1 Wednesday, 15 March 2000

2 [Open session]

3 --- Upon commencing at 9.32 a.m.

4 [The witness entered court]

5 JUDGE RODRIGUES: [Interpretation] Good

6 morning, ladies and gentlemen; good morning to the

7 technicians, to the interpreters. Can you hear me?

8 Thank you. Good morning to the counsel for the

9 Prosecution, the counsel for Defence; good morning,

10 General Krstic.

11 We will continue with our case. We know it's

12 the Krstic case. I will give the floor to Mr. Harmon,

13 and I believe we will go on with the testimony of

14 Mr. Ruez.

15 Is that the case, Mr. Harmon?

16 MR. HARMON: That is the case,

17 Mr. President. Good morning, Mr. President; good

18 morning, Your Honours; good morning, counsel.

19 [The witness entered court]

20 WITNESS: JEAN-RENE RUEZ [RESUMED]

21 JUDGE RODRIGUES: [Interpretation] Good

22 morning, Mr. Ruez. We will continue your testimony. I

23 will give the floor immediately to Mr. Harmon. I just

24 want to remind you that you're still under an oath and

25 that you will be answering questions put to you by

1 Mr. Harmon.

2 MR. HARMON: While Mr. Ruez gets himself

3 organised, Mr. President and Your Honours, we're going

4 to be now turning our attention now to Volume 2,

5 Exhibits 14 through 27.

6 Examined by Mr. Harmon:

7 Q. Mr. Ruez, we're now going to turn our

8 attention to Prosecutor's Exhibit 14, which is the Nova

9 Kasaba graves, and I believe we have a videotape that

10 we are going to play to begin this presentation.

11 A. Yes. We are going to start with the

12 Exhibit 14/12, which is a short videotape showing the

13 area of these graves of Nova Kasaba.

14 Q. Before we show the video, Mr. Ruez, would you

15 please point out to the Judges the location of those

16 particular grave sites?

17 A. So we are still in the area of Nova Kasaba,

18 which is located just south of the intersection of

19 Konjevici. The precise location of graves we are now

20 going to show is where the yellow dot is marked here as

21 a primary, undisturbed mass-grave area.

22 MR. HARMON: Could we have the audio booth

23 please now dim the lights, and we could start with the

24 film 14/12.

25 [Videotape played]

1 A. On the left was the intersection of

2 Konjevici. Just underneath here is the exit of the

3 little road that goes towards the valley of Cerska.

4 This road goes towards the soccer field of Nova

5 Kasaba. On the left is still the hill on which all the

6 people were jammed and witnessing events.

7 Here, just after the curve of this road, you

8 have an opening of ground. This is the location

9 number 1.

10 Just a bit further on, in front of the group

11 of houses on the opposite side of the road, in between

12 the river and the houses is an area here where we'll

13 currently zoom in, which is the site of the second

14 grave area. And this stretch of road continues a

15 little bit, arrives to the soccer field here. Nova

16 Kasaba town is just behind the name of the town has

17 changed recently. I don't have it in mind at this

18 moment.

19 This is again a view of this valley going

20 towards Konjevici, the direction north. That was the

21 final view.

22 Above Nova Kasaba town, looking towards the

23 soccer field, the grave area being now behind the hill

24 in the curve.

25 We -- no. The film continues, because now we

1 are flying above this hill from where the people could

2 overlook. So one can indeed see that from this

3 location it's a very good view on the road. We are

4 returning towards these grave area, which are now above

5 the road, and here is the first one we saw, just in

6 this curve, in a very specific shape.

7 MR. HARMON:

8 Q. Mr. Ruez, why don't you proceed by putting

9 some photographs on the ELMO, and if we could take

10 Prosecutor's Exhibit 14/1.

11 A. So this is an aerial photograph taken 13 July

12 1995. There is nothing to be noticed specifically on

13 this photograph. It is a reference for the next one.

14 Two areas are squared on this photograph,

15 which mark the grave areas which we saw on the video.

16 The one at the bottom left is the one we saw first and

17 then last, the one which has this specific shape. The

18 one on the right hand on the photograph is the one that

19 we saw and that which I mentioned was the site was in

20 between the river and the road. The site is, in fact,

21 just at the edge of the river. We'll see that later.

22 Q. Keep that photograph on the ELMO for just a

23 minute, because the caption says "Areas of disturbed

24 earth," and this picture doesn't show any disturbed

25 earth. So these rectangles represent areas where earth

1 would be later disturbed; is that correct?

2 A. Yes. That is correct. Again, the label is

3 because this photograph is in connection with another

4 one and, in fact, the stack of photographs related to

5 that specific crime scene is labelled "Area of

6 disturbed earth."

7 Q. Now if you would turn next to the photograph

8 that relates to this photograph, you can make the

9 demonstration. I'm referring Prosecutor's

10 Exhibit 14/2.

11 A. This exhibit, 14/2 is, is an aerial

12 photograph dated 27 July 1995, so in between the time

13 of the events and the time of reburial. On these

14 photographs, one can see very clearly, on the left side

15 or the left part of the photograph, in between the road

16 and the river, close to the river, an area of disturbed

17 soil which is split, in fact, in several smaller

18 disturbances.

19 On the right of the picture, which is south

20 on the map, towards Nova Kasaba, is an another area

21 very close to the river where a disturbance it is to be

22 noted.

23 Q. Mr. Ruez, would you turn your attention next

24 to Prosecutor's Exhibit 14/4? 14/4, Mr. Ruez. That's

25 14/3.

1 A. Exhibit 14/4 is the same photograph as

2 Exhibit 14/3, with the difference that the markings are

3 put on this photograph. The markings indicate the code

4 names which were given during the exhumation of this

5 site. The exhumation of this specific site was done in

6 1996.

7 This photograph is one of the two which was

8 shown by Madeleine Albright, who at that time was

9 US Ambassador at the United Nations, and this

10 photograph was shown -- was made public on 10 August

11 1995.

12 The exhumation of this place was conducted in

13 1996. I won't provide the full details about the

14 results since someone will come and develop the entire

15 results for all the exhumation which was conducted from

16 1996 through 1999 and will continue this year, but on

17 this specific location, 33 bodies were exhumed in

18 1996. The exhumation is completed here. The site was

19 split in four graves.

20 The next exhibit is the photograph marked

21 14/5, which is the same grave area we previously saw.

22 The interesting part here, aside seeing it in colour,

23 is if you reverse it, you will have exactly the same

24 photograph than the previous one, where you can see --

25 we'll circle the areas.

1 The area on the left of the aerial photograph

2 is in between these two trees of line [marks], and the

3 other one is an area of disturbance which was here

4 [marks].

5 MR. HARMON: For the record, Mr. President

6 and Your Honours, on this Exhibit Mr. Ruez has circled

7 three areas with a red pen.

8 A. The next photograph is also a photograph from

9 the helicopter, photographed in 1999, as the previous

10 one, and this is again the same site but seen from the

11 west, towards the east, and I will again circle the

12 locations since now with this one, one is very

13 obvious. The other one is nearly invisible because

14 it's hidden behind a tree line. I'll start with the

15 one most at the left of the picture, which is the most

16 north on the ground [marks]. This area here [marks]

17 and the second one is this area here [marks].

18 On this photograph, a small digression, but

19 you can also have here a very good view on the location

20 which I exposed yesterday, which is this execution

21 field in between two houses. I will very briefly

22 return on this point, not to say that there is a

23 connection between the execution site and these mass

24 graves, but the location is exactly there on this

25 photograph with all the reference points which I

1 indicated to you yesterday.

2 Here you have a pylon [marks], nearby which

3 someone was witnessing the events. Here you have a

4 white house and the house on top of the hill here

5 [marks], which would be the two houses in between which

6 the person could see the event. This area here

7 [marks] -- or a bit more on the left, I'm sorry, this

8 area here [marks] is the approximate -- it's smaller on

9 the ground, but it's the approximate area where the

10 execution took place.

11 MR. HARMON:

12 Q. So the record is clear, would you put the

13 number 1 next to the area where the executions took

14 place.

15 A. Number 1 is the area where the execution took

16 place; number 2 is the house which was on the left-hand

17 side of the person who was seeing the events; the house

18 at number 3 is the house which probably was on the

19 right-hand side of the person who could see the events;

20 number 4 will be the pylon in the vicinity the person

21 was standing. And now returning to the Nova Kasaba

22 graves, I will mark "A" for the site which is the

23 most -- at the left in the picture and letter "B" for

24 the one that is on the right of the picture.

25 Q. Please continue.

1 A. The next exhibit is a photograph which was

2 taken at the moment we did a probe of this site in

3 1996. The aim of presenting you this one is to give

4 you an indication of what it means when we say that we

5 are probing a site.

6 What we are doing in these circumstances is

7 that we are digging in a location where we suspect the

8 presence of a mass grave until we find multiple

9 remains, multiple remains indicating the presence of a

10 mass grave. Once this is successfully conducted, then

11 we schedule the site for exhumation, depending on the

12 priorities we think are the most appropriate at the

13 moment.

14 On this photograph, we did a bit more than

15 exposing only multiple remains, since we exposed nearly

16 complete bodies. On this photograph you can see, in

17 fact, one body part belonging to one individual here

18 [marks]. You can see one individual lying here with

19 his head under the soil and his hands in the back.

20 There is one more individual here [marks]. There is

21 one individual lying on his belly here [marks], with

22 his hands attached in the back. You have one

23 individual lying here [marks] with his hands attached

24 in the back, and he is lying on top of another

25 individual which is underneath him here [marks], and

1 his hands are on the head of another individual which

2 is also underneath him.

3 Q. For the record, that exhibit is Prosecutor's

4 Exhibit 14/7.

5 A. Exhibit 14/7. This operation was conducted

6 in April 1996.

7 The following exhibit, Exhibit 14/8, is just

8 a close-up on one of the bodies I just pinpointed, the

9 one who has his hands on the head of the individual

10 underneath him, and I am just going to pinpoint for you

11 on this photograph two elements which were pinpointed

12 already at the public hearing in July 1996, which are

13 the wedding ring of this man --

14 Q. Which you're circling in red.

15 A. Which I just circled and I will mark "A"

16 [marks], and I will mark "B" the wire ligature which is

17 binding the wrists of this man.

18 The following exhibit, Exhibit 14/9, is a

19 view of a second grave area which was already shown on

20 the broader view, which was showing these two sites.

21 This is the one which is the most south, so it was on

22 the right of the general overview of this area.

23 And the next exhibit marks the location of

24 the graves which are exhumed in 1999.

25 Q. That's Exhibit 14/10.

1 A. This is Exhibit 14/10. You can see here that

2 the site is divided into several subsites. The total

3 number of individuals exhumed in this location in

4 August and September 1999 is 55 individuals. The

5 details about the bodies, the other findings in the

6 graves, will be the topic of a specific expos‚.

7 Exhibit 14/11 is a photograph taken in 1999

8 which shows the same site as the one that was on the

9 aerial imagery, and I'm going to mark the location of

10 the site on this photograph as being "1". This is the

11 main site.

12 Q. Now, have you completed your presentation in

13 respect of these particular grave sites, Mr. Ruez?

14 Shall we move to a different topic?

15 A. Yes.

16 MR. HARMON: We will now move, Your Honours,

17 to Prosecutor's Exhibit 15, KP-1. In this particular

18 case, we do not have a video. We will start directly

19 with Mr. Ruez orienting Your Honours to the locations

20 of KP-1 on the large map.

21 A. On this large map, there is really no

22 possibility to differentiate this location from the

23 other ones. On the right here, this is very close by,

24 as you can see on the video filmed from the

25 helicopter. All the locations we are mentioning here

1 are along a stretch of road which is less than three

2 kilometres long, going from north to south. The

3 precise location of the grave we're going to show now

4 would be here [indicates], just nearby the exit of the

5 Cerska Valley.

6 Exhibit 15/A is a photocopy of the map of the

7 area, and the circle marks approximately the area of

8 the site and the green dot marks the more precise

9 location for this grave, which is on the right-hand

10 side of the road when travelling from the north to the

11 south, so from the top of the picture towards the

12 bottom of the map.

13 I'm going to skip Exhibit 15/1 which is

14 exactly the same exhibit as 15/2.

15 Exhibit 15/2 has some markings on it. So

16 this is an aerial photograph, dated 14 August 1995, on

17 which one can see, going from the left towards the

18 right, the dirt road that goes towards the Cerska

19 Valley and which exits in the plain of Nova

20 Kasaba-Konjevici. It hits the road that goes from the

21 bottom of the picture towards Nova Kasaba, and at the

22 top of the picture towards Konjevic Polje.

23 In the curve, behind a little group of trees,

24 is an area of disturbed soil which is marked "KP-1".

25 You can see on this picture that there is another area

1 of disturbed soil which is squared and which is just at

2 the exit of the Cerska Valley. I won't develop this

3 one any longer since we probed it and there was

4 absolutely nothing to be found there, so we have no

5 explanation for the presence of this disturbance.

6 Returning to KP-1, I shall like -- it's

7 another one that was the equivalent to this one. I'm

8 still going to show you the photograph 15/1 for the

9 reason that that one was dated 27 July. The site which

10 is on the left of the photograph is the one which I

11 indicated was negative -- the probe was negative when

12 we conducted it in 1998. But the site did not exist

13 prior to 27 July 1995, so it is a site which was

14 created between 27 July 1995 and 14 August 1995. We

15 have no explanation for that.

16 There is still one possibility that I would

17 like you to know about, it is only a possibility, but

18 since the aerial photographs which were shown

19 previously have been disclosed in public on the 10th of

20 August, there is the elimination of the theory that it

21 could be linked with some -- this creation of deception

22 sites following the presentation. This could have been

23 a military position, a tank position, or a position of

24 a gun, or something like this.

25 Where were we at this point?

1 Q. We are about to move to Prosecutor's 15/4,

2 which is a colour image.

3 A. Yes. Exhibit 15/4 is a view of this same

4 area but from a helicopter, a colour photograph. The

5 reference points to match it with the aerial photograph

6 would be the exit of the road coming from the valley of

7 Cerska, which is at the top right of the photograph and

8 which arrives on the asphalt road. This view is a view

9 from north towards south, from the intersection of

10 Konjevici towards Nova Kasaba.

11 The little group of trees which could be seen

12 on the aerial photograph is the group of trees I'm

13 going to circle on the picture [marks].

14 The buses which were transporting the people

15 deported from the enclave towards Kladanj were passing

16 along this road, coming from the bottom of the picture

17 towards the top of the picture. So this is a very good

18 location to hide a grave here since no one can see from

19 the road what is happening behind this tree line.

20 The location of a small grave found here --

21 I'm going to mark it with an arrow [marks] -- is just

22 behind the trees on the right hand of this group of

23 trees, so hidden from the road.

24 Q. Exhibit 15/5 has now been placed on the

25 ELMO.

1 A. Yes. Exhibit 15/5 is just to show you what

2 happened when we went to probe this site in 1999, and

3 we discovered very soon on this site here is half of a

4 skull close to the bucket of this backhoe. This was

5 the first finding in this grave. The exhumation was

6 completed there and 19 bodies have been found in this

7 one.

8 Q. Mr. Ruez, now let's move to Cerska, which is

9 your presentation beginning with Prosecutor's Exhibit

10 16/1 or 16/A, I'm sorry. Again --

11 A. On this main exhibit, the valley of Cerska is

12 going from the asphalt road towards the hamlet of

13 Cerska. We had a situation here where several

14 witnesses talked about a series of events and the

15 pasting of their information finally enabled us to find

16 more about it.

17 Some people saw buses getting inside the

18 valley followed by an APC, and later on heard intense

19 shooting coming from the area. Another person managed

20 to cross that area during the night, didn't see the

21 previous event, but when walking along this path at one

22 point walked in a pool of blood. The person was

23 barefoot, saw a few bodies, and was scared, ran away.

24 Another group of people who had imagined to

25 pass and didn't know about the event were hiding on top

1 of the valley of Cerska after we [sic] had decided to

2 return to Srebrenica because they had no idea where to

3 go. On their way back they smelt a disgusting smell

4 and noticed an area of disturbed soil.

5 So the pasting of all this information

6 enabled us to go to the valley. We didn't initially

7 find anything suspect here, but it's a long valley and

8 the method to find the graves is not really a hundred

9 per cent efficient. It is picking with a probe in the

10 soil and then sieve the other to find out if there is

11 something underneath. So in such large place it is not

12 very easy to do.

13 Nevertheless, we filmed the entire valley

14 from the top to the bottom of it and presented that

15 film to one of the persons who walked down that area

16 one week after the events, and that person enabled us

17 to find the grave by pinpointing the area where he

18 remembered having seen and smelled the thing.

19 Q. Mr. Ruez, you want to commence your

20 demonstration by showing a video. If we could have the

21 lights dimmed and we could turn to 16/5 and show the

22 video. Mr. Ruez, narrate as you find appropriate.

23 A. There will be sound on the video. Mr. Peter

24 Nicholson, who was doing the video in 1996, will speak

25 on it.

1 [Videotape played]

2 A. So this was the intersection of Konjevici.

3 This is again the main hill we constantly refer to at

4 this moment. Here is the little intersection that

5 leads right to the valley of Cerska. We had another

6 view just before of this group of trees with the grave

7 behind it.

8 This is the dirt road that leads towards the

9 valley. No. Sorry. This is still the asphalt road

10 that goes, at this moment, from Nova Kasaba towards

11 Konjevic Polje. Here, on the left, is the entrance of

12 the valley of Cerska in which we're going to fly into.

13 As you can see, it's a narrow entrance. It

14 is also a bit -- on the side it's -- on the road it

15 seems to be a very remote place, and it is indeed a

16 remote place.

17 This follows the dirt road up to the site.

18 There is nothing there except destroyed houses, a few

19 destroyed houses. This valley was an area of intense

20 fighting in 1993 when the Bosnian Serb army crashed the

21 forces of the 28th Division in this area.

22 This was a little intersection which leads to

23 the village of Macesi, which is a destroyed village.

24 This is a view of the valley, towards the top.

25 This is first an area where we suspected an

1 execution having taken place, but we have disregarded

2 the information since we didn't find any shell casings

3 in the area which was designated as being the execution

4 site.

5 This is the location of the execution of ...

6 that was the area of scooped soil.

7 The date on the video is irrelevant. It

8 might be a correct one, but most of the time in 1996

9 the dates on the videos were not correct. So we have

10 to listen to what he says at the beginning in fact.

11 This is again the spot of the grave, and

12 we're going to exit the valley to show somehow remote

13 this location is.

14 MR. HARMON:

15 Q. Mr. Ruez, please continue with your

16 presentation.

17 A. The Exhibit 16/A was the map of the area

18 which pinpoints the precise location of the grave in

19 the valley of Cerska.

20 The exhumation was completed in 1996, and the

21 initial information was that three buses of prisoners

22 were taken for execution towards this valley. A

23 hundred and fifty bodies have been recovered in that

24 location.

25 The exhumation report will enable to

1 reconstruct the events on the spot and give all the

2 details of the cause of death and the bindings found on

3 these prisoners.

4 Exhibit 16/1 and 16/2 are the same, so I will

5 show immediately the 16/2. Among the numerous elements

6 which enable us to provide you with the certainty that

7 we are indeed talking about victims from Srebrenica,

8 July 1995, and not other possible victims in this area

9 or victims from events from other dates, this aerial

10 photograph shows the grave of the valley of Cerska

11 which we discovered. On the left of the photograph you

12 can see the ground dated 5 July 1995. There is no

13 disturbance on the ground. On the right of this

14 picture you can see the same location at 27 July 1995.

15 You have here a massive disturbance on the left side of

16 the road and also a smaller disturbance on the right

17 hand of this road. So the event is, without any doubt,

18 in between the 5th July 1995 and the 27th July 1995.

19 The next exhibit is 16/3. It summarises, in

20 fact, the video we just saw since all the observations

21 can be summarised on this one.

22 You have on the left side of the road the

23 area where the collection of shell casings is ongoing.

24 The area of shell casings, in fact, matches the size of

25 the graven which is on the edge of the road, on the

1 right of the picture, where currently people dressed in

2 blue are conducting the probe.

3 Where the vehicles are standing on the dirt

4 road, on the left of these vehicles is an area of

5 disturbance which is, in fact, soil which has scooped

6 away from this hill. An excavator entering this valley

7 was witnessed by a person approximately half an hour

8 after the three buses entered the valley, and that

9 excavator probably scooped away this soil and just

10 dumped the soil on top of the bodies which fell at the

11 edge of this dirt road towards the meadow which is

12 underneath, and they were just covered with the soil

13 taken from the opposite hill.

14 The Exhibit 16/4 is an additional summary of

15 that grave which shows at the bottom of the picture the

16 shoes and the legs which we exposed. On top of this

17 mound of soil, which is, in fact, the bank of the road,

18 is one individual that shows the location of the road,

19 and just at the top of the picture is the area where

20 the soil has been scooped away from the hill on the

21 opposite side.

22 Q. Now, if I could have the assistance of the

23 usher, and I'd like to present Prosecutor's

24 Exhibit 16/6 to Mr. Ruez, and have him take it out of

25 the envelope and explain exactly what it is.

1 A. This is a piece of wire which is, in fact, a

2 ligature for the wrists which was found on one of the

3 bodies exhumed from this grave. All the details will

4 come later about this, but in this grave -- as far as I

5 have on my note here, 48 individuals were ligatured

6 with this kind of ligature and other style of

7 ligatures.

8 Q. Thank you, Mr. Ruez. You can put that back

9 in the envelope and seal it.

10 We've completed our presentation on the

11 Cerska Valley. We will now move to the next exhibit,

12 Prosecutor's Exhibit 17, KP-2. Again, why don't we

13 start with the orientation first, Mr. Ruez, and will

14 you take us through this particular presentation?

15 A. The next site is a very small site but it's a

16 good example of -- sorry.

17 The next site we are going to go to is a very

18 small site compared with the one we have just exposed,

19 but it's a good indication of how multiple the events

20 were in this area. We have events of various scales,

21 executions going from one individual to obviously 150

22 individuals in this area. We know some of them. We

23 certainly don't know all of them.

24 I indicated yesterday that it's particularly

25 difficult to find small graves. We still have found

1 some of this. The site we are going to show now is at

2 the east of the intersection of Konjevic Polje driving

3 towards Bratunac, 1.7 kilometres east from this

4 intersection. So all these events are part of a kind

5 of package of events happening in this area.

6 Q. Mr. Ruez, if you would go directly to

7 Prosecutor's 17/2 and 17/3. I will explain the error

8 in 17/1 to the Court after you complete your

9 presentation.

10 A. Exhibit 17/2 is the map of the area --

11 Q. I'm sorry. That's 17/A.

12 A. Sorry. Exhibit 17/A is a map of the area,

13 scale 1:50.000. The circle marks the approximate

14 location of the grave, and the yellow dot on this map

15 is misplaced, it should be at the south of the picture,

16 which is the bottom of the map. Going towards

17 Bratunac, the site is to the right of the road, and

18 this spot marks the left.

19 In this location -- we managed to find this

20 location from an aerial photograph, which I will not

21 present, since the only feature to be seen on it is a

22 little disturbance under a tree line. We went to probe

23 the area, thinking it was a mass grave. We didn't find

24 a mass grave. But when we returned to continue the

25 probe, since there was really no reason for this

1 disturbance to occur there without anything to hide,

2 with some insistence we uncovered a grave which

3 contained one individual.

4 This is Exhibit 17/3. It shows that person

5 inside this grave. The grave was a pre-dug whole in

6 which, in fact, the person has been dumped into,

7 probably -- the person certainly -- probably didn't die

8 at this location. The causes of death of this

9 individual are multiple gunshot wounds.

10 On the next exhibit, which is 17/4 -- sorry,

11 17/2, one can see the skull of a person with a big hole

12 in it, but this hole might have been done when the body

13 of this man was moved with heavy equipment. Just

14 nearby it is another grave with two individuals in it.

15 The area of disturbance indicates that most probably

16 these persons were not killed on the spot, but killed

17 in the vicinity and then moved to this location,

18 probably in the bucket of an excavator, and then just

19 unloaded into these holes which already existed and

20 then left there, covered with soil.

21 Just an example to highlight the fact that

22 there are probably many of these small sites in this

23 area, but we will never find them.

24 MR. HARMON: Mr. President and Your Honours,

25 there's been a photograph that has been placed out of

1 order that belongs in Prosecutor's Exhibit 8, and that

2 is the first photographic exhibit, Prosecutor's 17/1,

3 and I will have Mr. Ruez explain to you the location

4 that's relevant in this particular photograph, which is

5 the Kravica warehouse. We will spend just a minute to

6 correct the error on this.

7 Q. Mr. Ruez, if you would inform the Judges of

8 the importance of this photograph and the location of

9 the Kravica warehouse, we can then move on.

10 A. Yes. On this photograph, it is a view from

11 the west towards the east, and you can have a good view

12 here of the Kravica warehouse, which I circle [marks],

13 which enables us also to have a view on the tree line,

14 which is just behind the warehouse, and also on the

15 open meadow, which is a corn field which is behind the

16 warehouse.

17 It also gives a view of the hill, which is on

18 the right of the picture, south on the map, where you

19 can see the power line that people were following. Not

20 necessarily in this location, but this power line

21 continues towards Konjevici, and I'm going to just draw

22 a line along it [marks]. That's the power line. There

23 is a little path going uphill, and then at this power

24 line, there's more open ground. This power line goes

25 towards Konjevici.

1 MR. HARMON: So this exhibit, Mr. President

2 and Your Honours, should be considered in conjunction

3 with the other exhibits in the Prosecutor's series

4 commencing with 8.

5 Q. Now, Mr. Ruez, we can turn our attention to

6 the next part of your presentation, which is commencing

7 with Prosecutor's Exhibit 18. Would you orient the

8 Judges, as we normally do, and then inform the Judges

9 about this particular area.

10 A. Among the numerous events which happened in

11 this area at the moment people were surrendering, one

12 event is that persons who were surrendering in the

13 vicinity of Konjevic Polje were first taken towards

14 various buildings in this area, including the

15 guardhouse of the 5th Engineer unit, which was

16 billeting in the area of Konjevic Polje. Destroyed

17 houses. One hangar, which is visible on photographs

18 dated 1996 and on aerial imagery dated 1995, was then

19 transformed into a gas station.

20 When these people surrendered, at least one

21 of them, together with 15 others, were taken on board

22 of a bus and driven north towards the canyon of

23 Drinjaca, which is the entrance towards the Drina

24 River. The bus stopped on the right-hand side of the

25 road, and then the people were marched towards the bank

1 of the Jadar River, where they were immediately

2 executed as soon as they arrived at the edge of the

3 river. One of them managed to survive and provided us

4 with information.

5 Unfortunately, in terms of possibilities to

6 conduct forensics here, it is impossible, since the

7 river has changed in its flow and all the evidence has

8 probably been washed away. We couldn't find any shell

9 casings. But there were big wood logs blocked by other

10 trees which clearly show that the river, at one point,

11 was probably nearly a metre higher than it was when we

12 came there. So all the shell casings in the vicinity

13 of the place the person thought was the execution site

14 had been washed away, we didn't find anything, and we

15 didn't insist much on this one, since it was obvious

16 that we would not be able to find anything.

17 So the film you're going to see will only

18 indicate the reference points that the person had,

19 which is a huge cliff, on top of which was previously a

20 mosque; a parking spot for a bus, which for him is a

21 reference point of where they were then unloaded from

22 the bus and taken towards the river.

23 This footage will also show the difference of

24 ground between the area south and the area north in

25 which we're going to enter now. It's quite a

1 significant switch in the area. The landscape between

2 the south and the north is extremely different because

3 of the Drina River, and also this gives a feeling, once

4 you pass this place, of being in a completely different

5 area. So not only is it efficient to move people away

6 from here, towards the north, in order to avoid some

7 witnesses who could report about the events of what is

8 happening in the south, like the UN soldiers who were

9 still continuing to move in that place, but even

10 psychologically to give the feeling that you are

11 entering another world as soon as you have passed this

12 canyon. So you will see that on the video, and we will

13 return to that small piece later.

14 Q. If the audio booth could play us the

15 Prosecutor's exhibit which is marked 18/2, we can

16 proceed.

17 A. Exhibit 18/2 is a photocopy of the map of the

18 area -- do we have the video?

19 Q. Yes.

20 [Videotape played]

21 A. So this is the road that goes from Konjevici

22 towards Zvornik and which at this moment is entering,

23 what we call, the canyon of Drinjaca. It is the

24 intersection of the Jadar River and Drinjaca. This is

25 still the Jadar River. Here is the cliff, on top of

1 which is a white ruin which was a mosque. On the left

2 of it is the road.

3 Just here, after this curve, here is a

4 parking lot where a bus is standing. The location

5 where the person indicated the bus was standing is on

6 the right-hand side of the road, a bit more there. And

7 also there is another ground feature which we could

8 find which is a concrete water reservoir, which is

9 nearby these buildings which are the former territorial

10 barracks, where the person who survived the execution

11 then stopped to heal his wound. These are the former

12 barracks of the Territorial Defence in the area, and

13 used at the time of the events.

14 So Exhibit 8/1 [sic] marks the precise spot

15 where the event took place.

16 MR. HARMON:

17 Q. That's 18/A; is that correct?

18 A. Exhibit 18/A. And Exhibit 18/1 is a view of

19 the cliff which is the reference point for this area,

20 and the parking lot for the bus is approximately 100

21 metres further on this road, driving in the direction

22 we are driving on the picture, which is from south to

23 north. So this is more or less the vicinity of the

24 execution site which is close to the river. I didn't

25 show any pictures since, aside from the rubbish hanging

1 from the bottom of trees that shows the difference in

2 the height of the river, there is not much that I would

3 be able to show you on this site.

4 Q. Mr. Ruez, we're now going to proceed to the

5 Grbavci school, which commences at Exhibit 19, and

6 we're going to move north from the events in the

7 Srebrenica enclave at this point. Can you approach the

8 large map and explain to the Judges where we're going

9 and what these events relate to?

10 A. We're now, in fact, entering the new phase of

11 this expos‚ and entering the heart of the subject here.

12 [Microphone not activated]

13 A. As I said, we are now entering a new phase of

14 the expos‚ and, in fact, also a new phase of the

15 events. All that I've been explaining until now are

16 the events which happened in what we call "the area

17 south." These events are a lot of killings happening,

18 for sure, but not in a very organised fashion, if one

19 can say so. From now on, we are going to talk about a

20 process which is formally organised and structured, as

21 you will notice.

22 We are now in a situation where we are in the

23 night of the 13th to the 14th, where all the people who

24 have survived the events we have unfolded in these last

25 days, all of them are in Bratunac town. All the people

1 who survived that process are now in Bratunac town, and

2 the evacuation of these prisoners towards the execution

3 sites is starting on the 14th, in the first hours of

4 the day.

5 The first convoy filled with men takes the

6 direction of Zvornik, with a promise of exchange given

7 to them by General Mladic when he came to the warehouse

8 where these people were jammed inside, many of them

9 killed during the night through beatings and treatment

10 like this. The survivors of this warehouse, the

11 majority of them -- because it was not on the

12 extermination site, it was just a killing site -- all

13 these men were then taken in a column of buses and

14 trucks towards Zvornik, where they turned left,

15 thinking they would reach the zone of separation that

16 leads to Tuzla for exchange, but then turned right and

17 were stopped at a school where they had to enter the

18 gymnasium of a school.

19 During the day, the gymnasium filled, and at

20 some point, the execution of all these men started, as

21 we are going to develop through the exhibits.

22 First I will show you Exhibit 19/A. Exhibit

23 19/A is a photocopy of a map of the area. On this map,

24 one can see -- this circle indicates the approximate

25 area where the school is. The green dot inside the

1 circle marks the position of the Grbavci school. As

2 you can see, there is no where written "Grbavci".

3 There's a hamlet here. You can see "Lazete" and

4 "Lukici," but the name of the school is the Grbavci

5 school. Just above where it is written "Lukici," you

6 can see "Grbavci Donji," so the area of Grbavci. This

7 is why the school is named the Grbavci school.

8 On the left, you can also see Orahovac, which

9 is a little village, not to be confused with the same

10 village or the same area in Kosovo; this is a very

11 different situation.

12 What you can also see on this map is a

13 railroad line, which is marked on this map and which

14 comes from this direction [indicates], towards the

15 north. This railroad line exists on this map, but it

16 did not exist on previous maps, and this was an

17 important feature on the ground to recognise the area.

18 I will say a few words about this later.

19 I'm going to show now the next exhibit, which

20 is the school, Exhibit 19/1. This is a photograph of

21 that school taken in January 1996. You can see a part

22 of a building, but with the main elements, which is,

23 just in front, on the right, the school itself. Then

24 at the left of the school, the white construction is

25 the gymnasium in which the men were held.

1 We only know about the gymnasium as a

2 detention site, since all the four men who survived the

3 following execution were, all four of them, taken to

4 the gym. They didn't arrive at the same time of the

5 day. The gym stated to fill in in the morning,

6 continued to fill during the day, convoy after convoy,

7 until it was completely full and only then the

8 execution started.

9 An important element on this picture is right

10 in the middle of the picture. In between the gym and

11 the school is a high fence which runs along the wall of

12 the school towards the entrance, the small entrance.

13 The main entrance being on the main building, but the

14 prisoners took the entrance that goes to the gym, where

15 once inside it leads either right to the school or left

16 to the gym.

17 I'll show the next exhibit, which is 19/2.

18 This is a photograph which was taken in 1996, in May,

19 and this one is another view of the gymnasium with the

20 playground on it. It has also the interest to show the

21 access for the buses and trucks. The fence here is

22 destroyed, as you can see in the middle part of the

23 picture, and the trucks and -- or the trucks parked on

24 the playground. The people had to disembark there and

25 then had to abandon their clothing nearby the fence

1 before entering the gym.

2 You will also see on this picture, and I'm

3 going to circle it now, the exit door of the gymnasium

4 [marks]. The construction that I'm going to mark on

5 the photograph [marks]. This is the wardrobe of the

6 gymnasium. This is the room where the people went

7 through, got blindfolded, received a little sip of

8 water, and then were taken on board of the little TAM

9 trucks towards the execution site. This is the exit.

10 The entrance, I'm going to mark it with an

11 arrow [marks]. The entrance is here.

12 The next photograph is 19/3. It is a closer

13 view of the access to the gym. The photograph also

14 dated January 1996. Again you can see the fence

15 running along the wall of the school on the right of

16 the picture. This fence leads to the entrance which

17 I'm going to circle [marks].

18 The main building behind the white structure

19 is the gymnasium and the small building in front of it

20 is the wardrobe. On the left part of this little

21 building is the wardrobe.

22 Before showing the next photographs, the best

23 would be to first view the film.

24 Q. If we could dim the lights and show

25 Prosecutor's Exhibit 19/12.

1 [Videotape played]

2 A. So we are again in the canyon of Drinjaca

3 here. We have passed the area where previously the

4 event had taken place. The shiny zone in the middle of

5 the picture now is the Drinjaca River which is going to

6 enter the Drina River, which you can see on the film at

7 the moment. This is to you an indication of the

8 landscape. To give you an indication of the distances,

9 the best would have been to show you a film where we

10 travelled by road but this would have been really

11 boring. From now on we are travelling only by

12 helicopter. The crime scene is so large this is the

13 only method to give you a feeling of the place.

14 On the opposite side of the river, on the

15 right hand of the river you have the Federal Republic

16 of Yugoslavia, the reason why the helicopter is only

17 flying on the left. I won't be able to show you the

18 entire road because the road would just be underneath

19 the helicopter.

20 This is again the Drina Valley going north.

21 This is the Dam just before arriving in Zvornik, and

22 the road on the left is going along this river. Here

23 we have passed Zvornik. We are flying towards the

24 Grbavci School. On the left is the railroad line that

25 goes towards Zvornik, and you can see there are

1 tunnels. There were tunnels along this -- the railroad

2 line was passing inside a tunnel. There are several

3 bridges also in between Zvornik and Grbavci.

4 The railroad line is the main reference point

5 for the people who survived the execution there. They

6 didn't know where they were. We managed to find the

7 area following their description and by finding a piece

8 of map which had indeed at the time the railroad marked

9 on it. Following this discovery, we could then request

10 additional elements and make a request for imagery to

11 pinpoint the location of the site.

12 This is the Grbavci School. You can see the

13 fence on the right and the entrance. That's where the

14 people had to abandon their clothing and personal

15 belongings.

16 This gymnasium was completely filled with men

17 except on the left part of this gym. On the right part

18 here there was an opening space, a free space. All the

19 rest was filled with men. Many of the men were men

20 separated in Potocari and many of them were old men

21 separated in Potocari. A few kids also have been

22 separated and were in a specific part of that gym. We

23 initially thought that the kids had been spared in this

24 operation, but as you will see in the exhumation

25 reports, the bodies of the youngsters have been found

1 in Glogova.

2 JUDGE RIAD: There holes in the wall?

3 THE WITNESS: No. There are no -- yes.

4 There are a few bullet holes which I will show you on

5 still photographs.

6 The selection of the pieces of cloth that we

7 kept was done according to the colour and texture. So

8 it was a representative sample of, in fact, all the

9 rest which was found in that location.

10 This is not the entire film but it's a

11 summary of it. Many shell casings were found in the

12 area, but there was no execution, as far as we know,

13 happening at that school. The people were not

14 mistreated in this school. They were waiting all day

15 long. Soldiers were from time to time shooting inside

16 the gymnasium but above the people, towards the windows

17 or towards the ceiling, just to keep them quiet.

18 Because when they were starting to talk, with the

19 numbers it was making too much noise and the soldiers

20 wanted them to stay quiet. Aside from that, there was

21 no beating and no murders reported in this location.

22 That school --

23 MR. HARMON:

24 Q. Mr. Ruez, before you continue with your

25 presentation, it's time for a pause and you will

1 continue after.

2 JUDGE RODRIGUES: [Interpretation] Yes,

3 Mr. Harmon. We are going to have a 20-minute break,

4 and after that we will proceed. Thank you.

5 --- Recess taken at 10.51 a.m.

6 --- On resuming at 11.15 a.m.

7 JUDGE RODRIGUES: [Interpretation] Yes,

8 Mr. Harmon. You can move on, if you like.

9 MR. HARMON: Mr. President, I will await the

10 arrival of the accused.

11 [The accused entered court]

12 JUDGE RODRIGUES: [Interpretation] I'm sorry.

13 My mistake. Thank you very much.

14 You may be seated, Mr. Krstic.

15 Mr. Harmon, you may continue.

16 Q. Mr. Ruez, when we left, you were in the

17 middle of your presentation on the Grbavci school.

18 Will you please continue with your presentation?

19 A. Yes. One thing I wanted to comment about on

20 this film is all the shell casings and the other

21 military devices which could be found there, like the

22 Caterpillar tracks. There were more of these

23 Caterpillar tracks in the trash site. All these gas

24 canisters. All these items are not necessarily related

25 to the executions which followed or to the precise

1 events which happened in the gymnasium. This school,

2 we have the knowledge that it was used on a regular

3 basis by both the army and the police, who were coming

4 in and coming out of that location, more or less at

5 will, during the entire period of the war. So this

6 material could be totally unrelated.

7 The material which we believe is related to

8 the next series of events is the presence of these

9 blindfolds at the school.

10 I will now present to you Exhibit 19/4,

11 which, when entering the gymnasium, this is the wall on

12 the left-hand side. The interesting things on this

13 picture are the windows on the top left of the picture,

14 running along the wall at the top of the picture. It's

15 a feature recognised by the people. And in the middle

16 of the picture, where I'm going to mark the arrow

17 [marks] is the exit to the wardrobe, and when turning

18 right here is the exit through the wardrobe, to the

19 concrete playground outside.

20 The next photograph is 19/5, which had also

21 been used before we could bring people back to these

22 locations, to identify the place. And this row of

23 windows is also an element that people can recognise.

24 Photograph 19/6 is a photograph of one of

25 these windows, which is running along the right wall

1 when entering. As you can see, there are holes in the

2 window. I'm going to mark them; one here, another one

3 here, another one here, and another one here [marks].

4 This could be a result of the shooting that happened

5 from time to time inside the warehouse, when the guards

6 wanted the prisoners to be quiet inside --

7 Q. Mr. Ruez, you said "inside the warehouse,"

8 you mean "inside the gymnasium."

9 A. Sorry. Inside the gymnasium; that's

10 correct.

11 One could consider that since this is a

12 school, children are playing, and the fact is that

13 sometimes children throw stones at windows. It would

14 be, indeed, quite hard to see the difference between a

15 stone and a bullet. Despite what one would think,

16 sometimes the result is very similar. That's the

17 reason why I'm going to show you the next photograph,

18 which is 19/7, which is the ceiling of the gymnasium,

19 metallic ceiling, where you can see here a bullet hole

20 also [marks]. This one is a bullet hole.

21 The following photograph is 19/8. This is

22 the only photograph of this type which is dated 1999.

23 It is a photograph which we took when we returned to

24 this location with two of the people who survived the

25 events here. On this photograph, you can see both the

1 entrance of the gymnasium, which is the door I'm going

2 to mark number "1" [marks] and the exit of the

3 gymnasium, which is the access to the wardrobe, which

4 is number "2" [marks].

5 The approximate position where the people

6 were sitting, I can only tell you for two of them,

7 since two could not join the mission where we returned

8 to this location, one was sitting here [marks],

9 position "A"; another one who arrived earlier was

10 sitting here [marks].

11 The gym started to fill, starting from the

12 bottom of the picture towards the entrance, and once it

13 was full, the evacuation started through this wardrobe,

14 where there was a bucket of water. The people were

15 given a sip of water, and there was a stack of

16 blindfolds of various colours; in fact, several stacks

17 which were, according to the people, dumped in the area

18 nearby the exit.

19 Q. Mr. Ruez, would you put the letter "B" above

20 the second location where the individual was sitting?

21 A. [Marks]

22 Q. Thank you.

23 A. The following picture is 19/9. This

24 photograph is dated January 1996, and on this one, we

25 can see the exit of the wardrobe. There are a few

1 steps. No one is talking about going down steps for

2 the reason that the truck which was parked nearby this

3 exit had a kind of ramp at the back, so that the people

4 accessed directly the truck from the wardrobe. So no

5 one has a recollection of having climbed down a few

6 steps. This is the only time we could take this

7 photograph. Later on, this opening has been walled.

8 Exhibit 19/10 is a photograph of one of the

9 pieces of cloth we collected there. We will have later

10 on a presentation about the connections that were made

11 based on these blindfolds. The analysis of all the

12 blindfolds collected both at the school, in the primary

13 graves and in the secondary graves, all this material

14 is currently being handled by a judicial laboratory in

15 order to make connections between these blindfolds and

16 connect the sites each with another. The reports of

17 these connections are still not provided -- yes, they

18 have been provided, just recently then. They are

19 ready.

20 Q. Now, Mr. Ruez, if you would turn your

21 attention to Prosecutor's 19/11, which is a very

22 important exhibit, and take your time explaining this

23 particular exhibit.

24 A. So this exhibit is going to already introduce

25 the next site, which is the execution site also. It is

1 an aerial photograph which was taken in 1998. It's a

2 series of pictures shot from a helicopter by the

3 SFOR-ICTY liaison officer at the time.

4 It creates a panorama which enables us to see

5 both on the right of the picture the school and on the

6 left the site. I'm going to pass it under the ELMO.

7 Q. Would you circle with a pen the particular

8 features of importance.

9 A. I will have to use another one. First at the

10 extreme right of the photograph, the first circle is

11 going to be the school [marks].

12 Q. Put a letter, please, Mr. Ruez, or a number

13 next to that.

14 A. Letter "A." On this photo you can recognise

15 the main building of the school. We have no indication

16 of the presence of prisoners in this school. Not that

17 we are sure that no one was kept inside, it's only that

18 we don't have any report about people who might have

19 been kept inside. The survivors have all been kept

20 inside the gymnasium, not inside the school. So we

21 have no information about what happened inside the

22 school. The important location for us, therefore, is

23 the gymnasium on which I'm putting an arrow [marks].

24 One other important element on this

25 photograph is that you can see the railroad which runs

1 in that direction towards Zvornik [marks], and in that

2 direction there is a series of bridges passing above

3 the road that goes from Zvornik to Tuzla. There is

4 also a tunnel, which is approximately 300 metres long,

5 a few kilometres in the direction of Zvornik. These

6 are elements that people might talk about, since for

7 them it is reference points to try to identify where

8 they are. And they can get mixed very easily about the

9 situation, since if you take the opposite direction,

10 which is then the direction going north, this railroad

11 line will make the tour of a hill, take the direction

12 west and will arrive at a very long tunnel, which is

13 4.7 kilometres long, which is called the Kirizevici

14 tunnel.

15 I say all this because one witness is very

16 confused about this situation and believes he went

17 through the Kirizevici tunnel, which would have led him

18 directly towards the confrontation line and to his

19 capture. In reality, he went through a bridge which

20 was about 300 metres long. He went in the direction

21 south towards Zvornik, but he doesn't know that. I

22 never told him yet.

23 If we start from the school and follow the

24 road towards the left of the picture, which is north on

25 the ground [marks], that is the road followed by the

1 trucks carrying the prisoners to the execution field

2 was taking, arrived at this intersection here. The

3 vehicle turned, took the dirt road. The reason why

4 people say that at the end of the track it was bumpy,

5 they take this dirt road, they pass under the railroad

6 line where there is an underpass here I'm going to

7 circle [marks], and then the truck stopped somewhere in

8 this area here, which is the beginning of the execution

9 site, the first execution site. We call this place

10 LZ-2. The reason is initially we called that area

11 Lazete. As you could see on the exhibit which is the

12 map of the area the place where the Grbavci school is,

13 the hamlet is named Lazete. The reason why is in 1996

14 we called this site Lazete.

15 This one is Lazete-2, and the size of the

16 meadow here on this photograph would be like this

17 [marks]. This would be the area of the execution

18 site. It continues like this [marks], and it is also

19 the area of mass graves located here.

20 Q. Mr. Ruez, would you move that up so it's

21 more -- thank you very much.

22 A. Once the executions were over on this part,

23 the executioners moved to another site which is, in

24 fact, here [marks]. We initially called that site

25 Lazete-1. The reason is that we thought that the logic

1 will be that the first site used was the one closest to

2 the school, and then when the time it came to switch

3 sites, they moved to the second site. The reality is

4 exactly the opposite, and we could determine that only

5 by bringing the witnesses back to the site.

6 One main interrogation here was how could it

7 be that people who are inside the gymnasium, which is

8 very precisely 800 metres away from the site we call

9 Lazete-1, how could it come that since the execution

10 lasted all the afternoon and the evening, the people

11 who were still inside the gym after the beginning of

12 the execution didn't hear the sound of the execution?

13 The reasons for that are, in fact, quite simple.

14 Reason number one is that inside the

15 gymnasium, people were speaking. So there was constant

16 murmur inside covering noises. Also the fact that the

17 soldiers, some from time to time shot in the air to

18 make the people stop making this noise, creates a

19 buzziness in the ears that also can weaken their

20 ability to hear. But the main reason is that the site,

21 Lazete-2, once you pass under the railroad line, this

22 is quite a high elevation of soil on, in fact, which

23 the railroad is constructed, and this most probably

24 creates a natural sound barrier. So the Lazete-2 site

25 indeed is not far away, in terms of air distance, from

1 the gymnasium, but it is very possible that the sound

2 is very much weakened by this elevation of the ground.

3 An additional site to pinpoint on this

4 photograph, which will make also the aerial ones more

5 easy to understand, once having passed the railroad,

6 through the underpass, the path continues a little bit

7 uphill and then turns towards this direction, and very

8 precisely here is a place I'm going to mark "B." This

9 will be "B." This will be "C" [marks], which is a

10 garbage dump site.

11 Q. So the dump site is where you marked the

12 letter "C"?

13 A. Yes. Where I marked the letter"C" is a

14 garbage dump site. We will see more details about this

15 dump site in the film we will see very soon.

16 Before viewing the film, we might first get

17 through the first photographs of the second one.

18 Q. Well, that concludes the presentation, does

19 it not, on Exhibit 19, which is the Grbavci school?

20 Now we're going to turn the execution site and the

21 presentation about that; is that correct?

22 A. That is correct.

23 Q. Very briefly, if you could point the

24 execution site out on the large map and then proceed

25 with your demonstration.

1 A. So we have just talked about the Grbavci

2 school, which on the main map is pinpointed with the

3 symbol concentration spot for prisoners, and the site

4 we are now going to go to is, as I said, 800 metres

5 away from the Grbavci school and consists into two

6 execution meadows and two areas of mass graves which

7 are marked with the symbol red dot execution site and

8 mass grave attached to it. This mass grave, as you can

9 see on this symbol, is a disturbed one.

10 Exhibit 20/A marks the area of the site on

11 the map. The cross [marks] is a more precise

12 pinpointing. I marked a cross inside the circle to

13 more precisely pinpoint the location of these two

14 execution sites and mass graves.

15 Q. Mr. Ruez, shall we show the film which is

16 Prosecutor's Exhibit 20/16?

17 A. Yes. But, in fact, before that, showing

18 the -- more sense now to show the Rule 70 pictures.

19 Then we'll have better reference points for the video.

20 I won't show the 20/1 since it is exactly

21 same one as the 20/2. Sorry. The 20/2 is the same

22 photograph as 20/1 but has markings on it. So I will

23 show directly this one.

24 So on this photograph, first of all, the one

25 on the left is a photograph dated -- my photograph

1 doesn't show the two sites.

2 Q. 5th of July?

3 A. Yes. In fact, we should show the film now.

4 I didn't realise I broke it into two sides. We have to

5 show the film now and return back on each of them.

6 Q. Could we have the lights dimmed and could we

7 play 20/16.

8 [Videotape played]

9 A. So this is again the Grbavci school, and

10 we'll fly towards the execution site. The road going

11 to the left is the road leading towards the execution

12 site.

13 I forgot to pinpoint that just in front of

14 the site on the left of the picture now you can see the

15 railroad line, and on the photograph on which I had

16 marked some details, there is one detail to be marked

17 also, which is a construction just next to this

18 railroad line and which is what one person thinks is a

19 railroad station, in fact. It's a construction just

20 next to the railroad.

21 Here we are arriving towards the site. You

22 can see the little dirt road that goes towards the

23 railroad line here. The main house in the middle of

24 the field. Behind it was the railroad line. Here is a

25 short view of the site behind it.

1 This is the Lazete-2 execution and mass grave

2 site.

3 William Hagland is describing the piece of

4 evidence found there, human residues and clothing. The

5 underpass.

6 No. It's not finished. This is the garbage

7 dump site. Unfortunately, rotten documents.

8 In fact, we can stop here. There are a few

9 other items which are not very significant.

10 Q. All right.

11 A. There is the cane of an old man, there is

12 some live ammunition, and things like this. That's

13 fine.

14 Q. All right. We can raise the lights and stop

15 the video, and Mr. Ruez, then, please continue with

16 your presentation.

17 A. I'm returning to Exhibit 20/2.

18 Q. Exhibit 20/2.

19 A. Exhibit 20/2, which first shows the ground,

20 dated the 5th of July, 1995, and then shows the site as

21 it looked on 27 July 1995. We have two massive areas

22 of disturbance which were created in between these

23 dates. We believe that they were created, in fact,

24 during the night of the 14th to the 15th, since heavy

25 equipment was operating on the ground at the moment the

1 execution was going on, and the executioners continued

2 the operation, using the lights these of excavators.

3 The Lazete-2 site is the first site where the

4 execution took place and Lazete-1 is the one which was

5 used afterwards. The reason why we believe that this

6 is the chronology that happened is that the witnesses

7 all mention that the meadow was full -- covered with

8 bodies, entirely covered with bodies. So initially we

9 wondered how this could be possible, that the Lazete-1

10 site had been the first site, since the meadow is

11 extremely large and it's more or less impossible to

12 completely cover it. The second site, it's absolutely

13 feasible, it's not such a large site. So once the

14 Lazete-2 site was, indeed, completely covered with

15 bodies, the executioners decided to switch sites, made

16 a command to take the ammunition box, and went to the

17 other one.

18 The other one is -- first of all, this

19 Lazete-2 site has been fully exhumed in 1996. I don't

20 have the figures with me. The site has been totally

21 disturbed, but on this one, like in all the other ones

22 which have been disturbed, those who did the

23 disturbance did a very sloppy job and forgot, each

24 time, a significant number of bodies. In this site,

25 the precise number will be given to you. It is

1 approximately 100 bodies that had been forgotten by

2 those who erased this grave.

3 Photograph 20/4 is a panorama view of the

4 Lazete-1 site which has not been exhumed yet. We

5 intend to exhume this site this year.

6 THE REGISTRAR: [Interpretation] Sorry to

7 interrupt you, but what's happening with Exhibit 20/3,

8 please?

9 THE WITNESS: Sorry.

10 A. Exhibit 20/3 is another view of the site. In

11 fact, in one piece of the photograph which was used to

12 create the panorama, you can see in colour the

13 situation which can be seen on the black and white

14 aerial photographs, where you can see -- you can

15 compare this one and the aerial photograph, the style

16 of disturbances.

17 As an example, here you can see clearly track

18 marks from wheeled excavators [marks] and you can

19 compare these traces with the ones you can see on the

20 aerial imagery in black and white, they are perfectly

21 similar. Here, again, you have a dump site, you have

22 the underpass, and a piece of the Lazete-2 site.

23 Exhibit 20/4 is a view of the Lazete-1 site,

24 seen from the railroad. This house did not exist in

25 1995, it was a ruin in 1995. But there was a house

1 there, and you will hear details about a water pipe

2 which was running from that location towards the site

3 and which was probably severed during the disturbance,

4 and the piece was found in a secondary site -- nearby a

5 secondary site.

6 The Exhibit 20/5 is a view from the railroad

7 line, just above the underpass which leads from the

8 Lazete-1 site towards the Lazete-2 site, and this is

9 the path that leads to the so-called dump site, the

10 path going a little bit uphill and then turning left.

11 We won't show you any pictures, but going a little bit

12 further up, there was the body of a man lying on the

13 ground. We could think that he could come either from

14 the execution or any other situation; therefore, we do

15 not develop on him. He was just lying on the ground,

16 and the peasants living nearby were driving over his

17 body every day.

18 Exhibit 20/6 is a view from the operation we

19 did on the dump site which shows all the items which

20 were collected there -- not all of them were

21 collected. Only the blindfolds were collected for

22 further selection.

23 The photograph, Exhibit 20/7, is a view from

24 the back of the site on which one can clearly see the

25 Lazete-2 site with a specific shape, and one can assess

1 its size very well from this picture. I will mark the

2 location [marks]. This is the size of the area, and

3 this area which we will see on another photograph, was

4 probably the "rest area" for the execution team.

5 Q. The area you've marked on the right-hand side

6 with the image --

7 A. I will mark completely with red. This is an

8 area, we think it is a "rest area" for the reason that

9 here is a place where we found little labels of boxes,

10 packaging casings. So this is the location where they

11 were reloading the magazines of their weapons. It is

12 also a location where, behind the tree line, we found a

13 box of 1.200 rounds of ammunition, an empty box and

14 also two bottles, empty bottles lying there which could

15 be there or could have belonged to the perpetrators.

16 The other site, Lazete-1, is also clearly visible on

17 the picture, and I'm going to circle it.

18 Q. I'm sorry. Just slow down a little bit.

19 Thank you.

20 A. Exhibit photograph 20/8, on the -- just in

21 front of the picture, on the right of the picture is

22 the area of the execution site and the grave, and in

23 front is the area which is taped with yellow tape here

24 [indicates] is the so-called rest area. The area where

25 I'm going to put an arrow [marks] is the area where we

1 found the ammunition box. Here you can see that the

2 reference point which you had on the video, which is

3 the underpass, the excavation of the first remains

4 which were found there, were approximately just here,

5 in the middle right of the photograph [marks]. All the

6 yellow markers on this photograph mark either elements

7 of clothing, bones, or casings.

8 Exhibit 20/9 is a photograph of the

9 ammunition box which was found close to the so-called

10 rest area. It was piece of evidence number 31.

11 Exhibit 20/10 is a photograph of a label on a

12 carton box, which indicates that this is related to

13 ammunition of calibre .762. We think it is a packaging

14 of ammunition inside a box, and I will show you on the

15 next exhibits how, in fact, this style of ammunition is

16 packaged.

17 Exhibit 20/11 is a photograph taken in June

18 1996, at the top of the valley of Cerska, and the

19 village of Cerska is unrelated, but it shows a wooden

20 ammunition box which contained .762 ammunition boxes

21 inside this big box. And inside these kind of boxes is

22 an aluminium box, the same one that we have found on

23 the site, and within this aluminium box, when you open

24 it, you have the ammunition packaged in small carton

25 boxes. Every one has a little label. This is the same

1 style of elements that we could find on the meadow.

2 Exhibit 20/13 is a part of the Lazete-2 site

3 as it was when we first approached that site, and these

4 markers are marking bones, human bones.

5 The two next ones, 20/14 and 20/15, assembled

6 together can form a panorama. The 20/14 is taken from

7 the railroad and shows the -- at the left hand, the

8 west where Lazete-2 site is. Lazete-2 site would be on

9 your left, looking like this, in this direction. The

10 area of this photograph, is, in fact, to reach the

11 second one, 20/15, which is the same view but right

12 hand. This is an area that a witness recognises as --

13 he went on top of the railroad and later on snuck

14 towards a corn field which led him towards an area

15 where he could hear water flowing, and, indeed, there

16 is a little brook flowing just behind this tree line.

17 He believes that the corn field on the right hand of

18 this picture is still the same corn field through which

19 he snuck. This photograph is dated 1999. There will

20 be a next one to be put on the right of it which shows

21 that this corn is rotting on the spot since years. It

22 could very well be, indeed, the same corn field he went

23 through at the time of the events.

24 Q. Mr. Ruez, that completes your presentation on

25 Grahovac. We are now going to move to the Petkovci

1 school. If you would approach the large map and orient

2 the Judges, please.

3 A. That same morning of the 14th of July, 1995,

4 when the men started to be evacuated from Bratunac in

5 columns of buses and trucks towards the final

6 concentration spots and execution sites, groups of men

7 were taken, at the same time the operation was being

8 conducted at Orahovac, the same operation was being

9 conducted towards Petkovci. Convoys were driving these

10 men towards Zvornik, Karakaj. They passed Karakaj,

11 turned left towards the school called Petkovci. It was

12 the same day, the 14th of July, 1995.

13 Exhibit 21/A is the map of the area where you

14 can see the road that goes from the Petkovci school,

15 towards Karakaj and Zvornik.

16 The next exhibit, 21/1, is a view, photograph

17 99, a helicopter view of the Petkovci school, seen from

18 the front, from the road that goes from Petkovci

19 towards Karakaj, and also goes towards the Dam. The

20 access is done through that path which I'm going to

21 mark [marks], and behind that is a concrete playground

22 and also a white construction, which I'm going to

23 circle as "A"; the school will be "B" [marks].

24 Photograph 21/2 is a view of a construction

25 which was marked "A" on the previous exhibit and which

1 is a construction which is immediately recognised by

2 one of two survivors of this location. Aside from the

3 fact that it's an element of identification, there is

4 no knowledge about any criminal event on this spot.

5 Exhibit 21/3 is the same school but seen from

6 the back, where one can see again the playground, which

7 is also a kind of parking lot. There is no gymnasium

8 attached to this school. The only school in this area

9 which has a gym attached to it is the Grbavci school.

10 This is the element that initially led us to identify

11 that place, since teachers who operated in that place

12 knew that the only school in the area of Zvornik with a

13 gym attached to it was the Grbavci school. This one,

14 for example, has no gym. But it has recognisable

15 details.

16 When the prisoners were taken towards that

17 place, they were unloaded from the trucks on this

18 parking lot, and then they had to walk downstairs, in

19 between two rows of soldiers beating them.

20 Exhibit 21/4 shows the stairs which access to

21 the school. The entrance of the school is the door on

22 the right of the photograph.

23 The Exhibit 21/5. These photographs are

24 dated 1997. We could not visit the place -- we visited

25 the place very briefly in 1996 but could not stay

1 because of the pressure of refugees who were staying

2 inside. So we returned in 1997. It was emptied of

3 refugees, and we could take additional pictures and

4 make observations inside.

5 This is a very specific designed staircase

6 inside the school, which had been described by the

7 survivors before even coming back there and was

8 immediately recognised by them once they got inside.

9 The place had no problem at all in terms of

10 recognition.

11 These are the class -- this is the hall

12 leading to the schools on the first floor of the

13 building. The two survivors from this location were

14 kept inside classrooms on the first floor. They

15 strongly believe there were also people on the ground

16 floor. This is one of the last ones on this corridor

17 which was used for these people.

18 This is the view of the inside --

19 JUDGE RODRIGUES: [Interpretation] Sorry for

20 interrupting you, but for the record, you have to say

21 that this is Exhibit 21/6, isn't it?

22 A. [Previous translation continues] ... which

23 shows the hall of the first floor leading to the

24 classrooms on the right of the photograph.

25 The Exhibit 21/7 is the inside of the

1 classroom, which is at the end of this corridor the

2 last classroom on the right.

3 The next one is 21/8. There have been some

4 repairs made in these classrooms on the walls, but

5 there was still one detail in one of them that we

6 photographed in order to confirm one part of the story

7 which is that when people were standing up, soldiers

8 who were outside of the school shot from the outside

9 towards the inside to impeded the people to get to the

10 windows and to get fresh air or even look outside.

11 There is a report of one man who was killed in such a

12 fashion.

13 On the blackboard of this school, there were

14 some impacts on the blackboard, caused probably by

15 ricochets of bullets. The one I'm going to circle on

16 this picture here is a hole [marks]. The other ones

17 are only impacts without perforations. This one is

18 perforated. This is why I could stick a pen inside.

19 There are no other traces like this in the classroom,

20 which is partially renewed like the ones in this school

21 but only partially.

22 This closes the presentation for the school.

23 MR. HARMON:

24 Q. All right. Mr. Ruez, let's move to

25 Prosecutor's Exhibit 22, the site we referred to as the

1 Dam.

2 A. In the afternoon of the 14th, once the school

3 was also filled with prisoners, transportation of these

4 prisoners started. There was a different situation

5 than at the Grbavci school, not only in terms of the

6 treatment of the prisoners, which was, as I said, not

7 so bad at the Grbavci school, but very, very violent

8 behaviour at the Petkovci school, as you will hear from

9 the people, and people were not blindfolded but only

10 the hands attached and taken on board of little trucks

11 towards the Dam.

12 The Dam is approximately 2 kilometres away

13 from the school. It takes approximately five, six

14 minutes of driving at very slow speed to reach the Dam

15 from the school, and we will see the distance from the

16 video, which shows a helicopter view flying from the

17 school to the Dam.

18 The Dam is -- you will see the colour of the

19 Dam is red. The reason is that it's not a lake. It

20 is, in fact, a reservoir of waste for the aluminium

21 factory. So it's full of chemical waste, in fact.

22 Q. Mr. Ruez, we have a film. Should we commence

23 with the film, which is Prosecutor's Exhibit 22/10?

24 Then you can orient the Judges through the film and

25 then to the ensuing exhibits. So if we could have the

1 lights dimmed, we could play Prosecutor's

2 Exhibit 22/10, please.

3 [Videotape played]

4 A. Yes. The Petkovci school seen from the back

5 where the staircase is. This is now the school seen

6 from the front. At the bottom of the picture, the road

7 that leads towards Zvornik but also towards the Dam.

8 We can double-check the distance on the map.

9 Here you can see the Dam. But to access the Dam, you

10 will see -- this is the execution site already to be

11 seen on the Dam, at the bottom, and the road now goes

12 here at the middle of the picture. Here it turns

13 left. This is now the access road to the Dam. The

14 total distance is more three kilometres than two.

15 This is again the view of the execution site,

16 the plateau at the bottom of the Dam. In front is a

17 hill with a wood. This is the top of the Dam with the

18 so-called peninsula full of chemical waste.

19 Flying above the barrage, and this is the

20 plateau of the Dam, the execution site, the wood on the

21 hill in front of it.

22 This was the first arrival on the site.

23 William Hagland was the forensic expert on this site

24 that day. The site is absolutely scattered with

25 bones. On this one we won't see the pieces of skull.

1 We didn't spend a long time that day on it but we

2 returned. You will have extensive reports on the

3 findings at this location.

4 That's the execution site, all this here,

5 where the people are standing and all this

6 environment. It's a very large site.

7 The interest of the wooded hill in front is

8 that this is the location where the two survivors

9 managed to sneak away from the site after the

10 execution.

11 This is an area where the people then had to

12 cross in order to find another hiding place, all the

13 area here along this ridge, going uphill.

14 The main bones found on the surface and

15 scattered on the surface of the plateau are skull

16 fragments, and that matches the description that the

17 survivors give of the next day where during the entire

18 day of the 15th of July they could hear single shots

19 of -- it was the finishing of the wounded. The wounded

20 were begging to be killed during the night. The

21 executioners took all their time and only finished them

22 the next day. They could hear single shots all along

23 the day.

24 We came back there in June 1996, and the in

25 first collection operation we collected 1.031 shell

1 casings on the surface of the plateau, only the ones

2 which were lying on the surface, not those embedded who

3 are a little bit in the ground. And it was only a

4 visual search without metal detectors. When the

5 exhumation took place in 1998 an additional 750 shell

6 casings were found with a metal detector. These last

7 ones have been very precisely plotted on the ground,

8 together with skull fragments, and you will see all

9 these mappings in the report of Professor Richard

10 Wright, which gives a clear view of the site, the size

11 of the execution field, and other elements of

12 interest.

13 This is a view from the top of the Dam, which

14 is going to be a 360-degree view to have a complete

15 sighting of the entire area. That is the lake, in

16 fact, the waste, the chemical waste. The view is

17 turning towards the west. There is a guardhouse on top

18 of the Dam. This is the view just in front of the

19 Dam. This is the access path.

20 MR. HARMON:

21 Q. Mr. Ruez, please continue.

22 A. The Exhibit 22/A is the map of the area which

23 marks the location of the Dam.

24 The Exhibit 22/1 is an aerial imagery of the

25 site. The left part of the picture is a photograph

1 dated 5th July, 1995, and shows the -- how the ground

2 looks like at that date. The one next to it is the

3 same location photographed the 27th July, 1995 and

4 shows a clear area of recently disturbed soil, the same

5 area that you could see on the video where at one

6 moment that was group of men on it, and it was clearly

7 visible that there was a difference of soil at that

8 location.

9 The follow exhibit is 22/2. This is a

10 helicopter view from the same location. The location

11 of interest here are the surface of the plateau. I'm

12 going to circle the approximate size of the execution

13 area. We know about the size of the execution area due

14 to the repartition of both the shell casings and the

15 skull fragments on the site, and roughly it would

16 occupy that part of the field [marks]. I on purpose

17 tried to make it maybe smaller than larger.

18 What you also have here, and we'll have

19 closer views on it, is kind of a concrete canal that

20 goes from the top of the Dam to the bottom. It is in

21 case of an overflow of water. It's a canal that

22 enables the water then to flow towards the valley, and

23 it goes down from here, down towards the valley

24 [indicates]. It's an element of recollection for the

25 witnesses, because they had to crawl through this

1 before managing to reach the wooded area which I circle

2 on the picture [marks].

3 Then later, but seen from above, is something

4 that these people might have then some difficulties to

5 orient themselves with. This is the exfiltration path

6 for these two men.

7 The Exhibit 22/3 is a panorama, which is a

8 photograph from the middle height of the plateau. Here

9 you have a very clear view on the disturbance which was

10 visible on the aerial imagery shown previously. It is

11 a photograph which was dated end of April, early May

12 1995, so not a very long time after the events.

13 I'm going to circle around the area of

14 disturbance which is very clearly visible on the aerial

15 imagery [marks]. I'll mark it 1, area 1. This is the

16 approximate outline of the mass grave which was dug in

17 this location and later on disturbed.

18 On this one, it will be easier for me now to

19 mark you the size of the execution area according to

20 the observations made by the witnesses, since this is a

21 little mound of rocks which can be used as a reference

22 point. Approximately from here [marks] to the end,

23 covering the entire surface of the plateau, nearly

24 going to the edge of it [marks], is the size of the

25 execution area, which was, according to the witnesses,

1 covered with bodies on which they had to walk to find a

2 free spot.

3 THE REGISTRAR: [Interpretation] At the end

4 of the record, the year indicated for the photograph is

5 1995.

6 THE WITNESS: We didn't enter the territory

7 Republika Srpska in 1995. This is the location where

8 the American journalist David Rhodes has been

9 arrested. He went to this site, to this one was in end

10 of October 1995, I think, and went to this location in

11 order to implement the reports which were coming out

12 about the atrocities which happened in this area and

13 saw bones also sticking from the ground, but this place

14 is under constant surveillance, since it was a military

15 zone during the war. There were artillery positions in

16 the area, and it was constantly guarded. So he got

17 arrested and gaoled and even tried for having spied

18 this military facility.

19 JUDGE RIAD: Can you tell us how much it is

20 in square metres?

21 THE INTERPRETER: Microphone for Judge Riad,

22 please.

23 THE WITNESS: I cannot give you that precise

24 answer at this moment. In the report of exhumation,

25 all these measurements will be mentioned. I can just

1 give you the rough outline from the picture. I don't

2 have these measurements with me.

3 JUDGE RIAD: Can you give us an outline?

4 THE WITNESS: No. I would just give you

5 approximation. I would say a hundred metres in --

6 large and 50 metres long, I would say. I would say

7 roughly here 50 [marks], but all these precise

8 measurements are in the report of Professor Wright.

9 But this would be approximately 50 metres and this

10 would be approximately, from east to west, 100 metres

11 [marks], but this needs to be confirmed through his

12 report. I just say it as an indication.

13 JUDGE RIAD: Thank you.

14 A. On Exhibit 22/4, one can see both the

15 watchtower on top of the hill [marks] -- the

16 guardhouse, not the watchtower. Also, one interesting

17 element, since this photograph is, as I said, early

18 1996, so not a very long time after the events, one

19 witness describes the fact that the light -- the scene

20 was lit by projectors coming from the top of the Dam

21 which was providing the light beam for the execution

22 scene, and the projectors are still there in early

23 1996. This is the ramp of projectors which was

24 illuminating the execution area at the time of the

25 events, to assist the executioners to do their job.

1 This concrete canal, which is going downhill,

2 is the one the witnesses had to crawl into in order to

3 reach the little wood on the little hill, just on the

4 opposite side.

5 Exhibit 22/5 is another view that shows that

6 same little canal, and you can also see on this view a

7 path which I'm going to mark [marks]. The reason why

8 I'm mentioning this one is that on the 15th, in the

9 morning, the people could see from the opposite side of

10 this hill and noticed that a tractor was transporting

11 bodies on a little trailer. From the position the men

12 were, they couldn't see at one point where this little

13 tractor was going. But we will have then other

14 photographs which will give us more details about

15 that.

16 So during the day of the 15th, the bodies

17 were taken away, but at a very slow speed.

18 MR. HARMON:

19 Q. Mr. Ruez, why don't you wait just a moment.

20 We apparently have a technical problem.

21 [Trial Chamber confers with legal

22 officer]

23 JUDGE RODRIGUES: [Interpretation] Mr. Harmon,

24 it appears that we have a small technical problem, but

25 it's also time for our break. We will have a 20-minute

1 break, and I hope that the problem will be solved in

2 the meantime. Thank you.

3 --- Recess taken at 12.30 p.m.

4 --- On resuming at 12.54 p.m.

5 JUDGE RODRIGUES: [Interpretation] Mr. Harmon,

6 we have one and a half hours of work. Maybe it's going

7 to be a bit too long. I don't know how much time you

8 still need to finish this testimony.

9 MR. HARMON: I think I will finish my direct

10 examination, Mr. President and Your Honours, within the

11 allotted time of today. I don't know how much time

12 there will be on cross-examination or the Judges'

13 questions, but we should finish our presentation

14 today.

15 JUDGE RODRIGUES: [Interpretation] Very well.

16 Then we could perhaps have a ten-minute break half-way

17 through.

18 I'm addressing the interpreters now. If we

19 still need five or ten minutes more to finish today, I

20 don't know whether you will be agreeable to that. It

21 seems that it is okay. So more or less ten minutes.

22 Thank you very much.

23 Mr. Harmon, please bear this time framework

24 in mind. You may proceed. Thank you.

25 MR. HARMON:

1 Q. Mr. Ruez, we took the break as you were

2 starting to explain Prosecutor's Exhibit 22/5. So

3 would you please continue?

4 A. Yes. We are going now to pass immediately to

5 22/6. Again, on 22/6, the important element here is,

6 again, the ditch, the concrete ditch, through which the

7 survivors managed to sneak through. So here, again, we

8 have this ditch going towards the valley.

9 The next exhibit, 22/7, is a helicopter

10 overview of the area which shows a few other very

11 interesting places. First of all, again, the area of

12 disturbance, which marks the initial position of the

13 grave. You have also, just on the top right of the

14 picture, the ditch [marks], which I am outlining with a

15 red line, the wood on top of the hill in front [marks],

16 and then a line that goes from the top right to the

17 left of the photograph, which I'm marking with a dotted

18 line [marks] and which will be the exfiltration way of

19 the survivors.

20 The other interesting part here is that, as I

21 said, a tractor transporting bodies loaded on the

22 trailer was seen taking the little path going uphill,

23 but at that moment, the witnesses were somewhere in

24 this area here [marks], and once on the ground here

25 [indicates], due to the elevation of the ground, you

1 lose the vehicle from sight once it arrives

2 approximately in this area here [marks].

3 Our assumption is that the bodies have been

4 transported towards this direction [marks] and dumped

5 in the water, somewhere in this vicinity [indicates].

6 A survey was done through aerial imagery which didn't

7 enable us to find any grave site or disturbed soil,

8 other than this disturbance. Therefore, we made the

9 conclusion that the only possible location would be

10 this one.

11 This location, Professor Wright will explain

12 that it was checked, trenched, with limited results,

13 except one area which I think was approximately this

14 one [indicates], where all these chemicals had been

15 dumped, and even some which obviously looked

16 dangerous. So no trenching could be done, and the

17 negative result here is not concluded yet. But so far,

18 we don't know where these first bodies were taken to.

19 This lasted only during the day of the 15th.

20 There was heavy rain falling in the area at the end of

21 the day of the 15th, and that most probably stopped the

22 slow evacuation of all these bodies, and that's why

23 then heavy equipment came to finish the burial. And,

24 as I said, then the sight has been disturbed, and these

25 bodies have been taken to various locations, which we

1 have later on identified.

2 Q. So the record is clear, Mr. Ruez, the area

3 that you said where no trenching was done is the area

4 at the tip of the peninsula, and you've put parallel

5 red lines in that location; is that correct?

6 A. Yes. This is a rough indication. Since

7 Professor Wright is the one who did this operation, I'm

8 just roughly indicating the location. It's very

9 clearly indicated in his reports.

10 The next picture is 22/8. This is a picture

11 which was taken in April 1997, when we went to this

12 site to probe the area and, in fact, dig a hole in

13 order to assess if the place was disturbed or not. We

14 couldn't dig very far in it, since, as you can see,

15 it's a very rocky environment. These are small stones,

16 but underneath there are big rocks.

17 Just underneath the surface where we started

18 to dig, we found this piece of cloth which looks like a

19 wrist ligature. We have it in evidence.

20 We dug a one-metre-deep hole, and we finally

21 were lucky to find a skull, part of a skull, which

22 sparked the decision to exhume the place. In reality,

23 we had been extremely lucky. This is the only piece of

24 skull that was to be found among tonnes of rocks. The

25 final result of the exhumation here, this number will

1 have to be confirmed through Professor Wright, but it's

2 roughly the human remains belonging to 50 different

3 individuals. But this is only the elements which were

4 left in the grave after the disturbance. We will talk

5 about these bodies later on when we will discuss the

6 massive operation which was aimed to transfer all these

7 victims into smaller graves scattered in the area.

8 Q. For the record, the exhibit that has been

9 referred to is 22/9.

10 Mr. Ruez, we're now going to turn our

11 attention to the Pilica school, and would you orient

12 the Judges, please.

13 A. The events we know in this location have been

14 provided by several people. In fact, we have three

15 survivors from the events we are going to unfold now.

16 On 15 July, a convoy of prisoners left

17 Bratunac town and took the direction north, past

18 Zvornik, continued even more north, and reached the

19 area of Branjevo/Kula. The school in the hamlet Kula

20 is called the Pilica school. Pilica is, in fact, the

21 entire area here [indicates]. So the Pilica school,

22 it's a big building.

23 There were possibly already men inside this

24 school before that date, but the school was still

25 continued to be filled with prisoners the day of the

1 15th. This is the location we're going to start with

2 now.

3 The first exhibit is 23/A and is a photocopy

4 of a map of the area with a red circle around the

5 so-called area of Luke -- Kula, sorry, where the Pilica

6 school is, and there is a yellow-green dot which

7 roughly marks the position of the school within this

8 circle.

9 The national road that goes from Zvornik

10 towards Bijeljina, is along the Drina on the right of

11 the map, which is the east.

12 Exhibit 23/1 is a view from -- a helicopter

13 view, dated 1999, of the Pilica school, where one can

14 see first the access road to the school, which I'm

15 marking with a red line [marks]. The main building,

16 which I'll mark "A," is the school [marks]. The

17 building next to it, marked "B," is the gymnasium.

18 Both the gymnasium and the school were apparently

19 packed with prisoners.

20 At some point during the night, between the

21 15th and the 16th, one prisoner exited, on request of

22 his guards, the gymnasium in order to go and fetch

23 water. Upon arrival, the people were taken on the

24 playground where there are stairs going up to the

25 school, and this is the way the person took to exit it

1 [marks], and going a little path down behind the school

2 there is an area where there is a water pump that the

3 person described precisely in his initial statement.

4 Q. Will you mark that with a letter "C," please?

5 A. Which I mark with a letter "C."

6 The following exhibit is 23/2, which is the

7 plaque on which the name of the school is written and

8 also the location, Pilica, which I circle on this

9 plaque [marks].

10 The next photograph is the Exhibit 23/3, and

11 shows the stairs which was the access way for the

12 prisoners and also the way that the person who went to

13 fetch the water took.

14 The following one could be assembled with the

15 previous one to form a panorama. The next one is the

16 Exhibit 23/4, and shows the gymnasium seen from the

17 back of the school. These two pictures could form a

18 panorama like this.

19 The following one, the 23/5, is the inside of

20 the gymnasium, which had been renewed at the time we

21 could access the inside of the school. We accessed the

22 inside in 1998. We have not presented these

23 photographs, I think, to the survivors.

24 The windows could be clearly recognised on

25 the left hand, and on the next Exhibit, 23/6, the

1 windows on the right hand when entering the gym. We

2 have videotapes of all these locations, if needed.

3 Exhibit 23/7, is the view one has when going

4 behind the school and willing to access the water

5 reservoir. This is the reservoir. I'm going to circle

6 it [marks], water pump.

7 Q. The water pump is the location that you

8 mentioned in 23/1 marked with the letter "C"?

9 A. That is correct. In fact, it is described as

10 being water pipes, and indeed on Exhibit 23/8, one can

11 see what is referred to as the water pipe. I'm going

12 to circle it [marks]. This is the water pipe which was

13 described by the person who went to fetch the water.

14 That same person is the one describing then

15 the murder of a bus load of prisoners. I will very

16 briefly return on the Exhibit 23/1, which is the aerial

17 view of the school. It will make more sense to explain

18 the location.

19 When the person was coming back from the

20 water pipe, arriving more or less here [marks] -- the

21 person was with us when he provided these

22 explanations -- with an angle of view which allowed him

23 to have a view of this area here, which I mark with a

24 line and bars on it [marks]. In this area, a bus full

25 of prisoners stopped more or less where the parking

1 place is here and the persons were disembarking there.

2 Apparently, soldiers were in the vicinity of the road,

3 and once the people were assembled next to the school,

4 they opened fire on them and apparently killed all of

5 them.

6 This is the location where the event

7 happened, Exhibit number 23/9.

8 JUDGE RODRIGUES: [Interpretation] Excuse me,

9 Mr. Prosecutor. Perhaps it would be useful to mark

10 this, which Mr. Ruez has mentioned, in 23/1.

11 A. Yes. I'll call it area "D" [marks].

12 MR. HARMON:

13 Q. Area "D" is the area where the execution took

14 place?

15 A. Yes. The next exhibit is going to have a

16 better view on this point, Exhibit 23/9. This is, at

17 the very right of the picture, an old tower, which is

18 also a reference point. You can see at the extreme

19 right the playground, which was more or less the

20 location where the person would e coming from the water

21 pumps. The area in between these pictures, where the

22 trees are and a little bit more and the right, so I'm

23 going to circle the area. The approximate area where

24 the group of men were standing, according to the

25 witness, will be, [marks] on this photograph, the area

1 I would mark "A."

2 A few shooters committed the operation. The

3 person didn't see how many. These few individuals

4 were, according to him, standing in this area here

5 [indicates], which I'm going to circle, roughly. And

6 the shooting happened from the circled area towards the

7 squared area marked "A." I will mark "B" the position

8 of the shooters.

9 As one can already see on this photograph,

10 there are some marks on the wall. Unfortunately, there

11 have been some repairs and we cannot very precisely

12 date these repairs, but there are still some traces not

13 covered by repairs, like the two holes that I'm going

14 to circle on the right part of the picture of the right

15 wall [marks]. These are the most obvious ones. There

16 are smaller traces on this wall, not in significant

17 number, but you have also repair traces here. The

18 windows had been repaired, but some of them, in 1996,

19 still had marks on them. At the time we didn't know

20 where the event happened -- we only found out about it

21 in 1999 -- so we couldn't conduct observations inside

22 to confirm what could have been observed from the

23 outside.

24 Nevertheless, on the photograph which is

25 Exhibit 23/10, one can see, in fact, the view the

1 perpetrators had on the scene. I'm going to circle

2 again the area where the men were standing [marks],

3 which I'm going to mark area "A." Again, you can see

4 through that angle the traces and also these two holes

5 [marks].

6 We have a photo documentation available taken

7 in April 1996 of the outside.

8 Q. Wait just a minute, Mr. Ruez, please.

9 A. 23/11. This is the row of windows. I

10 selected this one as an example, where one can see

11 broken glass here and a hole here [marks]. I would add

12 the same comment that I made for the Grbavci school.

13 One could claim that these holes are also done by

14 children throwing stones. We would not challenge

15 that.

16 23/12 is a close-up on the wall from the same

17 facade, on the extreme right where you can see again

18 the two holes which were marked on the previous

19 photographs [marks]. You can also see smaller little

20 pockmarks. I'll circle some of them [marks]. Much

21 smaller scratches on this wall.

22 On the Exhibit 23/13 is the angle of that

23 same area. This is the approximate location where

24 probably the person who was the most at the left,

25 looking at these prisoners, would be standing and

1 shooting in that direction. There are marks on the

2 left part of the wall which have been repaired, but due

3 to their angle, it could very well be also that this

4 could be the results of shooting on someone who'd tried

5 to escape from the position in front towards that part

6 of the school. It is a possibility.

7 We collected shell casings in 1999 on this

8 location. I will have other photographs to present to

9 you regarding this survey for shell casings. I'll

10 return very briefly on the Exhibit 23/10, which is not

11 the best photograph to describe what I'm going to say

12 now, but in this area which is a bit out of the frame

13 of the picture, just on the right hand of the frame of

14 this photograph, is the area where we still managed to

15 find 11 shell casings on a first visit and 11 more on a

16 second visit, in this area here, and also on the little

17 stretch of road which is just where I'm standing

18 currently to take this photograph. All the other ones

19 could have been collected by children playing. The

20 ones we found were the ones completely embedded in the

21 ground and that no one picked up.

22 When we went there the first time in 1996, we

23 collected a certain number of shell casings in the

24 vicinity of this area where the playground is, the

25 concrete playground, but this might have also been

1 moved from one location to another. So the only ones

2 we will consider at this point were the ones which were

3 embedded in the ground, because these ones, at least,

4 we can assume that they didn't move too much in the

5 months following the events.

6 The last exhibit for the school will be the

7 23/14, which is a view of the main entrance of the

8 school. The main entrance is in between the school

9 building and the gymnasium, and the area which I'm

10 going to circle [marks] is the area where the men were

11 standing prior to their transportation on a bus

12 allegedly towards freedom and exchange.

13 Also when entering the school, there are

14 other elements that we could show and we could show on

15 video which implement descriptions given by the

16 survivors, like the presence of a little kitchen on the

17 left when entering the school.

18 Q. Mr. Ruez, this Pilica school is associated

19 with an execution site that we're now going to turn our

20 attention to. Can you approach the map and then

21 explain to the Judges what that site is and where it's

22 located?

23 A. Once the people exited the school and were

24 lined up at the location I just pinpointed on the --

25 JUDGE RODRIGUES: Microphone.

1 A. When the prisoners exited the school and were

2 lined up on the area just marked on the photograph,

3 they were taken on board of buses and told that they

4 would go for exchange. The bus quit the area towards

5 the asphalt road but didn't reach the asphalt road,

6 immediately continued along this dirt road and went

7 behind a hill towards the Branjevo Farm.

8 The first ones who arrived there arrived at

9 10.00, and at that location they were awaited by an

10 execution squad who conducted the extermination of all

11 the prisoners who were inside the school, the execution

12 lasting from 10.00 in the morning through 1500 hours in

13 the afternoon. This is the situation which has been

14 described through the testimony of Drazen Erdemovic,

15 the events on the Branjevo Farm.

16 MR. HARMON:

17 Q. Now, Mr. Ruez, the Branjevo Farm, is that a

18 normal farm or is it associated with the military in

19 any way?

20 A. It is called the Branjevo Military Farm. It

21 is a farm controlled by the army where they raise pigs

22 to feed the troops.

23 Q. Mr. Ruez, we're going to start with a video

24 presentation, and if I could have the lights lowered

25 and we could turn to Prosecutor's Exhibit 24/10,

1 please.

2 [Videotape played]

3 A. This is the Pilica school, and we are going

4 to fly along the road that leads to the Branjevo Farm.

5 The main element here that you can see to recognise is

6 the tower, the old tower which is behind the school,

7 behind the playground. Here you can see the school and

8 the gym attached to it, and this in front, where the

9 vehicle is driving towards east, is the road that goes

10 both towards the main asphalt road, the highway,

11 Bijeljina-Zvornik, but also leading to the dirt road

12 that leads to the Branjevo Farm. This is a view to

13 show how the landscape is in this area. It's very

14 different than the area south. It's still a hilly area

15 but then it opens on the Drina plain.

16 We are still following the road. We don't

17 always have it in sight, but we are still following

18 it. Here we can see it again. Here one can already

19 begin -- it's still going on.

20 Now we can see also the main road going --

21 now this is the one just here, which is turning towards

22 the Branjevo Farm. It continues. Here it is a

23 shortcut, in fact, that leads to the farm. The road is

24 here, just in the middle of the picture. It's a dirt

25 road. It's not the national road.

1 That dirt road which is on top of a hill, the

2 highway just being the opposite side of the hill here.

3 Here is already the Branjevo Farm. You will see

4 several buildings. The interesting part of the field

5 is on top of the picture.

6 Now here we have a few on the farm and in a

7 straight line is also the execution field.

8 This is showing the environment. These are

9 pigsties. This is the access to the farm, it's already

10 inside the farm. This shows the environment. This is

11 the back of the farm. This is the area where the grave

12 is here [indicates], just here. This is the area of

13 the execution field. This is the Drina River. The

14 Federal Republic is just on the other side. The corn

15 field on the left is the execution field.

16 Here you can see a vehicle going on the

17 highway, towards Pilica, Janja, Bijeljina and you have

18 a hill which no one can see from there, so the farm is

19 quite a distance from the highway, and you have a hill

20 also, no one can see from the road.

21 This is our first arrival in -- no, not the

22 first arrival, the second arrival. That's the shed

23 where there are vehicles. This is the area of the

24 grave. Just before was the area of the execution

25 site. This is seen from the grave area. This was in

1 April 1996. The first time we went there was in March

2 1996. Behind this shed was the team of the 10th

3 Sabotage Detachment persons.

4 This is the area of the execution field. The

5 tree on the left is a very common feature recognised by

6 the survivors. This is the shed, garage, and now here,

7 all this is the area where the execution took place.

8 All this area you have just in front of you now is the

9 execution field that we will see on the aerial imagery,

10 all this area in front. It's a large -- very large

11 site.

12 Now we are going towards a bridge. The

13 reason is that this bridge had been described and then

14 later on recognised by one of the survivors who escaped

15 the area and then stayed hidden for a couple of days

16 under the bridge, with destroyed vehicles underneath.

17 This is the bridge under which he was hidden, very

18 nearby the farm. In April 1996, the trash was still in

19 place.

20 Behind me is the direction of the school, and

21 in front, the direction of the farm. This is

22 approximately two kilometres away from the farm by

23 foot.

24 I will just pinpoint for you this bridge on

25 the main exhibit. The farm being here, the school

1 being --

2 JUDGE RODRIGUES: Microphone.

3 A. Sorry. The farm being where the marking

4 "farm" is, the school being where the marking "school"

5 is. This bridge is just here [indicates], more or less

6 where the intersection is of the path reaching then --

7 before going to the school, just here on the map

8 [indicates].

9 MR. HARMON:

10 Q. Mr. Ruez, using the exhibits that are found

11 in Prosecutor's Exhibit 24, would you continue your

12 explanation of the Branjevo Military Farm, please?

13 A. The first exhibit, number 24/A, is the map of

14 the area, with the Branjevo Farm circled. The Branjevo

15 Farm is very visible on this map. No, it's not on this

16 one, I'm sorry. Yes, it is, sorry. The map is

17 mismarked, this is the reason why I couldn't find it.

18 You will have to recircle it.

19 Under the markings -- I don't have this --

20 this was the map that was supposed to be for the Pilica

21 Cultural Dom. So under the circle which you have on

22 your map, approximately one kilometre south is a little

23 grouping of buildings with two little bars and one dot

24 on top of it. This is exactly the location of the

25 Branjevo Farm.

1 Q. Would you keep that map under the ELMO for

2 just a minute? The Judges may want to make a

3 correction on their maps. I take it, then, the large

4 circle, the Judges can ignore that on this exhibit; is

5 that correct?

6 A. Absolutely. And I'm going to use the

7 opportunity to also mark the bridge, which is more or

8 less here [marks].

9 Q. Would you put an arrow next to the bridge,

10 please?

11 A. [Marks]. Returning briefly to comments of

12 the film, the number of shell casings collected during

13 this operation that day was only 73 shell casings. The

14 reason is that we conducted only a visual check of the

15 field, we didn't use any metal detector. As you can

16 see, the field has been cultivated, so the soil turned

17 upside down. These were only the ones which were

18 obvious on the surface. We didn't make a very thorough

19 search, we were just a handful of people there on a

20 huge field. So there is certainly much more under the

21 ground than above the ground.

22 Our intention was not to have a final count

23 of these shell casings but only to collect enough of

24 them for future comparison with other sites. And this

25 is what we are doing with all the shell casings we are

1 collecting, we then use them in order to match sites

2 with each other. You will notice them when we talk

3 about the elements found in primary graves and

4 secondary graves, these shell casings are a very clear

5 indication of from where our elements are coming from.

6 They can also be used for other things, like matching

7 guns with shell casings, but that's another phase in

8 which we are not entering at this point and for which

9 we are still awaiting lab results.

10 Q. Mr. Ruez, since Exhibit 24/1 is -- I'm

11 sorry. Proceed with 24/1.

12 A. Yes. 24/1 is an aerial photograph taken of

13 the farm, the 5th of July, 1995. These pictures were

14 found after the first declarations of Drazen Erdemovic,

15 upon his arrest in Belgrade.

16 So this shows the field as it looked the 5th

17 of July, 1995. I'm going to circle two areas on it;

18 the first area is the approximate area of the

19 execution, which, in reality, is approximately --

20 according to what we saw on the film, starting more or

21 less here [marks], and continuing even out of the frame

22 of this picture. The fact is that the size of the

23 field -- of the execution field, as we could observe

24 it, due to the markings on the ground, is not

25 necessarily the one which existed at the time, since

1 shell casings might have been moved by the truck that

2 was plowing the field and transported a distance. So

3 we could only use concentration -- areas of

4 concentration of these casings. So if we would do it,

5 it would shrink, a bit, the size of this field. But

6 roughly this is more or less the position on this

7 photograph, and the grave area would be this area here

8 [marks].

9 I'm now going to show you the next --

10 Q. Mr. Ruez, would you mark an "A" and a "B" to

11 identify each of those areas.

12 A. [Marks]

13 Q. And "A" is the area of the execution and "B"

14 is the area of the grave, for the purposes of this

15 exhibit.

16 A. Exactly.

17 On Exhibit 24/2, the main elements are

18 marked. I will start with the farm. The building

19 which is on top of the photograph, which is, in fact,

20 the east, is a pigsty; the one at the west, at the

21 bottom of the photograph, is a pigsty as well. You

22 have here also an illustrated building [indicates].

23 You can see the tree which is next to the parking

24 shed. The parking shed is an element that Drazen

25 Erdemovic described in his testimony. The tree is an

1 element recognised by the survivors. Since they had to

2 walk, looking at their feet, but passed along this

3 part, the tree is an element that they all talk about.

4 What you can also see on this picture is the

5 area circled and named "Bodies". These are bodies

6 still on the ground on the 17th of July, 1995. It is

7 not the entire number of dead people here, since the

8 cleaning process of the area has already started, as

9 one can see from the tyre traces. So the area where

10 tyre traces are, indeed, an area where bodies were

11 picked.

12 You can also see clearly on this photograph,

13 with an attentive look, mounds of soil leading to the

14 grave. You can see the access ramp to the mass grave.

15 You can also see a stack of dots, which has been

16 indicated were possibly bodies as well. And where the

17 mound of soil is is where the human remains had been

18 filmed on the video, when they were still lying on the

19 ground. But this is a photograph taken before the

20 disturbance.

21 This was the same photograph as the Exhibit

22 2/3. Exhibit 2/3 has the markings which give it --

23 Q. You mean 24/3.

24 A. Yes, 24/3.

25 Exhibit 24/4 is dated the 21st of September,

1 so after the initial burial and before the

2 disturbance. You can see the area of burial and the

3 traces left on the execution meadow. I've also marked

4 on this photograph the dirt road which leads to the

5 highway, not to have this dirt road confused with the

6 National Highway, which is out of the frame of this

7 picture, so much more east if we were on the ground,

8 approximately 800 metres by air and out of sight.

9 The following photograph is 24/5, it's a

10 helicopter view, dated March 1996, which shows the

11 farm, the access path. All this is seen from the east

12 towards the west. And you can also see on the

13 photograph the area with the shed and the tree. I'm

14 going to circle it [marks]. This was the rest area for

15 the execution squad. The extreme right of this exhibit

16 connects with the next one, the 24/6.

17 This is a view that shows the execution

18 site. On the extreme left of the photograph you can

19 see the garage shed, which I'm going to circle again as

20 "A". Then in front of it, you have the area where the

21 execution took place. We collected shell casings

22 approximately where Peter Nicholson was standing and

23 making the comment that he indeed filmed a shell casing

24 further from the distance -- I'm not going to use that

25 one -- but the last area which is approximately this

1 line here [marks].

2 Q. Put a letter next to that, please, Mr. Ruez.

3 A. The letter "B". Letter "C" which is the

4 arrow is the position of the grave. The scale is

5 likely provided on this photograph by the little men

6 which I'm going to circle without putting any numbers.

7 These are military personnel provided for the

8 circumstance, which was the day of the visit of

9 Madeline Albright to the Branjevo Farm, in March 1996,

10 following the revelations of Drazen Erdemovic.

11 The next exhibit is 24/7 --

12 Q. Just wait a minute, Mr. Ruez, until the

13 Judges have an opportunity to remove theirs from the

14 plastic sleeves.

15 Please proceed, Mr. Ruez.

16 A. This panorama composed of three photographs,

17 attached each to another, show the access way to the

18 farm, where the buses were lined and the people on

19 board had the opportunity to watch everything that was

20 going on and just had to wait for their turn. The

21 buses were parked at exactly this location.

22 On the right of the photograph, if I slip it

23 through the ELMO, you can see the shed and the tree,

24 which was previously marked on the photographs. Behind

25 that line is the area of the execution meadow.

1 Unfortunately, the helicopter is standing right where

2 it is, but this gives also an indication, since you

3 have the men walking here at the right of the picture

4 where the helicopter is, this marks more or less the

5 extreme right of the execution area. And, indeed, the

6 execution area goes at least, if not further, than the

7 last man on this picture, which I'm going to circle

8 [marks].

9 Exhibit 24/8 --

10 Q. Just wait a minute, Mr. Ruez.

11 A. Okay.

12 Q. Mr. Ruez, please continue.

13 A. Exhibit 24/8 is a photograph taken in 1999,

14 when we came back to that site with one of the

15 survivors. The ground has changed. You can see that

16 now the entrance of the garage shed is blocked, and the

17 tree is still there and was immediately recognised by

18 that person. The corn now is high on the field, so it

19 created a bit of a difficulty for him to position

20 himself on the ground. It's hard to see on this

21 photograph, but he marked his position on that field,

22 approximately where I'm putting the arrow, but that

23 doesn't indicate the distance. It is about 100 metres

24 in that direction where the arrow is.

25 Exhibit 24/9 is just a reference opening to

1 the next step of activities on this site, which was

2 exhumation. These are some human remains which were

3 found there and left by the perpetrators who committed

4 the disturbance of the site.

5 They -- in addition to this, they forgot

6 approximately 150 bodies in this main grave. The

7 exhumation was conducted in 1996. Since then we have

8 localised, identified, and probed all the locations

9 where the secondary sites are to be found and who

10 contain the bodies of those killed at the Branjevo

11 Farm.

12 Q. Mr. Ruez, the Branjevo Military Farm is

13 connected now to our next area, which is the Pilica

14 Cultural Dom. Can you outline the Judges, please, to

15 that, and then we'll turn our attention to Prosecutor's

16 Exhibit 25?

17 A. As Drazen Erdemovic explained in his

18 testimony, once the execution of all these prisoners

19 was over approximately at 1500 hours in the afternoon

20 of 15 July -- sorry, 16 July 1995, the squad was

21 instructed to move towards the Dom Kulture, the house

22 of culture of Pilica, where they were instructed to

23 kill 500 prisoners who were in the cultural centre,

24 under the pretext that these people were attempting to

25 flee that location.

1 As you know from his testimony, he opposed

2 the move and others volunteered to go do the job. So

3 while some were killing the prisoners inside the House

4 of Culture, himself and members of his squad others

5 were having coffee and slivovitz in a cafe just in

6 front of the house of culture. We'll show you all

7 these places now.

8 JUDGE RODRIGUES: [Interpretation] Mr. Harmon,

9 perhaps we could now make a 10-minute break and then

10 move to Pilica.

11 --- Recess taken at 1.52 p.m.

12 --- On resuming at 2.02 p.m.

13 JUDGE RODRIGUES: [Interpretation]

14 Mr. Harmon.

15 MR. HARMON: Thank you very much,

16 Mr. President.

17 Q. Mr. Ruez, now let's turn our attention,

18 please, to Prosecutor's Exhibit 25, Pilica Cultural

19 Centre, and we shall begin, first of all, with the

20 video film. If I could have the lights dimmed, please,

21 and we could show Prosecutor's 25/17, please.

22 [Videotape played]

23 A. On this video -- in fact, it's a live video

24 of our arrival in the first location. We were, in

25 fact, looking for it at this moment. We didn't know

1 precisely where it was, and we even intended to show

2 the film to Drazen Erdemovic identification of the

3 place, but we found it that day.

4 If you turn left here, you arrive both at the

5 school of Pilica or at the Branjevo Farm, one continues

6 straight or turns left.

7 So driving towards ... here we passed it.

8 I've left a little piece and the rest of the footage in

9 order to give you an indication of how populated the

10 location is, what it looks like. This is the only

11 killing site which is inside a populated location. All

12 the other ones have been carefully selected outside of

13 populated areas. So indeed something might have

14 happened here which sparked the decision to kill the

15 people on the spot instead of transferring them

16 elsewhere.

17 It's not going to be long. Here we are

18 driving back towards the centre of this hamlet.

19 The house of culture is also the municipal

20 building. This is the front. Inside was a little

21 brand new telephone centre. The person tried to make

22 us believe that there was no cultural centre here,

23 there was nothing. On the right here is the cafe where

24 Erdemovic and his team and Lieutenant Colonel were

25 having drinks. Meanwhile, the execution was going on.

1 Again the cafe.

2 This is the plaque with "Pilica" on it. This

3 little structure was hiding the view from the cafe to

4 the entrance or exit of the house of culture, the

5 reason why Drazen Erdemovic couldn't see what was

6 happening just at the door, but he could see men

7 running out and being shot in the street. Then the

8 killers were searching their pockets for valuables.

9 This is a sealed access to the room which is

10 behind. This is the telephone centre I was talking

11 about.

12 That's the first view on the place where the

13 execution took place.

14 This is the door, the entrance door. There

15 is one next to it that goes up to the place where the

16 projectionist was showing movies. This is also a movie

17 theatre.

18 The shooters used these holes also to spray

19 bullets on the people who were inside. Allegedly

20 500 men were jammed in this place, according to the

21 Lieutenant Colonel who gave the instruction. We'll

22 know the final number once we have finalised all the

23 exhumations.

24 Drazen Erdemovic explained that killings were

25 conducted with rifles and also with grenades, and

1 indeed there are some obvious traces of explosion,

2 mainly where the area of the stage is. He's filming

3 the ceiling.

4 There is a little mistake in the editing of

5 this film, was supposed to be shorter than that.

6 The ejection for an AK-47 is on the right

7 hand, so it's normal that casings for a shooter who was

8 shooting through these holes end up in the staircase.

9 And the place was clean but very cursory. So each time

10 you can see it's cleaned and then you have a little

11 pile of trash and everywhere there is casings left.

12 The process was really badly done.

13 At this moment we were trying to open it. We

14 ended up breaking the lock.

15 This is irrelevant. These zoomings are of no

16 interest.

17 That's the construction obstructing the view

18 from the cafe.

19 These are the posters of Karadzic which were

20 all over the place at that time.

21 I missed a bit. The editing of this tape was

22 supposed to be shorter than that.

23 They show the environment of the entrance

24 door with a house just in front of it.

25 That's the area where men managed to get out

1 and were shot outside.

2 The plastic glove might have been used during

3 the, in brackets, "cleaning process" of the in side of

4 Dom Kulture.

5 Now the door has been opened. Probably no

6 one entered this place in between the moment we are

7 entering now and the moment the last ones who cleaned

8 the place exited this place. I will explain you the

9 reason why we believe that.

10 What can be seen on the wall when it is not

11 bullet holes is mainly human residues.

12 Q. Mr. Ruez, when you say human residues, what

13 do you mean by that?

14 A. Blood, hair, peel, skin. And all items which

15 have been taken by experts who went to fully process

16 this place in September or October 1996, they have

17 provided a full report of their findings on the spot

18 and of the samples which they have collected which were

19 processed and have a human origin. He's making a tour

20 of the location.

21 Now that's the right wall when entering. The

22 area where the stage is is the one where the

23 destruction is the most obvious. The reason is that

24 this was most probably the last location where the

25 people were compressed, trying to avoid the situation,

1 with no where to flee. Some were even hiding under the

2 stage. It was full of blood under the stage as well.

3 Part of the destruction of the stage was probably not

4 caused by the killing operation but during the cleaning

5 process.

6 A bullet head; probably went through a body

7 before lying on the ground. If not, it would be

8 crushed somewhere. In the cleaning of the place, a

9 total of 71 shell casings were collected in that

10 location. The number is enough for us to be able to

11 make connections between several sites.

12 Another bullet head. And Pilica.

13 MR. HARMON: Mr. President --

14 JUDGE RODRIGUES: [Interpretation] Mr. Harmon,

15 do you think we could finish within ten minutes,

16 realistically speaking?

17 MR. HARMON: Realistically speaking, I don't

18 think so, Mr. President. I apologise. The

19 presentation on the film was a little bit longer, but I

20 think it was useful to the Court and the public. I

21 would imagine, at the most, Mr. President, if we

22 continue on Monday, we would have 30 minutes.

23 JUDGE RODRIGUES: [Interpretation] Very well.

24 In that case, we shall also be realistic when we make

25 our decision.

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1 However, I should like now to turn to

2 Mr. Petrusic. Mr. Petrusic, how long will you need for

3 the cross-examination of Mr. Ruez? What do you think?

4 Do you have an idea?

5 MR. PETRUSIC: [Interpretation] Yes,

6 Mr. President. As things stand now, and in view of

7 what we have seen so far, we hope that it will take us

8 something between 60 and 90 minutes. But we shall do

9 our best to bring it down to 60 minutes, that is, one

10 hour, bearing in mind that Mr. Ruez is an investigator

11 only, that is, one of the witnesses, and that we shall

12 have witnesses testifying about each of these

13 individual examples. Thank you.

14 JUDGE RODRIGUES: [Interpretation] This is

15 becoming important now because, Mr. Harmon, you have

16 also to call other witnesses next Monday, I believe,

17 and you should be prepared for that. As you already

18 know, appropriate measures need to be taken to have the

19 witnesses called for not only in the next week, but the

20 week after, and for the first week of April. I believe

21 that Mr. Fourmy will need all this information. So

22 will you please take care and see if we can really

23 perhaps save some time and use best the time that we

24 have at our disposal.

25 Very well. As I have already told you, there

1 will be no hearing on Friday. Tomorrow is a holiday.

2 So we shall adjourn now and resume our work on Monday,

3 at 9.30. I also wish to tell you that myself and

4 Ms. Patricia Wald will be sitting here, since Judge

5 Riad will not be able to attend.

6 That is what I had to tell you today. I wish

7 you a nice weekend. I hope you have a good rest, but

8 also work. Until Monday then.

9 --- Whereupon the hearing adjourned at

10 2.33 p.m., to be reconvened on Monday,

11 the 20th day of March, 2000, at

12 9.30 a.m.

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