Page 21389
1 Wednesday, 16 November 2011
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 12.01 p.m.
5 JUDGE KWON: Good morning and good afternoon. For the first
6 session, we will sit pursuant to Rule 15 bis with Judge Morrison away,
7 who is coming on his way now to the Tribunal. I am absolutely confident
8 he will be with us from next session on.
9 Yes, Mr. Tieger. Yes, Ms. Sutherland.
10 MS. SUTHERLAND: Good afternoon, Your Honours. I need to go into
11 private session for a very short time to deal with some associated
12 exhibits with the last witness.
13 JUDGE KWON: Very well. Could the Chamber move into private
14 session.
15 [Private session]
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9 [Open session]
10 JUDGE KWON: Yes, we are in public session, Ms. Sutherland.
11 MS. SUTHERLAND: Your Honour, in relation to the video-tapes that
12 are associated with Dr. Kirudja's amalgamated statement, and they are
13 referred to in paragraph 163 of his statement. These are several clips
14 from 65 ter 40387, and I have been instructed to advise Your Honours that
15 four clips are Exhibit P49 from the Stanisic/Simatovic case.
16 Clips 1, 2, and 3 of Exhibit P49 in the Stanisic/Simatovic case
17 are contained under 65 ter 40387C in this case, and we would seek to
18 tender those.
19 And clip 4 of P49 in the Stanisic/Simatovic case is already in
20 evidence in our case and is contained under Exhibit P02158.
21 And there is an additional clip under 65 ter 40387, which is also
22 detailed in paragraph 163 and footnote 358 of Dr. Kirudja's amalgamated
23 statement, and this clip is identified as 65 ter 40387D, and we would
24 seek to tender that.
25 JUDGE KWON: So what are admitted are 40387C and D.
Page 21392
1 MS. SUTHERLAND: Yes, Your Honour.
2 JUDGE KWON: Thank you. I'm not sure whether the exhibit numbers
3 were given.
4 Very well. I was told that it was admitted as one exhibit. I
5 don't see any problem with that.
6 THE REGISTRAR: Exhibit P3879, Your Honours.
7 MS. SUTHERLAND: Very well, Your Honour. And finally, the last
8 administrative matter I wish to deal with was in relation to Mr. Krejic's
9 testimony, and it's Exhibit P03760. You may recall that I stated that
10 there were a number of procedural matters dealt with in that prior
11 transcript, and I have discussed these proposed redactions with
12 Mr. Robinson, who is in agreement, and the redacted version has been
13 uploaded in e-court.
14 JUDGE KWON: Thank you for that information, Ms. Sutherland.
15 Then please call your next witness.
16 MS. SUTHERLAND: The Prosecution calls Dr. Idriz Merdzanic.
17 JUDGE KWON: I take it the parties are informed of today's -- as
18 of today's sitting?
19 MR. ROBINSON: Yes, Mr. President.
20 MS. SUTHERLAND: Yes, Your Honour.
21 [The witness entered court]
22 JUDGE KWON: Would the witness make the solemn declaration.
23 THE WITNESS: [Interpretation] I solemnly declare that I will
24 speak the truth, the whole truth, and nothing but the truth.
25 WITNESS: IDRIZ MERDZANIC
Page 21393
1 [Witness answered through interpreter]
2 JUDGE KWON: Thank you, Dr. Merdzanic. Please make yourself
3 comfortable.
4 THE WITNESS: [Interpretation] Thank you.
5 JUDGE KWON: Yes, Ms. Sutherland.
6 Examination by Ms. Sutherland:
7 Q. Sir, could you please state your full name.
8 A. Merdzanic is my last name, and Idriz is my first name.
9 Q. Dr. Merdzanic, as we discussed, part of your evidence in this
10 case will be submitted in writing, and we first need to deal with the
11 formalities associated with that submission.
12 You've testified in three trials before the ICTY, and in
13 particular, the Stakic trial on the 10th and 11th of September, 2002.
14 On the 12th of September, 2002, did you provide a handwritten
15 document to the Tribunal regarding your Stakic testimony?
16 A. That is correct.
17 MS. SUTHERLAND: Mr. Registrar, could I have 65 ter 23496 on the
18 screen, please.
19 Q. Do you recognise the document that's on the screen in front of
20 you?
21 A. Yes. That is what I have written.
22 THE INTERPRETER: Interpreter's note: We can barely hear the
23 witness. Could all other microphones please be switched off when the
24 witness is speaking. Thank you.
25 MS. SUTHERLAND:
Page 21394
1 Q. Dr. Merdzanic, does this clarify an issue in your Stakic
2 testimony in relation to the check-points in Kozarac?
3 A. Correct. There was one question whether there was a check-point
4 at the entrance into Kozarac, and I thought about that after the trial,
5 and I remembered that there was an obstacle there for this tank that was
6 at the crossroads near the entrance into Kozarac.
7 Q. Dr. Merdzanic, have you had the opportunity to review the audio
8 recordings of your Stakic testimony?
9 A. Yes.
10 MS. SUTHERLAND: Your Honours, there is one word at transcript
11 page 7769, line 16, when he was asked in chief about the film that was
12 taken about the time at Keraterm, and the word "Keraterm" should read
13 "Trnopolje."
14 Q. And you agree with that correction, Dr. Merdzanic?
15 A. It is correct. I was never in Keraterm.
16 Q. With those clarifications, the document that you see on the
17 screen and the one that we just spoke about, can you confirm that your
18 Stakic testimony accurately reflects your statements at the time?
19 A. I can confirm that along with an explanation that I'd like to
20 provide. When I read this, I noticed that the time between the
21 announcement of the journalists' visit and the arrival of the
22 International Red Cross, it was sort of unclear. I would like to clarify
23 that. When it was announced that journalists would arrive and then up
24 until the arrival of the International Red Cross, hundreds of persons
25 were killed and I think that that should be clarified.
Page 21395
1 Q. When you say hundreds of people were -- were killed, can you
2 elaborate on that, please?
3 A. Yes. If you'll allow me to explain it now, I will.
4 JUDGE KWON: Could you indicate first, Ms. Sutherland, what
5 part -- what pages are dealing with that part, the interval between the
6 announcement and the arrival.
7 MS. SUTHERLAND: Your Honour, the arrival of the journalists --
8 the first visit of the journalists starts on page 7793.
9 JUDGE KWON: Very well. That's sufficient. Why don't you
10 proceed with the witness.
11 MS. SUTHERLAND:
12 Q. Mr. -- Dr. Merdzanic, when you say that a large number of people
13 were killed, can you elaborate on who you were actually referring to.
14 A. Camp inmates. When Dr. Karadzic promised in London that he would
15 allow journalists to visit the camps because he had claimed that they
16 were no camps, he returned to Bosnia and then an order arrived from Pale
17 from Dr. Karadzic to have the camps prepared for the journalists' visits.
18 Until the camps were prepared, the journalists could not come. This
19 order for the camps to prepare for the visits was basically a death
20 sentence for many camp inmates.
21 As for the Keraterm camp, it was decided to have it completely
22 emptied and to have all the camp inmates removed. Since there were a
23 great many camp inmates, they didn't know what to do with them --
24 JUDGE KWON: Doctor, I'm sorry to interrupt you. Did you mean
25 Keraterm camp? Did you not say that you have never been to Keraterm
Page 21396
1 camp?
2 THE WITNESS: [Interpretation] I'm speaking about the Keraterm
3 camp because it's tied to Trnopolje, because part of these people came to
4 Trnopolje. So I'm speaking along those lines. You can understand only
5 if all three camps are explained together.
6 JUDGE KWON: Back to you, Ms. Sutherland.
7 MS. SUTHERLAND:
8 Q. Dr. Merdzanic, so you indicated earlier that there were a large
9 number of people killed, and you have just provided an answer then to say
10 that this order for the camps to -- to be prepared for the visits was
11 basically a death sentence for many camp inmates. Can you -- can you
12 just elaborate on -- on what you mean by that?
13 A. Yes. I will try to explain that briefly now. They reached a
14 simple decision for Keraterm. Part of these people were supposed to be
15 transferred to Trnopolje. As for one hangar, they simply put
16 machine-guns in front of the door to that hangar, and they killed
17 everybody who was inside. Crljenkovic Enes was the only person to
18 survive. He is alive to this day. Everybody else was killed, over
19 100 people. Some people were taken in an unknown direction. That is as
20 far as Keraterm is concerned.
21 Omarska was also supposed to prepare for the arrival of the
22 journalists. Some people were sent to Manjaca. That is a camp that was
23 at the military barracks in Manjaca. Before they handed them over, they
24 killed some of them. Women and minors were first sent to Trnopolje.
25 Some of the inmates were hidden somewhere, taken away on buses and
Page 21397
1 trucks, and then after the journalists left, they were brought to
2 Trnopolje; whereas some persons were taken away in an unknown direction,
3 and to this day their bones are still being discovered in the places
4 where they were killed.
5 For a small number of people they prepared military cots with bed
6 linen, food, and those are the people they showed to the journalists.
7 Now, as far as Trnopolje is concerned, let us try to link all of
8 this up and see why I'm putting it this way. In Trnopolje, people knew
9 for quite a while that the journalists would come to visit the camp, and
10 since Trnopolje was already full, they organised convoys so that the camp
11 could be emptied, at least halfway, so that inmates from Keraterm and
12 Omarska would have room there.
13 The women and children who had arrived from Omarska were
14 released, taken to Prijedor. A fence was put up between the shop for
15 construction material and the other house on the other side, and that is
16 where they put these people. All the women and children practically --
17 the women and children from Trnopolje were practically taken away in a
18 convoy, and that was the first time that they allowed men to leave in
19 that convoy. This is not the convoy that was taken to Vlasic. That was
20 a convoy before that.
21 Q. Dr. Merdzanic, the -- the evidence that you're just giving now
22 about the fence that was put up is -- is dealt with in your Stakic
23 testimony, so we won't go over that again now.
24 So with that clarification that you've just given, if you were
25 asked about the same matters here in court today that were discussed with
Page 21398
1 you in the Stakic -- that you gave evidence about in the Stakic case,
2 would you provide the same information?
3 A. It's the same information except that this convoy for Vlasic was
4 organised when Dr. Karadzic allowed the camp of Trnopolje to be taken
5 over by the International Red Cross. Before they arrived, they organised
6 a big convoy in order to reduce the number of inmates even more. So when
7 the International Red Cross arrived, there were a lot less inmates,
8 whereas those who were sent via Vlasic were taken out of this convoy and
9 killed.
10 Q. And again, Dr. Merdzanic, with that additional clarification, if
11 you were asked about the same matters here in court today as you were --
12 you gave evidence about in the Stakic case, would you provide the same
13 information, that is, even if you couldn't give it word-for-word, the
14 essence of your answers would be the same?
15 A. Yes, the same. However, having said that, this was based on the
16 order from Pale and Dr. Karadzic, namely, to prepare these camps for the
17 arrival of the journalists and for them to be cleansed.
18 Q. Thank you.
19 MS. SUTHERLAND: Your Honour, I tender 65 ter 22174A, which is
20 the English transcript of Dr. Merdzanic's testimony. And I note in the
21 English transcript there's an incorrect spelling of the name Sahuric on
22 transcript pages 7739, 7826, and 7860. It should be spelled
23 S-a-h-u-r-i-c. And there is also a mistake in the transcript at
24 page 7779, lines 21 to 22. There's a reference to Exhibit S15-41 and
25 that should be S15-14, which is already Exhibit P00602 in our case.
Page 21399
1 I also seek to tender 65 ter 22714B, which is a redacted public
2 version of the witness's Stakic testimony, and 65 ter 23496, which is the
3 handwritten correction which the doctor provided at the completion of his
4 Stakic testimony. I would seek to tender those three documents.
5 JUDGE KWON: Just three documents being transcript and redacted
6 version and what?
7 MS. SUTHERLAND: And then this -- this document that
8 Dr. Merdzanic recognised this morning, which was put up on the screen.
9 JUDGE KWON: Oh, yes. Now I understand.
10 Mr. Robinson.
11 MR. ROBINSON: No objection, Mr. President.
12 JUDGE KWON: They will be all admitted.
13 THE REGISTRAR: Your Honours, 65 ter 22174A will be
14 Exhibit P3880, under seal.
15 22174B will be Exhibit P3881. And 65 ter 23496 will be
16 Exhibit P3882.
17 JUDGE KWON: And before going further, Ms. Sutherland, you stated
18 that had what Mr. -- Dr. Merdzanic said this -- today was covered in his
19 Stakic testimony, but my understanding is that it is true that he said
20 that camp, Trnopolje camp was prepared for the arrival from Keraterm, but
21 he didn't say at that time as to the killing at the Keraterm itself.
22 MS. SUTHERLAND: No, Your Honour. I was specifically referring
23 to the fence that is -- that is dealt with in his Stakic testimony.
24 MR. ROBINSON: And, Your Honour, actually we didn't object or
25 interrupt the witness, but would I hope that you could take that in
Page 21400
1 consideration if Dr. Karadzic needs some additional time for his
2 cross-examination.
3 JUDGE KWON: Thank you. We'll see how it will evolve.
4 Yes, Ms. Sutherland. Please continue.
5 MS. SUTHERLAND: And with Your Honours' leave, we'll read a
6 summary of the witness's written evidence.
7 Dr. Idriz Merdzanic, a Bosniak, lived in the Prijedor
8 municipality from 1988 until he was detained at the end of May 1992. In
9 1989, he began working as a physician in the Prijedor Health Centre,
10 which was responsible for health clinics in the municipality. In 1991,
11 the witness was in charge of the Trnopolje outpatient clinic and in
12 mid-1991 was also assigned to the sawmill in Kozarac where he was in
13 charge of treating employees of that company.
14 Dr. Merdzanic testified about the arming of the Serb population
15 and the distribution of weapons by the JNA in early 1992. He testified
16 about the increase in Serb military forces and the establishment of
17 check-points in the area.
18 The witness testified that he heard about negotiations concerning
19 the Kozarac police force which were led by Stojan Zupljanin. The Kozarac
20 police were given an ultimatum to accept the Serb insignia and fly Serb
21 flags in Kozarac by a certain date, otherwise the army would take Kozarac
22 by force if the conditions were not met by the stipulated dead-line.
23 When the ultimatum expired, people were no longer allowed to leave
24 Kozarac.
25 The witness described the attack on Kozarac on the
Page 21401
1 24th of May, 1992. The shelling lasted for two days. During this attack
2 the witness treated people for injuries received from shelling and
3 infantry weapons. The witness contacted the military command that was
4 attacking Kozarac and asked for permission to evacuate two seriously
5 wounded children that were dying. The reply he received was, quote, "Let
6 all of you Balija die there. We will kill you anyway." A number of
7 people died as a result of injuries received during the attack. And this
8 is scheduled incident A 10.1.
9 On the 26th of May, 1992, the witness was taken from Kozarac to
10 the Trnopolje camp, which is scheduled detention facility C 20.4. Along
11 with many of the men, women, and children, he was taken to Trnopolje --
12 he was taken to Trnopolje that day.
13 The witness remained in the camp until 30th of September, 1992.
14 Dr. Merdzanic testified about the inhumane conditions including
15 lack of adequate food or hygiene, beatings, rapes, and several killings,
16 and this is schedule incident B 15.5. He described how he treated
17 detainees for dysentery, body lice, scabies, and hepatitis, all of which
18 are consistent with extremely unsanitary conditions. He testified that
19 he reported incidents of rape to the camp authorities.
20 The witness testified that all around Trnopolje camp there were
21 guard posts with guards. The wire fence was put up at Trnopolje to
22 contain prisoners from Keraterm and Omarska, and after the first visit of
23 journalists, which included Penny Marshall, the fence was taken down.
24 Dr. Merdzanic also described the second visit to Trnopolje camp
25 by Penny Marshall and a visit by the ICRC in August 1992.
Page 21402
1 The witness testified that when the buildings at Trnopolje were
2 filled to capacity and could no longer hold any more people, the first
3 convoy of women, children and elderly men was organised. Continuing the
4 forcible removal of non-Serbs from their homes in the area surrounding
5 Trnopolje led to an increase in the detainee population in the camp.
6 The witness gave evidence about the convoy that left Trnopolje
7 camp and went over Mount Vlasic. Later the witness heard that younger
8 men were taken off the convoy and killed on Mount Vlasic. And this is
9 scheduled incident B 15.6.
10 Prior to leaving the camp on a convoy on the 30th of September,
11 1992, the witness and others had to sign certificates to the effect that
12 they were abandoning all their property to the Serb authorities.
13 That completes the summary of the witness's written evidence.
14 Q. Dr. Merdzanic, I just have a limited number of questions for you.
15 You worked at the Prijedor Health Centre in 1992?
16 A. [Microphone not activated] ... all belonged to Prijedor. I was
17 officially employed in Prijedor but my clinic was in Trnopolje.
18 Q. Was the employment of non-Serbs terminated after the takeover of
19 power by the Serb authorities? And here I'm specifically referring to
20 persons in the hospital who worked in the Prijedor Health Centre.
21 A. Yes. They were first dismissed from the health centre. They
22 were summoned to come to work and the director of the health centre,
23 Dr. Dereta [phoen] lined them up in the corridor at the entrance and told
24 them that from that day on, they are no longer allowed in the building
25 and shouldn't come to work again. The same happened to the Muslim
Page 21403
1 workers at the hospital in Prijedor a day or two later.
2 MS. SUTHERLAND: If I could have 65 ter 18897 on the screen,
3 please.
4 Q. Dr. Merdzanic, this is a list of 114 names, and this is a
5 document that you recently reviewed. It's a list of employees whose
6 employment has expired and it lists a number of -- of doctors and other
7 staff from the general hospital Prijedor and the dates of when their
8 contract was expired. Do you know a number of these persons listed on
9 this list?
10 A. The staff is mixed also with the staff from the hospital and the
11 health centre. I know only a smaller number of them. I was not born in
12 Prijedor. I moved there in 1988, and I was working more in the field. I
13 didn't know personally most of these people.
14 Q. And do you know why the employment was terminated of the people
15 that you do know on this list?
16 A. They were all either Muslim or Croat. At that time, I was
17 already in Kozarac, and as far as I know, the only reason for their
18 termination was that they were Muslims, and most of them did not agree to
19 be mobilised and go to the war zones in Croatia. I'm not aware of any
20 other reason.
21 Q. Did your wife also work at the hospital?
22 A. My wife worked at the health centre, and she was in that group of
23 personnel to whom Dr. Dereta said that they should not come to work any
24 more. They were prohibited from coming to work anymore, and that was
25 without any explanation.
Page 21404
1 Q. And are you able to read out the number of the -- next to the
2 names of the doctors that you -- that you are familiar with on this list?
3 Or doctors and other staff.
4 A. For instance, number 46, Dr. Esad Sadikovic. He was involved in
5 those negotiations, and then when their army occupied Prijedor, he was
6 taken to Omarska and killed. Then Dr. Zeljko Sikora was also taken to
7 Omarska, I think.
8 Q. And if we could go to page 2, please.
9 A. I also heard of Islam Bahonjic, but I'm not sure what became of
10 him. Dr. Emir Keric, I know him as well. Number 91, it says Emir Henim,
11 in fact it's Henic. I know the man. Then Dr. Zoran Vikalo. He's a Serb
12 doctor. And it's interesting, then, when the forced mobilisation was
13 going on, he was hiding and later fled to Croatia to avoid mobilisation.
14 Q. And if we can go to the third page, please.
15 A. Dr. Majda Sadikovic, and I know also Dr. Ibrahim Henic.
16 Q. Do you also know Dr. Begic who worked at the hospital?
17 A. I know him. He was a surgeon, and he worked for a while in the
18 hospital even after the takeover as long as they needed him, but when
19 they no longer needed him, they took him to Omarska and killed him.
20 MS. SUTHERLAND: Your Honour, I tender that document.
21 JUDGE KWON: Yes. That will be admitted.
22 THE REGISTRAR: As Exhibit P3883, Your Honours.
23 MS. SUTHERLAND:
24 Q. Dr. Merdzanic, I have no further questions for you.
25 MS. SUTHERLAND: Your Honour, I seek to tender the associated
Page 21405
1 exhibits, and in relation to the videos, I have the time-codes. I don't
2 know whether you want me to read them out.
3 JUDGE KWON: 65 ter 40424?
4 MS. SUTHERLAND: Yes. That's -- that needs to be tendered as
5 65 ter 40424C. The time-code is 00:31:31 to 00:32:03.
6 JUDGE KWON: Thank you. I have a couple of further questions.
7 MS. SUTHERLAND: Sorry, Your Honour. There's one other video.
8 JUDGE KWON: Yes.
9 MS. SUTHERLAND: 65 ter 40470 is -- needs to be referred to as
10 40424C -- 404, sorry, 70C, and the time-code for that is 00:05:38 to
11 00:06:17.
12 JUDGE KWON: Thank you. With respect to 65 ter numbers, starting
13 from 20535 to 20537, i.e., three documents containing two photos each,
14 from the transcript and the photos itself, it's not clear what these
15 photographs testify to in terms of relevance and probative value. If you
16 could explain that to us.
17 MS. SUTHERLAND: If we could -- if I can actually just quickly
18 deal with them with the witness.
19 JUDGE KWON: Very well.
20 MS. SUTHERLAND: If we could have 65 ter 20535 on the screen,
21 please.
22 Q. Dr. Merdzanic, you were shown this photograph in the -- during
23 your Stakic testimony.
24 A. Correct. We made those photographs with the camera that belonged
25 for -- to Arap Gulasovic [as interpreted] and they were made in Trnopolje
Page 21406
1 at the clinic the first day when we came. The top photograph shows Mujo,
2 the technician. Next to him is a man who was a patient. He just spent
3 there one night. And the photograph below shows me and Dr. Dzonlagic.
4 Q. Is that Hase Dzonlagic on the left and you on the right?
5 A. Hase Dzonlagic is on the left and I am closer up.
6 Q. And in your answer you said that these were photographs with the
7 camera that belonged to -- and the name in the transcript is -- is --
8 were you referring to Azra Blazevic?
9 A. Yes. I already said it belonged to Azra Blazevic.
10 Q. And these photographs were taken early in the days of being at
11 Trnopolje camp; is that right?
12 A. Correct.
13 MS. SUTHERLAND: Your Honour, I tender that document.
14 JUDGE KWON: Let's go through the other document --
15 MS. SUTHERLAND: [Overlapping speakers] If could I have 65 ter
16 20536 on the screen.
17 Q. Do you recognise that -- those photographs?
18 A. They are also from Trnopolje. Below you see Azra Blazevic, and
19 the one at the top is Sefik. I forget his last name, but I did state it
20 in my previous statements.
21 Q. Sefik Karabasic?
22 A. Correct. Sefik Karabasic.
23 Q. And he was also working with you in the medical centre?
24 A. I don't think he worked at the health centre. He only joined to
25 help us during the shelling in Kozarac, and he came with us to Trnopolje
Page 21407
1 from Kozarac. I don't know what his normal occupation is because I
2 didn't know him before.
3 Q. And he was with you in the clinic at Trnopolje?
4 A. Yes. That's a photograph from Trnopolje.
5 Q. And that was where you -- you had to -- you slept in the medical
6 centre?
7 A. We also slept there. We had everything there.
8 MS. SUTHERLAND: If could have 65 ter 20537.
9 Q. Do you recognise that photograph?
10 A. The one at the top shows a nurse, that's also in Trnopolje, and
11 below is Gutic Vasim [as interpreted], a student of medicine, and next to
12 him is Goga, who came with us to Trnopolje, but she was Serb, and the
13 Serbs told her she couldn't stay. She had to go home.
14 Q. And the gentleman that you mentioned that -- that is on the right
15 of the photo, the name again in the transcript, is that Vasif Gutic?
16 A. Vasif Gutic, who was a student of medicine then.
17 Q. And of these three photographs, are they simply putting faces to
18 names that you testify about in your transcript as -- as persons that
19 were with you in the medical centre at Trnopolje camp?
20 A. Yes, of course.
21 MS. SUTHERLAND: Your Honour, I tender those photographs.
22 JUDGE KWON: Thank you. With respect to 65 ter 20743, which is a
23 diagram drawn by the witness depicting Trnopolje camp, I think we need an
24 English translation. Until -- until then, we'll mark it for
25 identification. Then one final matter is related to 65 ter 40469A, which
Page 21408
1 is an excerpt from serial dispatches.
2 MS. SUTHERLAND: Yes, Your Honour. The time-code for that video
3 is 00:09:00 to 00:09:41.
4 JUDGE KWON: But, however, did the witness recognise the place
5 show -- shown in the video? I'm not sure.
6 MS. SUTHERLAND: Your Honour, we can -- we could play that clip
7 very quickly.
8 JUDGE KWON: Yes.
9 MS. SUTHERLAND: It's -- it's 30 seconds long. Or 45 --
10 41 seconds.
11 JUDGE KWON: Probably we need to switch to Sanction. Yes.
12 MS. SUTHERLAND: Yes, Your Honour. Mr. Reid has it ready.
13 JUDGE KWON: Yes. Let us play it again.
14 [Video-clip played]
15 "But not everything is normal. There is evidence of what has
16 happened. Along the main road. These are burnt-out Muslim homes. The
17 cross in a circle is a Serb's way of marking them out for special
18 attention. This is ethnic cleansing with a vengeance, and it was
19 thorough."
20 MS. SUTHERLAND:
21 Q. Dr. Merdzanic, did you recognise the -- the houses in the footage
22 that you just saw?
23 A. I'm not sure, not 100 per cent, but I believe that is a part of
24 Kozarac next to the main road that goes from Prijedor to Banja Luka. But
25 again, I'm not sure because the picture is very dark, and the houses were
Page 21409
1 not so completely destroyed when we were leaving Kozarac, but I believe
2 that's the lower part of Kozarac, closer to the Banja Luka-Prijedor road.
3 [Trial Chamber confers]
4 JUDGE KWON: Very well. We'll admit that, including that, then
5 all the -- with the -- all the clarification and all the associate
6 exhibits will be admitted into evidence and given number in due course.
7 Yes, Mr. Robinson.
8 MR. ROBINSON: Yes, Mr. President. I -- just so that we're on
9 the same wavelength that the Chamber would not be giving any weight to
10 the commentary that was in that video other than the commentary that the
11 witness has given to us.
12 JUDGE KWON: Thank you.
13 Instead of starting the cross-examination now, we'll take the
14 break now, and we'll resume at 20 -- yes, half past 1.00.
15 --- Recess taken at 12.57 p.m.
16 --- On resuming at 1.32 p.m.
17 JUDGE KWON: As indicated by Ms. Sutherland, Dr. Merdzanic, your
18 testimony given in the previous case was admitted in its entirety in lieu
19 of your examination-in-chief. Now you'll be further asked by
20 Mr. Karadzic in his cross-examination.
21 Yes, Mr. Karadzic.
22 THE ACCUSED: [Interpretation] Thank you. Good afternoon,
23 Excellency. Good afternoon to all.
24 Cross-examination by Mr. Karadzic:
25 Q. [Interpretation] Good afternoon, Dr. Merdzanic.
Page 21410
1 A. Good afternoon.
2 Q. Since our time is short, I'll try to put questions that are as
3 clear as possible, especially with regard to matters we can easily agree
4 upon. So most of your answers can be a simple yes or no. Of course, I
5 am not restricting you in any way.
6 In every one of your testimonies, did you take an oath stating
7 that you would say the truth, the whole truth, and nothing but the truth?
8 A. As far as I can remember, yes.
9 Q. When you testify, do you adjust your testimony to the person who
10 stands accused?
11 A. No, but emphasis is laid on the person who is accused, so then
12 perhaps one can emphasise things that are the responsibility of the
13 person who is accused.
14 Q. Who is it that indicates that to you, what you're supposed to
15 emphasise?
16 A. I'm over 18. I'm of age, and I think that I can make my own
17 decisions.
18 Q. Oh, so you do make a selection after all. You do adjust things,
19 don't you?
20 A. As for my view of the situation, that is what I present here.
21 The Judges are here to hear all the parties, collect evidence, and rule.
22 So this is just what comes from my side.
23 Q. Thank you.
24 A. You're welcome.
25 Q. How come you never mentioned that my order was a death sentence
Page 21411
1 for hundreds of people?
2 A. I was not -- I was not asked directly, and it was not your trial.
3 This is the first time that I'm attending your trial, and you decided to
4 have these camps prepared for the arrival of the journalists, and I was
5 there, and I saw how these camps were being prepared for the arrival of
6 the journalists.
7 Q. Thank you. How do you know that I ordered something?
8 A. That's quite simple. It's only logical. In principle --
9 Q. Just a minute. Just a minute. Let us agree that you should say
10 only what you know, not what is logical. Do you know? Did you see my
11 order --
12 JUDGE KWON: Mr. Karadzic, you asked how he did know that you
13 ordered something. Then you should hear him out. Don't interrupt the
14 witness, please.
15 Dr. Merdzanic, could you repeat your answer or start it again,
16 please.
17 THE WITNESS: [Interpretation] In my view, that is quite logical.
18 Dr. Karadzic promised journalists that he would let them visit the camps.
19 The journalists came to the camps through Karadzic in Pale. Those who
20 held the camps had no idea about that. The only way they could find out
21 that journalists were coming was if Karadzic sent them that information
22 from Pale. Nobody else could give that kind of information.
23 I said what he had ordered. I'm not going into whether he had
24 issued precise orders to have these persons killed or not. I'm just
25 saying that that decision meant a death sentence for the camp inmates.
Page 21412
1 MR. KARADZIC: [Interpretation]
2 Q. Thank you. Did you see any order of mine? Let me put it that
3 way then. Did you see any order of mine in that respect?
4 A. No, I did not see any order of yours, but I'm intelligent enough
5 to be able to reach certain conclusions. I know how much 2 plus 2 is.
6 Q. Thank you. With all due respect, Doctor, you know that in
7 medicine also people have to reach conclusions on the basis of facts. So
8 I kindly ask you to give answers about what you know.
9 A. I have just given you an answer based on facts.
10 Q. Why did you not say earlier on that hundreds of people had been
11 killed?
12 A. People knew earlier on as well that in Keraterm an entire hangar
13 had been killed and that people were killed in Vlasic. That was
14 discussed sufficiently, most definitely.
15 JUDGE KWON: Before both of you continue. Dr. Merdzanic, since
16 you're speaking the same language and both of which are to be
17 interpreted, if you could pay attention sufficiently to put a pause
18 between you start answering the question. I appreciate your kindness.
19 Yes. Please continue, Mr. Karadzic.
20 THE WITNESS: [Interpretation] I apologise.
21 MR. KARADZIC: [Interpretation]
22 Q. So you were not in Keraterm, and you did not see these killings;
23 right?
24 A. I was not, but after being in camp, I talked to Enes Crljenkovic
25 who survived all of that.
Page 21413
1 Q. Thank you. Today on page 9 you said that on the basis of my
2 order or information to the effect that journalists would come and the
3 International Red Cross, a convoy went to Vlasic and these people were
4 killed there; right?
5 A. That's right.
6 Q. You said, on page 9, that that was done in order to reduce the
7 number before the Red Cross arrives; right?
8 A. Before the International Red Cross arrive.
9 Q. Thank you. Is it correct that the International Red Cross
10 arrived on the 15th of August?
11 A. As far as I know, yes.
12 Q. And is it correct that the killings were committed on the
13 21st of August?
14 A. I cannot say now. I don't have this information when this
15 happened exactly. This convoy left before the inmates were registered by
16 the International Red Cross. The International Red Cross had not arrived
17 yet, had not registered these inmates yet, those who were taken to Vlasic
18 and killed there.
19 Q. I'm just asking you whether these dates are correct: The
20 15th of August, the Red Cross visited, and the 21st of August, the crime
21 at Koricanske Stijene was committed. Is that right yes or no?
22 A. I don't know when the crime was committed at Koricanske Stijene.
23 I just know that the International Red Cross had not registered these
24 people yet. They appeared on the 15th, but this convoy had left before
25 the International Red Cross arrived and managed to register these people.
Page 21414
1 Q. Thank you. Today the distinguished Madam Sutherland interpreted
2 your positions on page 12 that the ultimatum to Kozarac was issued
3 because of the flag and the insignia on police caps; right?
4 A. I did not attend these meetings. Now, whether that is the way it
5 was exactly -- well, at any rate, the policemen in Kozarac opposed that.
6 They did not want to recognise the Serb authorities, and they did not
7 allow the Serb police to take over Kozarac, where the population was
8 Muslim.
9 Q. Are you saying that the conflict in Kozarac broke out because of
10 the flag and insignia?
11 A. Well, in principle, the conflict did not break out on account of
12 that. The conflict broke out because the Serbs wanted to take Kozarac.
13 Q. Did they want to take Kozarac because of the flag and insignia or
14 because of something else?
15 A. No, it was of great strategic importance for them to create a
16 great ethnically pure Serbia. That was the real reason. The insignia
17 were probably just a pretext or an excuse for the Serbs.
18 Q. Do you know that Mr. Zupljanin wrote that Kotor Varos and
19 Prijedor do not have to use these insignia?
20 A. I don't know that, but I know that they attacked Kozarac and got
21 the tanks out.
22 Q. On page 14 - and could we please call this up now, P3883 - you
23 spoke about the list of persons whose employment had terminated. Do you
24 know that termination of employment is one thing and dismissal is
25 another?
Page 21415
1 A. These persons were forbidden from coming to work any longer.
2 Q. Who can confirm what you're saying just now?
3 A. My wife can. She was there personally, and those were the orders
4 issued to her. And all of these people from the list, if they are still
5 alive, can confirm that too.
6 Q. When was your wife told that it would not be a good idea for her
7 to come to work for a while? Wasn't that the way it had been put?
8 A. No, that's not true. They were forbidden from coming back to
9 work ever again. They were not eligible to work any longer.
10 Q. Thank you. Is she on this list?
11 A. No, she's not on this list.
12 Q. Are you on this list?
13 A. No, I am not on this list.
14 Q. So she was told after the attack on Prijedor on the 30th not to
15 come to work for a while; right?
16 A. I don't know exactly. I'd have to ask my wife what date that
17 was.
18 Q. On the other hand, can we say, then, that up until the
19 25th of May, that is the latest date here, I think, the 25th of May, that
20 up until the 25th of May, both you and your wife had continued to work?
21 A. I never received anything officially. I was in camp. No one
22 came to tell me that I was no longer employed.
23 Q. Thank you. You said that these were Muslims and Croats. Can you
24 read the name under number 11.
25 A. Jelena Topic. I said that I did know one Serb. I just mentioned
Page 21416
1 the persons I knew, and among them is Zoran Vikalo, who I know. We were
2 at university together. He's a Serb. He did not want to respond to the
3 call-up, mobilisation. He fled to Croatia.
4 Q. Thank you. Is Jelena Topic a Muslim?
5 A. No.
6 Q. Can you look at number 19?
7 A. Yes.
8 Q. Please read it for us?
9 A. Yes. Yes. Dr. Risto Stojanovski.
10 Q. Is he a Muslim?
11 A. No, he's probably a Macedonian, Stojanovski.
12 Q. Number 20, please?
13 A. Dr. Mario Karacic. That is probably a Croat.
14 Q. How about 22?
15 A. Josipa Grozdanic.
16 Q. Is she a Muslim?
17 A. No, she's not, but I just mentioned the people I knew. I don't
18 know what you're getting at.
19 Q. You said that this was a list of persons who were dismissed on
20 ethnic grounds; right?
21 A. I said that most of them were dismissed on ethnic grounds or had
22 not responded to mobilisation or had not wanted to do what the Serbs had
23 ordered them to do.
24 Q. Can you read number 25, and can you tell us whether that lady is
25 a Muslim?
Page 21417
1 A. Jozica Djakovic. She is not a Muslim.
2 Q. Can you read 38?
3 A. Slavica Nukic. She's not a Muslim either.
4 Q. Thank you. Can you read number 50?
5 A. Of course. Dusanka Vuketic. She's not a Muslim.
6 Q. She's a Serb, isn't she?
7 A. To tell you the truth, I don't know.
8 Q. Oh, you do know full well that Dusanka is a Serb name.
9 A. Well, how can I tell?
10 THE ACCUSED: [Interpretation] Can we have the next page.
11 MR. KARADZIC: [Interpretation]
12 Q. Can you read number 60?
13 A. Marinko Romanic.
14 Q. He's not a Muslim; right?
15 A. No, he's not.
16 Q. Number 70?
17 A. Jasna Jakovljevic.
18 Q. Is she Muslim?
19 A. Jasna can be a Muslim name and a Serb name. I really don't know.
20 Q. What about Jakovljevic, her last name?
21 A. I have no idea.
22 Q. Are there any Muslims who have the last name Jakovljevic?
23 A. How can I tell? I'm no expert for Muslims.
24 Q. Doctor, Jakovljevic is based on the name Jakov, which is Jacob,
25 Saint Jacob.
Page 21418
1 A. Well, how can I say?
2 Q. 85?
3 A. Emilija Jordan.
4 Q. Is she a Muslim?
5 A. Maybe. I have no idea.
6 Q. Emilija, a Muslim?
7 A. Why not? Why not? I mean, I don't know.
8 Q. Doctor, Doctor, let us be serious. 90?
9 A. Vid Djakovic, that's not a Muslim.
10 Q. 98? Thank you.
11 A. Dr. Zoran Vikalo. I mentioned him already. He's a Serb who fled
12 to Croatia.
13 Q. What about 103?
14 A. Ana Juric. That is not a Muslim name.
15 Q. What about 106?
16 A. Danica Bijekic, that's not a Muslim name.
17 Q. 107?
18 A. Dr. Vojislav Milosev, that's not a Muslim name either.
19 THE ACCUSED: [Interpretation] Can we have the next page, please.
20 MR. KARADZIC: [Interpretation]
21 Q. And 111?
22 A. Dubravka Zec. I think that's a Croat name.
23 Q. How do you come up with that? A Croat with the last name of Zec?
24 What are you saying?
25 A. I don't know. I had a lady who was my friend who was a Croat.
Page 21419
1 Her last name was Zec. How can I tell?
2 Q. Dr. Merdzanic, do you remember that a dismissal is one thing? It
3 has to be accompanied by reasoning, whereas a termination of employment
4 is something else, and the main reason for that is failure to appear for
5 work for five days?
6 A. I studied medicine, not law.
7 Q. Thank you. On page 16 you said that a certain doctor was taken
8 to Omarska and killed.
9 A. Yes. There were many who were taken to Omarska and killed.
10 Q. How do you know that?
11 A. That's quite simple. When I got out of the camp, I talked to
12 people. There were some people who came from Omarska, and finally all
13 the bodies have been identified. It is known that those people were
14 taken to Omarska. Their bodies were later found, and they were killed.
15 If you want me to, I can give you some names. You can check.
16 Q. I'm not interested. You know that from the words of others?
17 A. Yes. I was not there when these people were killed nor would
18 have the Serbs allowed anyone watch them kill.
19 Q. You went on to say that you worked at the medical centre in
20 Prijedor, and you worked at Trnopolje, and it's referred to here as a
21 clinic, but it was not a clinic, was it?
22 A. It was a small village clinic or an infirmary. I was in charge
23 of that infirmary, and at the sawmill in Kozarac I also worked as a
24 substitute doctor.
25 Q. But your permanent job was at the outpatient clinic in Trnopolje,
Page 21420
1 at this little infirmary.
2 A. Correct.
3 Q. You mentioned that some Muslims and Croats were hiding from
4 mobilisation drives. What about the mobilisation in June 1991 or
5 September 1991? Which one were you referring to?
6 A. It was after the war in Croatia had already started, and
7 especially after the Serbs with their army took over Prijedor.
8 Q. We'll come to Prijedor. Now you're talking about JNA
9 mobilisations linked to the war in Croatia.
10 A. Correct.
11 Q. From which mobilisation were they hiding?
12 A. I don't understand. What do you mean which one? There was only
13 one army, and their military police were -- was looking for people to
14 mobilise them by force and send them to the war in Croatia. When exactly
15 that was going on I can't say.
16 Q. In your Brdjanin testimony, 1D04458, page 7 -- sorry, line. The
17 page is 1792, lines 7 to 25, you said that many Muslims were hiding so
18 that the army could not find them and send them to the front lines. You
19 say they were hiding. I want to know which mobilisation drive they were
20 hiding from and for how long.
21 A. I'm not aware that there are two types of mobilisation. Whether
22 it was in September or perhaps in early 1991, I don't know. They were
23 hiding until the conflict in Prijedor broke out. And it was not only the
24 Muslims and Croats who were hiding. There were some Serbs hiding as
25 well. Radenko Djindjic was hiding in a Muslim house.
Page 21421
1 Q. So from June or September onwards, they were hiding from the
2 military police; right?
3 A. I couldn't give you the date.
4 Q. For how long were they in hiding and where?
5 A. I couldn't tell you. I know that people had a rucksack or a --
6 ready and packed so that if the military police came they could run to
7 their neighbour's house.
8 Q. What about their jobs at the time? Did they go to work? Could
9 the military police have found them at work?
10 A. Most of them did continue to go to work. Some didn't, perhaps.
11 I know that, later on, all the policemen who did not sign the loyalty
12 statement to the Serbs were dismissed.
13 Q. Is mobilising conscripts or reservists a criminal act?
14 A. You should ask a lawyer.
15 Q. Thank you. Do you know of anyone who was arrested and sent to
16 the front line in Croatia?
17 A. Dr. Emir Ceric, caught at his own home, given a uniform and sent
18 to the war.
19 Q. When was that?
20 A. I don't know. You should ask him. Fahrudin Bahtijarevic, sent
21 to dig trenches. You can ask him. He's still alive.
22 Q. Did the war in Croatia end in late 1991?
23 A. I have no clue.
24 Q. Were you a member of the SDA or some other party?
25 A. No, I was not.
Page 21422
1 Q. Did you take part in negotiations at any level or were you
2 regularly kept informed about negotiations between different sides in
3 Bosnia?
4 A. I know only what I heard from others.
5 Q. 1D04459, page 7820, you said that you don't know if anyone was
6 sent to the front line by force, and you cannot provide any names, and
7 now you have given names.
8 A. I couldn't remember the names at that time, and then when I
9 returned home, I gave it some more thought, and I made inquiries. I
10 cannot memorise all the names.
11 Q. So you are testifying now after making inquiries following
12 previous testimonies so that you can give those names today.
13 A. That's not true. It's 19 years after the fact today, so it's
14 natural I have to refresh my memory.
15 Q. Do you rely on your own memory? Can you rely on your memory?
16 A. Exact dates are easily forgotten, and names too, but things that
17 really happened remain.
18 Q. You mention roadblocks, and now you corrected yourself saying
19 that there were roadblocks. And you said also that Muslims also held
20 some check-points of their own.
21 A. I said I had seen a check-point at the entrance to Kozarac, but I
22 have to add that in my view, there is a difference between a person who
23 sets up a roadblock in front of their own house to defend their own home
24 and their children and the wife from being raped and someone who sets up
25 a check-point with the intention of killing people.
Page 21423
1 Q. Was the check-point near Kozarac, on the road between Prijedor
2 and Banja Luka, 12 kilometres away from Prijedor?
3 A. If you mean the one held by Muslims, was looking from that road
4 at the entrance to Kozarac, not on the road from Prijedor to Banja Luka
5 but when you approach Kozarac at a distance of about 50 to 100 metres,
6 and on the intersection itself, a Serb tank was standing.
7 Q. Outside Hambarine was the check-point Muslim or Serb?
8 A. I wouldn't be able to tell you. I wasn't there.
9 Q. In the Stakic case, you spoke about that on page 11798. You were
10 asked whether there were any check-points at other places near that road
11 near Kozarusa. You said you didn't know, but you heard that when the
12 Serbs took Prijedor, check-points were set up in Muslim settlements
13 because that was a sign that Serbs were going to take Muslim settlements
14 by force.
15 A. I don't remember that. Can you show me?
16 Q. The page is 11798.
17 JUDGE KWON: Yes, Ms. Sutherland.
18 MS. SUTHERLAND: Your Honour, this is the Brdjanin testimony.
19 And just for Mr. Karadzic's benefit, if the transcript starts 77 or 78,
20 then it's the Stakic testimony. If it starts 117, then it's the Brdjanin
21 testimony.
22 JUDGE KWON: Thank you. We're going to upload it now. Do we
23 have that --
24 THE ACCUSED: [Interpretation] I have 1D04458. 1D04458.
25 JUDGE KWON: No. This is Stakic transcript.
Page 21424
1 THE WITNESS: [Interpretation] Can I see the translation in our
2 language?
3 JUDGE KWON: No. Unfortunately, we do not have the translation
4 of the transcript.
5 THE ACCUSED: [Interpretation] I will read it and the interpreters
6 were interpret.
7 JUDGE KWON: But what is the 65 ter number first? Yes, we have
8 it. Page 11789.
9 THE ACCUSED: [Interpretation] 11798.
10 MR. KARADZIC: [Interpretation]
11 Q. Beginning with line 9:
12 "[In English] Whether -- like I was asked whether there were any
13 check-points at other places, outside of this road, perhaps at Kozarusa,
14 I don't know. But I did hear that when the Serb army took over Prijedor
15 and when they were indicating they were going to take the Muslim
16 settlements by force, then non-Serbs, Muslims and Croats, organised
17 themself [sic] -- themselves and put up guards in order to defend
18 themselves, in order to prevent the Serbs from entering the villages
19 suddenly and committing a massacre."
20 [Interpretation] Did you say this?
21 A. That's possible. That's just what I said about Kozarac a moment
22 ago, that people were defending their families and their houses, not
23 organising themselves to attack Serbs or anyone else and kill them.
24 Q. That's what you heard; right?
25 A. That's what I heard.
Page 21425
1 Q. Could we agree to make a distinction between what you heard and
2 what you knew for sure or saw yourself?
3 A. I can tell you what I saw. Before I went to Kozarac, two days
4 before I left I was living in Old Town, and in the evenings, at night,
5 people stood guard without any weapons, fearing that Serbs may come and
6 kill people.
7 Q. You lived in the Old Town and worked in Trnopolje; correct?
8 A. Yes.
9 Q. Do you know why the army took control over Prijedor on the
10 30th of April?
11 A. That's simple. Just before that, at a session of the parliament,
12 you yourself said that Muslims would disappear from that area, and they
13 have no chance of defending themselves, and, generally speaking, it was a
14 plan to carry out ethnic cleansing and organise a Greater Serbia. And
15 then when it was voted in Bosnia and Herzegovina that Bosnia should be
16 independent and sovereign, whereas you lost at the elections in Prijedor
17 because, as far as I know, the SDA won the elections, you decided to take
18 over by force, and you did it using the army.
19 Q. Are you speaking of my speech of the 15th of October, when I
20 asked that we should refrain from going for independence unless it was
21 agreed?
22 A. I know of only one speech where you said that Muslims had nothing
23 to defend themselves with. They will fail to defend themselves and they
24 would disappear from that area.
25 Q. Thank you. Did I try to talk Muslims into war or not to go to
Page 21426
1 war?
2 A. You were the leader of your party, and I know that in reality,
3 Chetnik units were restored and re-established.
4 Q. What about the speech? In that speech, was I trying to tell
5 Muslims that we shouldn't go to war or that we were going to war?
6 A. No. You were telling them what awaits them.
7 Q. Now, you mentioned Chetnik units. Did I set up Chetnik units?
8 A. You should know better than anyone else. You come from a family
9 that was a Chetnik family during the Second World War, and you know that
10 in that war Chetniks also wanted a Greater Serbia, and back then there
11 were also killing both Serbs and Croats without any ammunition,
12 preferably by knife.
13 Q. My father was in Montenegro where it was not between Serbs and
14 Croats. It was fighting for the king. Why are you bringing my father
15 into this?
16 A. I'm just saying that you know these things better than I do.
17 Q. But you said a moment ago that we set up Chetnik units. Did I
18 set them up?
19 A. You know that better than I. How would I know? It was organised
20 through the SDA. To what extent you were involved, I don't know.
21 Q. Well, you were speaking a moment ago as if you knew about these
22 things, but never mind. Do you know that on the 29th, a dispatcher
23 arrived to Prijedor ordering an attack from the ministry and from the
24 army?
25 A. I don't know.
Page 21427
1 THE ACCUSED: [Interpretation] I see Madam Sutherland.
2 JUDGE KWON: Yes.
3 MS. SUTHERLAND: Your Honour, I'm sorry. Mr. Karadzic might like
4 to clarify the answer at -- on page 37, line 24, when the interpretation
5 came through that it was the SDA.
6 JUDGE KWON: I take it you meant SDS, it was organised through
7 the SDS. Is it correct, Dr. Merdzanic?
8 THE WITNESS: [Interpretation] That's correct, the SDS.
9 JUDGE KWON: Thank you, Ms. Sutherland.
10 Yes, Mr. Karadzic.
11 MR. KARADZIC: [Interpretation].
12 Q. Do you know that the reason -- actually, yes. At that moment it
13 was the JNA. Do you know why the JNA took over control over the city,
14 the telegram ordering attack against the JNA, the city, the Serbs?
15 A. I don't know about that.
16 Q. Are you denying that the crisis in Hambarine broke out because of
17 the fact that two Serbs were killed and two Croats and two Serbs were
18 wounded? They were reservists, and it was at a check-point near
19 Hambarine?
20 A. I don't know exactly what happened there.
21 Q. Thank you. Do you know that because of shooting at check-points
22 in Kozarac an ultimatum was issued to hand over weapons, not to place
23 badges?
24 A. I did not attend the negotiations. I knew that the Serbs wanted
25 to take over Kozarac using their own police badges. That was an
Page 21428
1 insignificant matter. They needed some kind of excuse.
2 Q. Thank you. Do you know that a curfew was imposed after these
3 killings so that the situation would calm down and that things in general
4 would calm down?
5 A. That is not true. A curfew was imposed when the army took over
6 Prijedor.
7 Q. Thank you. You knew Sead Cirkin; right?
8 A. I heard of him, and I saw him once.
9 Q. So on the 21st or 22nd of May, you went to Kozarac, and you
10 stayed there. You did not return to Trnopolje; right?
11 A. That's right.
12 Q. Then you placed yourself at the disposal of the persons who were
13 preparing to fight; right?
14 A. That is not right. I just organised the infirmary. In case
15 somebody is wounded, we should be able to help. That had nothing to do
16 with anything else.
17 Q. You see, in the Brdjanin case, you said -- actually, you confirm
18 that Cirkin was an active-duty officer and that you went to see him and
19 that you saw a group of young men who were carrying weapons; right?
20 A. Yes, that is correct. That's right.
21 Q. And then you said that since there was this ultimatum to hand
22 over weapons that was running out on the 22nd of May, would you agree
23 that it was not then but a day or two later?
24 A. I know that the attack started on the 24th. I heard that it was
25 the 22nd, that that was the date. Now, I don't know whether that's
Page 21429
1 correct.
2 Q. Thank you. Do you know --
3 JUDGE KWON: Yes, Ms. Sutherland.
4 MS. SUTHERLAND: Your Honour, I note that -- that this evidence
5 is also contained in the Stakic case, and I recall Your Honour asking
6 with the previous witness whether information that Mr. Karadzic keeps
7 putting to him from prior transcripts other than the transcript that's in
8 evidence, whether it's also contained in -- in what is now evidence in
9 this case. And I also noted in relation to the mobilisation issue with
10 Muslims and Croats going into hiding where he put the Brdjanin
11 transcript, that's also included in the Stakic transcript, so I don't
12 know whether Your Honour wants to give Mr. Karadzic some guidance in
13 relation to that.
14 JUDGE KWON: Thank you, Ms. Sutherland.
15 I would very much prefer to concentrate on the transcript that
16 has been admitted into evidence in this case, but it's for you,
17 Mr. Karadzic, but bear that in mind.
18 THE ACCUSED: [Interpretation] Thank you, Excellency, but when I
19 come across contradictions, then I have to refer to his previous
20 statements and testimony. I believe that you would agree.
21 JUDGE KWON: I don't think there's any contradiction between the
22 two transcripts, according to the statement by Ms. Sutherland.
23 MS. SUTHERLAND: Yes. And, of course, I would agree. Of course,
24 Mr. Karadzic can take the witness to any alleged inconsistencies between
25 the two transcripts, but in -- in this regard, in relation to
Page 21430
1 Sead Cirkin, transcript page 7723, it says: "He was an active military
2 officer, and I wanted to talk to him," blah, blah, blah. So it's not
3 inconsistent in my view, but I've said what I've said.
4 JUDGE KWON: Thank you. Please continue. And, Mr. Karadzic,
5 yourself as well, please put a pause between the answer and your new
6 question. Yes, Mr. Karadzic.
7 MR. KARADZIC: [Interpretation]
8 Q. So did you say that the ultimatum had to do with -- I mean, I'll
9 tell you, this is your statement to the OTP, 2000, 1D4457, page 010352.
10 The ultimatum had to do with hoisting the flag and having insignia on
11 uniforms. That ultimatum was issued by Zupljanin to Kozarac.
12 A. It's quite possible that I said that, but in principle, no, the
13 policemen in Kozarac were supposed to sign an oath of allegiance to the
14 Serbs, and Kozarac was supposed to be taken over. That was the
15 precondition.
16 Q. And the hand-over of weapons and the cease-fire was not a
17 precondition? The people of Kozarac were not supposed to do that?
18 A. As far as I know, the people of Kozarac did not attack anyone.
19 They were just at their homes ready to defend themselves. They did not
20 leave Kozarac. They did not go out to attack the Serbs. It's the Serbs
21 who came to Kozarac to attack the people of Kozarac.
22 Q. What you're saying is on page 7722 in the Stakic case as well.
23 Your amalgamated statement, 7722, from the Stakic case. Yes, 22174, that
24 is the amalgamated statement. On page 7722 you also say that this is an
25 ultimatum that has do with the flag and insignia. Then you say in
Page 21431
1 response to the question put to you in view of negotiations, you said
2 that you thought that they were not successful, and you say: "I heard
3 that Zupljanin did not come to the negotiations," and so on. And in
4 response to the question, "Who did you hear this from?" You said, "I
5 heard this from patients and personnel people who worked there," and so
6 on and so forth. And then they asked you whether you ever heard on radio
7 or television that there was this ultimatum and you say that you had
8 never heard of that. Is that right?
9 A. That is right.
10 Q. That is to say that you don't know about these negotiations and
11 the essence of the ultimatum. You don't know anything about that?
12 A. I never claimed to have been present during these negotiations.
13 I always asserted that I heard all of this, and I can repeat that. It
14 was stated that Stojan Zupljanin had come and had given -- and gave an
15 ultimatum, and Serbs presented an ultimatum to Kozarac and the police.
16 It wasn't the other way around. It was the Serbs who said that they
17 would attack Kozarac if they did not surrender. It's not the other way
18 around as you've been trying to say all along.
19 Q. On radio and television, did you hear what was actually said,
20 what the ultimatum had to do with?
21 A. You want me to talk about radio and television here now. When
22 the war started in Bosnia, the first thing that the Serbs did was take
23 over radio and TV relay towers so that they could carry out their own
24 propaganda. Radio Prijedor also carried their propaganda. For example,
25 they accused Sikora Mahmuljin --
Page 21432
1 Q. Just a minute --
2 A. You wait. Let me explain this to you. When they accused them
3 over the radio that they had mistreated Serb patients, they arrested them
4 and took them to Omarska and killed them. On the radio there was this
5 propaganda that the Serbs did not want to have a war. They just wanted
6 to protect all Serbs and Muslims, and at the same time, they went to
7 people's houses, they searched them, and they beat Muslims.
8 Q. Thank you. Not to go into all of this now. You gathered
9 equipment and medicine and IV liquids and so on before the conflict in
10 Kozarac; right?
11 A. It's not the way you put it. There was a pharmacy in Kozarac
12 that had medicine there anyway, prescription medicines. A day before
13 that we went to this pharmacy, and we got medicines from that list, and
14 we took these medicines to the infirmary in Kozarac so that we could have
15 them if we needed them.
16 Q. Who thought of that? Were you the person who thought of that, or
17 did somebody order you to do that?
18 A. Nobody ordered me to do that. I cannot remember now whether I
19 was the one who thought of that. There were about ten of us there who
20 were discussing this, what to do, how to organise ourselves, because
21 obviously there was an ultimatum there. The police from Kozarac did not
22 want to surrender, and before that, an ultimatum had been issued to
23 Hambarine, and they had torched Hambarine and razed it to the ground.
24 Then we decided since in the infirmary itself, in Kozarac that is, there
25 wasn't enough medicine, then we remembered that pharmacy, and we brought
Page 21433
1 whatever was there.
2 Q. Thank you. In your statement to the OTP of 2000, on the 27th and
3 28th of August, in e-court that is 1D04457, on page 01035292, you say,
4 and I'm going to read this out in English -- yes, actually, I can --
5 JUDGE KWON: We will bring it up. 1D4457. We have them in both
6 languages, I take it.
7 THE ACCUSED: [Interpretation] I have page 01035292. That's
8 probably English. It must be page 3 in e-court, page 3.
9 MR. KARADZIC: [Interpretation]
10 Q. Can you see this, where it says --
11 THE ACCUSED: [Interpretation] Actually, now we have both pages in
12 Serbian.
13 MR. KARADZIC: [Interpretation]
14 Q. Can you find that bit here where you say that you are the staff
15 of this infirmary in Kozarac, that you went to the pharmacy, that you
16 personally went there, that you took this medical equipment as you were
17 expecting an attack, and that you got IV fluids and so on and so forth?
18 Did you do that as a physician who was someone who had passed a test in
19 war surgery?
20 A. I did not pass any such test. I had just received a degree in
21 medicine, and I had not specialised in anything.
22 Q. However, we all took this exam in war surgery, didn't we? Within
23 the subject called surgery there is wartime surgery, isn't there?
24 A. I can't remember any longer. I remember passing that exam called
25 surgery, but I do not remember war surgery, and it had nothing to do with
Page 21434
1 the wounds that we were dealing with.
2 Q. In English it's the last paragraph.
3 "[In English] On 23rd of May, 1992, the employees of the clinic,
4 including myself, went to the pharmacy in Kozarac and loaded up on
5 medical supplies, anticipating the attack on Kozarac."
6 [Interpretation] So, Dr. Merdzanic, you did not return to
7 Trnopolje. You stayed in Kozarac. You placed yourself at Cirkin's
8 disposal, and you became his military medical man.
9 A. That is not correct. That is a pure lie.
10 Q. Why did you not go back to work?
11 A. For a simple reason. One reason is the following: After the
12 ultimatum, the Serbs no longer allowed anyone to leave Kozarac. Then
13 there was another reason. Somebody was supposed to help these poor
14 people and treat them medically if necessary.
15 Q. Thank you.
16 THE ACCUSED: [Interpretation] Can this page be admitted?
17 THE WITNESS: [Interpretation] But that has nothing to do with
18 Cirkin or any other military organisation.
19 MR. KARADZIC: [Interpretation]
20 Q. However, you had prepared all these medical supplies for the
21 attack that was about to take place.
22 A. That's not true. These medical supplies were in the pharmacy
23 before the war just like in any other civilian pharmacy. That is not
24 correct. You are just trying to plant something on me. Try to be a bit
25 fair.
Page 21435
1 Q. Thank you. Did you state all of this that is contained in this
2 last paragraph that starts with the words: "On the 23rd of May, 1992,
3 the employees the clinic, including myself," et cetera, et cetera,
4 "anticipating the attack on Kozarac."
5 A. Yes. But not in the context that you have been trying to --
6 Q. Thank you.
7 THE ACCUSED: [Interpretation] Can this page be admitted?
8 JUDGE KWON: Ms. Sutherland.
9 MS. SUTHERLAND: Your Honour, at transcript page 7724, the
10 witness says:
11 "Kozarac was cut off. There was no one to obtain extra supplies
12 from. The only thing we had was a pharmacy in Kozarac itself, so we took
13 the supplies from the pharmacy and brought all the supplies from the
14 pharmacy to the outpatient clinic."
15 JUDGE KWON: Thank you. But I take it that's the part you can
16 raise in your re-examination. We will admit these two pages, English
17 page 3 and 4. I don't know the pages in the B/C/S, but the corresponding
18 page -- pages will be admitted. Shall we give the number.
19 THE REGISTRAR: Yes, Your Honour. Exhibit D1922.
20 MR. KARADZIC: [Interpretation]
21 Q. Please take a look at what you said here:
22 "[In English] On one occasion, I went to see Sead Cirkin a few
23 days before the attack, probably about the 20th of May or so. I wanted
24 to talk to him about Cirkin's plan for the GP surgery in the event of
25 attack. He told me that: I will do my job, you do yours. He did not
Page 21436
1 have much time for me. He encouraged me to take care of my surgery
2 myself."
3 [Interpretation] This is midway in the penultimate paragraph in
4 English.
5 A. That just confirms my version, namely, that I had no direct
6 connection to Cirkin. As a civilian doctor, I just tried to help
7 civilians in Kozarac as much as I could.
8 Q. However, you did report to the commander, didn't you?
9 A. I wanted to see whether he had a plan of any kind. That just
10 confirms that there was no co-ordination between the two of us.
11 Q. However, you say in 1D4461, page 119 -- sorry, 795, that you only
12 heard of Cirkin, whereas in this statement you say clearly that you made
13 contact with him and talked about his plans. This GP is probably general
14 practice surgery.
15 Where were you telling the truth, when you said you only heard
16 about him or when you said you made contact with him, saw him, and asked
17 him about a plan?
18 A. It is indeed written somewhere. I saw Cirkin. I went to see him
19 to ask him if there was a plan of any kind, but I went to see him as a
20 simple civilian without any other intentions that are trying to ascribe
21 to me here.
22 JUDGE KWON: Yes. Just a second. Yes. Is there a mistake in
23 terms of number?
24 MS. SUTHERLAND: Your Honour, I was going say Mr. Karadzic is
25 mischaracterising the witness's evidence. That is not what is contained
Page 21437
1 on transcript page 7723.
2 JUDGE KWON: 7 --
3 MS. SUTHERLAND: 7723, lines --
4 JUDGE KWON: But he referred to something else, page -- 1D4469,
5 page 11795. Shall we upload it?
6 MS. SUTHERLAND: He said you're making --
7 THE ACCUSED: [Interpretation] [Microphone not activated] ... I
8 just read is at the bottom of this page, 1D04461. It says: Do you know
9 who Sead Cirkin is? Look at line 20 onwards.
10 JUDGE KWON: But he's --
11 MS. SUTHERLAND: Your Honour, he's putting to the witness that he
12 didn't meet with Sead Cirkin. It's clear in both the statement and the
13 Stakic transcript that he did meet with him.
14 JUDGE KWON: Yes, Stakic, but in the transcript which was
15 admitted into evidence in this trial, if he said he met with Cirkin,
16 there's no point of putting that on another transcript, but let us -- let
17 us see what he said in 11446 on -- I've lost the number. 11461. Yes.
18 It says -- why don't you read it so that the witness can answer the
19 question. I see the last paragraph.
20 MR. KARADZIC:
21 Q. "Q. Do you know Sead Cirkin?
22 "A. I've heard about Sead Cirkin. He's an active military. As
23 far as I know, earlier, when the Serbs took Prijedor militarily, he tried
24 to organise a defence of Kozarac in Kozarac. I do not know where he got
25 it but he managed to put together some weapons and some guys who tried to
Page 21438
1 organise Kozarac defence."
2 [Interpretation] So you knew that he was the commander of the
3 Kozarac defence.
4 A. I only said I knew of him and heard of him. Whether there was
5 anyone else, I'm not sure, but as far as I know, he was the only one.
6 Q. But you say here that you've heard about him, not that you knew
7 him and met him.
8 A. You can twist my words as much as you like and we can debate it
9 as long as you want, but I'm telling you loud and clear that I went to
10 see him. I saw him for five minutes and then I returned and had nothing
11 more to do with him.
12 THE ACCUSED: [Interpretation] Can this page be admitted?
13 JUDGE KWON: Did he say here that he did not meet Mr. Cirkin?
14 But in any event, we will admit this page.
15 THE REGISTRAR: Exhibit D1923, Your Honours.
16 MR. KARADZIC: [Interpretation]
17 Q. Dr. Merdzanic, you say that -- how long did the fighting for
18 Kozarac last?
19 A. From the 24th to the 26th.
20 Q. And do you know what kind of losses the Serb side took?
21 A. How could I know? I suppose there were no great losses, because
22 first they used tanks and artillery to shell Kozarac. The Muslims had
23 nothing to open fire from against that. They only had regular infantry
24 weapons. And then when Serbs moved with their infantry, I don't know. I
25 was not at the front line. I was in my infirmary.
Page 21439
1 Q. In Stakic page 7732, that 65 ter that's been admitted, you said
2 you believed there were no military installations anywhere near Kozarac.
3 Do you know that Cirkin's unit actually had mortars?
4 A. I don't know.
5 Q. Then when the fighting stopped after two days, you say that you
6 retreated with all the medical equipment and supplies, anything that
7 remained at the hospital. You retreated to the edge of Kozarac, into the
8 woods.
9 A. Not after two days. The very next day, on the 25th, in the
10 morning. And not with all the medical supplies but only what could fit
11 in one car.
12 Q. So you went to some unfinished house where the police from
13 Kozarac were already hiding; correct?
14 A. Yes.
15 Q. Did you go to the hill or to Kurevo?
16 A. No, it's the suburb, the outskirts of Kozarac when you go uphill.
17 I believe it's not far from a mosque to the left of the road. It's still
18 inside Kozarac only at the outskirts.
19 Q. Earlier today, Mrs. Sutherland interpreted your earlier
20 statements to the effect that you called Serbs on the radio to accept
21 certain wounded people, and they laughed at you, saying, "We'll kill you,
22 Balijas." Where did you get a radio station?
23 A. It was not a radio station. It was a police vehicle, and every
24 police vehicle is fitted with a radio set to a certain frequency.
25 Q. So the police enabled you to talk to the police, not to your
Page 21440
1 colleagues, doctors.
2 A. No, they were not doctors. I suppose it was someone in the army
3 or whoever commanded that attack against Kozarac. At any rate, via that
4 same radio, the surrender of Kozarac was agreed.
5 JUDGE KWON: Mr. Karadzic, we passed the time to take a break.
6 If it is convenient, shall we take a break now?
7 THE ACCUSED: [Interpretation] All right.
8 JUDGE KWON: Before we -- I omitted mentioning to you,
9 Ms. Sutherland, that with respect to the associate exhibits, the
10 65 ter 20760, which is another drawing depicted by the witness, lacks the
11 English translation. So until then, pending the English translation,
12 we'll mark it for identification.
13 We'll take a break for 20 minutes and resume at 3.00.
14 --- Recess taken at 2.40 p.m.
15 --- On resuming at 3.00 p.m.
16 JUDGE KWON: Yes, Mr. Karadzic.
17 THE ACCUSED: [Interpretation] Thank you.
18 MR. KARADZIC: [Interpretation]
19 Q. Did you know, Dr. Merdzanic, that certain groups went uphill and
20 some went to the woods in Kurevo and reorganised the battle there?
21 A. I don't know that.
22 Q. Thank you. Let's just finish this. You talked from a police
23 vehicle, so you were only able to speak to a policeman, not your
24 colleagues at the hospital.
25 A. I was certainly not talking to colleagues at the hospital.
Page 21441
1 Earlier, when the ultimatum expired, the Serbs cut off the telephones so
2 you couldn't call Kozarac or from Kozarac.
3 Q. But then you said the next day an ambulance came, and that the
4 most seriously injured were taken to the hospital in Prijedor.
5 A. No, that's not correct. I said on the 26th, when the surrender
6 of Kozarac had been negotiated, conditions were agreed with the police
7 how to carry out this surrender. And then in a convoy, the wounded, the
8 police, and the civilians came out, but the police were then separated
9 from the rest and they were killed, all of them.
10 Q. Did you see that, Dr. Merdzanic?
11 A. I didn't see that. I was in Kozarac.
12 Q. Are you saying the Serb policemen killed the Muslim policemen
13 then and there?
14 A. I don't know if it was the police who killed them. When they
15 went into Kozarac, it was not policemen. It was uniformed troops with
16 military tanks.
17 Q. This first, 1D04456, page 8. You gave the federal police in
18 Keln [phoen] an interview saying that one of the next days an ambulance
19 arrived and took away the more seriously wounded.
20 A. No. I have my exact statement with the description how it
21 happened. I can repeat it. The surrender was agreed. No ambulance
22 arrived. We had an ambulance, and one of our drivers, the husband of
23 Azra Blazevic, got into that ambulance and carried away the wounded.
24 Q. Where?
25 A. As had been agreed. They drove towards the road from Prijedor to
Page 21442
1 Banja Luka, and then I believe they took the right-hand to Prijedor. We
2 didn't accompany them. We remained in Kozarac, and we went back to the
3 ambulance -- to the infirmary.
4 Q. At the time the hospital was held by the Serbs; right?
5 A. It was in Serb hands always.
6 Q. Do you know that, throughout the war, hundreds and thousands of
7 Muslims and Croats were given treatment in that same hospital?
8 A. During the war, hundreds of thousands of Muslims --
9 Q. I say hundreds and maybe thousands of Muslims and Croats received
10 dialysis and were given complete medical assistance.
11 A. I don't know that. You have to ask in Prijedor.
12 Q. We have this information. I'm just asking you as a doctor. Do
13 you know that?
14 A. I was in Kozarac. How would I know that?
15 Q. Do you know that the civilians from Kozarac, just before the
16 attack and during the attack, were called and came to Prijedor and found
17 shelter in Muslim and Serbian houses while the fighting lasted?
18 A. I don't know anything about that. I know that on the 22nd, when
19 the ultimatum expired, they said nobody would be able to get in or out
20 anymore, and by the 24th, two women came to the infirmary. They were
21 about to give birth, and they said that they could not go to Prijedor,
22 and I had to deliver them, with a nurse -- with a midwife.
23 Q. 1D04461, in the Brdjanin case, page 11801, you said there were
24 problems with civilians who did not know that Kozarac had surrendered.
25 A. Well, the telephones were not working, and those who did not hear
Page 21443
1 the announcement that everyone was supposed to get out remained in their
2 homes. And, of course, the Serbs who came in, I know of one woman whose
3 name was Sahuric who was in a basement with other civilians and later
4 came to Trnopolje looking for somebody who would be able to bury those
5 civilians, because the Serbs found them in that basement in Kozarac and
6 killed them.
7 Q. Who can confirm that story, Doctor?
8 A. That woman, Sahuric, if she's still alive. They live in Germany.
9 She has a son. I gave once the Office of the Prosecutor their names and
10 telephone number. Whether they had contacted them, I don't know.
11 Q. In Brdjanin, you also say, on page 11801, lines 18 to 21, that
12 there was a young wounded boy and a wounded Serb who were allowed to go
13 to Prijedor, and then you say you heard the policemen were killed on the
14 spot. Who told you that?
15 A. I heard that later in Trnopolje from people who were there, who
16 got out of them [as interpreted] on that same day.
17 Q. Can you tell us who told you that by name?
18 A. I can't tell you. I don't know.
19 Q. Thank you. So you came to Trnopolje on the 26th of May. You
20 were ordered to bring all your medical equipment, all you doctors, and
21 there you set up medical protection for the people in Trnopolje.
22 A. That's not correct. That's completely wrong. I don't know
23 where -- how you come up with that. When we were arrested in Kozarac at
24 the infirmary, three soldiers came in. Dragan Skrbic was one of them.
25 You can ask him. He's still alive. They ordered us first to wait while
Page 21444
1 they decide what to do with us. Then they brought a military truck. We
2 had to put all our medical supplies and equipment onto that military
3 truck, and it was all driven away. I don't know where. None of it, not
4 a single item of all that, ever arrived at Trnopolje.
5 Q. In your statement to the OTP, dated 27 and 28 August, 2000,
6 that's 1D04457, page 01035295, you said that medical equipment was loaded
7 and taken to Trnopolje.
8 A. That's not correct. I never said that.
9 JUDGE KWON: Let's do it one by one. Let's upload that
10 statement, 1D4457. Could you repeat the page? Here it is. Thank you.
11 Ending with 5295.
12 THE ACCUSED: [Interpretation] 95, 295, at the very end.
13 JUDGE KWON: Page 6. Yes.
14 THE ACCUSED: [Interpretation] I can barely see it myself. Can it
15 be zoomed in a bit? We should have the exact line too. Just a moment,
16 please. Eighteen through 21.
17 THE WITNESS: [Interpretation] Just a moment, please. "Then the
18 truck left, and I never saw it again." I found it just now.
19 JUDGE KWON: If you have an indication of line numbers, it should
20 be a transcript instead of statement.
21 THE ACCUSED: [Interpretation] No, no. We're on the statement
22 now. I cannot see that particular line in the statement, though. It is
23 this page, 295.
24 MR. KARADZIC: [Interpretation]
25 Q. Can you help us, Doctor? Where is that?
Page 21445
1 A. It was here in the Bosnian language a moment ago, but now
2 somebody removed all of it. Stop. Stop. That's it. Here at the
3 bottom. It says: "Then the truck left --" well, once again what is
4 this? Can I see the entire line, please? Fine. Just leave it this way,
5 please. You don't need to do anything else. Thank you.
6 So look at the bottom down here.
7 "Then the truck left. I don't know where it went, but I never
8 saw the supplies again."
9 I really don't see where you get this from.
10 Q. Now we're going to look at the entire paragraph.
11 A. Just go ahead and have a look at the entire paragraph.
12 MS. SUTHERLAND: Your Honour.
13 MR. KARADZIC: [Interpretation]
14 Q. So what was it that you took to Trnopolje?
15 A. As for medical supplies, we didn't take any of that to Trnopolje.
16 As a matter of fact, I didn't even manage to take my rucksack. Azra
17 managed to take a few things in her rucksack.
18 JUDGE KWON: Yes, Ms. Sutherland?
19 THE WITNESS: [Interpretation] But just personal belongings, no
20 military -- or, rather, medical material, no, nothing.
21 JUDGE KWON: But before that sentence the witness read earlier
22 on, it reads:
23 "We loaded all of the medical supplies we had from the clinic on
24 this truck. "
25 Are you referring to this sentence, Mr. Karadzic?
Page 21446
1 Yes, Ms. Sutherland?
2 MS. SUTHERLAND: Well, Your Honour, that's on transcript
3 page 7740 and 7741 of the Stakic transcript.
4 JUDGE KWON: Thank you.
5 MS. SUTHERLAND: Not Trnopolje. I mean the fact -- how the
6 witness has answered at lines 18 to 24.
7 MR. KARADZIC: [Interpretation]
8 Q. All right. Thank you. Now, tell us, you arrived in Trnopolje,
9 and you say that uniformed persons came to get you. What kind of
10 uniforms were they wearing?
11 A. Again, completely erroneous. You have to have a clear idea as to
12 how all of this happened.
13 We were taken prisoner in Kozarac. We were taken to the centre
14 of Kozarac. Nihad Bahonjic was taken out there and we heard later on
15 that he had been killed. Then they took us in a military jeep in the
16 direction of Prijedor to a tavern on the left-hand side. Then they
17 ordered us to board a bus that was coming from Prijedor. There were
18 women and children on that bus with a military escort, and that's the bus
19 that we arrived in at Trnopolje. When we got off the bus in Trnopolje,
20 there were very many men in uniform. One of them was Rade Baltic in
21 civilian clothing.
22 Q. Just a moment, please. When they came to get you, Predrag Behic,
23 whatever his name is, Dragan Skrbic, and another one, what were they
24 wearing?
25 A. They wore camouflage military uniforms. One of them had a red
Page 21447
1 beret, and all of them had on their upper arm a particular emblem. I
2 cannot remember the colour. I think that Skrbic even wore a blue
3 camouflage uniform whereas the others had green camouflage uniforms.
4 Most of the men we saw in Kozarac as we walked to the centre wore
5 camouflage military uniforms and they all had these armbands.
6 Q. So this is a band made of cloth, right?
7 A. Yes, some kind of cloth, linen probably. So that they could be
8 able to tell them apart.
9 Q. Thank you. Do you know that there was a radio broadcast saying
10 that all the civilians who did not wish to fight should wear such an
11 armband and that all houses from which there would be no shooting should
12 be marked with a white cloth?
13 A. I don't understand how you think that the people of Kozarac can
14 hear that. You cut off electricity, telephones, everything else. How do
15 you expect people to hear that information or broadcast? I've never
16 heard of that. I don't know.
17 Q. That will do, the fact that you did not hear it. It's not only
18 Kozarac. There are other parts of Prijedor as well.
19 A. Well, yes, there are other parts, and you also shelled them and
20 killed people.
21 Q. Doctor, let us leave all these general things aside. You say
22 that some unknown Serb wanted to kill you but that Skrbic forbade him to
23 do that; is that right?
24 A. No, it's not exactly the way it was. He was just very nervous,
25 and he was saying they should be all killed. It's not that Skrbic got
Page 21448
1 up, and it's not that this man really tried to kill us and that Skrbic
2 got up and stopped him in that way. It was a bit different. Goga, who
3 was a Serb woman, was with us and on her white coat she had her name
4 written --
5 Q. Let us just see what you say here --
6 A. I haven't finished.
7 Q. I am not interested in Goga, please. Did Skrbic stand in front
8 of him and stop him from doing that, forbid that?
9 A. No. If you allow me, I can explain.
10 Q. Let us call up a text. Your statement given to the police in
11 Kiel.
12 THE ACCUSED: [Interpretation] 1D04456, page 9. 1D04456. Page 9.
13 I'm going to read it out in English now so that the
14 interpretation is better. I mean, so that they would do a better job
15 than I would.
16 "[In English] The Serb whose name I did not know wanted to kill
17 us all immediately. However, Skrbic stood in front of us and forbade him
18 to do it. He might have done this because he knew our veterinarian,
19 Azra Blazevic, and had talked to our Serbian assistant before."
20 MR. KARADZIC: [Interpretation]
21 Q. You're guessing the reason why, but this is what you stated;
22 right?
23 A. Possibly. I can't really remember anymore, but I can tell you
24 what my recollection is right now. This Serb was nervous, and he was
25 saying that we should all be killed, and this Skrbic in some way
Page 21449
1 prevented that, but not by standing in front of his rifle and protecting
2 us that way with his own body. They called this Goga, this Serb, and
3 talked to her separately, probably asking her what our role was during
4 the shelling, and then he said that we should be left alone and that he
5 would decide what would happen to us, and then he left.
6 Q. Thank you. You say that Bahonjic was singled out. Do you know
7 how many Bahonjics there were in the organisation of this struggle?
8 A. I know that Nihad Bahonjic is an ambulance driver and that from
9 the beginning until the end, from the 24th until the 26th, he was at the
10 infirmary with us and he did not take part in any of the fighting.
11 Q. Thank you. And you then say that you heard that he had been
12 singled out and then you heard gunshots but you did not see him killed;
13 right?
14 A. No, but as far as I know, his bones have been found.
15 Q. We'll deal with that later. So you heard this and you did not
16 see it. All right. Now, tell me, in Trnopolje -- you were in Trnopolje;
17 right? And, actually, when was this school built in Trnopolje, the
18 municipal building, the infirmary, the stadium, the club, and also this
19 warehouse for construction material?
20 A. How could I know? At any rate, it was there for years.
21 Q. Thank you. And then you said that in your opinion that was
22 planned considerably earlier as a camp, because there is a railway --
23 railroad there?
24 A. Correct.
25 Q. So when was that, 30 or 40 years before that, with the intention
Page 21450
1 of having a camp there?
2 A. That's not true. That is not what I said. I said that
3 strategically, if you look at Prijedor and the surrounding area, the only
4 ideal spot for the Serbs where they could operate -- well, in principle,
5 that camp had been prepared for ethnic cleansing, so when women and
6 children are brought together there and when they are expelled from their
7 houses and villages and when a sufficient number of civilians are
8 gathered there, then a convoy is organised for expelling these civilians
9 from Serb territory.
10 Q. You were saying that now, and you said that in the Brdjanin case.
11 You said in the Stakic case, though, that you thought that all of this
12 was decided in haste; right?
13 A. I don't think so. I don't think that's the way it was. It
14 depends on the context.
15 Q. You said that in Stakic, 65 ter 22147, on page 7827, but you said
16 it could have been this way and it could have been that way; right?
17 A. I was not involved in the decision-making. Ask someone who was
18 involved in the decision-making as to where the camp would be.
19 Q. You said that your impression was that both was plausible, that
20 it was done in haste and that it could have been done earlier.
21 A. I said that that was my impression. You have to ask whoever had
22 planned that. However, if you look at where Trnopolje is and what
23 Trnopolje was used for, there is not a better spot in that area.
24 Q. Further on, you say that before the war this spot had been fenced
25 off; right?
Page 21451
1 A. Well, this was a small fence, a school fence, and also for the
2 infirmary, the construction material warehouse. In principle, there was
3 nothing new that was built there.
4 THE ACCUSED: [Interpretation] Could we now have a look at a
5 video-clip.
6 MR. KARADZIC: [Interpretation]
7 Q. Do you know this person?
8 A. The quality of the image is very poor.
9 THE ACCUSED: [Interpretation] 40504. That's the 65 ter number.
10 And then 24:00.
11 [Video-clip played]
12 THE INTERPRETER: [No interpretation]
13 MR. KARADZIC: [Interpretation]
14 Q. Is this the fence, the low fence that you mentioned?
15 A. That is a low fence. That was Trnopolje.
16 Q. And this fence is between what?
17 A. You have to play the video further. That fence had to be between
18 the house and the construction equipment store facing the football
19 stadium, because that is the only fence that was that low -- that low.
20 Q. I see. And that is where this warehouse with the construction
21 material was fenced off?
22 A. No, that's not right. That's a different fence, about 2 or
23 2.5 metres high.
24 Q. And what was this fence used for?
25 A. That fence had been prepared for the inmates from Keraterm. It
Page 21452
1 was built just before the journalists arrived.
2 Q. How high is this fence?
3 A. On that side it was perhaps 1.20 metres. I didn't measure it. I
4 don't know.
5 THE ACCUSED: [Interpretation] Can we play this on.
6 [Video-clip played]
7 THE INTERPRETER: [No interpretation]
8 THE WITNESS: [Interpretation] Can you stop at this point, please?
9 This is not that fence. This is somewhere near the school. This is the
10 other fence, the normal fence that was filmed later on when the Serb
11 journalists came.
12 MR. KARADZIC: [Interpretation]
13 Q. Thank you. Actually, that was the fence surrounding the school;
14 right?
15 A. I think so. On the Penny Marshall footage that can be seen.
16 THE ACCUSED: [Interpretation] Can we go on.
17 [Video-clip played]
18 THE INTERPRETER: "[Voiceover] Reporter: That means practically
19 that the fence does not separate you from the village.
20 "Prisoner: No, no, they let us go out. We leave our personal
21 identity card here and go up there.
22 "Prisoner: But there's no one in the village. We just go into
23 the gardens and get the vegetables.
24 "Reporter: That means you are free to take a hoe and dig up
25 something in the garden, right?
Page 21453
1 "Prisoner: Yes, we take a hoe, go up there, dig up potatoes,
2 tomatoes. We cook here for ourselves.
3 "Second prisoner: It's all running out.
4 "Prisoner: A few more days and there won't be anything up there
5 left either."
6 MR. KARADZIC: [Interpretation]
7 Q. So you spoke about that. I'll tell you where now. You told
8 about that in your interview from 2000, 1D04457, on page 296. It ends
9 with number 296. You said it was the normal fence surrounding the
10 schoolhouse from back before the war. There was one fence around the
11 depot of construction materials.
12 A. Yes.
13 Q. Another fence was around the school.
14 A. Yes.
15 Q. Was there a third fence?
16 A. Yes. Outside the infirmary, a low fence next to the road.
17 Q. Thank you.
18 A. And the fence that was put up before the journalists arrived.
19 Q. Before the arrival of the reporters a fence was put up for the
20 journalists?
21 A. No. It was for the inmates of Keraterm.
22 Q. And there was a section without any fence whatsoever.
23 A. The section closer to the football pitch. There was no fence
24 there.
25 THE ACCUSED: [Interpretation] Could we now see 1D4851.
Page 21454
1 MR. KARADZIC: [Interpretation]
2 Q. I believe this footage -- this aerial photograph is familiar to
3 you.
4 Can you see the football pitch here to the left?
5 A. Yes, we can see the football pitch.
6 Q. There was no fence on that side. And what is the rest? Can you
7 please explain?
8 A. In the upper part we see the schoolhouse. Then you see the
9 infirmary. Then this big hall, and close to the intersection is the shop
10 selling construction material.
11 Q. Thank you.
12 THE ACCUSED: [Interpretation] If this is not part of an exhibit
13 already, I would like to tender it.
14 May I just ask you to mark --
15 JUDGE KWON: Just a second. But before that are you minded to
16 tender the previous video-clip we saw?
17 THE ACCUSED: [Interpretation] Yes, yes. Certainly.
18 JUDGE KWON: That will be first admitted.
19 Ms. Sutherland, do you have any observation to that video-clip?
20 THE WITNESS: [Interpretation] Excuse me. Was that a question to
21 me?
22 JUDGE KWON: No. I asked Ms. Sutherland.
23 MS. SUTHERLAND: Your Honour, the video is -- was an associated
24 exhibit with Mr. Vulliamy, but I don't know about that particular portion
25 that was -- that was played, whether that excerpt came in as an
Page 21455
1 associated exhibit.
2 JUDGE KWON: Could you confirm it tomorrow?
3 MS. SUTHERLAND: Yes.
4 JUDGE KWON: All right. Then we'll wait.
5 Then in relation to this document, but please tell us,
6 Mr. Karadzic, first where this -- this document is from, whose marking
7 this is.
8 THE ACCUSED: [Interpretation] I believe this witness marked it in
9 another trial, Brdjanin or Stakic.
10 THE WITNESS: [Interpretation] I don't remember marking anything
11 on an aerial photograph.
12 THE ACCUSED: [Interpretation] That's the best we could find. We
13 found it at the Tribunal. Could we ask the --
14 JUDGE KWON: Could you help us? At the end of this document it
15 says P1770.
16 MS. SUTHERLAND: That was exhibit in the Stanisic/Zupljanin
17 trial, Your Honour.
18 JUDGE KWON: And do you know whose marking this is?
19 MS. SUTHERLAND: I'm not sure, Your Honour.
20 THE ACCUSED: [Interpretation] Could we ask the usher to help
21 Dr. Merdzanic to make his own markings.
22 MS. SUTHERLAND: No, Your Honour, I'm sorry. It was marked by
23 this witness in the Stanisic/Zupljanin case.
24 JUDGE KWON: When was it? Do you remember when it was, the date
25 of his testimony?
Page 21456
1 MS. SUTHERLAND: The 9th of December, 2010.
2 JUDGE KWON: Last year.
3 Doctor, do you remember now, having been assisted by the
4 Prosecutor? Do you confirm that's your marking?
5 THE WITNESS: [Interpretation] Certainly. It's not a problem.
6 This is Trnopolje for sure, and I can mark everything I recognise and I
7 know here.
8 JUDGE KWON: My question was whether you can recognise your
9 markings. These markings were done by you -- by you yourself.
10 THE WITNESS: [Interpretation] Possibly. I don't remember.
11 JUDGE KWON: Very well. Let's -- we'll -- our usher will assist
12 you to add some further markings, probably black -- in black this time.
13 THE ACCUSED: [Interpretation] In another colour, please.
14 MR. KARADZIC: [Interpretation]
15 Q. Doctor, by the school building, please put number 1. You may do
16 it even outside the red line. Could you mark the side closer to the
17 stadium with 2.
18 A. [Marks]
19 Q. And that's the side where there was no fence; right?
20 A. There was no fence on that side. Right.
21 Q. Now, inside, can you identify the infirmary as 3?
22 A. [Marks]
23 Q. And the warehouse of construction material with 4. There was a
24 fence around it; right?
25 A. Yes. [Marks].
Page 21457
1 Q. Is there another building you think needs marking?
2 A. I'll put 5 to mark this cultural hall.
3 Q. Yes, the cultural hall.
4 A. There was a library in the community hall. At one point between
5 the warehouse and -- of construction material and that community hall a
6 fence was put up.
7 Q. Could you put the date at the bottom.
8 A. [Marks]
9 Q. Thank you, Doctor.
10 THE ACCUSED: [Interpretation] Can this be admitted, please?
11 JUDGE KWON: Yes.
12 THE REGISTRAR: Exhibit D1924, Your Honours.
13 MR. KARADZIC: [Interpretation]
14 Q. About the arrival at Trnopolje, you said there was no
15 registration of newly arrived.
16 A. Not that I noticed.
17 Q. Still, you did give Slavko Puhalic a certain list, and you were
18 told that it was necessary in case somebody went missing.
19 A. Only of those who were in the infirmary. Those who were going to
20 the school and the community hall were not listed that I could see.
21 Q. You spoke about people being able to go out, and we heard on this
22 footage that people went out into the village to find food and came back.
23 A. Not exactly. There were several periods during the existence of
24 Trnopolje, and during various periods, food supplies were organised in a
25 different way. There was one stage when the surrounding population had
Page 21458
1 been expelled and sent away in a convoy.
2 Q. We'll come to that. We heard this man on the video saying that
3 nobody beat him, that he had not been involved in combat, that he had
4 come there to find shelter, and that they were able to go out. He said,
5 "We could take a hoe, go into the gardens, dig out vegetables," et cetera.
6 A. Play the video where they interviewed me, I didn’t say anything
7 either. They went into the infirmary, too. It was a Serbian television
8 crew. Do you think anybody dared say anything openly?
9 Q. Well, let's look at it again. The interpreters have the text.
10 We can continue where we stopped.
11 THE ACCUSED: [Interpretation] Could you play, please.
12 [Video-clip played]
13 THE INTERPRETER: "[Voiceover] Prisoner: They let us go out into
14 the village. We go there alone.
15 "Reporter: That means you're free to take a hoe and dig up
16 something in the gardens; right?
17 "Prisoner: Yes. We take a hoe, go up there, dig up potatoes,
18 tomatoes. We cook here for ourselves.
19 "Second prisoner: It's all running out, however.
20 "Reporter: When did you come here?
21 "Prisoner: On the 27th of May.
22 "Reporter: And why did you come?
23 "Prisoner: I came here when the fighting started where I lived.
24 I had to come. Where would I go on the other side?
25 "Reporter: Did you participate in combat?
Page 21459
1 "Prisoner: No.
2 "Reporter: So practically you were looking for protection,
3 right? For safety?
4 "Prisoner: Yes.
5 "Reporter: And what is it like here?
6 "Prisoner: Well, you can see for yourself it's okay. It's not
7 so bad.
8 "Reporter: Were there any problems, any mistreatment?
9 "Prisoner: No.
10 "Reporter: What about the others, anyone else here, because I
11 saw here that the -- in the camp we visited a little while ago, people
12 from another collection centre had arrived, and did this collection
13 centre function like some kind of camp where people were mistreated?
14 "Prisoner: Well, this is a collection centre. Fuck it. It
15 cannot be anything other than a collection centre. All those who didn't
16 fight came here. What do I have to fight for?
17 "Reporter: And what now?
18 "Prisoner: Only those who were being shelled had to come here.
19 "Reporter: And what do you expect now? If only those big
20 guys --"
21 THE INTERPRETER: The interpreters did not finish.
22 THE ACCUSED: [Interpretation] We can just add it to the previous
23 footage admitted. We don't have to give it a separate exhibit number.
24 MR. KARADZIC: [Interpretation]
25 Q. Did you hear what he said? There was fighting in surrounding
Page 21460
1 villages. There was shooting. They came here. They were looking for
2 food. Did you hear anyone asking him --
3 THE INTERPRETER: Mr. Karadzic has to slow down. We cannot catch
4 up with the --
5 JUDGE KWON: I'm sorry, Mr. Merdzanic. We have to start it over
6 again. Because of the overlap the interpreters were not able to catch up
7 with you.
8 Mr. Karadzic.
9 MR. KARADZIC: [Interpretation].
10 Q. Dr. Merdzanic, did this man say that there was shooting or
11 shelling there, that he was not involved in combat, that he came there,
12 and they are making do to find food, going out into surrounding villages?
13 A. I was in that village from beginning to end --
14 [Video-clip played]
15 THE WITNESS: [Interpretation] I want to answer now and please
16 don't interrupt me. I was in that camp from beginning to end, and I know
17 exactly in what way people came and how things were done in various
18 periods. There were various distinct periods in Trnopolje, and in
19 different periods the inmates received different treatment.
20 Speaking of most of the inmates, and I never said that all of
21 them were beaten or killed, but many were beaten and some were even
22 killed in Trnopolje.
23 Q. With all due respect, it's a different subject. We'll come to
24 it. I want to finish with this subject.
25 A. I'm trying to explain to you that what this young man is saying
Page 21461
1 to the Serbian television crew -- you either have to say what he is
2 saying or you say nothing. Just find this man and bring him here. Let's
3 see what he's going to say now.
4 Q. Do you see that he says that the guards were trying to help the
5 Muslims and the Serbs from the surrounding villages also came and tried
6 to help with what they had?
7 A. On that subject, I just said that there were certain Serbs who
8 tried to be helpful to us.
9 THE ACCUSED: [Interpretation] Your Excellency, I don't know -- I
10 know this has been exhibited already, and my assistants will provide the
11 exact minutes of -- of this segment. It belongs with the others.
12 JUDGE KWON: Yes. The additional part that we just saw will be
13 added to the previous exhibit -- Exhibit D1924.
14 Just a second.
15 [Trial Chamber and Registrar confer]
16 JUDGE KWON: I was mistaken. The OTP will confirm later on
17 whether this is a part that we already admitted. Thank you.
18 THE ACCUSED: [Interpretation] I don't think that is the right
19 segment. I don't think this segment has been exhibited, not this part.
20 JUDGE KWON: That being the case with -- this part will be added
21 to the existing video-clip.
22 Yes, Mr. Karadzic.
23 THE ACCUSED: [Interpretation] Thank you.
24 MR. KARADZIC: [Interpretation]
25 Q. So in Brdjanin, 1D04458, page 11813, lines 4 through 7, you said
Page 21462
1 that the guards tried to be helpful and did what they could, at least
2 some of them, but there were also Serbs who visited and tried to help;
3 right?
4 A. I never said Serbs were all bad or all Serbs were bad. I said,
5 indeed, that there were certain Serbs who visited and tried to help us as
6 much as they could. I also said there was one period, but it was only a
7 short period, where inmates were allowed under escort to go to
8 surrounding farms and bring potatoes and whatever food they found in
9 empty houses because there was no other food available.
10 Q. You spoke about intermittent arrivals from Keraterm and Omarska.
11 How often did groups come, and how large were there -- they?
12 A. From Keraterm there was only one group. And from Omarska, a
13 group of women came with minor children, and as far as I know, after the
14 journalists left, a larger group came that night after the journalists
15 left.
16 Q. That means there was one group from Keraterm and how many from
17 Omarska?
18 A. Two groups. One was women and underage children, and the other
19 time those from Omarska.
20 Q. Do you know that 59 were -- per cent were released from Omarska
21 and 41 per cent were sent to Manjaca? Just tell me if you know that or
22 not.
23 A. As far as I know, they came from Trnopolje -- they came to
24 Trnopolje, and most of them were released from Trnopolje, because, for
25 instance, my wife's father, who with his own wife and her sister stayed
Page 21463
1 at his home later, they were all found there and killed.
2 Q. Do you know -- did you say it was agreed that local residents
3 could visit and bring food to the camps?
4 A. Yes. That was in the early days, when the population in the
5 surrounding villages were still there in their homes, before they were
6 driven out of their homes and expelled in convoys.
7 Q. Did you see that?
8 A. Of course I saw that.
9 Q. You were in Elezi when that happened?
10 A. No, no. This was right by Trnopolje. People were brought to
11 Trnopolje. Not only from Elezi but also from other areas. The ethnic
12 cleansing of Prijedor was complete. Most of it happened through
13 Trnopolje, not all of it though. One convoy from Sanski Most, as a
14 matter of fact, was brought to Trnopolje. They were boarded onto a
15 train. They took a man and a woman out --
16 Q. Doctor, I don't have time for your very general statements, and I
17 have no time to make them more specific. You did complain about
18 Zoran Zigic, didn't you?
19 A. Zoran Zigic? I didn't complain. I just gave a statement saying
20 that on one occasion, Zoran Zigic came to Trnopolje. After they brought
21 the inmates from Keraterm, he lined them up within that fence that had
22 been built for them. He brought out one of them named Kum and told him
23 to kneel down and then he beat him.
24 Q. Do you know that several criminal reports were filed against him?
25 A. I don't know about that, but I know that the commander of the
Page 21464
1 guards and the commander of the company were all there. Everybody was
2 watching. It was out in the open. No one reacted.
3 THE INTERPRETER: Interpreter's note: We did not hear
4 Mr. Karadzic.
5 JUDGE KWON: Before that, interpreters didn't hear your question.
6 MR. KARADZIC: [Interpretation]
7 Q. I asked whether Dr. Merdzanic knew that he had been a criminal
8 and that criminal reports had been filed against him.
9 A. I've already responded that I don't know.
10 JUDGE KWON: Probably what the interpreters missed was the
11 exhibit number, the document number that we are -- in front of us and
12 that we are seeing now, yes.
13 THE ACCUSED: [Interpretation] There's a translation too.
14 MR. KARADZIC: [Interpretation]
15 Q. This is one criminal report dated the 2nd of July, because
16 some -- actually, he had asked some Muslims for money, and obviously he
17 was involved in a trade that was based on their fear.
18 A. It wasn't only him. When you expel the population from one
19 village, then you start looting in the houses. When the houses are
20 looted, it is only then that they are destroyed and razed to the ground.
21 It is not that the Serbs move into these houses.
22 Q. Thank you. Can we see who it was that filed this criminal
23 report. Simo Drljaca filed this criminal report; right? The chief of
24 the station.
25 A. I don't know who filed it.
Page 21465
1 Q. Thank you.
2 THE ACCUSED: [Interpretation] Can this be admitted?
3 JUDGE KWON: This is, I take it, 1D4465. This will be admitted.
4 THE REGISTRAR: As Exhibit D1925, Your Honours.
5 THE ACCUSED: [Interpretation] 1D4467. Can we have a look at that
6 now. 1D4467.
7 MR. KARADZIC: [Interpretation]
8 Q. Please take a look at the version in our language. The
9 translation is coming.
10 Do you agree that the same chief of the police station is asking
11 for Zoran Zigic to be taken to prison according to a decision such and
12 such number and so on?
13 A. That is just a piece of paper saying that.
14 Q. Thank you.
15 THE ACCUSED: [Interpretation] Can this be admitted?
16 JUDGE KWON: Yes.
17 THE REGISTRAR: Exhibit D1926, Your Honours.
18 MR. KARADZIC: [Interpretation]
19 Q. You said that you never saw women being questioned; right?
20 A. That's what I said in relation to Trnopolje.
21 Q. Thank you. Also, you were never beaten; right?
22 A. I was not beaten. I just went and gave a statement on one
23 occasion.
24 Q. Apart from that one statement, you were not interrogated.
25 A. I was not.
Page 21466
1 Q. Did you tell them then about all the things that you did in
2 Kozarac during the crisis?
3 A. I always said the same thing that I've been saying now. There
4 was this Serb woman, Goga. She made a statement too. Nothing else can
5 be said except for what had truly happened.
6 Q. Thank you. Your estimate was that about 10 per cent of these
7 people who were there were taken out for questioning and were beaten.
8 A. Perhaps I should have a look at this. I don't know what the
9 context was possibly. I have to see the statement.
10 Q. 1D4457, your interview with the OTP. 0103502 [as interpreted]
11 and 03. Those are the pages.
12 A. I said something like that, but I don't know whether that's the
13 context. I'd have to read it.
14 Q. On the same page, 04 --
15 THE ACCUSED: [Interpretation] Actually, what is this? 318? And
16 we need 302 and 303. I don't know how this happened. 5302 and 03.
17 Actually the numbers are the other way around.
18 JUDGE KWON: Is it not page 14 -- 14 in English, or 13.
19 THE ACCUSED: [Interpretation] Thirteen, possibly, 13.
20 MR. KARADZIC: [Interpretation]
21 Q. You mentioned Zigic here, and you see that they were prosecuting
22 him. And now let us see where you mentioned this percentage.
23 THE ACCUSED: [Interpretation] It's between pages 302 and 303.
24 Can we have the next page, then.
25 JUDGE KWON: Mr. Karadzic, I see the time. We'll continue
Page 21467
1 tomorrow morning. We have to rise.
2 THE ACCUSED: [Interpretation] Excellency, may I ask for a bit
3 more time, because this is a man who was in Trnopolje, and unfortunately,
4 there are quite a few general statements here, so I have to make them
5 more specific. I have to get to the things that he does know
6 specifically.
7 [Trial Chamber and Registrar confer]
8 JUDGE KWON: You still have half an hour, which in the opinion
9 the Chamber is sufficient for you to conclude. But we will see tomorrow.
10 We will resume at 9.00 tomorrow morning, but in the meantime,
11 Dr. Merdzanic, as you are aware of this well, you are not supposed to
12 discuss with anybody else about your testimony. Do you understand that,
13 sir?
14 THE WITNESS: [Interpretation] Yes.
15 JUDGE KWON: Tomorrow morning, 9.00.
16 --- Whereupon the hearing adjourned at 4.00 p.m.,
17 to be reconvened on Thursday, the 17th day
18 of November, 2011, at 9.00 a.m.
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