Tribunal Criminal Tribunal for the Former Yugoslavia

Page 7934

1 Tuesday, 29th October, 1996.

2 (Open session)

3 MR. DUSKO TADIC, recalled.

4 Examined by MR. KAY, continued.

5 THE PRESIDING JUDGE: Mr. Tadic, you understand that you are still

6 under the oath that you took when you began your testimony to

7 tell the truth, do you understand that?

8 THE WITNESS [In translation]: Yes. Yes.

9 THE PRESIDING JUDGE: Very good. Thank you. Mr. Kay, you may

10 continue.

11 MR. KAY: Thank you, your Honour.

12 Q. At the end of yesterday's hearing, Mr. Tadic, we were discussing

13 your military history in 1993. You gave evidence concerning

14 occasions when you were arrested and there was an enforced

15 mobilization at Gradacac. I would like you now to look at a

16 number of documents, the first of which I produce dated 9th June

17 1993. If this could be provided to the Registry for

18 identification purposes as D96 with translations? Your Honour,

19 these documents were provided to the Prosecution during the

20 video link stage of the trial.

21 It seems from our information that the witness to

22 replace Budimir, Aleksic will not be available to testify.

23 I have spoken to Mr. Niemann about this matter this morning and

24 he has agreed that it is appropriate these documents come in

25 through the accused, although they are not his documents and

26 there will be no objection to their admission.

27 THE PRESIDING JUDGE: Mr. Tieger?

28 MR. TIEGER: Yes, your Honour, that is correct.

Page 7935

1 THE PRESIDING JUDGE: Very good. Then there will be no objection

2 raised then by the Prosecution as to any of these documents?

3 MR. TIEGER: No.

4 THE PRESIDING JUDGE: Thank you.

5 MR. KAY: I am very grateful. There is a full set here for your

6 Honours and if I can hand those in to you?

7 THE PRESIDING JUDGE: Defence 96 then will be admitted.

8 MR. KAY: In fact, if the remaining pages are also put before the

9 witness as part of 96, it will be an easier and quicker way to

10 proceed.

11 [To the witness]: If you can keep them in the order

12 that has been provided, Mr. Tadic? Beneath each Serbo-Croat

13 document is a document that has been translated in English.

14 Perhaps if we can look at the document dated 9th June 1993?

15 Just looking at this document, it indicates that, indeed, you

16 were arrested or an order was given to a Sergeant Desimir

17 Grujicic on 9th June 1993 relating to Prijedor and Pecani. The

18 patrol assignment was the apprehension of the conscript Dusko

19 Tadic and his remand to command post, Slatina, pursuant to the

20 order of seizure of 8th June 1993. I think you told us

21 yesterday that Desimir was the man who arrested you, is that

22 right?

23 A. It is -- the name is Grujicic. I do not think your

24 pronunciation was correct -- it was Grujicic -- and he was there

25 every time they tried to arrest me.

26 Q. Right. If we could then move to the next document beneath that

27 which is headed: "Patrol leader report on the completed

28 assignment", it indicates there that you were apprehended and

Page 7936

1 remanded to South Slatina on 9th June 1993?

2 A. I saw this handwriting. It is very familiar to me because at

3 the time when I was arrested, Desimir showed me the arrest

4 warrant which was in similar handwriting, and also a fax which

5 he had received from Slatina.

6 Q. For the information of the Court, the official note beneath that

7 is a note that was put on the document later by a Judge in Banja

8 Luka and is not part of the original document, but was used at a

9 time when it was felt that that would be a means of providing

10 the evidence before the Court.

11 If we look then to the next document which is dated

12 21st July '93?

13 A. If only I could say I remember this was June 9 of '93. At that

14 time it was the first time that I was arrested in a legal way by

15 the military police. I remember that I was then arrested in my

16 office, at my workplace, in Kozarac. They arrested me several

17 times, but this time on that day they took me to the front and I

18 returned the same day. I think it was -- I spent the night

19 there, I think it was Friday, and then I went back and I was

20 arrested again on the next day, and returned to the front. It

21 was always Desimir who did this and his patrol.

22 Q. I think that we saw yesterday your mobilization, your military

23 book which showed your mobilization being stamped in the book

24 for 10th June '93 which would have been the day after the arrest

25 and the day after those documents that we have just looked at?

26 A. If you will allow me to tell it? On the 9th June of '93, I was

27 arrested in Kozarac, and then I was taken in a van to Prijedor,

28 to the headquarters of -- it was the fire station. I know it

Page 7937

1 was their headquarters. Then in the same van I was taken to the

2 front, and on the same day I escaped. Desimir himself said that

3 it was not done to any of the Secretaries of the Local Commune,

4 and he said that the warrant is a warrant and he had to do what

5 it said. Indeed, in the warrant it said that I should be

6 remanded for an interview. That evening I managed to get back.

7 I came back very late to Pecani.

8 I remembered spending the night there and in the

9 morning when my wife and I went for coffee, the same group,

10 actually a little bigger group, waited for me. They were in

11 front of the building and I said, "At least allow me to have

12 coffee". They said, "No, no, we have to go". Desimir showed me

13 the fax and said, "We were looking for you all night", and many

14 people did not know where to look for me, the military.

15 As far as the military book is concerned, they allowed

16 me to go back to the apartment, get the documents concerning my

17 military and my work, my employment, and those documents always

18 were the evidence against the impropriety, the illegality, of

19 their actions.

20 So I turned all my documents over to my wife, the

21 military book and the employment decision, and I told her to get

22 in touch with our brother immediately, to go to the office of

23 the Defence because I was not sure that things were going to

24 come out right.

25 On several occasions I was told that there was no

26 chance of me staying in Prijedor. They would do anything to

27 destroy me. So I was quite afraid. I did not understand all

28 the reasons, only later did I understand why this was being

Page 7938

1 done. But, all in all, when I came back home the next time, my

2 wife, that is what she told me later. She went with my brother

3 to the municipal office and they would not talk to them there.

4 She went to Miskovic, Simo Miskovic. Apparently, they called

5 the National Defence and they paid a visit there and again they

6 achieved nothing. So they were running in a circle.

7 Generally, they did not even know where I was. At the

8 time they did not know where I had gone to. My brother, when

9 I was taken away, did not know where I went. They would not

10 tell him and later he found somebody, and they found out that

11 I was in Gradacac and there were many places where the military

12 was located. This is the first time at the front that I saw

13 that military book. Mile Cavic who was the company Commander

14 gave me this book. I had left it with my wife and I got it back

15 in Gradacac.

16 My wife told me that Mr. Budimir told her, "Everything

17 is going to be resolved, give me the book", and that was a

18 mistake because they stamped it and then it was definitive, the

19 proof that I was tied to this military unit. You could not get

20 another stamp unless you got it from the highest authority in

21 the municipality.

22 Q. I think we understand this point. What I want to do is just to

23 put these records in before the Court at this stage. We

24 understand the purpose of your testimony on this matter. If we

25 just look at the next document dated 21st July '93, and it is

26 patrol sheet 019/-95? Again it refers to Sergeant Desimir

27 Grujicic and states on 21st July 1993 they were ordered to

28 patrol facilities and routes indicated in the Prijedor region.

Page 7939

1 Again the purpose was the apprehension of the conscript Dusko

2 Tadic and remand to the Unit's deployment area pursuant to the

3 order of the Battalion Commander of 19th July 1993.

4 That is the order they got, but if we look at the next

5 document we indicated we can see how it impacted upon you,

6 because it states that you were apprehended on 21st July 1993.

7 Is that right, that on 21st July 1993 that was another occasion

8 as part of your enforced mobilization that they had arrested

9 you?

10 A. Yes.

11 Q. Thank you.

12 A. Here you can see there the region to be searched around Kozarac

13 and Prijedor. I would always go to my workplace in Kozarac.

14 When I spoke to the Secretary in the municipality, who was in

15 charge of all the Secretaries of the Local Commune, he

16 said, "You have to report there in the specific time of the

17 day", but it was a circle because whenever I would show up at

18 work I was afraid that I may be arrested, and often times it did

19 happen that I was arrested.

20 So I wanted to move somewhere else, to another -- in

21 the school there were a lot of rooms. I was persecuted. I was

22 not aware of what was going on. Sometimes when I would come to

23 Kozarac my neighbours would say, "The military police was

24 looking for you". I was surprised because they could have found

25 me, but often they were looking for me. This time I know that

26 I was taken to Slatina in a luxury car. It was a zastava model

27 101.

28 Q. If we look at the next document dated 9th August 1993, again we

Page 7940

1 see a patrol sheet, again it is Sergeant Desimir Grujicic and we

2 see the order for the apprehension of the conscript Dusko Tadic

3 upon the orders of the Battalion Commander of 5th August 1993.

4 That is the order. If we look at the next document beneath it

5 we can see a note related to the completed assignment and, "The

6 individual was taken into custody on the premises of the Fire

7 Brigade in Prijedor, and after the interview with the personnel

8 or personal officer, Gavrilovic, the individual escaped".

9 A. I remember this event very well. At the time my wife was

10 already abroad in Germany, and I was in Prijedor by myself with

11 my mother and I was living in an apartment above Jugo-Banka.

12 I remember in the morning I went to find medicine for my mother,

13 gangrene of a toe, and I saw the police van approaching. At

14 first, I did not know who they were looking for. Then Desimir

15 beckoned to me. I turned around and started to run, and he

16 started running after me. I remember jumping over a fence, two

17 fences, and he was jumping over after me.

18 I came to a wall and he said, "Stop or I will shoot."

19 I turned around and I really saw him. He was holding a gun.

20 Maybe I would continue running ----

21 Q. Maybe I could stop you here. We do not need this detail as it

22 is not that crucial for the case. The facts are spoken of

23 within the documents and I do not think the Court would object

24 if I interrupted you on that matter. If we look at the next

25 document that is dated 30th August 1993, we again see the same

26 order. Again it is Sergeant Desimir Grujicic and the order of

27 30th August 1993, "shall patrol the facilities, routes, areas

28 indicated below, Prijedor, Pecani, Kozarac", and the assignment

Page 7941

1 is to remand the conscript Dusko Tadic pursuant to an order of

2 28th August 1993.

3 If we look at the last page, which is a final report,

4 it says, on the completed assignment, but it says, "The

5 conscript Dusko Tadic was not found at the indicated address or

6 seen in the Prijedor or in Kozarac. He was sought at regular

7 intervals and has not been found". What I would like to ask you

8 about is this. That reviews those documents. You referred to

9 your wife being in Germany during this period. Can you tell us

10 why she left for Germany during this summer of 1993?

11 A. At first, we were not clear about the main reasons were my

12 arrest. We simply could not survive there any more together.

13 At moments it seemed to us that it was because I got this cafe

14 to use, and it was a Major of the army of Republika Srpska was

15 behind it, but it was not the real reason. I took some

16 confidence in thinking that was the only reason, but when I was

17 taken to the fire station, when my wife had already gone abroad,

18 it was then that I realised that the difference -- that the

19 reasons were very different and after that interview at the fire

20 station I fled and I never went back.

21 I only once went back while I was in Banja Luka. It

22 was at night. I visited friends in Prijedor, and I asked them

23 what to do and they said it was best for me to leave and not to

24 come back.

25 Q. When did your wife leave the area to go to Germany?

26 A. She left after -- before this arrest on 9th August, and after my

27 arrest of 21st July, somewhere in that period. I am not sure,

28 but I know that I saw them off to Belgrade. I returned and I

Page 7942

1 was arrested promptly. So that was the very end of July.

2 Q. Did you go to Germany as well?

3 A. I went to Germany in November from Belgrade.

4 Q. Between August and November where were you?

5 A. I was in Banja Luka, hiding at my brother's, and I was staying

6 there during the day, but I was afraid that they would come and

7 look for me there. So I was sleeping at his mother-in-law, at

8 Milosa Duica Street, with Ljubo's son Nenad. He was keeping me

9 company there, even though he was living with the brother.

10 Q. What was your reason then for going to Germany in November 1993?

11 A. After my arrest in the fire station, I knew that I could not

12 survive in Prijedor. Major Gavrilovic, he is the one who

13 interrogated me. It was not just an interview, it was not just

14 an interview; it was an interrogation, and at that time

15 I realised that I had to leave the Prijedor municipality as soon

16 as possible and go as far as possible. I did not know that

17 I would go to Germany. I did not want to stay in the Republika

18 Srspka.

19 Gavrilovic told me openly, he knew -- he had all the

20 information about the brothers, "You are no warriors, you are no

21 soldiers". He was mocking us. "They were good in karate but

22 they do not fight". Now he had all the information. In

23 general, he cited the reasons. I remember signing a few

24 documents after the interrogation.

25 At first, he said that he would take me to Radio

26 Prijedor to publicly apologise to the Bosnian Serb Army because

27 I had said that they were a private army. I showed him the

28 document that I had work obligation. He said, "I will check it

Page 7943

1 with Slavko Budimir", and he said, "Yes, this is a legal

2 document, but we will revoke it today", and he said, "No, no,

3 you will stay here", and then I was detained.

4 There was a detention unit in the fire station, and he

5 said, "You are going to sign that we are not a private army,

6 that you will sign that you were a representative of Muslims".

7 Then I remembered that it was during the period of time when

8 I was taking part in the civic forum activities, and I told him

9 that I was coming to Prijedor with a group of citizens that had

10 nothing to do with any power or government. I was not connected

11 to them.

12 He said, "No, no, no. You negotiated on behalf of

13 people who later turned against the Serb authorities", and

14 I said that I would sign that I was a member of this delegation,

15 but I did not know the background of all this. I could not have

16 known. I did not know if there was somebody who wanted to

17 manipulate me. He said, "It was only formal negotiations. You

18 were really preparing for a war".

19 So I said that I would sign. He said, "I will let you

20 go if you sign". Then he said, "I cannot let you go, but if

21 people from the military police let you, you can go to your

22 mother's". I heard, overheard, when he gave the order for the

23 van to be prepared and for me to be taken to the front.

24 Somebody told me, "I did not know what is going on. I do

25 not know where they are taking you, but you will be killed on

26 the front". So, in August, the unit where I was was not on the

27 front line. At that time I realised for the first time the

28 seriousness of what was going on, and I told to a soldier, the

Page 7944

1 last salary, the last money that I had, I gave to this Desimir

2 so that I could be allowed to take medicine to my mother. I had

3 about 50 Marks.

4 I ran into the apartment, my mother's, grabbed all the

5 documents that I had and fled towards Banja Luka. I went on

6 foot to Petrov Gaj where I knew that the priest Majkic lived.

7 So I stopped there for a coffee. A train arrived and that is

8 how I got to Banja Luka. All in all, I went on foot. I did not

9 use the same road. When I would hear vehicles, I would go into

10 the fields. When I came to the priest, I know he was surprised

11 at how I looked. I was filthy and sweaty. I did not tell him

12 what had happened. I was embarrassed. I just told him that

13 I was going to Banja Luka and I did not tell him what was going

14 on.

15 When I was in Banja Luka later, I called some of my

16 friends and asked them what was going on. I had a telephone

17 number of somebody in the military police, Riki Lekenic, and he

18 told me not to go -- leave Banja Luka, that he would come to

19 Banja Luka and tell me what was going on.

20 Q. Did you go to Munich in Germany?

21 A. I first went to Nuremberg and then my brother Mladen came to

22 Nuremberg and took me to Munich.

23 Q. Did you stay in the house of your brother Mladen in Munich?

24 A. I lived in the same apartment as he did for a certain period of

25 time. It was a studio, and then I moved to a room which was

26 part of his club, and that is where I lived. That is where

27 I lived with my wife and my two children.

28 Q. When you were in Munich is it right that you were arrested on

Page 7945

1 12th February 1994 by the German police?

2 A. Yes.

3 Q. Subsequently, you were interviewed by investigators for the

4 Prosecution Office of the Tribunal on 9th to 10th May 1995?

5 A. Yes.

6 Q. And 21st to 22nd December 1995?

7 A. Yes.

8 Q. That is all I have to ask you. If you could remain there?

9 THE PRESIDING JUDGE: Cross-examination, Mr. Tieger?

10 MR. TIEGER: Thank you, your Honour. Your Honour, may I ask the

11 Court for the Court's indulgence for a brief recess? I was

12 having a document attended to by the translation unit which,

13 I think, will expedite matters considerably. It has not arrived

14 and I will check on its progress.

15 THE PRESIDING JUDGE: Do you expect that you will have it or do you

16 need a recess to check on its progress? Hopefully to check on

17 its progress but also to have it, I gather?

18 MR. TIEGER: Correct, that is right.

19 THE PRESIDING JUDGE: Five minutes.

20 MR. TIEGER: May I have 10?

21 THE PRESIDING JUDGE: We will stand in recess for 10 minutes.

22 (10.30 a.m.)

23 (The Court adjourned for a short time)

24 (10.40 a.m.)

25 THE PRESIDING JUDGE: Mr. Tieger, are you ready to proceed?

26 MR. TIEGER: Yes, your Honour, thank you.

27 THE PRESIDING JUDGE: We have to keep them satisfied. We try very

28 hard. You may proceed.

Page 7946

1 MR. TIEGER: Thank you, your Honour.

2 Cross-examined by MR. TIEGER

3 Q. In your testimony you spoke about the good people of Kozarac,

4 predominantly Muslims. Those good people, at least most of

5 them, are not there any more, are they?

6 A. Yes.

7 Q. They were driven from their homes?

8 A. Well, probably some of them were chased away and some left of

9 their own will, but not all of them have been chased away.

10 Q. Many were rounded up and put into camps, isn't that right?

11 A. I do not know what your question is.

12 Q. Many of the Muslims from Kozarac and from opstina Prijedor were

13 rounded up by Serbian forces and put in camps?

14 A. I did not take part in any of such activities.

15 Q. But you were aware that that was happening in opstina Prijedor

16 in the spring and summer of 1992?

17 A. Well, when I first visited Kozarac I did not find my neighbours

18 there. At that moment I did not know what had happened to them.

19 Q. The religious buildings of the Muslim community were all

20 destroyed?

21 A. During my first visit I saw that some had been destroyed and

22 later when I came back to work as the Secretary of the Local

23 Commune, yes, it is true that all religious property in Kozarac

24 was destroyed. Many of them were also destroyed in Prijedor

25 although there was no war there.

26 Q. By the time you left opstina Prijedor, about 90 per cent of the

27 Muslim community of the entire opstina had been killed, forced

28 out or thrown out, is that not true?

Page 7947

1 A. I do not know what the percentage would be exactly. I did not

2 have any conversations about that. I am not very well informed

3 of the percentage.

4 Q. Was the vast majority of the Muslim community of opstina

5 Prijedor forced out of the area?

6 A. Probably some were forced and some left of their own will

7 because they simply could not survive there any longer. There

8 were several reasons, but many of Serbs also left the area. A

9 great percentage left the area for different reasons, economic

10 reasons, and simply because they did not want to take part in

11 the war.

12 Q. What happened to the Muslim community of opstina Prijedor was

13 done under the direction of the authorities of the new opstina

14 Prijedor?

15 A. I do not know whether it was under their orders.

16 Q. Those new authorities were comprised of persons who wanted and

17 created a Srpski, Serbian opstina Prijedor and a Serbian

18 Kozarac?

19 A. The intentions were not clear to me, the intentions of the new

20 authorities, whether it was about creation of Republika Srpska

21 within Bosnia or something else, I do not know. I was not aware

22 of -- I did not know about the intentions of those authorities.

23 They were not made public. You could only guess, assume, and I

24 assumed that they themselves did not know.

25 Q. You mentioned in your testimony on Friday, I believe, in

26 response to a question from your attorney, that you did not

27 conduct the plebiscite in 1991 on behalf of the SDS, because the

28 plebescite was conducted through the Skupstina Opstine, through

Page 7948

1 the elected local assembly, on behalf of the whole opstina?

2 A. Yes.

3 Q. Can the witness be presented with Exhibit 146, please? I am

4 sorry, that may be the wrong number. Your Honour, the Court may

5 know this Exhibit. It is the decision on the plebiscite which

6 was displayed in Court on October 25th.

7 THE PRESIDING JUDGE: How many hundreds of Exhibits do we have, 149?

8 I do not know. I do not have the list of Exhibits before me.

9 MR. KAY: I think it is 146.

10 MR. TIEGER: That is what I have it listed as well. May I see the

11 Exhibit for the moment and make sure that we are talking about

12 the same one? That is the correct number, thank you.

13 Sir, this document, the decision on appointment of

14 voting officials for the plebiscite, is headed as the

15 "Instruction for the Plebiscite of Serb people in Bosnia and

16 Herzegovina", is that correct?

17 A. No.

18 Q. Can you look at the top of the page and see what that

19 instruction indicates? Is that not pursuant to paragraph (2)

20 under (4) of the instruction for the plebiscite of Serb people?

21 A. Yes, there was an instruction, but this is not the instruction

22 on the plebescite. Here it says, "pursuant to paragraph (2)

23 under (4) instructions for the plebiscite", so it is based on

24 the instruction, was this decision issued.

25 Q. This particular decision? The appointment decision itself,

26 although it cannot be seen on the monitor at the moment, is

27 written in Cyrillic, is that correct?

28 A. Yes, the decision.

Page 7949

1 Q. There is a stamp at the bottom?

2 A. Yes.

3 Q. What does that stamp say?

4 A. "Serbian Democratic Party of Bosnia and Herzegovina, municipal

5 board, Prijedor".

6 Q. You indicated in your testimony that the plebiscite itself was

7 conducted in the churchyard of the Serbian Orthodox church

8 because, you said, you did not want the plebiscite conducted in

9 a private home and "there were no other communal objects". In

10 fact, there were a variety of communal objects and buildings in

11 Kozarac, but the Orthodox church was the only exclusively Serbian

12 communal object, isn't that right?

13 A. No, the Orthodox church in Kozarac is over 120 years old, and

14 all people visited, not only the church but also the churchyard,

15 Muslims, Croats and others. I remember. I grew up there. We

16 used to play football there. We spent a lot of time there in

17 the churchyard, not only of the Orthodox church, but of the

18 mosque as well -- me and my neighbours.

19 Q. So the mosque was a communal object or building, the Mjesna

20 Zajednica was a communal building, the post office was a

21 communal building?

22 A. Yes.

23 Q. But the Serbian Orthodox church was the only Serbian communal

24 building?

25 A. Yes.

26 Q. As a matter of fact, it was the main board of the SDS which

27 entrusted you with the responsibility to conduct the plebiscite?

28 A. No, not the main board, the municipal committee. At that time

Page 7950

1 in the municipality of Prijedor there was a government which did

2 not belong to any party, and the municipal committee reached a

3 decision, issued instructions, as to the way the plebiscite

4 should be conducted. The municipal committee was not

5 composed only of members of the SDS. I do not even know if

6 there were any members of the SDS there. Maybe, I know that

7 there was a Croat was a member of that committee.

8 Q. Before you left Prijedor, you prepared a report to the SDS about

9 your work from 1990 to 1993, is that right? We have seen that

10 document in evidence.

11 A. On 8th, 8th August, I prepared that document in Kozarac and it

12 was composed on the basis of various sources, sources of

13 information, and various reports.

14 Q. You sent that report to a number of different places and

15 persons. For example, you sent it to the President of Bosnia

16 and Herzegovina -- the President of Bosnia and Herzegovina SDS,

17 correct?

18 A. I had the intention to do so, but I simply had no time to do

19 it. I sent the document on the same day, that is, on

20 8th August. I took it personally to the office in the town hall

21 in Prijedor. I had one copy with myself, and that copy was sent

22 by me at the end of August through Rajko Lekenic to Prijedor to

23 the main board of the Serbian Democratic Party. So one copy

24 should be with the SDS in Prijedor.

25 Q. You also prepared that work report to be sent to the President

26 of the Bosnia and Herzegovina SDS, Radovan Karadzic?

27 A. Well, I was -- there were not many preparations there. I just

28 did it within 20 minutes. I was sitting in the office in

Page 7951

1 Kozarac. I was afraid that I would be arrested. So I wrote it

2 on the basis of what I had seen in the office in Kozarac and on

3 the basis of some reports that I had there, on the basis of my

4 recollection.

5 So I managed to compose it and I managed to write it

6 on a typewriter although I had never used a typewriter before.

7 So I managed to do it very quickly and to hand it over there,

8 but I do not think it was really sent anywhere. As far as

9 I know, I personally handed it over in the town hall in Prijedor

10 and Rajko Lekenic took it from Banja Luka to the main board of

11 the SDS in Prijedor, and I do not think that anything was sent

12 to any other address. There is another copy of that report

13 which is with me, and I took it with myself to Belgrade and then

14 to Germany.

15 Q. Copies were intended, however, whether they managed to get there

16 or not, to go to, among others, the President of the Bosnia and

17 Herzegovina SDS? You typed that yourself, sir.

18 A. But they were intended for many other addresses as well. For

19 example, Commission for the Security and Co-operation in Europe,

20 the Red Cross of Yugoslavia, to many other organisations that

21 I had visited.

22 I showed that document to the representative of the

23 United Nations in Belgrade, because in October I had talks with

24 them. They received me and I showed that document to them.

25 They saw it and we talked, and then they referred me to the

26 Federal Executive Council and they told me that I should try to

27 exercise my rights there and ask about what had been happening

28 to me in Prijedor municipality. I also visited the

Page 7952

1 International Red Cross which had its seat in Sremska Mitrovica

2 at that time. I also went to the seat of the UNHCR in Belgrade.

3 Q. Excuse me. I think you have answered the question that was

4 asked. In that report you said that in November 1991 the main

5 board of the SDS in Prijedor municipality entrusted you with the

6 task of organising the plebiscite for Yugoslavia?

7 A. I do not know whether it says so exactly, but I probably thought

8 that it was so. It should not -- it is not necessarily correct.

9 Q. May the witness also be shown Exhibit 97, I believe? May the

10 English be placed on the monitor, please? Can you bring that

11 down just a little bit? No, I am sorry about the confusion. We

12 want the first page of that document which is the ballot paper.

13 This document depicts the two ballots which were used for the

14 plebiscite, isn't that right?

15 A. I suppose so. It is not very legible, but I presume.

16 Q. Those ballots are headed "The Assembly of the Serbian people in

17 Bosnia and Herzegovina"?

18 A. Possible.

19 Q. The plebiscite was important to the SDS, was it not?

20 A. I do not know.

21 Q. Was it not a sign of loyalty to the Serbian cause to vote in the

22 plebiscite?

23 A. I would not say so.

24 Q. Is it not true that Serbs were denounced as disloyal for failing

25 to vote in the plebiscite?

26 A. I guess you could say so, but it was not a general attitude at

27 that time. It was not publicly said that way. It was believed

28 that it was perfectly normal and that it is the duty of citizens

Page 7953

1 to vote at the plebiscite, that it was their civic duty.

2 Q. As a matter of fact, did you not denounce Serbs as disloyal for

3 failing to vote in the plebiscite?

4 A. I thought that they are people who could not be trusted, loyal

5 or not loyal. I do not know whether someone should be loyal to

6 me. Maybe in a later period ----

7 Q. Just as you ----

8 A. --- certain things were made clear, so I could have an

9 impression that those were the people who were not aware of

10 their own desires, who did not have any specific attitudes about

11 the future of Bosnia and Herzegovina and the plebiscite. Just

12 like many other people at that time, we, simple people, ordinary

13 people, did not know much about things at that time.

14 Q. Did you not denounce Serbs for failing to vote in the plebiscite

15 as being disloyal to the Serbian cause?

16 A. No, I did not denounce them, but until the end of 1993 some

17 things were such that you could realise that those who did not

18 know, who had not known, whether to take part in public

19 gatherings or not, that those were people whom you could not

20 trust for anything. They could not be trusted when it comes to

21 the plebiscite in Bosnia and Herzegovina or other things.

22 Those people probably took part in all kinds of

23 plebiscites and referendums that took place in Bosnia and

24 Herzegovina. It was strange because it was difficult to

25 understand, because someone who would vote for a plebiscite for

26 Yugoslavia could later vote for Bosnia and Herzegovina. I think

27 that one should know what he really wants, whether you want a

28 sovereign Bosnia and Herzegovina, a Yugoslavia, whether you want

Page 7954

1 to live in Bosnia, in Herzegovina or not. At least, such were

2 the circumstances in which we were at that time.

3 Q. You were not denouncing people for intellectual contradictions;

4 you were denouncing them for failing to vote in the plebiscite

5 because in so doing they were declaring unmistakably which side

6 they were on, is that not true?

7 A. Well, in a later period it became clear that they were on

8 nobody's side. They were not on the side of the Serbs or

9 Muslims. They were just pursuing their own interests. Those

10 were such people. They were just sitting on the fence and they

11 did not know what they wanted. From time to time, they would

12 side with the most extremist part of the Serbian population and

13 then later they would ally themselves with the most extremist

14 part of other people.

15 Q. You wrote to President Karadzic and others that Goran Babic had

16 refused to participate in the Serbian plebiscite, but voted (as

17 did his whole family) at the referendum for the sovereign Bosnia

18 and Herzegovina, declaring in unmistakable terms what side he

19 was on. You wrote that, did you not?

20 A. Yes, I did write something similar, but the information that you

21 have in that report is based on everything that had taken place

22 before -- throughout '92 and '93. That is, on the basis of some

23 reports that were accessible to me at the time, I was writing

24 that report, and those reports were made during the sessions of

25 the Local Commune Assembly in Kozarac, Executive Board of the

26 Local Commune of Kozarac and so on. That is how people declared

27 themselves. The Secretary of the Local Commune -- as the

28 Secretary of the Local Commune, I was in charge of taking

Page 7955

1 minutes of those sessions and meetings, meetings of the Council

2 of the Local Commune, and on the basis of that I composed that

3 document. It is not always -- it does not always represent my

4 personal opinions, but it is also something that testified to

5 what people thought at that time in that area.

6 Q. You told this Court that you made no distinctions between

7 Muslims, Croats, Serbs and others, but in fact you denounced

8 Serbs for various reasons for disloyalty to the Serbian cause

9 and, as part of that denunciation, you made sure that

10 authorities knew whether or not they were married to a Muslim or

11 Croat?

12 A. No.

13 Q. In your work report did you not denounce Ljuban Lukic and, as

14 part of that denunciation, did you not write to President

15 Karadzic and others that he had been married to a Muslim woman?

16 A. I was not writing to Radovan Karadzic. I never had an

17 opportunity to exchange any correspondence with him or talk to

18 him and, as far as that information is concerned, it is based on

19 the events that took place in the period between -- in the

20 period when our Local Commune was constituted in Kozarac,

21 exclusively on that basis, and the information that was in the

22 written reports of the proceedings, and Ljuban Lukic, 10 minutes

23 before the death of Ostoja Baltic, was in his company, and it is

24 very likely that in some way he contributed to his murder. He

25 was one of my assistants and he was killed shortly thereafter.

26 What happened, I do not know, but it was discussed at

27 the session of the Local Commune in Kozarac. Maybe because his

28 wife had close relationships with the Suljo Suljic, he was a

Page 7956

1 known criminal, maybe that was the reason why people believed

2 that he was a man who is collaborating with all sides and

3 damaging ordinary people. I know that he was one of the people

4 who wanted the Local Commune of Kozarac to come back and he was

5 -- he, therefore, perished as an innocent man.

6 Q. You wrote this work report. It was copied to the President of

7 the Bosnia and Herzegovina SDS, among others. You denounced

8 Ljuban Lukic and, as part of that denunciation, you made sure

9 that the main board of the SDS, that the President of the Bosnia

10 and Herzegovina SDS, and that all the other groups you sent it

11 to, including the chief of the public security station in Banja

12 Luka, knew that he was married to a Muslim?

13 A. Everybody knew that without that information. I was not

14 disseminating this information. I just said who I sent the

15 whole report and that was in the report of the Local Commune in

16 Kozarac. This is something that I was part -- it was part of my

17 job. I was not deciding what was right or wrong. It does not

18 reflect my own view, what my thoughts, my views were. That is

19 known to the people with whom I talked. But, as a Secretary of

20 the Local Commune, I wrote what was there.

21 I do not know why this person was denounced because he

22 continued to live in Kozarac in a Muslim house. He even -- his

23 house was not even destroyed. He lived in the worst part of

24 Kozarac. Now he moved to the centre of Kozarac and this person

25 continues to live there to date. He was in the police before,

26 he is in the police today. I do not think that I contributed to

27 his denunciation. Those are the facts.

28 Q. You denounced Brane Koncar and, as part of that denunciation,

Page 7957

1 you also made sure that the information that he was married or

2 had been married to a Muslim woman was included? That is in the

3 report too. When you condemned Goran Babic, you made sure

4 that the people to whom you were sending the report knew that

5 his wife was a Croat?

6 A. That was well-known. There was enough information. Everybody

7 knew who was who. Those are -- that is redundant information.

8 Those are the facts that existed. I did not invent that he was

9 married to a Croat. That was known and that was established.

10 Q. When you wanted to denounce the new policemen in Kozarac who had

11 been, according to you, appointed by Dusan Jankovic, you also

12 made sure that everyone to whom you were writing knew that they

13 were all related to Croats and Muslims; that was part of the

14 denunciation?

15 A. I think that they abused relationships that they had with

16 Muslims and Croats by not treating them fairly. My brother was

17 married, one to a Muslim, one to a Croat, and that is a fact

18 too.

19 Q. But it is true that when you denounced the new policemen you

20 made sure to put in that they were all married to Muslims and

21 Croats? That is in the report, is it not?

22 A. If it is there, that is probably how it is. That was based on

23 how things were. You could not say that somebody was not a

24 Muslim if they were a Muslim or a Serb if they were not a Serb.

25 That was well-known in Kozarac and elsewhere. That was not a

26 secret. It is a different thing whether people abused their

27 family relations for individual private gain. I was not in such

28 a position. I think that through those family connections they

Page 7958

1 had access to many things that Muslims did not have access to.

2 Maybe at the time I did not understand that, but later I did.

3 Q. You were in contact with Serbs who had been in Kozarac shortly

4 after the conflict. For example, you met Milan Vlacina in

5 Kozarac on your first visit?

6 A. Yes.

7 Q. He had been in Kozarac shortly after the conflict was over. In

8 fact, he had been there so soon after that he was there to see

9 Muslims being taken by buses to Trnopolje and Prijedor?

10 A. He told me that, but I do not know whether his story is based on

11 what he saw or what he heard. That, I cannot know, but that is

12 what he told me. On that day when we sat down, we were drinking

13 beer in my cafe and he told me that. I really cannot know

14 whether that was true or not, but that is what he told me.

15 Q. In addition to knowing some Serbian soldiers who arrived in

16 Kozarac immediately after the conflict was over, you knew some

17 Serbs who participated in the conflict?

18 A. That was the only man that I saw on that occasion, the others

19 that I met in passing, I did not know them. I do not know if

20 I may have seen one or two other people but Kozarac was empty.

21 It was abandoned.

22 Q. But you later had an opportunity to talk to Serbs who were

23 soldiers, and some of them told you that they had participated

24 in the conflict in Kozarac or others who were with them told

25 them they participated in the conflict in Kozarac?

26 A. During 1993 many things became clear and I found out a lot of

27 information about it, but when I started working in the police

28 reserve they were not talking openly about what had happened.

Page 7959

1 Only later, sometime in early '93, I found out -- we found out a

2 lot of things that we did not -- had not known about before.

3 MR. TIEGER: May this be presented to the witness in reference to one

4 of the confidential Defence witnesses?

5 THE PRESIDING JUDGE: Show it to the Defence first.

6 MR. TIEGER: Yes. (Handed) This is the man who testified in Court

7 as Witness W, is that right?

8 A. Yes.

9 Q. He was one of those who told you that he participated in the

10 conflict in Kozarac, in central Kozarac?

11 A. He did not. I think he never spoke, at least, he never told

12 me. He spoke publicly about some events, but not to having

13 taken part in the conflict. I remember him saying that he was

14 arrested when he went to the village of Vidovici, that he was

15 shot at when he was visiting ----

16 Q. Excuse me, but I am not asking for everything Witness W ever

17 said to you, but only whether or not he told you that he

18 participated in the conflict in central Kozarac. You have

19 answered that. As a matter of fact, you learned from ----

20 A. No, he was in a village. I think he at the time lived at his

21 sister's. Earlier, much earlier, he went to his sister's, to

22 the village. I do not know what the name of the village is.

23 I think Podgradje. That was his sister Dusanka and he was there

24 for a long time.

25 Q. As a matter of fact, you learned from Witness W and others that

26 he was part of a group led by Duca Knezovic?

27 A. Before the war in Kozarac he was on the front as a member of a

28 group under the command of Zoran Karlica. He was on the front

Page 7960

1 in Slavonia somewhere, but not during the conflict.

2 Q. That group led by Dusan Knezevic participated in the war in

3 Kozarac when the conflict began. That was something you

4 learned?

5 A. From the early July of '92, when I was on duties in Orlovci,

6 I heard that his brother was killed, that Dusan Knezevic, that

7 his own brother, he was killed -- he and several other people

8 were killed near Kozarusa. So he was a well-known fighter in

9 the Prijedor region. He was in Slavonia on the front and then

10 later there. Those where the stories that were told.

11 Q. You learned that the group led by Duca Knezevic participated in

12 the war in Kozarac, correct?

13 A. They probably did. I cannot say with certainty. I do not have

14 the real information there, but that was the story. All the

15 people who lived in Orlovci with whom we had contacts and those

16 who worked there before who knew him, they showed him to me

17 sometime early July in 92. He always drove a Mercedes. He did

18 not communicate too much with the people. He would pass and

19 nobody would stop him.

20 Q. That group led by Duca Knezevic also included Zoran Zigic, you

21 learned that as well?

22 A. No, I did not know that.

23 Q. You learned that this group led by Knezevic often visited

24 Keraterm?

25 A. Yes, there were stories in the city of Prijedor, there were

26 stories, during 1993. Many things were being told that people

27 had not been telling earlier, and Duca at that time was very

28 powerful at the time and maybe people in order to sort of put

Page 7961

1 him down, they were telling these things. He was a man who was

2 feared in the city of Prijedor. I know that -- at least this

3 was the story -- he and his men at one point broke, smashed, all

4 the cafes in Prijedor.

5 In Prijedor, there was confusion. They did not know

6 who the authority was. Sometimes it was the military police,

7 sometimes it was -- sometimes nobody had the authority. I think

8 that he and his men were, sort of, borderline paramilitary.

9 Q. I asked you some questions or a question or two about Milan

10 Vlacina. He was Nada Vlacina's husband, right?

11 A. No, Nada Vlacina -- you had a good idea, yes.

12 Q. Milan Vlacina was someone you saw in Kozarac on the first day

13 you visited?

14 A. Yes.

15 Q. He was a tank Commander?

16 A. At that time I did not know, even though he told me. Whether he

17 was a Commander or a member of the crew, I am not sure, but in

18 any event he was part of the crew, the tank crew. When

19 I walked, once I saw him by the tank. That tank was right at

20 the clothing factory and I walked by and he came. But I know

21 from earlier that Vlacina often during '91, there were several

22 attempts to mobilize him and I know he had problems with

23 nerves. He went to therapy in Banja Luka. So he refused to go

24 to the front. That, I know.

25 I know that on one occasion he was even taken to a

26 place near Prijedor. He told me that. They told him, "You are

27 the Commander of this unit", and there were some rocket

28 launchers and that, and he said, "I never knew how to command".

Page 7962

1 He was a very, highly educated man and it was a practice then in

2 Yugoslavia to give highly educated people commanding positions.

3 Q. While he was in Kozarac during the conflict, he saw the men of

4 Momcilo Radonovic, "Cigo", transporting the population from

5 Kozarac?

6 MR. KAY: I think we ought to establish whether the accused is aware

7 of this rather than facts about the person being mentioned by my

8 learned friend being put to him.

9 THE PRESIDING JUDGE: The question is, did he see that happening? He

10 can say "yes" or "no", he did not see it.

11 MR. TIEGER: I will put the question in another way then, your

12 Honour. That is fine. [To the witness]: You are aware that

13 Milan Vlacina was able to see the men of Momcilo Radonovic (who

14 is also known as "Cigo") transporting the population from

15 Kozarac during the conflict?

16 A. No.

17 Q. "Cigo" (or Momcilo Radonovic) was someone who later became the

18 deputy of the municipality in Prijedor, is that correct?

19 A. Early in '93, yes.

20 Q. You are also aware that, in addition to seeing Muslims being

21 bussed to Prijedor and Trnopolje from Kozarac, Milan Vlacina was

22 also in a position to later see people being bussed, Muslims

23 being bussed, to Omarska?

24 A. I do not know what is the truth of all that.

25 Q. That is what Milan Vlacina told you, is it not?

26 A. You mean on the day when we met in Kozarac?

27 Q. On the day you met in Kozarac or during later conversations, is

28 that not what you learned Milan Vlacina had seen?

Page 7963

1 A. During 1992 he never told me about these things, not in '92.

2 Q. You are aware at this moment as you are testifying to this Court

3 that Milan Vlacina was in a position to see Muslims bussed from

4 Kozarac, not only to Prijedor and Trnopolje, but also to

5 Omarska?

6 A. I am not so sure that he was in that situation. I had no way to

7 verify whether this was true.

8 Q. So the mere fact that he told you that makes you uncertain?

9 A. I cannot be sure.

10 Q. He told you that though, did he not?

11 A. During 1993 he said a lot of things, but during 1992 he did not

12 mention those events.

13 Q. According to what you have told us ----

14 A. And when I saw him, he was in a state of shock of sorts. I did

15 not see him sitting in a tank. I cannot say. I said what he

16 told me, that he was a crew member of that tank.

17 Q. You saw the tank?

18 A. Yes, but many people bragged, so I cannot guarantee. I was not

19 in a position to see him in the tank.

20 Q. You told this Court that you were at your checkpoint in Orlovci

21 on the Prijedor/Banja Luka road during July?

22 THE PRESIDING JUDGE: Excuse me, Mr. Tieger, before you move into

23 that area of questioning, we will stand in recess for 20

24 minutes.

25 (11.40 a.m.)

26 (The Court adjourned for a short time).

27 (12.00 p.m.)

28 THE PRESIDING JUDGE: Mr. Tieger, you may begin.

Page 7964

1 MR. TIEGER: Thank you, your Honour.

2 Q. Before we recessed, I had asked you about July 1992 when you

3 said you were at the checkpoint in Orlovci on the Banja

4 Luka/Prijedor road. In mid July 1992, you were aware that the

5 last significant pocket of Muslims left in opstina Prijedor were

6 gathered in the area of Hambarine?

7 A. No.

8 Q. In fact, there were nearly 20,000 Muslims gathered there, people

9 who had fled from other parts of the opstina?

10 A. It is the first time I hear about that.

11 Q. You are aware that they are not there any more?

12 A. I do not know. I have never been to Hambarine in my whole life.

13 Q. You are aware that the Hambarine area is a wholly devastated

14 area?

15 A. I heard that it had been shelled, but I donít know in what kind of a

16 state it is. I think it was on the day when I left Prijedor, on

17 23rd May, at least such were the stories, but I am not sure.

18 Q. How far is Hambarine from the town of Prijedor?

19 A. Well, I do not know. I have never been there. I have heard of

20 Hambarine, but I have never gone there and I could not even tell

21 you what road to take to get to Hambarine.

22 Q. You have never been to the brdo from Prijedor town?

23 A. There are many hills around the town of Prijedor. I do not know

24 which one you are thinking of.

25 Q. The brdo where the villages of Rizvanovici, Biscani, Hambarine,

26 Carakovo and others are located?

27 A. I have heard those names but I have never been in those places

28 -- never in my life.

Page 7965

1 Q. The cleansing of those villages began on about July 20th.

2 A. I do not know.

3 Q. You did not see bus loads of Muslims being taken from the area

4 of Hambarine down the Prijedor/Banja Luka road toward Keraterm

5 and Omarska?

6 A. No. Maybe once or twice I saw some buses, but I do not know

7 where they were coming from, from which area.

8 Q. How were the people on those buses positioned? Were they

9 sitting upright and looking around?

10 A. No, they had their heads bent with their hands behind their

11 heads, and they did not stop in Orlovci. They just drove

12 through, but you could notice that, and I know -- I saw that the

13 driver was wearing a military uniform.

14 Q. A military uniform of the army of Republika Srpska?

15 A. I do not know whose army it was, it was just a military uniform

16 without any insignia. I did not pay attention to that. It was

17 not within our jurisdiction. We had nothing to do with people

18 in uniform who were passing there.

19 Q. While you were at the checkpoint did you ever hear the sounds of

20 machine gunfire for any extended period?

21 A. No.

22 Q. Did you ever hear the sounds of automatic rifle fire for any

23 extended period?

24 A. Well, at the end of July, my colleague, Cvijic, once shot in the

25 air when two vehicles just drove through and did not stop. So

26 he shot, and that was the only shooting incident at the Orlovci

27 checkpoint. Later, I never heard anything similar.

28 Q. My question was, did you ever hear machine gunfire or automatic

Page 7966

1 rifle fire coming, not necessarily from the immediate checkpoint

2 area, but from anywhere in the area where you could hear those

3 sounds?

4 A. No.

5 Q. Was there a camping caravan located at that checkpoint so that

6 the traffic policemen or the military policemen could get some

7 rest or some sleep?

8 A. When I started my duty at Orlovci there was nothing at that

9 moment, but later the military police brought some -- a trailer

10 and they were using it, but they did not use it for sleep. The

11 trailer was used mainly as a kitchen, to eat there -- at least,

12 that is how we used it, me and Cvijic and Brdar. We never had

13 the possibility of sleeping there. I know that the things we

14 had with us we would usually leave them in the car which had

15 taken us to work and, as far as I know, neither the military

16 police slept there. It was not common. I think nobody ever

17 thought of doing such a thing.

18 At that time in June/July, well, most of the time we

19 spent outside. We did not even sit in the car. It was

20 difficult to stay in the open. We were afraid. So, on one side

21 of the car there was a small shelter and we mainly spent time

22 there and we would move it, we would never be at the same place,

23 and we would stay awake all the night in case of night duty.

24 Q. During your earlier testimony, you discussed at some length your

25 involvement with the group of Kozarac citizens which met on two

26 occasions with the Crisis Staff in Prijedor. Is it not true

27 that you met, not just on those two occasions with the Crisis

28 Staff in Prijedor, but there was a third occasion when you met

Page 7967

1 with the Crisis Staff in Prijedor?

2 A. No, it is not true. Only two times we met. Aside from that,

3 I do not know whether you are referring to the civic forum. If

4 you are referring to the civic forum, we met twice. As for the

5 citizens of the Kozarac Local Commune, we had another meeting at

6 the beginning of August when we filed a request to revoke the

7 decision whereby resettlement of Kozarac was prohibited. It was

8 with Bosko Mandic, with the President of the Crisis Staff, but

9 that was not the same group of people.

10 Q. I am referring to the civic forum. Is it not true that before

11 the meeting between the members of the civic forum, the people

12 from Kozarac and the members of the Krizni Stab, the Crisis

13 Staff, you met privately with the Crisis Staff Commander,

14 Stakic, and with SDS President, Miskovic?

15 A. No, it is not true that I met with them privately. It was a

16 meeting -- it was the agreement we had reached during the first

17 meeting. It was an agreement with the residents, with the

18 members of the civic forum. We once talked over the telephone

19 with them. It was Susic's telephone. Then we waited again and

20 then we called again. They did not want to receive us. They

21 said that if we are talking about the same people, we would not

22 receive anyone. So I talked to Susic. I wanted to know who

23 would be present because I had never attended meetings of the

24 civic forum before, and he told me approximately who would be in

25 the group. He said that the people who had negotiated before

26 would not be there, not the same people. They told me, "You

27 should go there" and then I said, "OK, I will go there one hour

28 earlier and then you will wait for me, and I will go out and

Page 7968

1 then later on I will tell you whether we will be received",

2 because there was a possibility of not being received at all.

3 Q. You were the one who contacted Miskovic and Stakic, correct?

4 A. Well, they told me to do so, and that is what we did. It was

5 part of our agreement because when I first talked to them over

6 the telephone nobody wanted to talk to me. They did not connect

7 me to anyone. The man on the switchboard, he said, "What kind

8 of agreements are you talking about? Those talks are over".

9 So when I went there I told them about the delegation

10 of the forum. I told them who the persons were, some positive

11 things about them. I also told them that those were not the

12 same people who had negotiated before, but later on it turned

13 out that there was one person there, Ilijaz Memic, who had had

14 talks before. That is what we realised at the meeting.

15 Q. In 1992 you had a police uniform, is that right?

16 A. Yes, when I started to work at Orlovci, yes.

17 Q. What other kinds of uniforms or uniform did you have?

18 A. I had the same uniform, as I described previously, the summer

19 uniform in the form of overalls. That is what my brother had

20 given me before in Banja Luka.

21 When Kusota, Kusota, when he deserted, gave me the

22 rifle, he brought some bag with parts of the uniform that he

23 had, which means -- the uniform was the SMB uniform but that

24 I never really wore it. I left it in Kozarac.

25 Q. So you had a police uniform, the camouflage uniform you

26 described, and an SMB uniform?

27 A. No, I did not have the SMB uniform. I left it in Kozarac and I

28 never took it. I never went to get it because, first of all, it

Page 7969

1 was not my size. This man is smaller than me. I would have

2 maybe taken it if it had been the right size.

3 Q. Your attorney asked you a question about the interviews which

4 were conducted both after your arrest in Germany and then here

5 in The Hague. The German authorities were also interested in

6 the question of uniforms. They advised you that there were

7 allegations that persons who participated in the conflict in

8 Kozarac had worn camouflage uniforms. Do you remember that?

9 A. It is possible. I do not recall exactly, but before the

10 conflict in Kozarac I saw many people wearing uniforms,

11 camouflage uniforms, but it is a general term. I do not know

12 what they were referring to, whether they were referring to blue

13 camouflage uniforms, green ones or yellow ones. It is a general

14 term, "camouflage uniform", for all kinds of uniforms that could

15 be used as camouflage uniforms. So it was not very clear what

16 colour they had in mind.

17 Q. Yes. The term "camouflage uniform" does cover a range of

18 possible colours, as you have indicated. But the German

19 authorities asked you, "Mr. Tadic, do you own a camouflage

20 uniform or other military uniform or have you ever worn one?"

21 You told them, "No", isn't that right?

22 A. I do not know. It is possible.

23 Q. You described the ----

24 MR. KAY: Can my learned friend actually recite the full answer that

25 the defendant gave in answer to this question, as it does not

26 just end at that?

27 MR. TIEGER: I would be pleased to. As a matter of fact, Mr. Tadic,

28 what you told the German authorities was this. They asked you,

Page 7970

1 "Mr. Tadic, do you own a camouflage uniform or other military

2 uniform or have you ever worn one?" You said, "No, no, as far

3 as the camouflage uniform goes. As to the rest, some

4 qualifications are called for. During my activity in Orlovci,

5 during the day time I wore blue trousers and short sleeved light

6 blue shirt also with police insignia, and at night I also wore a

7 jacket. Now, this is the uniform of the police unit I was

8 serving with. Owing to the insignia and the uniform I was

9 wearing, an outsider would in no way conclude I was in the

10 military but would categorise me as a police officer".

11 A. Yes, that is what I told.

12 Q. As a matter of fact, you wore a camouflage uniform, at least you

13 have admitted wearing a camouflage uniform, at the checkpoint

14 itself?

15 A. What they were referring to, I do not know, but at that time

16 I thought that they were referring to a military uniform, a

17 multi-coloured uniform with stripes, green stripes and blue in

18 colour. I do not know what colours they were. I was not

19 referring to a spotted type of uniform and I did not think that

20 that was a camouflage uniform, because it is a type of

21 camouflage uniform that you wear on top of regular uniform.

22 Personally, I do not know that uniform, who it belonged to, the

23 one that I was given by my brother.

24 Q. When were you given that uniform by your brother, when was that?

25 A. It was before I went to Trnopolje. I first talked to him and

26 then he gave me this uniform and then I went home. I put it

27 on. Then I left with Jovo and left. It was after the incident

28 he had had in Kozarac, we were told that we should not move

Page 7971

1 around without uniform after that.

2 Q. As a matter of fact, Mr. Tadic, the three uniforms you refer to,

3 the police uniform, the spotted camouflage uniform, which you

4 say your brother gave you and the SMB uniform that you say you

5 received from Kusota, were not the only uniforms you had, isn't

6 that right?

7 A. There was a uniform, a police uniform, a winter uniform, which

8 I did not use most of the time. It is a very thick type of

9 uniform. It is a blue one that we were issued in Prijedor, but

10 we did not wear it at that time. Sometimes at night, yes, but

11 it is all part of police uniform and I do not remember having

12 any other uniform.

13 Q. You received in that bundle from Kusota, according to you, not

14 only an SMB uniform but a camouflage uniform, isn't that

15 right?

16 A. No, I do not think it was there. I never used his uniform.

17 I said that I had received that, but it remained in the house

18 and I never used it.

19 Q. You made reference in testimony to an automatic rifle?

20 A. Yes.

21 Q. That is the rifle you took with you to Trnopolje camp?

22 A. Yes.

23 Q. Where did you get that rifle?

24 A. I got it before from Kusota. He is the owner, Mile Kusota, and

25 it was given to me by his brother Rade in Kozarac. I think it

26 took place at the end of '91.

27 Q. That is what your wife has also told us and your brother has

28 also told us, correct?

Page 7972

1 A. I do not know what your question is?

2 Q. Your wife and your brother also told the Court, testified to the

3 Court, that you got this rifle from Kusota?

4 A. As far as I can remember, yes, because my wife should have known

5 that because she received from Kusota's mother some beans

6 because they thought that that would relieve his son of the

7 military duty in Croatia. That is why she should have known

8 about that.

9 Q. Can we have Exhibit 148, please? This document is a certificate

10 whereby it is certified that Dusko Tadic, rank soldier, has

11 signed out an automatic rifle, with the number given, with 300

12 bullets, and that that weapon and ammunition were issued to you

13 for the purpose of carrying out the given orders. It is signed

14 and stamped by Lieutenant Colonel Milorad Sajic on behalf of the

15 Territorial Defence for the municipality of Banja Luka on May

16 4th 1992. This document was found in your house after your

17 arrest when German authorities searched your house, is that

18 right?

19 A. Yes, yes, I remember this paper.

20 Q. Where did you get this paper?

21 A. I got this paper from my brother Ljubomir in Banja Luka on the

22 date which is indicated here. I filled it out myself in Banja

23 Luka. This information here, Tadic Dusko and other data, were

24 handwritten by me. He had given me a blank, an empty form

25 because he knew that I had a rifle in Kozarac, and people were

26 saying that those weapons would be taken away by the authorities

27 in Prijedor. So he was afraid that it might happen, because it

28 was not only a question of having your weapons taken away; there

Page 7973

1 was also a problem of mobilization, or I could have been also

2 punished somehow because I did not have any papers for that

3 weapon that Kusota had given me. So that is why my brother gave

4 me this form and filled it out and I took it to Kozarac. So

5 that is why I kept it.

6 As for the quantity of ammunition, it is just a rough

7 quantity. I do not know whether I really had the exact amount

8 of ammunition. I know that Kusota had given me two cartridges,

9 but I just put here 300, just like that. I did not think too

10 much about that.

11 Q. So Kusota gave you two cartridges, as your wife testified, but

12 you wrote down 300?

13 A. Yes -- no, I got this form from my brother in Banja Luka. It

14 was empty. It just had a stamp and the signature here. It

15 happened on the day I evacuated my family. It was on 3rd May

16 and I got this paper the next day, the 4th May '92.

17 JUDGE STEPHEN: I wonder if you can find out what a "cartridge" is?

18 MR. TIEGER: OK. Mr. Tadic, by "cartridge" you are referring to the

19 clip that goes into an automatic weapon?

20 A. Yes, yes.

21 Q. Each clip contains how many bullets?

22 A. I do not know how many exactly, I never counted them, and I do

23 not know. I never had the opportunity to shoot out a clip so

24 I did not really know.

25 Q. We have heard other testimony in Court that there are 30 bullets

26 in a clip. Would you disagree with that?

27 A. No, I do not think there are that many.

28 Q. I wanted to clarify something you talked about at the end of

Page 7974

1 your direct testimony. When you left Prijedor, you went to

2 Banja Luka, in 1993, when you finally left Prijedor?

3 A. You mean in August?

4 Q. Yes.

5 A. Yes, yes.

6 Q. How long were you in Banja Luka?

7 A. For a long time. I stayed throughout September and I think

8 I left for Belgrade in October. At that time again there were

9 several reasons. First of all, you could not leave easily

10 because the controls were very strict, so my brother again found

11 a certificate for me.

12 Q. Mr. Tadic, sorry to interrupt you, but I want to stick to one

13 question at a time. How long were you in Belgrade?

14 A. I think until the beginning of November 1993.

15 Q. Where did you go from Belgrade?

16 A. During my stay in Belgrade I visited the Red Cross, the UNHCR

17 seat and the Human Rights Committee of the United Nations in

18 Belgrade. Only after that did I leave Belgrade. I mean, I left

19 Belgrade for Nuremberg. It could have been around 20th

20 November. I am not sure.

21 Q. How did you get from Belgrade to Germany?

22 A. By coach.

23 Q. How long were you in Nuremberg?

24 A. I stayed overnight in Nuremberg and the next day I spent it in

25 Nuremberg as well, and then I left to Munich with my brother.

26 Q. Mr. Tadic, I want to discuss with you the period of time around

27 the time you were mobilized or around the time you indicated in

28 direct testimony that you were mobilized. You testified that on

Page 7975

1 June 15th, a Monday, you left Banja Luka early in the morning by

2 train?

3 A. Yes.

4 Q. You were traveling alone?

5 A. Yes, I travelled alone. If I stated otherwise somewhere,

6 I probably made a mistake.

7 Q. You were met by Vokic in front of the police building. After a

8 discussion with Jankovic and Prpos, you were accepted into the

9 reserve force and then you spent that night in Prijedor at

10 Vokic's place?

11 A. On Friday, I told them that I would come the next working day

12 and I talked to Vokic and then he met me, took me to Dusan

13 Jankovic for an interview. It was all in the morning.

14 Q. Of June 15th?

15 A. Yes, yes.

16 Q. That night you were at Vokic's place and that was the only night

17 you ever spent at Vokic's place?

18 A. Later I was coming to his place. I do not think I slept there,

19 but I was coming to his place where he lived with his wife.

20 Q. The next day, the 16th, you were on duty at Orlovci on the

21 Prijedor/Banja Luka road?

22 A. Yes.

23 Q. Then you also testified that you fetched your wife and brought

24 her to Prijedor on 17th?

25 A. I am not sure that that is that exact date, but anyway, I knew

26 that she had to report to work by June 20th. I know that once

27 after the duty, went to Banja Luka and I brought her back.

28 There was a truck that was going towards Serbia, but I am not

Page 7976

1 sure if that was that exact date.

2 Q. I believe you testified that was on your second day of duty?

3 A. I do not remember exactly. It took place before June 20th.

4 That, I do know, because that was the deadline for her to

5 report to work.

6 Q. So you went to Banja Luka to get her?

7 A. Yes. She did not dare come, knowing, based on her previous

8 experience. There was a curfew in Prijedor at the time,

9 10 o'clock till 5.00 in the morning. There was no movement.

10 Q. So you spent the night in Banja Luka with her and brought her

11 back in the morning?

12 A. Then when I visited her? I am not sure about the date really.

13 Yes, yes, the first time. I went there twice to get my wife

14 during June of 1992, and once she came by herself with her --

15 with my mother and the children and they never went back.

16 Q. In any event, it was your recollection during your direct

17 testimony that you went to fetch her from Banja Luka on the

18 second day of your duty, 17th?

19 A. I am not sure that it was the second day of my duty. At first,

20 I was not sure whether my first day on duty was Monday or

21 Tuesday, what was counted. I was not sure whether I was

22 mobilized on a Monday or Tuesday. Then later in the book I saw

23 that it was a Tuesday, so I cannot be sure whether I went there

24 on Wednesday or Thursday. I cannot say that with any

25 certainty. It is very hard to remember that date. It was not

26 anything significant. There was nothing significant. I know

27 that after that I went to duty.

28 Q. On the day you fetched your wife from Banja Luka and were on

Page 7977

1 duty at the checkpoint, that night you and your wife spent the

2 night at the home of Martin and Mileva Dzaja, correct? You have

3 testified to that.

4 A. When we came back we slept together in the house of Mileva

5 Dzaja.

6 Q. Your wife told us that she went back to Banja Luka the next day,

7 the 18th?

8 A. I do not know if it was the 18th. All this took place, her

9 coming and her return, all took place before June 20th, but I am

10 not sure if it was on 17th, 18th or 19th, I am not sure. It is

11 true that she returned to Banja Luka by herself, that is true.

12 Q. Well, let us look at what you said about those dates before,

13 Mr. Tadic. You have referred before to interviews which were

14 conducted here in The Hague. Those interviews were conducted by

15 Mr. Reid in the detention facility at Scheveningen. You were

16 warned, advised of your rights to remain silent before the

17 interview, each interview began. Do you remember that?

18 A. Yes. I asked to talk, even before in Germany and here also.

19 That is no secret. I wanted to talk.

20 Q. Your lawyer was with you at all times?

21 A. Yes, absolutely. I asked for those interviews. I asked to

22 testify here. I do not think I have anything to hide.

23 Q. You spoke about coming to Prijedor from Banja Luka to Mr. Reid.

24 For the benefit of counsel I am referring to page 58 of the

25 December 22nd interview. You told him that on 15th June you

26 were staying in Banja Luka together with your family. "On that

27 day, as also before, we lived in a house in the street of Koste

28 Jarica. On 15th June 1992 I was in contact, that is I spoke

Page 7978

1 with my wife, Mira Vidovic, that is Mira Tadic, with Ljubomir

2 Tadic, with Slavica Tadic, with Zlatko Bajic." You also talk

3 about a number of other persons you talked to, about being in

4 the restaurant Skala. That is in Banja Luka, right?

5 A. Those days I had contacts with those persons, but I do not know

6 if it was all on the 15th or the 14th or some other date.

7 Anyway, those were the persons with whom I was in contact in

8 Banja Luka at that time.

9 Q. Then you continued to describe the events of that period of time

10 to Mr. Reid on that occasion and on other interviews. In May,

11 on May 10th in fact, you discussed your mobilization. Now I am

12 referring to page 76 of the May interview. You told

13 him: "I remember that on June 16th in the morning I came with my

14 brother to the centre of Prijedor." That is your brother

15 Ljubo?

16 A. I thought of him, yes, I had him in mind. I know that

17 I travelled with him from Banja Luka, but then on that first

18 day, I cannot remember the exact date, but on the first day of

19 my mobilization he was not with me. He only went to Kozarac

20 twice and then was coming later to Prijedor, but he was not

21 there on the date when I was mobilized.

22 Q. "I came with my brother to the centre of Prijedor. Radovan

23 Vokic, a policeman, took me to the Commander, Dusan Jankovic,

24 and staff Sormaz. Then I was told, they told me that I would be

25 mobilized in the reserve unit of the traffic police. I had then

26 met the Commander of the traffic police, Djuro Prpos. I handed

27 over my illegal rifle that on the same day was issued to me by

28 the police. Signed out. He told me that I was free then and

Page 7979

1 that I should report to work tomorrow morning. I know that

2 I had spent that night at the place, at the apartment, of

3 Radovan Vokic and Dusanka Vokic." That is what you told

4 Mr. Reid in May.

5 Now you also discussed the same period of time in

6 December with him. On that occasion in December 1995 you said

7 this, did you not, Mr. Tadic. Page 74 of the December

8 interview. "On 16th June 1992 I came with my brother Ljubomir

9 by train from Banja Luka, and I was mobilized by traffic,

10 reserve traffic police in Prijedor. After I was formally

11 mobilized, together with my brother and Radovan Vokic, I went to

12 the town centre and we went to a cafe bar next to Hotel Balkan

13 where we had a drink. Afterwards I noticed in the street

14 Beslagic and after sometime I called or I guess I invited my

15 brother together with Meho Beslagic. We went to the cafe

16 restaurant Aero Club where we sat in front of the Aero Club in

17 the terrace at Aero Club where we discussed the previous events

18 that took place in Prijedor and in Kozarac. Now sometime before

19 1 o'clock p.m. my brother Ljubomir took the train and left for

20 Banja Luka. I stayed for a short time with Meho Beslagic and we

21 also agreed to meet again in the following days. Now between 2

22 p.m. and 6 p.m. I was in the apartment of Jelena Gajic and

23 Zare. I had lunch there. I also speak with Milka Gajic. Now

24 also on that occasion it was the first time that I had seen

25 Nevenka Tadic and Jasminka Salkanovic and her son, the first

26 time since the conflict broke out. Also present was Zare Gajic

27 and his aunt, Dzaja Mileva. Now somewhere between 6 p.m. and 7

28 p.m. I went to the apartment of Radovan Vokic and there together

Page 7980

1 with his wife, Dusanka Vokic, we had dinner. Then we stayed for

2 sometime up and then went to bed."

3 All on 16th June, the day you say you were mobilized

4 in these interviews, the day you said you were mobilized in May

5 1995 and December of 1995. In fact you have said on a number of

6 occasions, have you not, that you were not on duty the first day

7 you were mobilized, isn't that right?

8 A. I was not on duty when I came to Prijedor and that was something

9 that was not fully clear to me. I was not sure about the date.

10 I thought that that was the date that I was mobilized. But

11 I was mobilized on the day when I started my duty. The quotes,

12 what you quoted, there were such meetings but maybe not on the

13 dates. What I have described, it is difficult to know whether

14 it was on 16th or on another day. But in June I met Meho and I

15 was in the Gajic apartment and I saw those people and my brother

16 was coming and we sat together with Meho, but it not all of this

17 could have taken place in a single day. I told what happened

18 and with whom I met.

19 Q. Well, let us talk about what happened then on 17th, or at least

20 what you say happened on 17th or said happened on 17th when you

21 were interviewed in May and December. Page 51. Here in another

22 interview you talked about being mobilized -- for the benefit of

23 the interpreters it is sections 113 through 115. They have some

24 markings and they can follow more easily.

25 You described again in detail -- I am sorry, this is

26 December -- again in detail what happened on the 16th, and

27 talked about how you and Ljubomir went to the cafe bar

28 restaurant, Aero Club. How Ljubomir left back to Banja Luka,

Page 7981

1 you went to the Gajic family apartment and then spent the night

2 of the 16th and of the 17th, those nights you spent in the house

3 of Radovan Vokic and Dusanka Vokic. You said how, "I can

4 remember very well that on 17th June 1992 in the morning I,

5 together with Radovan Vokic in an official car we left. We went

6 to the police station in Prijedor." That is what you said in

7 December '95, didn't you?

8 A. Yes, I said that. I thought that it was 17th and it is always

9 about the first day when I came to Prijedor, and when I went

10 with Vokic to -- and that date was also entered as the first

11 date of my duty in my military book. I simply said what

12 I thought. I thought that that was that date. I could not

13 remember the right date, but the event is correct. I first went

14 to duty with Vokic from his apartment.

15 Q. Well then, let us talk about June 18th. That is the day your

16 wife told us she went back to Banja Luka after the two of you

17 spent the night at the home of Martin and Mileva Dzaja. On page

18 59 (reference numbers 119 and 120 for the interpreters), you

19 described again the 17th in great deal. As to the 17th June

20 1992 you say: "I would just like to say one more thing which

21 I remember very well, and that is after my, after I finished my

22 duty controlling the traffic post in Orlovci, I went to Pecani,

23 to the settlement of Pecani, planning to sleep, spend the night

24 in the house of my friends, and in the settlement of Pecani

25 I met with Nada Vlacina and that was somewhere between 4.00 and

26 6.00 p.m. and her husband Milan Vlacina. I remember he was not

27 at home. He was on duty because he was a reservist in the

28 army. Then from there I went to the apartment of the Gajic

Page 7982

1 family and then decided to spend the night at the apartment of

2 the Vokic family." That is your description of 17th.

3 You go on: "As to 18th June 1992, I can tell you the

4 following. I was a member of the reserve police in Prijedor,

5 was a member of the traffic police in Prijedor. During the day

6 I mainly stayed in the town of Prijedor and on that occasion

7 I had contacts with Jelena Gajic, Zare Gajic, Mileva Gajic and

8 with Salkanovic Jasminka and her son and with Nevenka Tadic.

9 From in front of the police station in Prijedor I went on duty

10 together with Miroslav Cvijic and Miroslav Brdar. We went with

11 the police Golf which was driven by Miroslav Brdar and I was on

12 duty from 9.00 p.m. till 7.00 a.m. the following morning."

13 A. The descriptions are fairly correct, but not the date. I really

14 do not know the date. It is hard, it is hard to remember the

15 date. I had contact with all the people in the way that

16 I described, but I cannot recall whether if it happened on that

17 date. But it happened during June 1992. I would eat lunch

18 every day with Jelena Gajic and any time I was free, and that is

19 where I would meet people that I quoted, and I know that when

20 I visited Nada her husband was not there and so I had planned to

21 spend the night there, but then I decided otherwise. So those

22 were the people with whom I met there.

23 Q. Let us see what you said about June 20th. Page 16, reference

24 121. "As to 20th June 1992, I went to my duty post in Orlovci

25 together with Miroslav Cvijic and Miroslav Brdar. I was on duty

26 as a reserve policeman, traffic policeman, controlling the

27 traffic on the road from Prijedor to Banja Luka from 3.00 p.m.

28 till 9.00 p.m. Apart from those persons with whom I had

Page 7983

1 mentioned previously on that day, and also on the following

2 days, during my duty hours I had contact with Slavica Aleksic

3 who would every day go to Prijedor where she worked as a

4 waitress in Hotel Balkan, and also after finishing her work in

5 Prijedor she would go back." You mentioned Djurdevic Mirko.

6 "I would go from Prijedor to another location where he worked

7 and then back again." You mentioned Milomir Stakic, the

8 Commander of the Krizni Stab who worked in Prijedor but lived in

9 Omarska.

10 A. Yes, those were the people who were passing through the

11 checkpoint every day. There is a mistake. Mrs. Lukic, I did

12 not know her last name at the time well, but Mr. Reid insisted

13 on the dates and so I tried to remember the dates the best

14 I could. I am not sure that they were right, but the events

15 I described are all right.

16 Q. Did Mr. Reid insist that you tell him on more than one

17 occasion, "I remember very well"?

18 A. Maybe he did not insist that much, but I tried to make

19 it -- I knew that if my lawyers co-operated with the authorities

20 of Republika Srpska, I knew that there would be documents, that

21 there would be exact dates of my duties and one day if this

22 co-operation came to be that it would all be made public.

23 I tried to remember. I could not remember all the days.

24 I tried to create a picture of what happened there.

25 Q. You had those documents during your interview with Mr. Reid,

26 didn't you?

27 A. Yes, again, I would again sign them all and I would again tell

28 the story. The events are true. The dates I could not

Page 7984

1 remember. That is not possible.

2 Q. Your Honour, I am about to move on to -- let me just have a

3 moment.

4 THE PRESIDING JUDGE: Mr. Tieger, what documents were you referring

5 to when you said that Mr. Tadic had them during the interview?

6 MR. TIEGER: By "those documents", Mr. Tadic, I am referring to the

7 rosters that were introduced into court. Those are the

8 documents you had during the December interviews, right?

9 A. I do not know if I had them. I do not remember. Maybe I did

10 have them. Maybe I had them. I tried to remember everything.

11 MR. TIEGER: Your Honour, I will be moving on to a new subject. It

12 will consume more than five minutes, I believe, so I can

13 partially cover it or ----

14 THE PRESIDING JUDGE: We will stand in recess until 2.30.

15 (12.55 p.m.)

16 (Luncheon Adjournment)

17

18

19

20

21

22

23

24

25

26

27

28

Page 7985

1 (2.30 p.m.)

2 THE PRESIDING JUDGE: Mr. Tieger, you may continue.

3 MR. TIEGER: Thank you, your Honour.

4 Q. I would like to ask you some questions now about the time period

5 between May 23rd, the day before the attack on Kozarac, and the

6 date you say you were mobilized. You testified before this

7 Court that on May 23rd you travelled with Trivo Reljic and

8 others to Prijedor and from there took a train to Banja Luka at

9 about noon, and once in Banja Luka you went to the house on

10 Koste Jarica Street. You indicated that you returned to Kozarac

11 during the period of time before you were mobilized, and you

12 said on page No. 5967 that you returned to Kozarac on June 1st

13 by train with your brother, and then returned that same day to

14 Banja Luka at dusk after being at Lamovita and in Kozarac. You

15 also spoke with Mr. Reid about this time period as well -- you

16 recall that?

17 A. I do not recall. We discussed everything, but I do not know

18 specifically what I did not -- I was not paying attention.

19 There were several questions relating to 1990, '91, '92, so it

20 is quite possible that we discussed that period as well.

21 Q. Is it also possible that when you talked to Mr. Reid about the

22 first time you say you returned to Kozarac after leaving on May

23 23rd that you said you went back at the beginning of the first

24 week of June and stayed at the Timarac' house for several days?

25 A. It is possible that I said something like that.

26 Q. Would it be helpful if I read the specific references?

27 A. No, it is OK. I believe you. It is quite possible.

28 Q. When you spoke to Mr. Reid a second time about the time period

Page 7986

1 between May 23rd and the date on which you say you were

2 mobilized, did you tell Mr. Reid that you returned on May 30th,

3 went back to Banja Luka the same day, stayed one day in Banja

4 Luka and then returned to Babici again?

5 A. It is possible again. When it comes to dates, I cannot say

6 anything. I know that the first visit to Timarci, Lamovita and

7 Kozarac took place before I went to Trnopolje. Trnopolje is the

8 period which I can recall with most certainty. I know it was a

9 weekend and I know that this first visit took place before

10 that. I know that because in that period I met in Banja Luka,

11 in Starcevica neighbourhood, I met with Kahrimanovic and I

12 talked to him and he told me that should I go there once again

13 that I should visit his house also.

14 I remember that I said to people in Trnopolje that

15 I had been to Kozarac. When I met to Turkanovic and Ferid

16 Gunjic, they asked me about Kozarac and I told them I had been

17 there once and I described them what I had seen. That is how

18 I remember that I visited Kozarac only once before I went to

19 Trnopolje. I cannot tell you exactly whether it was on the

20 1st. It is quite possible, but I would not be surprised if it

21 was otherwise.

22 I could not remember dates. That is why I keep

23 referring to that visit to Trnopolje, because there were several

24 mobilizations in that time, and the mobilization which took

25 place on 16th was rather important and I know that it was a

26 weekend when I went to Prijedor when I was mobilized into the

27 police, and I believe that there had been an attack during the

28 weekend at Prijedor.

Page 7987

1 I know they were discussing the state, the war state,

2 in Prijedor and I remember I visited the family house of Gajic

3 family and they showed me some holes in the walls and they were

4 saying that there had been an attack on Prijedor. That is why

5 I remember those events, but I cannot tell you the exact dates.

6 It is very difficult. It is difficult even for those who

7 mentioned dates here in the Court. It is difficult to tell with

8 certainty.

9 The same is with holidays, you tend to remember

10 certain holidays, the 1st May or 25th May, which used to be

11 Tito's birthday. Those were the dates we would often remember,

12 remember easily. But, as for any other dates, it was quite

13 difficult unless you had some official documents like military

14 books, the official documents which can be found in the Prijedor

15 town hall. If I had those documents, I would be more specific,

16 but I cannot simply forget my meeting certain people and what we

17 discussed and so on. I told you about the places I visited and

18 the people I spoke to, but it is difficult to say -- for

19 example, when it comes Hambarine, I can tell you with certainty

20 that I have never been there. That is what I know for sure.

21 Q. Let us forget specific dates for a moment then. The German

22 authorities were also very interested in this period of time,

23 the period of time between shortly before the attack and the

24 date on which you say you returned from Banja Luka to Prijedor.

25 They explained to you that they were interested in it because

26 there were allegations that you had been in Kozarac and

27 participated in the conflict.

28 A. I was not talked about in relation to the conflict. I was only

Page 7988

1 accused for alleged killings of people in Omarska. There were

2 no charges in relation to Kozarac. At that time there was only

3 one alleged act which then was extended and the same pace

4 continued here. At first, Kozarac was not mentioned at all. It

5 was just a general story about the area.

6 Q. I am going to refer your counsel to page 11 of the second day of

7 the German interviews on which you were asked the following

8 question, Mr. Tadic: "Mr. Tadic yesterday when providing

9 information about the individual, you said that on 23 May 1992

10 and until 16 or 18 July you had been at your family's in Banja

11 Luka". You later corrected July to June when you saw your

12 military book or learned the date in your military book.

13 The quote goes on: "What do you respond to statements

14 by witnesses that in the meantime you returned to Kozarac and

15 played an active part in the taking of the town by the Serbs?"

16 That was the question. You said: "As far as I can remember,

17 the war began on 24 May 1992 in Kozarac and I did not return to

18 Kozarac in the above mentioned time period".

19 A. Yes, I remember that answer, although I think that when they

20 asked me that they phrased their question as to -- they wanted

21 to know where I lived at that time, not where I was. We

22 discussed it later on, because it was difficult to explain what

23 their intention was, what they wanted, and the question that

24 I gave them. I realised they were interested in knowing where

25 I was living at that time with my family, and I remember that

26 they claimed that I had gone back to live in Kozarac with my

27 family.

28 So when I was relating about those events, I was

Page 7989

1 referring to the life of my family in Banja Luka. We were not

2 discussing -- it is possible that they asked me about an active

3 participation in those events. So I probably gave them a

4 similar answer because I know I had not taken any active part in

5 the conflict in Kozarac.

6 Q. Mr. Tadic, perhaps it will surprise you to learn that the

7 Germans anticipated this problem and assertion and so pressed on

8 and again asked you,: "I am now asking you again expressly, in

9 the period in question were you only in Banja Luka and nowhere

10 else?" Answer: "I was only in Banja Luka."

11 A. Well, their question was, "Did you live in Banja Luka and

12 nowhere else?" and my answer was always, "I lived in Banja

13 Luka", and not "I was".

14 I was in Trnopolje and they put the same question in

15 relation to Trnopolje, and they asked me in a similar way about

16 Trnopolje and Orlovci, but that is different. I thought that

17 I lived in Banja Luka until the moment my family moved to

18 Prijedor. I did not have anything in Prijedor. I did not have

19 any clothing and I was living at various different -- at various

20 places. That is what I had in mind when I answered. It may

21 have been interpreted in a different way, but that is what I was

22 thinking.

23 Q. Of course, you told the German authorities that you slept in

24 Banja Luka every night?

25 A. When I was in Banja Luka I slept in Banja Luka.

26 Q. Exactly.

27 A. Well, it could not be that I was either in barracks or at the

28 front.

Page 7990

1 Q. Mr. Tadic, you spoke in your testimony at page 4992 of the

2 transcript that you wanted to report yourself as a refugee in

3 Banja Luka, but you could not because there were some laws of

4 which you were not aware. Indeed, you tried to but they told

5 you there was no way, that first you would have to report to a

6 military office.

7 In fact, on an earlier occasion you attempted to

8 explain the fact that you were not on the refugee list in Banja

9 Luka in a different way. You said on a previous occasion that

10 the reason that you were not on the refugee list was not because

11 you tried to register, but because you were ashamed to be a

12 refugee, isn't that right?

13 A. Well, both are correct, but in any case I tried. I remember

14 taking some food from the Red Cross at one occasion and together

15 with my brother I brought that food to Starcevica. I was

16 ashamed of having done that, let alone being on their list.

17 I was not considered to be such a poor man which I was at that

18 time.

19 Q. When asked about that by Mr. Reid, you only told him that you

20 were ashamed to be a refugee, not that you had tried in any way

21 to get yourself on the list? It is only here in Court that you

22 have tried to say that you made an effort to do so, isn't that

23 right?

24 A. Well, it is possible, but I did not insist to be put on that

25 list. I asked, I enquired, about the procedure because my

26 family could not obtain the status of refugees through regular

27 procedure because they told me that, "We do not have anyone from

28 Prijedor, you are the only ones". So it was simply not

Page 7991

1 possible. All the rights that I could have, they told me that

2 I should have them in Banja Luka.

3 When I left Prijedor, I cancelled my residence from

4 Prijedor and you have in my identity card "residence cancelled",

5 I believe it was in July, in favour of Banja Luka, but I could

6 never register in Banja Luka, and when I asked they told me it

7 was not possible. I needed certificates from the military

8 office. The priority was the military book. It was a law. You

9 could not do anything without a military book. If you wanted to

10 have any rights whatsoever, it was impossible without that.

11 So each time, and I said I had proof that my family

12 house had been destroyed in Kozarac, and they told me that

13 I should go to Prijedor and have my rights regulated there. So

14 I would go back to Prijedor to get some kind of status and it

15 was simply impossible, and I realised that it was impossible to

16 obtain any rights if you were not a member of the army.

17 When you asked me about the people of Muslim

18 nationality, the same procedure, the same law, applied to

19 everyone. The law of Republika Srpska did not specifically

20 state. There was a general law that only those people who had

21 taken part in war had the right to obtain status. So a wife,

22 for example, could not obtain a job if she did not have a

23 certificate whereby it was certified that her husband had been a

24 member of the army.

25 It was a general procedure in Republika Srpska at that

26 time and I think that the same situation was elsewhere, and that

27 very procedure forced people to leave. That is why I had to

28 leave and I think that many Muslims and Croats had to leave the

Page 7992

1 area because of that, not because they were being evicted, but

2 simply they could not regulate the rights of their status if

3 they were not members of either the military or the police. At

4 that time companies were not working.

5 Q. Yesterday you discussed the procedure by which you obtained

6 accommodation in Pecani. You described how you went to the town

7 hall, asked for accommodation, said you were with the police,

8 which was a kind of condition, and the clerk sent you to Pecani

9 to the commission in charge of making lists of apartments

10 available.

11 Did you receive any kind of special treatment to get

12 this apartment of Hasan Tulundzic or did you just go through the

13 normal procedure that a reserve traffic police officer would?

14 A. It is not only a procedure whether you were military or

15 policeman. You simply had to be somewhere to be a conscript,

16 either a member of the reserve force. It applied to anyone, to

17 members of Crisis Staff and so on. If you wanted to leave or

18 travel to Prijedor or Banja Luka, you just needed a certificate,

19 you needed something.

20 First, you had to present, to produce, the military

21 book. At that time it was considered as an identification

22 card. My treatment was the same as the treatment of any other

23 people. Only those who were members of the police or the

24 military could obtain the same rights. That was some sort of

25 unofficial rule, and when I discussed that with the person who

26 was in charge, he went to talk to someone and when he came back

27 he told me that he had met with the President of the Executive

28 Council and later on, when I said after a certain period when

Page 7993

1 I moved there, I told them that I did not have a written

2 decision to be there, and Miskovic said, "Well, that is not a

3 problem, nobody has a decision". When I went there, I did not

4 know whether the apartment used to belong to Tulundzic or

5 someone else. I simply had no other place to take my family to.

6 Q. Mr. Tadic, I asked you earlier whether or not -- in fact, the

7 question was, "The group led by Dusan Knezevic also included

8 Zoran Zigic, you learned that as well?" and you said, "No, I did

9 not know that". Referring now to page 18 of the December

10 interview, this was another matter you spoke to Mr. Reid about

11 in December 1995. You told him -- for the benefit of the

12 interpreters, your Honour, reference 101 -- "Now, according to

13 what I have heard, Zoran Zigic participated in the war in

14 Croatia and later on when the conflict began in Prijedor, he

15 participated in ... that, when the conflict began in the area of

16 Prijedor, that he participated in the war in Kozarac and that he

17 was together in a group with Dusan Knezevic". Those were your

18 words, is that correct, Mr. Tadic?

19 A. It is possible that I said that. At the end of 1994 I was

20 interviewed in Germany as a witness in the case of Zoran Zigic,

21 and they asked me about him and I told them what I knew in

22 relation to that man. So everything I said I repeated there,

23 and this is what I heard before I left the Prijedor

24 municipality. As for some specific proof that they really were

25 in the same group, I do not know, but those two people were

26 notorious in Prijedor, especially after the murder of certain

27 civilians in Prijedor town, after what Zoran Zigic was arrested

28 and convicted in Banja Luka. I am not sure whether he was rally

Page 7994

1 convicted or not, but that is what I read in the papers in

2 Germany.

3 Those people are well-known in Prijedor. I did not

4 have any contacts with them. I am just telling you what

5 I heard. Whether it is correct or not, I do not know. I did

6 not know who Zigic was and I do not remember whether I ever met

7 him. As for Duca Knezevic, I used to see him in passing either

8 in town. He was driving a motorcycle. He never walked on foot

9 and I never saw him as a civilian. The first time I talked to

10 him, it was in October '92 when he came to Kozarac, to the Local

11 Commune, together with his father and his uncle. They were

12 asking about some plums. I do not know. They were asking for a

13 service at the level of the Local Commune.

14 Q. I also talked to you about Milan Vlacina earlier in the day and

15 asked you about what he told you and what you were aware he saw

16 about seeing people transported from Prijedor. You said,

17 "During 1992, he never told me those things, not in 1992". You

18 also said, "During 1993 he said a lot of things, but during 1992

19 he did not mention those events". I refer your attorney to ----

20 A. I believe this is so.

21 Q. --- page 20 of the December interview at 103. You talked about

22 Radonovic Momcilo, same person known as Cigo. You say:

23 "Radonovic Momcilo is the same person as this Cigo. What I can

24 say about him is that the first time I met him was in the autumn

25 of 1992 in Prijedor. Previously, I had heard about him from my

26 colleagues at the duty post in Orlovci, and what I heard about

27 him was that he had participated in the war in Croatia and that

28 he was also the leader of a military unit whose members were

Page 7995

1 mainly men from Orlovci.

2 "Now, in connection with the events that took place in

3 the Prijedor municipality, when I met Milan Vlacina in Kozarac

4 he told me that he had seen Radovan, Radonovic Momcilo, actually

5 that he had seen the men of Radonovic Momcilo transporting

6 population from Kozarac". Then you added that you were not a

7 member of Radonovic's military unit, and that you had met him

8 while he was a deputy in the municipality. Those were your

9 words too, correct?

10 A. It is quite possible that this is so, but I did not say -- I did

11 not mention Orlovci. I think it was Omarska. I do not know

12 whether I said that he was the leader of the group from

13 Orlovci. That man always lived in Omarska, not in Orlovci. It

14 is possible that I made a mistake.

15 As for the description that was given to me by Milan

16 Vlacina, that is what he told me. Whether he told me that on

17 that day, I do not know, but he told me that he was in Kozarac

18 when that happened, but I cannot claim here that he said that on

19 that particular day. I did not consider it to be an important

20 piece of information. I do not know whether he said that in

21 December or in January. I am not sure about that.

22 Q. I also asked you earlier about any occasions on which you saw

23 buses transporting prisoners on the Prijedor/Banja Luka road.

24 You said maybe once or twice you saw such buses, and described

25 how the prisoners were positioned in the bus. You said they

26 just drove through, but you could notice that and "I know I saw

27 that the driver was wearing a military uniform". Next

28 question: "Was it a military uniform of the army of Republika

Page 7996

1 Srpska?" You said, "I do not know whose army it was. It was

2 just a military uniform without significance. I did not pay

3 attention to that".

4 Referring your counsel to page 62 of December 22nd 1995

5 interview conducted by Mr. Reid with Mr. Tadic -- these are

6 references 122 through 124 -- he also asked you if at any time

7 while you were on duty you saw buses, and you said the

8 following: "Only once I believe that I noticed a bus only with

9 men, and also I noticed that on the bus were men from the

10 security of the army of Republika Srpska, men in uniform".

11 Those were also your words, correct?

12 A. Yes, if I think about it more closely, that is what I think

13 I said. I cannot say with certainty, but the driver, if I can

14 recall, the driver had a beard, as far as I can recall, but

15 I cannot -- I cannot say if that is so. But if -- that he had a

16 uniform, yes, I saw a driver. I think that there was also some

17 security there, but it was just a glance. I did not pay much

18 attention.

19 Q. Security of the army of Republika Srpska?

20 A. An assumption, who else could it have been? The question is

21 strange. It could not have been security of the Bosnian Army.

22 What else I should have said? I know that they were not

23 policemen. That is absolutely correct. They would not have

24 been in a blue uniform. What else could it be?

25 Q. As long as we are on the subject of uniforms, we also discussed

26 that earlier. You referred to the three uniforms that you had,

27 the police uniform, the spotted camouflage uniform (which you

28 say your brother gave you) and the SMB uniform you received from

Page 7997

1 Kusota which you said ----

2 A. I did not own an SMB uniform. That was the uniform that stayed

3 in Kozarac. I do not know what period you are referring to.

4 I did not drag that uniform together with children's clothing.

5 It had no significance for me. I was not a conscript to take my

6 military equipment with me, and that rifle I had was exclusively

7 in the house.

8 Q. Then I asked you whether or not you received a camouflage

9 uniform in addition to the SMB uniform from Kusota and you said

10 "no"?

11 A. I do not understand your question.

12 Q. You told us earlier that you had only received an SMB uniform

13 from Kusota along with a rifle, no camouflage uniform.

14 A. I think that is how it was, and the uniform that I got from my

15 brother I did not consider it a camouflage uniform. I did not

16 consider it anything. I do not know.

17 Q. Let me refer you and your attorney to page 47 of the May 10th

18 interview with you and Mr. Reid. Reference is 26 through 28.

19 You describe the weapon and how you came into possession of it

20 from Kusota. Then you say that, "He came back carrying on his

21 back a big bundle which was wrapped in linen". The investigator

22 asked, "Sorry, a big bundle of what, weapons?" You said the

23 following: "No, no. Later I saw that actually inside was a

24 rifle, uniform, boots, the regular army, the regular equipment

25 that is issued to a soldier, and also I remember that there was

26 a classic uniform and that there were also boots, and there was

27 also a uniform of mixed colours, yellow colours". So that was

28 another uniform which you had in your possession in 1992?

Page 7998

1 A. I do not think so. I am not sure. I cannot say. I only looked

2 at that equipment and then left it. Even the boots that I got

3 were not my size.

4 Q. You agree that you told Mr. Reid that you received a camouflage

5 uniform in addition to an SMB uniform when Kusota brought the

6 bundle that you described?

7 A. I did not get the uniform that Mr. Reid thinks about, and

8 I think that that is what Mr. Reid thinks about. The yellow

9 thing I did not get from him. That I can say with certainty.

10 Maybe I did not -- I did even say so, but it is not important

11 whether I got a yellow SMB or something else. I know that the

12 uniform that he brought I never used.

13 Q. Mr. Tadic, I would like to satisfy you that the words were not

14 Mr. Reid's but were yours and, in fact, were not suggested by

15 Mr. Reid who was simply asking you a question about what you

16 received. So perhaps you would like to look at your exact

17 words? May I have this marked for identification and shown to

18 the witness, please?

19 A. There is no need for that. I believe you. What I am telling is

20 what I know for certain. Maybe I have said that way, but I know

21 that it was not so. I do not think that there was any

22 significance. When Mr. Reid and I talked I was not accused of

23 anything regarding uniforms. Even if I had 10 uniforms, maybe

24 I would have said there was something like that. It was

25 insignificant. I am not accused of having a uniform.

26 JUDGE STEPHEN: My recollection may be in error, but I thought the

27 witness in evidence in chief said that in the bag there was the

28 SMB and there may have been a camouflage uniform. Did he not

Page 7999

1 say that?

2 MR. TIEGER: I checked the transcript, your Honour. I will be happy

3 to read that exact portion as I found it.

4 JUDGE STEPHEN: Yes.

5 MR. TIEGER: Mr. Tadic, as a matter of fact, you had enough uniforms

6 that you were giving them away. Do you remember giving one to

7 Mirko Vidovic in June?

8 A. When I started working with the police, it was not a big problem

9 for uniforms, the one that I described. There were some reserve

10 uniforms, auxiliary uniforms, and I gave one to my wife's

11 brother. I was not in a position to give them out to others.

12 Whoever was in the reserve police had an opportunity to get a

13 uniform. As far as that uniform is concerned, I said, as far as

14 I recall, at the time when we talked, I did not consider it

15 significant whether it was in a bag or somewhere else.

16 I thought that it was insignificant as a question.

17 Q. You yourself wore a camouflage uniform at the checkpoint, in

18 addition to your blue police uniform?

19 A. That uniform I wore exclusively when my uniform of the reserve

20 policemen was being laundered. I did not have two summer

21 uniforms for the reserve police. I got it from Vokic Radovan.

22 I do not know the date, but I got it from him and the winter one

23 I got at the police station in Prijedor.

24 Q. Referring your counsel to page 83 of the May 10th interview --

25 for the benefit of the interpreters, I am looking for the

26 reference number, just below 85 -- on that occasion you were

27 asked to describe the uniforms you wore at the checkpoint. You

28 said the following: "As far as I remember, during June of 1992,

Page 8000

1 I mostly, mainly, wore a multi-coloured yellow uniform. The top

2 part and the down part was the same colour." Those were your

3 words, right?

4 A. Yes, as far as I recall, sometimes I wore that kind of uniform

5 too. In any respect, I had police insignia on all of them,

6 regardless of whether it was a yellow or a blue one. On each of

7 those uniforms on the shoulder there was an insignia. There

8 was "police" insignia written. I really cannot say how many

9 times in June I wore that uniform and another one, but those are

10 the reasons. There were no other reasons why. That was the

11 only reason why the laundering of uniforms.

12 Q. That is why you wore mainly in June your yellow camouflage

13 uniform. Let me ask you some questions about ----

14 A. It is possible that that was the reason. That was one of the

15 reasons.

16 THE PRESIDING JUDGE: Mr. Tieger, the one that Mr. Tadic said had an

17 insignia on it, is that the one that his brother gave him?

18 MR. TIEGER: Mr. Tadic, did you hear the Court's question?

19 A. Yes. I understand that question. When I started working in the

20 police in Prijedor, we all got insignia, the police insignia,

21 especially the word insignia, that are very conspicuous. It is

22 about 10 centimetres wide, half circled, blue background and

23 white stitching in Cyrillic letters "Police". We also signed

24 out to the blue berets with the insignia, a metal badge of the

25 Republika Srpska.

26 Q. Mr. Tadic, how many times were you in Trnopolje camp in 1992?

27 A. I will try to remember. I think I was there five times. I do

28 not mean the camp -- you talked about the "camp". I do not know

Page 8001

1 what you mean under the "camp", but in Trnopolje I was about

2 five times.

3 Q. Where in Trnopolje were you?

4 A. The first time I was with Jovo Samardzija, as I said earlier,

5 over the weekend in June of '92.

6 Q. That was in the camp?

7 A. Pardon?

8 Q. That was in the camp?

9 A. I do not know. Please ask me specifically. I do not know what

10 you mean under a "camp", so I am not in a position to answer.

11 Is it the whole complex or was it the street that I was passing

12 on? It is not clear to me what you had in mind.

13 Q. Were you inside or at the site of Trnopolje camp with

14 Mr. Samardzija?

15 A. Could you please say specifically? If you show me photographs,

16 there were some photographs seen here, and if you show me the

17 photographs, I will show where it was. It is not a secret.

18 Some people are saying that the camp was the school building,

19 some say that it was the entire complex. So now I am not sure

20 what they think when they say the "Trnopolje camp". So, please,

21 if you can be very specific with your question?

22 Q. When you visited with Mr. Samardzija, were you on the grounds of

23 what had once been the school?

24 A. No, never -- neither at that time nor later.

25 Q. Were you on the street which runs immediately in front of the

26 school within the boundaries of where the former school was?

27 A. You mean in the summer of '92?

28 Q. At any time in '92?

Page 8002

1 A. No, not in the summer. I said I was there five times. In the

2 summer of '92, I was exclusively only once with Jovo Samardzija

3 and I know where I was and whom I met. I know that I saw then

4 -- I saw people who I grew up with and that is what stayed in

5 my memory. Hiba Hankic, my neighbour, and her husband, Salih,

6 I greeted them; greeted with Gunjic Ferid and I talked to him --

7 he still lives in Prijedor today -- with Osman, Sahib Kulasic.

8 They all asked me what happened. I did not know what was going

9 on.

10 Q. Were those people free to leave the area they were in, the area

11 of Trnopolje camp?

12 A. I do not know if they could leave. We did not talk about that

13 and again I say I did not meet them at that space where you

14 say. I met them in the street, and some I met in front of the

15 ambulance in Trnopolje, the space in front of the ambulance,

16 ambulanta. In 1992, I was never in the school yard of

17 Trnopolje.

18 Q. Have you told investigators on previous occasions, either the

19 German investigators or the Tribunal investigators, that

20 Trnopolje was an open area and people were free to leave?

21 A. At that time when I visited with Jovo Samardzija, that was my

22 impression. What happened later, I do not know. Whether the

23 status change in the summer of '92, I did not go there. When

24 I saw -- neither my neighbours told me that it was very

25 difficult for them, neither did I get that impression.

26 Q. Please tell us the other four occasions when you were in

27 Trnopolje and, please, you can tell us what part of Trnopolje

28 you were in?

Page 8003

1 A. I know that once I was there officially. I do not know, again

2 I cannot say the exact date, but it was the moment when the

3 refugees from Trnopolje were going to Karlovac in organisation

4 of the Red Cross, the UNHCR. That was the first time that

5 I went there on official business as a reserve policeman.

6 I stood by a bus and my job was to help in -- to the Red Cross

7 in its activities.

8 I know that there was a young woman who was reading

9 names off a list. She was in front of the school building.

10 People were passing by her one by one and were getting on the

11 bus. I know that we -- I remember that we stayed almost all

12 day. It was raining and I had a blue cape and Goran Babic, the

13 Commander of the police station in Kozarac, was with us and

14 about 10 other policemen who had similar duties.

15 Q. What about the other three occasions you were in Trnopolje, when

16 were they and where were you?

17 A. It was all in the period between the fall, that is, the end of

18 1992. On one occasion I remember I went to Trnopolje. First,

19 in Prijedor I met Adil Jakupovic's wife. We often visited more

20 often, more often than this gentleman stated here. Every other

21 day or at least once a week we visited each other in Prijedor.

22 On one occasion when I went to his wife, to their house, she

23 told me she was not at the old address any more. So I found her

24 at another house that was closer, and she said that Adil went to

25 Trnopolje with one of the sons.

26 Q. When was that? When did you visit Trnopolje on that occasion?

27 A. I believe that it was the end of October 1992. I cannot say

28 with certainty, but I also know that it rained again and the

Page 8004

1 weather was pretty bad. We stood by a house up the road, up the

2 street, and we talked. I know that Zonjic -- he is also a

3 reserve policeman. He is a refugee from Bosanska Bojna. He was

4 with me.

5 Q. When were you in Trnopolje on the remaining two occasions you

6 recall?

7 A. I cannot recall exactly the date. On one occasion I was there

8 with my brother. At that time I worked as a Secretary of the

9 Local Commune and he came to Prijedor with Hamdija, his friend.

10 They came from Banja Luka. That Hamdija had a friend in

11 Kozarac, and he said, "Oh, let me come along". He wanted to

12 find a friend of his. I think his name was Rega. I had heard

13 of him. He was a salesman.

14 So we went together to Trnopolje. He talked to some

15 people and finally found out that this man had been in Slovenia

16 for quite some time. That was one time. Also, I went as a

17 Secretary of the Local Commune with Popovic Joso. I asked him

18 to give me a ride to Trnopolje, because before that in Prijedor

19 I got many messages from the Red Cross.

20 I went to the International Red Cross and they gave me

21 about 20 messages of refugees. Somebody from abroad were

22 writing to people who were the natives of Kozarac, and the

23 representative of the Red Cross gave me those messages and he

24 said, "All these are for people from Kozarac, so there". I left

25 that with the policeman on duty whom I found there and we

26 returned, Joso Popovic and I. I think the policeman's name was

27 Petkovic. He was in the part where the restaurant used to be,

28 across the street from the ambulanta, the health clinic. I do

Page 8005

1 not know if I ever went there again after that.

2 I remember seeing Adil Jakupovic on later occasions in

3 Prijedor, and he said that he never managed to go there, that he

4 got registered with the International Red Cross. It was his

5 intention because otherwise he could not leave Prijedor in a

6 normal, regular manner. The only way would be something

7 unofficial, through the military or if you get a letter of

8 guarantee from abroad, the other members of the family would

9 write to the International Red Cross.

10 Q. Mr. Tadic, just focusing on Trnopolje, what were you wearing on

11 the occasions you were in Trnopolje other than the time you

12 described being there as a reserve policeman or the time you

13 visited with Mr. Samardzija?

14 A. I do not remember. Sometimes I -- I remember when I went there

15 on official business I had a raincoat of blue colour. When

16 I went with Adil Jakupovic, I do not remember what kind of

17 uniform I had. On other occasions, I went in civilian clothes,

18 normal clothes that you wear. It was the fall and so I know

19 that it was warmer clothing.

20 Q. Were you armed?

21 A. On the occasion when I was doing -- I was on security detail for

22 the International Red Cross, yes.

23 Q. You have indicated you have some trouble remembering the dates.

24 You just know it was sometime between the fall and then you did

25 not specify what time period. Do you know whether or not you

26 were in Trnopolje in October?

27 A. I think that around October 1st those refugees left for

28 Karlovac. My birthday is on October 1st, but I am not sure that

Page 8006

1 it was on that very day. I think there were maybe -- or maybe

2 it was 31st, maybe it was 2nd, maybe it was 1st. I am not sure

3 about the date.

4 Q. Do you know whether or not you were in Trnopolje in November?

5 A. It is possible. As I said, I do not recall exactly because

6 there were very brief visits, except for the time when I was

7 there officially. Then that day I was there from morning till

8 dusk. The representatives of the Red Cross handed out food to

9 the refugees, but they could not give us any. We could not give

10 food to the police and the military of the Republika Srpska.

11 Q. Do you know whether or not you were in Trnopolje in December

12 1992?

13 A. I do not remember. I am not sure. I know that I think I was

14 there about five times altogether down there, but it was not

15 the -- I never entered, though, the space, as you claim. The

16 closest encounter with people there was in the street with

17 people that I knew. As far as I know, people moved around

18 freely in the street. I do not know what rules were there at

19 the time. When I was there with Adil Jakupovic, I know that

20 people moved about freely.

21 Q. Were you in Trnopolje in September?

22 A. As I said, from the fall, that is, during the fall, I was there

23 about four times and once during the summer. I know my

24 reasons. I know why I went there. I know with whom I had

25 contact there. I cannot say exactly when I went there the first

26 time. In fact, I know that when I was there on official

27 business it was when part of the refugees were leaving. I think

28 it was 37 or 38 buses that were leaving Trnopolje. As far as

Page 8007

1 the other visits, were all to the town of Trnopolje. Maybe they

2 had other rules there, but I was exclusively in the street and I

3 know with whom I talked and why I talked and I never went there

4 alone.

5 Q. In fact, with respect to the uniforms you wore when you were in

6 Trnopolje camp, Mr. Tadic, did you not tell the German

7 authorities that on four occasions when you were in Trnopolje

8 camp you were uniformed?

9 A. It is possible that I said that. I did not think it was

10 important. I know why I went there and I know exactly with whom

11 I went and I know with whom I met there. I know that I was

12 there once officially and that was then. I cannot tell you the

13 exact date with certainty, but I know that I was there on that

14 occasion when those people were leaving Trnopolje for Karlovac.

15 I know there was a white van which was parked there. It was an

16 UNHCR van. I talked to a representative on that occasion and it

17 was a Frenchman, and I also know that there was a representative

18 of the Red Cross there. There was the Red Cross there who

19 visited me in my detention unit. He told me that, indeed, there

20 was a French representative of the Red Cross there at that

21 time. I would have never gone there officially had I not known

22 that there was an International Red Cross office there and that

23 the UNHCR was there too.

24 Q. Earlier we discussed the rifle and the certificate which was

25 placed in front of you which indicates the certification for

26 issuance of a rifle and ammunition. You stated that you

27 received this paper from your brother Ljubo in Banja Luka on the

28 date indicated there.

Page 8008

1 A. I know that I requested a similar certificate in Prijedor.

2 I used to know a man by the name of Slobodan Bokan and I asked

3 him for a such a paper, and he did give me a certificate of some

4 sort, but the certificate that I have seen here, it is the

5 certificate that I was given by my brother in Banja Luka.

6 I tried several times to obtain a similar certificate in

7 Prijedor because I saw that many of my neighbours in Kozarac had

8 similar certificates, and Fikret Tulundzic showed the same

9 certificate to me, except there was not the "Territorial

10 Defence, Banja Luka", but the "Territorial Defence, Prijedor",

11 marked on that.

12 Q. Let us talk about that for a moment. In fact, you were asked

13 about that in an interview with Mr. Reid to be found at page

14 48. It is reference Nos. 30 and 31. That should be May 10th

15 interview. "Can you explain the following about that

16 certificate, Mr. Tadic?" "Yes, that automatic rifle stayed in

17 my possession and that same rifle was signed out when I was

18 assigned to the reserve traffic police. Now, as far as this

19 automatic rifle is in question, in April '92 I spoke to Simo

20 Miskovic and I told him about the rifle and asked him what

21 I should do with it and he told me that I should keep it until

22 the police comes asking for it. But at, by the end of April,

23 the local residents of Kozarac had been saying, or whether they

24 were just rumours, that all weapons, unauthorised weapons, to be

25 found in the houses will be seized, confiscated. So, on one

26 occasion when I went to Prijedor, I do not know exactly when,

27 I spoke to Bokan Slobodan who was a reserve military personnel

28 and I told him about it and then he gave me a certificate, just

Page 8009

1 like that, an empty certificate, that I had been issued a

2 weapon. And since I was not mobilized, the origin of the weapon

3 could have caused problems, so somewhere, around the beginning

4 of May, I filled out that certificate in my own handwriting and

5 I put down my own name, so that it would serve me as a sort of

6 guarantee regarding the origin of the weapon". First of all,

7 those are your words, correct?

8 A. Yes, that is how it happened, but it is not the same certificate

9 I have been talking about. I was given a certificate from him.

10 I forgot. I did talk to Miskovic, but I cannot tell you it was

11 the beginning of '91. I think it happened at the end of '91.

12 Q. That is not the certificate that you were examining which is

13 Exhibit 148?

14 A. No, it is a similar certificate but the title was different. It

15 read "Territorial Defence, Prijedor". The other one

16 is "Territorial Defence, Banja Luka".

17 Q. So at the beginning of May you filled out two or you actually

18 forged two similar certificates for this weapon?

19 A. I did not forge it. I do not know why you think that I forged

20 it. The data on the certificate are OK. The number of the

21 rifle was important, nothing else. There was a kind of

22 guarantee certificate of the origin. The fact that my name was

23 there -- well, I see no other way I could have done that.

24 I did the same thing as many of my neighbours did,

25 nothing special. None of us never hid weapons, neither did my

26 neighbours hide their weapons from me. Later on they were

27 openly carrying weapons. They talked to me about everything.

28 I had no secrets with my real neighbours. The only thing is

Page 8010

1 that I could not contact with people who had had a criminal

2 record from before and who were dangerous for anyone there.

3 Q. So, apparently, then you were aware of Serbian civilians being

4 armed by the SDS?

5 A. Why do you think it is clear?

6 Q. You did not see that?

7 A. No, I did not. There were all kinds of stories. I cannot deny

8 that. There were stories that people, both from the SDA, SDS,

9 the green berets, were being armed. There were all kinds of

10 stories. Which of them were true, I do not know. It was

11 obvious that people were armed and that they were obtaining

12 weapons, whether individually or in some other way, that is a

13 different story.

14 Q. Let us pursue this just a bit more, if we may? So in May 1995

15 you told Mr. Reid about the certificate you say you got from

16 Slobodan Bokan, but you did not mention the certificate you

17 received from your brother?

18 A. Nobody asked me about that. I had other certificates that my

19 brother had given to me. I had a certificate to travel to

20 Serbia, for Belgrade. It was a similar certificate.

21 Q. In Court you mentioned the certificate you received from your

22 brother, but not the certificate you received from Slobodan

23 Bokan?

24 A. Had someone asked me, I would have said that.

25 Q. That certificate was found in your house when the German

26 authorities searched it after your arrest?

27 A. I do not remember what was there, but when I fled Prijedor

28 I just took everything I could. I put them in a bag and left.

Page 8011

1 The same thing happened when I was leaving Banja Luka. I did

2 not know what to take until the very moment I was leaving for

3 Serbia. If my departure had been normal, I would have probably

4 not taken. I did not think it was something dangerous. Those

5 are the facts. I did not say that I did not have a rifle, that

6 I did not have a certificate. It was the certificate that was

7 filled out with me and I am not responsible for that.

8 If you think it is a forgery, then it is a forgery,

9 but I was never really a soldier. It is true that a soldier is

10 mentioned there, but I have never been a soldier. If you think

11 that I was a soldier, well, please, you can check on that.

12 Q. No, Mr. Tadic, I only meant it was a forgery in the sense that

13 you are saying you filled it out rather than an official filling

14 it out. In any event, the Germans seized that document and they

15 interviewed you. They asked you specifically about that

16 document, a document which said you were a soldier, which said

17 that you had been issued an automatic rifle, which said that you

18 had been issued 300 bullets, which said it had been issued from

19 the Territorial Defence of Banja Luka, and they said:

20 "Mr. Tadic, what about that document?" You said: "I do not

21 know anything about it", isn't that right?

22 A. Well, it is true, according to the description you just gave,

23 but that is the way they described it. But my answer is, no, it

24 is true I was not given the certificate by the Territorial

25 Defence and I was not given the weapons by the Territorial

26 Defence. I was not a soldier of the Territorial Defence. That

27 is not true. What is true is that I filled out that certificate

28 and I was not asked about that. It is true that I was given a

Page 8012

1 blank form and all other details, other all data, that I was a

2 soldier member of the Territorial Defence, that is not true.

3 On the basis of that paper, I do not know. I do not

4 know how you reached the conclusion that I was a soldier of the

5 Territorial Defence because of that paper. Such data should be

6 found in the military book. Ever since I served my military

7 duty, regular duty, in the JNA, I have not changed my military

8 book and all the relevant information is there in my military

9 book.

10 Q. The German authorities asked you about the certificate referring

11 to an exhibit number and they asked you: "What about that

12 document?" You said: "I do not know anything about it", isn't

13 that what happened?

14 A. Yes, that is what happened. The description that they gave, I

15 do not know anything about that. I did not receive the weapon

16 from the Territorial Defence, and that was my answer. How they

17 described it, I do not know anything about that. That is

18 correct and that is true.

19 Q. Mr. Tadic, that interview was interpreted for you throughout the

20 entire process of the interview, was it not, and after each

21 question and answer you and your attorney were permitted to

22 object to it or to add to it, if you wished and you signed off

23 on that page, your signature appears on that page, isn't that

24 all true?

25 A. Yes, it is true what you are saying, the fact that I had the

26 right to add anything I wanted to, and I asked for something to

27 be added. You can ask Mr. Sklebitz. I wanted his assistance to

28 add something, something that I thought that had not been

Page 8013

1 adequately described. I am not saying that the certificate was

2 not discussed, but it was not presented in the same light as

3 I presented it here. The German authorities, when at the end

4 of '93 we talked about the case, they wanted me to give a

5 statement in the case of Zoran Zigic and I said, "I will accept

6 if you allow me to add what I think should be added to my

7 previous interviews". They said, "OK" and then we sat down and

8 they even asked a Minister of some kind to come there and he

9 gave his approval.

10 But that policeman told me that we would first discuss

11 the case of Zoran Zigic and then we would later discuss what

12 I wanted to be discussed or to add. I agreed and then we

13 discussed the Zoran Zigic case. After that when it was -- when

14 we had to discuss our previous interviews, when I wanted to add

15 something, when I heard -- when he heard what I said, he said,

16 "No, it is out of the question. You said everything you had to

17 say".

18 So I was not given the opportunity to say during that

19 interview, I do not know anything about interpretation, but

20 there are quite a few things that are not correct. The very

21 title "Local Commune Territorial Defence", I do not think that

22 German authorities knew about things, that they knew what was

23 what. Their objective was just to question me for ever.

24 Q. You speak some German, do you not, Mr. Tadic?

25 A. I would not say so. I do speak some English now. I have

26 learned it in my cell, although I do not have much communication

27 with the outer world, but I can understand some things.

28 Q. You did not speak to the guards at the detention facility in

Page 8014

1 Germany in German?

2 A. I did communicate with one of the guards sometimes, but before,

3 before my departure, when I knew that I would be transferred

4 here. Nobody talked to me before that. They would just tell

5 me, "Go back to your room. Do this or that". They just

6 communicated in that way. I sometimes asked them for help, but

7 it was not a correct attitude towards me.

8 Q. However much German you speak, you certainly do speak enough,

9 would you not agree, to know the meaning of "Ich weiss nicht"?

10 That is not too complicated? You can say and understand "I do

11 not know" in German?

12 A. I do not understand you. I did have an interpreter when

13 I talked to the German authorities -- that is beyond doubt --

14 but I just said -- I just described the way they talked to me,

15 the way they behaved towards me. I know that Mr. Reid said if

16 there is anything I want to add that I would have the

17 opportunity to talk later on, and that is what I was told in

18 Germany. But they did not allow me later on to discuss

19 anything.

20 I am not saying it is -- I do not claim that what

21 I would say later on would be completely true. I was just

22 trying to tell what I could remember. I am not saying here that

23 I did not make any mistakes. I do not think anyone can remember

24 all the dates. I was accused several times and ever since

25 summer '92, and they kept asking me, "Where were you on the

26 12th, 13th, 14th, 15th?" and so on, in the morning and in the

27 evening. I was not a robot and there is nothing I can say in

28 relation to that.

Page 8015

1 Q. I asked you earlier about Witness W and whether ----

2 THE PRESIDING JUDGE: Mr. Tieger, before you go on to Witness W,

3 maybe 10 minutes ago you made reference to a certificate that

4 the German authorities asked about, then much else was

5 discussed. It is still not clear to me what certificate they

6 were talking about. You referred to an Exhibit number and then

7 there was a long discussion about something else. Maybe

8 I missed it.

9 MR. TIEGER: No. I will try to clarify that, your Honour. Thank

10 you.

11 Just to clarify, the document the German authorities

12 were referring to when they asked you about the certificate

13 issuing you a rifle and 300 bullets is the same document that

14 was seized from your home in Munich and the same document that

15 we have looked at here in Court today, is that correct?

16 A. I did not see that document in Munich during the interview.

17 I was described that document in a different way. There are

18 certain things that are written there and that were described in

19 their own way, but the reality was different. Whether they were

20 thinking of this certificate or some other certificate, I do not

21 know. That is why I said that I do not know what they were

22 referring to. That is the way they described it; that I was

23 issued the rifle by the Territorial Defence, for example, that

24 I was a soldier of the Territorial Defence. Those were their

25 questions.

26 They did not show me the certificate and that is why

27 I gave them the answers that I gave them. This is the first

28 time I am hearing this story, the story that you told here.

Page 8016

1 I have never seen that certificate, the way they described it,

2 and I do not know which certificate they were talking about.

3 Q. Just so it is clear, sir, the interview with the German

4 authorities which you signed which was contemporaneously

5 interpreted states: "Exhibit 1.12.87", your Honour, which is

6 the German number, "contains a certificate dated 4th May 1992

7 that Dusko Tadic had been provided by the 'staff of the

8 Territorial Defence' with an automatic rifle AP and 300 rounds

9 of ammunition. Mr. Tadic, what can you tell us about that

10 certification?" That was the question, sir. That was the

11 question to which you answered you knew nothing about it.

12 A. I do not know anything about it. I do not know whether I was

13 issued with that rifle by the Territorial Defence staff and that

14 was my answer. I was not issued that rifle.

15 Q. Mr. Tadic, I asked you earlier about Witness W and asked you

16 whether or not he was one of those who told you that he

17 participated in the conflict in central Kozarac. You responded

18 that he did not. I would like to direct your counsel's

19 attention to the December interviews, December 22nd, on page 24

20 -- I am sorry, I apologise, page 69. That should be in the May

21 series, on May 10th. Mr. Tadic, you were talking at that time

22 on May 10th about the conflict in opstina Prijedor and in

23 Kozarac. You suggested that if the interviewer wanted you to,

24 you could give the names of the persons you had spoken to and

25 who had participated in the conflict that took place in the

26 centre of Kozarac. The first name you mentioned was that of

27 Witness W?

28 A. It is possible that I mentioned that name, but it is just an

Page 8017

1 assumption, only because I knew from earlier that that witness

2 had been in the war in Slavonia, in Zoran Karlica's Unit, and it

3 was common knowledge in Prijedor that Zoran Karlica was

4 Commander of the attack on Kozarac. That is why I thought that

5 he might be one of the participants in the conflict. I did not

6 know for sure whether he really was or not.

7 Q. What you said to Mr. Reid was, "If you want me to, I could give

8 you the names of the persons who had spoken to me and who had

9 participated in the conflict that took place in the centre of

10 Kozarac". Those were your words, not Mr. Reid's, correct?

11 A. Yes, it is possible. It was not a secret. People were talking

12 about the events in Kozarac, but I could not know what was true

13 of all those stories. That was just my assumption.

14 Q. Mr. Tadic, you have spoken in evidence about -- I think I am

15 quoting -- "we simple, ordinary people". The fact is that you

16 were not only a member of the SDS, and not a member in name

17 only, but you were an earnest member of the SDS who before the

18 conflict tried to obtain weapons for Serbs, organise assignments

19 for the conflict, obtain information about weapons which the

20 Muslim police might have and discourage Serbs from co-operating

21 with Muslims?

22 A. That is your opinion.

23 Q. There were people in Kozarac, SDS members, who were not passive

24 members, correct? There were activists, SDS activists, in

25 Kozarac?

26 A. I knew only about my wife and Miso Radulovic. I do not know

27 that there were other members of the SDS during my stay in

28 Kozarac.

Page 8018

1 Q. Miso Radulovic was the man whom you described as an SDS

2 activist?

3 A. It was an assumption. I think it is something that followed

4 from the fact that he was a member -- I think so -- of the board

5 for the plebiscite, nothing else. I am not sure whether he was,

6 but I think he was.

7 Q. Before the conflict in Kozarac, Miso Radulovic tried to organise

8 the assignments for Serbs to be implemented should war break

9 out?

10 A. He talked about the need to evacuate the population, because he

11 used to be a Commander of the Territorial Defence in Kozarac, so

12 he knew about the ways to evacuate population. So in relation

13 to that, it was in relation to that that he talked about the

14 needs and so on, that in case of conflict the population should

15 leave in an organised way, because it was clear to us at that

16 time, me and my family, we were not involved, we were not on the

17 lists for shelters. So everything that followed from my

18 contacts with Miso Radulovic and some other people in Kozarac

19 was in relation to the safety of my family and my personal

20 safety. I tried to create conditions to save me and my family.

21 Q. You worked side by side with Miso Radulovic who was an SDS

22 activist to organise the assignments to be implemented if the

23 war broke out?

24 A. No, I did not work with him about that. Those were just simple

25 conversations. I do not know in what way I was involved, as you

26 say. I do not think he was involved. Those were just

27 discussions, what if this should happen, if that should happen.

28 But nobody had any solutions in that situation. There was a

Page 8019

1 discussion about how to evacuate oneself and one's family.

2 I participated in those discussions because I did not own a car

3 and I knew that I was not on the list of shelters, so I had to

4 talk to someone. Those were just conversations about what to do

5 in this or that case.

6 Q. Mr. Tadic, in the report, however, which you prepared and

7 submitted, in the work report which you prepared for the purpose

8 of submitting to SDS officials and other authorities, you

9 described the following: "Under such circumstances, Milos

10 Radulovic and I tried to join forces and organise the

11 assignments to be implemented which, as arranged, were to come

12 into effect should fighting start. The majority of people with

13 the village of Vidovici as a sole exception refused to

14 co-operate siding with the stronger". Those are the words you

15 wrote to, among others, the President of the SDS in Bosnia and

16 Herzegovina to describe what you did in 1992?

17 A. Those were the words that I wrote on the basis of my work as the

18 Secretary of the Local Commune and the reports that had been

19 drafted for the Local Commune in Kozarac in the period

20 of '92, '93. So all that information is based on the

21 declarations and statements of some people who attended those

22 meetings and sessions of the Assembly or the Executive Board.

23 As for those activities, it is normal that I was concerned about

24 how to save me and my family from that area because nobody knew

25 what would happen. So when it comes to co-operation, I talked

26 to Slobodan Savanovic because he had a lorry. I simply needed

27 to have someone if I wanted to leave Kozarac. So I had to wait.

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

Page 8020

1 (4.00 p.m.)

2 (The Court adjourned for a short time)

3 (4.20 p.m.)

4 THE PRESIDING JUDGE: Mr. Tieger, you may continue.

5 MR. TIEGER: Thank you, your Honour.

6 Q. Mr. Tadic, before the conflict in Kozarac there were sentry

7 posts and checkpoints which were manned by both Serbs and

8 Muslims, is that correct?

9 A. I do not know exactly what period you have -- you are referring

10 to.

11 Q. In 1992, before May 24, when the attack on Kozarac occurred,

12 there were joint checkpoints or joint sentry points in Kozarac?

13 A. I cannot say with certainty that they were joint. I had no

14 particular insight into that.

15 Q. Did you not denounce Serbs who served on checkpoints with

16 Muslims in your letter to the President of the SDS and to

17 others?

18 A. That letter was composed in 1993 and I do not know in what way

19 that was possible to do. I think in '93, I think 8th

20 August '93.

21 Q. You wrote the report on 8th August 1993 and the report

22 encompassed your work for the SDS between the period of time

23 1990 through 1993, isn't that right?

24 A. Correct, but it is based on information that was in the reports

25 created during the sessions of the Local Communes, presided by

26 Jasikovic Branka, at the -- Bosko Dragicevic presided over the

27 Local Commune and in December of 1992 while I was the President,

28 and so it was based on the statements of the members. Those are

Page 8021

1 -- that is information that is not, that is not verifiable.

2 I was not a policeman to be able to verify it.

3 Q. Mr. Tadic, this report is all about you, is it not? The report

4 begins: "I was born on October 1st 1955 in Kozarac", and it

5 ends with your name, "Dusko Tadic", many pages later? It is

6 about what you did in 1990 through 1993 and it is about your

7 views about what happened during that time?

8 A. In some parts there are elements, my views, but they are all

9 based on my activities in Kozarac, as the Secretary of the Local

10 Commune. I think that the latter part of that report, it

11 states, "The Secretary of the Local Commune". So, as a

12 Secretary, I had access to all the minutes of all meetings of

13 the Assembly of the Local Commune. This was done pretty fast.

14 I was not a typist. There are many mistakes and one -- maybe

15 that was one of the reasons why I was arrested on August 9th

16 when the authorities in Prijedor got a hold of this document.

17 Q. Wherever you got the information about this person from or these

18 people, you write to the SDS authorities that Mirko Grahovac and

19 his son Zeljko were also patrolling at the checkpoint near the

20 Orthodox church and you denounced them for that, isn't that

21 true?

22 A. I do not know how I could denounce in August of '93, a year

23 later in the area of the Local Commune of Kozarac, but that

24 information are facts.

25 Q. Brane Koncar was a Serb who patrolled with Muslims at the

26 checkpoint near the old sawmill and you denounce him for it?

27 A. When you refer to Grahovac, that is only a segment. He stole

28 five or six thousand litres of gasoline while, apparently, he

Page 8022

1 was on duty. I do not know how to take those duties if they

2 were not honest, so this person could have looted all Kozarac.

3 I visited his house. I know what his property was like before

4 the war and what it was after. He had three times more. He had

5 livestock and all of a sudden he had 30 cows.

6 Q. Even before you wrote this letter and even before the outbreak

7 of the conflict, you and Miso Radulovic worked together to

8 discourage Serbs from participating in these joint patrols?

9 A. Those were, perhaps, ideas of Miso, but Miso himself gave his

10 hunting rifle to his colleagues who were manning those

11 checkpoints. It is something that was spoken about.

12 Q. You were trying to persuade Serbs not to participate in the

13 joint checkpoints and joint sentry points?

14 A. After our meeting with the municipal Crisis Staff in Prijedor,

15 we, all of us who were there representing the civic forum, we

16 agreed in every contact with the population, we worked hard on

17 improving the trust in Kozarac. So, regardless of whether

18 somebody was a Muslim, a Serb, if you contacted with friends or

19 acquaintances, we told them how to approach them. We said not

20 to wear a uniform. I still stand by it. I met Emir Susic and I

21 told him, "I will give you my hunting rifle. You should not,

22 and I will -- I do not want you to lose your head".

23 Q. Despite your effort and Miso Radulovic's efforts, Serbs,

24 nevertheless, continued to participate with Muslims in the joint

25 patrols, Serbs like Koncar and Grahovac?

26 A. I do not know if they -- maybe sometimes they, they were seen

27 there, because also Miso's son was on the front line from the

28 first day. I cannot say anything about that. If I talked to

Page 8023

1 Miso about it and Miso himself was present at the Assembly of

2 the Local Commune, and he was talking very strictly to all of us

3 who had these initiatives about Kozarac. He was the Commander

4 of the Territorial Defence of Kozarac. He was a native. He was

5 almost 60 years and I assumed that he had experience. Nobody

6 was under age there, so that I would -- should give them

7 advice.

8 Until the last day, I was socialising with my

9 neighbours, the ones that I trusted and who trusted me. Four

10 days before the conflict, I had a barbecue party with Fikret

11 Tulundzic. We had carp and we barbecued carp, and we looked and

12 we thought that everything would pass. We did not believe that

13 things would happen. I knew that he had weapons; he knew that

14 I had them. He sometimes gave me the bullets for my .765

15 handgun. That was all open.

16 Q. You tried to get other weapons as well; a few months before the

17 war you worked with Vaso Radunjic on trying to get weapons

18 which belonged formerly to the shoe factory and which were

19 stored in the Prijedor barracks?

20 A. I heard about that event, but I did not take a direct, active

21 part in it. My brother Mladen told me about it, who -- he was

22 in Kozarac four or five months in late '91 and I think my

23 brother was there. He had a van, a Nissan, of red colour. They

24 tried something and nothing came of it. Radunjic was to be

25 fired, he was suspended, and he and his wife who was a Muslim,

26 after the SDA came into power, six months later, he fled

27 abroad. That is only something that I heard. I cannot be sure

28 if that even happened. My brother Mladen could say more about

Page 8024

1 that.

2 Q. Let us read the words from the letter which you wrote when you

3 sat down to describe your work for the SDS between 1990 and

4 1993. That is on page 4. "A few months before the war,

5 I worked with Vaso Radunjic, the secretary in resignation in

6 the shoe factory, on trying to get weapons which were the

7 company's property but were stored at the Prijedor barracks. We

8 had delivery documents drafted and an agreement to be allocated

9 those weapons stored at the barracks, but when my brother tried

10 to load them on to the van Captain Javoric in person accompanied

11 by his security officer, Iso, prevented him. It never went any

12 further from that, though news about our attempt leaked down to

13 Kozarac.

14 "I was able to understand the whole thing only when

15 I found out that the security officer mentioned above was a

16 Muslim from Montenegro, and that it was his ethnicity that made

17 our effort futile, though I was never able to understand why

18 Javoric was allowed then and later to work against Serbs,

19 distributing weapons to Muslims and justifying his work by

20 saying that the weapons were common property".

21 A. I think that the description is very clear, that Mr. Radunjic,

22 whether he tried or not, I cannot be sure, but on that day I was

23 there. I know that the brother came back to Kozarac and he told

24 about it. Since I have heard of it, about it, I thought that in

25 some ways I was a participant of it.

26 But, as far as Javoric is concerned, I cannot say

27 much. I heard about him before and after the war and there were

28 also stories that he was distributing weapons to everybody, but

Page 8025

1 not to help, but in order to create an even worse situation,

2 only worse.

3 By the very fact that a tank was at the entrance of

4 Kozarac, it was clear that the tank would be used in the

5 conflict in Kozarac. I think it is absurd to think about

6 fighting tanks with rifles. I do not know who could have

7 thought about that. It is already on May 3rd that the Serbs

8 gave clear indications that they would use tanks in Kozarac. I

9 do not know why, how, what an idea it would be had it not been

10 for the conflict. I thought that it would be best if I left

11 Kozarac, and I think that many left before me following the same

12 kind of thinking.

13 Q. During 1992 you repeatedly attempted to obtain information on

14 the number of weapons that the Kozarac reserve police had?

15 A. You cannot say -- you could not say that I tried, that there

16 was -- there were always discussions to return the weapons or

17 not. During our meetings in Prijedor it was discussed. There

18 was always arguments, whether they were secret weapons brought

19 in from Sarajevo or whether they were supplying in another way.

20 But none of this information was verified.

21 So, that information seeped into my head as it did

22 into everybody else's. There were a lot of unknowns. My

23 curiosity, if it existed, it was all based on fear for my own

24 personal security. I knew what was to happen. If I had known

25 what was going on, I would have left Kozarac much earlier. Why

26 did I come back, and I would not have taken my family out if

27 I had any other option.

28 Q. In fact, it is not me who says that you repeatedly attempted to

Page 8026

1 do so. I am just reading from your letter at this point,

2 Mr. Tadic, and I am quoting it on page 4: "When I repeatedly

3 attempted to obtain from him information about the number and

4 nature of weapons the Kozarac reserve police had" -- that is

5 what you wrote in 1993 when you prepared your report about your

6 activities from 1990 to 1993.

7 A. I was curious, that is true, but that is where it stayed. Just

8 as many were curious about whether I had weapons or whether

9 I knew somebody maybe, what was going to happen, but I did not

10 know anything. That was the exchange of views. I do not think

11 that it was anything very significant.

12 Q. Mr. Tadic, you did not engage in these efforts because you were

13 curious or because you were a simple, ordinary person. You did

14 those things because you were an earnest SDS member and a

15 self-proclaimed activist. You describe yourself as an activist

16 in this letter, don't you?

17 A. You could say after August 15 1992 I was, sort of, an activist

18 but nothing before that.

19 Q. You did these things because you were an enthusiastic supporter

20 of the idea of creating Republika Srpska, and that is what you

21 said in this letter?

22 A. Every lay person in Bosnia and Herzegovina, that there are three

23 constituent people in Bosnia, Croats, Muslims and Serbs had the

24 equal rights and one of the reasons for my being in -- I lived

25 in a place which was 95 per cent Muslim and I never questioned

26 that. Up until 1992, all my contacts were with my neighbours

27 and in Prijedor I never met with people with whom I had not been

28 meeting before that. All people with whom I was meeting know my

Page 8027

1 views.

2 Had I not been thinking well about people in Prijedor

3 and had I not been thinking well -- meant well for people in

4 Kozarac, I never would have become active in a way I did.

5 Sometimes maybe people joined sentries in order to show to their

6 neighbours how they felt, but I was never in those sentries

7 myself.

8 Q. Mr. Tadic, you outlined all these activities to the officials

9 and others whom you intended to receive this letter and you told

10 them how you had worked since 1990 in order to contribute to the

11 creation of a common Serbian country?

12 A. I think this letter -- it was created in August, 8th August,

13 1993, and I had been arrested at least 10 times by the

14 authorities that you describe. At the entrance of the city hall

15 in Prijedor, I was again arrested and after that I had to leave

16 Republika Srpska. That is a reflection of my understanding

17 after that letter, that I still had -- that it was still a big

18 tragedy. I had no task.

19 That letter, it was written in a very simple way and

20 it is all based on the Assembly of the Local Commune

21 proceedings. The continuity between 1993, you can see there,

22 there is '93 and then there is 1990. That letter was not

23 directed to the authorities of Republika Srpska. They were only

24 -- I also visited the United Nations office in Belgrade and I

25 talked about that and nobody was really interested in that.

26 Q. After those efforts (some of which you detailed in the letter),

27 when the time came, May 24th, that the Srpski opstina Prijedor

28 would be cleansed of Muslims, you continued to contribute as an

Page 8028

1 activist in places like Omarska, Keraterm and Jaskici?

2 A. No, only the contribution to the revival of the Local Commune of

3 Kozarac and, as far as the ethnic cleansing is concerned that

4 you talk about, I do not know what my departure and what the

5 departure of my family from Republika Srpska means, if that is

6 not ethnic cleansing.

7 I did not leave there, because I had it good there

8 because I had some merits, because I thought I left because

9 I did not think that I could really rely on people. I know very

10 well where I was moving. I may be wrong about the dates, that

11 is true. I may be wrong about some descriptions, whether a

12 sleeve was blue or whether the uniform was blue or yellow, but

13 I know where I was all my life. I cannot forget that, and I

14 cannot be wrong whether I was in some location where I had never

15 been in my life. I can be wrong about the date, yes.

16 Q. But the cook, the carpenter, the florist, the home maker, the

17 businessman, the school teacher and dozens and dozens and dozens

18 of others from Kozarac, from Kevljani, from Prijedor, from

19 Hrnici, from Jaskici, from Sivci, they are all wrong?

20 A. I do not know what you have in your mind. I do not think that

21 anybody is guilty. Many who came here suffered, but I did too.

22 There is no difference there because I was a Serb and they were

23 Muslims or Croats. All the people who suffered are those who

24 did not want to fight in the Serb Republic on the front line.

25 Those activities were not deemed to anything much in the

26 beginning, those political activities. People who were --

27 during the communist period everything was taken over from the

28 old system.

Page 8029

1 Q. No, I am talking about the dozens and dozens and dozens of

2 people who saw you in those locations.

3 A. Maybe they saw me in Prijedor. Many of my neighbours whom I saw

4 and with whom I visited, they could see me there. They could

5 see me in Orlovci where I was doing my job. Some of them I even

6 met in Banja Luka, it is true. They could see me on TV images

7 when Monika Gras made her film, and she edited the footage

8 of '91 and puts it in as if it was '92 and then repeats it every

9 week. It was, it was there repeated in Germany every week. My

10 winter uniform and the summer in Trnopolje, that is what she has

11 cut together. So that is the truth.

12 MR. TIEGER: I have nothing further, your Honour.

13 THE PRESIDING JUDGE: One question, Mr. Tieger, would you go back

14 regarding the certificate that the German authorities showed to

15 Mr. Tadic. You have mentioned a particular Exhibit number and I

16 still want to make it clear in my own mind what certificate we

17 are talking about and whether or not that was shown to Mr. Tadic

18 by the German authorities.

19 MR. TIEGER: Your Honour, I read to Mr. Tadic from the text of the

20 interview and that is as far as the testimony went. If the

21 Court has a question about the relationship between the Exhibit

22 number referred to in the German interview ----

23 THE PRESIDING JUDGE: I will just ask.

24 Examined by the Court

25 Q. Mr. Tadic, the certificate that you have discussed and

26 Mr. Tieger asked you about, and the certificate I am referring

27 to is the one that indicates that you have been issued an

28 automatic rifle and 300 bullets. You have testified that you

Page 8030

1 received that from your brother Ljubomir and that you actually

2 filled in your name and the amounts, etc. When you were

3 interviewed by the German authorities, was that certificate

4 shown to you?

5 A. No, it was not shown to me. They described it to me and phrased

6 the question in a way whether I had received it from the

7 Territorial Defence in Banja Luka, "Did you get it as a member

8 of the Territorial Defence Unit?" And I said, "I hear about

9 such certificate for the first time". It was about signing on a

10 weapon. So that is -- and not what my brother gave me which

11 I filled out and which Mr. Prosecutor calls a forgery.

12 Q. So you had not received it from the Territorial Defence, that is

13 what you are saying? You had received it from your brother as

14 you have testified today?

15 A. Yes, the blank certificate and I filled -- I got it from my

16 brother and I knew the number of the rifle and it matches the

17 serial number of the rifle that Kusota signed out on. I think

18 that that can be verified.

19 THE PRESIDING JUDGE: Mr. Tieger, do you have additional questions in

20 the light of that question?

21 MR. TIEGER: No, your Honour, nothing arising from that.

22 THE PRESIDING JUDGE: Mr. Kay, do you have any redirect?

23 MR. KAY: Thank you, your Honour.

24 Re-examined by MR. KAY

25 Q. You were asked a series of questions about the interviews with

26 the Prosecutor in May and December 1995 and those were

27 interviews conducted by Mr. Robert Reid. You were asked, or it

28 was put to you, that you had documents there at the time of the

Page 8031

1 interviews. Just so it is clear to us, we have had documents in

2 this Court, but I would like to ask you this: were the lists

3 and the official duty plan that we had produced with the names

4 of people at checkpoint Orlovci as well as the list of names in

5 the schedule with you during that series of interviews in May

6 and December 1995?

7 A. I did not have that document. The one that Mr. Wladimiroff

8 provided, that was given to the Defence. I think that Simo

9 Drljaca was the chief. I had no reason to believe him and so

10 I did not regard that document at all. I was talking about what

11 I tried to remember.

12 Q. Did you have before you during the December or May interview a

13 letter that had been provided by Simo Drljaca?

14 A. No, no, exactly when that took place, there were two pieces of

15 paper with Simo Drljaca's signature and Mr. Wladimiroff put in

16 front of me, and I said that I could use it if I wanted to.

17 I told him that I did not need it and that was sitting next to

18 me. The official documents that I saw, the official working

19 lists, I did not see that.

20 Q. So, the documents that we have had produced in Court showing

21 those on duty at checkpoint Orlovci in the official duty plan as

22 well as the schedule of names with the times and dates were not

23 documents before you during those interviews?

24 A. They were not.

25 Q. I would like you now to look at the work report. If 344A could

26 be provided in your own language before you. 344B, if the Bench

27 have it, is the English translation of that document. Before it

28 goes before you, perhaps if it could be handed to me so that

Page 8032

1 I can find the appropriate passage?

2 If you could look at the text at the top of the page

3 that I am putting before you which is at the foot of page 7 of

4 the English translation? Perhaps if page 7 of the English

5 translation could be put on the overhead monitor? If it could

6 be moved up the screen so we can see the foot of the page? When

7 I raise my hand, if you could turn over to the next page?

8 Mr. Tadic, if you could read out from the top of the

9 that page? I believe it starts: "Fighting in Kozarac started

10 on 25th May 1992". Do you see that at the top? Could you read

11 that what is written in the text there in this work report or

12 letter to Dr. Karadzic? Can you read it out, please, in your

13 own language to us?

14 A. [No interpretation].

15 THE PRESIDING JUDGE: We are not getting any translation.

16 THE WITNESS: "Fighting in Kozarac started on 25th May 1992. One day

17 before that" ----

18 MR. KAY: Continue.

19 A. "Fighting in Kozarac started on 25th May 1992, and one day

20 before that I had left for Banja Luka where my family lived as

21 refugees in an abandoned house living off of our last saved

22 food. I never took part in the attack on Kozarac because,

23 despite everything after I had been living among those people

24 for 35 years, I still did not see why I would have to shoot at

25 my former neighbours when, surely, things would change with time

26 because the truth will come out and because I did not see that

27 all had to end in destruction and devastation. Mere luck saved

28 those few Serbs who had not been organised and the unexpected

Page 8033

1 chaos in the green berets. I came back to the Kozarac in June

2 of '90 and immediately joined the reserve police force in

3 Prijedor on the traffic police patrol at the checkpoint in

4 Orlovci".

5 Q. Thank you. That is that passage.

6 JUDGE STEPHEN: Does that mean the translation is inaccurate?

7 MR. KAY: No. I am re-examining him on a document that was put

8 before him in relation to his activities at the time.

9 JUDGE STEPHEN: Yes, but there are two lines that appear in the

10 English that were omitted.

11 MR. KAY: I am just going back to that, your Honour, as I was able to

12 notice that as well.

13 JUDGE STEPHEN: Thank you.

14 MR. KAY (To the witness): Could you read it more slowly? I want you

15 to go back to the position of "living among those people for 35

16 years" which I think you will find is about the fourth line.

17 Just read it slowly, not at 100 miles an hour.

18 A. "I never took part in attack on Kozarac because despite

19 everything, after I had been living among those people for 35

20 years, I did not see why I would have to shoot at my former

21 neighbours, and in time the truth will come out whether it all

22 had to end up in destruction and devastation, this setting up

23 and looting of people's property, disregarding of who the

24 previous owner was. Mere luck saved those few Serbs who had

25 luck".

26 Q. Just stop there. Can you just go back a sentence and please

27 read it slowly so that the translator can catch your words. Go

28 back to the "35 years" and just read it slowly. Just start at

Page 8034

1 the "35 years".

2 A. "I never took part in the attack on Kozarac because despite

3 everything, after I had been living among those people for 35

4 years, I thought that I should not shoot at my former

5 neighbours, and that in time the truth will come out whether it

6 all had to end in the destruction and devastation, in setting up

7 camps and looting of property, disregarding of who the previous

8 owner was."

9 Q. Thank you. Your Honour, that is all I ask in re-examination.

10 Great reference has been made in the cross-examination to the

11 two interviews that took place in May and December 1995.

12 I would ask that those be made as Exhibits before the Court in

13 the form of the English translation, so that the Court is able

14 to see the full extent of those interviews.

15 THE PRESIDING JUDGE: We have heard a lot of statements and they have

16 been used throughout the trial. I suppose in cross-examination

17 we never received all of the statements though. What is the

18 position of the Prosecutor? Do you have any objection?

19 MR. TIEGER: It had been our intention to tender that document in the

20 course of our rebuttal case, but if the Court wishes it now we

21 do not have any objection.

22 THE PRESIDING JUDGE: We will wait until the rebuttal.

23 MR. KAY: I anticipated that was the case as I know Mr. Reid is being

24 called at the rebuttal stage. It just occurred to me it would

25 be useful for the Court to have it now.

26 THE PRESIDING JUDGE: It might be better to come in in the orderly

27 way so we can receive the benefit that whoever is going to offer

28 it wishes us to have. Is there anything else? Mr. Kay?

Page 8035

1 MR. KAY: We do not have any witnesses for today, but it looks as

2 though we will get through our business at a fairly early point

3 tomorrow.

4 THE PRESIDING JUDGE: That is what I understand from Mr. Bos.

5 Mr. Tieger, you are standing still, do you want to contribute

6 something or did you have additional questions? I do forget,

7 I am sorry. We got on to other matters about the Exhibit. Do

8 you have any recross, Mr. Tieger?

9 MR. TIEGER: Yes, your Honour. Thank you.

10 Further Cross-Examined by MR. TIEGER.

11 Q. Mr. Tadic, with respect to the letter that your counsel referred

12 to when asking you about the rosters and dates, that letter was

13 a timetable of the times and dates at the Orlovci checkpoint, is

14 that correct, the timetable of shifts?

15 A. I do not remember exactly.

16 Q. Well, do you recall that it was a list -- you do not recall the

17 letter at all?

18 A. I remember two pieces. When I saw the signature of Simo Drljaca

19 I left it with my family. I was not interested in that, because

20 I was not sure whether his information was accurate. In view of

21 some previous events I believe that something may be incorrect.

22 Q. Did you not have that document with you during the December 22nd

23 1995 interview?

24 A. If you allow me, if you show me that, I could tell you. It is

25 not a letter. It is just two pieces of paper.

26 Q. Your Honour, may this be marked for identification as

27 Prosecution next in order? Mr. Tadic, this is the timetable of

28 shifts, among the timetables of shifts which accompanied the

Page 8036

1 letter, correct?

2 A. I have seen this paper, but I do not know which letter you are

3 referring to. It is not clear to me.

4 Q. Well, this is among the documents you had with you on December

5 22nd 1995 and which you referred to during the course of that

6 interview?

7 A. At one point Mr. Wladimiroff did give me such a sheet of paper

8 with this information, so I had it with me. Yes, this is the

9 document. I just do not think that the signature was the same.

10 I think it was -- yes, timetable of shifts, but the signature

11 was not like this, nor was the stamp. I am not sure. I am not

12 sure if it is the same document. I think there were two sheets

13 of paper, not one. It is not a complete document.

14 Q. There were other dates on there. As you can see that particular

15 document, Exhibit 361, refers to June and July, and the other

16 documents refer to following dates, isn't that true?

17 A. If you say so it must be that way. I just say that I have seen

18 two sheets of paper. I do not know whether this was one of

19 them. I do not remember. I did not pay any attention after

20 that. I just think that it was signed by the Chief of Police,

21 Simo Drljaca. The signature here is Jankovic Mile. I am not

22 sure if this is the paper. If there is another paper I would

23 kindly ask you to give me that paper so I can tell you for

24 certainty whether we are talking about the same thing.

25 Q. May I have this marked as Prosecution Exhibit 362.

26 A. Yes, this is a complete document. This is the form I received

27 and you have here Chief of the Security Services Centre, Simo

28 Drljaca, but I did not have this paper during my interview in

Page 8037

1 Germany and my first interview in The Hague. I did have it at

2 some point during a second interview. Mr. Wladimiroff who had

3 asked one of your members if he could use that, gave me that

4 document and then I had it. I saw the signature Simo Drljaca

5 and I had a look at the document. I just skimmed it and I did

6 not pay any attention to details.

7 Q. May I ask that that document be tendered for admission, your

8 Honour?

9 THE PRESIDING JUDGE: Is there any objection to 361 and 362?

10 MR. KAY: No, your Honour.

11 THE PRESIDING JUDGE: They will be admitted.

12 THE WITNESS: Because here under the paragraph 1 you see that here

13 these are the extracts from timetable of shifts, and at that

14 time we did not have the timetable of shifts available.

15 MR. TIEGER: The ones which were introduced in court?

16 A. Yes.

17 Q. This document is a compilation of those rosters?

18 A. That is what it says here. I did not know whether it -- I did

19 not know whether it was true or not, because here you have an

20 extract from something.

21 Q. Your Honour, I had that marked temporarily as two different

22 Exhibits. I do not think that is appropriate under the

23 circumstances. In addition I would like to have the witness

24 shown this document.

25 THE PRESIDING JUDGE: I gather 362, is that for other months, perhaps

26 August and September?

27 MR. TIEGER: This is ----

28 THE PRESIDING JUDGE: No, 362.

Page 8038

1 MR. TIEGER: Right. One is a letter -- those should be marked, it

2 seems to me, 361A, B and C, and this would be C.

3 THE PRESIDING JUDGE: Let us see what this is.

4 MR. TIEGER: Was that part of the document as well?

5 A. It is possible, it is probably that it is, but I cannot claim

6 with certainty when I saw it for the first time. This document

7 is also an extract of something, of a timetable of shifts. So

8 it is a copy of what was written in the police station in

9 Prijedor. The signature is Marko Djinardja. I think that was

10 the person who was Commander of the police station at that

11 time. I was on duty. I was securing the police station in

12 Prijedor and I was also in charge of securing the bus station in

13 Prijedor.

14 Q. Your Honour, I can submit the English translations at the same

15 time.

16 THE PRESIDING JUDGE: Mr. Kay, is there any objection then to 361

17 becoming 361A, 362 will become 361B and what now has been marked

18 for identification purposes will be 361C? Do you have any

19 objection?

20 MR. KAY: No objection, your Honour.

21 THE PRESIDING JUDGE: No objection to the last Exhibit?

22 MR. KAY: No.

23 THE PRESIDING JUDGE: Then they will all be admitted as A, B and C

24 361.

25 MR. TIEGER: Mr. Tadic, you indicated that you do not recall

26 referring to this document during the course of your interview

27 with Mr. Reid?

28 A. I was told that I could use, I could refer to this document, but

Page 8039

1 I do not remember whether I used it and in what way.

2 Q. Well, do you recall being asked a question about the allegations

3 concerning the 20th, the time period on or around 20th July --

4 it is page 42 -- then being referred to the document by

5 Mr. Wladimiroff, and then subsequently providing an answer that

6 said: "In any case, I can say that that day I was on duty as a

7 reserve traffic policeman in Orlovci. I was on duty from 7 a.m.

8 to 7 p.m."? Is that something you did without recourse to the

9 document?

10 A. I do not remember. It is also possible that I had a look at the

11 document. I think that his questions were put in such a way

12 that I had to answer whether this was true. That is how

13 I understood it. That was the kind of answer that I gave him,

14 whether it was true or not. At first sight I realised it was

15 not an official document. I knew that there were other

16 documents which are kept in Prijedor.

17 Q. Well, I believe the question on page 41, Mr. Tadic, was: "Is

18 there anything you wish to say in relation to that allegation?"

19 Does such a general question refresh your memory about whether

20 or not you referred to the document yourself in providing such a

21 specific date and time?

22 A. I think that these dates were not especially important in our

23 interview, but it became clear at that moment that there were

24 original documents at that time, and the investigator could go

25 there and check those documents. I only thought that we could

26 talk about whom I spoke and so on at that time. It is perfectly

27 clear how I spent my time there.

28 Q. Mr. Tadic, you wrote your work report in August 1993 and you did

Page 8040

1 so at a time when you were preparing to leave Prijedor, is that

2 right?

3 A. I was not sure whether I was going to leave at that time. It

4 occurred on the 9th, but I was not sure.

5 Q. By that time you were already aware of allegations against you

6 concerning activities in camps and during the cleansing?

7 A. No. I had read some information in Serbian paper Vrema. They

8 were just general allegations in relation to crimes committed.

9 That is what I read in Banja Luka. That information had been

10 sent from Prijedor by the Prijedor authorities in agreement with

11 some journalists, and that is how Mrs. Monika Gras arrived with

12 some policemen to make a video of me in January '93. She could

13 not come to Kozarac without the approval of Mr. Simo Drljaca who

14 finally issued an approval for that, because he knew what he was

15 doing. The subject of Omarska was then simply transferred to

16 Kozarac.

17 Q. You knew this letter was intended to be sent to the media in

18 Yugoslavia and elsewhere?

19 A. That letter should be read from the beginning till the end, and

20 you can easily see that it does not make sense. It relates to a

21 period of three years. I was not a professional. I could not

22 compose a professional letter for the media. That information

23 was taken from the minutes that were available to me at that

24 time. I was being persecuted. I was on the run and that is

25 what I managed to write in a very short period of time. You

26 have many mistakes there. You have very long periods of time.

27 There is a mention of the date of 10th June and so on. So I put

28 zero instead of six. It was not important for me at that

Page 8041

1 moment. I did not think about that at that moment. The essence

2 of what had happened was there.

3 Q. You planned to take this letter with you to Germany where it was

4 ultimately seized from your home?

5 A. No. A lot of documents that you have offered here as evidence

6 against me were found with those papers. If I had thought about

7 that I would have never taken them with me to Germany. I do not

8 know what kind of use I could have with those documents in

9 Germany, I mean, the fact that I had weapons and things like

10 that. I was a persecuted man at that time, ever since the

11 beginning of 1993 until my departure from Yugoslavia. I did not

12 leave because I wanted to leave.

13 Q. This letter was intended to be sent, not to remain in your

14 personal confidential possession as a secret, correct?

15 A. I did not think about that at all. I only remembered about this

16 letter from when the German authorities told me about it. I did

17 not think of any of the documents that I had. I packed within

18 half an hour. I did not have a visa for Germany and it was by

19 sheer luck that I got it through my brother. I left with the

20 Yugoslav selection to Germany. My brother did not send me a

21 guarantee. My brother did not want me to go to Germany and my

22 wife was not there with my brother. She was staying with his

23 former wife and I did not send my wife and my children to my

24 brother's. I had a very bad experience with Serbs, whoever they

25 were.

26 MR. TIEGER: That is all, your Honour. Thank you.

27 THE PRESIDING JUDGE: Mr. Kay?

28 MR. KAY: Nothing arises, your Honour.

Page 8042

1 Examined by the Court.

2 JUDGE STEPHEN: Mr. Tadic, this letter, the work report, did you in

3 fact send one copy off or deliver one copy off to somebody, or

4 did you simply take it with you in your papers?

5 A. When I wrote that letter I made two copies of it. One copy was

6 delivered by me on the same day in Prijedor, and I took the

7 other with me. I left it in my flat in Prijedor. At the time

8 of my arrest on 9th August I just grabbed whatever I could get

9 hold of and fled to Banja Luka.

10 Q. I appreciate that. To whom did you deliver the letter in

11 Prijedor?

12 A. At the very entrance in to Prijedor there is a sort of reception

13 office and I left it there. It is a common procedure if you

14 wanted to hand over any kind of document, if you wanted your

15 document to reach some authority.

16 Q. Yes. At the very entrance to what? You say "at the very

17 entrance"?

18 A. To the town hall in Prijedor.

19 Q. The Monika Gras interview with you which was made into a film,

20 when did that occur, about?

21 A. I know. I remember that event very well. On 31st December

22 in '92 I was in Belgrade. I was there for the New Year's Eve.

23 I came back and I was surprised to learn. At the beginning

24 of '93 in January I went to my work, my work as the Secretary of

25 the Local Commune in Kozarac, and all of a sudden I saw just

26 across the church a TV team and Monika Gras, whose name

27 I learned later on, were there together with two policemen from

28 Prijedor. They were talking to Dusanka, I do not her surname

Page 8043

1 but at that she was working as a teleographer (?) in the

2 Prijedor police station. At one she said: "They are looking for

3 you. They want to talk to you." I said: "Why to me?" They

4 explained that they had come to Prijedor under somebody's

5 instructions and the Commander had sent them there. I did not

6 know what it was all about, and Dusanka told me: "They are

7 talking about the church. They do not believe that it is 120

8 years old church", and so on. I told them that I did not want

9 to talk to such people, because I did not know what the

10 conversation would be about.

11 Q. But I only wanted to know the date and you have told me that.

12 One other thing I wanted to know about it. Did the film accuse

13 you of acts similar to some of those in the present indictment?

14 A. Yes, and partly the text and the warrant of arrest, that was

15 publicly declared by Emin Jakupovic on TV and some other

16 people. It was obviously a suggestion of Monika Gras. They

17 kept saying "Dule, Dule, Dule". There was a big montage which

18 showed my image at that time. They were filming me and I was

19 not aware of that fact.

20 Q. I think that at one stage in your evidence you mentioned

21 somebody by the name of Cirkin, and I think that you referred to

22 him as having a criminal record. Am I right in the name?

23 A. Yes.

24 Q. Is that the same person as the Captain Cirkin that we, long ago

25 now, in evidence heard had been organising Muslim resistance, or

26 is it a different person altogether?

27 A. It is a different person. I now remember the name. His name

28 was Ramiz Cirkin. He had spent many years in prison and he was

Page 8044

1 well-known in that area.

2 Q. If it is a different person ----

3 A. It is not the same person.

4 Q. If it is not the same person I am not interested. The next

5 thing I wanted to ask you was about the checkpoint at Orlovci.

6 We have heard a lot about caravans, containers. You spoke about

7 caravans. Initially there was nothing. Then there was a

8 caravan. At any time were there two containers beside the

9 checkpoint?

10 A. It is quite possible. To be frank, I cannot say with certainty

11 because we did not pay much attention to that vehicle. We never

12 really used them. They belonged to the military police. They

13 had their instructions about that. They did what they wanted

14 with that. It is possible. We mainly used our vehicles,

15 vehicles which belonged to the police, because we had a radio

16 connection from the car.

17 Q. The final question I wanted to ask you was, you said, I think,

18 that the real reason for your frequent arrests by the military

19 police in 1993 was not a question, as I had perhaps earlier

20 gathered, of rivalry over the ownership of a cafe or the

21 operation of a cafe in Prijedor, but there was another real

22 reason. What was that real reason?

23 A. For a very long time I thought that the cafe was the reason and

24 my family thought so. However, when I publicly stated that

25 I would not use that cafe, those business premises, I had

26 adapted it and so on, but it would have been absurd for me to

27 enter into any kind of business at that time because the

28 military had the power at that time. But after several arrests

Page 8045

1 took place I realised that that was not the case, because they

2 knew that the cafe was no longer a problem. The real reason

3 I think was the fact that I had become involved in the revival

4 of Kozarac. They did not want Kozarac, life to be brought back

5 to Kozarac, and they did everything they could not to revive

6 that town.

7 Q. Who is "they"?

8 A. It was only later that I understood. The municipal Crisis Staff

9 had an absolute power. They were above everyone else, above the

10 Regional Crisis Staff and the area of Kozarac at that time was

11 under the jurisdiction of the Regional Crisis Staff in

12 Lamovita. We were just mocked by people from the Regional

13 Crisis Staff. We were insignificant.

14 JUDGE STEPHEN: Thank you.

15 THE PRESIDING JUDGE: Additional questions, Mr. Kay?

16 MR. KAY: No, thank you, your Honour.

17 THE PRESIDING JUDGE: Mr. Tieger?

18 MR. TIEGER: Your Honour, if I could just have a second. Thank you

19 your Honour.

20 Further Cross-Examined by MR. TIEGER.

21 Q. Mr. Tadic, you mentioned that you intended to drop the letter

22 off for a municipal official in Prijedor. Who was that

23 official?

24 A. I do not know with whom I left it. I did not think about that.

25 I know that in the town hall there were some authorities like in

26 any other town hall, but it was not any specific individual and

27 I did not believe that it would end up in the hands of Karadzic,

28 as you stated. If it had ended up in his hands I would not have

Page 8046

1 been arrested maybe.

2 Q. You said you went to Germany as part of the Yugoslav selection.

3 What did you mean by that?

4 A. I was not a member of the Yugoslav selection. My brother was

5 very influential, a karate sportsman, and very often he was the

6 host of the Yugoslav selection in karate in Germany. So he had

7 intervened with the then President of the karate association and

8 he asked him to help me with the visa, because I had no other

9 opportunity to go to Germany. So I was some kind

10 of -- I accompanied the selection, the karate selection of

11 Yugoslavia at that time.

12 THE PRESIDING JUDGE: Mr. Kay?

13 MR. KAY: No thank you, your Honour.

14 THE PRESIDING JUDGE: Just one question. Mr. Tadic you just

15 indicated that you did not know the person whom you left the

16 letter with at the reception centre. But who was the official

17 to whom you wanted this letter delivered?

18 A. I did not have any specific person in mind. I was just thinking

19 of someone who could help me and who could check those data.

20 I did not think about that. If I had thought about that I would

21 have sent it maybe to the Chief of Police as any ordinary

22 citizen would do. I did not have a clear idea in my mind about

23 what to do with it.

24 Q. So you left it with the reception centre in Prijedor, at the

25 town hall?

26 A. Yes.

27 Q. Did you leave it in an envelope with anyone's name on it or did

28 you just leave it with the receptionist?

Page 8047

1 A. It was in an envelope. I just left it there. I put

2 "Municipal" ----

3 Q. Municipal?

4 A. --- "Assembly Prijedor".

5 THE PRESIDING JUDGE: Mr. Kay, additional questions?

6 MR. KAY: No thank you, your Honour.

7 THE PRESIDING JUDGE: Mr. Tieger?

8 MR. TIEGER: No thank you, your Honour.

9 THE PRESIDING JUDGE: Mr. Tadic, I presume will be excused. You will

10 be with us. My usual question is, is there any objection to the

11 witness being permanently excused. I am sure you have heard me

12 say that for several months now. So I do not have to say that

13 today. We will adjourn until tomorrow at 10. I understand from

14 Mr. Bos that you expect you will be finishing tomorrow with your

15 case in chief?

16 MR. KAY: Yes, your Honour.

17 THE PRESIDING JUDGE: Very good. We will adjourn until tomorrow at

18 10 a.m.

19 (5.30 p.m.)

20 (The court adjourned until the following day).

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