document marked as Exhibit 97 for identification?

18 (Document handed). (To the witness): Dr. Greve, what is Exhibit 97

19 for identification?

20 A. This is a ballot paper which was used in the plebiscite held in

21 October, sorry, in November 1991, and in which the Serbian people in,

22 particular were, asked in what kind of statehood relationship they

23 would want to stay.

24 MR. TIEGER: We tender 97 for admission.

25 THE PRESIDING JUDGE: Any objection?

Page 1009

1 MR. ORIE: No objection, your Honour.

2 THE PRESIDING JUDGE: 97 will be admitted.

3 MR. TIEGER: May that be put on the screen, please?

4 (To the witness): Dr. Greve, what is the general issue presented by this

5 plebiscite?

6 A. I should perhaps indicate immediately that this ballot paper is

7 actually -- in one paper we have two different ballot papers, and

8 what is being shown at the screen at the moment is the ballot paper

9 which is given to the people of Serb ethnic background, those who

10 declare themselves as Serbs. They are asked to vote and indicate

11 whether they are in

12 favour of a decision reached by the Assembly of the Serbian people in

13 Bosnia and Herzegovina on 21st October 1991, whereby the Serbian

14 people shall remain in the common state of Yugoslavia which would

15 include Serbia, Montenegro, SAO Krajina, SAO Slavonia, Baranja,

16 Western Srem along with all others willing to remain in such a state.

17 Q. How was the ballot framed for non-Serbs?

18 A. That is shown and indicated on this same paper. It was formulated

19 differently for the non-Serbs. They are asked if they are in favour

20 of Bosnia and Herzegovina remaining a republic with equal status in a

21 common state of Yugoslavia with all the other republics which also

22 declared themselves willing to do so.

23 Q. Aside from the reference to the Assembly of the Serbian People in

24 Bosnia and Herzegovina in the ballot presented to Serbs, is there

25 any mention of Bosnia and Herzegovina in the common state of

Page 1010

1 Yugoslavia?

2 A. Excuse me, may I ask you to repeat the question?

3 Q. Sure. In the ballot presented to non-Serbs where it indicates

4 whether or not the Serbian people shall remain in a common state of

5 Yugoslavia, and list the members of that common state, is

6 Bosnia-Herzegovina indicated anywhere? I am sorry, I misspoke.

7 This is the ballot presented to Serbs, excuse me. Does the -----

8 A. No, excuse me, I was a bit slow. I am sorry. No, in the ballot

9 paper presented to the Serbs there is no indication of the existence

10 of Bosnia-Herzegovina as such. Here we are only -- they are only

11 referring to these autonomous regions.

12 Q. Did most Serbs vote in the plebiscite?

13 A. Yes.

14 Q. What about non-Serbs?

15 A. There were a few non-Serbs voting, but I have not seen any figures

16 for how many participated. It is my understanding it was relatively

17 few.

18 Q. Was the plebiscite regarded as an important event by Serbian

19 officials?

20 A. Yes, later it is actually -- whether or not one had participated in

21 this plebiscite is considered significant as to have demonstrated

22 one's true understanding of what it means to be a Serb.

23 Q. Was its importance in part affirmed by the subsequent declaration of

24 a wholly separate Serbian entity?

25 A. Yes, it was.

Page 1011

1 MR. TIEGER: Can I ask that Exhibit 50 be shown to the witness? (Document

2 handed).

3 THE PRESIDING JUDGE: Dr. Greve, maybe this is very naive on my part, but

4 how did the election for the plebiscite take place or how did the

5 voting take place? One ballot was given to Serbs; would people line

6 up and show some proof that they were Serb and they would get the

7 ballot for Serbs, and then there would be another line of people who

8 would demonstrate that they were non-Serbs, and they would get the

9 other ballot? Is that the way it operated and, if so, what about

10 the people who were mixed?

11 A. It is my understanding for (1) that the word, it was spread by word

12 of mouth. This I have from witnesses and information gathered in

13 general. I have not been able to see any newspaper article listing

14 this completely, but I understand that Serbs were approached

15 informally and told that it was appreciated that they would go and

16 vote. Everyone was asked to vote. According to non-Serbs who came

17 to vote, it was a question whether they had to be registered on this

18 list or that list. It is like going to vote in our countries; we

19 will be marked off on whether we come to vote or not. There would be

20 separate lists for Serbs.

21 If at this time people also, which there is some indication to,

22 could sort of declare themselves as Serbs, if they came from a mixed

23 background and had not considered themselves Serbs before, possibly

24 they could do that. I am not completely sure on it. But those who

25 said, "I am a non-Serb" were at least be given the ballot paper for

Page 1012

1 non-Serbs. That is my understanding. I apologise it is

2 superficial.

3 MR. TIEGER: Your Honour, if I could follow up on the court's question and

4 recall the previous exhibit, Exhibit 97, before we proceed?

5 THE PRESIDING JUDGE: The two ballots?

6 THE WITNESS: Linked to the two ballots, there is also an instruction as

7 to how to proceed and it is for the Serb Democratic Party to organise

8 this.

9 MR. TIEGER: Could page 2 of that document be displayed on the elmo? (To

10 the witness): Accompanying the article in which the ballot or copies

11 of the two ballots are shown, are there also instructions, specific

12 instructions, for how the voting should take place and who should

13 organise it? Dr. Greve, I am sorry, I am just identifying that

14 portion of document. Does it indicate that organs were established

15 for the conduct of the plebiscite and instructions on how to

16 undertake that?

17 A. Yes, it does.

18 Q. Turning to the last page of that document, are there instructions on

19 how the ballots are

20 to be presented to individuals who appeared to vote in the

21 plebiscite?

22 A. Yes, it is. There is, however, there is one interesting point in

23 this, if I may say so. It is not particularly clear whether an

24 identity card at this moment would already indicate national

25 background or ethnic group, but possibly this could be read out of

Page 1013

1 the ID card and the numbers already, I do not know.

2 Q. It indicates that the ballots would have separate colours?

3 A. Yes. Yellow for the non-Serbs.

4 JUDGE STEPHEN: I wonder if I could ask a question at this stage? Bearing

5 in mind the long years of communism in Yugoslavia, if one was

6 completely irreligious, how would anyone know that one was Serb or

7 Croat or Muslim? Would it just be by common repute, the

8 language will be the same, the true ethnicity would be the same?

9 A. This, your Honour, is a very good question which a number of people

10 have told me they asked themselves because they simply said, "I have

11 lost track; I have two grandparents from this group and one from each

12 of the others. I never practised religion. Our language is the

13 same. We cannot be distinguished by features or anything". It was

14 not common in the period of the communist regime to think in ethnic

15 terms. One was a Yugoslav.

16 So time and again people would come forward and say, "I really

17 do not know. I am me, but I do not really find myself as belonging

18 to this group as opposed to that group". But some people would live,

19 and this was particularly, perhaps, in remote rural areas where there

20 was more homogenous structure and people had lived and married within

21 a tiny little circle for a long time, but particularly in the cities,

22 there seems to be a lot of people who found themselves to be of such

23 a mixed descent that it was a matter of choice to present yourself as

24 this or that.

25 MR. TIEGER: Turning back to page 3 of that document, does it indicate

Page 1014

1 that the Commissions were to be established for the conducting of the

2 plebiscite including a main Commission, a District Commission and

3 then at the more local level election board?

4 A. Yes, it does.

5 Q. These were the instructions on how to conduct the plebiscite?

6 A. That is correct.

7 Q. But you have, aside from word of mouth, not seen articles on the manner

8 in which it was actually conducted when it happened?

9 A. No.

10 Q. If we can now return to Exhibit 50? Dr. Greve, I had asked you about

11 the importance attached to the conducting of a plebiscite by Serbian

12 officials, and whether or not the establishment of a separate Serbian

13 entity affirmed that importance. In that connection I would like you

14 to look at Exhibit 50 and ask that it be placed on the elmo.

15 A. That is the declaration.

16 Q. In paragraph 1 of that document does it indicate the basis on which

17 the declaration of the Serbian Republic of Bosnia and Herzegovina ---

18 A. Yes, it does.

19 Q. -- is made?

20 A. Yes, it does. It refers to the plebiscite held on 19th November

21 1991.

22 Q. And indicates that it has done so on the basis of the plebiscite?

23 A. Yes, it does and the Serbian people's decision in that plebiscite.

24 Q. Dr. Greve, I appreciate that the discussion of these entities in a

25 kind of chronological order maybe a bit confusing, so if I can have

Page 1015

1 this marked for identification as Exhibit 98? What is that document?

2 A. This is a tiny organogramme which I made simply to visualise the

3 different levels in the different structures.

4 MR. TIEGER: I tender that document for admission.

5 THE PRESIDING JUDGE: Any objection?

6 MR. ORIE: No objection, your Honour.

7 THE PRESIDING JUDGE: 98 will be admitted.

8 MR. TIEGER: May that be placed on the screen, please?

9 (To the witness): What does the left side of the document indicate?

10 A. The left side of the document indicates the legal structure in the

11 time of the Socialist Federal Republic of Yugoslavia, and the

12 different levels, administrative levels, the Republic, the Federal

13 Republic level, the Republic of Bosnia and Herzegovina, the regional

14 level, which at that time was not that significant -- it was the two

15 main Chambers of Commerce -- and the opstina level -- here indicated

16 by opstina Prijedor -- and what I referred to yesterday as the Mjesna

17 Zajednica meaning the local communes.

18 Q. What does the right side of the document describe?

19 A. The right side is made to indicate the separate structure which is

20 being set up in 1991, 1992. On 27th April 1992, it is recalled from

21 Dr. Gow's explanation that the Federal Republic of Yugoslavia was

22 declared which is a legal entity. Then there are these new entities,

23 and I have placed them sort of from the federal level and down to the

24 commune level; the Republic of the Serbian people of Bosnia and

25 Herzegovina, which was declared on 9th January 1992, changing its

Page 1016

1 name, 28th February 1992, to become the Serbian Republic of Bosnia

2 and Herzegovina, changing again its name on 12th August 1992 to

3 become Republika Srpska, and having declared itself in statehood with

4 the Federal Republic of Yugoslavia.

5 This again operated with the autonomous regions. There were

6 several of them. I have indicated the autonomous region of Krajina,

7 which carries the acronym ARK, because that is the regional unit

8 which is just about opstina Prijedor. When the Serbs took power in

9 Prijedor, they declared it to be Srpska opstina Prijedor, meaning the

10 Serbian opstina Prijedor, and still the local communes, which then

11 became Serbian communes, remained Mjesna Zajednica. It is only to

12 indicate the different levels as I myself find it easier to relate

13 something sometimes to what is illustrated.

14 Q. I note that on the left side, which indicates the democratically

15 elected structure of Bosnia and Herzegovina, the region is marked but

16 there is no box. In the official government, was there any regional

17 structure analogous to the autonomous region of Krajina?

18 A. No, there was not. It was only these two Chambers of Commerce which

19 had a very different background and level of functioning.

20 MR. TIEGER: I am about to move on to a separate topic, your Honour,

21 unless the court has questions?

22 THE PRESIDING JUDGE: I did have a question regarding 98, is it? Dr.

23 Greve, on the right-hand side of the diagram, you have the boxes in

24 dotted lines, the four boxes, below the Federal Republic of

25 Yugoslavia. Why are they in dotted lines?

Page 1017

1 A. I have put them in dotted lines because it is disputed if this is

2 legal structures or not. They are objected to as being legally and

3 lawfully established structures, but they are definitely de facto

4 existing structures. I only did this to visualise something, but not

5 to minimise the debate on that important issue.

6 Q. It is helpful to visualise it. But I also note that you do not have

7 any arrows. When I think of an organisational chart, I think of

8 something being at the top, and then there being arrows to show who

9 reports to whom;is it the purpose of this chart to suggest or to

10 establish that the Republic of Srpska reported to the Federal

11 Republic of Yugoslavia?

12 A. As political science is not my field of expertise, I have purposely

13 left out arrows so that I should not move beyond my own

14 understanding.

15 THE PRESIDING JUDGE: We will stand in recess for 20 minutes.

16 (11.30 a.m.)

17 (The court adjourned for a short time)

18 (12.00 p.m.)


20 MR. TIEGER: Thank you, your Honour. Dr. Greve, we have been discussing

21 in general a period of time between the elections in August 1990 and

22 the takeover in April 1992. I would like to take you to a point in

23 the middle of that in 1991 when the war in Croatia erupted. Did that

24 have an effect on ethnic relations in opstina Prijedor?

25 A. Yes, it did when it came to mobilization.

Page 1018

1 Q. And did the national or ethnic groups respond differently as groups

2 to the mobilization?

3 A. Yes, they did.

4 Q. How did the Serbs respond to the mobilization to fight in the war in

5 Croatia?

6 A. In contradistinction to the non-Serbs, Serbs responded positively in

7 principle. There were of course many among them as well who were

8 hesitant to go to the war.

9 Q. What was the Muslim and Croat community response to the mobilization?

10 A. In general they did not respond, that is they would not be willing to

11 fight in the war in Croatia.

12 Q. Did the SDA on a republic and opstina levels support the mobilization

13 or opposed the mobilization?

14 A. It opposed the mobilization.

15 Q. Did they take any steps, however, to physically obstruct the

16 mobilization in any way?

17 A. Not in principle, but they were quite eager to see at the time that

18 there would be rather a reduction in armament and war efforts.

19 Q. Did this disparate response by the ethnic groups create heightened

20 tensions between those groups

21 A. To a certain extent I think it was most efficient in terms of

22 being useful for the propaganda efforts, and the split being created

23 by the Serbs being threatened and having many enemies among them.

24 Q. Was there an increase in propaganda following the outbreak of the

25 Croatian war?

Page 1019

1 A. Yes, there was indeed.

2 Q. Now did the different responses to the mobilization have an effect on

3 arming within or on the level of arms within opstina Prijedor?

4 A. Yes, it did.

5 Q. First of all, with respect to those Serbs from Prijedor who responded

6 to the mobilization what effect did it have?

7 A. They were armed and they were equipped and trained and sent to the

8 theatre of war in Croatia.

9 Q. When they returned to Prijedor, were they demobilized?

10 A. No, they were not. There was a decision by the legal authorities in

11 opstina Prijedor that they should be disarmed and demobilized, but

12 that was not accepted and did not happen de facto.

13 Q. Did Muslims who had previously been members of the reserve units

14 become no longer part of those reserve units of the JNA?

15 A. Yes, in part that happened, quite to some, a large extent I would

16 say.

17 Q. Now in addition to the arms received by Serbs who responded to the

18 mobilization and who returned with those arms and were not

19 demobilized, was there additional arming of persons within opstina

20 Prijedor?

21 A. Yes, there was considerable additional arming. The general

22 population were not alarmed by the fact that soldiers going to war

23 were being armed, but they started to be alarmed when they saw

24 neighbours and Serbs in general being armed.

25 Q. So Serb citizens who were not part of the war in Croatia were also

Page 1020

1 being armed?

2 A. Yes, such as elderly women, young youngsters, clearly under age to go

3 to war.

4 Q. Did Serbian de facto officials in Prijedor later acknowledge this

5 arming of citizens?

6 A. Yes, they did.

7 Q. May I have this document marked as No. 99 for identification, please?

8 (Document handed). Dr. Greve, what is this document?

9 A. This is a newspaper article from Kozarski Vjesnik dated 9th July 1993

10 where it is excerpts from what was broadcast on Radio Prijedor in the

11 programme Srdjan Mrdjan Maladan which was broadcast on 30th June

12 1993.

13 Q. Does it contain the presentation of a programme which included the

14 participation of the Deputy Chairman of the Prijedor municipality?

15 A. Yes, it does.

16 Q. The commander of the 43rd Brigade Militia Unit?

17 A. Yes, it does.

18 Q. The head of the public security station in Prijedor at that time in

19 July 1993?

20 A. Yes, it does.

21 Q. Your Honour, I tender that No. 99 for admission.

22 MR. ORIE: No objection.

23 THE PRESIDING JUDGE: Exhibit 99 will be admitted.

24 MR. TIEGER: Dr. Greve, can I draw your attention to page 3, please. Can

25 the monitor be focused on the fifth paragraph. Dr. Greve, you see the

Page 1021

1 fifth paragraph which is a Radanovic speaking according to the text?

2 A. Yes, I see that.

3 Q. Who is Simo Radanovic?

4 A. He is the military commander.

5 Q. Was he an active leader during the time of, following the takeover

6 and during the time of cleansings in the Prijedor municipality?

7 A. Yes, he was. According to himself he was the head of the so-called

8 Gypsy Brigade.

9 Q. Did he later become deputy Chairman of the Prijedor Municipality

10 Assembly after that?

11 A. Yes, according to himself and statements in the newspaper.

12 Q. OK. Does he confirm whether or not there was arming of Serbs in

13 opstina Prijedor before the takeover?

14 A. Yes, he does.

15 Q. In fact, does he certify it in that first sentence?

16 A. Yes. He says: "I hereby certify that, with agreement and

17 co-operation of some countries Serbs at the time, we had indeed

18 started the armament of Serbian people, but under condition that the

19 abuse of weapons should be avoided."

20 Q. Is he speaking about the time prior to the military takeover of

21 Prijedor?

22 A. That is that he does.

23 Q. May I have this document marked as Exhibit 100, please? (Document

24 handed). What is this Exhibit, Dr. Greve?

25 A. This is again a translation of a newspaper article printed in

Page 1022

1 Kozarski Vjesnik, 6th August 1993 with a headline: "Third Anniversary

2 of the Serbian Democratic Party of Prijedor preventing a repetition

3 of the Serbian massacre of 1941".

4 Q. Who is primarily quoted in this article?

5 A. There are several. Simo Miskovic, I think he is the one who is

6 primarily quoted.

7 Q. We tender this document for admission, your Honour.

8 THE PRESIDING JUDGE: Any objection to Exhibit 100?

9 MR. ORIE: No objections, your Honour.

10 THE PRESIDING JUDGE: Exhibit 100 will be admitted.

11 MR. TIEGER: May that be placed on the screen, please. Dr. Greve, you

12 mentioned Simo Miskovic, who was he?

13 A. He was Chairman of the SDS, the Serbian Democratic Party District

14 Committee.

15 Q. Does the article at the top indicate the occasion which prompted the

16 interview with Simo Miskovic?

17 A. Yes, the third anniversary of the Serbian Democratic Party of

18 Prijedor.

19 Q. Turning to the last sentence in paragraph 3, does Simo Miskovic

20 indicate whether or not Serbs were armed prior to the military

21 takeover in 1992?

22 A. Yes, he acknowledged this, saying the SDS leadership saw what they

23 were planning, referring to non-Serbs,and started to arm their own

24 people in order to prevent the tragedy of 1941.

25 Q. I note in that same paragraph, Dr. Greve, in the second sentence it

Page 1023

1 says that: "On August 2nd 1991 we in the district of Prijedor have

2 formed the SDS." Is that an accurate date for the establishment of

3 the SDS in Prijedor?

4 A. No, it cannot be as they participated in the election the previous

5 year, but also, as this is printed in 1993, there could be a mistake

6 in the original or in the translation, as this is called "the third

7 anniversary" indicating, of course, that this party was established

8 in Prijedor before participating in the election.

9 Q. Was the process of arming Serbs by the SDS within opstina Prijedor

10 accelerated as the time drew closer to the military takeover?

11 A. Yes, indeed.

12 Q. In that connection I ask you to look at Exhibit 91, if that can be

13 presented to the witness. (Document handed). Dr. Greve, who

14 participated in the arming of Serbs in the opstina Prijedor?

15 A. It was again a joint effort between the party, the military and the

16 Serb people.

17 Q. Can I ask that page 1 of Exhibit 91 be displayed on the screen? Can

18 we focus on the fourth paragraph, please? Looking at that paragraph

19 and the one on the next page, does it indicate the co-operation and

20 assistance of the Commander of the army in Prijedor at that time?

21 A. Yes, it does. It is actually referring in the last line to Colonel

22 Arsic, Vladimir Arsic, who was the Commander in the area.

23 Q. Can we display the top of the next page, please?

24 A. Here it is stated that he was the Commander of "our garrison, a good

25 soldier and a man with a lot of experience and we decided that we

Page 1024

1 must speed up the process of arming ourselves."

2 Q. All this was before April 30th 1992 when the takeover occurred?

3 A. Yes, it was.

4 Q. And before the announced time of withdrawal for the JNA from Bosnia

5 and Herzegovina?

6 A. Yes, it was. If I may add something which I think is significant,

7 which is that this process of armament, of arming the ordinary

8 people, fed well into the line of propaganda, that is, people became

9 even more fearful when they were told that they had to be armed to

10 protect themselves, so as if there were enemies everywhere.

11 Q. Now in addition to the standing army, the JNA, the defence system of

12 the former Yugoslavia also included Territorial Defence; is that

13 right?

14 A. That is correct.

15 Q. Which was in some practical effect a sort of republic army?

16 A. Yes.

17 Q. Were weapons of the TO under that system held by the local opstinas?

18 A. Yes, it was.

19 Q. Did that mean that in this case weapons were available to Muslims and

20 Croats by virtue of the existence of the TO?

21 A In principle, yes. In practice they had started to withdraw arms from

22 the TO in 1991. This is one of the issues that I think Dr. Gow

23 was looking into also with reference to the book of General

24 Kadijevic.

25 Q. May I have this document marked as Exhibit 101? (Document handed).

Page 1025

1 Dr. Greve, what is this document?

2 A. This is also a translation of an article in Kozarski Vjesnik dated

3 20th May 1994, headlined: "We know our goal".

4 Q. It contains an interview with?

5 A. Colonel Radmilo Zeljaja, Commander of the 33rd Prijedor Motorized

6 Brigade.

7 Q. We tender this document for admission, your Honour, 101.

8 THE PRESIDING JUDGE: Any objection?

9 MR. ORIE: No objection, your Honour.

10 THE PRESIDING JUDGE: 101 will be admitted.

11 MR. TIEGER: Can that be displayed on the screen, please, on page 1? Can

12 we look to the second paragraph, please? Dr. Greve, looking at the

13 middle of that paragraph, the sentence which begins "Our command",

14 does Colonel Zeljaja indicate what happened to the weapons of the TO?

15 A. Yes, he does. He is saying that, "Our command, with the approval of

16 the Corps," that is the one headquartered in Banja Luka, "managed to

17 get together both the weapons and technical equipment from the

18 Territorial Defence TO units of the municipalities, Prijedor,

19 Sanski Most, Novi Grad and Bosanski Dubica, as well as Kninska

20 Krajina region, and place them under our control in our depots."

21 Q. So those TO weapons would at that point be under the physical control

22 of the JNA?

23 A. That is my understanding from the article.

24 Q. Do you know whether any of these weapons were later redistributed to

25 the TOs?

Page 1026

1 A. Yes, they were.

2 Q. In general what amounts and what quality weapons?

3 A. In general it was just a small amount of the total number of weapons,

4 and it was not good quality weapons.

5 Q. Now in addition to having a separate Police Force and a separate

6 Assembly, did Serbs authorities refer to a Serbian TO, a separate TO?

7 A. Yes, they did. They started to refer to a Serbian TO prior to taking

8 power on 30th April 1992.

9 Q. And who was the head of that Serbian Territorial Defence?

10 A. It was Slobodan Kuruzovic.

11 Q. May I have this document marked as Exhibit 102 for identification,

12 please? (Document handed). What is this document, Dr. Grieve?

13 A. This is again an article from Kozarski Vjesnik dated 30th May 1994.

14 It is headlined: "Staff changes in IBC (the Information and Business

15 Centre) Kozarski Vjesnik, new manager Slobodan Kuruzovic".

16 Q. We tender this document for admission as 102.

17 MR. ORIE: No objection.

18 THE PRESIDING JUDGE: Exhibit 102 will be admitted.

19 MR. TIEGER: May that be displayed on the screen? If we could go back and

20 look at the third paragraph. Looking at the third paragraph, Dr.

21 Greve, does it indicate Slobodan Kuruzovic's position in the Serbian

22 TO?

23 A. Yes, the last sentence in paragraph 3 refers to him, Slobodan

24 Kuruzovic, as being the Commander of Serbian Territorial Defence

25 headquartered in Prijedor and one of the organisers of the seizure of

Page 1027

1 power in Prijedor on 29th/30th April 1992.

2 Q. Does it indicate whether or not he was also a member of the SDS?

3 A. Yes, it does.

4 Q. After Mr. Kuruzovic was commander of the Serbian Territorial Defence

5 headquarters in Prijedor and had assisted in organising the military

6 takeover of Prijedor, what position was he appointed to according to

7 this article?

8 A. According to this article, he is becoming head of the Kozarski

9 Vjesnik which at this point has long been a mark piece of the Serbian

10 propaganda and information efforts in opstina Prijedor.

11 Q. Looking at the last line of the article, does Mr. Kuruzovic indicate

12 the principles by which he will be guided in running Kozarski

13 Vjesnik?

14 A. Yes, he does. "The orthodox creed, the interests of Serbian people

15 in Republika Srpska will be the main guidelines for my editorial

16 policies in IBC, said Kuruzovic."

17 Q. Dr. Greve, I would like to bring your attention to the period of time

18 immediately before the military takeover of Prijedor at the end of

19 April 1992. First of all, let me ask you briefl

20 about the political situation within Prijedor at that stage. Was the

21 Municipal Assembly functioning effectively and as a working

22 democratic institution at that point?

23 A. No, it was not, but let me perhaps add that there was an Executive

24 Board with secretariats that did function, although the Assembly with

25 its committees did not function or not function very well.

Page 1028

1 Q. So the opstina was not completely broken down, but were political

2 decisions being made in the normal fashion?

3 A. It was running as a political entity, yes.

4 Q. What was happening within the Assembly at that point? How

5 effectively was it functioning?

6 A. It was not functioning effectively. It was being obstructed. It was

7 almost impossible to reach a consensus on anything and there were

8 occasions where participants would leave the Assembly.

9 Q. So the mechanisms were still available but decisions could not be

10 made?

11 A. That is correct.

12 Q. Had a separate Assembly been established by that time by Serbs in

13 opstina Prijedor?

14 A. Yes, it had, as it was illustrated earlier by the decision that they

15 wanted to join the autonomous region of Krajina.

16 Q. And had the separate police stations been established by that time?

17 A. Yes, they had.

18 Q. With respect to the military situation at that point, had troops or

19 reservists who had gone or volunteers who had gone to fight in

20 Croatia returned?

21 A. Yes, the majority had returned and even more than the people who came

22 from Prijedor. There was a cease-fire in Croatia early in 1991, and

23 because Prijedor has this infrastructure and link between the regions

24 in Croatia where the battles had been fought, all the troops that

25 withdrew through Bosnia-Herzegovina or a large number of those troops

Page 1029

1 necessarily would be withdrawn through Prijedor. That is not exactly

2 the corridor but it is this important link by road from these

3 Croatian battlefields and to Serbia.

4 Q. Were those persons who had been mobilized or volunteered to fight in

5 Croatia, primarily of one ethnic group?

6 A. The majority were Serbs, yes.

7 Q. When they returned were they demobilized?

8 A. They were not.

9 Q. Did they retain their arms?

10 A. They did.

11 Q. Were additional troops beyond those persons who were originally from

12 the opstina placed in or near opstina Prijedor?

13 A. Yes, that is to say, some of them had been placed when the war in

14 Croatia was already on and the people will claim that, "This was our

15 troops, so we were not afraid of them", they were placed locally and

16 it was said that possibly they would move on to Croatia if they were

17 needed on the battlefield, and they just were stationed in Prijedor.

18 Others when going back did not leave Prijedor but stayed on for a

19 while in Prijedor.

20 Q. Had heavy weaponry been brought into the area?

21 A. Yes, a lot of heavy weaponry, such as tanks, howitzers, artillery.

22 Q. Were there paramilitary troops in Prijedor?

23 A. Yes, there was.

24 Q. Were the origins of some of those troops known to citizens?

25 A. Yes, it was. I may perhaps explain at this point that there are two

Page 1030

1 main variations to my understanding of the Serbo Croatian language;

2 it is Ekavian which is spoken essentially in Serbia, and Ijekavian

3 which is spoken in Croatia and Bosnia. Again, I do not know the

4 language, but it is explained to me that the difference is equal to

5 that between British-English and American-English, so that people

6 will immediately be able to distinguish if a person speaks the

7 Ekavinin language which is found in Serbia proper. But there are

8 exceptions. There are some areas in Serbia proper which speaks the

9 same Ijekavian language as the people in Croatia and Bosnia, but not

10 the other way round, according to the dictionaries which I have

11 consulted.

12 Q. Finally, were Serb civilians armed at that time?

13 A. Yes, they were.

14 Q. What happened on the night April 29th, April 30th?

15 A. In the very early hours of 30th April, that is after midnight,

16 approximately 4 o'clock, the Serbs in opstina Prijedor, co-operation

17 between army, including paramilitary forces, police and the party,

18 were seizing power with armed force; that is, they established all

19 over the town of Prijedor checkpoints, placed armed guards outside

20 all the main buildings, police station, bank, town hall and inside

21 the radio station, etc., etc., and ha

22 snipers on the roofs. They also went public on Radio Prijedor to

23 announce that they

24 had by force established Srpske opstina Prijedor.

25 Q. Now did the de facto Serbian authorities later claim that the

Page 1031

1 takeover was triggered by some particular event?

2 A. Yes, they did. When journalists spoke, well, I should say this, that

3 the people living in opstina Prijedor at this time, as mentioned

4 yesterday, had been cut off from receiving TV transmissions and

5 broadcasts from Sarajevo. They would only see the broadcasts that

6 came from Belgrade, Banja Luka or eventually Pale. The TV station in

7 Belgrade had on 29th April transmitted a facsimile of a telefax to

8 the effect that the Republic -- the leader of TO in the Republic of

9 Bosnia-Herzegovina had given an instruction to the TO in

10 Bosnia-Herzegovina to attack and obstruct the JNA when they were to

11 withdraw from Bosnia-Herzegovina. But immediately this telefax was

12 denounced and declared false by the authorities in Sarajevo, and I

13 have not come across people who have actually had themselves access

14 to this telefax in Prijedor. However, when journalists later came to

15 Banja Luka, they were given a copy of this telefax as the pretext why

16 this power change had to take place.

17 Q. May I have this document marked as Exhibit 103? (Document handed).

18 What is that document, Dr. Greve?

19 A. It is called FBIS EEU 92084, of 30th April 1992 -- FBIS EEU is the

20 Foreign Broadcast Information Service Eastern Europe -- and it is

21 referring to a broadcast which was made by radio Sarajevo network in

22 Serbo-Croatian at 1818 GMT, 29th April 1992.

23 MR. TIEGER: I tender this document for admission, your Honour.

24 THE PRESIDING JUDGE: Any objection?

25 MR. ORIE: No objections, your Honour.

Page 1032

1 THE PRESIDING JUDGE: Exhibit 103 will be admitted.

2 MR. TIEGER (To the witness): Does this document indicate whether or not

3 Bosnian authorities were aware of reports that an order had been

4 given to local TOs?

5 A. Yes, it indicates that they were informed of this and they thus had

6 to come out immediately to state that this was false.

7 Q. Does the exhibit indicate whether or not a public denunciation of

8 that fax as false was made?

9 A. Yes, it is referring to such denunciation already having been made

10 and it is repeating it.

11 Q. In fact, Dr. Greve, did the de facto Serbian officials of Prijedor

12 indicate themselves whether or not the takeover was a spontaneous

13 event in response to this fax or, in fact, a long-standing plan?

14 A. They are consistently referring to a long-standing plan. At one point

15 they speak about why it had to be the 9th to 30th; they are saying

16 that, "We had it considered to make it the 30th, the night after this

17 night to 1st of May, but because of this we had to move forward 24

18 hours". But I should also add that years after this happened, there

19 is no more any mention of this telefax. However, there is reference

20 to a completely different telefax to which no mention was made in the

21 early days.

22 Q. May I ask that Exhibit 91 be placed before the witness? If I can ask

23 you to look at the third paragraph, does this indicate whether or

24 not the takeover was a spontaneous reaction or a planned event for

25 some time?

Page 1033

1 A. It clearly states that this was not a spontaneous reaction; it was

2 only the final act of a long-standing plan.

3 Q. The person who says this is whom?

4 A. It is Milomir Stakic.

5 Q. Was he the first Chairman of the Serbian Municipal Assembly?

6 A. He was.

7 MR. TIEGER: May document Exhibit 90 be placed in front of the witness

8 once more? (To the witness): Dr. Greve, you indicated that the

9 takeover was a co-ordinated effort between political police and

10 military authorities?

11 A. Yes, I stated that.

12 Q. Does paragraph 3 of Exhibit 93 indicate who participated in the

13 takeover?

14 A. Yes, it does.

15 Q. What does that article say?

16 A. This paragraph refers, if I should take at this point only the second

17 half of it, "It was not easy to hold illegal meetings and to prepare

18 for defence, but after the presidency of the former BIH blockaded the

19 barracks and other military installations, it was decided in

20 agreement with the officers of the Serbian army, the Serbian

21 Democratic Party and the Executive Committee of the Municipality of

22 Prijedor to seize power from the Muslim extremists"

23 Q. In this takeover which took place by force of arms on April 30th

24 1992, with the agreement and co-operation of the JNA, was that before

25 the announced withdrawal of JNA troops from Bosnia and Herzegovina?

Page 1034

1 A. Yes, it was.

2 Q. They were the JNA at that time?

3 A. Yes, they were.

4 Q. Did the Muslims physically resist when confronted by the arms, the

5 combined arms, of the JNA, the Serbian police, the paramilitaries?

6 A. No, they did not, and I assume that is why it can also be stated here

7 in the article, in the next paragraph, that all this happened without

8 one shot being fired, and that is repeatedly referred to in

9 newspaper articles.

10 Q. In that connection, can I draw your attention back to Exhibit 100?

11 In Exhibit 100, does Simo Miskovic indicate whether or not there was

12 Muslim or Croat resistance to the takeover on April 30th?

13 A. Simo Miskovic is stating that on 30th April 1992 the takeover was

14 achieved without a single shot being fired and without a single

15 casualty.

16 Q. Dr. Greve, I would next like to ask you about the immediate

17 consequences of this takeover. First of all, did it have an effect

18 on the dissemination of propaganda or information?

19 A. Yes, it did. Immediately, both Kozarski Vjesnik and radio Prijedor

20 became virtual mouth-pieces of the new authorities, that is, the

21 Srpska opstina Prijedor.

22 Q. Was there an escalation of the tenor or the tone of that propaganda?

23 A. Yes, the terms used for Croats and Muslim became much more

24 derogative.

25 Q. Was there an effect on the movement for Muslims and Croats within the

Page 1035

1 opstina?

2 A. Yes, movement for these groups was severely obstructed, but I should

3 perhaps say that when one refers to Muslim and Croats, it is perhaps

4 even more correct to refer to non-Serbs because there were other tiny

5 minority groups who were also not included in the Serb group. Among

6 Serbs were considered also the Montenegrins, there were not many of

7 them, but they were like smaller brothers, and there were some of the

8 aliens who were well accepted, but, essentially, it was the Serbs and

9 the non-Serbs of whom the Muslims were the majority.

10 Q. What was the nature of the control of movement within the opstina,

11 how was it affected?

12 A. There were several measures being implemented. There were road

13 blocks at intersections where people would have to show their IDs,

14 and if their ID card would not prove them to be Serbs, then they

15 could not been identified as Serbs, they were not necessarily

16 entitled to pass the road blocks. They would need special permits to

17 travel, and it was very limited and restricted where were they were

18 able to travel. They could no longer leave opstina Prijedor,

19 essentially. They also had to abide by a curfew.

20 Q. Did Serbian officials later acknowledge just how tight these controls

21 became?

22 A. Yes, they did.

23 Q. Can I direct your attention back to Exhibit 99, please? Directing

24 your attention to page 3 of that document, looking at the middle of

25 that page where there is a statement by Mr. Ecim, does he indicate

Page 1036

1 in any way how tight some of those controls became?

2 A. Yes, he does indeed, because he is referring to the difficulties,

3 well, actually he is placing blame on some Serbs who assisted,

4 allegedly, Muslims to leave or non-Serbs to leave, saying that they

5 were leaving the region in coffins, in cars owned by the Serbs and

6 with Serbian IDs which indicates it was not an easy thing to get out.

7 Q. Was there a control of communication?

8 A. Yes, it was control of communication. It is recalled that there are

9 some main roads going through the area and it was no more possible

10 for the non-Serbian population to have bus tickets to leave, and they

11 could not leave with their own cars least they had had Serbian IDs,

12 and they could not easily get a ticket, if at all, on the railway,

13 and there is an aerodrome in the area, but it is not a modern

14 airport, it is more like a sports field for sports planes and there

15 were no regular air traffic through the area.

16 Q. What about the use of telephones, did that change in any way?

17 A. Yes, they were on and off the telephone lines were blocked for the

18 non-Serbs. This soon became more the general rule than the exception

19 and also electricity was in part shut down.

20 Q. After the takeover, was there an effect on the employment status of

21 Muslims and Croats?

22 A. Yes, actually, and this is later being confirmed by the official

23 gazette by the autonomous region of Krajina, now it became important

24 to be a good Serb, someone who knew that and had demonstrated that

25 they were loyal to the Serbs, the party, the plebiscite had voted for

Page 1037

1 independence etc., and this definitely meant that all the non-Serbs

2 would no more qualify for leading positions and they were asked to

3 leave all leading positions

4 Eventually, within days, the majority of the workforce, even in

5 factories, were asked

6 to leave their positions.

7 MR. TIEGER: Your Honour, may I have this document marked as Exhibit 104

8 for identification, please? (Document handed).

9 (To the witness): What is this document, Dr. Greve?

10 A. This is a full translation of a newspaper article. It is not

11 mentioned where it is published in the translation, but it mentioned

12 that the date of publication is 22nd June 1992, and its headline is

13 "Leaders - only loyal Serbs!". Within this article there is a

14 facsimile from a decision made by the autonomous region of Krajina.

15 It is Crisis Staff in Banja Luka.

16 MR. TIEGER: We tender this document.

17 THE PRESIDING JUDGE: Any objection?

18 MR. ORIE: No objection, your Honour.

19 THE PRESIDING JUDGE: Exhibit 104 will be admitted.

20 MR. TIEGER (To the witness): Can that be raised a bit? Dr. Greve, does

21 this document indicate whether or not the process of termination from

22 the employment of Muslims and Croats which began after the takeover

23 continued?

24 A. Yes, it indicates that this continued and it was more and more

25 demands being made concerning those who were to keep positions.

Page 1038

1 Q. Does it also indicate the conditions or qualifications for continued

2 positions, important positions, within the autonomous region?

3 A. Yes, it does. This is the time when virtually most of the

4 non-Serbian population has already been asked to leave their jobs.

5 Now, the remaining ones are Serbs, and it is being indicated that any

6 Serb is not good enough. It is stated that in addition to being of

7 Serbian nationality -- I am looking at the second paragraph, the

8 second part -- "In addition they", that is the Serb nationals, "must

9 have confirmed their Serbian nationality in the plebiscite". That

10 is the one, 9th and 10th November 1991, and it must be ideologically

11 clear to them that the only representative of the Serbian people is

12 the Serbian Democratic Party.

13 JUDGE STEPHEN: I wonder if I can ask a question about this? I see the

14 reference here to the army of the Serbian Republic of

15 Bosnia-Herzegovina. This was at a time when it had been declared

16 that a Serbian Republic would remain part of Yugoslavia.

17 A. That is correct, your Honour.

18 Q. Could one have a separate army if one was a Republic of the Yugoslav

19 nation?

20 A. In my opinion, no, your Honour.

21 Q. Did the other entities of that rump nation have their own armies?

22 A. Eventually, they moved to establish their own armies and armed

23 entities but, as was illustrated yesterday with the decision made by

24 the committee of senior officials in the then conference on

25 co-operation and security in Europe, it was pointed out in that

Page 1039

1 decision that the heavy equipment belonging to the JNA had to be

2 withdrawn, as had all the personnel that did not belong to Bosnia or

3 come originally from Bosnia-Herzegovina, and that it could not simply

4 be up to the JNA to decide to establish a Bosnian-Serb army, give

5 them full armament etc.; either the arms had to be withdrawn from

6 Bosnia-Herzegovina or it had to be placed under the control of the

7 legal authorities, that is, Sarajevo.

8 MR. TIEGER: Did the new de facto Serbian authorities following the

9 takeover begin to make demands on the Muslim and Croat population?

10 A. Immediately.

11 Q. What were the nature of those demands?

12 A. One of the first demands was in a sense a follow-up, if I may

13 mention, of what had happened already previously or prior to taking

14 power; that is, that non-Serbs who for one reason or the other had a

15 weapon, they were being approached by police or tanks or anyone.

16 Although this might be a hunting rifle and they may have a licence

17 for carrying that hunting rifle, they were asked to give up their

18 arms. They were told if they did not accept to give it up, they will

19 be forced to give it up.

20 So many people had started to hand in whatever hunting weapons

21 they had, or other weapons if they were members of sports clubs,

22 handling weapons or whatever. But this was speeded up considerably

23 after the Serbs took power. Then they made a demand that everyone

24 who had any kind of weapons should hand them over immediately.

25 Q. In general, how did the Muslim and Croat community respond to those

Page 1040

1 demands to surrender their weapons?

2 A. By and large, I believe most of those weapons were handed into the

3 Serbs because they were confronted with an overwhelming strength of

4 arms. However, there were people who were appointed policemen by the

5 legal authorities in Sarajevo who were not

6 necessarily immediately willing to give up their arms to an illegal

7 entity; there was a conflict of loyalty in this situation.

8 They were appointed as representatives of a legal government,

9 and they did not, all of them, immediately give up their arms. The

10 same was the case with this not so good arms kept by some of the

11 Territorial Defence. They were also in this; they were a part of a

12 legal structure and immediately to hand over their weapons to an

13 illegal entity was not always done.

14 Q. Did the de facto Serb authorities demand any demonstration or pledge

15 of loyalty to their new regime?

16 A. Yes, they did. Before virtually dismissing all the police, they

17 called them for meetings and said they would have to carry the new

18 Serbian insignia, they would have to pledge loyalty to the new

19 Srpska opstina Prijedor, etc.

20 Q. Did the schools function normally?

21 A. Initially, yes, but it was decided (and that is also confirmed by the

22 decision made by the autonomous region of Krajina) that this

23 particular year they would end school much earlier than normally.

24 They would end on 20th May which, I think, is a significant date for

25 the later events. This is also the time when virtually everyone in

Page 1041

1 the Serb population had been mobilized to the army, to the reserve,

2 to the police, to the Reserve Police Force, and this way also the

3 teachers became available to take up service also in the Territorial

4 Defence Forces of which the Serbs had their special branch.

5 Q. Schools were closed by order of the autonomous region Krizni Stab on

6 May 20th?

7 A. Yes.

8 Q. When did the first military action against a Muslim or Croat

9 community take place?

10 A. 22nd May. If I may add also one thing, already during the

11 mobilization for Croatia, it had become a problem that there were not

12 enough military uniforms when they tried to get everyone into

13 uniform. So it seems that on occasions many people would go to war

14 partly dressed in uniform and partly in civilian clothing.

15 MR. TIEGER: Can we have Exhibit 78 displayed? I apologise. Apparently,

16 Exhibit 79 will better illustrate the region for the witness. (To

17 the witness): Dr. Greve, can you show us the area where the first

18 military attack occurred?

19 A. It is on this stretch from Prijedor and up to Hambarine which is

20 located on a higher level than Prijedor, the town, and Hambarine is

21 one village, but it is also a Mjesna Zajednica which includes areas

22 to its north and west, essentially -- also some to the south.

23 Q. Was there any incident which preceded the military attack?

24 A. Yes, there was. Hambarine is located on the way towards Ljubija --

25 this road actually continues down to Ljubija -- and Ljubija was an

Page 1042

1 area which at that time had not been -- the full Serbian control had

2 not yet been established; that is, as we will return to later, on the

3 day of 22nd May, the Serbs claimed that once again they took power in

4 Ljubija without any violence, they just being cunning (as they are

5 saying themselves) were able to get all the weapons away from all the

6 non-Serbs in that area.

7 But, at this day there was a road block on the road from

8 Prijedor up to Hambarine, manned by some Muslim people, and there was

9 a car coming up, I believe it was, according to newspaper articles

10 referring to this later, four Serbs and one Croat in this car; the

11 Croat being the driver, the Serbs possibly being members of the

12 Bijeliorlovi which is the White Eagles which is a paramilitary unit.

13 They were in uniform and they were carrying arms and they were asked

14 to stop at this check point to give up their arms before they passed.

15 Apparently, they did not want to do that and there was a shooting

16 incident in which two Serbs were killed; one of the Muslims was

17 initially wounded and subsequently died from his wounds.

18 Q. Following that incident, was there an ultimatum made on the residents

19 of Hambarine?

20 A. Yes, there was an ultimatum that Hambarine as such would have to hand

21 over to the authorities in Prijedor town, it was announced on radio

22 Prijedor, the three or four people who had actually been manning this

23 checkpoint.

24 Q. When the ultimatum expired the next day, what happened? Was there a

25 military attack?

Page 1043

1 A. There was a military attack. Compared to what was later to come,

2 this was not an extreme attack. It was an attack whereby Hambarine

3 area and nearby locations were initially shelled by heavy artillery,

4 some of which were stationed in the town of Prijedor at the airfield,

5 aerodrome, Urije, in that area, so they were actually shooting from

6 across Prijedor and up to Hambarine. When the bombardment ended, the

7 Serb armed entities came with tanks and other weaponry to the area of

8 Hambarine. Many of the people had already left this area going either

9 north to Rizvanovici, Biscani and other villages in this

10 area which at this point were not that much attacked, and they had

11 tried to withdraw to the south which is a forested area -- it is

12 called Kurevo -- and that was being shelled as well as the people

13 left.

14 THE PRESIDING JUDGE: We will stand in recess until 2.30.


16 (1.00 p.m.)

17 (Luncheon adjournment)

18 (2.30 p.m)

19 THE PRESIDING JUDGE: Mr. Tieger, you may proceed.

20 MR. TIEGER: Thank you, your Honour. Your Honour, yesterday I tendered

21 document 82 with the understanding that it was a black and white copy

22 of a document we expected to receive in full colour shortly. That

23 document is here and it can be used today.

24 THE PRESIDING JUDGE: Fine. That is 88?

25 MR. TIEGER: 82, your Honour.

Page 1044

1 THE PRESIDING JUDGE: 82, sorry. Is there any objection to the colour

2 being substituted for what was admitted yesterday as 82?

3 MR. ORIE: No objection, your Honour.

4 THE PRESIDING JUDGE: OK, very good. It will be substituted.

5 MR. TIEGER: May the new document 82 be displayed for the witness?


7 MR. TIEGER: Yes, your Honour. (To the witness): Dr. Greve, you

8 explained this map to us yesterday when it was only depicted in black

9 and white. Perhaps you can indicate to us quickly what the colours

10 represent?

11 A. Yes. The colour code will be that the green indicates predominantly

12 or mainly Muslim habitations and settlements, the blue indicates the

13 Serb ones and the red indicates the Croat ones.

14 Q. Can you indicate then on this map of the ethnic distribution of

15 opstina Prijedor where the region you were talking about before the

16 adjournment or the recess is located?

17 A. We then was looking at Hambarine which is both a village and a Mjesna

18 Zajednica which covers adjacent areas as well.

19 Q. You indicated that on May 23rd Hambarine was subjected to first

20 shelling and then troops?

21 A. Invaded by troops and tanks, yes.

22 Q. What did the residents of Hambarine do when the shelling began?

23 A. They tried to run away, run to the north, to other Muslim areas, or

24 to the south, still to Muslim areas; and the Carakovo which is

25 indicated here, that is in a forested area as well, so it is possibly

Page 1045

1 easier to hide to the south than to the north, but it was shelling

2 also in the Carakavo area for those who fled to the forest.

3 That eventually led to a number of people seeking even further

4 to the southwest, to the

5 area marked as Ljubija.

6 Q. Did the residents of the area eventually return to the Hambarine

7 area

8 A. Yes, quite a number did return. It should be remembered, though, that

9 there had been ethnic cleansing going out outside of opstina

10 Prijedor, in opstina Bosanski Novi, to the west, that this, so some

11 people had come into opstina Prijedor and, essentially, come to

12 settle in this western/southern part of opstina Prijedor with people

13 who were Muslims or who were Croats as again in Bosanski Novi the

14 people who were ethnically cleansed were the non-Serbs.

15 Q. The residents who fled that initial shelling of Hambarine and the

16 invasion of troops, and then returned, did they eventually leave the

17 area again?

18 A. Yes, at a later stage they did.

19 Q. OK. We will come to that in the course of your testimony?

20 A. Yes, we will.

21 Q. You mentioned that after this initial attack on Hambarine on May 23rd

22 some of the residents fled to the Ljubija area which is also

23 depicted on the map?

24 A. That is correct. It is this area. It is actually divided in two

25 settlements. It is called Donja Ljubija and Gornja Ljubija; "donja"

Page 1046

1 is lower and "gornja" is upper.

2 Q. Were there weapons available in Ljubija at the TO headquarters?

3 A. Yes, there were.

4 Q. Did the residents of Hambarine who fled to the Ljubija area gather up

5 those weapons?

6 A. No, they did not.

7 Q. What happened to those weapons that were in the TO?

8 A. According to the Serb chronicles of what happened in Ljubija at this

9 time, the Serbs succeeded in taking hand of all these weapons

10 immediately before they ever been used.

11 MR. TIEGER: May I have this document marked for identification as Exhibit

12 105? (Document handed).

13 JUDGE STEPHEN: You raised my expectations; I thought you were going to

14 give each of us a coloured map, not so?

15 MR. TIEGER: I had the same hope, your Honour, but I understand, based on

16 discussions, we can scan that document this evening, and produce

17 colour copies from the printed.

18 JUDGE STEPHEN: Thank you very much.

19 MR. TIEGER (To the witness): Dr. Greve, what is Exhibit 105?

20 A. This exhibit is once again an article from Kozarski Vjesnik. It is

21 dated June 17th 1994, and it is a series of articles and it is set in

22 connection with May 22nd when Serbian rule was established in

23 Ljubija.

24 MR. TIEGER: We would tender that document for admission.

25 THE PRESIDING JUDGE: Any objection?

Page 1047

1 MR. ORIE: No objections, your Honour.

2 THE PRESIDING JUDGE: Exhibit 105 will be admitted.

3 MR. TIEGER (To the witness): Dr. Greve, can I ask you to look at the

4 second page of that document -- actually perhaps we had better place

5 it in context. Would you look at the first page? In the bottom of

6 the first paragraph, does it indicate what happened after the attack

7 on Hambarine?

8 A. Yes, it referred to the fact that mostly non-Serbian population lived

9 in the environs of Ljubija and they were well-armed. In Ljubija

10 itself, there was a Territorial Defence unit which had only three

11 Serbs. All the extremists from the left side of the Sana, that is

12 the river that flows on the left side of this area, hid in the woods

13 around Ljubija and in the wake of May 22nd, 1992 refugees started

14 pouring into town.

15 Q. Does the article go on to disclose what happened to the weapons in

16 Ljubija which were, according to the article, guarded by only three

17 Serbs -- if you could turn to page 2?

18 A. Yes, it does.

19 Q. Looking at the bottom of the page, does that indicate what happened

20 to those weapons?

21 A. Yes, it referred to the fact that the local leader of the Crisis

22 Committee, his name being Slobodan Taranjac, concludes that the only

23 real danger they, meaning the people in the Ljubija area, still faced

24 was from the Territorial Defence, because it was largely made up of

25 non-Serbs, and it is referring that as being yet another problem.

Page 1048

1 Q. Did the leader of the Serbian Territorial Defence find it necessary

2 to rest those weapons from the non-Serbs weapons of the TO with

3 force?

4 A. No, he decided it would be enough to resort to cunning behaviour.

5 Q. How were those weapons extracted from the TO?

6 A. Do you want me to have the third page of the article?

7 Q. Please.

8 A. The first paragraph on this page explains it. Do you want me to read

9 it?

10 Q. Certainly.

11 A. He is stating that they resorted to cunning: "I sent Krivi to tell

12 the Territorial Defence that we were being attacked by 150 green

13 berets; that Ivica Milosevic and his men had placed themselves under

14 my command and that we were defending Ljubija. About 30 minutes later

15 I sent Milo Gliga in his van to pick up the weapons from members of

16 the Territoria

17 Defence. He asked me how he was going to disarm them and I told him

18 they had already done it themselves, because they would not defend

19 Ljubija. Then Gliga arrived at Territorial Defence headquarters. He

20 found Krivi there alone with all the weapons. That is how we

21 eliminated yet another danger without firing a bullet."

22 Q. So, according to the article, Krivi walked in and took the weapons?

23 A. Yes, took care of the arms.

24 JUDGE STEPHEN: Would you look at page 1, there is a reference to a

25 military unit there, the commander of which told them, the 43rd

Page 1049

1 Brigade, not to open a front. What Brigade is that? What sort of

2 unit is that?

3 MR. TIEGER: If it helps your Honour, we will be submitting documentation

4 which indicates what the 43rd was and where it operated during this

5 period of time.

6 JUDGE STEPHEN: Thank you.

7 MR. TIEGER: Can we see the exhibit 82 again, please?

8 THE WITNESS: The article which we just saw on the screen there -- I

9 should perhaps have mentioned then -- also referred to 8,000 refugees

10 coming into the Ljubija area.

11 MR. TIEGER: Dr. Greve, the ethnic distribution indicates a large area

12 depicted in green representing a large concentration of the Muslim

13 population in the Hambarine area. Looking to the right, is there

14 also, or was there also, a large concentration of the Muslim

15 community of Prijedor in the Kozarac area?

16 A. Yes, there was the possibly largest concentration of Muslim people in

17 this area. The larger Kozarac area or the Potkozarac area, it is the

18 mountain of Kozarac which is up, that is why there are no Serbian

19 settlements up in the mountain.

20 Q. I believe you indicated this earlier, but approximately how many

21 people lived in that region?

22 A. In that larger area, including also down to Trnopolje and to

23 Kevljani, there would be approximately 27,000 people of non-Serbian

24 origin.

25 THE PRESIDING JUDGE: What region is this now?

Page 1050

1 A. This is the larger region of Kozarac, Kozarac being this location,

2 but it is often referred to as one larger area, the Kozarac area.

3 The mountain is called Kozara and it runs up the entire length.

4 Q. I thought you were talking about the entire Prijedor region opstina;

5 I understand now.

6 A. Excuse me, your Honour.


8 MR. TIEGER: Can we call up photos 5/0101 followed by 5/0102 and 03? (To

9 the witness): Dr. Greve, what does this depict?

10 A. To my understanding, this is a post card and it actually shows the

11 mosque in Kozarac.

12 Q. Next picture, please? What does this picture depict?

13 A. Again it is my understanding that it is another picture from Kozarac,

14 and it shows the Marsala Tito which is the main street which crosses

15 the two streets running Prijedor, Banja Luka, the old and the new

16 one.

17 Q. The next picture, please? Does this picture depict another shot of

18 Kozarac?

19 A. It does.

20 MR. TIEGER: Your Honour, I tender these for admission as Exhibit 106 and

21 we do so in the form of this single document.

22 MR. ORIE: No objection, your Honour.

23 THE PRESIDING JUDGE: 106 will be admitted.

24 MR. TIEGER (To the witness): Dr. Greve, what sort of town was Kozarac,

25 what did the people do primarily? How prosperous was it?

Page 1051

1 A. It was a prosperous area. It was located close to the mountain of

2 Kozara. It was an area which had sawmills and some timber

3 activities. It was an intersection, a cross-road. It was the access

4 road up to the main war memorial on the Kozara mountain, and a number

5 of people in this area had been working abroad as foreign workers and

6 had had some financial means to establish themselves with small

7 businesses, etc. So it was considered to be a prosperous area within

8 a, generally speaking, prosperous opstina Prijedor.

9 Q. After the armed takeover of opstina Prijedor, did the de facto

10 Serbian authorities make demands or ultimatums on the Kozarac

11 community?

12 A. Yes, they did. They did demand that the TO also in this area would

13 immediately pay respect, be subordinate to, the new authorities in

14 Srpska opstina Prijedor.

15 Q. Was there any demand made on police officials in Kozarac?

16 A. Yes, the same as on every police official in the opstina.

17 Q. Did negotiations take place between the representatives of Kozarac

18 community and the de facto authorities in Prijedor?

19 A. Yes.

20 Q. Were those negotiations successful?

21 A. Possibly the participants thought they were successful to a certain

22 degree and did expect them to go on but, as it all turned out, they

23 were not successful.

24 Q. Did the demand for a pledge of loyalty by the police and the TO to the

25 new Serbian authority continue?

Page 1052

1 A. Yes, it continued.

2 Q. Was there a demand for disarmament?

3 A. Yes.

4 Q. Did that continue to be made?

5 A. Yes.

6 Q. How well armed was the Kozarac community?

7 A. There were weapons with the police and there were weapons with the

8 Territorial Defence forces, and there were a number of Muslims who

9 had bought weapons if they could as they saw others being armed.

10 But, generally speaking, there was very limited arms as compared to

11 the arms available to the other side.

12 Q. Let me ask you one more question about the oath of loyalty that was

13 demanded by de facto Serbian leaders. That would be an oath to be

14 loyal to the new Serbian authority?

15 A. Yes, as being a party to this separate structure and separate

16 Republika Srpska.

17 Q. Would it mean that the people of Kozarac would no longer be part of

18 Bosnia-Herzegovina?

19 A. That would be so.

20 Q. After the demand for surrender of arms and after the demand for a

21 pledge of loyalty to the new officials, was Kozarac attacked?

22 A. Yes, it was.

23 Q. When did that begin?

24 A. It is my understanding that it started on 24th May.

25 Q. How did the attack on Kozarac begin, using what sort of military

Page 1053

1 force?

2 A. This time it was very heavy bombardment of the entire area. If we

3 can have again perhaps the map of -----

4 Q. Perhaps we could exact Exhibit 79, 2/35? If the court is looking on

5 the screen, it is a little difficult to read so perhaps you can

6 orientate us before you describe -----

7 A. This is Kozarac; this is the town of Prijedor; this is the

8 mountainous area behind; these are the main roads Prijedor, Banja

9 Luka; this is the fish farm, lake; yes, these are the basics that one

10 needs just at this point to have an understanding. When Kozarac was

11 attacked it is combined information from, well, actually all sources

12 will indicate that it was attacked and bombarded from several

13 different areas. Some were across -- or maybe I should start, there

14 are proper military installations, long-term military installations,

15 on the top of the

16 Mountain Kozara. There were several installations on this mountain

17 that were used to bombard Kozarac and nearby areas.

18 However, there were also installations, to my

19 understanding, placed somewhere in this area, the Kamen area, I

20 understand, from the other side of the fish farm or the lake, Topjka

21 Brdo and in some other areas here, Racelici, perhaps. That is that

22 the people in Kozarac felt as if they were bombarded from every side

23 at the same time and it was heavy bombardment with all kinds of heavy

24 artillery which was only available, or had only been available, to

25 the JNA.

Page 1054

1 Q. How long did that heavy bombardment continue?

2 A. The immediate heavy bombardment continued for about 24 hours.

3 Q. Then did it stop entirely?

4 A. Not entirely.

5 Q. Did it continue intermittently?

6 A. Yes.

7 Q. For approximately how long?

8 A. For approximately up to 12 hours, I believe.

9 Q. What did the residents of Kozarac do when the bombardment began?

10 A. Seek shelter, essentially, that is to say, some would immediately try

11 to find the best cellar in the area, their own house or a

12 neighbouring house; others would try to move towards the foot of the

13 mountain although they were being shelled from the top of the

14 mountain. This is as it is read out of the map, slightly hilly and

15 they probably thought it would be safe in some of these areas. But

16 as people moved up to the foot of the mountain the shelling also

17 focused on the foot of the mountain.

18 Q. After the shelling ceased, what happened militarily after the

19 shelling ceased?

20 A. Again, there was one co-ordinated operation where several units were

21 working together. It was ordinary military units with reserves and

22 paramilitaries and police and reserves, and some local Serbs -- this

23 was the time when about every adult male Serb was in uniform -- and

24 moving in from different directions on the roads would come tanks and

25 troops, and they would start attacking some of the different

Page 1055

1 localities.

2 Q. That happened to the residents of Kozarac after the troops moved in?

3 A. They were forced to leave their houses, their shelters and asked to

4 come out into the streets.

5 Q. Once they gathered in the streets, where were they taken?

6 A. They were taken to some points of, to where they were to be gathered

7 and concentrated. Those who were from the centre of Kozarac were

8 taken, essentially, in the direction of Kozarusa; some were also

9 taken down on this main road towards Trnopolje, as we will come back

10 to.

11 The people were then separated so that women with small

12 children up to 12, 15, and the elderly men, 60, 65 in this context,

13 would be one group and the male population between 12, 15 or 60, 65,

14 would be another group. A number of people were killed in the

15 process -- we will come back to that, I think -- but those who were

16 not killed were separated like this.

17 Q. Did the destruction of Kozarac end with the cessation of the

18 shelling?

19 A. No.

20 Q. Did you have an opportunity to see video footage taken by journalists

21 who visited the Prijedor area in the summer of 1992?

22 A. Yes, I did. I also spoke with some NGOs who were let into the area

23 when it was almost so-called cleansed of non-Serbs who travelled

24 through on the main road.

25 Q. Have you seen recent footage of the Kozarac area or footage recently

Page 1056

1 taken?

2 A. Yes, I have seen footage taken by the Prosecutor's office.

3 Q. Is that also the most comprehensive footage of the area which you

4 have seen?

5 A. Yes, it is.

6 Q. Does it include both sides of the street, of the main street, that

7 you showed us?

8 A. Yes, it does.

9 Q. Does it include portions of both the main highway and the old road

10 going in the direction both toward Omarska and toward Prijedor?

11 A. That is what I have been told and it corresponds to information I

12 have from other sources but I have not been there, but maybe I should

13 say that when the area had been cleansed and when it had been

14 bombarded or bombarded and cleansed, each and every property which

15 belonged to non-Serbs were, essentially, pillaged and then they were

16 blown up from inside. So all the damage that could be seen on this

17 footage is not due to the bombardment; it is also later activities.

18 MR. TIEGER: Your Honour, can we play video No. 5 at this time? Before we

19 start it, the video is a portion of the footage taken all of which

20 has been made available to the Defence. The extract is approximately

21 40 minutes long. It is not my intention to play the entire extract

22 to the court at this time. I am sure the court will be interested in

23 seeing it at

24 a time more convenient, but I will play a portion of that before we stop

25 the tape. I would like that marked for identification as 107

Page 1057

1 then.

2 THE PRESIDING JUDGE: Is there any objection to Prosecution 107?

3 MR. ORIE: No objection, your Honour.

4 THE PRESIDING JUDGE: 107 will be admitted.

5 (The video tape was played)

6 MR. TIEGER: Dr. Greve, this is the main street of Kozarac?

7 A. That is my understanding, yes.

8 Q. Is this the mosque depicted in the photograph we saw earlier?

9 A. That is also my understanding, yes.

10 Q. Has the vehicle from which this video was taken now left the main

11 portion of the town and proceeding up the road leading up to the

12 mountain?

13 A. Yes, that is my understanding.

14 Q. Dr. Greve, this section of the video is back down from the mountain

15 leading back to town?

16 A. That is my understanding, yes.

17 Q. That was the Prijedor Banja Luka highway where the video ended?

18 A. That is my understanding, yes.

19 MR. TIEGER: Can we stop the video, please? Your Honour, as I indicated,

20 the video which was just an extract from a longer video goes on for

21 approximately 45 minutes depicting similar scenes of destruction

22 along the old road on both sides leading in the direction of

23 Prijedor, on the Prijedor, Banja Luka highway on both sides leading

24 towards Prijedor on that same highway and going toward the Omarska

25 area and the old road going towards the Omarska area. There are just

Page 1058

1 two additional questions I want to ask Dr. Greve about that, and then

2 I will leave it to the court to review at its convenience.

3 (To the witness): Dr. Greve, does the video to your recollection depict

4 this Serbian orthodox church in Kozarac?

5 A. Yes, it does.

6 Q. Is the church damaged or destroyed?

7 A. No single sign of damage is shown in the video.

8 Q. Does the video also depict the Serbian village of Omarska?

9 A. Yes, it did.

10 Q. That can be shown at the end of the video. What is the condition of

11 Omarska village?

12 A. That is intact; it has not been destroyed.

13 Q. Dr. Greve, after the Muslims and Croats of the Kozarac area were

14 rounded up and segregated, where were the men of that area taken?

15 A. The men were taken to two camps that were opened, one in Prijedor

16 City, which is the one that is referred to as "Keraterm", and the

17 other one just to the south of Omarska village, and that is referred

18 to as "Omarska".

19 Q. Was there a third camp in the area?

20 A. Yes, there was a third camp in the area and that is actually the

21 railway station for Kozarac. It is also called Trnopolje.

22 Q. If we could call up 2/35-2 on the computer screen, and could we have

23 a zoom on the Omarska area in the upper right-hand corner? Dr.

24 Greve, does this exhibit depict the location of Omarska village?

25 A. This is the central of Omarska village, according to the map, yes.

Page 1059

1 Q. If we could hand back the original of the exhibit, please? First of

2 all, I would like to tender that map as No. 108.

3 THE PRESIDING JUDGE: Any objection?

4 MR. ORIE: No objection.

5 THE PRESIDING JUDGE: Exhibit 108 will be admitted.

6 MR. TIEGER: Do I need to request for that to be printed? Thank you. (To

7 the witness): Just to orientate us here, Dr. Greve, as I look up on

8 the top portion of the map to the left side, does that show a small

9 corner of the fish farm you referred to earlier?

10 A. Yes, it is this one -- should there be an arrow? I do not know how I

11 make this -----

12 Q. You may want to return, if necessary, I am just trying to orientate

13 us according to the map we saw earlier that showed Prijedor and

14 Omarska which is Exhibit 79.

15 A. Here we see the village of Omarska which is linked again through to

16 the railroad that leads the whole way up to Prijedor, and we see the

17 lake, the fish farm, here.

18 Q. Is the location of the camp that was established in the Omarska area

19 depicted on this map?

20 A. To my understanding, it is not. It is two kilometres south of

21 Omarska village, and the scale of this map is that every square is

22 500 metre by 500 metre, so it is two kilometres to the south,

23 slightly to the west of Omarska city, I understand, or village.

24 Q. Is it located near any physical landmark?

25 A. Yes, it is located close to an open pit mine and there is an

Page 1060

1 extension of the iron ore mine, the Omarska extension of that mine.

2 Q. OK. If we return to Exhibit 108 -- let me ask you this question

3 first. The iron ore mine, I take it, that is located next to or in

4 the vicinity of iron ore or iron ore pits. Are those shown on the

5 map?

6 A. Yes, they are. I see that by accident I placed an arrow on the map,

7 that was just my ignorance, but if I can move this, there are open

8 pit mines in this area here. I may remind for convenience that this

9 is the second largest iron ore mine in Europe so it is quite a large

10 mine.

11 Q. The portion of the mine that was turned into a camp, what did that

12 consist of?

13 A. It consisted of an administrative area and a huge garage or, rather,

14 it was almost like a hangar. The compound as such had actually five

15 buildings; the one administrative building in which there was a

16 canteen and the first floor with offices; this huge garage which was

17 for maintenance of the heavy equipment used in the mine; a seemingly

18 a tiny little building which was the "white house" and then there was

19 another small building called the "red house" and a small pump

20 station.

21 Q. Who operated the camp?

22 A. It was called a military investigation centre. It was run in

23 co-operation between the police and the military, that is, the

24 Serbian police.

25 Q. Were only men taken to Omarska camp?

Page 1061

1 A. Primarily men, but there were 36, 37, 38 women in the camp.

2 Q. What age groups were taken to the camp?

3 A. This was with reference to women or with reference to the male?

4 Q. The overall population. Let us start with men.

5 A. The men were those between 12, 15 and 60, 65, essentially.

6 Q. When did Omarska begin to function as a detention camp?

7 A. It is referred to by the Serbs themselves as having operated from

8 25th May.

9 Q. Approximately how many people were held there at any given time?

10 A. The numbers have varied. I think it had an absolute maximum

11 capacity, somewhere about 3,000, 3300 perhaps.

12 Q. I would like to ask you some questions about the general conditions

13 of the camp, and the general conditions in which the prisoners there

14 were held. First of all, let me ask you about into what spaces the

15 prisoners were put, how much space was there for the prisoners who

16 were placed in areas or rooms of the former mine complex?

17 A.This varied over time but, initially,people were extremely cramped and,

18 that is to say, it is described as if they were sardines in a tin.

19 They would have to stand. They could not turn around and they would

20 stand like this for a few days.

21 Q. Were the prisoners provided with any bedding or blankets?

22 A. They were provided with nothing in terms of bedding and blankets.

23 Q. So they sat or slept on bare floors?

24 A. That is correct.

25 Q. How much food did the prisoners get?

Page 1062

1 A. They got food once a day, one-eighth of a bread is what they referred

2 to, and a ladle full of some soup-like fluid and possibly with some

3 cabbage or macaroni in it and some water.

4 Q. Was this a diet sufficient to sustain a person?

5 A. No, it was not.

6 Q. Were prisoners fed immediately upon arrival?

7 A. No, they would frequently face a period of three, four, five days

8 when they were only cramped in with no water and no food.

9 Q. How long did the camp operate, through portions of the summer of '92?

10 A. Yes, it was actually closed 5th/6th August, essentially, 1992.

11 Q. Is the summer hot in the Prijedor area?

12 A. The summer is said to be very hot in the Prijedor area, yes.

13 Q. How much water was available to the prisoners and what was the

14 quality of that water?

15 A. It was not pure water; it was water generally available in the mine

16 and it was very limited water made available to them. So all water

17 they had, essentially, went for drinking and no cleaning purposes.

18 Q. What about facilities for personal hygiene; were they provided?

19 A. There were very few such facilities. There were a few toilets which

20 were not sufficient.

21 Q. How did prisoners attend to their personal needs in that regard?

22 A. They would, essentially, be showed to the field.

23 Q. Could the prisoners leave their rooms when they needed to and use

24 whatever facilities were available for that purpose?

25 A. They could not.

Page 1063

1 Q. Over time did the prisoners begin to suffer from medical conditions?

2 A. Yes, they did; malnutrition, diarrhoea, lice, very soon different

3 diseases became rife, particularly it was very difficult to disinfect

4 any wound.

5 Q. Was regular medical care provided?

6 A. There was no regular medical care or medical care to any degree.

7 There were some prisoners who were doctors and they tended to fellow

8 prisoners if they could, but, essentially, with no implements, no

9 medicine, no disinfectant.

10 Q. Were interrogations conducted in the camp?

11 A. Yes, they were. I think that is also indicated by the main

12 intelligence centre.

13 THE PRESIDING JUDGE: Indicated by the main?

14 MR. TIEGER: I am sorry, could you repeat that? I think you were not

15 heard.

16 A. I mean, this was a military investigation centre, so if

17 investigations are carried out, it in a sense followed from that they

18 were likely to want to do some kind of question.

19 MR. TIEGER: In that connection, could I have Exhibit 92 presented to the

20 witness? (To the witness): Were interrogations conducted at all

21 three camps?

22 A. Yes, they were, but the tougher interrogations were in Omarska and

23 Keraterm where the men were held. I may just add, that some men

24 ended up in Keraterm, sorry, in Trnopolje, but it seems that was if

25 an individual Serb would help them, or if there were so cramped

Page 1064

1 conditions they could not possibly be put into one of the two other

2 camps. So, in principle, the males were taken to Keraterm and

3 Omarska.

4 Q. Did the Serbian officials have a designation or name for the

5 interrogations?

6 A. Yes, they referred to them as "informative talks".

7 Q. Was that in conversations with journalists and people from outside?

8 A. Yes, and in conversations with journalists and aid personnel and in

9 their own newspaper articles.

10 Q. Do we have an indication, according to the Serbian officials, at any

11 rate, how many informative talks were conducted in the camps in the

12 summer of 92?

13 A. According to Simo Drljaca, the head of the Serbian police, 6,000 such

14 talks were held in these camps.

15 Q. Can I ask you to display Exhibit 92 on the monitor looking at the

16 second paragraph from the bottom, the first sentence? That is an

17 interview with Simo Drljac?

18 A. That is again, yes, the one interview he gave when he had been

19 appointed to be Vice Minister.

20 Q. Indicating that more than 6,000 informative talks were held at the

21 three camps?

22 A. That is correct.

23 Q. He was the Chief of Police at this time ---

24 A. Yes, he was.

25 Q. -- at the time the camps were in operation?

Page 1065

1 A. Yes, for the entire length of that.

2 Q. Who was it that actually conducted the interrogations or informative

3 talks?

4 A. It was interrogators coming from outside and most of them belonged to

5 the police, but they would have people with them who would also be

6 army related personnel. It is said as being a military centre, but

7 some of the investigators, that is, came from the public security

8 office, the office of the police.

9 Q. In what manner were the interrogations conducted?

10 A. In very brutal manners.

11 JUDGE VOHRAH: Dr. Greve, could you speak a bit louder because I have

12 difficulty hearing. I believe Mr. Orie too has difficulty hearing.

13 A. I really apologise because ......

14 MR. TIEGER: I am sorry. I will repeat the question, your Honour. (To

15 the witness): In what manner were these interrogations conducted,

16 Dr. Greve?

17 A. In very brutal manner.

18 Q. Were prisoners beaten?

19 A. They were severely beaten.

20 Q. Were they tortured?

21 A. Many were severely tortured.

22 Q. Were the statements extracted from the prisoners during these

23 informative talks later used to justify both their imprisonment and

24 the cleansing of Prijedor?

25 A. Yes, they were.

Page 1066

1 Q. In that regard, can I ask you to look at Exhibit 91, to be presented

2 to the witness? Can page 2, the second full paragraph, be displayed

3 on the monitor? Dr. Greve, this issue of Kozarski Vjesnik contains

4 an account of how the first Chairman of the Serbian Municipal

5 Assembly of Prijedor, Dr. Milomir Stakic, saw the events?

6 A. That is correct.

7 Q. In that first sentence of the second paragraph does he indicate what

8 happened after the prisoners were taken into custody?

9 A. Yes, he is indicating that enough information was gathered from them

10 to conclude that the Muslims were very well organised and determined

11 to liquidate their fellow citizens, the Serbs.

12 Q. So after the prisoners were taken into custody, that information was

13 gathered, according to Mr. Stakic?

14 A. That is correct.

15 Q. Looking three sentences past that in the sentence which begins, "From

16 the interrogation records ... "?

17 A. It is claimed that they learned, the Serbs learned, that they,

18 meaning the non-Serbs, had intended to simultaneously take over power

19 and seize the barracks and with it the arms.

20 Q. What else was learned during those interrogation sessions, according

21 to Mr. Stakic?

22 A. Worst of all, according to him, the Serbs found out that the Muslims

23 had a detailed plan for the liquidation of the Serbian population of

24 Prijedor.

25 Q. So the interrogation records extracted from prisoners during these

Page 1067

1 brutal interrogations then produced the information that Mr. Stakic

2 was talking about?

3 A. That is my understanding.

4 Q. In addition to beatings during interrogation, Dr. Greve, were

5 prisoners subjected to physical abuse at other times?

6 A. Yes, they were. They were subjected to physical abuse when they went

7 to the canteen to get their food, when they could be beaten at any

8 one time, to the extent that prisoners, although they needed the food

9 badly, had to consider whether they were in a shape to go to fetch

10 their food.

11 Similarly, if they needed to relieve themselves, they had

12 to consider if it was safe to do that considering who were the guards

13 on duty because they were also subjected to beatings on such

14 occasions. A number of prisoners who at night-time slept in the

15 canteen would stay outdoor. It is called a pista. It is a concrete

16 platform between the administrative building and a huge garage. When

17 they were staying there, they could also be randomly subjected to

18 ill-treatment. Particularly at night-time, people would come to

19 where the prisoners were kept and ask for a few names and take them

20 out.

21 Q. This was just regular shift guards who subjected prisoners to such

22 beatings?

23 A. No. There were people from inside and outside the camp, police,

24 military, paramilitary, locals.

25 Q. Were any particular type of people, people from any particular

Page 1068

1 segment of society, more at risk in Omarksa than others?

2 A. Yes, for (1) it seems to have been the tendency that in Omarska the

3 upper echelons or the elite of the non-Serbian community was gathered

4 and, particularly, the elite, meaning people who held important

5 positions in the community, politicians and leaders, everything from

6 people who were good football players and onwards would be

7 particularly subjected to ill-treatment.

8 Q. Were any particular parts of the camp more dangerous for prisoners

9 than others?

10 A. The by far most dangerous part of the camp was the seemingly small

11 white house.

12 Q. What happened in the white house that made it more dangerous or were

13 special people put in the white house?

14 A. Well, people were frequently put in the white house upon

15 interrogation, if they had survived the interrogation, and they were

16 subjected to possibly the most extreme of the ill-treatment.

17 Q. What treatment were the women who were held in Omarska subjected to?

18 A. On one level they had better conditions than the male population.

19 However, for them the main problem was rapes at night-time, and it

20 happened almost all the time, it is being reported.

21 Q. Dr. Greve, were prisoners killed in Omarska?

22 A. Yes, a number of prisoners were killed in Omarska. It is difficult

23 to establish the exact numbers, but the fact that, according to Serb

24 officials, there were no large scale releases and considering the

25 numbers who were taken to the camp, it must have been a substantial

Page 1069

1 number.

2 Q. By "substantial" do you mean dozens, tens?

3 A. I would rather suggest thousand or more, but I am not in a position

4 to establish numbers.

5 Q. Were these killings of prisoners secret ---

6 A. No.

7 Q. -- kept by the prisoners?

8 A. No, they were not secret, that is to say, interrogation took place in

9 closed offices and the white house had closed doors and was a

10 compound on its own. However, dead prisoners would be left outside

11 so that other prisoners going to relieve themselves, going to fetch

12 their food or staying on the pista, that is, the concrete platform in

13 day time, would be able to see them.

14 Q. Was the camp a secret? Did local Serbian leaders know about it or

15 not know about it?

16 A. Yes, it was no secret.

17 Q. Did they ever visit the camp?

18 A. Yes, some of them did visit the camp.

19 Q. What about Simo Drljaca, the chief of police?

20 A. Yes, he did visit the camp.

21 Q. Did Serbian officials from outside opstina Prijedor visit the camp?

22 A. Yes, they did from Banja Luka. It is also my understanding that

23 Radio Televizija Banja Luka came to the camp.

24 Q. What about the ICRC or humanitarian organisations, were they able to

25 visit and inspect the camp during its operation?

Page 1070

1 A. As long as Omarska was operated this way that is being described now,

2 they never visited the camp. When it was being closed down and given

3 beautification or shined up for foreign journalists to come in, also

4 ICRC was entitled to come to the camp.

5 Q. When was the camp closed or when did it begin to close?

6 A. There was an article in the American press, 2nd August, and

7 subsequent to that it was an immediate effort made to close the

8 camp, transfer prisoners. It was basically closed on 5th and 6th

9 August 1992.

10 Q. When the camp's existence was made known to the western world, did

11 journalists try to enter the camp?

12 A. Immediately, yes.

13 Q. Were some journalists able to enter the camp around the time period

14 you have just mentioned?

15 A. Yes, but only after the main group of prisoners had been removed and

16 a lot of clean up had been made and then only to a very limited area

17 of the camp -- essentially the canteen.

18 Q. Were the majority of prisoners from Omarska transferred at that time,

19 end of the first week of August?

20 A. Yes, the vast majority or possibly they were left 100 or some more

21 than 100 but .....

22 Q. Where were they taken?

23 A. The majority was most probably taken to Manjaca. Manjaca is a camp

24 which is located in opstina Banja Luka, to my understanding. I have

25 not focused much on that particular camp, but it has been referred to

Page 1071

1 by the Serb authorities. But also maybe more than 1,000 were taken to

2 Trnopolje which was kept open after the time when Omarska was closed.

3 Q. Although I appreciate that you have not focused on Manjaca

4 extensively, do you know whether or not conditions in Manjaca were

5 the same as in Omarska?

6 A. It was far better. It was not that dangerous. It was the likelihood

7 of survival.

8 Q. Did some prisoners remain behind in Omarska after the majority of

9 prisoners were transferred?

10 A. Yes, as the camp was being showed to the international media, they

11 were the ones to be paraded.

12 Q. Were they responsible for cleaning up the camp and making it as

13 presentable as possible when the media came?

14 A. Yes, these men who were left behind, and also the women before they

15 were transferred, were asked to do some of the cleaning. Three women

16 were left behind initially, but when the press came it was denied

17 that there were any women in the camp and they had been taken out in

18 a car to Omarska at the time.

19 Q. Were Serbian officials connected with the operation of the camp

20 questioned about the nature of the camp after the journalists

21 discovered it?

22 A. Oh, yes, they were.

23 Q. Were they questioned, in particular, about whether or not prisoners

24 had been beaten or killed?

25 A. Yes, they were questioned about this.

Page 1072

1 THE PRESIDING JUDGE: When did you testify that you believed journalists

2 learned about the camp? You said that it was closed in August,

3 August 4th or 5th, I believe, 1992, and that would have been shortly

4 after they learned. So when do you believe that they first learned

5 about the camp and came to the camp?

6 A. The first article written about the issue which was well-known was

7 Roy Gutman's article published in Newsday, I believe, in the United

8 States, 2nd August 1992. Then things happened very, very quickly

9 because prior to that it had been alleged that camps existed, and now

10 pressure was put on Radovan Karadzic to let journalists into the

11 specific locations in Prijedor. So it happened very, very quickly, I

12 understand.

13 MR. TIEGER: May I have this marked for identification as Exhibit 109,

14 please? (To the witness): Dr. Greve, what is Exhibit 109?

15 A. This is a transcript from an interview where Stakic is making

16 statements concerning, inter alia, Omarska.

17 Q. I tender that for admission.

18 THE PRESIDING JUDGE: Any objection?

19 MR. ORIE: No objection, your Honour.

20 THE PRESIDING JUDGE: Exhibit 109 will be admitted.

21 MR. TIEGER: May that be displayed on the monitor, please?

22 (To the witness): First of all, does Milomir Stakic indicate at whose

23 direction or upon whose decision the camps were set up? I would

24 direct your -----

25 A. Yes, he does. In the second paragraph he is saying that this was

Page 1073

1 done at the decision -- on the decision of the Prijedor Civil

2 Authorities.

3 Q. Was Milomir Stakic asked about beatings in Omarska?

4 A. Yes he was.

5 Q. What did he say?

6 A. He is saying that, according to the information, there was no

7 maltreatment and physical violence in the centres themselves.

8 Q. Was he confronted about reports of killing in Omarska?

9 A. He was, and said, "There were cases, as the Commander in charge let

10 me know, of death which all have medical documentation which

11 testifies to that and not to murder".

12 Q. Does he indicate that he is referring to Omarska?

13 A. Yes, he does. He is particularly asked if this was in Omarska and he

14 confirms that.

15 Q. Does he say that in any event the number of prisoners who died of

16 natural causes was small?

17 A. Yes, he said that he is unable to say exactly, but it was not a large

18 number. He is asked again if it was not many people and he says, no.

19 Q. Was this denial of beatings in Omarska always consistently

20 maintained by the de facto officials of opstina Prijedor?

21 A. No.

22 Q. May I have this marked as Exhibit 110 for identification? (Document

23 handed). What is Exhibit 110, Dr. Greve?

24 A. It is again a transcript from an interview this time with Kovacevic.

25 Q. A member of Krizni Stab?

Page 1074

1 A. Yes, he was.

2 Q. And a member of the SDS?

3 A. Yes, he was or may still be, I do not know.

4 Q. In this interview is he also asked by Omarska and physical

5 mistreatment in Omarska?

6 A. Yes, he is.

7 MR. TIEGER: I tender that for admission, your Honour.

8 THE PRESIDING JUDGE: Any objection?

9 MR. ORIE: No objection.

10 THE PRESIDING JUDGE: Exhibit 110 will be admitted.

11 Mr. Tieger, you asked Dr. Greve if he was a member of

12 what? Chris?

13 MR. TIEGER: Krizni Stab or Crisis Staff.

14 THE WITNESS: That brings to mind that we have, perhaps, not focused on

15 the establishment of the Krizni Stab. I think we left that out. If

16 your Honours would like, I am happy to briefly describe that.

17 MR. TIEGER: It may be more convenient to finish this section of the

18 examination and pick it up after the break.

19 THE PRESIDING JUDGE: That is fine.

20 MR. TIEGER (To the witness): Can we focus on the bottom part of the page?

21 Is Mr. Kovacevic asked about the situation in Omarska and

22 investigations of Omarska?

23 A. Yes, he does.

24 Q. OK. Is he confronted by a reporter who was told that some men had

25 been investigated because of Omarska, some prison guards?

Page 1075

1 A. Yes.

2 Q. How does he respond to that?

3 A. He is saying that there were some mistakes. He accepts that some

4 mistakes have been discovered, and then he moves on to say that war

5 is war and some people got drunk, and then he is being interrupted by

6 the interpreter. And "Of course, we condemn it and we are working to

7 solve it. Some of the men have been imprisoned already".

8 Q. Does the reporter press on to find out how many people have been

9 imprisoned for mistakes in Omarska?

10 A. Yes.

11 Q. What does Kovacevic tell him on page 2 of that document?

12 A. He is saying that this is not his field of work. His field is

13 economy, and he does not know how many they are, but they do exist,

14 according to him.

15 Q. Was Mr. Kovacevic interviewed on another occasion about Omarska?

16 A. Yes, he is -- I think on many other occasions than this one.

17 MR. TIEGER: May I have this document marked as Exhibit 111 for

18 identification? (Document handed) (To the witness): What is

19 document 111, Dr. Greve?

20 A. It is again an interview where Mr. Kovacevic is answering questions.

21 Q. Is he answering questions about Omarska?

22 A. Yes, he is.

23 MR. TIEGER: I tender that for admission, your Honour.

24 THE PRESIDING JUDGE: Any objection?

25 MR. ORIE: No objection, your Honour.

Page 1076

1 THE PRESIDING JUDGE: Exhibit 111 will be admitted.

2 MR. TIEGER (To the witness): In this interview Mr. Kovacevic is asked

3 about how many people died on the Serbian side and how many on the

4 Muslim side?

5 A. That is correct.

6 Q. What is it that he starts talking about at that point?

7 A. At this point he makes a reference to Jasenovac which was mentioned

8 yesterday as being the most notorious of the death camps during World

9 War II located in Croatia. Here a comparison is made with Auschwitz.

10 Q. Does he indicate that it is impossible to know even at this late date

11 exactly how many people, Serbs in that case, were murdered in

12 Jasenovac?

13 A. Yes, he is indicating that even after 50 years they are still unable

14 to say how many people were killed in Jasenovac.

15 Q. In the question of how many people were killed, in this interview,

16 does Mr. Kovacevic spontaneously raise the issue of the deaths camps

17 to explain why it is so difficult to approximate numbers or estimate

18 numbers?

19 A. Yes, it is his comparison.

20 MR. TIEGER: We are just about to show the video, your Honour, but it is

21 all three clips, it will probably consume about 10 minutes.

22 THE PRESIDING JUDGE: Then we will stand in recess for 20 minutes, please.

23 (4.00 p.m.)

24 (Short Adjournment)

25 (4.20 p.m.)

Page 1077


2 MR. TIEGER: Thank you, your Honour. Just before the recess we were about

3 to play the video clips from which the transcripts were taken.

4 Before that is played, can we give the court three copies of those

5 transcript exhibits? (Documents handed) Your Honour, are they

6 marked by an exhibit number?

7 THE PRESIDING JUDGE: At the top upper right-hand corner they have your

8 numbering, I think, whatever, 4/227. I see. I have Exhibit 110, 111

9 and then a page with nothing, 109.

10 MR. TIEGER: There were stickers on them before. The order should be a

11 one page interview with Stakic, a two-page interview with Kovacevic

12 and then a small, single paragraph or a brief interview with

13 Kovacevic again. Can we then show tape clips 2, 3 and 4?

14 (Tape clips 2, 3 and 4 were played).

15 Can you play No. 4, please?

16 Thank you. Your Honour, I tender document the video as

17 No. 112 in evidence.

18 THE PRESIDING JUDGE: Any objection to 112?

19 MR. ORIE: No objections, your Honour.

20 THE PRESIDING JUDGE: Exhibit 112 will be admitted.

21 MR. TIEGER (To the witness): Dr. Greve, you mentioned that some of the

22 Serbian officials we saw were members of the Crisis Staff. Could you

23 tell the court whether or not the Crisis Staff was an organ of the de

24 facto Serbian government in opstina Prijedor?

25 A. Yes, in opstina, in Srpska opstina Prijedor, the Crisis Staff was

Page 1078

1 sort of the Crisis Headquarters. It was composed of the leading

2 military people, the head of the police and the leading members of

3 the SDA, in addition, one of the directors of the mine, key people,

4 that is, from different aspects of society to make it possible to

5 co-operate closely.

6 Q. Dr. Greve, you mentioned that those persons who were rounded up after

7 the attack on Kozarac were sent to Omarska, Keraterm and Trnpolje

8 depending upon sex and perhaps other factors. Where was Keraterm

9 located?

10 A. Keraterm is located within the town of Prijedor. It is within the

11 vicinity of the town centre. It is this former ceramic tiles

12 factory.

13 Q. Perhaps you could show us on Exhibit 79?

14 A. This is the clay -- it is called on the map "clay production plant".

15 It is located here, in the main buildings here.

16 Q. Was it established and run by the same authorities who established

17 and operated Omarska camp?

18 A. That is my understanding, yes.

19 Q. Approximately how many Muslims or Croats or non-Serbs were held in

20 Keraterm plant at any given time?

21 A. At a maximum, approximately 1,500. May I also say that there were the

22 occasional Serb who was taken to Omarska and Keraterm if they tried

23 specifically to assist their non-Serbian fellows.

24 Q. Were the conditions in Keraterm camp, the crowding, the lack of food

25 and absence of hygiene and sanitary facilities, similar to those you

Page 1079

1 have described briefly in Omarska?

2 A. More or less the same, yes.

3 Q. Were prisoners also beaten and killed in Keraterm?

4 A. They were.

5 Q. Were there any incidents in which particularly large numbers of

6 prisoners were killed at any one time?

7 A. Yes, there was one particular incident. In this camp, it is one main

8 building and there are different halls, one called hall No. 3. The

9 night between 25th and 26th of July, it is believed that at least 150

10 people were machine gunned down in the night, and when their dead

11 bodies were removed, the wounded were taken out with the dead, and

12 possibly it could have been numbers like 60 or 80 wounded among them.

13 That is indicated on -- I am not exactly sure of the numbers, but

14 this was an event which was given much attention. It was considered

15 a massacre. I would like to draw your attention to the fact that

16 there is the main road running just by this camp, so actually people

17 could see from the main road, look into, not the inside of the camp,

18 but at least the camp compound, and roads were blocked following this

19 incident as the cleaning up was taking place.

20 Q. Were other prisoners who were killed in Keraterm murdered by bullet

21 in the same way or were there other forms of killing?

22 A. I think that the rest of those killed were mainly killed by beatings

23 or stabbings or a combination of this, not so much by bullets.

24 Q. Can you show us where Trnopolje camp is located, please?

25 A. Actually, on this map Trnopolje is not listed by name, but as Stanica

Page 1080

1 Kozarac, that is to say, the station of Kozarac, but it is also --

2 the village of Trnopolje, it is also located here.

3 Q. Was Trnopolje camp run by the same authorities whom you referred to

4 earlier?

5 A. Essentially, yes, but also the by then Serbian local Red Cross played

6 an important role in running of this camp.

7 Q. Who was the head of Trnopolje camp?

8 A. It is the man previously referred to as head of the TO, SDS member,

9 Slobodan Kurozovic.

10 Q. That is the man who later was placed in charge of some aspect of

11 Kozarski Vjesnik?

12 A. That is correct.

13 Q. Did the function of Trnopolje camp differ in any way from that of

14 Omarska and Keraterm?

15 A. Yes, it did; its main function was to be a staging area for

16 deportations,so in this respect it is conveniently located next to

17 the railroad station.

18 Q. Who was held in Trnopolje camp?

19 A. This was what briefly may be called the women's group with the

20 children and the elderly men.

21 Q. In general, how were conditions in Trnopolje compared to Omarska and

22 Keraterm?

23 A. Much, much, much better. But still it was a concentration camp and

24 there were many difficulties.

25 Q. Was there physical abuse of prisoners from Trnopolje?

Page 1081

1 A. Yes, there was.

2 Q. Of what type?

3 A. Again, beatings, some arbitrary killings and for the women rape was

4 the perhaps most important problem.

5 Q. Can you return to Omarska and Keraterm camps for a moment? Is there

6 any indication what was intended for the prisoners of Omarska and

7 Keraterm had the international press not discovered and exposed those

8 camps?

9 A. Yes, I think it is indicated well by the head of police, Simo

10 Drljaca, once again in the interview he gave, because at that time in

11 April of 1993 he is indicating that it was only due to pressure from

12 the western world that those whom he labelled extremists,

13 fundamentalists, etc. did not got their right punishment, indicated

14 that would be the most severe punishment possible, or existing.

15 Q. Can I direct your attention to Exhibit 92, please? Looking at the

16 second to last paragraph -- first of all, is this an interview with

17 Simo Drljaca?

18 A. That is correct.

19 Q. Does he indicate in his interview that more than 1500 Muslims and

20 Croats had been proven through proper documentation to have actively

21 participated in conflicts against the army of the Serb Republic?

22 A. That is correct.

23 Q. In the context of this article and other statements from Serbian

24 officials, does that proper documentation refer to the

25 interrogations, the "informative talks"?

Page 1082

1 A. Yes, it does. It is also listed two lines above.

2 Q. Based on those "informative talks" and the information extracted from

3 them, what other crimes were these 1500 Muslims and Croats believed

4 to be guilty of by Simo Drljaca?

5 A. Participating in the genocide of the Serb people.

6 Q. Does he complain that Serb officials were not permitted to impose

7 just punishment on those Muslims and Croats who had been proven to

8 have participated in genocide?

9 A. I read the last sentence to state that, yes. The last sentence in

10 the paragraph, that is, "Instead of receiving their just punishment,

11 the white world mighty men forced us to release them all from

12 Manjaca".

13 Q. Thank you. By the time the camp was discovered and prisoners were

14 transferred to Manjaca and Trnopolje from Omarska, what were their

15 physical states by that time, in general?

16 A. People had lost considerable weight. As we will come back to, there

17 were two main occasions on which males were brought to Omarska and

18 Keraterm. It was after the attack on the Kozarac area and the

19 immediate following attack on Prijedor town, and it was in late July,

20 after 20th July, when the Ljubija area became surrounded and attacked

21 and ethnically cleansed, so-called. That is, some people had been in

22 the camps since late May/early June and many of them had lost weight,

23 20 or 30 kilos, or even more.

24 MR. TIEGER: I would like to tender a photograph for admission which has

25 been presented to the Defence. It is No. 113. It is photo 5/1/04.

Page 1083

1 MR. ORIE: No objections, your Honour.

2 THE PRESIDING JUDGE: Exhibit 113, there is no objection to Exhibit 113?

3 That will be admitted.

4 MR. TIEGER: Can that be displayed on the elmo, please?

5 (To the witness): Dr. Greve, is that a photo of a prisoner who had

6 recently been released from Omarska by the time the photo was taken?

7 A. I do not know if it is correct to say "released". He had been

8 transferred to Trnopolje but he had been a detainee of Omarska.

9 Q. This depicts his condition immediately or shortly after his transfer

10 from Omarska?

11 A. That is correct.

12 Q. I had asked you about the difference in the primary function of the

13 camps in Omarska, Keraterm and Trnopolje. You indicated that

14 Trnopolje camp served the function of

15 deportation centre as well. What happened to the majority of the

16 prisoners who were held at the Trnopolje camp?

17 A. The majority were deported out from opstina Srpska, opstina Prijedor.

18 Q. Through what means were they deported?

19 A. I am not able to say if the majority were deported by rail or road,

20 but these were the two main used. It is reported that up to 25

21 cattle wagons at a time would be placed at the railway station in

22 Banja Luka when in transit. So at least a large number did leave by

23 rail and, essentially, by cattle wagons -- like it was used during

24 deportations in World War II in Europe.

25 THE WITNESS: May I have this marked for identification as Exhibit 114?

Page 1084

1 (Document handed). (To the witness): Dr. Greve, what is this

2 document?

3 A. This is a communication to the press by the International Committee

4 of the Red Cross. It is dated 2nd October 1992.

5 MR. TIEGER: I tender document 114 for admission.

6 THE PRESIDING JUDGE: Any objection?

7 MR. ORIE: No objection, your Honour.

8 THE PRESIDING JUDGE: Exhibit 114 will be admitted.

9 MR. TIEGER (To the witness): Dr. Greve, does Exhibit 114 reflect one of

10 the evacuations of prisoners from Trnopolje camp?

11 A. Yes, and now we have moved on in time, that is to say, that this is

12 an evacuation; it is not a deportation. This is the time when the

13 International Committee of the Red Cross has been granted access to

14 some camps, including Trnopolje, and they are asking to be entitled

15 to evacuate people out, among them a number of those who had been

16 released also from previously from Omarska and Keraterm.

17 Q. Was the release of prisoners from Trnopolje either by deportation in

18 the earlier stage or by evacuation once the ICRC conditioned on the

19 relinquishment of anything by the prisoners?

20 A. Yes, they had to sign a special document where they relinquished all

21 their material goods, moreover agreed not to return to Srpska opstina

22 Prijedor.

23 MR. TIEGER: May I have this document marked as 115 for identification?

24 (Document handed). (To the witness): What is that document, Dr.

25 Greve?

Page 1085

1 A. It is a quote of article 11 from an agreement on the release and

2 transfer of prisoners which was made on 1st October 1992. The quote

3 as such was included in my study, but it is taken, I had at that time

4 the original agreement -- that is a photocopy of the original

5 agreement -- at hand.

6 MR. TIEGER: We tender document 115 for admission.

7 THE PRESIDING JUDGE: Any objection?

8 MR. ORIE: No objection, your Honour.

9 THE PRESIDING JUDGE: 115 will be admitted.

10 MR. ORIE: We have difficulties in keeping track of the -- would there be

11 a copy available for us because we cannot trace this exhibit at this

12 moment? (Document handed) Thank you, your Honour.

13 THE PRESIDING JUDGE: No objection to 115?

14 MR. ORIE: Still no objection, your Honour.

15 THE PRESIDING JUDGE: It is still admitted then.

16 MR. TIEGER (To the witness): Dr. Greve, referring to 115, Article 11 is

17 an agreement reached with which parties?

18 A. It is suggested and proposed by the International Committee of the

19 Red Cross. It is entered into and signed by the different parties

20 participating in the conflict in Bosnia-Herzegovina. That is also a

21 representative of Radovan Karadzic.

22 Q. Does Article 11 reflect an understanding by ICRC officials that the

23 release of prisoners from Trnopolje camp was dependent upon their

24 giving up property voluntarily, and any right of return voluntarily?

25 A. I do not know whether the understanding of the ICRC is linked to what

Page 1086

1 they had experienced by then in Trnpolje or if it is based on their

2 general understanding of what was happening, because it was a

3 practice which we have come across, the Commission of experts came

4 across, all over Bosnia-Herzegovina where areas were ethnically

5 cleansed. Possibly the ICRC could build on information from any one

6 area in this respect. But it speaks to the fact that ICRC was aware

7 that two categories of people, prisoners who were to be released or

8 transferred and civilians, would be asked to sign this kind of

9 document.

10 Q. OK, so this practice was not limited to Trnopolje camp?

11 A. No, it was not.

12 Q. Article 11 reflects a general understanding of the use of that

13 practice in camps throughout Bosnia

14 A. At least it reflects this as being a widespread problem and it

15 is general in the way it is made, yes.

16 Q. Did prisoners in Trnopolje execute such documents in order to be

17 released?

18 A. Yes, and they were also advised to do so by ICRC because it was a

19 precondition for leaving, so the International Committee of the Red

20 Cross actually advised people to sign in order to get out.

21 Q. Did all of those who were deported from Trnopolje during its

22 operation for the ICRC intervention make it to safety after they left

23 the camp?

24 A. No, they did not. There were two main obstacles. It was the

25 conditions during transportation, the lack of fresh air, water and

Page 1087

1 food, it could take some days, and the least healthy ones would not

2 always make it, babies, elderly people. At the end of the transport,

3 the deportees would normally be asked to continue walking and

4 frequently they would have to cross the frontline which was mined and

5 there would be shooting above their heads and occasionally at a group

6 of people walking.

7 Q. Were there any particular incidents in which large numbers of

8 deported prisoners or evacuated prisoners did not make it to safety?

9 A. Yes, there is one particular incident in which it may, perhaps, be

10 useful, if I may suggest so, to have back again the general map of

11 Bosnia-Herzegovina so that it could be pointed out in which direction

12 the peoples were moved?

13 Q. Certainly. If we could have Exhibit 78 shown to the witness?

14 A. As can be seen on this map, from Prijedor the railroad goes to Banja

15 Luka and it continues the way to Doboj, and from this area it

16 continues further down. Frequently people were just taken by rail a

17 little further on from Doboj and then asked to proceed on foot in the

18 direction -- I am sorry, I need to read the map more carefully. Some

19 would move towards Tuzla, others would move towards Zenica. In the

20 direction of Zenica, however, people were also deported by road, and

21 then they will go from Banja Luka on the road in the direction of

22 Zenica and/or rather to Travnik first. These were areas in Central

23 Bosnia controlled by the government of Bosnia-Herzegovina at the

24 time.

25 When moving down on road, you will see a place called

Page 1088

1 Skender Vakuf -- it was also pointed out as being an opstina -- and

2 the road moves on, and a little further to the south and east of

3 Skender Vakuf, there is a mountain called Vlasic. On this mountain,

4 22nd about of August, as I seem to remember, possibly some 250 or 300

5 males deported by road were taken out of the column of deportation

6 vehicles and moved up on the mountain, the prisoners or the

7 deportees. These were, essentially, people who had been detained in

8 Keraterm, some in Omarska. They were asked to move out and on to the

9 edge of a cliff, to kneel down and were shot down. Very few, maybe

10 four, five, six, that we have been able to trace, survived.

11 But this incident is also, to some extent, documented by

12 the fact that it took place outside of opstina Prijedor and the

13 military Commander, the Serb military Commander, in the place where

14 it happened was not pleased to have this number of prisoners killed

15 within his area of responsibility. So, they were virtually all shot

16 down at the side of the cliff, down the cliff.

17 Q. Dr. Greve, you indicated that these camps were put in active

18 operation after the attack on Kozarac which occurred on May 24th.

19 Did the cleansing of the Muslim and Croat communities of opstina

20 Prijedor end with the attack and collection of citizens from Kozarac?

21 A. No, it did not, and one may also add that it did not only start with

22 the attack on Kozarac, because at the same time, from mid May 1992,

23 some members of the elite were individually rounded up and sorted out

24 in Prijedor town as well and when the main cleansing had taken place

25 in the Kozarac area, it continued for some time as some people had

Page 1089

1 been able to hide in some shelters in nearby small villages and

2 hamlets, but their fate was no better than that of the others.

3 Possibly, the killings of those who were not rounded up immediately,

4 more of them possibly percentage-wise were killed.

5 Q. In Prijedor town itself, or within the opstina, was there any

6 coordinated act of resistance against the coup leaders in the

7 takeover of the town?

8 A. Not from within Prijedor town, but if I may exchange the maps?

9 THE PRESIDING JUDGE: Which one do you want to put on?

10 MR. TIEGER: I think you need Exhibit 79.


12 MR. TIEGER: Yes, I believe 79 is the map which the court has copies of.

13 A. On this map we have Prijedor town and we have the Sana River and we

14 have the left bank of the Sana River. We have the village Hambarine

15 which was attacked prior to Kozarac, and we have a forested area

16 called Kurevo to which some people had been retreating. Among them

17 were some people who organised an armed resistance led by a Croat

18 named Slavko Ecimovic who later died in Omarska. Approximately

19 150-strong this group launched an attack on Prijedor town to regain

20 power from the Serbs.

21 Q. How successful was that attack?

22 A. That attack was without any success at all. That is, maybe they

23 thought they would have support from within Prijedor, but they had no

24 support. They were not well-armed and they were routed and driven

25 out again, some killed within a few hours. They came through across

Page 1090

1 the Sana River and then through the old part which is called Stari

2 Grad of Prijedor town.

3 Q. May I direct your attention to Exhibit 93? Looking at the bottom of

4 Exhibit 93, does it refer to the effort by these 150 or so people to

5 regain Prijedor?

6 A. Yes, it does. They are being referred to as green berets which

7 again is a reference to Muslim military or paramilitary units.

8 Q. You indicated that the people who carried out the attack were not

9 particularly well-armed. Did they have any heavy weapons, any

10 armour, any artillery?

11 A. No, they did not have anything but handguns, machine guns and

12 possibly some grenades, possibly grenade launches, but they had no

13 artillery or any heavy equipment.

14 Q. Were all of them armed?

15 A. Not all of them were armed.

16 Q. Why was that?

17 A. As they could not find the needed number of arms, and also most

18 probably because they thought when coming into town possibly some of

19 them would be able to assist them, that they might be able to kindle

20 some kind of rebellion, but that was not possible.

21 Q. According to the Serbian authorities, how long did it take to defeat

22 these 150 poorly armed people?

23 A. Several hours.

24 Q. Then the attack was over?

25 A. Then the attack was over, from the attackers' side that is.

Page 1091

1 Q. OK. Were announcements made on Radio Prijedor about the attack?

2 A. Yes, announcements were made in the early morning on Radio Prijedor,

3 essentially telling the people to stay indoors, to keep calm and not

4 be afraid because this would soon be controlled by the Serbian

5 authorities.

6 Q. Were Muslims or Croats of Prijedor advised to do anything?

7 A. Yes, they were advised to put up sheets of white material, blankets

8 or whatever they would find, to mark their house and to indicate

9 that they had surrendered or were loyal to the Serb authorities in

10 Prijedor town.

11 Q. What happened in portions of Prijedor that day after Muslim and Croat

12 citizens, or at least those who received the word, put white flags

13 out of their windows to identify their homes?

14 A. A number of quarters in Prijedor were this very morning ethnically

15 cleansed, that is, the incoming Serb armed groups, army paramilitary,

16 police and locals, would after having reported the attackers go on

17 and ask all non-Serbs living in houses that had been marked in this

18 manner to come out into the streets, and again they would subdivide

19 them into these two categories: the male group between 12-15, 60-65,

20 and the women's group, who were the children and the elderly men.

21 They would move them then on, men again to Keraterm and Omarska, and

22 women to Trnopolje. I should perhaps add that at this time it was so

23 cramped everywhere that it was very difficult to find room for

24 people. So some of the women's group were taken to a gymnasium, a

25 sports hall, Mladost, in the city itself which also served as a

Page 1092

1 staging area. Others were initially detained in schools just for

2 there to be enough space in the three camps proper for the different

3 categories.

4 Q. Were any portions of the Prijedor town destroyed?

5 A. Yes, the one portion that was particularly destroyed was the Stari

6 Grad, meaning the old city, and the old city is located next to the

7 Sana River and then it is on all other sides surrounded by a canal.

8 It is said to have had particularly old, beautiful and Muslim

9 dominated architecture, and it was almost raised to the ground.

10 Reportedly there were afterwards only a few buildings left. But not

11 all the buildings were destroyed in the attack. It was followed up

12 later, being raised to the ground.

13 Q. Did the cleansing of Muslims and Croats continue in other parts of

14 the opstina?

15 A. Yes, it did continue. I should hasten to add that in this period

16 after Kozarac region had been cleansed and the town of Prijedor had

17 been cleansed, I believe, if for nothing else, logistical purposes it

18 was impossible to take on cleansing of further areas immediately.

19 But cleansing went on in villages, hamlets, separate houses in the

20 manner that they would come to a house, arrest an individual and they

21 would put very hard pressure on the remaining population. This was

22 the time when they were also asked to wear a white arm band to

23 distinguish themselves when they went out to the streets. Virtually

24 any Serb could go to a home of any non-Serb and demand whatever they

25 liked, be it property, be it for the women to join them. No one had

Page 1093

1 any protection, legally speaking, any more if they were non-Serbs.

2 Q. Were and where did the last major cleansing take place?

3 A. The last major cleansing was concentrated on the one remaining main

4 area with non-Serbian population, that is the Ljubija area, the

5 Hambarine area, the Kurevo forest. All that is on the west bank of

6 the Sana River.

7 Q. Can we show Dr. Greve Exhibit 79 again.

8 A. This again is the Sana River. This is the left bank of the Sana

9 River. This is Ljubija. This is Hambarine. I should also perhaps

10 point out some other names that you will probably hear again from

11 witnesses: Rakovcani, Ecimovic, Biscani and Carakovo. This entire

12 area is frequently referred to as "Brdo" meaning mountain. It is a

13 mountainous forested area. Ljubija is again one large extension of

14 this main mining complex.

15 Q. Approximately how many non-Serbs were in the area when this last

16 major cleansing took place?

17 A. It is estimated to have been approximately 20,000 altogether. I

18 should add that moving south of Ljubija we still have some part of

19 opstina Prijedor, and these were areas essentially inhabited by

20 Croats. There were only 5.6 per cent Croats in the opstina according

21 to the census of 1991, and many of them were living in the Ljubija

22 area and to its south.

23 Q. If I can have the elmo panned back in the direction of the area

24 between Prijedor and Kozarac. I would like to move you

25 chronologically through the period of time which you have described

Page 1094

1 this afternoon leading up to the last major cleansing in the

2 Hambarine area. You already indicated that the first attack took

3 place in Hambarine and then the next day moved on to the Kozarac area

4 which is depicted here. Did some of the residents of the Kozarac

5 region, which included that broader area you showed us, flee in

6 various directions?

7 A. Yes, they tried to flee in various directions, but it was again

8 extremely difficult for them to get out. Some were eventually

9 rounded up as they tried to climb the mountain and get over it to the

10 northern side of the Kozara mountain. Some were actually also

11 rounded up by UN and handed over to the Serbs. Some of them tried to

12 go into other areas. When it was cramped in Trnopolje at one point

13 it was decided that some of the women and children could go out again

14 and stay with relatives. Some of these relatives lived in a

15 predominantly Muslim suburb to Prijedor named Puharska and others

16 would go to a village named Cela which is across the fish lake, fish

17 farm from Kozara, and a number may have also tried to get into

18 Ljubija area. But their freedom of movement was severely restricted

19 at this time.

20 Q. Over the succeeding weeks following the attack on Kozarac, was the

21 area systematically cleansed of Muslims and Croats piece by piece and

22 village by village?

23 A. Almost house by house, yes.

24 Q. That would include the area we see south of Kozarac?

25 A. It would include all the areas that we see here. When we come over

Page 1095

1 to, for instance, the area of Orlovci or in this direction we find

2 more Serb dominated areas, but essentially it may be said that every

3 single village and hamlet and settlement was cleansed for the

4 non-Serbs. It should also be mentioned that before the main attack

5 on the Kozarac area and later on the left bank of the River Sana and

6 also before Stari Grad was attacked by the Muslims, the Serbs one way

7 or another had been alerted and were out or primarily out. Of course

8 there were the occasional people who did not want to move.

9 THE PRESIDING JUDGE: Dr. Greve, just for the record, what do you mean by

10 "cleansed"?

11 A. I may perhaps, first of all, apologise for using this term. It is a

12 euphemism. "Ethnically cleansed" means by armed force or violence,

13 being rounded up. If one survives this rounding up, it means being

14 transferred to camps such as Omarska or Keraterm for the males and

15 for the women to be ready for deportation. It means there is no room

16 for them any more in Srpska opstina Prijedor.

17 MR. TIEGER: During this period of time from May 24th, actually from May

18 23rd until the attack on the Hambarine area in July, did some people

19 attempt to flee in the direction of the Hambarine area?

20 A. Yes, they did.

21 Q. Then when did this last major attack take place?

22 A. It started on 20th July 1992.

23 Q. How did that attack begin?

24 A. Again the area was bombarded and then it obviously had been

25 surrounded as troops were moving in from all their front directions.

Page 1096

1 With "troops" I refer to ordinary military forces, Reserve troops as

2 well. I refer to paramilitary groups. I refer to police units and

3 Reserve Police and I refer to some occasional local Serbs.

4 Q. After the bombardment, that is when those units moved in?

5 A. That is when those units moved in.

6 Q. Did this cleansing action differ in any respect from those which had

7 preceded it in Hambarine in May and in Kozarac in May and in the

8 smaller cleansings that followed

9 A.It is difficult to establish exactly,but possible on-the-spot

10 killing was happening to a

11 larger extent in this last killing, excuse me, than in these

12 previous cleansing operations. I do not know if it has anything

13 to do with the fact that there were still many prisoners both in

14 Omarska and in Keraterm, and now when they had rounded up prisoners

15 they seem to find no place to put them. So there are reported bus

16 loads of killings.

17 JUDGE STEPHEN: I am not clear in what area this happened.

18 MR. TIEGER: Sorry, your Honour. If we can refer back to Exhibit 79. I

19 apologise for departing from the map.

20 Dr. Greve, you had indicated Kozarac and then the areas

21 of the intermittent and systematic cleansings which took place

22 thereafter. Now you have just been discussing the last major

23 cleansing. Can you direct the court's attention to where that took

24 place?

25 A. Yes. This is in the Hambarine-Ljubija area. It is on the left bank.

Page 1097

1 Maybe we can have some details of the map, first to the north of

2 Hambarine. Actually, everything from Prijedor and up in this

3 direction, or actually on the left bank of the River Sana, there is

4 another area which is cleansed in smaller operations later, and that

5 is on the east bank of the River Sana and the fish pond. But at this

6 time it is from Prijedor town up to approximately this Biscani,

7 Hedici and down again all over the Ljubija area and all the areas

8 between the River Sana and the roads. This is the main road. This

9 is the main road leading down to Sanski Most. It is also known that

10 troops, the 6th Sana Brigade, for instance, came from Sanski Most to

11 participate in this cleansing operation.

12 Q. Where were those Muslims and Croats who survived the shelling or the

13 invasion of troops taken after that?

14 A. The male groups were taken to Keraterm and Omarska. The women's

15 group, children and elderly men, were taken to Trnopolje. Some may

16 have been deported straight from an athletic field that was to be

17 built in Tukovi which is a suburb to Prijedor town on the left bank

18 of the River Sana.

19 Q. Ultimately, if they survived the camps, to be deported from opstina

20 Prijedor?

21 A. That is correct.

22 Q. You mentioned one of the contingents of military forces which

23 participated in the last cleansing action against Hambarine. I would

24 like to ask you about some of the military forces which participated

25 in the cleansings which you have described in Kozarac and Hambarine

Page 1098

1 and so on. Can we learn from Serbian officials themselves some of

2 the military units which participated in these cleansings?

3 A. Yes, we can as they are celebrating this later.

4 Q. In that regard I would like to direct your attention to this exhibit

5 which I would ask to be marked as No. 116 for identification what is

6 this document, Dr. Greve?

7 A. It is again a newspaper article from Kozarski Vjesnik dated 20th May

8 1994. It is headlined: "To the Pride and Honour of the Fatherland".

9 Q. Is that an article which occurs in honour or which is written in

10 honour of the day of 43rd Prijedor Motorized Brigade?

11 A. That is correct.

12 Q. We tender this document for admission.

13 THE PRESIDING JUDGE: Any objection?

14 MR. ORIE: No objection, your Honour.

15 THE PRESIDING JUDGE: Exhibit 116 will be admitted.

16 MR. TIEGER: Dr. Greve, turning to page 3, the second paragraph, does the

17 article indicate where the 43rd Motorized Brigade participated in

18 actions in opstina Prijedor?

19 A. Yes, it does. It refers to Prijedor which, from the context, must be

20 the town of Prijedor, Kozarac, Kurevo, the forested area on the left

21 bank of the River Sana that is, Panjik, Hambarine and what is

22 referred to as other Mujaheddin strongholds.

23 Q. Did units of the 43rd also participate with other contingents of the

24 Serb military forces in other clensings?

25 A. Yes, it is referred to participation in Novi Grad, Kljuc, Sanski Most

Page 1099

1 and Krupa on the River Una.

2 Q. Along with what other military units?

3 A. The 5th Kozara and the 6th Krajina. The 6th Krajina is the same as I

4 previously referred to as the 6th Sana. It had its headquarters in

5 Sanski Most which is the opstina and the town to the south of

6 Prijedor.

7 Q. May I now direct your attention to this document which I would ask to

8 be marked as No. 117 for identification.

9 A. Maybe before we move I may also point out that in the next paragraph

10 there is a reference to 5th Kozara and 6th Grmec. It is my

11 understanding that the headquarters or a headquarters of the above

12 mentioned 6th Krajina is at the plateau of a small mountain called

13 Grmec, meaning that it is the same unit as it is referred to call 6th

14 Grmec and 6th Krajina.

15 Q. Dr. Greve, what is this document?

16 A. This again is a newspaper article from Kozarski Vjesnik, dated 6th

17 August 1994: Persistent in the defence of Serbian people, the war

18 path of the 5th Kozarac Brigade.

19 Q. I tender this for admission.

20 THE PRESIDING JUDGE: Any objection to 117?

21 MR. ORIE: No objection.

22 MR. TIEGER: Dr. Greve, as you indicated, this is an article on the war

23 path of the 5th Kozara Brigade?

24 A. That is correct.

25 Q. Does the article indicate why the 5th Kozarac Brigade will be

Page 1100

1 created?

2 THE PRESIDING JUDGE: Excuse me, is there any objection to 117?

3 MR. ORIE: There is no objection, your Honour.

4 THE PRESIDING JUDGE: 117 will be admitted. Do you want to repeat the

5 question?

6 MR. TIEGER: Dr. Greve, is there any indication why the 5th Kozara Brigade

7 had been created?

8 A. Yes. It is in the first paragraph. It is specifically stated that

9 the 5th Kozara Brigade had been created as a territorial formation

10 within the army forces of the former Yugoslavia to carry out the

11 warfare in the region of Prijedor municipality.

12 Q. Does the article indicate further down on that page where the 5th

13 Kozara Brigade conducted its operations? If I could direct your

14 attention to the last section of that first major paragraph.

15 A. The troops and the commanding officers contributed a great deal

16 towards the preparations of the Serbs to take control in Prijedor, as

17 well as during cleansing of the town from the Muslim fundamentalists.

18 Q. When does the article indicate that the 5th Kozara Brigade

19 successfully completed its combat operations at Prijedor?

20 A. On 1st August 1992 as it could then move on to other obligations.

21 Q. The cleansing operations were largely completed at that point?

22 A. That is correct.

23 Q. May I have this document marked as Exhibit 118 for identification,

24 please? What is this document, Dr. Greve?

25 A. This is again an article in Kozarski Vjesnik, dated 29th July 1994.

Page 1101

1 It has the headline: "The Brigade of a long and honourable war path,

2 a war path of the 5th Kozara Brigade, immense contribution to the

3 freedom."

4 Q. I would tender this document for admission.

5 THE PRESIDING JUDGE: Any objection?

6 MR. ORIE: No objection, your Honour.

7 THE PRESIDING JUDGE: Exhibit 118 will be admitted.

8 MR. TIEGER: Dr. Greve, may I direct your attention to the fourth page of

9 this article, the last paragraph? Does that indicate where the 5th

10 Kozara Brigade participated in the cleansings and with what other

11 units?

12 A. Under the headline "20th May 1992" it is referred that, "The Assembly

13 in the village of Jaruge Prijedor of the first battalion consisting

14 of the troops from Slavonia and some new recruits. Subsequent

15 involvement in the battles for liberation of the villages of Kozarac

16 in a joint operation with the first battalion of the 43rd Transport

17 Brigade and parts of the 2nd Battalion of our Brigade previously

18 gathered in the village of Gornji Garevci", that is a Serb dominated

19 village.

20 MR. TIEGER: Your Honours, does the court wish me to continue?

21 THE PRESIDING JUDGE: No, it is 5.30. I just had a question about where

22 these troops came from. Where did they get their material and who

23 were the troops themselves? Were they Bosnian Serbs, Serbs from the

24 Prijedor area or somewhere else? But I suppose we can explore that

25 tomorrow.

Page 1102

1 Dr. Greve, you are excused until tomorrow at 10.00 a.m.

2 Thank you for coming.

3 We want to talk about the schedule for next week, Mr.

4 Niemann?

5 MR. NIEMANN: Yes, your Honour.

6 (The witness withdrew).

7 THE PRESIDING JUDGE: As you indicated this morning, Mr. Niemann, you had

8 heard that there will be another matter handled by this Chamber I

9 suppose next week. You have heard a number of things, but let me

10 focus on that. The schedule for next week will be as follows. Much

11 to my regret, on Monday we will not hear this case. Monday is a

12 holiday. I just enquired what holiday it is and I was told that it

13 is Whitsun. Anyway, it is an official holiday and government

14 offices are closed, so we will not hear this case. Tuesday we will

15 also not hear this case, Mr. Orie and Mr. Niemann. The Trial

16 Chamber has another matter that it has to consider. On Wednesday we

17 will not hear this case in the morning; this Trial Chamber has two

18 matters it has to consider. But we will continue Wednesday afternoon

19 of next week, as well all day Thursday and all day Friday

20 So, to recapitulate, Monday is an official holiday, the Tribunal will

21 be closed. On Tuesday this Trial Chamber has

22 another matter to handle and on Wednesday we have two additional

23 matters to handle. So we will not hear the case on Tuesday at all.

24 On Wednesday we will begin at 2.30 of next week and we will sit all

25 day Thursday and all day Friday.

Page 1103

1 Are there additional matters, Mr. Niemann or Mr. Orie?


3 THE PRESIDING JUDGE: OK. Then we will adjourn until tomorrow at 10 a.m.

4 (The hearing adjourned until the following day)