1 Wednesday, 29 March 2000

2 [Open session]

3 [The witness entered court]

4 [The accused entered court]

5 --- Upon commencing at 9.30 a.m.

6 JUDGE MUMBA: Would the Registrar please call

7 the case.

8 THE REGISTRAR: [Interpretation] IT-96-23-T,

9 IT-96-23/1-T, the Prosecutor against Dragoljub Kunarac,

10 Radomir Kovac, and Zoran Vukovic.

11 JUDGE MUMBA: Are we still with

12 cross-examination, isn't it?

13 MR. JOVANOVIC: [Interpretation] Yes, Your

14 Honour, that's right.

15 JUDGE MUMBA: Please continue, please.

16 MR. JOVANOVIC: [Interpretation] Your Honour,

17 unfortunately I have to inform you that the Defence of

18 Zoran Vukovic is unable to continue this

19 cross-examination, and I am not sure that we will be

20 able to continue with our Defence.

21 Let me explain. At our previous meeting,

22 which was before the status conference, I informed that

23 the Tribunal that there were some problems with regard

24 to my appointment. At that time I received a decision

25 which extended my appointment to 30 days, and I was

1 informed that this problem would be resolved in the

2 shortest possible time. Yesterday this 30-day period

3 has expired, and as of this moment, to all practical

4 intents and purposes, I am no longer the Defence

5 counsel, because I have no appointment papers. I don't

6 know how this came about. I checked my locker this

7 morning, which I got thanks to this registry, but there

8 is no decision on my appointment. The final decision,

9 the last decision that I have, which I did not receive

10 myself, in actual fact, but was given to me by my

11 colleague, is it, and yesterday that 30-day period

12 expired. I do not know whether this poses any problems

13 of a formal nature, but I suppose it does.

14 [Trial Chamber deliberates]

15 JUDGE MUMBA: We are taken by surprise,

16 because we were under the impression that your

17 continuing as Defence counsel was a matter that was

18 settled. The Trial Chamber has decided that you

19 continue as Defence counsel and the trial continues.

20 In the meantime we are asking the registry to send the

21 signing officer to get a representative of the

22 Registrar to come to this Trial Chamber and explain

23 what the position is. We continue the trial. You go

24 ahead with cross-examination.

25 MR. JOVANOVIC: [Interpretation] Thank you,

1 Your Honour.

2 WITNESS: WITNESS 51 [Resumed]

3 Cross-examined by Mr. Jovanovic:

4 [Cont'd]

5 Q. Good morning.

6 A. Good morning.

7 Q. I am going to ask you a few more questions to

8 try and clarify some matters.

9 A. Yes. Go ahead.

10 Q. After your departure from Foca, in your

11 statement you say you went to see a doctor. Could you

12 please tell us where you went to see the doctor, why,

13 how long your treatment lasted, and so on?

14 A. Do I have to tell you? You know why I went.

15 Q. You have --

16 A. I state in my statement why I had to go and

17 see the doctor, so I think it's quite clear.

18 Q. Let me reformulate my question. You went

19 because you had health problems caused by the incidents

20 that occurred while you were in detention?

21 A. Yes, that's right. That's why I had to go

22 and see a doctor.

23 Q. Did your treatment last long?

24 A. Well, I don't know how long it lasted. Do I

25 have to say how many days it lasted? I had to go and

1 see a doctor, I had to be examined, I had to go for

2 checkups, because everything that was done for me was

3 not -- everything that was done to me was not because I

4 wanted it to happen.

5 Q. Well, you needn't tell me how long, how many

6 days, but could you just say whether it was a week, two

7 weeks, ten days?

8 A. I went for checkups for as long as I thought

9 it was necessary, until I felt that I was better, was

10 feeling better.

11 Q. Do you have any medical documents on that

12 treatment?

13 A. No, I do not.

14 Q. Thank you.

15 MR. JOVANOVIC: [Interpretation] The witness

16 has her statement in front of her in the language which

17 she understands.

18 Q. Would you please turn to page 6 of your

19 statement.

20 A. I have page 6 in front of me.

21 Q. Now, look at the last paragraph, please.

22 MR. JOVANOVIC: [Interpretation] And Your

23 Honours, that paragraph begins with the following

24 words: the name S50. It begins with the name of a

25 person, and that person has been designated the number

1 S50.

2 A. Do you want me to read this out?

3 Q. I should like to discuss this matter with

4 you.

5 A. Yes, go ahead.

6 Q. On that occasion did this particular

7 individual -- was this particular individual taken out

8 alone or were they with somebody else?

9 A. Do you mean the first person, or who? Who

10 are you thinking of?

11 Q. You know that we were not allowed to state

12 names. Yes, and I do mean her. Was she alone when she

13 was taken away or was she with somebody else?

14 A. I don't know. I don't remember whether she

15 was alone or with anybody else. I just know that there

16 was always a rotation; some would be returned, others

17 would be taken out. We did not want things to happen

18 as they did to us, but unfortunately that's how it was.

19 Q. If I understand you correctly, you cannot

20 answer my question.

21 A. Why do you mean I can't answer? How do you

22 mean?

23 Q. Let me repeat the question. Do you remember

24 whether on that particular occasion this individual was

25 taken out alone, or was she taken out with somebody

1 else?

2 A. Well, I've already told you. I don't know.

3 I don't know.

4 JUDGE MUMBA: The witness has answered. You

5 see, the witness will not give you an answer you want,

6 okay? The witness will give answers according to what

7 she knows. She is under solemn declaration to do so.

8 If she doesn't know, she can't remember; that's it.

9 MR. JOVANOVIC: [Interpretation] The problem

10 was entirely my own. I did not understand what she

11 said, Your Honour. Of course she will answer what she

12 knows. I don't wish to elicit anything else.

13 Q. Tell me, please -- well, let's put it this

14 way. I'm going to say something and then you can say

15 if I'm right or not. Your living conditions in the

16 Partizan Sports Hall were terrible; isn't that correct?

17 A. Yes, that's right. They were awful, not

18 conducive to living.

19 Q. You didn't have anywhere to live?

20 A. No.

21 Q. You weren't able to eat?

22 A. No.

23 Q. You had no hygienic conditions?

24 A. No.

25 Q. For you and other women there, it was

1 terrible, and awful things happened to you?

2 A. Yes. Dreadful things happened to us, things

3 that one couldn't even live through. It would be

4 terrible for any normal man, and nobody would survive,

5 but it seems that we have survived somehow, just to

6 show that what -- to tell the truth about what happened

7 to us.

8 Q. During that period of time were you afraid

9 for your life?

10 A. Yes, I was always afraid for my life, and I'm

11 still afraid. I still have that fear from all the

12 things that I had to live through and experience, and I

13 still don't know if you can be normal and go through

14 things like that; with my four children, let me add.

15 Q. How many children were with you?

16 A. There were over 20 children. The youngest

17 child was 1 year old, and the oldest child that was

18 there was 18.

19 Q. I meant your children. How many of your

20 children were with you?

21 A. I've already said, four of my children. I

22 had my four children that I gave birth to. My four

23 children were there with me.

24 Q. Would you turn to page 8 of your statement,

25 please, and look at the last sentence, which reads: "I

1 was taken to the Partizan just once." And you go on to

2 explain, and you have signed this. And let me quote:

3 "I think that the reason I was taken away only once

4 was that, whenever I could, at night I would escape

5 from Partizan and wait for morning." Next to the

6 Partizan there were some bushes?

7 A. Yes, that's right. There were some bushes.

8 Q. "That night I spent in hiding. There were

9 many holes in the fence, and it wasn't difficult to go

10 out and hide. The guards..." And then it goes on to

11 say, "I think that because of that I was just taken

12 away and raped once. The guards did not stop us going

13 out into the courtyard."

14 Now, I am interesting in knowing the

15 following: If your conditions were as you have

16 described them, and if you were afraid for your life,

17 for your very survival, why didn't you try to escape?

18 A. To escape where? Where could I escape? Did

19 we have any money? Did we have any transport? Did we

20 have any resources? How could I escape? I had 100

21 marks. I had one hundred marks. The last 100 marks

22 they took away from me when I arrived in Foca. How

23 could I go anywhere? Who could I pay for my ticket?

24 Who would take me out? Who would take me on? Where

25 would I go?

1 Q. Well, I understand you. You're trying to

2 escape from a prison by bus, paying a ticket?

3 A. Well, of course. How else? How could I

4 escape? Everything was burnt. I have no house. Where

5 would I live? In burnt-out houses in Foca, where

6 nobody could live?

7 Q. Thank you. I should now like to ask you a

8 few things about Zoran Vukovic.

9 A. Yes, go ahead.

10 Q. This is on page 9 of your statement. Could

11 you look at page 9, please. Have you found the last

12 paragraph?

13 A. Yes, I have. We read it out yesterday.

14 Q. Yes, we did. If you have nothing against it,

15 I would like to read this out again slowly.

16 JUDGE HUNT: Whereabouts on the page?

17 MR. JOVANOVIC: [Interpretation] I do

18 apologise, Your Honour. In my text it is page 9, the

19 last paragraph of page 9, and it begins, "I remember

20 that Zoran Vukovic." It's on page 10, interpreters

21 note.

22 JUDGE HUNT: Thank you.

23 MR. JOVANOVIC: [Interpretation]

24 Q. Zoran Vukovic was one of the Serb soldiers

25 who took your daughter out. In your second sentence

1 you state, "I had heard about Zoran Vukovic before the

2 war." Now, I ask you, what did you hear about Zoran

3 Vukovic?

4 A. Well, I heard that there was a man named

5 Zoran Vukovic, but I didn't know him personally, and

6 I've already said that.

7 Q. We don't seem to be understanding each

8 other. We're talking about the Zoran Vukovic who took

9 out your daughter. And in continuation of your text,

10 you said, "I heard about him before the war." From

11 this I assume that you heard about Zoran Vukovic, the

12 Zoran Vukovic who took out your daughter.

13 A. No, I don't agree with that. I said that I

14 heard that there was a man named Zoran Vukovic, but I

15 said that I did not know him personally, no. But, yes,

16 he did take my daughter out. And I stand by that. I

17 have taken the oath here and said that I will tell the

18 truth. And she was taken out and she wasn't even 17.

19 And you can ask me whatever you like, but that is the

20 truth, that is what happened and nothing else. And I

21 have taken the oath here to tell the truth before this

22 Tribunal and in front of all the people here. And I

23 wanted to tell the truth once and for all so that

24 people know what happened. And did it have to happen

25 to us? Did we have to be raped?

1 Q. We heard -- have heard your story several

2 times. Would you now refrain from that and answer my

3 questions.

4 A. Yes, go ahead.

5 Q. Do you know how many Zoran Vukovics there are

6 in Foca?

7 A. Yes, I do. There are three, with the one

8 that's here. But this one that is here, that's the one

9 I'm talking about now.

10 Q. So you heard something before the war about

11 this particular Zoran Vukovic?

12 A. Not heard about him. I heard about other

13 Zoran Vukovics as well, that there were three Zoran

14 Vukovics. But as far as my daughter is concerned, this

15 is the Zoran Vukovic I'm talking about, the one that's

16 here.

17 Q. If I tell you there are 12 Zoran Vukovics in

18 Foca --

19 A. I don't know. I heard that there are three.

20 Let there be a hundred. I couldn't care less. I can't

21 know everybody. Perhaps there are people with my own

22 name in the hundreds. I really wouldn't know.

23 Q. But what Zoran Vukovic did you hear had

24 become a criminal?

25 A. For me a man is a criminal if he was -- if he

1 did something to me that was criminal. That man for me

2 is a criminal, who inflicted evil on me. And I can't

3 forget what he did as long as I live.

4 Q. I'm not asking you what you consider to be a

5 criminal; I am asking you who did you -- who told you

6 that Zoran Vukovic had become a criminal? And in that

7 way you have described him and --

8 A. I experienced his crimes personally, on my

9 own child. I experienced this, and that is the man.

10 Q. Well, we can go on like this forever. I ask

11 you one thing, you're answering something quite

12 different. But let's proceed.

13 Yesterday during your testimony you said that

14 you did not see that you were pitiful and in a terrible

15 state and that you were afraid and that it was dark.

16 You are giving -- you gave the wrong description of an

17 individual who is to be found here in the courtroom,

18 and yet you say that you're 99 per cent certain. Could

19 you explain that to me?

20 A. The individual that I talked about is here

21 personally. And as for my description, I cannot

22 guarantee my description one hundred per cent, because

23 I was afraid. I was afraid throughout my detention,

24 for all the 40 days that I was kept there I was

25 afraid. And I kept crying day and night.

1 Q. Did you talk to anybody before you came to

2 this courtroom yesterday or the day before?

3 A. Who do you think that I talked to?

4 Q. That's what I'm asking you.

5 A. No. No. Who would I talk to?

6 Q. Did anybody tell you what this courtroom

7 looks like? Did they describe it to you?

8 A. Who could have?

9 Q. Well, I'm asking you that. Did anyone?

10 A. I came here yesterday and I came here again

11 today.

12 Q. Before yesterday, did anybody tell you what

13 this courtroom looked like?

14 A. No.

15 Q. Very well. I have another question for you.

16 Continuing on through the text that we have just been

17 reading, I have a question to ask you before that. How

18 long did you spend in Partizan?

19 A. I spent 40 days in Partizan. On the 3rd of

20 July, my house was burnt.

21 Q. How many times during that period was your

22 daughter taken away?

23 A. I don't know. I couldn't tell you the number

24 of times.

25 Q. Was it more than five?

1 A. She was taken away quite a few times. Should

2 she have been taken away at all?

3 Q. Was it always the same people that took her

4 away?

5 A. No, they weren't always the same people.

6 JUDGE MUMBA: This evidence has been repeated

7 how many times, so many times. Can you avoid asking

8 for a repetition of the evidence which the witness has

9 already given? Because even if evidence is given

10 during examination-in-chief by the Prosecution, it is

11 still evidence, so please don't ask her to repeat what

12 has already been said. Go ahead with other questions.

13 MR. JOVANOVIC: [Interpretation]

14 Q. How come you do not remember the name of any

15 other person except for the name of Zoran Vukovic?

16 A. I do not remember any other person.

17 Actually, I did not enumerate the names of those who I

18 remembered, but --

19 Q. You said, "I do not remember the names of the

20 other soldiers who took Witness number 50 away."

21 A. Yes.

22 Q. Yes. How come you remember only one name?

23 A. Well, that first name I remember took away

24 her youth when she was younger than 17, and this was

25 done by force, not voluntarily.

1 Q. Where did this happen?

2 A. In Buk Bijela. I said that five times until

3 now.

4 MR. JOVANOVIC: [Interpretation] Thank you,

5 Your Honour. I have no further questions.

6 JUDGE MUMBA: Counsel, any other counsel

7 wishing to cross-examine?

8 MR. PRODANOVIC: [Interpretation] I do, Your

9 Honour, by your leave.

10 JUDGE MUMBA: Please, go ahead.

11 Cross-examined by Mr. Prodanovic:

12 [Interpretation]

13 Q. Can you tell me how many men were in your

14 village in the age group between 18 and 65?

15 A. No, I don't know exactly. I never did the

16 counting.

17 Q. Can you tell me how many men were arrested on

18 the 3rd of July?

19 A. I can tell you that 28 were killed,

20 disappeared, on the 3rd of July. Not only men, but

21 also women, children. There. And they've been missing

22 ever since. They found their bones. People know where

23 they were.

24 Q. Do you know where the rest were?

25 A. I don't know. I don't know. I was with my

1 group and I told you about that yesterday, who was with

2 me, who I was with, everything.

3 Q. You say that you were hiding in the woods for

4 two months. Who were you hiding with?

5 A. With my family. With my children.

6 Q. Was your husband with you?

7 A. Yes.

8 Q. Was he always with you?

9 A. Yes.

10 Q. Were women hiding separately from the men?

11 A. My husband was with me, and I don't think

12 they were hiding separately, because they would not

13 have been killed together otherwise. How could they

14 have killed them together otherwise. Where are the

15 young men who were killed? If they were hiding

16 separately they could not have been killed together

17 also in Foca, in the very same place.

18 Q. Before the war conflict broke out, were there

19 village guards in the village?

20 A. No. No. I did not see that. I don't know

21 anything about that. I was not interested in any kind

22 of politics or anything. I lived with my children. I

23 was a housewife in my own home.

24 Q. Since you were absent, you were hiding in the

25 woods, as you said. How could you see the Serbs that

1 they were armed?

2 A. Well, of course I could. My neighbours

3 passed right by my house. There's an asphalt road that

4 goes by my house. Every day they passed in trucks.

5 And of course I could -- they were shooting. Of course

6 I could see it.

7 Q. You said that the Muslims handed over their

8 hunting weapons.

9 A. Yes.

10 Q. Do you know whether there were any weapons

11 that were not surrendered?

12 A. That I do not know. As far as I know, no. I

13 don't know any people who had weapons. I know that a

14 month and a half or perhaps even more than that, before

15 the war, people came and collected these weapons, and

16 that's it.

17 Q. Do you know that during those days, and

18 before those days, Serbs were also being killed?

19 A. I don't know. I was not involved in

20 politics. I was not interested in anything. I thought

21 that what happened to me would not happen. What

22 happened to me is the worst kind of thing that can

23 happen to a person in a person's lifetime. I was not

24 involved in any kind of politics. I was not involved

25 in any kind of fighting. I was at my home. I don't

1 know.

2 Q. Do you know that on several occasions on the

3 road between Mjesaja and Tjentiste, there were several

4 Muslim ambushes on the occasion of which Serbs lost

5 their lives and your neighbours from Mjesaja?

6 A. I don't know. I don't know anything about

7 that. I didn't talk about this, I don't know about

8 this, and I don't want to talk about things I don't

9 know about. I talk about myself. Everyone can come

10 and say for themselves what they had lived through,

11 what they experienced. I am talking in my own name and

12 on behalf of my children.

13 Q. Do you know about the incident in June, when

14 an antitank mine killed several Serbs near your

15 village?

16 A. No. I don't know anything about that. I was

17 not involved in that kind of thing at all. I was not

18 employed. I was a housewife who took care of her

19 children at home, who did housework. I did not go

20 anywhere. I did not find things out.

21 Q. Did you ever pass by the Partizan building

22 before the war?

23 A. Yes, but very few times, perhaps only twice

24 in my life, until I was detained, where I spent quite a

25 bit of time.

1 Q. When you came to Partizan, were there iron

2 bars on the windows? Do you remember that?

3 A. There were bars. I don't know which side

4 they were on, but there were bars.

5 Q. Were you free to leave the Partizan building

6 to go out into the yard?

7 A. Yes. When they would take one of us out,

8 then nobody would forbid us to leave. Not a single

9 guard ever said during my stay there in prison, not a

10 single guard ever said, "Don't take this girl. Don't

11 take this woman out," and they were supposed to guard

12 us.

13 Q. I'm putting concrete questions to you, and I

14 want a concrete answer.

15 A. Yes. Go ahead.

16 Q. I asked you whether you were able to leave

17 Partizan when you were not being taken away? There

18 were such moments when nobody came?

19 A. Yes, but there were very few such moments.

20 We could go to the steps and back. Where else could I

21 go? There was no way out.

22 Q. Could you go to the nearby shops?

23 A. I did not. I never went out.

24 Q. Do you know whether anybody else went out?

25 A. I don't know. Sometimes some woman would

1 bring bread. I don't know where from. I never went

2 out.

3 Q. Do you know Veda Markovic?

4 A. Veda who?

5 Q. Let me help you. Was there a Serb lady who

6 lived in the vicinity of Partizan?

7 A. Yes.

8 Q. Is that perhaps Veda Markovic?

9 A. I really don't know her name. That was the

10 first time I saw her in my life.

11 Q. Did you go to her apartment, or anybody else

12 who was there?

13 A. She would come to see us, perhaps twice.

14 Q. Do you know whether a doctor came to the high

15 school centre?

16 A. I don't know. Yes. Yes. Yes. For the

17 children. Yes. Yes, you're right. There was a

18 3-year-old child who was wounded and there was a woman

19 who was wounded, two women were wounded. They were

20 taken to hospital to get bandages. They were taken

21 about once or twice, I think.

22 Q. Do you know why you were transferred from the

23 high school to Partizan?

24 A. No. No. I don't know.

25 Q. Did you hear about Serb refugees being

1 brought to the high school centre after you were taken

2 from there, people whose houses were burned?

3 A. No. No way. I did not hear about that. How

4 could I?

5 Q. While you were in the high school centre, was

6 there a TV crew that came there to interview someone

7 who was there?

8 A. I don't know. I don't know.

9 Q. Do you still stick to the claim you made

10 yesterday, that you saw Gagovic come to Partizan in a

11 yellow Golf, and that you saw him take person number 48

12 from Partizan?

13 A. Yes. Yes, he did.

14 Q. And that person number 48 told you that

15 Gagovic raped her?

16 A. Yes. Yes.

17 Q. Do you also abide by your claim that person

18 number 48 told you that Gagovic raped her in Sukovac?

19 A. Yes. Yes.

20 Q. Let us clarify this. This neighbourhood is

21 outside Foca, on the left side of the Drina River?

22 A. Yes.

23 Q. Do you know that in the neighbourhood of

24 Sukovac a single house has an elevator? Is there a

25 single house in this neighbourhood with an elevator?

1 A. No.

2 Q. What does this no mean, that you don't know

3 about it?

4 A. No, I don't know about it. I never went to

5 houses in Sukovac so that I could know whether there

6 were elevators there or not.

7 Q. Do you know whether there is a single

8 apartment block in Sukovac?

9 A. I don't know.

10 Q. While you were in Partizan do you know

11 whether any person was exchanged?

12 A. We were supposed to be taken to Gorazde, but

13 we never went. I don't know about the rest. No body

14 was exchanged while I was there and no one was

15 exchanged from my group, that is. The three girls who

16 remained, remained in Foca, and the rest of us got out.

17 THE INTERPRETER: Microphone for

18 Mr. Prodanovic.

19 MR. PRODANOVIC: [Interpretation]

20 Q. Do you know whether some persons went without

21 being exchanged? Let me be clear on this.

22 A. One group went to Cajnice supposedly and was

23 returned.

24 Q. Can you tell me when this was?

25 A. No.

1 Q. Can you describe the persons involved?

2 A. I know exactly about one person. I can write

3 down that person's name. But I cannot remember the

4 rest, so I can't write their names down.

5 Q. Can you write the name of that person who

6 went to Cajnice for this exchange?

7 A. Yes.

8 MR. PRODANOVIC: [Interpretation] Your Honour,

9 could the witness please write the name of this person

10 who went to Cajnice to be exchanged? This is a

11 protected witness.

12 [Witness complies]

13 JUDGE MUMBA: I just want to clarify this

14 part of the evidence with the witness, because at one

15 time she appeared to be saying that there was a group

16 which went to that place apparently to be exchanged but

17 they returned. So I just want the witness to clarify

18 whether the person she has written down never came

19 back, or was not returned once she was taken for

20 exchange.

21 A. The person that left returned. She was not

22 exchanged. She was taken away after that and she

23 stayed in Foca for eight months.

24 JUDGE MUMBA: Is that number 75?

25 MS. UERTZ-RETZLAFF: Yes, Your Honour.

1 MR. PRODANOVIC: [Interpretation] I would like

2 this to be admitted into evidence, Your Honour.

3 THE REGISTRAR: [Interpretation] This will be

4 D16, Defence Exhibit D16, and this is a confidential

5 piece of evidence.

6 JUDGE MUMBA: Thank you.

7 MR. PRODANOVIC: [Interpretation]

8 Q. Do you know how many days these persons who

9 were taken to Cajnice for an exchange stayed in

10 Cajnice?

11 A. I don't know. I think it was two days, but

12 I'm not one hundred per cent sure. They were taken

13 back.

14 Q. Did you ever go, either by yourself or with

15 someone, to Gagovic to report what happened, what was

16 happening to you?

17 A. Yes. I went with a woman, but nothing came

18 out of it. It was just as if we didn't do anything

19 about it. I said, "Why were we suffering to such an

20 extent? Why weren't we allowed to leave? Why were we

21 detained?" No one ever came to ask.

22 Q. Can you write the name of this person with

23 whom you went to Gagovic to complain about the

24 situation in Partizan?

25 A. I cannot write that person's name, because I

1 don't know it exactly.

2 Q. I don't understand. You know that you went

3 to complain with a woman and you don't know who you

4 went with?

5 A. I went to ask. I personally went.

6 Q. If I understood you correctly, you said that

7 you went with a woman. What is true, that you went on

8 your own or that you went with a woman?

9 A. I went, and then this woman went after me. I

10 know that I went. That is what I can say.

11 Q. So on what basis do you claim that this other

12 woman went too?

13 A. Well, she told me that she went.

14 Q. I don't understand. If she told you that,

15 how come you don't know her name?

16 A. I don't.

17 JUDGE MUMBA: Should she have known her

18 name? Go ahead, counsel.

19 MR. PRODANOVIC: [Interpretation]

20 Q. I apologise. You said that before your

21 memory was better than it is know. That says that --

22 that means that your memory was better in 1995, when

23 you made your first statement to the investigators.

24 Could you please tell me, how come you did not mention

25 Dzaga then and yesterday you did mention Dzaga?

1 A. I heard about Dzaga while I was detained in

2 Foca. Of course I'm going to say that I heard of this

3 person when the woman asked me nicely, "Have you heard

4 of this person?" Yes.

5 Q. On page 7, the one-but-last line, you say

6 that individuals 189 and 48 were taken out with you.

7 Yesterday you said that on that first occasion it was

8 189 and 47 that were taken out with you. What is

9 correct? What you said yesterday or what you said in

10 1995 when you gave your statement to the investigators?

11 A. Number 48, woman 48, and woman 89 were taken

12 out with me, and that is 100 per cent sure. They were

13 -- we were taken out -- all taken out together, all

14 three of us and we were all raped. What else do you

15 want me to say? Is that enough.

16 Q. Well, please don't be angry. You have no

17 reason to be angry?

18 A. What do you mean I have no reason? Did I

19 have a reason to be raped? Did I want to be raped?

20 THE INTERPRETER: Microphone, please,

21 counsel.

22 MR. PRODANOVIC: [Interpretation]

23 Q. Could you tell us what is the exact figure?

24 A. I have just enumerated the individuals who

25 were with me. I told you the numbers. I don't have to

1 repeat things all the time, do I?

2 MS. UERTZ-RETZLAFF: Your Honour, may I

3 interrupt.

4 JUDGE MUMBA: Yes.

5 MS. UERTZ-RETZLAFF: I just want to point out

6 to counsel that we don't have a number 47 on the sheet

7 that the witness was looking at when she was asked

8 these questions. I'm not aware that she said 47, but

9 obviously this then is just a mistake, because the

10 person she's talking in the statement and the person

11 that's listed here was 48, and there's no 47 on it at

12 all.

13 MR. PRODANOVIC: [Interpretation] Perhaps

14 there was an error in the interpretation. I said that

15 yesterday the witness said that with her were taken off

16 individuals 189 and 87, and this can be checked in the

17 transcript. And in the statement she gave to the

18 investigators she said that on that first night

19 individuals were taken away with the following

20 numbers: 189 and 48. I asked her what was correct,

21 whether she said -- what she said on the first occasion

22 or what she said yesterday. And I think I was clear.

23 I didn't mention 47 -- 87.

24 JUDGE MUMBA: Let the witness explain.

25 Witness, just clarify this bit.

1 A. I said yesterday that it was 189, the person

2 that was taken away with me, and number 48 was with me

3 when they took us off to rape us, and that is

4 absolutely certain. Those two individuals were with me

5 the whole night. I said that yesterday. I said the

6 same number yesterday, because I had the same list in

7 front of me.

8 MR. PRODANOVIC: [Interpretation]

9 Q. Let us move on, although she did say 87

10 yesterday, and this can be checked out in the

11 transcript.

12 You said before you were arrested by the

13 Serbs, that one woman went off to give herself up and

14 to register. Could you give us the -- write down the

15 name of that individual?

16 A. No, I can't.

17 Q. Well, this brings me to the end of my

18 questioning. Could you tell us how many days you spent

19 in the secondary school centre?

20 A. I can't tell you exactly. I didn't say the

21 exact number of days yesterday or today. I don't

22 know. But I do know exactly how long I spent in Foca,

23 whether I was in the secondary school centre or in the

24 Partizan. It was all the same to me.

25 Q. Could you tell us when you were transferred

1 to Partizan?

2 A. I can't say. If I could tell you how long I

3 was in the secondary school centre exactly, then I

4 would know exactly when I was taken to Partizan, but I

5 don't know exactly.

6 Q. You said yesterday --

7 JUDGE MUMBA: Counsel, we've been through

8 this again so many times. Please do not ask the

9 witness to repeat what she has said before, as much as

10 possible.

11 MR. PRODANOVIC: [Interpretation] I have one

12 more question in this area, Your Honour.

13 Q. Yesterday you said that ten days prior to

14 your departure that individuals 87, 75, and DB were

15 taken out of Partizan and that they never returned.

16 A. Yes, that's true.

17 Q. You left Foca on the 13th of August?

18 A. Yes, that's correct.

19 Q. Do you agree with me that 87, 75, and DB

20 persons were taken from Partizan on the 3rd of August,

21 1992, that is to say, ten days before you left on the

22 13th?

23 A. I say again: I don't know the exact date. I

24 didn't state the exact date yesterday. I don't know

25 the exact date. But I do know that the individual who

1 was taken away, and I'll tell you her number in just a

2 moment, she stayed in Foca for eight months. Just wait

3 one second and I'll tell you exactly who that person

4 was. It was number 75.

5 MR. PRODANOVIC: [Interpretation] Thank you,

6 Your Honour.

7 JUDGE MUMBA: Any questions.

8 MR. KOLESAR: [Interpretation] I have no

9 questions, Your Honour.

10 JUDGE MUMBA: Thank you. Any re-examination

11 by the Prosecution?

12 MS. UERTZ-RETZLAFF: Yes, Your Honour. I

13 want to clarify one matter that was raised by Defence

14 counsel Jovanovic, Defence counsel of the accused Zoran

15 Vukovic

16 Re-examined by Ms. Uertz-Retzlaff:

17 Q. Witness, Defence counsel asked you if before

18 yesterday when you came into the Court you were

19 explained the outset of this courtroom, and you said

20 "no". Let me ask you a question. Were you here

21 immediately in this courtroom immediately before you

22 started to testify to get the technical procedure with

23 the voice alteration fixed?

24 A. Yes, that's right. I was. I did come in

25 before the actual trial.

1 Q. And on this occasion were you explained in

2 general terms the outset of this courtroom?

3 A. Yes, they did explain that to me. I said

4 that I hadn't entered the courtroom before yesterday,

5 but before I actually sat down to testify, I did come

6 in to see what the courtroom looked like. But I never

7 came before yesterday, before I was to come yesterday

8 to testify. So before I actually sat down and came in

9 to testify, I did come in once to see the layout of the

10 courtroom. That was what happened yesterday, before I

11 actually testified, but I have never been here before

12 that. That's what I wanted to say. Before I came here

13 yesterday, I had never been here. But before I

14 actually testified yesterday, I did come in for a

15 moment to see what the courtroom looked like. That's

16 true.

17 Q. On this occasion, was the outlay of the

18 courtroom explained to you in general terms?

19 A. Yes, that's right.

20 Q. On that occasion was the exact position of

21 the accused pointed out to you, especially the exact

22 position of the accused Zoran Vukovic?

23 A. No. I was told who sits where, but nobody

24 said by name where people would be sitting. They told

25 me where people would be, but nobody said that

1 such-and-such a person would be sitting in

2 such-and-such a place.

3 MS. UERTZ-RETZLAFF: Your Honours, that is

4 the only point I wanted to raise.

5 JUDGE MUMBA: Yes. Thank you. There are no

6 questions from the bench. Thank you very much,

7 Witness, for testifying to the Tribunal. You are

8 free. You can now go.

9 WITNESS: Thank you too.

10 JUDGE MUMBA: We have to have the blinds down

11 before the witness can leave, actually.

12 MS. UERTZ-RETZLAFF: Your Honours, the

13 Prosecution likes to switch position, because now

14 another member of the Prosecution will question the

15 next witness.

16 JUDGE MUMBA: Yes. That's okay.

17 THE REGISTRAR: [Interpretation] Is it

18 possible to have a short break of five to ten minutes

19 in order to fine tune the technical aspects for the

20 next witness?

21 JUDGE MUMBA: Okay. Before we do so, I would

22 like to inform our counsel for Zoran Vukovic, that is,

23 Mr. Jovanovic, that the Registrar has actually decided

24 that you continue as counsel for Zoran Vukovic, until

25 further notice.

1 What I'll ask you to do is you'll get a copy

2 of the decision and you must study it carefully,

3 because there are certain things that the Registrar has

4 to deal with before a final decision can be made. But

5 otherwise you are to continue as Defence counsel.

6 [The witness withdrew]

7 JUDGE MUMBA: The Court will rise for ten

8 minutes to allow the technical problems to be settled.

9 --- Break taken at 10.25 a.m.

10 --- On resuming at 10.35 a.m.

11 [The witness entered court]

12 JUDGE MUMBA: Yes. May the witness please

13 make the solemn declaration. Can she stand up,

14 please.

15 THE WITNESS: [Interpretation] I solemnly

16 declare that I will speak the truth, the whole truth,

17 and nothing but the truth.

18 THE WITNESS: WITNESS 50

19 JUDGE MUMBA: Yes. You can sit down.

20 Examined by Ms. Kuo:

21 Q. Good morning. With the assistance of the

22 usher, I'd like to show this witness Exhibit 186. This

23 copy has also been previously given to Defence counsel,

24 and I believe the Court also has copies.

25 Witness, do you see your name on Exhibit 186?

1 A. Yes.

2 Q. And next to it do you also see the number 50?

3 A. Yes.

4 Q. Throughout these proceedings you will be

5 referred to by that number. Do you understand?

6 A. Yes.

7 Q. Witness, do you also see your birth date

8 under your name?

9 A. Yes.

10 Q. On that piece of paper do you also see your

11 mother's name?

12 A. Yes.

13 Q. And what is the number next to your mother's

14 name?

15 A. Number 51.

16 Q. Do you see your father's name?

17 A. Yes, I do.

18 Q. What is the number next to his name?

19 A. Number 52.

20 Q. And do you see your grandmother's name?

21 A. Yes.

22 Q. What is the number next to her name?

23 A. Number 62.

24 MS. KUO: Your Honours, the Prosecution

25 wishes to enter into evidence Exhibit 186.

1 JUDGE MUMBA: Can we have the number formally

2 entered, please.

3 THE REGISTRAR: [Interpretation] This will be

4 document 186, the Prosecution evidence, and this is a

5 confidential exhibit.

6 MS. KUO:

7 Q. Before we continue, I'd like to ask you if

8 you're taking any medication this morning.

9 A. Yes.

10 Q. What are you taking?

11 A. A tablet to calm me down.

12 Q. Is this a prescription from a doctor?

13 A. No.

14 Q. Does the fact that you're taking this

15 medication affect your ability to understand or to

16 answer questions today?

17 A. No.

18 Q. Do you believe that it affects your memory in

19 any way?

20 A. No.

21 Q. Okay, Witness. How old are you?

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 Q. Do you know when the war in Foca started?

20 A. On the 8th of April, 1992.

21 Q. Did you hear or see anything at that time?

22 A. I saw via the media that there was war going

23 on, there was shelling, and I could hear the shelling

24 as well.

25 Q. Did you also see soldiers in your village?

1 A. From time to time.

2 Q. Did the war in Foca affect your life in your

3 village?

4 A. Yes, it did, absolutely.

5 Q. Can you explain in what way?

6 A. Well, for example, we couldn't go into town

7 anymore. We weren't able to buy food, cigarettes,

8 anything like that, any toiletries, anything, anything

9 you wanted -- you needed, whether you needed to go to a

10 doctor or anything else, you couldn't go. It was

11 impossible to go into town.

12 Q. Were you scared?

13 A. I was too scared.

14 Q. Can you explain why you were scared or what

15 you were scared of?

16 A. Well, I was afraid that something bad would

17 happen to me, that I would be killed or something like

18 that, and actually, all the things that I was afraid of

19 I experienced on my own skin later on. That's how it

20 turned out.

21 Q. Witness, what ethnicity are you?

22 A. Muslim.

23 Q. Did the fact that you were a Muslim have

24 anything to do with why you were scared?

25 A. Well, yes, because only the Serbs were armed,

1 nobody else.

2 Q. At the beginning of May 1992, did you and

3 your family begin to live in the woods?

4 A. Yes.

5 Q. Why?

6 A. We saw more of the army and our neighbours

7 wore uniforms. They had weapons. And we were afraid

8 that we might be burnt in our homes, which had started

9 to happen in the surrounding villages. And for these

10 reasons, and other reasons, we withdrew -- we took to

11 the woods.

12 Q. How far were the woods from your house?

13 A. Not very far.

14 Q. Did you ever go back to your house while you

15 were in the woods?

16 A. Yes. We would come during the daytime to

17 prepare some food, something to eat. We would have a

18 change of clothing. And then as dusk fell, we would go

19 back.

20 Q. So you were sleeping in the woods too?

21 A. Yes.

22 Q. How many people were with you in the woods?

23 A. About 15.

24 Q. Do you know if there were other groups living

25 in the woods?

1 A. I think there were. The people a little

2 further off I think went to the woods as well.

3 Q. Do you know what ethnicity they were?

4 A. Muslims.

5 Q. And the people living with you in the woods,

6 were they also Muslims?

7 A. Yes.

8 Q. Do you know if there were any Serbs who were

9 also hiding in the woods at that time?

10 A. No.

11 Q. On July 3rd, 1992, was your village attacked?

12 A. Yes, it was.

13 Q. What time of day was that?

14 A. In the early morning, at about 6.00 a.m.

15 Q. Where were you at that time?

16 A. In the shelter we were in before in the

17 woods.

18 Q. What did you see?

19 A. At first I didn't see anything. You could

20 just hear shooting all over the place. It was

21 terrible. There was such a lot of shooting. It was

22 absolutely awful. In fact, the shooting woke me up.

23 Q. What did you do when you heard the shooting?

24 A. We got dressed quickly and we thought we

25 should get away from that improvised tent and go

1 further into the woods, and that's what we did

2 afterwards.

3 Q. Was your father with you at that time?

4 A. That night he was, but before I woke up and

5 before the shooting began, he had gone down to the

6 house. He wasn't there.

7 Q. So who was with you then? What other members

8 of your family?

9 A. My mother, my two brothers, and my sister;

10 and the other people were other members of my broader

11 family.

12 Q. Where did you go when you went further into

13 the woods?

14 A. I don't understand.

15 Q. Did you go someplace specific, or did you

16 stay someplace?

17 A. Yes. We went to a spot, a place, and we

18 thought that it would be a little safer there, because

19 it was situated between the Serbian and Muslim houses,

20 equal distance from both these groups of houses.

21 Q. How long did you stay there?

22 A. I think we stayed until the 5th of July, when

23 we were captured. I don't know exactly.

24 Q. Could you describe how you were captured?

25 A. Well, I seem to remember that very badly now,

1 because the night between the 3rd and the 4th of July,

2 there was such terrible shooting going on in the

3 neighbouring village called Trosanj, in the village

4 above my own, and I was so afraid that I really don't

5 know what happened. I just know that we went onto a

6 road and that four soldiers dressed in uniform came out

7 before us, and one of my neighbours was among them. I

8 knew him. I've known him ever since I was a child, for

9 as long as I've lived. That is something that I

10 remember most vividly, whereas what happened before is

11 all a haze to me. I remember it faintly.

12 Q. And the neighbour that you mentioned, what

13 ethnicity was he?

14 A. He was a Serb.

15 Q. What happened when you saw these four

16 soldiers?

17 A. Well, nothing. That neighbour came up to us

18 and he said that there was no reason to be afraid, that

19 as we were good neighbours, we would be taken to

20 Montenegro, to free territory, that we're not to blame

21 for anything, and we weren't to blame, because we were

22 just women and children. He said that they would just

23 help us to be transferred to Montenegro and that

24 everything would be all right.

25 Q. After he told you that, what did you do?

1 A. They took us off to Buk Bijela, to the motel

2 in Buk Bijela, which was close by.

3 Q. Did you know -- or had you been to Buk Bijela

4 before this?

5 A. Yes. Yes, I did know it.

6 Q. Could you describe what it was?

7 A. You mean the facility, the buildings, or

8 what?

9 Q. Yes.

10 A. All right. There was a motel, the Buk Bijela

11 motel, where there was a restaurant, a kitchen, and so

12 on. And opposite the motel was something like some

13 barracks, some prefabricated huts, which were there

14 maybe for the workers to spend the night in.

15 MS. KUO: With the assistance of the usher, I

16 would like to show the witness Prosecution

17 Exhibit 11, number 7416. This, again, is an enlarged

18 version of what is in the binders. If the usher could

19 also, after the witness has looked at the exhibit,

20 place it on the ELMO.

21 Q. Do you recognise what is in the photograph

22 before you?

23 A. Yes, I do recognise it.

24 Q. What is it?

25 A. Yes.

1 Q. Can you describe what it is in the

2 photograph?

3 A. The arrow points to the motel. The buildings

4 around it, these buildings further up here [indicates],

5 when I was talking a moment ago, I thought these were

6 the barracks. This with the black roof is the motel

7 and restaurant itself.

8 Q. And where are the barracks? Can you indicate

9 that, please?

10 A. Yes. These are the barracks [indicates],

11 over here was well, all this. All these are barracks.

12 Q. And you're indicating the buildings with the

13 white roofs; is that right?

14 A. Yes. That's right.

15 Q. Thank you.

16 MS. KUO: Your Honours, I see we have only

17 five minutes before our break. May I request that we

18 take the break at this point so the next line of

19 questioning can continue uninterrupted.

20 [Trial Chamber deliberates]

21 JUDGE MUMBA: All right. We shall allow the

22 request by the Prosecution, and we shall break. And

23 perhaps we'll start five minutes early, 11.25.

24 --- Recess taken at 10.55 a.m.

25 --- On resuming at 11.26 a.m.

1 JUDGE MUMBA: We'll proceed with the

2 examination-in-chief.

3 MS. KUO:

4 Q. Witness, when you were taken to Buk Bijela,

5 were you taken in a group?

6 A. Yes.

7 Q. And were they all women and children in that

8 group?

9 A. There were two men, elderly, distantly

10 related to me.

11 Q. Did you see what happened to them when they

12 were taken to Buk Bijela?

13 A. I don't remember.

14 Q. When you were taken to Buk Bijela, where were

15 you told to go at first?

16 A. We were told that we were supposed to wait

17 for transportation in Buk Bijela. The neighbour I

18 mentioned a few minutes ago would organise

19 transportation for us in order to be transferred to

20 free territory.

21 Q. And when you arrived at Buk Bijela, where did

22 you go, or where were you taken?

23 A. We were taken to one of the rooms in these

24 barracks.

25 Q. Were you taken out separately from that room

1 at some point?

2 A. Yes.

3 Q. Who took you out?

4 A. Am I supposed to say the name?

5 Q. If you know the name, please say it.

6 A. A man named Zoran Vukovic took me out.

7 Q. Did you know this man from before the war?

8 A. I might have seen him before the war. The

9 face seemed very familiar to me. Whether I knew it

10 from before, I don't know.

11 Q. Did you know his name before the war?

12 A. I don't remember.

13 Q. Did you learn his name during the war?

14 A. On several occasions, yes.

15 Q. At the time that he took you out at Buk

16 Bijela, did you know his name?

17 A. I don't remember.

18 Q. What was he wearing when he took you out?

19 A. Military clothing, camouflage.

20 Q. Did he have any weapons?

21 A. Yes.

22 Q. Are you able to describe those weapons?

23 A. I know for sure that he had a pistol.

24 Whether he had something else, I cannot remember at

25 this moment.

1 Q. Where did Zoran Vukovic take you?

2 A. He took me to another room, approximately in

3 this last prefabricated building, on the bank of the

4 Drina River. I think that this room was at the end of

5 the hallway, because its window faced the Drina River.

6 Q. Was there anyone else in that room when you

7 arrived?

8 A. When we arrived, no.

9 Q. Could you describe the room; what kind of

10 furniture it was or how big it was?

11 A. It was meant to be a bedroom. It had two

12 beds, perhaps a night table by it, a cupboard. A real

13 bedroom.

14 Q. Were you told why you were being taken there?

15 A. I was told that I was supposed to be

16 questioned about something.

17 Q. What did Zoran Vukovic do when he took you to

18 that room?

19 A. He raped me.

20 Q. I'm sorry to have to ask you some specifics,

21 but the Court will need to know. Can you describe what

22 he did?

23 A. Yes. He pushed me onto one of the beds. He

24 asked me to put his penis into my mouth.

25 Q. And did he do that?

1 A. He did it himself.

2 Q. How long did that last?

3 A. I don't know.

4 Q. Did he say anything while this was happening?

5 A. He was saying things like: What am I afraid

6 of? Don't I know what sex is? Haven't I done it

7 before? That kind of thing. "Let's enjoy it." That

8 kind of thing.

9 Q. Were you scared?

10 A. Yes.

11 Q. Did you feel like you could do anything to

12 defend yourself?

13 A. It was impossible. He had a pistol. He

14 threatened. And even had I risked my own life there, I

15 was afraid for my family's lives. So I didn't dare do

16 anything.

17 Q. When did this stop?

18 A. I don't know. I can't say exactly.

19 Q. Did something happen?

20 A. I did not understand your question. Can you

21 rephrase it?

22 Q. I'm sorry. I meant, did something happen to

23 stop what he was doing to you?

24 A. I think so, yes. Yes. For sure something

25 happened. But I don't know whether these two soldiers

1 walked into the room or whether they knocked on the

2 door before that, or whether they were clamouring in the

3 hallway. At any rate, somebody came in and it stopped.

4 Q. And whoever came in, did they indicate that a

5 bus was ready to leave?

6 A. Yes.

7 Q. And what happened after that?

8 A. They put us onto a bus. And they also said

9 that they were taking us away from there; that we would

10 be reunited with the other women and children who were

11 also waiting to be transferred to free territory, and

12 straight from there they took us to the high school

13 centre in Foca.

14 Q. Was your mother on the bus?

15 A. Yes.

16 Q. Did you tell her at that time what had

17 happened to you?

18 A. I don't think I told her, but she was smart

19 enough to understand what had happened.

20 Q. Why didn't you say anything to her about what

21 had happened to you?

22 A. I thought that if I had to suffer, they

23 didn't have to know about it.

24 Q. Did you ever tell the details of what

25 happened to you there to anyone in your family?

1 A. Never.

2 Q. In 1995, do you remember speaking with

3 investigators from the Tribunal, at the end of August

4 and the beginning of September?

5 A. Yes, I remember.

6 Q. And you gave a statement at that time about

7 what happened to you during the war; is that right?

8 A. Yes.

9 Q. Did you tell the investigators at that time

10 the details of what happened to you at Buk Bijela, and

11 Zoran Vukovic?

12 A. I did not.

13 Q. Why not?

14 A. I don't know. Those words could not leave my

15 mouth.

16 Q. Over this past weekend, on Sunday, March

17 26th, did you come to the Tribunal and meet with an

18 investigator, and I was there as well?

19 A. Yes.

20 Q. Were you shown your previous statements?

21 A. Yes.

22 Q. Did you read your previous statements?

23 A. I read them.

24 Q. Were you asked at that time if you wanted to

25 correct or add anything to your statements?

1 A. Yes.

2 Q. Did you describe what Zoran Vukovic did to

3 you at Buk Bijela at that time?

4 A. I did.

5 Q. Why did you describe it then?

6 A. First of all, because of the oath I took

7 today, that I would speak the truth and nothing but the

8 truth. I knew I'd come to this courtroom. That's

9 why. And secondly, let it be known that it really

10 happened. It's not easier for me to speak about it

11 today, but nevertheless, I wanted everyone to hear

12 about it.

13 Q. Now, you mentioned, Witness, that you were

14 taken to Foca High School. Was that the school that

15 you were attending back in 1992?

16 A. Yes, it was the same school.

17 MS. KUO: I'd like to ask, with the

18 assistance of the usher, that the witness be shown

19 Prosecution Exhibit 11, photograph 7418 and 7419.

20 After showing it to the witness, if you could please

21 put it on the ELMO, that would be helpful.

22 Q. Do you recognise what is shown on these

23 photographs?

24 A. Yes.

25 Q. What is it?

1 A. That is the high school centre in Foca.

2 Q. Thank you. When you were taken to the high

3 school centre, were there people already there?

4 A. Yes.

5 Q. Were they also women and children?

6 A. Yes. Yes. These were people who were

7 arrested on the day when the village was attacked, on

8 the 3rd of July. On that same day they were brought to

9 the high school.

10 Q. So they were also people from your village,

11 people you knew; is that right?

12 A. Yes. Yes, they were.

13 Q. Do you know approximately how many people

14 were there all together at the high school with you?

15 A. Perhaps about 50. I don't know exactly.

16 Q. Was there anything there to sleep on?

17 A. There were some kind of mattresses, sponge

18 mattresses, and there were also some army blankets.

19 Q. Were you all placed into one room together or

20 into separate rooms?

21 A. No. We were all placed into one room.

22 Q. On the first day when you were brought to the

23 high school, did anything happen?

24 A. No, nothing.

25 Q. On the second day did anything happen?

1 A. Yes. On the second day, in the evening, a

2 group of soldiers came. They entered the classroom

3 that we were in. They stood in the middle of the

4 classroom, and they were pointing their fingers at

5 girls and women who were supposed to get up and go with

6 them to the other room.

7 Q. Did you recognise any of those soldiers?

8 A. Only Janko Janjic; not the others.

9 Q. How many soldiers came into that room?

10 A. I don't know exactly. I think there were

11 less than ten.

12 Q. How many girls did they pick out?

13 A. Eight, I think. Eight.

14 Q. Were you one of the girls that they picked

15 out?

16 A. Yes.

17 MS. KUO: With the assistance of the usher,

18 I'd like to show the witness Exhibit 187. This has

19 already been given to Defence counsel and to the

20 Court.

21 Q. On Exhibit 187, do you see the names of the

22 other girls who were picked out that day?

23 A. Yes.

24 Q. And I'd like for you to read this exhibit to

25 yourself and state the name -- I'm sorry. Do not state

1 the name; state the number or the initials next to the

2 name of the girls who were taken out with you on that

3 day, or picked out by the soldiers.

4 JUDGE MUMBA: Can we have the exhibit into

5 evidence, please.

6 THE REGISTRAR: [Interpretation] This will be

7 Exhibit 187 of the Prosecution. This is a confidential

8 exhibit.

9 MS. KUO:

10 Q. So Witness, if you see the name of one of the

11 girls, could you please give us the number or the

12 initials next to her name.

13 A. Initials DB, number 87, number 75, number 95,

14 number 88.

15 Q. Is there also a name that does not have a

16 number next to it?

17 A. Yes.

18 Q. Was that girl also taken out?

19 A. Yes.

20 Q. Does that girl have the same name as your

21 mother?

22 A. Yes.

23 Q. But it was not your mother that was taken

24 out; it was another person with the same name, a girl;

25 right?

1 A. Yes.

2 Q. Where were you taken after the soldiers

3 picked you out?

4 A. Into another room, also a classroom, the one

5 next door, I think.

6 Q. Were all of you taken there together?

7 A. Yes.

8 Q. Were you told to go somewhere or do something

9 in that room?

10 A. There were a few mattresses there too, and

11 they said that every one of us should stand by one of

12 these mattresses or sit on it. That's what one of them

13 did. And the other one said that they had free choice,

14 that they could choose the one they wanted.

15 Q. When you say "they," who are you referring

16 to?

17 A. The other soldiers, the Serbs.

18 Q. Did you stand or go toward a mattress?

19 A. I went and sat down.

20 Q. Did a soldier come to you?

21 A. Yes.

22 Q. How was he dressed?

23 A. In a uniform, an army uniform.

24 Q. Could you see if he had a weapon?

25 A. They all had weapons.

1 Q. What did he do?

2 A. At the first moment he sat next to me, and

3 then he got up and he said that we should get out of

4 there.

5 Q. What did you do?

6 A. What he said. I got up and followed him.

7 Q. Where did he take you?

8 A. To yet another one of the classrooms, to the

9 next classroom.

10 Q. Was there anyone in that room?

11 A. No.

12 Q. What did he do after he took you there?

13 A. He ordered me to lie down and to take off my

14 trousers.

15 Q. And then what did he do?

16 A. Then he raped me.

17 Q. I apologise again for asking you specifics,

18 but the Court needs to know. Can you describe what he

19 did?

20 A. This time he raped me vaginally.

21 Q. Do you mean that he put his penis into your

22 vagina?

23 A. Yes.

24 Q. Did he say anything to you?

25 A. I don't remember exactly what he said to me.

1 They were all speaking and saying the same things.

2 Always they were saying, "You Muslim women, you Bule,

3 we'll show you," and that's what they said, all of

4 them, the same things.

5 Q. Do you know how long this lasted, this

6 particular incident?

7 A. Not very long. Perhaps an hour and a half.

8 Q. And what happened afterwards? What did you

9 do?

10 A. He took me back to the first classroom where

11 the other children and women were.

12 Q. Did you tell anyone at that time what had

13 just happened to you?

14 A. I never described what happened to me in

15 detail to anyone. If I wanted to say what happened, I

16 said the worst had happened, referring to rape, and

17 from then onwards, throughout my stay in this camp, I

18 never talked to anyone about anything from that event

19 onwards; I kept silent.

20 Q. How did you feel?

21 A. Awful. There are no words in this world that

22 could describe my feelings. It is the worst thing that

23 was happening to me.

24 Q. Did you see the other girls who were picked

25 out with you?

1 A. Afterwards?

2 Q. Yes. Yes, that's what I mean.

3 A. Yes, I saw them afterwards. They were

4 returned to this same classroom.

5 Q. Did they tell you what happened to them?

6 A. I don't remember.

7 Q. Were you ever taken out again while you were

8 at the high school?

9 A. No.

10 Q. Did you see other girls being taken out at

11 the high school?

12 A. Yes, I did.

13 Q. How often would you say other girls were

14 taken out from the high school?

15 A. It's hard to tell. They would take them out

16 when they wanted to, when they felt this urge to take

17 this out on them. But at any rate, every night some

18 girl would end up someplace with the same soldier or

19 with a different soldier.

20 Q. And could you see when soldiers came to pick

21 out the girls?

22 A. Yes. I'd see it sometimes. Sometimes I was

23 not there; I was in the toilet or somewhere.

24 Q. Can you describe how they picked out the

25 girls?

1 A. They would always do this by pointing their

2 finger: You, you, or you. That's how they did it.

3 Q. Did you see the girls when they were

4 returned?

5 A. Yes, I did.

6 Q. Could you describe how they looked?

7 A. They looked dreadful. They were all crying.

8 They would all be crying when they came back. Some of

9 them would be bleeding from the nose. They would be

10 screaming, tearing out their hair. Different things.

11 Q. While you were at the high school were you

12 ever hit or provoked?

13 A. Yes. On one occasion in the hallway of the

14 secondary school centre, in front of the classroom in

15 which we were kept, a soldier hit me with his rifle in

16 the back.

17 Q. Do you know why he did that? Did he say

18 anything?

19 A. I think he asked where my father was, and I

20 didn't know myself. They wanted to get answers from me

21 which I wasn't able to give. They would say, "Where is

22 our army," or things like that. There was no "our

23 army," so it was impossible for me to answer questions

24 of that kind.

25 Q. How long did you have to stay at the high

1 school?

2 A. I don't know exactly to the day, but I think

3 it was 11 days; that is, the group that I came with,

4 the group and myself.

5 Q. While you were at the high school, did you

6 ever feel free just to leave?

7 A. I didn't dare move off the mattress under the

8 blanket, let alone anything else, and I lost all

9 feelings of freedom on the 3rd of July.

10 Q. When did you finally leave the high school,

11 were you taken out?

12 A. After 11 days.

13 Q. Where were you taken?

14 A. This time they took us to the Partizan Sports

15 Hall.

16 Q. And did everybody from the secondary school

17 get taken to Partizan?

18 A. Yes, they did, all of the people were taken

19 there.

20 Q. Could you describe what Partizan looked like

21 when you arrived?

22 A. It was a large hall, nothing much inside,

23 fairly simple. There was a sort of stage at one end,

24 a -- raised above floor level about a meter. On one

25 side there were two rooms. One of them had previously

1 been used as an office and the other was for the

2 storage of sports equipment that wasn't being used. At

3 the bottom of the hall, next to the stage, there were

4 stairs leading downwards where the bathrooms were and

5 the water. But of course there wasn't any hot water;

6 there were just two or three toilets and one or two

7 wash basins.

8 Q. Was there anything to sleep on?

9 A. Yes. They were gym mats, rubber ones, foam

10 ones, used for the sports that were practised in the

11 sports hall. And that was the only thing that we were

12 able to lie down on.

13 Q. How many people were with you at Partizan?

14 A. We came first. After us a smaller group was

15 brought in. And I would say there were about 60 people

16 there, perhaps a little more.

17 Q. Were all these people women and children?

18 A. Yes, except two elderly men. They were about

19 70 years old.

20 Q. Were all these people Muslims?

21 A. All of them.

22 Q. While you were at Partizan, did you feel free

23 to just leave?

24 A. No.

25 Q. Why not?

1 A. I've already said: I was raped, I was

2 mistreated, I was beaten, and I wouldn't dare even

3 cross the threshold of the Partizan, because these

4 soldiers moved around town quite freely. Any one of

5 them could kill me at any time, or do anything else to

6 me, for that matter.

7 Q. Did soldiers go to Partizan also and pick out

8 girls?

9 A. Yes, of course they did.

10 Q. How often did that happen?

11 A. Very frequently. Sometimes perhaps somebody

12 would not come for one day and then they would come the

13 next day two or three times, but, generally speaking,

14 it happened very often.

15 Q. Did the soldiers come during the day or at

16 night, or both?

17 A. Whenever they wanted to, they came.

18 Q. So was that both during the day and night?

19 A. Yes.

20 Q. Were these the same soldiers that came to the

21 secondary school?

22 A. They came and many, many others came too.

23 Q. Were there some soldiers who came to Partizan

24 many times, repeatedly?

25 A. Yes. Yes.

1 Q. What would you do when the soldiers came?

2 A. I would usually try and hide, perhaps in the

3 lavatory or under a blanket, but I wasn't always

4 successful.

5 MS. KUO: With the assistance of the usher, I

6 would like to show this witness Prosecution Exhibit 11,

7 photographs 7298 and 7299, and then 7327 and 7328.

8 Q. First looking at photograph 7298 and 7299, do

9 you recognise what's in those photographs?

10 A. Yes.

11 Q. Can you describe what it is?

12 A. Yes. That's the Partizan Sports Hall.

13 MS. KUO: Can the witness now be shown

14 photographs 7327 and 7328.

15 Q. Do you recognise that?

16 A. Yes.

17 Q. Can you describe what that is?

18 A. That's the WC in the Partizan Sports Hall,

19 the only one we had at our disposal.

20 Q. Is that where you would try to hide when the

21 soldiers came?

22 A. Sometimes, yes.

23 Q. Thank you. When you would hide, would you be

24 found anyway?

25 A. Yes. Yes, that happened too.

1 Q. Did your mother also hide?

2 A. Probably she did.

3 Q. Did your mother know where you hid?

4 A. Yes, she knew.

5 Q. Was there one time when your mother was

6 forced to come find you?

7 A. Yes. That happened when I was in the WC that

8 was on the photograph you showed me a moment ago.

9 Q. Do you know what happened, why she came to

10 find you?

11 A. Two soldiers took away individual number 87

12 and went off with her. I think they also took away all

13 the other girls from the Partizan Sports -- that

14 they had already been taken away, except for me, and

15 then I tried to hide and went down to the lavatory.

16 However, this person number 87 returned with them, and

17 with another soldier, to look for me.

18 Q. And your understanding is that they were

19 looking for you and that's why your mother came to get

20 you; is that right?

21 A. Yes.

22 Q. Was it your understanding that the soldier

23 was looking for you?

24 A. One of them was, yes.

25 Q. Were you taken out by soldiers while you were

1 at Partizan?

2 A. Yes.

3 Q. Are you able to say how often you were taken

4 out or how many times?

5 A. I don't know exactly how many, but it was

6 often.

7 Q. Was it every night, every day?

8 A. Not every night and every day. Sometimes not

9 for two days. But then I would be taken up every day

10 for three days, that kind of thing.

11 Q. When you were taken out, how long were you

12 kept away?

13 A. That depended too, depended on the

14 situation. Sometimes for a short period, just to let

15 them do what they wanted to with me, and at other times

16 in flats of unknown individuals, it would last for

17 three days. I would be shut up for three days.

18 Q. Whenever you were taken out, were you also

19 raped?

20 A. Yes, every time.

21 Q. And when you say "rape ", do you mean what

22 happened to you at the high school, the same thing?

23 A. Yes. Every other time it was the same thing,

24 every time after that it was always the same thing.

25 Q. Do you remember the first time that you were

1 taken out from Partizan?

2 A. Yes.

3 Q. Do you remember when it was?

4 A. Perhaps a day or two later, after our arrival

5 in the Partizan.

6 Q. Do you remember who took you out?

7 A. Yes.

8 Q. Who was it?

9 A. It was what I talked about a moment ago, when

10 I was in the WC. Two soldiers whom I did not know

11 came, and among them was Zoran Vukovic again.

12 Q. When you say again, do you mean the same

13 person who raped you at Buk Bijela?

14 A. Yes.

15 Q. Do you remember if he was armed at that time?

16 A. Yes, he was.

17 Q. Where did he take you?

18 A. He took me to an apartment. I assume that it

19 had been abandoned, because I didn't see anybody

20 there. When he brought me to that apartment, he took

21 me into one of the rooms, which was to the left-hand

22 side of the hallway. There was a big bed there for

23 sleeping in. I don't remember exactly whether there

24 was a cupboard or what there was there, but it was a

25 bedroom. And then it happened once again; I was raped

1 again.

2 Q. Did Zoran Vukovic say anything to you?

3 A. Well, yes. They would always say things.

4 But once he had done what he was about -- I mean, once

5 he had raped me, when he finished raping me, he sat

6 down and lit a cigarette, and he said that he could

7 perhaps do more, much more, but that I was about the

8 same age as his daughter, and so he wouldn't do

9 anything more for the moment.

10 Q. Can you -- would you be able to recognise

11 Zoran Vukovic today?

12 A. Yes, I could.

13 Q. I'm going to ask you to look around the

14 courtroom, and please take your time. Let us know if

15 you recognise somebody here who was the Zoran Vukovic

16 you have described.

17 A. If I look from the door going down, the first

18 person next to the guard with dark hair, is Zoran

19 Vukovic.

20 Q. To help clarify the record, could you just

21 describe something he's wearing?

22 A. He is wearing a light blue shirt, a dark blue

23 suit.

24 MS. KUO: Your Honour, may the record reflect

25 that the witness has pointed out the accused, Zoran

1 Vukovic.

2 JUDGE MUMBA: Yes.

3 MS. KUO:

4 Q. Did you see Zoran Vukovic again at Partizan?

5 A. After this event I can't remember exactly

6 whether I did or not.

7 Q. Were you taken out of Partizan again?

8 A. Yes.

9 Q. Let's go through the specific incidents, the

10 ones that you remember.

11 A. Do you want me to start telling how it

12 happened myself?

13 Q. Yes. If you remember the order in which it

14 happened, start from -- do it that way, but if you

15 don't remember the order, then just describe the

16 incidents.

17 A. The next time was when I was taken to a

18 house. The house was opposite the bus stop in Foca,

19 the bus station in Foca. There was only one bus

20 station and everybody knew it. A group of soldiers

21 took me off, along with three other girls from the

22 Partizan Sports Hall. They took us into a house, which

23 was -- how shall I describe it? It was all ransacked,

24 things all over the place. You could see that nobody

25 lived there. And the first thing they ordered us to do

1 was to tidy the house and they said they'd go off to

2 see to some business and that they'd come back. And as

3 far as some cleaning things were concerned, we didn't

4 get anything, but we just had to make do and clear the

5 place up. They went off, and when they came back there

6 were more of them.

7 They were people that I hadn't known or seen

8 before that, and there were some of them who weren't

9 from Foca at all. And they raped us there. Each one

10 of them raped the girl he wanted to rape, and as many

11 times as he wanted to rape her. Everybody would pick

12 and choose. They would say, "Come on, you." or "Let's

13 go upstairs," because the house had rooms on the

14 ground floor and on the first floor. So we would be

15 down there until they took us off to rape us, to

16 another room. And whenever they wanted to, they picked

17 the girl they wanted to and raped her.

18 I think that I was raped there three times,

19 perhaps more. I can't remember exactly how many times,

20 but it was dreadful. They would take their turns, one

21 after the other. They would have breaks of 15 minutes

22 or maybe one hour, as long as they wanted, but there

23 were terrible things going on there. There were old

24 people there. They were dirty people and drunken

25 people, and they would take my friend off. He would

1 rape her and then rape me. But they did their best to

2 rape all of us, that each one of them raped each one of

3 us in turn.

4 Q. How many different soldiers raped you that

5 day?

6 A. Well, I said a moment ago that I counted up

7 to three. All three of them were different. I was

8 raped three times by three different men, not by one

9 person. But they didn't pay any attention of how much

10 my body could take. They did what they wanted until

11 absolute exhaustion. It was absolutely terrible.

12 Q. How many soldiers would you say were there?

13 A. Well, today I can't remember the number

14 exactly, but I do know that there were a lot of them.

15 Perhaps a little less than ten, but there were more of

16 them than there were us. And they took turns. So two

17 of them would go off for a period of time and then some

18 others would come back or they would come back. There

19 was nothing definite. That was how it went.

20 Q. And you mentioned that some soldiers were

21 from Foca but others were not. Do you know where the

22 soldiers who were not from Foca were from?

23 A. One of the ones who raped me in the room, in

24 that same house, he told me that he was from Bileca and

25 that his name was Nedjo.

1 Q. Did any of the soldiers mention which brigade

2 they were from?

3 A. In that house I can't remember. I don't know

4 exactly. I can't say.

5 Q. The other girls who were taken with you,

6 could you tell us their numbers, please?

7 A. 87, DB, and I think the third was number 75,

8 but ...

9 Q. But you're not sure about that one?

10 A. I'm not quite sure about the third. I'm

11 certain one hundred per cent about the first two,

12 though.

13 Q. Were you returned to Partizan?

14 A. I didn't understand your question.

15 Q. Sorry. After what you described happened in

16 that house, were you taken back to Partizan?

17 A. Yes. Yes, I was.

18 Q. Do you remember when that was?

19 A. I think it was in the morning, but I can't

20 say for sure.

21 Q. Could you tell us about the next time that

22 you were taken out from Partizan?

23 A. Yes. I apologise for not explaining that

24 properly in my statement in the order that it happened,

25 but it was in the house that I didn't mention in my

1 statement. I don't know why I didn't mention it in my

2 statement. Probably I was too nervous and overwrought

3 and upset.

4 Q. Why don't you tell us about it now?

5 A. Yes. Another group came. The group came

6 again; the group of soldiers came again, and they took

7 away two other people together with me, at least. One

8 of them was number 75, but I'm not quite sure who the

9 other person was, which one she was. This house was

10 also an abandoned Muslim house, a terrible mess inside

11 everywhere. There was clothing all over the place, the

12 furniture had been -- was a shambles. A soldier took

13 me up to the first floor, into a room there on the

14 upper storey, and I remember that there was a bed there

15 and some clothes and other things all over it. He

16 raped me there. He was the only one who raped me

17 there, but he repeated it many times.

18 Q. Do you know who that soldier was?

19 A. No.

20 Q. Where was this house?

21 A. The house, if you could -- approximately -- I

22 could explain; I don't know how to do it, though.

23 Q. Maybe you could just tell us what part of

24 town it was in.

25 A. Approximately it was between Prijeka Carsija

1 and Gornje Polje. I don't know exactly which

2 neighbourhood of the two I mentioned it actually

3 belonged to, but it was there for sure.

4 Q. Could you describe the next time that you

5 were taken from Partizan?

6 A. Yes. That time I was taken to Brod.

7 Q. I'm sorry. Where were you taken?

8 A. I was taken to a neighbourhood that was

9 called Brod.

10 Q. And what happened there?

11 A. I was taken by a man. I knew him before the

12 war. I saw him often. He was called Gica, or rather

13 his nickname was Gica. He took me to an apartment,

14 that I think was his own, at Brod.

15 When I arrived there, nothing happened

16 immediately, but I was so famished; I was so

17 exhausted. I just lay in a corner. I don't know. I

18 did not feel right; I didn't feel normal.

19 I saw quite a few girls who were brought from

20 Miljevina, Kalinovik, and the surrounding area. Among

21 them I only recognised a schoolmate of mine. That is

22 person number 175 here. I did not talk to her about

23 the war and about what was happening to her or to me.

24 We chatted about unimportant things.

25 There were quite a few soldiers who came and

1 went. They were coming and going so often. I was

2 raped there too.

3 Q. How long were you kept there?

4 A. Three days.

5 Q. On which of those days were you raped?

6 A. I think on the second day.

7 Q. Who raped you?

8 A. I was raped by an acquaintance of mine,

9 (redacted)

10 (redacted). He knew me very well. We took the

11 same bus every day. He went to work and I went to

12 school. And he was certainly 20 years older than I.

13 He was a married man.

14 Q. Did he say anything to you when he raped you?

15 A. It was terrible. He laughed. I had the

16 feeling that he was doing this precisely because he

17 knew me, to inflict even more evil on me. I don't know

18 exactly.

19 Q. Can you describe another time when you were

20 taken out of Partizan and raped?

21 A. Yes. Yes. Another time a Serb took me to

22 his mother's apartment -- his apartment too -- also in

23 Brod, but it's not the same apartment, it's not the

24 same man, and it's not even the same neighbourhood.

25 Perhaps it's a kilometre away.

1 He took me to his mother's apartment, and he

2 asked me to introduce myself as a Serb, to say that my

3 name was (redacted), to say that I was from Ustikolina,

4 that -- I don't know -- that my mother and father were

5 also Serbs. And that's what I had to do.

6 I kept quiet all the time. He talked for

7 me. He talked about some people from Ustikolina, about

8 these parents, who he said had to be mine during this

9 night that I was spending with him. We sat there for

10 about two hours like that. They even brought me some

11 brandy to drink. I never drank alcohol, especially at

12 that time, when I wasn't even 17 years old. They knew

13 that very well, that Muslim women did not drink

14 alcohol, for the most part. And he changed my name.

15 He wanted me to be his Serb girl that night.

16 We sat for about two hours that way. He did

17 the talking most of the time; I kept quiet. There was

18 no light at that apartment at the time. A candle had

19 been lit. He took me to his room. He raped me four

20 hours, for sure, in succession. Perhaps he made 15- or

21 20-minute breaks, whatever suited him. At any rate, he

22 was so terrible. He was so terrible. He did such

23 things that I cannot even explain them. I had no place

24 to take a bath. I couldn't even wash my hands or

25 something like that.

1 Q. Do you know who that person was who did this

2 to you?

3 A. In 1992, I knew the name, because his mother

4 spoke freely in front of me, because she thought I was

5 Serb. I can't remember today.

6 Q. Was he also a soldier?

7 A. Yes. Yes, he was a soldier.

8 Q. And just to clarify, all the other soldiers

9 who took you out, were they Serbs as well?

10 A. Invariably. Serbs, and only Serbs.

11 Q. Now, this particular incident when you spoke

12 with investigators with the Tribunal, you did not

13 describe that, did you?

14 A. That is correct.

15 Q. Do you know why not, specifically?

16 A. I was ashamed to admit to people that that

17 night I had to use a different name, that I had to be

18 someone else.

19 Q. Did you do that freely, or were you forced

20 to?

21 A. I was forced to.

22 Q. Could you describe for us now another time

23 when you were taken out of Partizan?

24 A. Yes. This happened again on the 2nd of

25 August, 1992. Again, three girls and I were taken to a

1 house in Aladza, in the neighbourhood of Aladza.

2 Nearby was a mosque by the same name, Aladza. I think

3 the house used to belong to a Muslim man, a tailor. At

4 that time there was no one in it but Serb soldiers and

5 us who were brought in.

6 That's the way it was. First we were taken

7 to a room upstairs in that house. That's where they

8 sat and that's where we sat. When I say "they," I'm

9 referring to Serb soldiers. Among them were those who

10 took us away and those who were waiting for us there.

11 At the first moment I sat together with the

12 girls that were taken with me. We tried to talk about

13 something. However -- I do not remember exactly what

14 was the reason for this. Perhaps I laughed a bit or

15 something. For some reason, one of the Serb soldiers

16 didn't like this. He said to me, "Come on, you. Since

17 you have such a nice laugh, come with me." He took me

18 to another room, a room that was also there on that

19 same floor. He raped me on a sofa, underneath the

20 window.

21 Q. Who was that person?

22 A. That was Kunarac, nicknamed Zaga.

23 Q. Did you know him before the war?

24 A. No.

25 Q. Are you able to recognise him today?

1 A. Yes.

2 Q. I'm going to ask you to take your time and

3 look around the courtroom, and please let us know if

4 you see the person that you've referred to as nicknamed

5 Zaga Kunarac.

6 A. I see him.

7 Q. Could you please point him out to us, please,

8 perhaps by what kind of clothing he's wearing.

9 A. He has a pink shirt, a multicoloured tie, a

10 dark suit. If I said that Zoran Vukovic is the first

11 person up there, then he is the last person on the

12 other side.

13 MS. KUO: May the record reflect that the

14 witness has identified the accused, Dragoljub Kunarac.

15 JUDGE MUMBA: Yes.

16 MS. KUO:

17 Q. Did he say anything to you while he raped

18 you?

19 A. He did say something for sure, but today,

20 eight years later, and after so many rapes, I cannot

21 remember. I only know that he was very forceful, that

22 he wanted to hurt me as much as possible. But he could

23 never hurt me as much as my soul always hurt me.

24 Q. What happened after Kunarac raped you?

25 A. He took me back to the first room where we

1 all sat, as if nothing had happened.

2 Q. Was he wearing a uniform that day?

3 A. On that day, they were all in uniform.

4 Q. Do you remember what time of day or night

5 that was?

6 A. It was in the evening, perhaps an hour or two

7 before the Aladza dzamija was destroyed for the last

8 time in Foca.

9 Q. And where were you when the Aladza dzamija

10 was blown up?

11 A. In that same house where I was brought on the

12 2nd of August. I was still there.

13 Q. How do you know that the mosque was blown up

14 at that moment?

15 A. When I came, I saw that the mosque still

16 existed; however, it had been damaged. At the moment

17 when it was blown up, the glass on the windows started

18 to break. The Serb soldiers started to curse, to

19 yell. I think that I was screaming too. It was

20 awful. It was very close to that house.

21 Q. Did the Serb soldiers react afterwards

22 differently?

23 A. I think that they said that no one had told

24 them that that night the mosque would be destroyed, so

25 they were there with us in the house. They told us how

1 they attacked or took away some car or something like

2 that -- I don't know exactly -- from some Muslims, that

3 they were at the front line.

4 Q. Did they say they had just been at the front

5 line, or could you maybe clarify that a little bit?

6 A. Yes. They said that they had just been at

7 the front line, that they had just returned from the

8 front line, that they had vanquished the Muslims.

9 That's what they were saying, things in that sense. I

10 did not dare ask anything; I just heard what they were

11 saying. And they boasted how they had gathered a lot

12 of gold and other valuables from Muslims.

13 Q. Do you remember if they said where they had

14 just been, I mean what they refer to by "front line"?

15 A. They thought they were probably in some kind

16 of combat. They called that combat, but that is not

17 combat against unarmed people. They would just come,

18 kill whom they killed, raped whom they raped, torched

19 houses, took away valuables. With my very own eyes, I

20 saw my own burnt house.

21 Q. Did these soldiers say where they came from,

22 where they were from originally?

23 A. There were several of them. Some of them

24 came from Niksic, from Montenegro. They said so

25 themselves.

1 Q. Did they say anything about who was in

2 charge?

3 A. Today, I can no longer remember that.

4 Q. Were you raped any other time at that house,

5 I mean that same day, that same night?

6 A. Yes. The first time I was raped in that

7 house, that's what I just described. That happened in

8 an upstairs room. However, the second time I was

9 raped, now I cannot remember whether this second person

10 who raped me first took me to this room upstairs. I

11 think he did. Then since there were a lot of people

12 and then these other people were supposed to rape these

13 other girls, he took me to this workshop that I already

14 described in my statement. It looked like a small

15 room. It was attached to the house, to the ground

16 floor of the house, that is. Things were scattered all

17 around inside as well. I went down there with him.

18 I think that he belonged to some of these

19 other brigades, these brigades from Montenegro or

20 something like that. I could reach that conclusion on

21 the basis of his accent, the way he spoke. It was

22 different from Bosnian. He was old. He was awful. He

23 had a knife. He said to me, "You will see, you

24 Muslim. I am going to draw a cross on your back. I'm

25 going to baptise all of you. You're now going to be

1 Serbs." And many things I could not possibly

2 describe today.

3 He threatened me so much with the knife that I

4 thought I would lose my life any minute. However, he

5 decided to rape me after all, in a beast-like manner.

6 He raped me so hard that later I saw that I was

7 bleeding, and everything hurt me: my stomach, my back,

8 my legs; everything ached. What hurt me most of all

9 was that he was certainly some 30 years older than I

10 was. He was probably my father's age.

11 Q. You mentioned that you were brought to this

12 house with some other girls. Could you tell us their

13 numbers, please?

14 A. DB, 87, person number 75, but whether there

15 were other girls too, that I cannot remember exactly

16 today.

17 Q. Were you taken back to Partizan that night?

18 A. Yes, after midnight, I think.

19 Q. Were you taken back alone or with other

20 girls?

21 A. Alone.

22 Q. Did you ever see those other girls again

23 while you were in Foca, the three whom you mentioned

24 just now?

25 A. Never again.

1 MS. KUO: Your Honour, I have some more

2 questions, but I see that we have come on our 1 o’clock

3 break.

4 JUDGE MUMBA: Yes. We will have the lunch

5 break, and will continue this afternoon at 1430 hours.

6 --- Luncheon recess taken at 12.59 p.m.

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1 --- On resuming at 2.28 p.m.

2 JUDGE MUMBA: Yes. We'll continue with

3 examination-in-chief by the Prosecution.

4 MS. KUO: Thank you, Your Honour.

5 Q. Witness, after the night that you were taken

6 to the house in Aladza and returned to Partizan, how

7 much longer did you remain at Partizan?

8 A. Ten days.

9 Q. During those ten days did soldiers continue

10 to come and take out girls?

11 A. Yes.

12 Q. Did they come more or less often than before?

13 A. The same, I think.

14 Q. Were you taken out again after that?

15 A. No.

16 Q. During the entire time that you were detained

17 at Partizan, did you see the person identified on the

18 piece of paper before you as 48 being taken out?

19 A. Yes.

20 Q. Do you recall specifically by whom she was

21 taken out?

22 A. Yes. It was the chief of SUP at the time in

23 Foca, Dragan Gagovic.

24 Q. During the time you were at Partizan, did you

25 see the person identified as 95 being taken out?

1 A. Yes.

2 Q. Do you recall specifically by whom and when

3 she was taken out?

4 A. It's a little difficult to explain.

5 Everybody was taken out very frequently. But this

6 particular person was taken out one or two nights

7 before we left Partizan. And as she herself told me,

8 this group of Serb soldiers who had come in from Serbia

9 took her to Buk Bijela. I think they were accommodated

10 there. That's where they were to spend the night. So

11 they took her up there.

12 Q. Did she tell you what happened to her there?

13 A. Yes, she did.

14 Q. Can you tell us very briefly what she told

15 you happened to her there?

16 A. She told me that when she was brought there

17 -- I don't know how to explain this -- that she was

18 raped so many times. She told me 100. She said a

19 hundred times, but she lost count. She said that

20 figure like ordinary people tend to give a figure. I

21 don't know -- I can't explain how, but they took

22 turns. She was raped all the time one by one. They

23 took turns, without stopping. And she said that

24 sometimes she was raped by three soldiers at one and

25 the same time, at the same time.

1 Q. When were you finally able to leave Partizan?

2 A. We left on the 13th of August, 1992.

3 Q. How were you able to leave?

4 A. Well, the day before we left, people from the

5 SUP came and asked for a list of names. They told us

6 that we would have to leave, that they would organise

7 buses to take us away, and they printed some permits

8 for us, exit permits, with our names on them and our

9 dates of birth.

10 Q. Were you given a reason for your leaving?

11 A. I heard that the reason was that it was

12 thought that the International Red Cross Committee

13 might be coming to Foca, and that is why I assumed we

14 had to disappear from there.

15 Q. Did you, in fact, leave Partizan on the buses

16 that were organised for you by the SUP?

17 A. Yes. We went by buses. I think they were

18 organised by the SUP.

19 Q. Now, in addition to the incidents that you've

20 described for us in court today when you were raped,

21 were there other incidents during this time period when

22 you were raped that you are not able to recall the

23 details?

24 A. I didn't quite get your question. What you

25 mean?

1 Q. You've described a number of instances where

2 you were raped, you were taken to specific places and

3 raped by specific people. Were there other -- do you

4 recall now that there were other times that you were

5 taken out and raped, but you cannot provide details?

6 A. I think there were other times, yes. I

7 wasn't taken off to other places, but at the places

8 that I was taken to, I was raped a number of times.

9 And when I gave my statement, on the day I gave my

10 statement, it was actually the first time that I had

11 ever told anybody that, and it was very difficult for

12 me, and I'm sure I didn't say everything that had

13 happened to me.

14 Q. The person that you identified in court

15 earlier today as Kunarac, nicknamed Zaga, did you see

16 him any other time while you were kept at Partizan?

17 A. I think I did, but I don't know where

18 exactly.

19 Q. Do you recall what he was doing those times?

20 A. Well, mostly he would come to take out women

21 and girls. That's the only reason they visited us.

22 Q. At Partizan, you mean?

23 A. Yes.

24 Q. Do you recall Kunarac, nicknamed Zaga, being

25 with another soldier, whose name you know, or nickname?

1 A. I don't know exactly.

2 Q. Do you recall being shown a photo board, a

3 group of photographs, on the 31st of March, 1998, at a

4 police station?

5 A. Yes.

6 Q. Do you recall picking out a photograph of a

7 person?

8 A. Yes.

9 Q. Was the man whose photograph you picked out

10 the same as the man you identified today in court as

11 Kunarac, known as Zaga?

12 A. I can't remember exactly. I don't remember

13 the photograph very well.

14 Q. Do you remember telling the investigator from

15 the Tribunal at that time that you thought that this

16 was the house in Aladza, that it was at the house in

17 Aladza at the time when you saw the man in the

18 photograph you picked out, that you were not sure

19 whether you saw this man at Partizan, and that you were

20 not sure if this man himself sexually abused you? Do

21 you remember saying that?

22 A. Yes, I do remember.

23 Q. And am I correct to say that at that time you

24 were uncertain about these particular details when you

25 picked out the photograph?

1 A. Yes. That's correct. Yes.

2 Q. But are you certain today that the person you

3 pointed out in the courtroom as Kunarac, known as Zaga,

4 was the same man who raped you in the house in Aladza?

5 A. Yes, I'm sure today.

6 Q. Can you explain why you're sure today, but

7 were unsure then?

8 A. Yes. I think it's very understandable,

9 because I was raped by so many people, so many

10 different faces, that all the faces have become mixed

11 up in my mind. But today, when I saw him here in the

12 courtroom, I recognised him straight away and I'm quite

13 certain, and now I remember that it was him; it was

14 quite certainly him.

15 Q. Do you recall being shown photographs and

16 being asked to identify Zoran Vukovic in September

17 1999?

18 A. Yes. That's right.

19 Q. Did you tell the Tribunal investigators that

20 you knew Zoran Vukovic from before the war?

21 A. Yes. I said so on that occasion.

22 Q. What did you mean by that when you said that?

23 A. It's difficult for me to explain that now,

24 but I thought I knew him from somewhere, because his

25 face, when I saw him for the first time, was very

1 familiar to me. Perhaps over the passage of years,

2 from all the fear and everything that has happened to

3 me, perhaps that's why I said what I said and how I

4 said it then. But I'm certain that I did see him

5 around somewhere before that.

6 Q. And when you were shown those photographs,

7 were you able to identify Zoran Vukovic in some of the

8 photographs but not in others?

9 A. Yes. That's right.

10 Q. Was there a particular reason for that?

11 A. Every time I said something, I didn't want to

12 say anything that I wasn't 100 per cent certain of. I

13 didn't want to lie. Only when I was absolutely

14 certain, when I had full recollection of what had

15 happened to me, then I would say something; otherwise,

16 I wouldn't.

17 Q. Are you absolutely certain that the person

18 you identified in court today as Zoran Vukovic is the

19 same person who raped you at the Buk Bijela and also

20 when you were detained at Partizan?

21 A. Yes, I am.

22 Q. After you left Foca, were you able to see a

23 doctor?

24 A. Yes, I was.

25 Q. When was that?

1 A. I don't know the exact date, of course. It

2 was after I had left Foca I went to see a doctor,

3 because the whole time I was in Foca, I never had my

4 periods. Of course, I was afraid of what might have

5 happened, and when I went, it turned out that I had an

6 inflammation of the ovaries and my uterus, and I didn't

7 get my periods. And the doctor explained to me that

8 that was out of fear. And then later on, two or three

9 months later, my periods came back and became regular

10 again.

11 Q. After you left Foca, and in the years between

12 then and now, did you ever go to see a psychiatrist or

13 a psychologist?

14 A. Once.

15 Q. When was that?

16 A. A few years ago, perhaps two years ago. Not

17 recently.

18 Q. Was there a specific reason that you felt you

19 needed to seek the help of a professional?

20 A. Of course. There were moments when I felt so

21 bad. All my fears came back to me. I felt

22 psychologically unwell. I would get very excited and

23 very upset, and this fear would keep coming back to me.

24 Q. And did that visit to the psychiatrist or

25 psychologist affect your memory in any way whatsoever?

1 A. The doctor I went to see, the psychiatrist or

2 psychologist, I didn't tell him any details. I didn't

3 talk to him about the details that I'm talking about

4 here today. We just had a conversation; that was all.

5 I don't really know.

6 MS. KUO: That's all the questions from the

7 Prosecution, Your Honours.

8 JUDGE MUMBA: Yes. Any cross-examination

9 from counsel?

10 MR. JOVANOVIC: [Interpretation] Yes, Your

11 Honour. I shall begin, and then my colleagues will

12 have some of their own questions after that

13 Cross-examined by Mr. Jovanovic:

14 Q. Good afternoon. Could you tell us whether

15 you remember when you first came into contact with the

16 investigators of the Tribunal?

17 A. It was in August 1995.

18 Q. Can you tell us how many times after that you

19 had contacts with them or individuals working for

20 them?

21 A. Three or four times, I believe.

22 Q. You gave a statement every time?

23 A. I think I did, something every time.

24 Q. And that statement was read out to you every

25 time, and you know what you stated?

1 A. Yes.

2 Q. You said a moment ago that you would say only

3 things that you were 100 per cent sure of?

4 A. Yes. I didn't understand.

5 Q. You said a moment ago that you always say

6 only what you are 100 per cent certain of?

7 A. Yes.

8 Q. If I understand you correctly, all the

9 statements that you have given to date and the

10 testimony here today before this Trial Chamber, they

11 are all 100 per cent correct, are they?

12 A. Well, it doesn't mean that everything need be

13 100 per cent. There might be slight differences. But

14 it doesn't mean that I was lying. It was because I was

15 upset when I talked to the people from the Tribunal.

16 Q. Well, I know that there might be slight

17 discrepancies, and in asking you my questions I'm going

18 to point out some substantial differences. And that is

19 why I asked you the question that I did a moment ago.

20 What you stated in your statements earlier on, and what

21 you said here today, that is all correct, because you

22 tell the truth?

23 A. Yes. I am speaking the truth exclusively.

24 That's right.

25 Q. Thank you. I'm interested in the following:

1 According to the information I have, you have given

2 five statements to date to the investigators of the

3 Tribunal, and one of those statements --

4 MR. JOVANOVIC: [Interpretation] Your Honours,

5 is the memorandum which we received yesterday, which my

6 colleague mentioned -- it was the conversation with the

7 witness on the 27th of March, 2000, that is to say, a

8 few days ago. I beg your pardon. It was the 26th of

9 March and the document was compiled on the 27th of

10 March.

11 Q. Is that correct?

12 A. Yes.

13 Q. Very well. I'm now interested in the

14 following.

15 Before I go on to that, would the usher show

16 the witness the statement in the B/C/S language which

17 she gave on the 11th of -- that is to say, on the 30th

18 and 31st of August, 1995.

19 THE REGISTRAR: [Interpretation] This document

20 will be marked D17, Prosecution Exhibit D17. I'm

21 sorry, Defence Exhibit D17. Defence Exhibit D17.

22 MR. JOVANOVIC: [Interpretation] Could the

23 witness be shown the statement she gave on the 5th of

24 September 1995, please. It is the B/C/S version

25 again.

1 THE REGISTRAR: [Interpretation] This document

2 will be Defence Exhibit D18.

3 MR. JOVANOVIC: [Interpretation]

4 Q. Are those the statements which you gave? Do

5 you recognise them?

6 A. Yes, I do.

7 Q. I apologise. I didn't hear your answer.

8 A. Yes, I do.

9 Q. At the end of those statements there is a

10 certificate which you signed, a witness

11 acknowledgement. Have you got that acknowledgement

12 before you?

13 A. Yes.

14 Q. Was it clear to you, when you read this

15 acknowledgement, that you could be called upon to

16 testify before this Trial Chamber?

17 A. Yes.

18 Q. When did you decide to tell the truth? And

19 may I refer you back, and I will quote, to the

20 beginning of your statement, or around the beginning of

21 your statement, where you say that you decided --

22 JUDGE MUMBA: Which one? Because there are

23 two.

24 MR. JOVANOVIC: [Interpretation] I am thinking

25 about today's testimony, at the beginning of her

1 testimony here today.

2 Q. At the beginning of your testimony today, you

3 said that you had decided to tell the whole truth when

4 you read the solemn declaration before this Trial

5 Chamber and when you were invited to attend these

6 proceedings.

7 A. Among others, yes.

8 Q. Could you explain to me what you mean by

9 "among other things"?

10 A. I said this because what -- the things that I

11 added today linked to the events in Buk Bijela, if that

12 is what you mean. I just couldn't utter those things

13 at that time. They wouldn't pass my lips.

14 Q. Does that mean that, when you made your

15 statements, there was one truth, and there is a

16 different truth today?

17 A. No. Everything I have said is the truth.

18 Q. When?

19 A. What do you mean, when?

20 Q. When you gave your statements and when you

21 talked to us here today, is everything the truth?

22 A. Everything I said today is the truth. I just

23 passed over certain things before, and today I gave an

24 explanation why I did not say them then.

25 Q. How many times have you passed over and kept

1 silent about things?

2 A. I don't understand your question.

3 Q. I asked you: How many times, to the present

4 day, have you kept silent about what you told us here

5 today?

6 A. I said that for the first time here today.

7 Q. I know you said this for the first time

8 today, and that is precisely why I am asking you. But

9 you did not say these things the first time today.

10 A. I said this at the Tribunal on the 27th or

11 28th of March. I don't know exactly.

12 Q. That's it, then?

13 A. Yes.

14 Q. I would like to know the following: In your

15 statement -- in your statements, the plural, that you

16 gave to individuals from the Prosecution, you described

17 some very brutal scenes that you experienced. Is that

18 true? Generally speaking.

19 A. Yes. I described what happened to me, what I

20 experienced. That is true.

21 Q. Very well. Why, then, were you not able to

22 describe this specific event?

23 A. Precisely because it was so specific.

24 Q. And why was that event more specific than all

25 the other events?

1 A. It was my first and most painful experience.

2 All of them are very painful, but that was the first

3 one, the one that made me most frightened.

4 Q. Well, precisely because it was the first time

5 that something like that had ever happened to you?

6 A. If you can't understand me, let me put it

7 this way. I was ashamed to say.

8 Q. And you weren't ashamed to say all the other

9 things?

10 A. No, it wasn't, because I lived through them

11 all. I experienced all this. It happened to me.

12 Q. I don't understand you. You were not ashamed

13 to say all the other things, because you experienced

14 them, and you experienced this too?

15 A. Yes, that is correct.

16 Q. And you were ashamed to say so?

17 A. Yes, at that time I was unable to talk about

18 it.

19 Q. If I understand you correctly, you were not

20 able to talk about it for five years?

21 A. Yes, that's right.

22 Q. Well, let us move on. Today, when you were

23 examined by my learned colleague, you were asked a very

24 specific question related to the manner in which the

25 event ceased to evolve, that first specific event.

1 When did you say that? When did you explain that?

2 Could you clarify this?

3 A. You want me to explain once again?

4 Q. No. I don't mean that you have to tell us

5 what happened to you again. I'm just interested in

6 knowing when -- my colleague asked you whether that

7 soldier, or those soldiers, informed you that the bus

8 had arrived, and that that is why everything stopped.

9 In all the documents that we received, there is no

10 mention of that. Now, I would like to know when you

11 gave this piece of information to the Prosecution.

12 A. The last time we talked.

13 Q. You mean the talk that took place on the 26th

14 or 27th?

15 A. Yes.

16 MR. JOVANOVIC: [Interpretation] I apologise,

17 Your Honours. May I have just a moment to take a look

18 at the document? I don't think it is in the document,

19 but may I just have your indulgence for a minute or two

20 to give myself a chance to check?

21 JUDGE MUMBA: Yes, please.

22 [Trial Chamber confers]

23 MR. JOVANOVIC: [Interpretation] Your Honour,

24 there is a constant problem with the translation,

25 because I got this document only in the English

1 language.

2 JUDGE MUMBA: May we find out from the

3 Prosecution, because we don't seem to have this copy

4 either, even in English, so we are wondering what ...

5 MS. KUO: Your Honour, this was a memo that

6 was written up about the conversation with this

7 witness. It was not a formal statement. It was not

8 shown to her, she did not sign it. It was a summary

9 prepared by the investigator regarding what was said.

10 So it was not -- and it was only prepared on Monday.

11 It was not translated and it was turned over

12 immediately to the Defence.

13 JUDGE MUMBA: So it was for the use of the

14 Prosecution investigators?

15 MS. KUO: That's correct. And we gave it to

16 the Defence so that they would be on notice that this

17 would be what the witness would probably testify.

18 MR. JOVANOVIC: [Interpretation] May I

19 proceed, Your Honour?

20 JUDGE MUMBA: Yes, you can go ahead.

21 MR. JOVANOVIC: [Interpretation]

22 Q. Very well. Please look at page 2 of your

23 statement.

24 JUDGE MUMBA: Whenever you talk of statement,

25 please identify which one. We have D17, we have D18,

1 and they are on different dates. So it will be helpful

2 for the witness and the rest of us in this trial.

3 MR. JOVANOVIC: [Interpretation] Yes, Your

4 Honour. I was just getting ready to say the date.

5 Q. The 30th and the 31st of August 1995. I made

6 a mistake. D17. The page is number 4, actually.

7 Please, when you were brought to the high

8 school --

9 A. Yes.

10 Q. -- you were brought from persons from your

11 village?

12 A. Yes.

13 Q. I assume that you knew most of the persons in

14 your village?

15 A. Most of them, yes.

16 Q. Can you give us a tentative figure as to the

17 number of Muslim inhabitants in your village?

18 A. I really don't know exactly. I can't say.

19 Perhaps over 70, something like that.

20 Q. Very well. Can you tell me, approximately,

21 how many persons there were of your age group and of

22 your sex?

23 A. I don't know.

24 Q. Approximately 30, 50?

25 A. It could not have been 30, it could not have

1 been 50. I really do not know who was my age. I have

2 no idea.

3 Q. Did someone go to school together with you,

4 someone from your village?

5 A. One person, but she was a year younger than

6 me.

7 Q. All right. Was there anyone at the high

8 school when you arrived?

9 A. Anyone?

10 Q. I'm asking about other people.

11 A. Yes. There were persons who had survived and

12 who were captured on the 3rd of July 1992, in the

13 village of Trosanj, and were brought to the high

14 school.

15 Q. Very well. Please take a look at the persons

16 that you mentioned here.

17 A. Yes.

18 Q. You said, in connection with the last person,

19 that it was another person. That's what you said

20 today. It was not your mother, as the Prosecutor had

21 asked; it was somebody else?

22 A. I already explained that.

23 Q. Yes, but tell me, did you know this person

24 from before?

25 A. Yes.

1 Q. What is the name of the mother of that

2 person?

3 A. I have no idea.

4 Q. What is the father's name?

5 A. I don't know that either.

6 JUDGE MUMBA: Find out from the Prosecution

7 whether, even though the person may not be a witness,

8 whether it would be okay to identify her publicly, or

9 him publicly, because I thought that some of the people

10 being mentioned by witnesses, though they are not

11 witnesses in this case, may be -- may require

12 protection, because their identification will lead to

13 the identification of the witnesses in this trial.

14 MS. KUO: That's correct, Your Honour, and so

15 we are asking for all the names of victims to be

16 protected.

17 MR. JOVANOVIC: [Interpretation] I have

18 understood this, Your Honour. I understand the concern

19 of the Prosecution. I'm going to rephrase my

20 question.

21 Q. Could you please take a piece of paper and

22 write the names of the parents of this person?

23 A. I cannot. This person is not from my

24 village. She was only married in my village.

25 Q. I'm sorry. I did not hear the last thing you

1 said.

2 A. This person is not from my village. She was

3 not born in the village; she was only married there.

4 Q. Can you write her husband's name on a piece

5 of paper, please?

6 A. Why is this necessary?

7 Q. Because I'm interested in it.

8 JUDGE MUMBA: Can the usher please give a

9 piece of paper to the witness.

10 MR. JOVANOVIC: [Interpretation]

11 Q. At the same time, I would ask you whether you

12 could remember some other details. If she had

13 children, could you give the names of the children.

14 Since your village is small --

15 JUDGE MUMBA: Yes, Ms. Kuo?

16 MS. KUO: Your Honour, we have the same

17 concern as the witness, what is the relevance of all these

18 details of a person, who's not really central to this

19 testimony, what relevance could there be to the names

20 of relatives?

21 JUDGE MUMBA: Counsel, the objection is that

22 the mention of the relatives of this person is -- they

23 are not relevant, and the Trial Chamber is of the same

24 view. Can you explain?

25 MR. JOVANOVIC: [Interpretation] The relevance

1 is in the following, Your Honour: I believe, and I am

2 convinced, having read this, that there are major

3 differences between the different statements. The

4 person whose name is mentioned here, actually has the

5 same name and surname as the witness's mother. Today

6 we found out that this is not her mother. Today we

7 found out that this was a different person all

8 together. I am asking about the identification of this

9 other person in order to see what the credibility of

10 this witness is. Bearing in mind, this statement that

11 we heard here yesterday from the mother of the witness

12 we have here today in relation to the persons she was

13 taken out with. Was she taken out on her own? Was she

14 taken out with someone else?

15 So I'm putting a question related to all the

16 circumstances involved. This is one of the ways in

17 which I'm trying to ascertain how credible this witness

18 is.

19 [Trial Chamber deliberates].

20 JUDGE HUNT: Can you tell me just what it is

21 you are seeking to do with the name of the mother of

22 other people mentioned? Is this going to lead to some

23 inquiry of them, or is it just a test to see whether

24 she can name the mother of these other persons named?

25 MR. JOVANOVIC: [Interpretation] Your Honour,

1 thank you for having put this question to me. It

2 involves the following: There is a list of persons who

3 left Foca and who received permits to leave. These

4 persons are ethnic Muslims. It is very simple. We can

5 compare what we hear from this witness today to the

6 names of persons on that list, and in this way we can

7 test the credibility of this witness.

8 I have no intention to investigate some new

9 circumstances or new facts; I just want to see whether

10 the witness is telling the truth, if you understand

11 what I'm saying.

12 JUDGE HUNT: You say that there is some list

13 of everybody who left Foca, is there?

14 MR. JOVANOVIC: [Interpretation] Your Honour,

15 all the persons from the high school and from the

16 Partizan Sports Hall that left Foca, to the best of my

17 knowledge, had permits in order to be able to leave.

18 We saw some of these permits.

19 JUDGE HUNT: You told us a moment ago, as I

20 read the transcript and as I heard you, you said there

21 is a list of persons who left Foca and who received

22 permits to leave, and you want to compare with that

23 list the list of -- that you're going to get from this

24 witness of the mothers of everybody whom she's named.

25 Now, is there such a list?

1 MR. JOVANOVIC: [Interpretation] Your Honour,

2 perhaps I misspoke. Most probably I did. I'm only

3 interested in the persons who were in the high school

4 and in the Partizan Sports Hall, nothing else. I just

5 want to see who these persons were. And I think that

6 we have an identity problem here. However, if this is

7 a problem, I shall give up on this question all

8 together.

9 JUDGE HUNT: Well, you've still got a

10 problem, so far as I'm concerned, because unless there

11 is some list which exists that you can make a

12 comparison with, this seems to be a completely

13 pointless exercise and it is an unnecessary one as

14 well.

15 MR. JOVANOVIC: [Interpretation] Yes, Your

16 Honour.

17 Q. Please, above that name, there is another

18 name. In the translation that I have, this is a man.

19 Can the witness explain this to me?

20 JUDGE MUMBA: Which one?

21 A. A man?

22 JUDGE MUMBA: Which statement?

23 MR. JOVANOVIC: [Interpretation] Your Honour,

24 this is D17, page 4. We are talking about the same

25 list of persons. Above the name that I was asking

1 about just now, there is another name. The translation

2 here says --

3 A. What do you want to hear from me? I don't

4 understand.

5 Q. I'm interested in hearing whether this person

6 is male or female.

7 A. Female. Female. I don't see how you could

8 conclude that it was a man.

9 Q. According to the name.

10 A. According to the name? A name that ends with

11 an "A"?

12 Q. If you look at the parentheses and the first

13 word after the brackets, do you know or assume that all

14 of this is being first translated into English and then

15 into our language and then from our language into

16 English. I just want you to explain this to me.

17 A. You want me to explain it to you?

18 Q. This is probably a mistake that was made by

19 the translator. That's why I asked you whether this

20 person was a man or a woman.

21 A. This person is a female.

22 Q. Very well. My colleague just told me that in

23 the English language, it says the very same name, just

24 like in the Serbian language?

25 JUDGE MUMBA: The witness who knows what

1 she's talking about, has informed the Trial Chamber

2 that this name belongs to a person who is female. Can

3 we get on from there, please.

4 MR. JOVANOVIC: [Interpretation] Yes, Your

5 Honour.

6 Q. I shall now have to ask you about a

7 particular event related to the way in which you were

8 taken out of the Partizan Sports Hall, when you were

9 hiding. Can you confirm to me that it was your mother

10 who found you in the toilet and brought you to the

11 person who was looking for you?

12 A. Yes. This is a very particular thing. I

13 said it a bit differently in the statement than it

14 actually was. I'm sure I'm saying the truth. This was

15 a mistake for sure. When I spoke this, perhaps I was

16 not paying much attention to details. Here I thought

17 about the fact that I left on my own. I left

18 voluntarily, because I was afraid that something even

19 worse would happen to someone else. I did not clarify

20 that fully at that point, and I saw that.

21 Q. You said to me a few minutes ago that you

22 read each and every one of your statements before

23 having signed them.

24 A. Yes. Yes, I did. I mean, it's better for me

25 to say that I heard it. I could not read it, because

1 they were not printed out yet. I heard them in our

2 language.

3 Q. Are you telling me that all the

4 inconsistencies in your statements that exist are only

5 a question of bad translation, or something else?

6 A. I did not say bad translation, not at all.

7 It is quite possible to explain things differently than

8 they actually were. But I personally know what they

9 mean.

10 Q. I am not trying to say that you don't know,

11 but we should know.

12 A. Yes.

13 Q. So it was not, after all, the way you

14 described it here?

15 A. Not quite that way, but I always thought of

16 one thing. However, I apologised for having made this

17 omission, this mistake.

18 Q. All right. We'll understand that as a

19 mistake.

20 A. It was a mistake.

21 Q. All right. Do you have some problems related

22 to telling colours apart?

23 A. What was that?

24 Q. I'm asking you whether you perhaps have a

25 problem in telling colours apart.

1 A. I did not notice anything like that.

2 Q. Well, I'm asking you because during

3 identification today you said that a man who you

4 identified to be Zoran Vukovic had dark hair?

5 A. Hair?

6 Q. Yes. You said that this person had dark

7 hair.

8 A. Perhaps I said a dark suit, but I did not

9 mention hair. I do not remember having mentioned hair.

10 JUDGE HUNT: She did say that he was sitting

11 next to a man with dark hair, meaning the guard, as I

12 recall. We can look it up, if you like. It isn't the

13 same -- it is not the same officer as was here then.

14 MR. JOVANOVIC: [Interpretation] Your Honour,

15 I believe you entirely, but then I did not have the

16 right interpretation.

17 Q. You will have to clarify a certain part to

18 me.

19 [Trial Chamber confers with legal

20 officer]?

21 MR. JOVANOVIC: [Interpretation] Your Honour,

22 since I will have to go back to the document that I

23 received from the Prosecutor, dated the 27th of March,

24 2000, concerning the interview with the witness that

25 was conducted on the 26th of March, I would like to

1 have this document tendered into evidence.

2 JUDGE MUMBA: Any objection from the

3 Prosecution?

4 MS. KUO: No, Your Honour.

5 THE REGISTRAR: Neither the Registrar nor the

6 Chamber do have copies of this document.

7 JUDGE HUNT: While that's being done, I

8 should tell you the transcript perhaps is equivocal.

9 It's perhaps how each of us heard it. At page 66 of

10 today's transcript, the question -- the answer is:

11 "As I look from the door going down, the

12 first person next to the guard, with dark hair, is

13 Zoran Vukovic."

14 Whether the second comma there alters the

15 sense or not, I don't know, but my clear recollection

16 at the time I heard it was that I interpreted the

17 answer as saying that the guard had dark hair, and not

18 the accused. But I think that it's open to you to

19 pursue, if you wish.

20 JUDGE MUMBA: That's how it was interpreted,

21 and the guard actually is not the same guard we have

22 now, and he had dark hair.

23 MR. JOVANOVIC: [Interpretation] Your Honour,

24 yes, I fully believe you, and that was my oversight.

25 But due to the translation, or something else, I didn't

1 understand it correctly, and that is why I asked her

2 the question. I thought that I had understood it in

3 the proper way.

4 JUDGE MUMBA: Yes. Let's proceed, please.

5 The Registrar will give us the number.

6 THE REGISTRAR: The memo dated 27th of March,

7 2000, will be Defence Exhibit D19.

8 MR. JOVANOVIC: [Interpretation] I'd like to

9 go back to this interview of the 26th of March, 2000.

10 Your Honour, I do apologise for jumping from one

11 subject to another during my cross-examination, but we

12 have this document only in English. And then -- I

13 mean, you know, the translation and everything else.

14 So I do apologise for not having put these questions

15 successively. I'm going back to something I should

16 have asked earlier on.

17 Q. Before you talked to the investigators of the

18 Tribunal, did you read your statements, the statements

19 that you gave?

20 A. Yes.

21 Q. You were shown the statements and you read

22 them all?

23 A. Mm-hmm.

24 Q. After that we have this new information that

25 you give.

1 A. Yes.

2 Q. Did you on that occasion, with members of the

3 Prosecution, talk about your statements, previous

4 statements?

5 A. Yes, I did.

6 Q. I didn't understand you.

7 A. Yes, I did talk to them.

8 Q. Thank you. And this brings me back to the

9 question I was going to ask a moment ago. Did you at

10 some time, in addition to the D17 information, when you

11 described Zoran Vukovic, tell the Prosecution, or

12 somebody else, some other data related to him and

13 members of his family which would identify him in more

14 precise terms?

15 A. I think I did on one other occasion.

16 Q. And what did you say on that occasion?

17 A. I said that his wife worked in the -- at the

18 newspaper stand, newspaper kiosk, and that I might have

19 seen her here and there, that I knew her face. That

20 was more or less it.

21 Q. Did you tell any other witnesses about what

22 Zoran Vukovic looked like, where his wife worked, and

23 did you send them -- that is to say, did you tell --

24 state it to other witnesses?

25 A. Other witnesses? No, never.

1 Q. Never?

2 A. No. Why would I give out information of that

3 kind to anybody?

4 Q. Well, I'm only asking.

5 I now have to ask you to explain to us in a

6 little more detail how you came to know Zoran Vukovic

7 before the war, because there's a big age difference.

8 You were going to school. Do you move around the same

9 places?

10 A. No.

11 Q. Do you have friends in common?

12 A. No.

13 Q. Well, tell me how you came to know him.

14 A. I said that I had probably seen him around,

15 places where there are people. It was very easy to

16 know people in Foca.

17 Q. Let me read something to you?

18 MR. JOVANOVIC: [Interpretation] And Your

19 Honours, it is on page 6 of document D17. The

20 one-but-last paragraph begins with "Vukovic." It

21 says: "I recognise Vukovic because I knew him before

22 the war. I knew Vukovic before war, so I recognise

23 him."

24 Q. That is the sentence as it stands.

25 A. Yes, that is what it says here.

1 Q. Is there once again a problem in the

2 translation?

3 A. Well, I don't know. You had some problems

4 with the translation a moment ago. It's quite

5 possible.

6 Q. Yes, but I translated what I needed. But we

7 keep coming to problems of translation when it comes to

8 you. Do you want to say that you didn't say that?

9 A. I said that I don't remember exactly, but I

10 say today that I seem to feel that I knew him from

11 before. He looked familiar.

12 Q. Would you answer my question, please. What

13 you stated here, that first sentence, is it true or is

14 it not? Yes or no, please.

15 A. I can't say exactly.

16 Q. Yes or no?

17 A. Yes, it's correct. I did used to see him.

18 Q. I didn't ask you whether you used to see him;

19 I asked you whether you knew him. The two of us can

20 understand each other, and we know the difference in

21 the words we use.

22 A. Mm-hmm. How do you mean did I know him? Do

23 you mean did I know his name and surname, whether I

24 knew his face, or what? What do you mean?

25 Q. Did you know -- is what you said here

1 correct, that first sentence? Is it correct? Would

2 you give me a simple answer, please?

3 A. Yes, it is correct.

4 Q. And then is what you said today true?

5 A. What do you mean? I state once again, and I

6 will always state it: I believe that I had seen him

7 before. His face was familiar to me. It was imprinted

8 on my mind.

9 Q. Would you now turn to the next page, please,

10 page 7, in which you describe an incident which

11 occurred next to the SUP building. You give a very

12 detailed explanation of the situation and everything

13 that happened to you.

14 A. Next to the SUP building, you mean?

15 Q. No. Just a moment, please. No. The house

16 in which you were, the house that was destroyed.

17 A. Yes.

18 Q. Did the soldiers and people who were with you

19 then, were they drunk or were they not drunk?

20 A. I can't answer your question as simply as

21 that, because some of them were drunk and some of them

22 weren't.

23 Q. Your statement is full of things that appear

24 to be one thing and then another.

25 MR. JOVANOVIC: [Interpretation] Your Honours,

1 part of that paragraph is on page 7.

2 Q. It is paragraph 5, and the paragraph begins

3 with -- that is to say, the sentence ends, "They

4 weren't drunk. They didn't -- not smell liquor on

5 their breath." [As interpreted] And today you said

6 that they were all drunk when you described this

7 scene. Were they drunk or weren't they?

8 A. We talked about many things today, and I

9 can't remember what I said for these here.

10 Q. Well, I'm telling you we can look back to the

11 transcript and see the record. Will you answer,

12 please?

13 A. Well, possibly I was wrong in saying that all

14 of them were drunk. There were always those who were

15 drunk. They were coming and going.

16 Q. Now we seem to have three versions: One

17 version is that none of them were drunk, the other

18 version is that all of them were drunk, and you now say

19 that some of them were drunk.

20 A. When did I say that all of them were drunk?

21 Q. "They were not drunk. I did not smell any

22 liquor on their breath": That's what you stated then.

23 Today you say --

24 A. But on the occasion did I say that they were

25 all drunk when I said -- when I gave my testimony

1 today? Did I say they were all drunk? I don't know.

2 Q. Well, you state that here. In your statement

3 you say that nobody was drunk. You say these men were

4 not drunk. Now, I would like to know how come they

5 were drunk now.

6 JUDGE MUMBA: May I get some clear answer?

7 This is the incident in which house? Which house.

8 MR. JOVANOVIC: [Interpretation] Your Honour,

9 according to the notes that I took today, this refers

10 to the incident which took place in the house; that is

11 to say, a doctor, a Muslim doctor, Dr. Reuf Tavro.

12 That was the house that it took place in, belonging to

13 the Muslim doctor.

14 When the witness explained that there were

15 three different men, I am not sure whether she mentions

16 in her statement the name, that is to say, did she

17 state the house she was actually in. But the

18 individuals and events that took place, just to

19 conclude that it is this particular incident, because

20 that was the one described in the statement.

21 [Trial Chamber deliberates]

22 JUDGE HUNT: The transcript, at page 68,

23 that's the 68th page today, the evidence was: "There

24 were old people there. There were dirty people and

25 drunken people." She didn't say they were all drunk.

1 MR. JOVANOVIC: [Interpretation] Yes, Your

2 Honour, but in the statement she doesn't mention

3 anybody having been drunk.

4 JUDGE HUNT: That's a matter for you, but I

5 was just correcting you as to your assertion as to what

6 her evidence was earlier on today.

7 MR. JOVANOVIC: [Interpretation] Yes, Your

8 Honour. You are quite right. It is very difficult to

9 follow in a foreign language. Sometimes it is

10 gruesome.

11 JUDGE MUMBA: You have co-counsel, who we

12 understand can read English, so why doesn't she do the

13 cross-examination, or at least assist you?

14 MR. JOVANOVIC: [Interpretation] Your Honour,

15 my co-counsel assists me as much as she is able at any

16 given point.

17 JUDGE MUMBA: The reason we have regulations

18 that counsel must be able to speak one of the languages

19 of the Tribunal is precisely this one, and sometimes

20 the rules are bent a little to allow as much

21 participation as possible, and then we insist that the

22 co-counsel must be able to use one of the two

23 languages. It's precisely this reason.

24 MR. JOVANOVIC: [Interpretation] Just a

25 minute, please.

1 [Defence counsel confer]

2 MR. JOVANOVIC: [Interpretation] I see in the

3 transcript that on page 68, line 8, I'm looking at that

4 now --

5 JUDGE MUMBA: Yes. You can go ahead. Yes?

6 MR. JOVANOVIC: [Interpretation] That is why I

7 asked the question with regard to the drunken people,

8 because drunken people are mentioned. But let's move

9 on.

10 Q. At the end of that same page, you describe

11 the event when you were taken out from the Partizan

12 Sports Hall. Could you describe this place, Brod?

13 What was Brod like? What kind of houses are there in

14 Brod? Are they apartment blocks, private houses?

15 A. Well, they're different types of houses.

16 There are no high-rise buildings. There are mostly

17 smaller buildings, private houses. There is the Maglic

18 factory.

19 Q. What type of building were you in?

20 A. Well, it was a building, a smaller building.

21 Q. Describe it for me. Did it have one

22 apartment, several apartments?

23 A. The building had several apartments. All of

24 them do.

25 Q. Please, take a look. Somewhere around the

1 middle of the text, the sentence starts with the

2 following words: "I stayed there for three days."

3 Would you please read that sentence for us? Only that

4 one.

5 A. "I stayed there for three days, and during

6 this time hundreds of girls were brought in and would

7 leave after being raped."

8 Q. Please, can you explain this word "hundreds"

9 a bit more specifically?

10 A. I don't know how the Tribunal staff wrote

11 this down. I just meant a lot of persons.

12 Q. Oh, it's a problem with the translation

13 again.

14 A. No, it's not a problem with the translation;

15 I just don't know how it was understood. I was just

16 trying to say that it was a multitude, that it was a

17 lot of persons.

18 Q. If I understand you correctly, you said

19 "many" and the transcript said "hundreds".

20 A. I'm not trying to say I said "many". I meant

21 many girls.

22 Q. Did you or did you not say "hundreds"?

23 A. I do not recall.

24 Q. All right. Can you explain to me, then, in

25 very concrete terms, what "many" means?

1 A. What "many" means?

2 JUDGE MUMBA: Counsel, it simply means that:

3 many. Can we move on, please.

4 MR. JOVANOVIC: [Interpretation] Your Honour,

5 if you permit. We started with "hundreds". I was

6 interested in having the witness explain to me how did

7 this happen with hundreds of other persons. Now --

8 JUDGE MUMBA: She has explained. She has

9 explained it. She meant several, many.

10 MR. JOVANOVIC: [Interpretation] Yes, Your

11 Honour, but I asked for an answer. I want to know what

12 the witness means by "many", because my further

13 questions will hinge on that.

14 JUDGE MUMBA: Yes. Can the witness explain?

15 Maybe it is material to counsel.

16 A. I meant that it was not one or two girls. I

17 meant that quite a few had come. As I mentioned a few

18 minutes ago, I was very frightened. I lay in a

19 corner. I was hiding. I really didn't count. Many

20 had passed. And how many there were exactly, I cannot

21 say for sure. It wasn't only two or three; it was more

22 probably.

23 MR. JOVANOVIC: [Interpretation]

24 Q. And these persons that you're speaking about,

25 these are only the persons that passed through the

1 apartment that you were in?

2 A. Yes. Yes, that passed through that

3 apartment.

4 Q. Did you go out of that apartment?

5 A. During those three days while I was there? I

6 don't think I did.

7 Q. How come you know they were taken to other

8 apartments as well?

9 A. Well, because they were no longer there.

10 They came to get them, they took them out, and then

11 they took them away. I know that from my own

12 experience, because I was taken out the same way.

13 Q. I'm asking you how do you know that other

14 women were taken to other apartments? Not those that

15 you saw in the apartment that you were in. I'm asking

16 you about others.

17 A. Are you asking a general question about all

18 the women in Partizan? I don't understand your

19 question.

20 Q. My question specifically pertains to this

21 event here. I'm interested in those persons, not the

22 persons from Partizan. I'm interested in what you

23 saw. Tell us that.

24 A. What did I see? As I already said, I saw

25 quite a few girls who were coming in. They were

1 brought from somewhere and taken away somewhere.

2 Q. All of this in the apartment that you were

3 in?

4 A. I'm talking about that apartment, yes.

5 Q. What do you know about other apartments that

6 you were brought -- that they were brought within that

7 framework? I'm asking you that. That's what you

8 said.

9 A. I don't remember how come I knew. I don't

10 know. I cannot really understand your question. Can

11 you specifically explain what you're asking me to do?

12 Q. I'm going to read it. Perhaps it's going to

13 be easier for you.

14 A. All right. Read it.

15 Q. "I was taken to a private apartment and the

16 other women and girls were taken to other apartments.

17 I stayed there for three days, and during that time

18 hundreds of girls were brought in that left after they

19 had been raped."

20 I am asking you about these other

21 apartments. Is this your statement?

22 A. You are asking me how come I knew that they

23 left? These were women from Partizan. We did not

24 understand each other.

25 Q. Who did not understand each other? You and I

1 or you and the investigator?

2 A. You and I did not understand each other. The

3 women that I mention here that went to other

4 apartments, these are women from Partizan. If you look

5 a bit more carefully, you will see a week later I was

6 taken out of Partizan again. The Serb soldiers, who I

7 did not know, came again to take away some women and

8 children. The same thing happened again. They just

9 pointed at us. This time they took us out of Foca to

10 Brod.

11 Q. Can you, with the usher's assistance,

12 identify on this list the women that were taken out of

13 Partizan together with you on that occasion?

14 A. I do not remember that. I did not mention it

15 in the statement. I do not remember which are the ones

16 that were taken out. I know that several were taken

17 out, but I cannot remember.

18 Q. Not a single one?

19 A. Not a single one.

20 Q. You remember everything else concerning that

21 event except for who was with you?

22 A. What was that?

23 Q. I'm asking you the following: You remember

24 everything else concerning that event except for who

25 was with you?

1 A. I remember as much as I know. I said how

2 much I remember. There were many events. I don't want

3 to say just anything now and to say something wrong.

4 I'm not sure. I cannot say exactly who.

5 THE REGISTRAR: [Interpretation] The registrar

6 would like to remind Mr. Jovanovic that he has to

7 switch off his mike when the witness answers his

8 questions. He has to do that every time in order to

9 avoid that the voice of the witness is heard outside.

10 MR. JOVANOVIC: [Interpretation] Thank you.

11 Q. Now we're going to go back to an event

12 described on page 4. We talked about it a few minutes

13 ago. That was the incident at the high school. When

14 you say how long this incident lasted, what time are

15 you referring to?

16 A. I did not understand what you were saying.

17 What do you mean, what time? The time that had

18 elapsed, the time when this took place, what?

19 Q. I'm referring to the duration of this

20 incident, from the beginning to the end.

21 A. Again I did not understand. What incident?

22 Q. All right. Let's go on. Let's move on to

23 another question. Maybe we're going to understand each

24 other now.

25 After that had happened, you returned to the

1 room where your family was?

2 A. Yes.

3 Q. You confirmed that you did tell your mother

4 what had happened to you?

5 A. I confirmed -- are you asking me whether I

6 confirmed that I said it?

7 Q. Yes.

8 A. I always said that I never, ever described

9 the events that took place to anyone. If I said it, it

10 was in some other way. It wasn't that I told her

11 directly that such-and-such a thing had happened.

12 Perhaps I just said the worst had happened, or

13 something like that. I never described this to anyone.

14 Q. I did not mean that you described what had

15 happened; I meant by way of information, that you

16 informed her what had happened to you. Did you or did

17 you not inform your mother of what had happened to you?

18 A. I do not remember exactly. I do not remember

19 exactly what I said then.

20 Q. I do not mean what you said exactly. I'm

21 just asking whether you told her or not. The words

22 don't matter.

23 A. At this moment I cannot remember that.

24 Q. I'm going to remind you of the statement you

25 made, page 5, the fourth paragraph. It starts with the

1 words "I do not remember." The text reads as follows:

2 "He left and I went back to the room where my family

3 was. I told my mother what had happened." Do you

4 confirm that, that that is what you stated?

5 A. That I stated this? You want me to confirm

6 that I stated this? Yes. I do not remember exactly.

7 Q. You do not remember that this is what you

8 told the investigators?

9 A. I do not remember exactly, yes. It's been

10 five years. I cannot remember each and every sentence.

11 Q. All right. D19, that was admitted today,

12 that is a memo.

13 MR. JOVANOVIC: [Interpretation] The witness

14 that we are examining today says that she read her

15 statement and that she confirms that all the previous

16 statements she made and that she read are correct.

17 Q. And now I'm asking you the following: If you

18 stated this on the 26th of April -- 26th of March, and

19 now you say that you don't know what is correct?

20 A. I did not tell you that I don't know what is

21 correct. I said that I cannot remember each and every

22 sentence from my statement so well.

23 Q. Did you tell your mother or did you not tell

24 your mother; yes or no?

25 A. I don't remember.

1 Q. Is this statement of yours correct, the one

2 that you gave here?

3 JUDGE HUNT: Which one?

4 A. Yes, it's correct.

5 MR. JOVANOVIC: [Interpretation] Your Honour,

6 I am referring to this specific sentence that reads:

7 "I told my mother what happened." Your Honour, we

8 went back to her statement, the witness and I, the one

9 that is D17, I think.

10 JUDGE HUNT: It would help us if you'd just

11 identify that when you do. It's very difficult to

12 follow when we now have three different documents.

13 MR. JOVANOVIC: [Interpretation] You are quite

14 right.

15 Q. I was talking to His Honour, the Judge. I

16 was not following everything you said to the end. What

17 you said here, is that correct?

18 A. I told you: I cannot remember, even when I

19 read this statement. I said that I could not remember

20 each and every sentence, each and every word. When I

21 read ten pages, I could have omitted something on the

22 fifth page.

23 Q. Thank you. Do you know that your mother, who

24 was heard here as a witness, said that you did not tell

25 her anything?

1 A. I don't know.

2 Q. Well, I'm telling you.

3 A. All right.

4 Q. That is precisely why I'm putting this

5 question to you. You said one thing; your mother, who

6 was heard here before you, said a different thing. I'm

7 interested in which one of the two is correct.

8 A. Partly both are correct.

9 Q. Partly both are correct?

10 A. I said that I never talked to anyone about

11 it.

12 THE INTERPRETER: Could counsel please stop

13 overlapping the witness.

14 A. My full statement -- my statement is fully

15 correct, sir.

16 MR. JOVANOVIC: [Interpretation] Thank you.

17 JUDGE MUMBA: Counsel, we are coming to

18 time. Do you still have questions?

19 MR. JOVANOVIC: [Interpretation] Yes, Your

20 Honour. Unfortunately I still have some questions

21 left. And I never pay attention to the time, so thank

22 you for drawing my attention to it.

23 JUDGE MUMBA: Very well. Then the

24 cross-examination will continue tomorrow morning at

25 0930 hours. I just want to remind counsel that there

1 will be a new schedule for April, because the Tribunal

2 will have plenary on the 17th and 18th of April. So

3 the proceedings for that week will be for only two

4 days: 19th and 20th. 21st is a UN holiday. It's Good

5 Friday. So it will be issued in writing. The Court

6 will rise.

7 --- Whereupon the hearing adjourned

8 at 4 p.m., to be reconvened on

9 Thursday the 30^th day of March, 2000,

10 at 9.30 a.m.

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