Page 1848

 1                           Wednesday, 5 May 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.15 p.m.

 5             JUDGE KWON:  Good afternoon everybody.  I was advised that there

 6     are preliminaries from both parties.  Mr. Tieger.

 7             MR. TIEGER:  Thank you very much, Your Honour.  The first matter

 8     I would need to raise in -- well, there's two matters, one in open

 9     session, one in private.  I think the other matter to which the Court

10     alluded would also be raised in private, so let me go to the second

11     matter first, the one that can be raised in open.

12             I raised this with Mr. Robinson today.  As the Court will recall,

13     the redirect examination of the previous witness was abbreviated as a

14     result of the understandable interest on all sides to conclude the

15     witness's testimony by the end of the court week and also to allot as

16     much time as possible for the actual cross-examination rather than

17     redirect.  For that reason, I raised with Mr. Robinson the possibility of

18     submitting a very few documents that I would have submitted to the

19     witness during the course of redirect examination.  It constitutes a

20     total of six documents.  I inquired whether there was any objection in

21     principle on the part of the Defence to this proposed admission.

22     Mr. Robinson indicated there was not.  It's in light of the circumstances

23     and the fact that it was a limited number of documents rather than a

24     massive, wholesale submission.

25             I provided Mr. Robinson with a list of the proposed documents so

Page 1849

 1     he could review the specifics, but I simply wanted to bring that to the

 2     Court's attention at the earliest opportunity so you know that matter is

 3     being considered.  Once Mr. Robinson has had an opportunity to review the

 4     documents and indicate his position on them specifically, I'll make the

 5     formal submission to the Chamber.

 6             The second matter, as I indicated would be in private session, if

 7     that's possible.

 8             JUDGE KWON:  Before we go into that, I wonder whether

 9     Mr. Robinson is in a position to give any confirmation.

10             MR. ROBINSON:  Yes, Mr. President.  I haven't had a chance to

11     discuss the specific documents with Mr. Karadzic yet, so I can't say

12     whether or not we would agree, but in principle we will try to co-operate

13     and facilitate the admission of the exhibits, if possible.

14             JUDGE KWON:  Thank you.

15             Mr. Tieger, in the meantime, did the Chamber receive that list of

16     documents yet?

17             MR. TIEGER:  No, I can do so, Your Honour, if the Court wishes.

18             JUDGE KWON:  Thank you.  Then we'll go into private session

19     briefly.

20                           [Private session]

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

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Page 1852

 1                           [Open session]

 2             JUDGE KWON:  Yes.  We are now in open session.  Mr. Robinson.

 3             MR. ROBINSON:  Thank you, Mr. President.  This deals with the

 4     62 ter statement of the witness who is about to come in to testify, and

 5     we thought it would be better to deal with this before she came, rather

 6     than asking her to be excused when she had identified her 92 ter

 7     statement.  There are some points in the statement that we ask to be

 8     excluded, and they relate to sniping and shelling incidents which are not

 9     charged in the indictment, in particular, in paragraphs 10, 16 through

10     18, and 37.  There are mention of some incidents which do not appear in

11     the Schedule F or G which list the shelling and sniping incidents in the

12     indictment.  And it's our position that when specific mention is made of

13     specific victims and dates that those things should have been pled in the

14     indictment and that it would frustrate the Trial Chamber's order under

15     Rule 73 bis (D) if the Prosecution were allowed to add new incidents that

16     were not the subject of the indictment.

17             As you know, you requested them to reduce the number of incidents

18     and they did that.  They eliminated Schedule G(3), (16), (17) and (18)

19     and sniping incident F(13), and we think if they're allowed to introduce

20     evidence of things that were never even in the indictment that that would

21     be frustrating the Chamber's ruling in which the Chamber indicated it was

22     gravely concerned about the scope of the Prosecution's case and the

23     potential effect it would have on the fair and expeditious conduct of the

24     trial and administration of justice.  And I'm quoting from the decision

25     on the application of Rule 73 bis that you issued on the 9th of October,

Page 1853

 1     2009.

 2             The second issue relates to paragraph 38 of the statement, and we

 3     believe that this should be excluded on the grounds of physician/patient

 4     privilege.  The witness is repeating what a patient told her about her

 5     father, and I have to admit this is an issue that is not -- we have not

 6     been able to find any jurisprudence on at the ICTY or the ICTR as to

 7     whether a physician/patient privilege is even recognised by the Tribunal.

 8     But it is recognised in other international instruments as well as many

 9     local jurisdictions, and we feel it ought to be recognised in this

10     Tribunal.

11             So those four -- those four groupings of paragraphs, paragraph

12     10, 16 through 18, and 37 we ask be excluded on the grounds that those

13     incidents should have been in the indictment if the evidence were to be

14     led on them, and paragraph 38 as a communication that is covered by the

15     physician/patient privilege.  Thank you.

16             JUDGE KWON:  And you are not objecting to the -- oh, when we --

17     you may deal with it when it comes, but do you have any say as to the

18     diary that the witness kept?

19             MR. ROBINSON:  Yes.  We don't object to the diary.

20             JUDGE KWON:  The -- that privilege you referred to can be invoked

21     by the physician or nurse but only can be waived by the patient.

22             MR. ROBINSON:  I believe that unless the patient waives it, the

23     physician or nurse is not allowed to give evidence without a waiver.

24             JUDGE KWON:  My question is whether the accused has any right or

25     authority to interfere with that privilege.

Page 1854

 1             MR. ROBINSON:  No, he has no right to interfere with the

 2     privilege but the Chamber, I think, would have an obligation if it

 3     believes that the privilege exists to make sure that there's been a

 4     waiver before privilege is violated.

 5             JUDGE KWON:  And I just had the opportunity to take brief look at

 6     paragraph 38.  Separate from the probative value it will have, if any,

 7     can we not view it as a kind of direct observation of what the witness

 8     saw and heard?

 9             MR. ROBINSON:  Well, it's definitely an observation of what the

10     witness heard, but that's the whole point of the privilege because it

11     says I asked her about this and then it quotes what she said.  So it's a

12     communication between a patient and a nurse.  So we think it's directly

13     covered by the privilege.  I agree the probative value is low, but I

14     think this is an issue -- there are also physicians who are going to be

15     testifying in the case, and so this is an issue that will come up again

16     and perhaps this would be a good time to try to resolve it.

17             JUDGE KWON:  Thank you.  Judge Morrison has a question.

18             JUDGE MORRISON:  Mr. Robinson, you no doubt are very aware of the

19     position in the United States.  Bearing in mind that there's no direct

20     jurisprudence in the Tribunal, we're going to obviously have to look for

21     guidance outside the scope of the -- our inherent findings in previous

22     cases.

23             You would agree, I presume, that there is a difference between

24     medical privilege and legal privilege.

25             MR. ROBINSON:  Yes.  In fact, the legal privilege is

Page 1855

 1     attorney/client privilege, if you're referring to that specifically

 2     provided for in the ICTY statute.

 3             JUDGE MORRISON:  And presumably in the US, as in the UK, that is

 4     a distinction which is recognised.

 5             MR. ROBINSON:  It is recognised.  It's a different privilege, a

 6     privilege -- it's a stronger privilege for lawyer/client communication

 7     than it is for patient/physician.

 8             JUDGE MORRISON:  And the privilege is one, that the President has

 9     said, that can be raised by the physician but only waived by the patient

10     because it's the patient's privilege, as in a legal sense it would be

11     the -- an accused's person privilege in an attorney/client relationship.

12             MR. ROBINSON:  Exactly.

13             JUDGE MORRISON:  But the difference surely is this:  That where

14     it's an issue of confidentiality, medical confidentiality, it's called

15     privilege, but in reality it's an issue of confidentiality between the

16     physician and the patient.  If the doctor elects to ignore that

17     privilege, that's not a matter for the Court.  The issue then becomes an

18     issue between the patient and the doctor or the doctor's, as it were,

19     ethical obligations or medical council, or whatever, in the jurisdiction

20     that that doctor practices rather than an issue for the Court.  What the

21     issue for the Court is whether or not what is likely to be said is

22     relevant and probative and is generally of assistance in the case.

23             MR. ROBINSON:  Well, I think the Court has to deal with whether

24     the privilege -- whether it can hear evidence which is being offered in

25     violation of the privilege.  This actually came up in the Simic case with

Page 1856

 1     respect to the Red Cross.  In that case, there was an employee of the

 2     International Red Cross who was ready willing and able to give evidence

 3     about what he had observed while working with the Red Cross and had given

 4     a statement to the Prosecution about those things.  But the Chamber ruled

 5     that it was the privilege of the Red Cross that was at issue, and unless

 6     they waived that privilege, despite the willingness of the employee that

 7     it would exclude the evidence, and it did exclude the evidence, because

 8     the Red Cross wasn't willing to waive that privilege.  So I think

 9     although the privilege should be invoked by the person who is appearing

10     before the Chamber, we can't -- the Chamber has the right -- has the

11     obligation to see that the privilege isn't violated and needs to have

12     some evidence from the privilege holder that they've waived it,

13     regardless of the willingness of the person who's here before you.

14             JUDGE MORRISON:  Yes.  Well, that's -- as I say, that would be --

15     would not be the position in the UK law, and would not be the position,

16     as I understand it, in the US law.  The question of whether or not the

17     Court would admit the evidence would be balancing exercise as to whether

18     or not the breach of confidentiality was justified in the circumstances

19     of the case.

20             MR. ROBINSON:  I think the UK and the US are a little different

21     on that.  The UK --

22             THE INTERPRETER:  Could Mr. Robinson kindly slow down for the

23     interpretation.  Thank you.

24             MR. ROBINSON:  Yes.  I've been asked to slow down.  Sorry about

25     that.  I think my understanding is the UK looks at it as a policy issue,

Page 1857

 1     and the US and some other jurisdictions look at it more as a technical

 2     privilege issue.  I have to say that in the US, it's only available in

 3     civil cases, not in criminal cases.  But I believe in civil cases, when

 4     the privilege issue comes up, the US will not allow the evidence unless

 5     there's a waiver by the patient.

 6             JUDGE MORRISON:  But is that perhaps that the US is a far more

 7     litigious society?

 8             MR. ROBINSON:  We certainly are, yes.

 9             JUDGE KWON:  Will it be Ms. Sutherland or Mr. Tieger?

10             MS. SUTHERLAND:  Yes, Your Honour.  Your Honour, Mr. Robinson's

11     objections to the admission of parts of Mrs. Zaimovic's statement, on the

12     basis that it includes evidence of acts not charged in the indictment, is

13     misguided on three fronts.  First of all, her evidence is relevant to the

14     charges of terror contained in the indictment.  And passages of the

15     paragraphs that Mr. Robinson referred to do contain that.

16             It's also relevant to the allegations of a widespread or

17     systematic attack against the civilian population of Sarajevo, which is

18     contained in the indictment.  And as Your Honours know, appellate

19     jurisprudence allows for the admission of evidence related to unscheduled

20     incidents as proof of general elements of the crimes charged.

21             THE INTERPRETER:  Kindly slow down when reading for the

22     interpretation, thank you.

23             MS. SUTHERLAND:  If I can go to the first point that her evidence

24     is relevant to the charges of terror contained in the indictment.

25             It requires the Prosecution to prove acts or threats resulting in

Page 1858

 1     grave consequences to the victim, and grave consequences include death or

 2     serious injury as well as psychological impact on the population.  And

 3     that is to say, evidence of actual terrorisation may contribute to

 4     establishing other elements of the crime of terror; for instance, grave

 5     consequences.  And that's the Dragomir Milosevic Appeals Chamber

 6     judgement of the 12th of November, 2009 at paragraphs 33 and 35.

 7             Her evidence is also relevant to the allegations of widespread or

 8     systematic attack against the civilian population and that's -- I take

 9     Your Honours to paragraph 88 of the indictment, and it's well established

10     in the jurisprudence that they -- that the crimes against humanity

11     require proof of the existence of a widespread or systematic attack on

12     the civilian population.  And that's Perisic Trial Chamber decision on

13     the Prosecution's submission on interpretation of the Trial Chamber's

14     decision of the 15th of May, 2007, regarding unscheduled incidents.

15             The decision is dated the 31st of October, 2008, and it's at

16     paragraph 11.  That decision cites to Article 5 of the Tribunal in

17     Blaskic Trial Chamber judgement of the 3rd of March, 2000, in paragraph

18     98.  In fact, it's incorrect and this should be to the Appeals Chamber

19     judgement of the 29th of July, 2004, paragraph 98.

20             Mrs. Zaimovic's evidence is also relevant to the general nature

21     of the shelling and sniping campaign directed against civilians, and the

22     details provided by her in relation to the unscheduled incidents that

23     Mr. Robinson refers to are integral to a necessary -- to evaluate her

24     observations.

25             In relation to the third point that the appellate jurisprudence

Page 1859

 1     allows for the admission of evidence related to unscheduled incidents as

 2     proof of general elements of the crimes charged, Galic Appeals Chamber

 3     judgement of the 30th of November, 2006, paragraph 219 states that

 4     evidence regarding additional incidents could be introduced at trial

 5     pursuant to Rule 93 of the Rules, in order to prove a consistent pattern

 6     of conduct relevant to the charges in the indictment, including a

 7     campaign.

 8             There's also the case of Seselj which we referred to in our OTP

 9     first Rule 73 bis submission.  And that's the Seselj interlocutory appeal

10     decision on appeal against the Trial Chamber's oral decision of

11     9 January 2008, and the decision's dated the 11th of March, 2008.

12             At paragraph 24, where they affirm the Trial Chamber's ruling

13     that evidence of crime sites removed under Rule 73 bis (D) can go towards

14     proving the purposes and methods of a number of things which include the

15     general elements of the persecution campaign.

16             Your Honour, for those reasons, I submit that the evidence that

17     Mr. Robinson wishes to have excluded from paragraphs 10, which discusses

18     an attack -- sorry, a shelling that happened on the 14th of May, 2000 --

19     1992, and the evidence at paragraphs 16 to 18 which deal with shellings

20     which occurred at a school and in the Otoka area in November 1993, and in

21     relation to the evidence he seeks to have excluded at paragraph 37 which

22     relates to a shelling incidents which occurred on the 10th of October,

23     1992.

24             With respect to the evidence at paragraph 38, which has been

25     discussed between Mr. Robinson and the Bench already, the Prosecution --

Page 1860

 1     it's the Prosecution's position that this should be dismissed for a

 2     number of reasons, the first being that Mr. Robinson has not established

 3     the existence of a physician/patient privilege, and the recognition of

 4     such a privilege would frustrate international criminal proceedings, and

 5     in any event, in our submission, the type of information at issue is not

 6     likely to be governed by a physician/patient privilege.

 7             If I can turn to the first bases that he hasn't established --

 8     the Rules are obviously silent and that has -- we have been able to find

 9     no decision, either ICTY or ICTR that recognises the existence of this

10     privilege under conventional customary international law.  Rather, the

11     approach consistent with Tribunal jurisprudence would be that where a

12    third party confidentially exists, as Your Honours have already said, it's

13     for the Trial Chamber who has the discretion to weigh it against the

14     interests of justice, including the need to ensure that all relevant and

15     probative evidence is available to the Chamber.

16             The accused -- or Mr. Robinson, I should say, his general claim

17     that a -- of a medical privilege would not further the objectives.

18             Mr. Karadzic is subject to proceedings for having committed

19     crimes against individuals, and, in our view, he shouldn't be permitted

20     to assert the victim's physician/patient privilege as a bar to allowing

21     relative and probative evidence.  This Tribunal was established for the

22     Prosecution of persons responsible for war crimes, crimes against

23     humanity, and genocide.  And it is, therefore, evident that either

24     medical records or other evidentiary material connected with medical

25     assistance may be of importance and to allow the Defence to assert the

Page 1861

 1     privilege to oppose the use of evidence could lead to the

 2     stultification of international criminal proceedings.

 3             Your Honour referred to the case of the United States

 4     jurisdiction, and it's our submission that even under US law, the fact of

 5     a patient stating this to, in fact, a nurse, as opposed to a physician

 6     would not be privileged even in the United States.

 7             For those reasons, Your Honour, I submit that all of the evidence

 8     that Mr. Robinson objects to should be allowed to remain in the

 9     amalgamated witness statement.

10             JUDGE KWON:  Thank you, Ms. Sutherland.

11                           [Trial Chamber confers]

12             JUDGE KWON:  As regards the paras 10, 16 to 18 and 37, we agree

13     with the observation given by Ms. Sutherland.  They are relevant to the

14     general facts regarding terrorising and chapeau and general requirements

15     of the crime of the statute.

16             As regards 38, while we do agree with the Prosecution's

17     submission that in this case that patient and physician privilege is not

18     subject -- is not to be applied in this case, we do not find that

19     paragraph of great probative value; i.e., in order to be admitted as to

20     the truth of the girl's belief that para (A) is too speculative or

21     argumentative.  So in that basis, we would not admit that paragraph,

22     i.e., paragraph 38.

23             So your objection is partly overruled and partly granted,

24     Mr. Robinson.

25             That said, shall we begin with our evidence.  Let's bring the

Page 1862

 1     witness in.

 2             MS. SUTHERLAND:  The Prosecution calls Fatima Zaimovic.

 3             JUDGE KWON:  While the witness is being brought in, I was advised

 4     that there's an outstanding motion of the addition of 65 ter list to two

 5     documents.

 6             MS. SUTHERLAND:  Yes, Your Honour.

 7             JUDGE KWON:  I take it there is no objection to it, Mr. Robinson.

 8             MR. ROBINSON:  That's correct, Mr. President.

 9             JUDGE KWON:  It is granted.

10             And I was also told there was remaining business from the

11     previous witness, Exhibit 779 or 799.  So if you could remind me of that

12     matter later on.  Thank you.

13                           [The witness entered court]

14             JUDGE KWON:  If the witness could take the solemn declaration.

15             THE WITNESS: [Interpretation] I solemnly declare that I will

16     speak the truth, the whole truth, and nothing but the truth.

17                           WITNESS:  FATIMA ZAIMOVIC

18                           [Witness answered through interpreter]

19             JUDGE KWON:  Please, please be seated.

20             THE WITNESS: [Interpretation] Thank you very much.

21             JUDGE KWON:  Ms. Sutherland.

22                           Examination by Ms. Sutherland:

23        Q.   Witness, could you please state your name.

24        A.   Fatima Zaimovic is my name.

25             MS. SUTHERLAND:  With your leave --

Page 1863

 1             JUDGE KWON:  Yes, please go on.

 2             MS. SUTHERLAND:  With your leave, Mr. President, I will proceed

 3     with the requirements of Rule 92 ter.

 4             JUDGE KWON:  Yes.

 5             MS. SUTHERLAND:

 6        Q.   Mrs. Zaimovic, on the 26th of February, 2010, you signed an

 7     amalgamated statement; is that correct?  2010, yes.

 8        A.   Yes.

 9             MS. SUTHERLAND:  I would ask that 65 ter 22274 be brought up onto

10     the screen, please.

11        Q.   Is that your signature at the bottom of page 1?

12        A.   Yes.

13             MS. SUTHERLAND:  Could we please go to page 13.  Sorry, the

14     previous page.

15        Q.   Mrs. Zaimovic, you confirmed that this statement was read back to

16     you in the Bosnian language.  However, upon reviewing the statement

17     yesterday, you wished to make a correction to one paragraph; is that

18     right?

19        A.   Yes.

20             MS. SUTHERLAND:  Could we please go to page 5 of the document.

21        Q.   The correction relates to paragraph 15, regarding the first

22     sentence.  The words "sniper fire" should read "shell-fire"; is that

23     correct?

24        A.   Yes.

25        Q.   And the two patients from the internal client that are referred

Page 1864

 1     to in that first sentence are the two patients referred to -- the same

 2     two patients referred to in paragraph 13 above?

 3             MS. SUTHERLAND:  If we could just go to the previous page,

 4     please.

 5        Q.   Is that correct?

 6        A.   Yes.

 7        Q.   And you don't know of any patients or hospital staff who were

 8     killed by sniper fire at the Kosevo Hospital; correct?

 9        A.   I don't.

10        Q.   And you wish to correct the statement by deleting --

11             MS. SUTHERLAND:  If we can go to the next page, please, where

12     paragraph 15.

13        Q.   You wish to correct the statement by deleting the heading

14     directly above paragraph 15 and the first three sentences of paragraph 15

15     which related to those two patients; is that correct?

16        A.   Yes.

17        Q.   So do you confirm that with the above corrections, your

18     amalgamated statement accurately reflects your evidence and that you

19     would provide the same answers to questions if you were asked under oath

20     about these topics today?

21        A.   Yes.

22             MS. SUTHERLAND:  Mr. President, at this time I seek to have the

23     amalgamated witness statement 65 ter number 22274 admitted into evidence.

24             JUDGE KWON:  Unless it is objected to.

25             MS. SUTHERLAND:  With the caveat of the paragraph 38.

Page 1865

 1             MR. ROBINSON:  Yes, Mr. President.  We have no objection, but I

 2     would ask if the last sentence of paragraph 15 is being maintained.

 3             JUDGE KWON:  I take it whole para will be deleted.  Am I correct

 4     in so understanding?

 5             MS. SUTHERLAND:  Your Honour, the correction the witness wanted

 6     to make was in relation to the sniper fire.  So it was simply the first

 7     three sentences which referred to the two patients.

 8             JUDGE KWON:  You said three sentences.

 9             MR. ROBINSON:  I'm referring, myself, where she said:  "From time

10     to time, I found pieces of bullets and slugs in an attic room --"

11             MS. SUTHERLAND:  That's the fourth sentence.  So we simply are

12     asking for the first three sentences to be redacted and the heading.

13             JUDGE KWON:  Yes.  So you will produce a redacted version later

14     on.

15             MS. SUTHERLAND:  Yes, Your Honour.

16             JUDGE KWON:  Thank you.  It will be admitted as?

17             THE REGISTRAR:  As Exhibit P814, Your Honours.

18             JUDGE KWON:  814.  Thank you.

19             MS. SUTHERLAND:  With Your Honours leave, I'll now read a brief

20     summary of the witness's evidence.

21             Mrs. Zaimovic has lived all of her life in Sarajevo in Bosnia and

22     Herzegovina.  In 1979, she became the head of nursing in the Children's

23     Surgery Department of the Kosevo Hospital in Sarajevo.  She remained

24     working in that position throughout the war, 1992 to 1995.

25             During this time, Mrs. Zaimovic kept her own diary about the

Page 1866

 1     patients wounded during the war.  She listed in her notes the names of

 2     331 wounded children treated in the Children's Surgery Department of the

 3     Kosevo Hospital.  Wounded children were also treated at the Sarajevo

 4     State Hospital, Dobrinja General Hospital, and the Orthopaedic Clinic and

 5     Traumatology Clinic.

 6             Mrs. Zaimovic describes in detail the consequences of the

 7     shelling and sniping on patients and staff and traumatisation suffered by

 8     the children.  The Kosevo Hospital buildings were often shelled

 9     throughout the war, and a number of staff were killed as a result of

10     shelling.

11             The witness was working at the hospital when it was shelled,

12     killing two patients and wounding another who were hospitalised in the

13     nearby internal medicine clinic.

14             Mrs. Zaimovic witnessed, on a regular basis, the tank shelling --

15     a tank shelling Sarajevo town from the area of Osmice in Serb-held

16     territory.

17             Mrs. Zaimovic describes treating patients from shellings which

18     occurred at the Fatima Gunic school on 9 November 1993 and at Otoka on

19     10 November 1993.  She also describes the burn injuries as a result of

20     gas explosions.

21             The witness describes the shortage of utilities and medical

22     supplies and conditions under which she and her colleagues operated in

23     the hospital during the war, in particular the problems related to the

24     lack of electricity and sufficient water.  Operating conditions were very

25     difficult, especially in the winter.

Page 1867

 1             Mrs. Zaimovic also describes the personal sniping incidents and

 2     consequences of shelling and sniping on the witness and her family.  The

 3     witness felt constant fear throughout the war, afraid for her family, and

 4     for the injured and wounded children.

 5             Your Honours, that concludes the brief summary of the witness’s

 6     evidence, and I now intend to question the witness for approximately

 7     25 minutes.

 8             JUDGE KWON:  Yes, please.

 9             MS. SUTHERLAND:  And to highlight various aspects of her

10     evidence.

11        Q.   Mrs. Zaimovic, as your amalgamated witness statement is now in

12     evidence in this case, I will be asking you only a limited number of

13     questions relating to matters contained in your statement.  Before I do

14     that, I would like you to orient the Trial Chamber as to the location of

15     the Kosevo Hospital on a map.

16             MS. SUTHERLAND:  And I would ask that 65 ter number 11791 be

17     brought up onto the screen, please.

18             Your Honours, this is a map of Sarajevo and its environs, and

19     it's map 1 in the Sarajevo specific court binder which has been

20     distributed to Your Honours and the accused and the parties.

21        Q.   Mrs. Zaimovic, are you able to point to the area where the

22     Kosevo Hospital is situated?

23        A.   Kosevo Hospital is close to the centre.  If we look at the

24     stadium, the sports stadium here, it's here roughly.  That's where it is.

25     Somewhere around here.

Page 1868

 1        Q.   Okay.

 2             MS. SUTHERLAND:  Your Honour, I would seek to tender 65 ter

 3     number 11791 into evidence but without the witness's marking.

 4             JUDGE KWON:  Without the marking.

 5             MS. SUTHERLAND:  Yes.  It was simply to orient you as to where

 6     the hospital was situated.

 7             JUDGE KWON:  Yes.  It will be admitted.

 8             MR. ROBINSON:  As Exhibit P815, Your Honours.

 9             JUDGE KWON:  Thank you.

10             MS. SUTHERLAND:  I ask that 65 ter number 09390A be brought up

11     onto the screen.

12        Q.   Mrs. Zaimovic, do you recognise what is marked in red directly

13     below the word "Breka" on the map?

14        A.   Right underneath that word is the entire complex -- or compound

15     of the Kosevo Hospital.  It's an enormous compound containing 36 large

16     clinics.

17             MS. SUTHERLAND:  Your Honour, I seek to tender that document --

18     that cropped map into evidence.

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  As Exhibit P816, Your Honour.

21             MS. SUTHERLAND:

22        Q.   While we still have that map on the screen, are you able to point

23     to where the main entrance road is.

24        A.   It is here, around Bolnicka street.  That's where the entrance

25     would be.  The hospital actually had two entrances, one the main entrance

Page 1869

 1     and the other one the back entrance, as it were.  One was close to the

 2     orthopaedic clinic, right above the hospital itself.  So those are the

 3     two entrances that existed.  This was the main entrance, and this is

 4     where most of the ambulances entered the hospital premises.  It's in this

 5     first part here where Bolnicka street is.

 6        Q.   Yes.  And you -- your marking is where the -- the brown -- the

 7     line -- the road is marked in brown on the Bolnicka street side.

 8             MS. SUTHERLAND:  I would ask that Rule 65 --

 9             THE WITNESS: [Interpretation] Yes.

10             MS. SUTHERLAND:  I would ask that Rule 65 ter number 22797 be

11     brought up onto the screen, please.

12        Q.   Mrs. Zaimovic, do you recognise what's shown in this satellite

13     aerial image?

14        A.   I think that this is the entire hospital compound.  If you wish,

15     I can point it out to you.  It is this part around here.  That's the

16     compound of the hospital where I worked.

17             JUDGE KWON:  Ms. Sutherland, do you like the witness to mark

18     the --

19             MS. SUTHERLAND:  Yes, Your Honour.

20        Q.   If you can draw with a light pen.

21        A.   What is it that you would like me to point out?

22        Q.   The grounds of the Kosevo Hospital.

23        A.   [Marks]

24        Q.   Can you also point to the location of the Children's Surgery

25     Department during the war.

Page 1870

 1        A.   The Children's Surgery Department was close to the main gate.

 2     These are three big Austrian buildings.  That's it.  We were in the first

 3     building here.  That's where our department was.  These buildings are

 4     linked by long corridors or halls.  Also, the clinic of urology was

 5     there, pulmonology, the operation rooms, and so on.  Neurosurgery was

 6     there as well, but it was moved to another area afterwards, but basically

 7     all the surgery departments were in this area, along with five operation

 8     rooms that were on the ground floor.

 9             MS. SUTHERLAND:  Your Honour, I didn't intend to tender a marked

10     diagram, but for the -- for the record, the witness pointed to where the

11     Children's Surgery Department was, and it's the -- the second building,

12     the most southern -- south-eastern building on the -- on the image within

13     the compound, the Kosevo Hospital compound, and it has a red tiled roof.

14             I would seek to tender that document into -- that image into

15     evidence, Your Honour.

16             JUDGE KWON:  As marked.  As marked by the witness or without

17     marking?

18             MS. SUTHERLAND:  Without the marking, or if -- if -- if we --

19             JUDGE KWON:  Why don't we admit the marked version --

20             MS. SUTHERLAND:  Marked version [overlapping speakers]

21             JUDGE KWON:  Mrs. Zaimovic, if you could kindly sign your

22     signature on that image and date of today.

23             MS. SUTHERLAND:  If it's going to be --

24             JUDGE KWON:  Which is 5th of May.

25             THE WITNESS: [Interpretation] Today's the 5th; right?  Is it the

Page 1871

 1     5th?

 2             MS. SUTHERLAND:  And as we're going to admit a marked one,

 3     Your Honour, perhaps Mrs. Zaimovic could put a C where the Children's

 4     Surgery Department is.  Just above the building.

 5             THE WITNESS:  [Marks]

 6             MS. SUTHERLAND:  Thank you.

 7             JUDGE KWON:  Yes.  That will be admitted as?

 8             THE REGISTRAR:  Your Honours, the unannotated map will be

 9     Exhibit --

10             JUDGE KWON:  No, I don't think we need to admit the --

11             THE REGISTRAR:  The annotated map will be P817.

12             JUDGE KWON:  Yes.  Thank you.  Let's move on.

13             MS. SUTHERLAND:

14        Q.   I wish to now turn to matters contained in your statement.  I

15     have a number of questions related to the notes that you kept before the

16     war.

17             MS. SUTHERLAND:  And for the benefit of the Court and the

18     accused, this is mentioned in paragraph 9 of the statement.

19        Q.   Mrs. Zaimovic, you stated that you kept this personal diary

20     regarding the patients wounded during the war who were treated in the

21     Children's Surgery Department.  How did you keep the diary?  Was it --

22     was it a typed notes, handwritten notes?  How was the -- how was the

23     diary?

24        A.   Sometimes when I'd have time, I'd type it out on a regular

25     typewriter.  There weren't any computers in our hospital at the time.

Page 1872

 1     Sometimes I'd write it in my own hand.  You can see in the diary itself

 2     that the handwriting is sometimes a bit more nervous, looks scribbled.

 3     In addition to this diary that I kept as the head nurse, I also submitted

 4     regular reports that went to the administrative service, the

 5     administration of the hospital.  This is something that was personal, for

 6     my very own point of view.  It had to do with the very special situation

 7     involved when wounded children were brought into the hospital.  Every one

 8     of these children had a story to tell, as it were, in view of that most

 9     unfortunate situation.

10        Q.   Mrs. Zaimovic, I want to concentrate just on the questions in

11     relation to the keeping of the diary.  So the handwriting, whose

12     handwriting was it, all of the handwritten entries, are they all your

13     handwriting?

14        A.   Yes.

15        Q.   And the typed records?

16        A.   Yes.

17        Q.   When did you record the names of the patients?

18        A.   I recorded patients names when they would be brought in, or

19     perhaps a bit later when I'd have enough time in view of all the work I

20     had then.

21        Q.   And the dates, are they all in chronological order?

22        A.   Yes.

23        Q.   You said that you kept the notes for your own -- you said it was

24     something personal for your very own point of view.  Did you -- did you

25     list every wounded child?  Did you manage to do that?

Page 1873

 1        A.   For the most part, every wounded child, I think.  Maybe there may

 2     be some that I omitted to -- to record, but for the most part it's all of

 3     them.

 4        Q.   What information did you generally record for each patient?

 5        A.   The name and surname of the child, the date when the child was

 6     admitted, the child's date of birth, the address of residence or the

 7     address from which the child had come, and the neighbourhood, the part of

 8     town that the child had come from.  Also, the patient's diagnosis.  The

 9     diagnosis was recorded by the doctors, of course.  I would just copy it

10     out from the other document.  And also there would be date when the

11     patient was discharged or died or was transferred to another clinic or

12     was transferred to another country.

13        Q.   How were the majority of injuries to the children sustained?

14        A.   All children that were brought in and that were recorded in this

15     diary were injured by shrapnel or sniper fire.  A very small number of

16     children were also injured by phosphorous shells, those that cause burns,

17     and some were injured by gas explosions.

18        Q.   Do you know approximately how many wounded children were treated

19     in the hospital in 1992?

20        A.   In 1992, 163 children were brought to our clinic.  Out of the

21     163, nine died at the clinic itself, but all the children that died on

22     the spot were not brought to our clinic.  They were brought to the morgue

23     directly or to the mortuary where we sent our own patients who had passed

24     away while in hospital.

25             MS. SUTHERLAND:  I would ask that 65 ter number 16843 be brought

Page 1874

 1     up onto the screen, please.

 2        Q.   Mrs. Zaimovic, do you recognise this document?

 3        A.   Yes.

 4        Q.   What is it?

 5        A.   They are my impressions, the ones that I recorded and wrote down

 6     personally.  My feelings, what I felt on that day, the day here being the

 7     10th of October, 1992, what the situation was like around me and within

 8     me.  It was something personal.

 9             MS. SUTHERLAND:  Could we go to the next page, please.

10        Q.   Mrs. Zaimovic, what is shown on page 2?

11        A.   Page 2 shows the names and surnames of the patients who had gone

12     outside the country, who were very seriously injured, and they were sent

13     with the physicians of the world to be helped and treated further,

14     because we were no longer able to do anything for them.  We didn't have

15     the necessary resources or equipment to deal with these extremely

16     difficult cases, severely wounded children.  And some of them left in

17     1992, some in 1993, and perhaps some children left later, which I might

18     not have recorded in this list, but mostly these are children that went

19     abroad for treatment.  There were 32 of them.

20             MS. SUTHERLAND:  Can we go to the next page, please.

21             JUDGE KWON:  Ms. Sutherland, just to note, this is page 3 in

22     B/C/S.

23             MS. SUTHERLAND:  I'm sorry, Your Honour.

24             JUDGE KWON:  Let's move on.  Page 2 in English.  You're right.

25             MS. SUTHERLAND:

Page 1875

 1        Q.   Ms. Zaimovic, can you describe very, very briefly what is on

 2     page 4 of the B/C/S and 3 of the English?

 3        A.   Here you can see the names of patients who were wounded on the

 4     9th of September, 2002, their names, their date of birth, the type of

 5     injury they sustained and the day they were discharged.  Here we have a

 6     little boy, his name was Sergije Bjelos, who was wounded in 1992 on the

 7     14th of September, and his wounds were so severe that he died as a result

 8     of his injuries.  There are quite a few more names.  If you would like me

 9     to read them out, I will do so and I can say a few words about them.  Of

10     course, it's been a long time since then, so I might not remember them

11     all, but most of them I do.  All those children are constantly with me.

12     I remember them.

13        Q.   Mrs. Zaimovic, as we have only a limited amount of time, I want

14     to take you to certain entries in this -- in this -- in your diary.

15             MS. SUTHERLAND:  I would ask that we go to page 14 of the B/C/S

16     and page 12 of the English please.

17        Q.   Mrs. Zaimovic, I draw your attention to entry which is numbered

18     210, Muamer Mrdic.

19        A.   Yes.

20        Q.   And also entry number 212, Camo.

21        A.   Yes.  And what do you want me to tell you?

22        Q.   What -- what is the date that -- that the patients were treated?

23        A.   Muamer Mrdic was admitted on the 1st of May, I think it was, as

24     far as I can see here, 1993, and he was born on the 17th of February,

25     1974.  The date of discharge is the 6th of July, 1993.

Page 1876

 1        Q.   Mrs. Zaimovic -- if I can interrupt you there.

 2             MS. SUTHERLAND:  Could we blow-up the B/C/S, please, so that you

 3     can see the date clearly.  It's not --

 4             THE WITNESS: [Interpretation] The 1st of May, 1993.  He came from

 5     Dobrinja.  And he had a very serious injury to his abdomen with his

 6     injuries to the colon, and so on, a rupture to the colon, and he was

 7     discharged in July 1993, but he came in in May, and he spent almost two

 8     months in our hospital.

 9             MS. SUTHERLAND:  Mrs. Zaimovic, do you see the date of the -- of

10     the victim -- the patient, sorry, above Colic --

11        A.   Colic.  Esmeralda Colic, yes, I see that.  The 31st of May,

12     2003 [as interpreted].

13        Q.   Mrs. Zaimovic, you have the original of your diary in front of

14     you.  Do you want to look at the original which is a better copy of, I

15     think, what we have on the screen, just to check whether the date is in

16     fact, the 1st of May?

17             MS. SUTHERLAND:  Your Honour, may the witness be given leave to

18     refer to her -- to her original notes.

19             JUDGE KWON:  No problem.  But, Ms. Zaimovic, could you find

20     Muamer Mrdic in the list.  To me, his date of birth looks like 1st of

21     June; is it not correct?

22             THE WITNESS: [Interpretation] May I just take a moment, please.

23             MS. SUTHERLAND:  Your Honour, I --

24             THE WITNESS: [Interpretation] The 1st of June,

25     '06 [as interpreted].

Page 1877

 1             MS. SUTHERLAND:  And that was the date that he was admitted.

 2             THE WITNESS: [Interpretation] The 1st of June, 1993, yes, that's

 3     right.  So this is a mistake here.

 4             MS. SUTHERLAND:  [Overlapping speakers]

 5             THE WITNESS: [Interpretation] It's the 1st of June here.

 6        Q.   And the date of birth, is that next to his name?

 7        A.   The date of birth is the 17th of February, 1979.  The 17th of

 8     February, 1979.

 9        Q.   And in relation to Mrdic and also Camo, is the date -- sorry, for

10     the date for Camo, is that also the 1st of June, 1993, as being the date

11     admitted?

12        A.   Yes, that's right, the 1st of June.  Three children were admitted

13     on that same day, the 1st of June.  The 1st of June there, the 1st of

14     June, and the 1st of June, including Camo, Samir.  He came on the 1st of

15     June, 1993, as well.

16        Q.   [Overlapping speakers]

17        A.   And he was born in --

18        Q.   Sorry for interrupting.  Do you know in relation to number 210

19     and 212 the -- where they came from?  I think you mentioned already that

20     Mrdic came from Dobrinja.  Do you know where Camo came from?

21        A.   Yes.  Camo came from Petra Drepsin street, number 1.  Now, where

22     that street was, I can't tell you now.  I really don't know, but that's

23     the street name.  I don't know where it is.

24             JUDGE KWON:  I'm sorry, Ms. Sutherland, I don't want to interrupt

25     with these minor questions, but I found that the entry numbers are not

Page 1878

 1     matching between the English translation and B/C/S.

 2             MS. SUTHERLAND:  Your Honour, if you look at --

 3             JUDGE KWON:  Samir Camo has no number, while Irfan Sehovic has

 4     212, but if you look at original, Camo is numbered as 212.

 5             THE WITNESS: [Interpretation] Camo, Samir is 212, yes.

 6             JUDGE KWON:  With that note, we shall proceed.

 7             MS. SUTHERLAND:  Yes, I would now ask to go to page 30 in the

 8     B/C/S and 21 of the English -- I'm sorry.  Before we do that --

 9        Q.   Mrs. Zaimovic, could you just give a very brief description of

10     the injuries of Mrdic and Camo.

11        A.   Mrdic, Muamer had an injury to the abdomen and a fracture of the

12     femur due to a shell explosion, and he sustained several types of injury,

13     in fact.  Camo, Samir had head injuries and the femur of the fracture and

14     the upper leg, and those are the type of injuries that people sustain

15     when a shell explodes.  They have multiple injuries, not just one but

16     multiple injuries, and these children came in that way, injuries caused

17     by shells exploding.

18        Q.   Okay.  Now I'll move on to another entry, page 30 of the B/C/S

19     and page 21 of the English, please.  Mrs. Zaimovic, I ask you to look at

20     entry number 291.  What was the date this patient was treated?  First of

21     all, the patient's name.

22        A.   Who do you mean, Kapetanovic, Muhamed Kapetanovic?  Is that the

23     one?  291, yes.

24        Q.   Yes.  What date was he treated?

25        A.   He arrived on the 22nd of January, 1994.

Page 1879

 1        Q.   Do you know where he was brought from?

 2        A.   He arrived from Alipasino Polje.  And in my diary, I recorded

 3     that six other children died -- were killed together with him, and that's

 4     what happened.

 5                           [Prosecution counsel confer]

 6             JUDGE BAIRD:  Ms. Zaimovic, I'm looking at the English

 7     translation.  Amina Birdzo, that also entry 291 in the English version?

 8             THE WITNESS: [Interpretation] 292 --

 9             JUDGE BAIRD:  292.

10             THE WITNESS: [Interpretation] -- is Amina Birdzo --

11             JUDGE BAIRD:  Thank you.

12             THE WITNESS: [Interpretation] -- a girl.  She was hit by a

13     sniper.

14             JUDGE BAIRD:  292.  Thank you.

15             MS. SUTHERLAND:

16        Q.   I would now go to another entry on page 31 of the B/C/S and page

17     22 of the English.

18             Mrs. Zaimovic, I ask you to look at entry number 294.

19        A.   Yes.

20        Q.   The name of that patient is Sabahudin --

21        A.   Sabahudin, Ljusa, yes.

22        Q.   [Overlapping speakers] patient?

23        A.   Born in 1983 and came to the clinic on the 4th of February, 1994.

24        Q.   Do you know where this patient was brought from?

25        A.   From Dobrinja.

Page 1880

 1        Q.   That reference to 3 Oslobodilaca Sarajevo street, what does that

 2     refer to?

 3        A.   It's the street he lived in.  That's the street he lived in.  The

 4     name of the street.  Sarajevo has, of course, different street names.

 5        Q.   If we could go to the next entry, number 295.  What date was this

 6     patient treated and the name of the patient?

 7        A.   This patient was admitted on the 5th of February, 1994.

 8     Denis Stuhlik, born in 1979.  Ilija Grbic street is where he lived in

 9     Sarajevo, and he was injured at the marketplace of Markale.

10        Q.   I'd now like to turn to page 32 of the B/C/S but still page 22 of

11     the English.  Mrs. Zaimovic, if you look at entry number 296.

12        A.   Yes.

13        Q.   And the name of this patient?

14        A.   Nejla Basic, born in 1991, also wounded at Markale market.  On

15     the same date, the 5th of February, 1994.

16        Q.   And if I can turn to page 33 of the B/C/S, still on page 22 of

17     the English.  I'm sorry, if you look at the next entry, number 297.  I'm

18     sorry.  Could you -- could you --

19        A.   The 5th of February, 1994, that's when she was admitted.

20     Enesa Daidzic.  Enesa, mother of the child, born in 1952.  That's

21     the mother of the child.  And we have her child, too, also -- she and her

22     child were wounded at the marketplace, but they recovered from their

23     wounds.  They weren't killed.

24        Q.   And what does it say in the second column in relation to their

25     injuries?

Page 1881

 1        A.   The mother had wounds from explosives in -- injured in her leg

 2     and in the thorax.  And the child had an injury above her knee from the

 3     shells.  The shrapnels from shells hit them and wounded them.

 4        Q.   And if we can turn to page 33 of the B/C/S and still on page 22

 5     of the English and is that entry number 298?

 6        A.   Yes.

 7        Q.   And again does it say this is in relation to Aldijan Daidzic.

 8     Does it say where he came from?

 9        A.   Aldijan Daidzic, yes.  On the 5th of February, 1994, was when he

10     was admitted together with his mother.  Sutjeska street, Sarajevo, was

11     the address.  That's where they both lived.  You see that Sutjeska street

12     is recorded for the mother and child.  And it says in brackets that the

13     mother and child were together.  They had both undergone a great shock so

14     you couldn't separate the mother and the child.

15             MS. SUTHERLAND:  Your Honour I seek to tender 65 ter 16843 into

16     evidence.

17             JUDGE KWON:  Yes.

18             THE REGISTRAR:  As Exhibit P818, Your Honours.

19             MS. SUTHERLAND:  I would ask that 65 ter number 22798 be brought

20     up onto the screen, please.

21             JUDGE KWON:  While we are waiting for that, how much longer do

22     you have with this witness?  Because I'm seeing the clock.

23             MS. SUTHERLAND:  Maybe five, ten minutes, Your Honour.

24             JUDGE KWON:  Yes.  Let's move on.

25             MS. SUTHERLAND:  These entries are taking a little bit longer

Page 1882

 1     than I anticipated.

 2        Q.   Mrs. Zaimovic, do you recognise that document on the screen?

 3        A.   Yes.

 4        Q.   What is it?

 5        A.   You mean from number 1 onwards?

 6        Q.   Well, if -- if -- if --

 7        A.   Yes.  These two lists.

 8        Q.   Is this -- is this list also part of your diary?

 9        A.   Yes.

10        Q.   And this is -- this is actually the beginning of the diary as

11     opposed to the last document we saw which started with patient number 98,

12     I think; is that correct?

13        A.   Yes.  This is the beginning.  This is when the children first

14     arrived in our clinic.  The first child was Emir Zolj and then

15     further down the list, and the injuries became more and more severe as

16     you go down the list.

17        Q.   Now, with this document here, if -- if -- these were -- these

18     were pages that you produced to the Office of the Prosecutor at a

19     different time to the -- to the first lot of pages; is that right?

20        A.   Well, I think the Prosecutor took what he considered necessary,

21     and I think you did the same.  You took what you felt you needed, and

22     among those documents is this first page, and I'm happy to see that you

23     took that page because these were very seriously injured children.  For

24     us in the health sector, the injuries were shocking.  A little girl

25     suffered from paraplegia.  There were very serious injuries which we had

Page 1883

 1     never seen before, the likes of which we'd never seen.

 2        Q.   Mrs. Zaimovic, if we can just bring up -- back Exhibit P818,

 3     please.  Quickly.

 4        A.   Which number?

 5        Q.   Just one moment.  And if we could go to the -- once the document

 6     comes up.  The last exhibit, the one that -- just page 1.  Page 1.  And

 7     then if you could go to the very end page.  Page 35 in the B/C/S and

 8     page 23 in the English.

 9             Mrs. Zaimovic, you see that this last number in this document

10     goes up to number 307.  If you look at the screen --

11        A.   Yes.  Yes.  I'm looking for it.  Just let me take a moment,

12     please.  Here it is, yes.  Go ahead.

13        Q.   And the beginning of these patients, if we can go back to page 2

14     of the English and page 3 of the B/C/S.  Page 3 of the English - I'm

15     sorry - starts on patient 99.  You agree?

16        A.   Yes.

17        Q.   If we can -- if we can now bring back onto the screen the

18     document we just had, and that was document number 22798.  Mrs. Zaimovic,

19     were you asked to provide the list of the patients either side of

20     patients number 99 to 307 the other day, so patients numbered 1 to -- to

21     98, and then patients 308 to 331?

22        A.   Yes.

23        Q.   And in relation to that, when you provided the -- the additional

24     pages this year, you said that there was some changing in numbers;

25     is that correct?

Page 1884

 1        A.   Yes.  The numbers were corrected a long time ago.  When we saw

 2     that mistakes had been made, they were corrected and aligned with the

 3     number of children, and that's quite normal.  You know, when you're

 4     writing under a situation of that kind, which was a terrible time, you

 5     tend to make a mistake in the number of children.  It's not the number

 6     that's important.  What is important is just how many children were

 7     killed and how many children were wounded.  That is the most important

 8     thing in all this.  And it's terrible.

 9        Q.   And the numbers --

10        A.   You ought to speak about that.

11        Q.   And the numbers changed, correct me if I'm wrong, because there

12     were some handwritten entries within the typed pages; is that correct?

13        A.   Yes.  Now, why was that changed?  Well, I realised that I had

14     omitted to list some of the children because I had a lot of work to do.

15     I was very busy and I was under a lot of stress.  And then when I

16     remembered, I would add them in and correct the numbers, and you can see

17     that for yourselves.

18        Q.   Okay.  If we can go to page 16 of the B/C/S of this document and

19     page 14 of the English.  If I can ask you to look at entry numbered 308.

20        A.   Yes.

21        Q.   Can you tell us when this patient was admitted?

22        A.   This patient was admitted on the 24th of May, 1995.

23        Q.   How old is this patient?

24        A.   His name was Drazen Gelo, and he was born on the

25     10th of September, 1993.

Page 1885

 1        Q.   Do you know where he was brought from?

 2       A.   The street that he was brought from was called Safeta Zajke number

 3     88.  His father's name was Ivan, and the wound he sustained was from an

 4     explosive device, from an explosion, and part of the shell, the shrapnel

 5     and metal remained lodged in his body.

 6        Q.   I would ask to go to page 23 of the B/C/S and page 18 of the

 7     English.  And I draw your attention to number 328.  When was this patient

 8     admitted to the hospital?

 9        A.   Andreja Svoboda was the name, admitted on the 28th of August,

10     1995 --

11        Q.   And how old --

12        A.   -- from Sarajevo.  The girl was born on the 22nd of March, 1991.

13        Q.   And do you know where she was brought from?

14        A.   From Sarajevo.  The street name was Darovalaca Krvi number 15.

15             MS. SUTHERLAND:  Your Honour, I seek to tender that document into

16     evidence.

17             JUDGE KWON:  Yes.

18             THE REGISTRAR:  Your Honour, that will be Exhibit Number P819.

19             MS. SUTHERLAND:  Your Honour, I don't know when you wanted to

20     take the break, and I know that I have taken a lot longer than half an

21     hour in relation to these diary entries, but I would ask for your

22     indulgence for another ten minutes, five to ten minutes with this

23     witness.  I have another --

24             JUDGE KWON:  Very well.

25             MS. SUTHERLAND:  -- six questions.

Page 1886

 1             JUDGE KWON:  We will adjourn for 25 minutes.

 2                           --- Recess taken at 3.45 p.m.

 3                           --- On resuming at 4.10 p.m.

 4             JUDGE KWON:  Yes, Ms. Sutherland.

 5             MS. SUTHERLAND:

 6        Q.   Mrs. Zaimovic, in your statement at paragraph 36, you say mention

 7     that children were very frightened and traumatised.  Can you describe

 8     briefly for the Court the children's reactions to the sniping and the

 9     shelling?

10        A.   All the children who came to our clinic were traumatised, first

11     of all, because of the injuries they had sustained.  After that, they

12     were hospitalised.  Shelling went on in town, and whenever a shell fell,

13     they would jump out of bed.  They were traumatised.  They were afraid.

14     Some of them peed in their beds.  They were terrified.  They asked the

15     nurses to protect them, to help them.  It was very hard to deal with

16     them.  It was very hard to carry out medical interventions.  So this war

17     trauma was more than visible in that period on all the children.  It was

18     particularly difficult when we had to move the children into basements,

19     halls, in such conditions and it was simply substandard, but that's the

20     way it was.

21        Q.   How often did this occur when you were having to take children to

22     the basement?

23        A.   Well, you know, it depended on the shelling.  Children would be

24     taken out in the middle of the day, in the middle of the night.  The

25     heavier the shelling, the more likely it was.  Then we would be

Page 1887

 1     instructed to take the children to shelters, basements as quickly as

 2     possible.  That was the only way in which we could help them.

 3        Q.   Was this happening on a regular basis?

 4        A.   Yes.

 5        Q.   What was the psychological impact on the children as a result of

 6     the sniping and the shelling that you were -- that you witnessed?

 7             THE ACCUSED:  Objection, Your Honour.

 8             JUDGE KWON:  Yes, Mr. Karadzic.

 9             THE ACCUSED: [Interpretation] The distinguished Ms. Sutherland is

10     putting many leading questions, and she is putting questions to the

11     witness as if she were a psychiatrist or an expert.  She's a witness

12     here.  She's not a psychiatrist.  And now she is dealing with certain

13     matters that are not for this witness to speak about.  Perhaps somebody

14     else could.

15             JUDGE KWON:  She would --

16             THE WITNESS: [Interpretation] May I answer?

17             JUDGE KWON:  No, Mrs. Zaimovic, it's for the Chamber.

18             Mr. Karadzic, what she asked is the symptom or the phenomenon as

19     she witnessed or observed.  As such, there's -- there's nothing the

20     witness should be prohibited from saying anything.  The objection is

21     overruled.

22             Let's proceed.

23             MS. SUTHERLAND:

24        Q.   Mrs. Zaimovic, you may answer the question.

25        A.   After the shelling, the children -- a great many children started

Page 1888

 1     wetting their beds.  Before that, they hadn't done that.  When a shell

 2     would be fired, they would start screaming so hard, and they'd flee to

 3     the nurses, asking them for protection.  That is truly what happened at

 4     the clinic.

 5        Q.   When you said the shells would be fired, where would -- what

 6     would they be fired on?

 7        A.   Shells were falling all over the place.  They were shooting at

 8     will.  Whatever -- they did whatever they wanted to do.  They shelled

 9     apartments, buildings, marketplaces, wherever.  Whatever they wanted to

10     do.

11        Q.   How often -- I'll rephrase the question.  How -- was -- you

12     mentioned in your statement that the hospital was shelled on a number of

13     occasions.  What was the result of -- of the shelling in relation to the

14     actual Children's Surgery Department building?

15        A.   Our building was shelled.  It's a big building built in the

16     Austrian times.  It has enormous windows, and all of the windows were

17     broken.  There was no glass on any of the windows.  Can you imagine what

18     it's like to work under these conditions in such rooms?

19        Q.   Did you witness -- in relation to the children, did you witness

20     any other impacts on them as a result of the shelling and the sniping?

21     You mentioned that the children were wetting the bed.

22        A.   They were frightened always.  Whenever they'd hear anything loud,

23     they would jump out of bed.  They were drawing things because we tried to

24     calm them down in that way.  Whatever they drew was a reflection of the

25     war.  You could not see a child draw a pretty picture.  All of them had

Page 1889

 1     to do with the war, burning, shelling, and the like.

 2        Q.   I want to turn now to the shelling and the sniping that -- that

 3     you were involved in.  What effect did -- did the shelling of your

 4     residential building, which you mentioned in paragraph 43 of your

 5     statement, what effect did that have on you and your family?

 6        A.   Our building was shelled often like all other buildings.  As for

 7     my own apartment, a shell fell in the bedroom.  Thankfully we weren't

 8     there at the time.  But, indeed, we were all frightened.  Believe me, the

 9     entire family was frightened.  Whenever you'd go to the hospital or

10     wherever, you didn't dare look.  Somehow you'd keep your head down, and

11     you'd be thinking that your turn had come, that you'd be the victim of

12     such a shell or of a sniper.

13             I was terribly frightened.  I have to tell you that in all

14     sincerity.

15        Q.   And what psychological or physical injuries do you suffer from

16     today as a result of the shelling and sniping which occurred in Sarajevo

17     in 1992 and -- between 1992 and 1995?

18        A.   Not sniper or shelling, but once, when my husband and I had set

19     out to work, someone had aimed at us with a sniper.  Thankfully we were

20     not hit.  It was near the entrance to the orthopaedics clinic.  Somehow

21     the sniper fired between myself and my husband, and then we decided not

22     to go to work together.

23             MS. SUTHERLAND:  Your Honour, I have no further questions.  And a

24     redacted version of the witness's statement, Exhibit P814, has been

25     uploaded with the redactions to paragraphs 15 and 38.

Page 1890

 1             JUDGE KWON:  Thank you, Ms. Sutherland.

 2             Mr. Karadzic.

 3             THE ACCUSED: [Interpretation] Thank you, Excellency.  I omitted

 4     to say that the previous question that I was referring to, whether it was

 5     a regular thing, et cetera, in my view that was a leading question, but

 6     let it be.

 7                           Cross-examination by Karadzic:

 8        Q.   [Interpretation] Good afternoon, Ms. Zaimovic.

 9        A.   Good afternoon, Mr. Karadzic, and I'm glad to see you here in

10     this courtroom.

11        Q.   I'm glad to see you as well.  Tell me, please, when did you come

12     from Mitrovica to Sarajevo?

13        A.   As a three-month-old baby.

14        Q.   I see.  Is this your maiden name?

15        A.   No, my maiden name is Arifovic.

16        Q.   Thank you.  What does your husband do?

17        A.   My husband is a lawyer.

18        Q.   What was he before that?

19        A.   What do you mean before that?

20        Q.   Did he do something in the meantime.  I mean, what was his

21     education?  Did he complete any kind of school?

22        A.   He completed a secondary medical school.  I think he socialised

23     with you and some other people from that school, and then he entered

24     university and then got a university degree.

25        Q.   Well, that's what I wanted to ask you about, because I'd be

Page 1891

 1     surprised if he hadn't told you that we had been friends.

 2        A.   He did tell me that, yes.

 3        Q.   Thank you.

 4             JUDGE KWON:  Please bear that in mind, that since you are

 5     speaking the same language, please put a pause between question and

 6     answers.  Let's proceed.

 7             THE WITNESS: [Interpretation] Thank you.  Thank you very much,

 8     and I do apologise.

 9             MR. KARADZIC:  [Interpretation]

10        Q.   Can you tell me where you lived at Breka, which street?

11        A.   Hasan Susic is the name of my street, and it's number 7.

12        Q.   We knew Hasan Susic as well, didn't we?  Tell me, when did you

13     move there?

14        A.   We moved there in 1986.

15        Q.   You moved to that apartment, you mean?

16        A.   Yes, that's right.

17        Q.   How did you go to work?  Did you walk or did you take the car?

18        A.   We walked.

19        Q.   What street or through which streets?

20        A.   Are you familiar with the area?

21        Q.   Yes, yes.

22        A.   We'd just go down by one building, we'd go through the passage

23     and then we'd enter the orthopaedics clinic.

24        Q.   So the second row of houses at Breka; right?

25        A.   Yes, yes.

Page 1892

 1        Q.   So where did they fire at you with a sniper?

 2        A.   On the steps between the entrance and the entrance into the

 3     orthopaedics clinic.

 4        Q.   Is it true that your department for children's orthopaedics is

 5     the best hospital for that?

 6        A.   Yes.

 7        Q.   Is the best hospital, but it's actually the best clinic, too.

 8     Were children treated elsewhere as well?

 9        A.   Yes.

10        Q.   Were children treated elsewhere as well, I mean, by surgeons?

11        A.   You know what the town was like -- or, rather, you don't know

12     because you were shooting from up there.  Children were being treated at

13     the state hospital, in Dobrinska Hospital.  Some came to the orthopaedics

14     department and some also came to the traumatology department, but most

15     children were brought to us.

16        Q.   Thank you.  When did you become head nurse?

17        A.   I became head nurse in 1979.

18        Q.   I'm a bit perplexed by something here.  It says that that's what

19     you did from September 1992 until August 1994.  What does that mean?

20        A.   Could you repeat that?  I don't understand.

21        Q.   Well, that's what you said in your statement of the 18th of

22     January, 2002, in the Galic case.  The page is 1843.  Namely, that you

23     held that position between September 1992, and August 1994.  Is this a

24     new position?

25        A.   It's no position.  I became the head nurse of the clinic in 1979,

Page 1893

 1     and that's what I did up until my retirement.  I retired three years ago.

 2        Q.   I don't understand why it says here that you worked from

 3     September 1992 until August 1994 at that position.

 4        A.   I don't understand that either.

 5        Q.   Were there any changes in your position, in your professional

 6     position in September 1992?

 7        A.   The only thing was that I was an assistant at the higher medical

 8     school, and I worked as a teacher at the secondary medical school in

 9     addition to the regular work that I did, because my students would come

10     to the clinic as well.

11        Q.   Very well.  Thank you.  This remains unclear.  Tell me, you knew

12     all the doctors in that compound quite well, didn't you?

13        A.   Well, for the most part, I knew my own doctors, the ones that I

14     worked with, and the surgeons for the most part.  At some of the other

15     clinics, I knew most of the doctors, but you cannot really know everyone.

16     You know how big the clinical centre is.  You cannot really know

17     everyone.

18        Q.   I have to wait.  This street that you referred to, Bolnicka, is

19     that the former street called Mose Pijade?

20        A.   It was always called Bolnicka.

21        Q.   When I lived there, it was called Mosa Pijade; isn't that right?

22        A.   Bolnicka 25, well perhaps your part down this was called maybe

23     Mosa Pijade, but this was called Bolnicka 25.

24        Q.   I guess that Mosa did something wrong because the whole street

25     used to be called Mosa Pijade.  Do you know why it was changed?

Page 1894

 1        A.   Well, probably because all streets in Sarajevo changed their

 2     names.

 3        Q.   So you knew professor Borisa Starovic, Professor Jovo Vranic,

 4     Professor Milutin Najdanovic, Andrija Gvozdenovic,

 5     Nemanja Veljkov.

 6        A.   Yes, I knew all of them.

 7        Q.   You also knew -- well, we have to wait for the interpretation.

 8     You knew Milica Lopandic as well, didn't you?

 9        A.   Yes.

10        Q.   In your statement here, the one from the 9th of April, 2000, that

11     is, on page 00938863, paragraph 3 -- actually, before that as well.  In

12     the amalgamated statement of the 26th of February, in paragraph 3, you

13     say that before the outbreak of the war, some of the Serbs had left the

14     hospital.  Can you shed more light on that?  When did they start leaving

15     the hospital and why?

16        A.   Serbs left the hospital for the most part when the war started.

17     Some Serbs like Andrija Gvozdenovic, your friend, got ill all of a

18     sudden, sprained his ankle.  What an excuse.  And then he did not work in

19     hospital for at least five or six months.  From time to time he would

20     come to see us.  And on the basis of his views and his statements, we

21     could realise that something was in the making, that something was going

22     on.

23        Q.   Oh, so they hadn't left before the war, but when the war broke

24     out.

25        A.   Yes, when the war broke out.

Page 1895

 1        Q.   Then the statement should be corrected.  Isn't that right?  Isn't

 2     that right?  Shouldn't the statement be corrected?  It's not that they

 3     left before the outbreak of the war but when the war broke out.

 4        A.   They left when the war broke out.

 5        Q.   Further on you stay in your statement dated the

 6     9th of April, 2000, 0038863, paragraph 4, that's the reference, that most

 7     of the Serbs and Croats who were doctors stayed on, but they slowly

 8     started leaving one by one; isn't that right?

 9        A.   Yes, that's right.

10        Q.   Then you said on the 18th of January, 2002, transcript

11     reference -- rather is the Galic transcript, IT-282 --

12             THE INTERPRETER:  Interpreter's note:  We cannot catch the

13     number.

14             MR. KARADZIC:  [Interpretation]

15        Q.   Paragraph 12.  Fifteen nurses left, and two Croat women and three

16     Serb women stayed there and continued working.

17        A.   Yes.

18        Q.   Until when did they work at the clinic?

19        A.   Who do you mean?

20        Q.   You said that it was two Croat women and three Serb women that

21     stayed at work?

22        A.   Yes.  The Croat women who had stayed on still worked there.  They

23     were young nurses.  One of the Serb nurses was pensioned off and she

24     left, and the other one left too.  So, indeed, they were with us all the

25     way up until the end of the war.

Page 1896

 1        Q.   Thank you.  What about some of the doctors who happened to be at

 2     their weekend cottages when the war broke out?  Did they try to come

 3     back?  Do you remember that?

 4        A.   No.

 5        Q.   Professor Mirko Sosic, for example.  He stayed on for a while and

 6     tried to work, right?

 7        A.   Yes, he did work.  I don't know whether he had returned from his

 8     weekend cottage.  I don't know about that.  I just know that he returned,

 9     that he started working, and then he and his wife left the city.

10        Q.   Thank you.  Does this sound accurate to you, namely that Sarajevo

11     was left by almost 250 doctors, physicians, primarily Professors

12     Starovic; Sucur; Radivojevic; Kaufer, Leopold Kaufer; Guzina; Dusan

13     Vukatic [phoen]; Marko Vukovic, and so on?

14        A.   Leopold Kaufer did not leave town.  He stayed in town and he died

15     in town.  As for the rest, they followed you to Pale, because you

16     probably brought pressure to bear, in that sense.  So they all left us.

17     No one was trying to get rid of them.  They left of their own accord.

18        Q.   Mrs. Fatima, I understand your emotions, but if you are saying

19     that I exerted pressure on them, then I will have to spend a lot of time

20     proving that that is not true.  You will agree that I am not a magician

21     so that I could lure 250 doctors to leave Sarajevo; right?

22        A.   No, you're not, but that's what your policy was.

23        Q.   Well, now, did they flee from your policy or did they run towards

24     my policy?  That is a case that has to be proven.  Do you remember that

25     Professor Surgeon Borisa Starovic was also a victim of sniper fire?

Page 1897

 1        A.   I don't know.  I really don't know, but I know that he was ill

 2     and that because of his illness he left.  That's what he had said anyway.

 3        Q.   However, that was so well known, and as a matter of fact, he was

 4     even forced to say that he was the victim of Serb fire, although Serbs

 5     were not firing anywhere nearby, but never mind, let's move on.

 6        A.   I'd like to ask you something.  Please don't bother me with all

 7     of that, who left, why they left, et cetera.  I came here to say how many

 8     children and civilians you targeted with your army, as if they were balls

 9     or objects down there.  That's what I came to say.  Believe me, they all

10     know why they left the city, but that's not what I came to talk about

11     here.

12        Q.   I believe that I do have the right to ask you everything that you

13     knew about and everything that you had touched upon.  You said that we

14     were shelling, and you said that we were shelling all of the city,

15     although you couldn't see that, so please don't get angry.  I have to

16     illuminate all of these matters.  Nothing should remain unclear.  This is

17     a criminal court.  This is not a debate club.  So we have to clarify

18     everything.  We have to see whether you know something or whether you had

19     heard of other things, and so on.

20             JUDGE KWON:  Exactly as you said.  This is not a debate club.

21     Just ask questions, Mr. Karadzic.

22             THE ACCUSED: [Interpretation] I hope, Excellency, that you are

23     going to protect me.  If you don't protect me then I have to say this,

24     because I cannot accept the limit that the witness is imposing on me.

25             JUDGE KWON:  Yes, we do protect you, as long as you are asking

Page 1898

 1     relevant questions.  Let's proceed.

 2             MR. KARADZIC:  [Interpretation]

 3        Q.   Mrs. Zaimovic, you said in your statement of the 18th of January,

 4     2002, in the Galic case, on page 1851, in paragraph 25, that one morning

 5     you were sitting on the balcony and you heard an explosion.  Then you

 6     said that that was a barrel that had been full of explosive material and

 7     was then pushed downhill, and it ultimately destroyed some houses.  You

 8     said the same thing on the next page, in paragraph 1, as well.  And then

 9     you said that there were only civilian targets there and that there were

10     no military targets in sight; is that right?

11        A.   Yes, that's what I said.  As for military and civilian targets, I

12     said what I said because I saw barrels hitting houses.

13        Q.   Did you just come to the conclusion that it was a barrel because

14     you heard the explosion?

15        A.   We heard the explosion and we saw the barrels moving down from

16     that rock.

17        Q.   One barrel or several barrels?

18        A.   Several barrels.

19        Q.   You, therefore, think and say that there were no military

20     installations or targets over there.

21        A.   I have no knowledge or awareness of that.

22        Q.   Now in the hospital, there were no soldiers or military

23     installations or artillery or mortars or anything of that sort; isn't

24     that right?

25        A.   Yes, that's right.

Page 1899

 1        Q.   And Breka didn't have any military units or military

 2     installations; isn't that right?

 3        A.   To the best of my knowledge, no, it didn't.

 4             THE ACCUSED: [Interpretation] May we now have a map displayed,

 5     please.  It is 1D906.  May we have it called up on e-court.  1D906 is the

 6     document number.  And may I ask the Registrar to provide Mrs. Zaimovic

 7     with a marker so that she can draw on the map.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Have they provided you with a pen, Mrs. Zaimovic?

10        A.   Yes.

11        Q.   Would you now mark in on the map where your building was within

12     the hospital compound.

13        A.   Well, you know that the children's surgery ward was to be found

14     at the central entrance to the hospital, which is here.  Kosevo Hospital,

15     this is the central part, as far as I know.  This map is a little

16     different than the one I was looking at just a moment ago, but I think

17     it's somewhere in that general area.

18        Q.   Thank you.  That is the -- those are the surgical clinics; is

19     that right?

20        A.   Yes.

21        Q.   Thank you.  Now do you know what is to be found underneath

22     Stjepan Tomic street?  Which faculties are there there?

23        A.   The medical faculty is lower down and the electrical engineering

24     factory.

25        Q.   Just underneath the street, Stjepan Tomic street.  Which faculty

Page 1900

 1     buildings are there there?

 2        A.   The electrical engineering faculty, as far as I know, was located

 3     in that area.  That was the only one.  I don't know of any others.  And

 4     the faculty of architecture.  That was in the same building.

 5        Q.   Would you mark that on the map for us.

 6        A.   I'll do my best.  I'm not quite sure that I'm getting it right

 7     because I'm not a military expert.  And I apologise.  I worked at the

 8     clinic, so I never gave maps and the like any thought.

 9        Q.   Very well.  But we all know that's where the faculty buildings

10     were.  Now, if you look at -- in the upper right-hand corner, 901 is the

11     elevation point, you have the hill there.  Meta [phoen] hill.  Would you

12     mark that in for us.

13        A.   I can't see that.  I don't know.  You mean above Breka?

14        Q.   About the -- above the forests, the Sedam Suma forest.  The upper

15     right-hand corner where it says Grdonj.  901, elevation 901.

16        A.   Is this what you mean?

17        Q.   And who here had control of Grdonj, madam?

18        A.   I don't know.

19        Q.   You don't know that it was the Muslim units who were up at

20     Grdonj?

21        A.   No, I don't.  I'm not a military expert, as I said.

22        Q.   Thank you.  Now, could you mark in Betanija?  Do you see where it

23     says Betanija in the upper left-hand corner?  Is that where the

24     obstetrician ward and maternity ward was?

25        A.   Where it says Djecija, yes.  Betanija over here.

Page 1901

 1        Q.   Thank you.  Now, could you indicate where you, yourself, lived?

 2        A.   Breka.  I lived right above the hospital, in that general area.

 3        Q.   The second row of houses; right?

 4        A.   Yes, the second row of houses and you know that full well.  You

 5     know where that is.

 6        Q.   Now do you see the entrance to the tunnel?  It says

 7     Kosevsko Brdo, Kosevo hill, Kosevsko Brdo.  And you can see the tunnel.

 8        A.   You mean over here, Kosevsko Brdo?

 9        Q.   No, it's the stadium, but it says Kosevsko Brdo, Gorica, so

10     somewhere in the middle, to the left of the map in the middle.

11        A.   I can't see that.

12        Q.   It's written up in large letters.  Right along the left-hand side

13     of the map.

14        A.   It says Jezero and it says Djecija.  But why are you asking me all

15     this?  Why are you asking me to indicate things on this map?  I'm not a

16     military expert.  Could you -- Your Honours, I don't want to answer

17     questions like that.

18             JUDGE KWON:  Mrs. Zaimovic, he's entitled to ask questions, and

19     he wants the Judges to be familiar with the geography, as we are not

20     familiar with it.  So during the course of examination and question and

21     answers, we get familiarised with the maps.  I see Kosevsko Brdo in the

22     left part underneath Kosevo.

23             THE WITNESS: [Interpretation] I really can't see it.  Kosevo is

24     over here.  I can see that.  I can't see Kosevsko Brdo.

25             JUDGE KWON:  To the left could you see Kosevo there.  Do you see

Page 1902

 1     Crni Vrh there in the left part?

 2             THE WITNESS: [Interpretation] Just a moment, please.  You mean

 3     this here.  There's Kosevsko Brdo.

 4             MR. KARADZIC:  [Interpretation]

 5        Q.   Thank you.  Now, right above where it says Kosevsko Brdo, do you

 6     see the entrance to the tunnel there?

 7        A.   You mean the red, the area in red?

 8        Q.   No, within the circle.  You've already drawn a circle around

 9     Kosevsko Brdo, and you see right above that that's where it is.

10        A.   [Marks]

11        Q.   Yes.  Thank you.  That's right.

12        A.   And that leads directly to the hospital.  There's the bypass

13     passing over the cemetery and leading on towards the hospital.

14        Q.   Yes, that's right.  Now what about Breka Potok or Breka stream?

15     Where is that?  Can you pinpoint that for us, please?

16        A.   Is it on the map?

17        Q.   No.  There's Breka and then --

18        A.   Breka Potok moves towards Pionirska street.  It's in that general

19     area.  Somewhere over here.

20        Q.   Thank you.  Now, do you know where the institute for the deaf and

21     dumb, deaf and dumb children is, called Nemanja Vlatkovic?

22        A.   Yes.

23        Q.   Could you mark that in?

24        A.   That's near Breka too, somewhere above the end part of the

25     hospital compound.  So somewhere here.

Page 1903

 1        Q.   Thank you.  And do you know where the bakery at Breka is?

 2        A.   The bakery?  I don't know where the bakery is.

 3        Q.   Very well.  Thank you.

 4             JUDGE KWON:  Madam Zaimovic, if we could put D for the institute

 5     for the deaf and dumb in order for us to remember later on.

 6             THE WITNESS:  [Marks]

 7             JUDGE KWON:  Let's proceed.

 8             MR. KARADZIC:  [Interpretation]

 9        Q.   Thank you.  Now these two circles where you lived.  You lived by

10     the lower circle; right, where it says 201?

11        A.   Yes, that's right.  Over here.  Right up above the hospital.

12        Q.   Yes, that's right.  Thank you.  Now, may I ask you to sign that,

13     put your initials on the map, and I'd like to tender this map into

14     evidence now, please, having recorded that.

15        A.   Do you want me to write the date as well?

16        Q.   Well, that would be good -- a good idea.

17        A.   [Marks]

18             JUDGE KWON:  That will be admitted as?

19             THE REGISTRAR:  Exhibit D120, Your Honours.

20             THE ACCUSED: [Interpretation] Thank you, Your Excellency.  We

21     will probably come back to this map later on, but may we have called up

22     another document now which is 1D905, please.

23             MR. KARADZIC:  [Interpretation]

24        Q.   And while we're waiting for that, let me tell you what the

25     document is about.  It's a document from the General Staff of the

Page 1904

 1     BH Army, the command of the 1st Corps, and you know that the 1st Corps

 2     was in Sarajevo, don't you?

 3        A.   Probably.

 4        Q.   Here organisational changes are being ordered -- or, rather, the

 5     General Staff is ordering organisational changes in the area of

 6     responsibility of the 1st Corps.

 7             THE ACCUSED: [Interpretation] Ah, we haven't got it on our

 8     screens yet.  May this document be called up on e-court, please.  And may

 9     we have both the English and Serbian version on the screen, please, so

10     that Mrs. Zaimovic can see what it's about.  So both versions, please.

11     Thank you.

12             MR. KARADZIC:  [Interpretation]

13        Q.   And on the first page in that first rectangle, we see in the area

14     of responsibility of the 1st Corps formed the following battle units, the

15     command of the 12th Division with the staff units and headquarters in

16     Sarajevo, and the following units will comprise the composition of the

17     division of 105th Mountain Brigade.  There was 105th Motorised Brigade,

18     and now here we have the 105th Mountain Brigade.  Have you heard of that?

19        A.   Well, perhaps I have, but this has got nothing to do with why I

20     have come in here to this courtroom to testify.  I wasn't a military

21     expert.  I worked at the clinic all my life and the whole time, and I

22     wasn't interested in military units or their names or numbers or

23     whatever.  So I -- my answer is that I have no knowledge of that.

24        Q.   Was your son in the army?

25        A.   Yes, my son was in the army.

Page 1905

 1        Q.   In what unit?

 2        A.   The 105th.

 3        Q.   And you weren't interested in the 105th Brigade at all?

 4        A.   He had to go.  He was recruited and had to join up and, of

 5     course, defend his country.

 6        Q.   Madam, that is commendable, but how is it possible that you're

 7     not interested in the 105th Brigade of which your son was a member?

 8     Where was the brigade deployed?

 9        A.   I really don't know that.  I really don't.

10        Q.   You don't know that it's area of responsibility was Breka?

11        A.   No.

12        Q.   Now let's move on to page 3 of this same document, please.

13             THE ACCUSED: [Interpretation] May that be displayed.

14             MR. KARADZIC:  [Interpretation]

15        Q.   And that rectangle there, the Motorised Brigades of the 1st Corps

16     should be restructured to become mountain brigades as a provisional

17     military formation, number T412.194, and it involves 105th, 102nd, and

18     105th Brigade should become the 105th Mountain Brigade which was your

19     son's brigade; isn't that right?

20        A.   Well, most probably, but I really can't say.  I don't know.  What

21     was important to me was to have my son come back home alive.

22        Q.   Certainly, yes.

23             THE ACCUSED: [Interpretation] Now may we see the last page of

24     this document.  It is army General Rasim Delic who signed the document.

25             MR. KARADZIC:  [Interpretation]

Page 1906

 1        Q.   Is that Rasim Delic's signature?  Is that what it says there?

 2        A.   Well, it says Rasim Delic.

 3        Q.   Thank you.

 4             THE ACCUSED: [Interpretation] I'd like to tender 1D905 into

 5     evidence, please.  And may we have 1D902 next.

 6             JUDGE KWON:  Unless it is objected to, it will be admitted.

 7             MS. SUTHERLAND:  Your Honour, I do object to this document.  She

 8     hasn't been able to speak to any of it.  For that reason, I object.

 9             JUDGE KWON:  Your ground of objection is based upon the relevance

10     or the authenticity?

11             MS. SUTHERLAND:  The relevance, Your Honour.  And we don't know

12     about the authenticity because she hasn't been able to speak to the

13     document at all.  She doesn't recognise the document.  She hasn't said

14     that that's Delic's signature.  She simply said that the word "Delic" is

15     there.

16                           [Trial Chamber confers]

17             JUDGE KWON:  The Chamber does not find much relevance of this

18     document as such.  You will have another opportunity to tender this

19     document.  On that ground this will not be admitted.

20             THE ACCUSED: [Interpretation] Well, I see the relevance with

21     respect to the witness's credibility, first and foremost, and the fact

22     that I want to prove and show that Sarajevo was a fortress and fulcrum, a

23     military stronghold, and not a peaceful town that was attacked by some

24     wild men.  And to be quite honest, I'm surprised that this document is

25     not going to be admitted.  But let's have 1D902 next, please.  Thank you.

Page 1907

 1             MR. KARADZIC:  [Interpretation]

 2        Q.   This is the command of the Sarajevo-Romanija Corps, dated the

 3     25th of February, 1995, and it is a report sent by the intelligence

 4     services to what it says at the bottom.  We see that the

 5     102nd Motorised Brigade or Mountain Brigade and the 105th Mountain

 6     Brigade is referred to.

 7             Now let's move on to page 5, please, of this same document.

 8             Madam, do you know where Trampina street is?

 9        A.   I can't really remember.

10        Q.   Do you know where the Ivan Cankar school is?

11        A.   I can't remember that either.

12        Q.   Do you know where Hladivode is?

13        A.   No.

14        Q.   Do you know where Kobilja Glava is?

15        A.   I know where Kobilja Glava is.

16        Q.   Mala Kula?

17        A.   What Mala Kula?

18        Q.   Well there is just one Mala Kula, and I think that you can see it

19     on that map.  It's above Breka where you were.  Let's see now what it

20     says in relation to the 105th Brigade.  Commander Izet Berkovic, have you

21     heard of him?  Do you know of him?

22        A.   No.

23        Q.   What about Tinjak, Mustafa?

24        A.   No.

25        Q.   Salko Softic?

Page 1908

 1        A.   No.

 2        Q.   Ah-ah.  Now, do you see that it says here that the command post

 3     is in the Sipad building in Trampina street and the auxiliary command

 4     post is in the Ivan Cankar school; isn't that what is written here?

 5        A.   Mr. Karadzic, I am no military expert.  I am asking you very

 6     nicely not to ask me about things like this.  I spent all the time with

 7     the children at the clinic.  I have no idea about this.  This means

 8     nothing to me.  You're putting questions to me that I know nothing of.

 9     Please don't put military questions to me.

10        Q.   Well, see, Ms. Zaimovic, it says here number of men 5.500 to

11     6.000.  That's the number of soldiers that are in your neighbourhood and

12     around your neighbourhood with all of the necessary infrastructure,

13     logistics, with a rear command post, and you are saying that there was

14     nothing there and that you don't know anything about it?  And your own

15     son is on that unit.

16        A.   That's your reports.  I have no idea about any of this.

17             JUDGE KWON:  Just a second.  Yes, Ms. Sutherland.

18             MS. SUTHERLAND:  Your Honour, can Mr. Karadzic put a question and

19     not comment when he's speaking with the witness.

20             JUDGE KWON:  What do you see as comments?

21             MS. SUTHERLAND:  What is his question to the witness?

22             JUDGE KWON:  Was his question not whether she knows that 5.000 or

23     6.000 number of soldiers were in her neighbourhood?

24             MS. SUTHERLAND:  I'm sorry, Your Honour, I got up in the middle

25     of the question.

Page 1909

 1             JUDGE KWON:  Yes.  Okay.  Let's proceed.

 2             MR. KARADZIC:  [Interpretation]

 3        Q.   Mrs. Zaimovic, may I read this out to you, the zone of

 4     responsibility of this brigade, the 105th Brigade, the brigade that your

 5     son was in, Hladivode, Mala Kula, Breka, Potok, Pionirska Dolina, Kobilja

 6     Glava, composition five battalions including the rear, and so on and so

 7     forth, the number of personnel is between 5.500 to 6.000 men.  At

 8     Srebrenik, that's where the command post of the 1st Battalion is.

 9     Hladivode, Mala Kula is the area.  The second one is commanded by

10     Senad Tokaca, and the command is at the institute of seismology, do you

11     know that that institute is there?

12        A.   Yes.

13        Q.   And that battalion had about 1.000 men.  The 3rd Battalion is

14     commanded by Enver Krljus.  The command is in a day care centre at

15     Kosevsko Brdo.  The defense area is Breka Potok, Sipska Kosa.  The

16     4th Battalion, the commander is a certain Daidza.  Manoeuvre Battalion,

17     it only consists of Muslims under the age of 30.  Engineer battalion, the

18     command is in Razija Omanovic elementary school.  Do you know where that

19     school is?

20        A.   I do know, but for heaven's sake, I have no idea about any of

21     this.  I have no idea about any of this.  You have to realise that I

22     don't know anything about that.  You know that.  I have no idea.

23        Q.   But you see that it is written here that that's where the command

24     posts are, in day care centres, kindergartens, schools, and your son is

25     fighting in that same unit.  They are in uniform.  They are passing by

Page 1910

 1     there, and you do not know anything about this very strong unit

 2     consisting of 6.000 men, a brigade, a proper brigade that is guarding

 3     your own neighbourhood, and you are trying to say that you don't know

 4     anything about that?

 5        A.   I don't.

 6        Q.   What's the population of Breka?

 7        A.   I don't know about that either.  I don't know exactly.  I don't.

 8        Q.   Well, I'll tell you.  Not more than 2- or 3.000.  And the number

 9     of soldiers is double in relation to that; isn't that right?

10        A.   That's what you're saying.  I don't speak about that and I don't

11     know about that.

12             THE ACCUSED: [Interpretation] Excellencies, I am tendering this

13     document.  I believe that it is more than relevant because the place was

14     full of soldiers.  It was teeming with soldiers.  It is more than

15     relevant, not only in terms of the credibility of this witness but

16     also --

17             JUDGE KWON:  No speech, Mr. Karadzic.

18             JUDGE MORRISON:  Dr. Karadzic, let's look at it.  It falls into

19     two categories.  You have information from documents that you can use to

20     base cross-examination on.  For instance, you have a document which says,

21     As far as the 105th Motorised Brigade is concerned, in the vicinity we're

22     talking about, there were between 5.500 and 6.000 men.  So it's perfectly

23     legitimate for you to ask the witness, Were you aware that in that area

24     of responsibility there were up to 6.000 soldiers.  There's no problem

25     with that.  It becomes a perfectly legitimate question, but, of course,

Page 1911

 1     you are bound by the answer the witness gives.  But that doesn't prove

 2     the document.  Unless this witness was either the author or recipient or

 3     otherwise had personal knowledge of the document, it doesn't prove the

 4     document.  It didn't prevent you from using the context of the document

 5     to ask questions in cross-examination, and it doesn't prevent you from

 6     proving the document in due course as part of the Defence case.  But

 7     unless the witness can speak to, identify, or accept the document as

 8     genuine, that's a completely separate issue as to the use of the document

 9     as a basis for cross-examination.  Do you see the distinction?

10             I see that Mr. Robinson does.

11             MR. ROBINSON:  I do very much, Judge Morrison, but I'm wondering

12     whether that's not consistent with the practice that we've adopted so far

13     in this trial because --

14             JUDGE KWON:  That's the point I'm going to take.

15             Ms. Sutherland, apart from the principles set out by His Honour

16     Judge Morrison, has it not been our practice that as regards the military

17     documents or official documents, has it not been our practice to admit --

18     admit them as far as the authenticity of those were not challenged?  Or

19     Mr. Tieger.

20             MS. SUTHERLAND:  If you would just give me a moment, Your Honour.

21             JUDGE KWON:  Yes.

22             MR. TIEGER:  I'd say that's -- I'd have to canvass -- excuse me,

23     Your Honour, canvass all the specific rulings, but I say generally that's

24     probably been the case.  I would -- and -- so I understand the Court's

25     point in that respect.  I would note that I received an e-mail from

Page 1912

 1     Mr. Robinson recently in connection with the proposed submission I had,

 2     suggesting an approach to documents that was not consistent with the one

 3     he's advancing now.  So we're just looking for some consistency.

 4             I would note, as I have on previous occasions, that in a

 5     circumstance like this, when the witness indicates quite clearly that he

 6     or she doesn't know about that particular document, the submission is

 7     basically in the form of a bar table or an independent submission.  I

 8     don't particularly have a problem with that.  I think that can indeed

 9     advance the relevant information available to the Chamber, but it

10     obviously can't be a one-sided affair or the Court won't have the benefit

11     of the information it needs.

12             So to the extent it's considered a practice, then we'll certainly

13     be doing the same.  I don't want to resile from the fact that I have

14     encouraged, on a number of occasions, the Court to receive documents that

15     the particular witness may not have authored or specifically received but

16     about which the provenance is reasonably known and the reliability is

17     reasonably clear.  So I certainly don't want the Prosecution to be

18     adopting two different positions, but that would apply equally to the

19     Defence.

20             JUDGE KWON:  If we are talking about a statement, a witness

21     statement given -- bear with us, Madam Zaimovic.  We are having some

22     digression now.  If we are dealing with witness statement or paper --

23     newspaper clippings, I see a point.  Unless the witness confirms the

24     content or the veracity of the document, we cannot admit those documents.

25     However, in terms of official documents, military documents, if we

Page 1913

 1     start -- parties start asking the parties to authenticating such

 2     documents, there will be no end to --

 3             MR. TIEGER:  No.  And I'm reminded of the Court's ruling, which I

 4     believe was on the last court date or the date before, in which you said

 5     precisely that in connection with the tendering of excerpts from larger

 6     documents which were official, contemporaneous documents.  I see that is,

 7     indeed, consistent with the practice that you just asked about, and so I

 8     guess to that extent, and I think it's a clear signal from the Court, the

 9     answer to your question, Your Honour, is yes, that is the practice the

10     Court seems to have adopted.

11             JUDGE KWON:  I'm sorry, Ms. Sutherland.  I haven't asked what

12     your position is about this document.

13             MR. TIEGER:  Well, again, I think in fairness, since I've just

14     responded to the general question, I'm not going to suggest that this

15     document somehow falls outside the parameters of that response, and I

16     believe that's what the Court was -- why the Court made the inquiry in

17     the first place.  So you've heard our response the general proposition

18     that you made in connection with the practice, and I'm not -- not in a

19     position to challenge the provenance of this document.  It appears to be

20     an official document.

21             I do want to point out that we are receiving the documents almost

22     as you see them on the screen yourself, and we really don't have -- I

23     mean, some of these may, in fact, be on the Prosecution's 65 ter list.

24     Some of them may be easily -- for some of them the provenance may be

25     easily identified.  For others, there may be more questions.  It may

Page 1914

 1     result in requests for -- that the documents be marked for identification

 2     so we can check that because of the rapid timing, but -- so there's a

 3     difference between indicating that we're not in a position to know

 4     precisely the provenance of a document at the particular moment it's

 5     tendered and objecting to the document because we think it's unreliable.

 6             JUDGE KWON:  So are you minded to reconsider your response given

 7     to the previous document?

 8             MR. TIEGER:  Again, Your Honour, in light of the guidance -- the

 9     practice the Court has identified, the guidance it's providing and with

10     the caveat there may be numbers of documents for which we would seek an

11     opportunity to consider the provenance after it's marked for

12     identification, the answer is yes.

13                           [Trial Chamber confers]

14             JUDGE KWON:  Mr. Karadzic, if you could remind me of the 65 ter

15     number of the document we just dealt with.  The second one, which is

16     before us now.

17             THE ACCUSED: [Interpretation] 903 -- no, no.  903, the new one.

18     905, actually.  No.  No.  This was 902.  902.  The last one was 902, the

19     one that we dealt with.  902.  1D902.

20             JUDGE KWON:  Thank you.  The Chamber by majority, Judge Morrison

21     dissenting, finds this document relevant in terms of the credibility of

22     the witness and the -- and as far as authenticity is concerned, following

23     the practice of the Tribunal, admits the document, which is 1D902, and

24     reconsider the previous decision regarding 1D905 and admits that document

25     as well.

Page 1915

 1             What will be the exhibit numbers?

 2             THE REGISTRAR:  Your Honours, 65 ter 905 will be D121, and 1D902

 3     will be Exhibit D122.

 4             JUDGE KWON:  Thank you.  Let's proceed.

 5             THE ACCUSED: [Interpretation] Thank you, Your Excellency.  May I

 6     have 1D906 called up again, please.  And I'd like Mrs. Zaimovic to be

 7     provided with a pencil.  Thank you.

 8             MR. KARADZIC:  [Interpretation]

 9        Q.   Now, Mrs. Zaimovic, would you indicate Kosevo stadium, please.

10     We all know where it is.

11        A.   [Marks]

12        Q.   Thank you.

13        A.   You set fire to it.

14        Q.   Now indicate Bjelave, please.

15        A.   [Marks]

16        Q.   Thank you.  Would you now indicate the Centrotrans settlement?

17        A.   I don't know where that is.

18        Q.   I think it's between Kosevo and Pionirska street.  You remember

19     where the Centrotrans district was?

20        A.   I can't remember.

21        Q.   Never mind, never mind.  Now, could you sign the map and then I'd

22     like to tender it into evidence.  And we'll identify the Centrotrans

23     settlement in due course, on another occasion.

24        A.   [Marks]

25        Q.   Thank you.  Now 1D903 is the next document I'd like us to look

Page 1916

 1     at.

 2             JUDGE KWON:  Yes.

 3             THE REGISTRAR:  Your Honours, the annotated map will be

 4     Exhibit D123.

 5             THE ACCUSED: [Interpretation] 1D903 next, please.  1D903.  Thank

 6     you.  Only the relevant portions have been translated, but we have

 7     nothing against the Registrar having it all translated.

 8             This is a document dated the 13th of August, 1995, providing

 9     intelligence about the enemy in the area of responsibility of the

10     Sarajevo-Romanija Corps.  May we move on to page 4, please.  No, page 5.

11     Page 5 of that same document.

12             The passage that has been highlighted, which has been translated

13     by the way.  It says here that the 105th Mountain Brigade has around

14     5.000 soldiers divided into four battalions, of which one is constantly

15     at Niska plateau.  The area of responsibility of this brigade is

16     Sijanicka Kosa, Pionirska Dolina, Grdonj, Hladivode.  Supporting assets,

17     a battery of 120-millimetre mortars at the Centrotrans neighbourhood, a

18     battery of 82-millimetre mortars at the Kosevo stadium, and two howitzers

19     of 105 millimetres located at Bjelovar.  Do you see that?

20        A.   Yes, I do.  I see that it says that there.

21        Q.   Did your son every talk to you about any of that?

22        A.   No.

23        Q.   Thank you.

24             THE ACCUSED: [Interpretation] Your Excellencies, I'd like to

25     tender this document as well.  That's another passage on the following

Page 1917

 1     page but that's not important.  Anyway, I'd like to tender this into

 2     evidence.  Thank you.

 3             JUDGE KWON:  Ms. Sutherland.

 4             MR. TIEGER:  Sorry, Your Honour.  Since I started taking these.

 5     It's not fully translated.  That's another reason for the MFI request.

 6     It's also extremely difficult to read the B/C/S we have here, which would

 7     be another basis for asking that this be MFI'd at the moment, so we can

 8     either seek a better copy or make further inquiries.

 9                           [Trial Chamber confers]

10             JUDGE KWON:  We'll marked it for identification.

11             THE REGISTRAR:  As MFI D124, Your Honours.

12             THE ACCUSED: [Interpretation] Thank you.  May we have the map

13     again, please.

14             JUDGE KWON:  Sorry.  If it is convenient, we can have a second

15     break.

16             THE ACCUSED: [Interpretation] Yes, Your Excellency.

17             JUDGE KWON:  We will have a break for 25 minutes.

18                           --- Recess taken at 5.25 p.m.

19                           --- On resuming at 5.56 p.m.

20             JUDGE KWON:  Yes, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] Thank you.

22             MR. KARADZIC:  [Interpretation]

23        Q.   Ms. Zaimovic, did you work every day?

24        A.   Yes, every day.

25        Q.   And how much time did you spend at work?

Page 1918

 1        A.   Well, it depended.  Mostly from morning till evening.  Sometimes

 2     I had to stay on during the night, too, because the nurses that live far

 3     away were not able to come to work because of the shelling.

 4        Q.   And who was the head nurse before you?

 5        A.   Before me it was a nun.  Her name was Sergeja.

 6        Q.   And what happened to her?

 7        A.   She retired.

 8        Q.   Thank you.

 9             THE ACCUSED: [Interpretation] Now, can we have the map displayed

10     again, please, the same map, Your Excellency, so that we don't have to

11     have a new drawing and a new exhibit every time.  So D123, the map that

12     we were previously looking at, please.

13             Well, I can tender it into evidence, but then I'll be tendering a

14     new map with the new markings.  Thank you.

15             MR. KARADZIC:  [Interpretation]

16        Q.   Now, Mrs. Zaimovic, do you have a pencil?  And if you do, could

17     you mark in the area of Ciglane.

18        A.   Yes.

19        Q.   Thank you.  And now could you draw a circle around the blue

20     skyscraper, "plavi solitar" [phoen].

21        A.   Which blue skyscraper?

22        Q.   Well, everybody from Sarajevo knows what is meant by the blue

23     skyscraper.  By the cemetery and the tunnel leading to the hospital.  You

24     know where the blue skyscraper was.

25        A.   You mean the two blue skyscrapers opposite the hospital?

Page 1919

 1        Q.   Yes.

 2        A.   Right.  The two blue skyscrapers opposite the hospital.  Is that

 3     what you mean?

 4        Q.   Yes, yes.  That's right.

 5        A.   Well, they're somewhere in this area here.  Thereabouts.

 6        Q.   No, that's Breka.  But underneath the faculty building.  You

 7     remember the blue skyscraper with the cafe and everything.  Right

 8     opposite the cemetery and by the faculty building.  Do you remember?

 9        A.   Well, I do vaguely remember, but I can't remember well enough to

10     mark it in here.  And it's not important, after all.  I can't find it.

11        Q.   All right.

12             THE ACCUSED: [Interpretation] Now, may we have document 1D920.

13     It hasn't been translated.  Yes.  Can we have this recorded.

14             JUDGE MORRISON:  Dr. Karadzic, do you have the large bundle of

15     photographs?

16             THE ACCUSED: [Interpretation] I haven't taken the binder with me,

17     but I know that it does exist, the bundle.

18             JUDGE MORRISON:  It's just that I see on one of the photographs a

19     blue skyscraper, and I'm just wondering if that's the one you're

20     referring to.  It's on the photograph that looks like that.

21             THE ACCUSED: [Interpretation] Yes, Your Excellency, that's it.

22     That's right.

23             JUDGE KWON:  Would you like to tender this map marked separately

24     from the previous one?  Yes.  Can we save it separately --

25             THE REGISTRAR:  Your Honour, that will be Exhibit D125.

Page 1920

 1             JUDGE KWON:  Yes.  Let's proceed.

 2             THE ACCUSED: [Interpretation] Thank you.  Now, may we have 1D920,

 3     920.  It hasn't been translated yet, that is, but I'm just going to read

 4     two or three lines from it.

 5             MR. KARADZIC:  [Interpretation]

 6        Q.   And while we're waiting, madam, have you heard had of

 7     Juka Prazina?

 8        A.   Yes, I have.

 9        Q.   Do you know that he became a general in the war?

10        A.   No, I don't know that.

11        Q.   Do you know that he was a well-known criminal prior to that?

12        A.   I don't know that either.  I really don't.

13        Q.   And who was Juka Prazina?

14        A.   Well, I heard that he had taken part in the defence of the town.

15        Q.   When he was wounded just prior to the war, was he treated at

16     Kosevo Hospital?

17        A.   I don't know.  He was an adult patient, and adult patients didn't

18     come to our children's ward, children's clinic.

19        Q.   Thank you.  I'd like you to focus on paragraphs 4 and 5 of this

20     document.  It says:

21             "Juka Prazina's headquarters is located in Ciglane, at the

22     intersection towards the hospital in the blue high-rise building.  They

23     interrogate prisoner in the theatre building in the city centre."

24             Did you know that Juka Prazina had his headquarters so near to

25     the hospital?

Page 1921

 1        A.   No.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] I'd like to tender 1D920, please,

 4     and we will be providing -- oh, I see.  It has been translated.  I didn't

 5     realise.

 6             JUDGE KWON:  Ms. Sutherland.

 7             MS. SUTHERLAND:  No objection, Your Honour, although I would note

 8     that the stamp hasn't been translated.  It's not a full translation,

 9     but -- so it can either be MFI'd until the document's properly translated

10     or it can be --

11             JUDGE KWON:  Yes.  Mark for identification pending translation.

12             THE REGISTRAR:  As MFI D126, Your Honour.

13             JUDGE KWON:  So I note that this is a draft translation by the

14     Defence teams.  So we will wait for the official translation.

15             Let's proceed.

16             THE ACCUSED: [Interpretation] Thank you.  May I have 1D921 next,

17     please, 921.  Yes, the document is on our screens.  I am not sure whether

18     it's been translated yet.  I don't think so.  It says Ministry of the

19     Interior, National Security Service, Republika Srpska, the War Department

20     of Ilidza.  Now, may we have page 2 of the document.

21             MR. KARADZIC:  [Interpretation]

22        Q.   Madam, did you know that most of the fighting in Sarajevo was

23     started by the BH Army?  Almost all the battles were started by the

24     BH Army.  Did you know that?

25        A.   No.  All I know is that you shot from up on the hill and that you

Page 1922

 1     targeted the town.

 2        Q.   All right.  We'll come to that.  But you didn't know, you say,

 3     that all the offensives that were launched in Sarajevo were launched by

 4     the BH Army.  Is that what you said?

 5        A.   Yes, that's right.  I didn't know.

 6        Q.   How is that possible when it was on television, the information

 7     was broadcast over television?  The people were told what positions they

 8     had taken control of and where they broke through, and so on.

 9        A.   Mr. Karadzic, I was at the clinic.  There was no electricity or

10     water.  The children were wounded.  We didn't know where to turn first,

11     we had so much work to do.  We worked from morning to night.  And when I

12     went home, I was so tired and I didn't even have any food to cook for the

13     children.  My life during the war was very difficult, and I don't know

14     about anything of the things you're asking me about, and I'm not

15     interested in them.  I have to be quite sincere there.  You're asking me

16     about military matters, something that you should ask military experts

17     and not me.  I have come here to testify about the difficulties that the

18     children were facing, children who were wounded and who were killed,

19     whose parents were crying, whose lives were disrupted and were targeted

20     like pigeons in town.  Of that's what I want to say.  Do you have any

21     conscience?  Do you have a conscience, because you destroyed the Muslim

22     children and the Croatian children and the Serbian children.  That's what

23     you did.  You destroyed them all.  That's what I've come here to talk

24     about and not to speak about military strategy that I know nothing

25     whatsoever about.

Page 1923

 1        Q.   Thank you, madam, but as soon as you say that somebody shot, you

 2     provide the basis for me to ask you why and how.  As soon as you're

 3     saying that Breka was shelled, I had to put it to you that your son was a

 4     member of the 105th Brigade which numbered 6.000 men and that the whole

 5     place was teeming with soldiers, that there were more soldiers than the

 6     inhabitants of Breka.

 7        A.   Leave my son alone.  That's not true and leave my son alone.  I'm

 8     not talking about your children.  I don't want us to talk about our

 9     children.  We're discussing something quite different here.

10        Q.   Madam, I have every respect for your husband who was a friend of

11     mine and your child, and it was his duty to --

12             JUDGE KWON:  Mr. Karadzic.  Mr. Karadzic.

13             THE ACCUSED: [Interpretation] Yes.

14             JUDGE KWON:  Come to your questions.  You haven't cross-examined

15     yet the evidence which was given by this witness.  Let's move on to your

16     real topic, please.

17             THE ACCUSED: [Interpretation] Thank you.

18             MR. KARADZIC:  [Interpretation]

19        Q.   We'll come back to this document.  1D946 is the next one I'd like

20     us to look at.  It has been translated, so may we have both versions, the

21     Serbian and English on our screens.  Can we have a split screen, please?

22     Thank you.

23             It says, "Military secret, highly confidential."  The date is the

24     28th of July, 1993, an interim combat report for the 28th of July, 1993.

25     It says:

Page 1924

 1              "Today the enemy has violated the cease-fire to the Serb side.

 2     His firing positions, mortar located in the Kosevo Hospital compound.

 3     They fired 20, 82-millimetre mines on the Jagomir ground and

 4     Ernest Grin."

 5             Do you know where those are?

 6        A.   Of course, I do.

 7        Q.   "The mines were falling in the region of Promolj, and the head of

 8     the hospital, Cukovic, Miladin, was killed as a result and a nurse

 9     wounded.  The snipers are constantly active and a soldier from the

10     Rajlovac Barracks was killed by sniper fire.  Engineering works are still

11     underway, and PANs and PATs are being used and pound the lines of the

12     division with the Ilijas Brigade."

13             So within the hospital compound, you had several mortars,

14     82-millimetre ones, and 20 mines, and you say you know nothing about

15     that.

16        A.   Probably that's not -- that's not true, and I really don't know

17     anything about it.

18        Q.   Well, this is a secret document, highly confidential.

19             THE ACCUSED: [Interpretation] It wasn't intended for any

20     propaganda purposes, but I'd like to tender the document into evidence

21     now, please.

22             JUDGE KWON:  While we have admitted so far such documents, I --

23     I'm wondering what's the -- what's the point of your tendering all these

24     documents with the witness.  Are you not minded to call a witness who can

25     speak about these documents?

Page 1925

 1             THE ACCUSED: [Interpretation] Well, Your Excellency, the witness

 2     provided me with the basis for me asking the questions, but also it is my

 3     duty to do so because she put -- she said here that somebody savagely

 4     shot at Kosevo Hospital.  And I spent 50 years of my life working in

 5     Kosevo Hospital and training there, and it's very dear to my heart, just

 6     as it is to Mrs. Zaimovic, but I have to demonstrate here the factual

 7     situation, what the facts were.  In that hospital compound there were

 8     tanks and artillery pieces and brigades.  There were criminals named --

 9     one of them was named Kinez, the Chinaman because he was a very powerful

10     man in that hospital.  So the hospital was everything but a hospital.

11     Quite simply, there was a lot of armed force there.  They abused the

12     traumatology ward and the entire compound, the faculty.  They shot there.

13             JUDGE KWON:  Mr. Karadzic, you can put as many questions as you

14     wish to the witness, and you are entitled to put your case, but you are

15     bound by the answer given by the witness.  So you do not have to put

16     every point to the witness, and then there's no need to deal with all of

17     these documents.  You can deal with it to test the credibility, one or

18     two or several points of such nature, and then you can proceed.  Putting

19     every point to the witness, in the Chamber's view, is a waste of time.

20             Ms. Sutherland, what do you -- would you say to this document?

21             MS. SUTHERLAND:  No objection, Your Honour, although I note that

22     the stamp hasn't been translated, but apart from that it has.

23             JUDGE KWON:  Yes.  In the same line, it will be marked for

24     identification pending translation as 1D127.

25             THE REGISTRAR:  Your Honours, that will be MFI D127.

Page 1926

 1             JUDGE KWON:  Let's proceed, Mr. Karadzic.

 2             MR. KARADZIC:  [Interpretation]

 3        Q.   Mrs. Zaimovic, I'm going to put my case to you and make an

 4     assertion, and I'd like to see your answer.  The Kosevo Hospital was a

 5     torture place for the Serbs; yes or no?

 6        A.   No.

 7             THE ACCUSED: [Interpretation] May we have 1D947 next, please.

 8     And while we're waiting, did you know Mr. Vladimir Kojovic.

 9        A.   No.

10        Q.   On the basis of this document -- well, this part here where it

11     says:

12             "We have also learned that Dr. --"

13             Actually, the previous one in Serbian.

14             "We also found out that Dr. Vladimir Kojovic, who works in the

15     Kosevo Hospital mistreated Serbs in his very own way and that

16     Nedeljka Simic, a doctor of the same hospital helped the Serbs and

17     shielded them --"

18             JUDGE KWON:  Just a minute.  Yes, Ms. Sutherland.

19             MS. SUTHERLAND:  [Overlapping speakers] translation doesn't

20     correspond with the B/C/S document.  The B/C/S document is dated the

21     28th of July and the English translation is 18th of June, 1994, and the

22     other one is 1993 in July.

23             THE ACCUSED: [Interpretation] The Serbian version was not placed

24     there, 947.  This is the old Serbian document -- the old document, I

25     mean.

Page 1927

 1             JUDGE KWON:  Can you try 1D947.

 2             I was advise this is the correct document, so shall we proceed in

 3     the absence of the English translation for the moment?

 4             THE ACCUSED: [Interpretation] No.  This is the previous document.

 5     This is 946.  Let's have a look now.  Yes.  This is 946.  We are actually

 6     asking for 947 to be called up.  We can also have it placed on the ELMO,

 7     the Serbian version.  The mistake is in e-court obviously.

 8             MR. KARADZIC:  [Interpretation]

 9        Q.   So the reference here is to a Serb who is mistreating Serbs at

10     the Kosevo Hospital, and Dr. Nedeljka Simic is protecting them and giving

11     them shelter.  Have you heard of that doctor Nedeljka Simic?

12        A.   No.

13             THE INTERPRETER:  Microphone for Ms. Sutherland, please.

14             JUDGE KWON:  Microphone.

15             MS. SUTHERLAND:  I'm sorry, Your Honour.  The document on the

16     left and the right of the screen are exactly the same, and it's -- it's

17     document 1D946 and 1D947.  It's the same document.  So we don't have even

18     the B/C/S of the document that Mr. Karadzic is reading from.

19             JUDGE KWON:  Yes.  There seems to be a mistake on the -- on the

20     Defence part.  Let's proceed.  Let's move on to another topic.

21             THE ACCUSED: [Interpretation] Very well.  We'll deal with it

22     tomorrow perhaps.  Then could I have document 949, please.  At least the

23     relevant portions have been translated.  So we have the document now.

24             MR. KARADZIC:  [Interpretation]

25        Q.   The date is the 8th of May, 1995.  The Muslim intentions in the

Page 1928

 1     area of Sarajevo.  This is intelligence, so it is confidential

 2     information again.  That:

 3             "The MUP of Republika Srpska, RDB, through operative activities

 4     has received information that plans for attacks at Sarajevo have been

 5     prepared and finalised.  Four brigades have been brought to Sarajevo and

 6     three more expected from the area of Zenica.  The attack is supposed to

 7     occur in several directions simultaneously."

 8             I apologise.  I have to read this more slowly.

 9             "The attack should begin from the city," et cetera.

10             Mrs. Zaimovic, do you know that in the summer of 1995, the Muslim

11     army had started a large-scale offensive from the city and from

12     Central Bosnia?

13        A.   Believe me, I don't know.  I don't know anything about any of

14     that.

15        Q.   Let us move on to paragraph 1, 2, 3, 4, 5.  5:

16             "An 82-millimetre battery is located in the new maternity

17     building, and they are occasionally taken out the main side entrance

18     towards the stadium.  Two mountain cannons, B1, are located on the

19     premises of the Kosevo Hospital, in the part near the faculty of civil

20     engineering."

21             Do you know that there were two mountain cannons in -- on the

22     premises of the Kosevo Hospital?

23        A.   No.

24        Q.   But they were firing.  Did you hear the explosions?

25        A.   No.  In my opinion, that was certainly not the case.  These are

Page 1929

 1     your reports.  I have no idea.

 2        Q.   Let us move on to the next paragraph and then the last sentence

 3     in that next paragraph.

 4             "The sniper nest is above the school for deaf mutes."

 5             Nemanja Vlatkovic was the name of the school, wasn't it?

 6        A.   I don't know about that.  That's what you're saying.

 7        Q.   Could we move on to the next page, please.  The second paragraph

 8     on the next page:

 9              "The command of the 2nd SMB is at the faculty of civilian

10     engineering and headquarters is at the institute of geology in the

11     building of the hygiene institute.  The civil engineering faculty is

12     right next to the hospital."

13             You did you mark it; right?

14        A.   Yes.

15        Q.   Are you saying that this did not actually happen?

16        A.   What is it that you think?  What is it that I'm claiming?  I

17     didn't understand your question.

18        Q.   Is it your assertion that these military installations were not

19     in the localities specified in this document?

20        A.   Do you understand what I'm saying to you, that about these

21     military things that you're talking about in the city, I have no idea

22     about that.  You keep putting these questions to me, and I have no idea

23     about any of that that you're asking me about.  Do you understand that I

24     don't know anything about this?  I wasn't interested in it at all.  I was

25     doing completely different things.

Page 1930

 1        Q.   Mrs. Zaimovic, you said several times here that Serbs were firing

 2     at the city.  So now we have to see whether they were firing at

 3     legitimate targets or whether they were randomly shooting all over town.

 4     Do you agree that there is a difference, if there is a cannon, a

 5     howitzer, a mortar at Biljevina, doesn't that make a difference?  Does it

 6     make the situation different if there was not a mortar battery there or

 7     howitzers or whatever?

 8        A.   Mr. Karadzic, you know full well what you did.  You know that you

 9     surrounded Sarajevo.  You know that you fired whenever you wanted to.

10     You killed people whenever you wanted to.  People had to get organised

11     and defend themselves.  But I don't know about these military targets at

12     all.  I don't know about this kind of thing at all.  You have to

13     understand that.

14        Q.   Thank you.

15             THE ACCUSED: [Interpretation] Could this document please be

16     admitted.

17             JUDGE KWON:  Ms. Sutherland.

18             MS. SUTHERLAND:  No objection, Your Honour, but again the stamp

19     hasn't been translated.

20             JUDGE KWON:  If I can get the confirmation from the Court Officer

21     that this -- this -- these kind of documents will be translated

22     officially by the CLSS.

23                           [Trial Chamber and Registrar confer]

24             JUDGE KWON:  They will be marked for identification pending

25     translation.

Page 1931

 1             THE REGISTRAR:  As MFI D128, Your Honour.

 2             JUDGE KWON:  Mr. Karadzic, having followed the evidence of

 3     Mrs. Zaimovic so far, I don't think there's a point of you continuing to

 4     put those documents relating to the locations of ABiH, et cetera.  You

 5     can put your case, and then you have another opportunity to prove what

 6     you put to the witness, but given the position of the witness that she

 7     does not know anything about military location or the attack from the

 8     BiH Army, I don't think it's -- it will help your case at this moment.

 9     So I -- I tell you to move on your different topic.

10             THE ACCUSED: [Interpretation] Your Excellency, we are getting

11     closer and closer to the hospital.  As for the rest of today and

12     tomorrow, we are going to be dealing with what it was that happened in

13     that hospital that Mrs. Zaimovic portrayed as an innocent target.  We are

14     going to prove that that was not the case at all, and you will see that

15     the situation was quite different to what Mrs. Zaimovic has been saying.

16             JUDGE KWON:  As I tell you, Mr. Karadzic, put your case and then

17     move on to another topic.  You don't have to deal with all these

18     documents with this witness.  You will have another opportunity.

19             THE ACCUSED: [Interpretation] 1D950, please.

20             MR. KARADZIC:  [Interpretation]

21        Q.   Mrs. Zaimovic, what about the salaries of Serbs and Muslims in

22     Kosevo Hospital?  Were they the same?

23        A.   We didn't have any salaries at all at the beginning of the war.

24     The salaries had always been the same, whenever we received them, that

25     is.  There was no difference whatsoever.

Page 1932

 1        Q.   We'll deal with that later.  Thank you.

 2             THE ACCUSED: [Interpretation] Could we have the third paragraph

 3     in this document.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   According to the information we have received, there is a very

 6     small number of people of Serb ethnicity admitted to the Kosevo Hospital,

 7     those being the ones whose bare lives to be rescued by doctors'

 8     interventions only.  After the first signs of recovery, executioners

 9     enter the rooms.  They beat the Serb patients, returning them to a

10     devastating situation.  In relation to that, the source states that a

11     certain Mirza employed as a security guard in the hospital, as well as

12     Senada, a nurse, and a medical technician, Almir, are the people who

13     terrorise the Serbs in the Kosevo Hospital the most.

14             On the 31th of December, 1992, the three of them placed all Serbs

15     who were on the ward in one room, in which, on the morning of the 1st of

16     January, 1993, a group of soldiers of the so-called BiH Army barged into

17     the room beating the patients mercilessly and torturing them for two or

18     three hours.  A certain Marinkovic had died from the beating.

19             Are you saying that this did not happen?

20        A.   I don't know about this, but I assert that no such thing every

21     happened at the hospital.  Everybody was treated the same way, really and

22     truly.  These are pure fabrications.

23        Q.   Do you know these persons whose names were mentioned?

24        A.   No.

25             THE ACCUSED: [Interpretation] I would like to tender this

Page 1933

 1     document, Your Excellencies.  All of these reports are strictly

 2     confidential or were strictly confidential when they were created.

 3             JUDGE KWON:  Same position, Ms. Sutherland?

 4             MS. SUTHERLAND:  Yes, Your Honour.

 5             JUDGE KWON:  They will be marked for identification pending

 6     translation.

 7             THE REGISTRAR:  As MFI D129.

 8             THE ACCUSED: [Interpretation] Thank you.  Could I have 1D951,

 9     please.  1D951.  It is possible that there is no translation yet.

10             JUDGE KWON:  Mr. Karadzic, I think you didn't understand me in

11     full.  I just asked you to put all of your case to the witness and move

12     on to other topics instead of showing all the documents about which the

13     witness has no knowledge at all.  There's no point of continuing such

14     practice.  Put all the case.  And having received the answer, you proceed

15     to ask other topics.

16             THE ACCUSED: [Interpretation] Thank you, but this is an

17     opportunity, because it has to do with the hospital.

18             MR. KARADZIC:  [Interpretation]

19        Q.   Madam, let me put it this way:  Do you know that gunpowder was

20     smuggled in the oxygen bottles that were sent to you in the hospital?

21        A.   I don't know.  How could I know that kind of thing?

22        Q.   Well, that was rather well known.  It was written about in the

23     media.

24        A.   I have not read about that, and I have no way of knowing about

25     that really.

Page 1934

 1        Q.   Thank you.  Now I would like to move on to another topic, namely

 2     what happened to your colleagues in the Kosevo Hospital.  Now I'm going

 3     to ask -- actually, 951 is a document I wanted to tender as well.  It is

 4     another secret report at the time when the smuggling was uncovered.

 5             JUDGE KWON:  Mr. Karadzic, apart from the principle we've taken

 6     as regards the admissibility of documents, given our -- given my

 7     instruction to move on to another topic without relying on such

 8     documents, the Chamber will not admit this document.  Let's proceed.

 9             THE ACCUSED: [Interpretation] Thank you.

10             MR. KARADZIC:  [Interpretation].

11        Q.   Mrs. Zaimovic, in your statement of the 9th of April, 2000, you

12     say on page 00938863, paragraph 4, that Serb and Croat doctors stayed on,

13     for the most part, but that then, slowly, they started leaving one by

14     one.  Is that the way you had put it?

15        A.   Yes.  At first the doctors were there with us for the most part,

16     and as time went by, Serbs and Croats were leaving us and ultimately some

17     Muslims as well whose families had left town.  Masses of people had left

18     town because they were afraid for their lives.  So out of a total of 14

19     doctors, we ultimately had only two, one Muslim and one Croat.

20        Q.   Thank you.  Are you trying to say that they were leaving because

21     they felt good and safe and that they went to the Serb side and gave us

22     statements as to what happened to them in Kosevo Hospital; or are you

23     going to accept that they were threatened there, primarily Serbs and Jews

24     and Croats, and that they fled to our side and then gave statements to

25     us?

Page 1935

 1        A.   In Sarajevo, nobody was threatened really, especially not at the

 2     Kosevo Hospital.  They worked together with us side by side.  We shared

 3     the very last bits of food that we had.  Ethnic Serbs were the first to

 4     leave our clinic, then Croats with their families as the war became more

 5     and more intensive.  They all had young children, et cetera, and finally

 6     Muslim doctors left.  I repeat:  We only had two doctors left who taught

 7     young doctors how they could work and help as well.  You can imagine what

 8     it was like for us to operate in that situation with so few doctors

 9     around.  You know full well what was going on.

10        Q.   Are you trying to say, Mrs. Zaimovic, that a doctor who tries to

11     leave town without permission was not punished and was not sentenced to a

12     prison term of half a year, at least?

13        A.   What do you mean prison sentence.  You are a doctor and you

14     killed patients.  You took the oath and you did horrible things.  What do

15     you know?  You should read up on this.  Doctors who left went to save

16     their lives.  Some went to your side, and others went just to save

17     themselves and their families, like all citizens of Sarajevo.  Sarajevo

18     was a city under siege, terrible siege.  So many days and so many shells

19     fell.  Everybody was in fear for their families and themselves.  It was

20     very hard to live in town, and you know that full well.  You are taunting

21     me with all these questions, but go on.  I can take it.

22             JUDGE KWON:  Mrs. Zaimovic, I understand how you feel, and you

23     are very -- you are in a very difficult situation, but please try to

24     answer the question.  By that way you are assisting the Chamber.  You are

25     not answering to Mr. Karadzic but to the Chamber.

Page 1936

 1             Let's proceed.

 2             THE WITNESS: [Interpretation] Yes, I apologise, Your Excellency.

 3             JUDGE KWON:  No, you don't have to apologise.  Let's proceed.

 4             MR. KARADZIC:  [Interpretation]

 5        Q.   Thank you.  Can you tell me whether you knew Dr. Kemal Drndo.

 6        A.   Yes.  He was an excellent surgeon.

 7        Q.   And an excellent man, too.

 8        A.   Yes, an excellent man and excellent surgeon.

 9        Q.   And he was professor to me and to your husband.  Now, can you

10     tell me why he was replaced?

11        A.   He wasn't replaced at all.

12        Q.   And what post was he when the end of the war came?

13        A.   He was the principal surgeon of the emergency ward.

14        Q.   But wasn't he a director before that?

15        A.   He was the principle surgeon at the emergency ward.

16        Q.   And what was he at the beginning of the war?

17        A.   He was the head of thoracic surgery.

18        Q.   Did you know Professor Najdanovic, who was also at the thoracic

19     surgery ward?

20        A.   Yes.

21        Q.   Do you know what happened to him?

22        A.   No, I don't.

23        Q.   Mrs. Zaimovic, I have to doubt that, because it's common

24     knowledge what happened to him.  So I can't believe it when you say you

25     don't know what happened to him.

Page 1937

 1        A.   I don't know what happened to him.  All I know is that he was

 2     killed.  That's all I know, but I don't know what actually happened to

 3     him.

 4        Q.   Do you know that there are photographs of him stark naked and

 5     circumcised and being led through your hospital compound and then they

 6     killed him and threw him into a rubbish dump, into a container?  Do you

 7     know that?

 8        A.   No, I don't.  I really don't.

 9             THE ACCUSED: [Interpretation] May I have 1D911, next, please.

10     1D911 is the number of the next document I'd like called up on e-court,

11     please.  We have the Serbian version there.  The date is the 17th of

12     October, 1992.

13             JUDGE KWON:  Mr. Karadzic, does that document contain the

14     contents that you just put to the witness?  That being the case,

15     recommend you to move on to your next topic.  I said to you to put all

16     the cases without having to rely on the documents.  Let's proceed.

17             THE ACCUSED: [Interpretation] Well, Your Excellency, then I have

18     to change my approach, and I cannot accept having the witness avoid

19     matters that were so drastic that the whole of Sarajevo knew about them.

20     I just can't believe that the witness is being sincere.  It's -- it's a

21     matter of confirming facts that everybody in town knew about.

22             JUDGE KWON:  Mr. Karadzic, as I told you, you can put all your

23     case to the witness, and even you can ask whether -- to the witness

24     whether she's lying or not, and then you'll have another opportunity to

25     tender and prove the facts as you wish.

Page 1938

 1             As Judge Morrison told you, you should be bound by what the

 2     witness said in relation to her evidence.

 3             Let's proceed.

 4             THE ACCUSED: [Interpretation] Thank you.  Her testimony contains

 5     a lot of allegations about Serb conduct.

 6             MR. KARADZIC:  [Interpretation]

 7        Q.   Now, madam, you said that you knew Dr. Starovic.  Do you know

 8     that on the 6th of April, at the very beginning of the war, when he was

 9     getting into his car, a neighbour of his who was an underage person shot

10     at him with the intention of killing him?

11        A.   I really don't know that.  I know that Dr. Starovic fell ill, and

12     because of his illness he left town.

13        Q.   Thank you.  Now, do you know who Bane Surbat, a national hero is?

14        A.   Well, I have heard the name, yes.

15        Q.   Did you know his brother, Dr. Gojko Surbat?

16        A.   No.

17        Q.   Everybody living in Sarajevo knew Dr. Surbat.  Do you know he was

18     killed in front of his own house?

19        A.   I really don't know that, no.

20        Q.   And what about Dr. Vladimir Belenki, have you heard of him?  He

21     was a doctor at the ear, nose, and mouth department.

22        A.   I have heard of Dr. Vladimir Belenki from that department, but I

23     don't know what happened to him.

24        Q.   He was killed too.  Now, have you heard of Dr. Zarko Mijatovic,

25     who worked in the maternity ward and helped all the women of Sarajevo

Page 1939

 1     give birth?

 2        A.   Yes.

 3        Q.   And do you know that he was wounded through a firearm?

 4        A.   Well, do you know how many other doctors and nurses were wounded

 5     and injured in Sarajevo?

 6        Q.   I'm asking about a man who was wounded by the Green Berets with

 7     the intention of killing him.

 8        A.   No, I don't know that he was wounded and injured.  I really

 9     don't.

10        Q.   Did you know Dr. Mihajlo Vujovic.

11        A.   Yes.

12        Q.   Do you know that he was stabbed in the stomach a number of times

13     and hanged at his own threshold with the intention of making it look like

14     a suicide?

15        A.   I really don't know, and I think that that is something that

16     should be proved.  I have -- I don't know anything about that.

17        Q.   Do you know Dr. Bajko Hogic [phoen]?

18        A.   Of course I do.

19        Q.   Do you know that the doctors who returned to work after those

20     first clashes and conflicts, that he would say to them at meetings, What

21     are you doing here, and how dare you address me, and that's how he sent

22     doctors packing?

23        A.   I don't know that, but I know that he was an excellent boss and

24     an excellent neuro surgeon.  And he did very hard work in the clinical

25     centre when he lost a lot of doctors and he had to work overtime.

Page 1940

 1     Certainly he would be angry with people from time to time, but he was a

 2     real doctor, a real humanist, and, out of respect, everybody should get

 3     up when he comes into a room.

 4        Q.   And do you know when they offered him to become part of a peace

 5     mission he said, What peace mission?  We've been waiting for this from

 6     1804, which was the first Serbian -- the date of the first Serbian

 7     uprising?

 8        A.   No.  I know nothing about that.

 9        Q.   Do you mean to say, Mrs. Zaimovic, that Dr. Dejan Kafka, from a

10     Serbian Jewish marriage, a fateful marriage, and Dr. Marko Vukovic,

11     Dr. Sabljak and Dr. Medenica and Veljko Nemanja, did not get a six-month

12     sentence when they tried to leave?

13        A.   Let me tell you about Dejan Kafka.  He was a doctor working at my

14     clinic.  He was married to a wonderful woman.  His wife was really a

15     wonderful woman.  I don't know what ethnicity she was.  But during the

16     war, a son was born to him and we would all take presents to him, to help

17     him out, clothing and firewood, and so on.  And at one point, he felt

18     that he could no longer remain at the clinic.  He had to leave.  He

19     collected up his belongings because his wife had gone to Belgrade before

20     him and he escaped through the tunnel.  Now, what happened to him after

21     that I don't know, but he worked at our clinic for a long time because

22     his father was the first head of the surgical ward, Professor

23     Dr. Ivan Kafka, who was an exceptional surgeon and with whom I worked for

24     many years.

25        Q.   Thank you.  Dr. Kafka, yes, his father was very well known and

Page 1941

 1     his mother was a Serb woman and his father was a Jew.  But all the ones

 2     that I listed we see were given six-month prison sentences because they

 3     attempted to leave town?

 4        A.   Well, that's a matter of politics, but that man really did work

 5     for quite a long time at our clinic, and he's still alive working in

 6     Belgrade.  We met him recently, and when his wife gave birth to their

 7     son, we tried to help them out as best we could, taking them clothes and

 8     food and firewood, and so on.  We never distinguished between anyone.

 9        Q.   Now, do you know that Enko Rustempasic was never forgiven - he

10     was a Muslim doctor and his wife, Sonja Sorajic, a good

11     anaesthesiologist, perhaps the best - for having contracted a mixed

12     marriage, ethnically speaking, and when Sonja addressed the authorities

13     for help, they wouldn't, and they said that they had to leave Sarajevo.

14        A.   I think all that is pure invention, and that's the kind of rumour

15     that was put about and led people to hate each other.  That's what you

16     keep doing all the time.  You want to intensify hatred among people by

17     putting out rumours of that kind.

18        Q.   Well, in due course, we'll provide evidence about that.

19             Now, do you know about this man Kinez, who was the head of

20     security at the hospital?

21        A.   Well, I have heard of him, but I never met him.

22        Q.   But what was he, the head of what?

23        A.   I don't know what he was at all, but I did hear his name

24     mentioned, but I, myself, never met him, nor do I know him at all.  Nor

25     do I know that he was at the hospital either.  Absolutely not.

Page 1942

 1        Q.   Very well.  We'll ask the Trial Chamber to show the statements of

 2     these people that you say I'm making them all up.

 3             Now, from the traumatology department were mortars fired around

 4     Serb positions?

 5        A.   I'm sure that's not true, and I don't know about any of that.

 6        Q.   But you say you know that it's not true.

 7        A.   It's certainly not true, but I don't know.  I'm sure people would

 8     have seen that, but I think that you're making it all up, big time.

 9        Q.   Now, we both knew Dr. Milica Lopandic?

10        A.   Yes, we did, and I liked her very much.

11        Q.   She was Sreten Lopandic's wife; right?

12        A.   Yes, she was.

13        Q.   And they had a rather large apartment, very nice one?

14        A.   Yes.

15        Q.   And what happened to Dr. Milica Lopandic?

16        A.   Does the Trial Chamber really want me to say what happened?

17        Q.   I say that she was thrown out of the window because other people

18     coveted her apartment?

19        A.   You are lying.  She wasn't thrown out.  She was at our clinic all

20     the time.  We helped her.  We brought her food.  We visited her husband

21     and all the rest of it.  But because of the shelling, and she was

22     terribly afraid of the shelling, she would frequently come to our

23     basement where we would take refuge with our children, and she spent a

24     lot of time there because she was very afraid of the shelling.  And one

25     day we heard that she had committed suicide jumping out of the window.

Page 1943

 1             Now, about this coveting of her apartment and seizing her

 2     apartment, that's just not true, but that can be investigated to see who

 3     actually did take her apartment.  But Dr. Milica Lopandic merited every

 4     respect, but she suffered a nervous breakdown because of the tireless and

 5     ceaseless shelling in Sarajevo.

 6        Q.   And when did Mrs. Lopandic die?

 7        A.   I don't know the exact date.  I don't know when she died, but we

 8     buried her, gave her a nice funeral.  We waited for her daughter to

 9     arrive from America and her son from Belgrade, and we -- the clinical

10     centre paid for the funeral.  Professor Kolihagic [phoen] and Professor

11     Dizdarevic, we all attended the funeral, regardless of the fact that

12     there was shelling going on all the time.  We all attended her funeral.

13     And I think you're telling it a lot of lies, and I find it horrific to

14     have to listen to everything you're telling me.

15        Q.   Well, I find it horrific too.  I'm not saying that you threw her

16     out of the window.

17        A.   Well, nobody threw her out of the window, and that's quite

18     definite.

19        Q.   We're going to show what your big-time journalists write about

20     this custom of throwing people out of windows.  We'll come to that

21     tomorrow.

22             Do you maintain that people weren't thrown out of the window in

23     order to kill them?  And a Serbian poet said he didn't jump, they jumped

24     him.

25        A.   That's what you say, sir.  I know nothing about that.

Page 1944

 1        Q.   Do you say that the Sabotage Company of the 105th Brigade did not

 2     have a post at the bakery?

 3        A.   Well, please believe me when I say that I don't know where this

 4     bakery was.

 5        Q.   Do you know where Juval Nitrak street was?

 6        A.   No.

 7        Q.   I'd like to go back to a document now -- well, actually, we

 8     haven't called it up yet.  But anyway, let's see what the reports were

 9     like about the situation in Kosevo Hospital, the supplies, and so on.

10     And that, I think, is 948, document 948.

11             THE ACCUSED: [Interpretation] May we have 948 called up on

12     e-court, please.  I think there's a translation as well.

13             JUDGE KWON:  While we are waiting for the translation,

14     Mr. Karadzic -- I was told that there's none.  You will have spent, by

15     the end of today for your cross-examination, about two hours.  Originally

16     you indicated -- you projected your cross-examination to be four hours,

17     and then later on you requested further -- more two hours.  I'm speaking

18     for myself, but I think you could conclude what you put today to the

19     witness in less than half an hour or even 15 minutes.  So discuss the way

20     how to cross-examine with your legal advisor, and we expect you to

21     conclude your cross-examination by the first session tomorrow.

22             We have five more minutes.  Let's proceed.

23             THE ACCUSED: [Interpretation] Thank you.  I don't think that will

24     be sufficient, but in view of the allegations made by the witness, by the

25     by.

Page 1945

 1             MR. KARADZIC: [Interpretation]

 2        Q.   But let's focus on paragraph 3.  This is a strictly confidential

 3     secret document.  It says:

 4             "The Kosevo Hospital in Sarajevo is well supplied with medicines,

 5     medical material, and sufficient quantities of blood.  About 7.000 meals

 6     are served and prepared each day for the duty staff of which there are

 7     1.200 and for about 1.500 patients.  The meals are mostly made up the

 8     rice, beans, and macaroni.  And in every fourth building of this

 9     institution, there's a separate place for worship, something like a

10     mosque.  The hospital is regularly supplied with gas, electricity, and

11     water, and it also has gas-powered generators should the electricity

12     supply be cut.  The generators are maintained by UN members."

13             What do you have to say to this report?

14        A.   What I can say is at the beginning of the war, when you cut off

15     our electricity and water supply, the situation in the hospital was

16     extremely difficult.  We had no water and no electricity, and electricity

17     was the main problem.  Well, so was the water, and all the sheets that we

18     used were destroyed because we had to use some very strong disinfectants,

19     since we couldn't wash and launder clothes properly.  So a lot of what it

20     says here is not true.  There was food, but of very poor nutritional

21     value.

22             We appealed to the citizens to bring in food to the children and

23     pyjamas, sheets, and so on.  That didn't happen until the physicians of

24     the world turned up and UNICEF, and they helped us a lot to have the

25     minimum supplies of food and medicines and sheets and everything else we

Page 1946

 1     needed in the hospital, but our situation was very difficult.  We just

 2     had small weak lamps until the physicians of the world came in and

 3     brought in better equipment, together with UNPROFOR, to provide what the

 4     generators needed so that the operating theatres could function.

 5             So you're not being honest and sincere, Mr. Karadzic, to put out

 6     untruths like that to the -- you destroyed the city that provided you

 7     with your education and your life.  Why don't you repent and tell the

 8     truth before this Trial Chamber?  You destroyed thousands of people and

 9     lives.  Your people, our people, our ethnicities, you destroyed everyone.

10     And it's not fair of you.  What you're saying now, you're not being fair.

11     You're speaking and uttering terrible untruths.  I apologise for my

12     emotions, but this is something that I feel strongly about and that

13     affects me deeply.

14        Q.   Madam, I am reading reports put out by intelligence services.

15        A.   What intelligence services?  You had spies everywhere.  They were

16     your intelligence services.  What you did to us is terrible.  You

17     destroyed thousands of lives and people.  So repent.  Say it, I did that

18     with my army.  I did those things.  But you don't want to do that.  You

19     don't want to say that.  And you did do that.  That's what you did.  You

20     killed innocent people.

21        Q.   Madam -- the Islamic Declaration?

22        A.   Let's leave that aside.

23        Q.   You know who was guilty, guilty.  It was the writers of the

24     Islamic Declaration.  Those are the culprits.  They were the culprits, as

25     far as you were concerned, and as far as I was concerned.

Page 1947

 1             THE ACCUSED: [Interpretation] And I'd like to tender this

 2     document.

 3             JUDGE KWON:  As I told you, we will not admit this document.

 4     Bear in mind, we will give you the first session tomorrow.

 5             We will rise for today.

 6                           --- Whereupon the hearing adjourned at 7.01 p.m.

 7                           to be reconvened on Thursday, the 6th day

 8                           of May, 2010, at 2.15 p.m.

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