141209ED

Page 29467

1 during the testimony of Nenad Kecmanovic.

2 A few pages of D555 -- 557, I apologise, which is a 77-page

3 document, entitled "Islamic Declaration," was used with

4 Witness Kecmanovic. In September the Defence advised the Chamber that it

5 would seek to tender the entire document. On the 13th of October of this

6 year, the Chamber requested the Defence to file submissions giving the

7 reasons as to why the entire document should be admitted. The Chamber

8 hereby sets a deadline of the 19th of December, 2014, for these

9 submissions.

10 [The witness takes the stand]

11 JUDGE ORIE: Good morning, Mr. Amidzic.

12 THE WITNESS: [Interpretation] Good morning, Mr. President of the

13 Trial Chamber. Good morning, Your Honours, Judges.

14 JUDGE ORIE: Mr. Amidzic, I'd like to remind you that you're

15 still bound by the solemn declaration you've given at the beginning of

16 your testimony, that you'll speak the truth, the whole truth, and nothing

17 but the truth.

18 Mr. Ivetic will now continue his examination-in-chief.

19 WITNESS: BOSKO AMIDZIC [Resumed]

20 [Witness answered through interpreter]

21 JUDGE ORIE: Please proceed, Mr. Ivetic.

22 MR. IVETIC: Thank you, Your Honour.

23 Examination by Mr. Ivetic: [Continued]

24 Q. Good morning, Colonel.

25 A. Good morning.

Page 29468

1 MR. IVETIC: I'd like to call up in e-court Exhibit D847, which

2 should be the statement of the witness. And could we please turn to page

3 6 of the same in both languages. I apologise. It will be one page prior

4 in the English. We're looking at paragraph 25.

5 THE WITNESS: [Interpretation] I've found 25.

6 MR. IVETIC:

7 Q. Sir, in this paragraph you mention that you provided three sets

8 of field kitchen trailers for the Nepalese Battalion of the UN forces.

9 Can you tell us how and why it came to be that you were called upon to

10 provide these to the Nepalese Battalion?

11 A. Well, Judges, in response to this question, I'm going to say the

12 following. We kept this buffer zone in Slavonia; or rather, the units of

13 my corps that separated the warring peoples and disabled conflicts,

14 although conflicts were under way.

15 As this area was left, according to the agreement reached between

16 the JNA and UNPROFOR it was the peacekeeping forces that took over, or

17 rather the forces, for ensuring that area. That was the Nepalese and

18 Argentinian Battalions. When this area was taken and when this function

19 was taken over from our units, I was asked for three kitchens with tents

20 and equipment for preparing meals in the field. My organs gave this to

21 them, and they were supposed to give it back, which, indeed, they did.

22 THE INTERPRETER: Interpreter's note: Could all microphones

23 please be switched off when the witness is speaking. Thank you.

24 JUDGE MOLOTO: If I may just get some clarification, Witness.

25 You are recorded as having said "disabled conflicts." This is at

Page 29469

1 page 4, line 13. Was it disabled conflicts? It doesn't make sense

2 what -- that you said. Or is it disabled convicts? I don't know.

3 THE WITNESS: [Interpretation] No.

4 JUDGE MOLOTO: Let me read the sentence to you. You say:

5 "We kept this buffer zone in Slavonia; or rather, the units of my

6 corps that separated the warring peoples and disabled conflicts..."

7 Or are you -- is the disabled -- is a vapier?

8 THE WITNESS: [Interpretation] In my language that is what it

9 means, to disable conflicts, not to make conflicts possible.

10 JUDGE MOLOTO: Thank you so much.

11 JUDGE ORIE: Please proceed, Mr. Ivetic.

12 MR. IVETIC:

13 Q. Colonel, I'd now to now look at paragraph number 30.

14 MR. IVETIC: Which should be on the next page in both languages

15 of the statement.

16 Q. And here it says that prisoners of war organised the preparation

17 and distribution of their own food at Manjaca. Can you please explain

18 for us the manner how food was provided for them to prepare and

19 distribute themselves.

20 A. That task, as well as the task in general that was being carried

21 out for all combat units in terms of working along these patterns, as we

22 say, we carried this out through the organs that were the mainstays of

23 these activities. However, the command of the camp provided the numbers

24 and the requests to the Kozara barracks and then they made calculations

25 according to standards and then provided food and other things to the

Page 29470

1 camp.

2 It is true that the prisoners themselves organised the

3 preparation and distribution of food. My duty was also not only to

4 provide food but also accommodation, change of clothing, and bathing. I

5 can add another thing. The assortment of articles and needs that were

6 provided according to these calculations did not differ at all from the

7 rations I provided to others. Often this was not sufficient, but that

8 was the case for all.

9 Q. Sir, you have just said:

10 "The assortment of articles and needs that were provided

11 according to these calculations did not differ at all from the rations I

12 provided to others."

13 What "others" are you talking about?

14 A. I mean other units that were there for security in the entire

15 area, because the POW camp had to be supplied with food according to the

16 norms and standards that are prescribed otherwise. I made no distinction

17 between the members of the army and the persons who were in the camp. I

18 did it in an equal way, depending on the numbers involved.

19 Q. Thank you. Now I'd like to look at paragraph 37 --

20 JUDGE ORIE: Could I ask one follow-up question.

21 MR. IVETIC: Yes.

22 JUDGE ORIE: I do understand that the quantity of food needed was

23 calculated and that you made no distinction between security and the

24 prisoners of war. Were you there when the food was distributed?

25 THE WITNESS: [Interpretation] Most often I was not because the

Page 29471

1 POWs organised this themselves. As for inspections, I could not adjust

2 it to that, and it was a rare occasion when I would be there when food

3 was being distributed.

4 JUDGE ORIE: So -- so whether -- I do understand that there was

5 not sufficient food. What -- what quantity was -- was it 50 per cent?

6 What was needed that was provided? Or 70 per cent or -- could you tell

7 us a bit more about that? On average.

8 THE WITNESS: [Interpretation] I cannot tell you about

9 percentages. The assortment of articles differed. Sometimes there was a

10 full assortment, and sometimes certain articles were lacking. So when I

11 didn't have that, I didn't have it for others either when I had no way of

12 getting ahold of things like that. I'm saying that the pattern of supply

13 was the same for officers and soldiers and on the front and these persons

14 who were in the POW camp.

15 In the same way, the rules were being applied. The rules

16 governing supplies. It depended on what I had. At certain points I had

17 more and then, say, the following day I would have less. Often the meals

18 would simply be poorer. There wouldn't be a full assortment of articles.

19 JUDGE ORIE: Now, how could you be sure that those who were

20 providing security would, in effect, get the same poor rations and not -

21 which one could imagine - either take more than their share was or take

22 less than their share was. How would you know who finally got what?

23 THE WITNESS: [Interpretation] Ultimately that is really difficult

24 to be everywhere, because it's a big area, a large number of units,

25 and --

Page 29472

1 JUDGE ORIE: Witness, I do understand that you finally would not,

2 could not know for certain whether it was shared in the way as it was

3 calculated.

4 THE WITNESS: [Interpretation] On the contrary. My calculations,

5 yes, and everyone in the field got whatever was possible. And my organs

6 did that in a very professional and responsible way.

7 JUDGE ORIE: Yes. But you said it's really difficult to be

8 everywhere which means that you finally were not able to verify whether

9 it all went as it was planned and as it was calculated who really got

10 what.

11 THE WITNESS: [Interpretation] Well, Judge, sir, the commander of

12 the unit is the one that counts, and then they can give me information

13 saying there wasn't sufficient and so on. However, I sent people of my

14 own to check, and then we would improve the situation as much as

15 possible.

16 JUDGE ORIE: To check what?

17 THE WITNESS: [Interpretation] Everything. Rules, standards,

18 application, quality of meals, way of distribution, cleanliness, hygiene,

19 everything else.

20 JUDGE ORIE: What did your people find that needed to be

21 improved?

22 THE WITNESS: [Interpretation] Quite a bit. There is a broad

23 spectrum in terms of all the objections that we heard, and it depended on

24 the people who would use the articles they received. Also hygiene. Were

25 they prepared, ready to do that. Also cleanliness, personal cleanliness,

Page 29473

1 clothing, and other equipment.

2 JUDGE ORIE: Yes. I would have preferred to have concrete

3 answers rather than general statements, but I leave it to that.

4 Mr. Ivetic, you may proceed.

5 JUDGE FLUEGGE: May I put one follow up question.

6 You said, Witness, you said --

7 THE WITNESS: [Interpretation] Sir, sir, Judge.

8 JUDGE ORIE: No, no. Please, we are not --

9 JUDGE FLUEGGE: Listen to my next question.

10 JUDGE ORIE: We're not used to being interrupted.

11 Please proceed, Judge Fluegge.

12 THE WITNESS: [Interpretation] Sorry.

13 JUDGE FLUEGGE: You told us that the prisoners of war did the

14 preparation and distribution of the food by themselves. How did they

15 organise it?

16 THE WITNESS: [Interpretation] There was a particular point where

17 the kitchen was for cooking. Then there was a particular area with

18 certain tables for distribution. And then there was a certain lineup. I

19 mean, in terms of the way how these persons who were in camp were

20 brought.

21 Then after the cooking, the commander of the camp had to be

22 present to taste the food and to approve its distribution. That was the

23 sign that the food was prepared in a proper way, that it was healthy, and

24 that it could be distributed.

25 JUDGE FLUEGGE: However, you didn't tell me how the prisoners of

Page 29474

1 war organised themselves. This was the question. Because earlier you

2 said they organised it by their own. How did they do that? I'm not

3 asking about the commander and about his duties.

4 THE WITNESS: [Interpretation] I understand. On the basis of

5 mutual -- I mean, selection or the command -- on the basis of the

6 composition involved, I mean, the persons who were found there, who were

7 professional waiters, who could do that kind of work, they were involved

8 in such obligations and then they would do that for the entire camp.

9 JUDGE FLUEGGE: And the prisoners decided who is a professional

10 waiter?

11 THE WITNESS: [Interpretation] Well, don't forget that when

12 persons came in and were processed, that was very detailed. During that

13 processing and during that registration, the command and the persons who

14 comprised the security of the camp have an exact overview of the

15 structure of these persons and also what they could be involved in.

16 JUDGE FLUEGGE: I'm sorry, but you didn't answer my question how

17 the prisoners organised themselves. But I leave it to that.

18 Mr. Ivetic.

19 MR. IVETIC:

20 Q. Did you have anything additional to tell the Judges, or can we

21 move on, sir?

22 A. I should explain yet again. In every respect in terms of

23 regulations that camp was well organised. From the moment those people

24 entered and were processed, there was no doubt that they could have been

25 engaged in the organisation of work in the camp itself. As for the camp

Page 29475

1 administration or the camp command, they knew exactly who they could

2 engage and who they couldn't, because they were not capable of working.

3 Q. Okay. Now, sir, I'd like to turn to the next page in your

4 statement and look at paragraph 37. Here, sir, you're explaining that

5 since you were at your maximum, you allowed and humanitarian

6 organisations provided additional materials to provide a higher standard

7 of life to those in Manjaca camp. Can you identify for us which

8 humanitarian aid organisations these were that did this.

9 A. Your Honours, this part of the answer is the addition to my

10 previous answer. There were shortages and there were gaps in security,

11 and I therefore allowed humanitarian organisations to fill the gaps and

12 to provide for what I could not provide. Those same representatives of

13 humanitarian organisations inspected the camp so we could together

14 ascertain what needed to be brought in, equipment, cleaning agents,

15 personal hygiene articles, and food I could not provide. To be more

16 specific, most commonly they brought in medicines and a whole range of

17 necessities in terms of medical supplies. And as for their names, most

18 commonly, it was Merhamet, the Muslim charitable organisation

19 headquartered in Banja Luka, and Caritas, also a charitable organisation

20 run by the Catholic church. The Red Cross, the local Red Cross was also

21 present, and you already know about the role that the

22 International Red Cross played in all that.

23 I apologise. I told all of them there and then what my

24 capabilities were and I welcomed them all. As far as I know, they

25 inspected the area even without me. When they were announced they were

Page 29476

1 allowed to get in. I am not aware of the fact that any of their

2 announced visits was not approved. All those who could play a role and

3 improve the standard of living and the humanitarian situation of those

4 who were kept in the camp were more than welcome to do so.

5 MR. IVETIC: Now I'd like to look at paragraph 39, the same page

6 in English, the next page in Serbian.

7 Q. Here you mention that you read reports and found statements, even

8 of those that visited the Manjaca with you, with meant --

9 misrepresentations about Manjaca. Can you tell us what reports or

10 statements you are referring to?

11 A. Your Honours, I really need to start my answer to this question

12 in this way, in the following way: All those who escorted me very often

13 and what I established during my controls did not reflect the situation

14 as was portrayed by the persons who were often visiting the camp with me.

15 We looked at the same things and then their stories ended up being

16 different. They would end up saying that a lot of irregular things were

17 going on, including inhumane treatment, ill-treatment, torture --

18 JUDGE ORIE: Witness, let me stop you there.

19 I'm also addressing you, Mr. Ivetic.

20 You were asked what statements you were talking about.

21 Of course you'll understand, Mr. Ivetic, that this Chamber is

22 unable to evaluate any evidence which says some statements I heard or

23 that and that without knowing what statements we are talking about.

24 Apart from that, it's not usual for a witness who tells us that he was

25 often not present, that he could tell us exactly that those who are

Page 29477

1 telling about certain events are not telling the truth where the witness

2 himself apparently, or we could check that on the basis of the statements

3 he's talking about, whether he was present or not, whether he went -- can

4 contradict that. And by the way, it's not a matter of telling that

5 someone else is not telling the truth. But if this witness has any

6 specific knowledge about certain events, we'd like to hear that. And

7 then, of course, we have to evaluate and we have to assess which is the

8 truth, what is the truth, and what is not. But these kind of sweeping

9 general statements of others not telling the truth doesn't assist the

10 Chamber. Could you please be focused in your questions on these matters.

11 MR. IVETIC: I thought I was by asking what statements he's

12 talking about, Your Honours.

13 JUDGE ORIE: Yes, but -- you were, but then you let the witness

14 just go and he says before answering the question I have to make all kind

15 of statements. You could have reminded him at that moment that you

16 require him to answer your question.

17 MR. IVETIC: Okay.

18 JUDGE ORIE: Please proceed.

19 MR. IVETIC:

20 Q. Colonel, could you please identify for us precisely what

21 statements you are referring to in this paragraph of your statement.

22 A. Your Honours, as I was preparing for this testimony, I came

23 across the statements of the witnesses who testified here before me.

24 JUDGE ORIE: Well, first of all, that's an answer to the

25 question. I take it that you then refer to those statements and that

Page 29478

1 you --

2 THE WITNESS: [Interpretation] Yes.

3 JUDGE ORIE: -- apparently studied them. Who provided them to

4 you?

5 THE WITNESS: [Interpretation] As I was preparing myself for this

6 testimony, I came across a statement by Colonel Selak.

7 JUDGE ORIE: Witness, I didn't ask you at this moment whose

8 statement you were talking about. Who provided the statement to you or

9 how did you find it?

10 THE WITNESS: [Interpretation] When I was being provided with

11 materials from -- by the Defence team and when I wanted to be acquainted

12 with all the materials in order to prepare for this appearance. A lot of

13 the things were shown to me.

14 JUDGE ORIE: Witness, the simple answer is: They were given to

15 me by the Defence. Because that was the question.

16 THE WITNESS: [Interpretation] Yes.

17 JUDGE ORIE: Okay. Would you tell us exactly what you received

18 from the Defence, names of the witnesses.

19 THE WITNESS: [Interpretation] In that statement that I am trying

20 to interpret and use here in order to provide my own explanation. Again?

21 JUDGE ORIE: Again, I stop you. My question was: Whose

22 statements you received by the Defence. So I expect you to tell me

23 Witness A, Witness B, Witness -- I just want names at this moment so that

24 we know what statements you received and reviewed.

25 THE WITNESS: [Interpretation] In the specific case,

Page 29479

1 Colonel Osman Selak. His statements.

2 JUDGE ORIE: Did you receive any other statement, and did you

3 review any other statement?

4 THE WITNESS: [Interpretation] I did not have an opportunity.

5 However, I saw parts of his statement where it says exactly this. I

6 don't know what was happening there. I don't know. But people told me,

7 people from Merhamet told me that. That's what I saw in the statement.

8 JUDGE ORIE: Witness, do I understand that the only statement you

9 have read and reviewed was the statement of Mr. Selak?

10 THE WITNESS: [Interpretation] There were several statements.

11 JUDGE ORIE: Okay. Then give us the name of the other witnesses

12 whose statements you reviewed.

13 MR. IVETIC: Perhaps I can assist. There's a translation issue.

14 He said [Interpretation] "he has several statements," referring to

15 Mr. Selak.

16 JUDGE ORIE: Okay. Fine, if you have several statements. Whose

17 statements do you have?

18 THE WITNESS: [Interpretation] Precisely. His statements,

19 Osman Selak's statements.

20 JUDGE ORIE: Yes. Do you have statements of any other witness,

21 other than Selak?

22 THE WITNESS: [Interpretation] In this matter, apart from Selak's,

23 nothing else.

24 JUDGE ORIE: Okay. What do you have from Selak's statements?

25 THE WITNESS: [Interpretation] Well, Your Honour, I've just told

Page 29480

1 you. In one part of his statement, it says as follows: When it comes to

2 the --

3 JUDGE ORIE: Witness, we'll come to that later. I first want to

4 know: Do you have one statement of Selak, do you have several statements

5 of Selak? And, if so, how many.

6 THE WITNESS: [Interpretation] I can't be sure how many. However,

7 one of them deals with this issue and I remember very well --

8 JUDGE ORIE: Witness, Witness --

9 THE WITNESS: [Interpretation] If you will allow me, I can't

10 remember what year that statement was from.

11 JUDGE ORIE: Witness, no. I want you first to answer my

12 questions. You want to move through a certain subject and we need

13 information before we come to that subject. If there's any specific

14 matter -- Mr. Mladic, are you supposed to remain seated, first of all.

15 If there's any translation issue, Mr. Stojanovic, tell us.

16 Apparently there is a ... is there no audio? No loud speaking.

17 MR. IVETIC: I'm told everything should be okay now.

18 JUDGE ORIE: Yes.

19 Now, I want you -- we want to know exactly on what your statement

20 in this respect is based, and that's the reason why we want to have that

21 information first. What you did see? How many pages? Was it a short

22 statement? Was it a long statement? How many statements have you seen?

23 From Mr. Selak.

24 THE WITNESS: [Interpretation] Several statements on several

25 occasions. They were all by Selak. But what he dealt with in this

Page 29481

1 particular statement, I remember that --

2 JUDGE ORIE: Witness, again, we'll come to that. Please answer

3 my questions first. You say you have seen -- are they all short

4 statements, and in what language are they?

5 THE WITNESS: [Interpretation] Those statements were in English

6 and in Serbian.

7 JUDGE ORIE: You read English?

8 THE WITNESS: [Interpretation] No.

9 JUDGE ORIE: And how was that -- did you also read transcripts of

10 the testimony of Mr. Selak or did you just read statements which he

11 signed like the statement you've given?

12 THE WITNESS: [Interpretation] Your Honour, I can't make a

13 distinction between the two. I think it was a transcript. I don't know

14 what you mean when you say "the transcript of his statement." It was the

15 transcript -- transcript of his testimony or statement.

16 JUDGE ORIE: Okay. What a statement is is the relatively short

17 report of an interview in which you just see what the person may have

18 said. Like your statement as you find it on your screen now. That's

19 what I call a statement.

20 What I call a transcript is a verbatim record of what someone

21 tells us in court, which means that you'll see question put, answers,

22 interventions saying we take a break, et cetera, et cetera.

23 Now, what you did you -- and usually those transcripts are

24 relatively long. That is, could be easily 30, 40, 50, 60 pages, whereas

25 usually statements are short; that is, anything between two and often not

Page 29482

1 more than ten pages. What did you read?

2 THE WITNESS: [Interpretation] I just told you, a transcript. It

3 was longer than a statement that you have just mentioned.

4 JUDGE ORIE: Okay. Now, that was in what language?

5 THE WITNESS: [Interpretation] In Serbian.

6 JUDGE ORIE: Yes. Well, this Chamber is not aware of any

7 transcript being prepared -- although there is a translation problem at

8 this moment.

9 Mr. Ivetic, could you tell us out as to whether --

10 And let me ask you first: Where did you get that transcript

11 from? Did you get it from the Defence.

12 THE WITNESS: [Interpretation] I've told you, yes.

13 JUDGE ORIE: Okay. Mr. Ivetic, were any which is possible

14 transcript provided to the witness in preparing for his testimony.

15 MR. IVETIC: Mr. Lukic prepared this witness and my understanding

16 is that only ICTY statements were -- would have been given to the witness

17 to comment upon if he knew anything about specific allegations of

18 Mr. Selak, and it is possible that a Google translation of the draft

19 statement was also provided.

20 JUDGE ORIE: Okay. So it's at this moment, if I could say so,

21 it's more likely than not that he was provided with an English or at

22 least a -- statements taken in B/C/S or written down in B/C/S?

23 MR. IVETIC: My understanding is all the ICTY statements are

24 taken in English with a B/C/S translation provided.

25 JUDGE ORIE: Yes. But statements, not testimony.

Page 29483

1 MR. IVETIC: Well, I've also indicated that I believe also a

2 Google translation of the transcript could also be provided.

3 JUDGE ORIE: Yes. Okay. All right. Now, when this witness

4 makes this statement about I heard, I was told, et cetera, I may take it

5 that when he was interviewed that it was verified what he exactly

6 referred to rather than putting on paper any comment without having

7 verified on what it was based? What it referred to.

8 MR. IVETIC: Yes, Your Honour. And the witness has five times

9 today tried to identify particularly the statement from Mr. Selak, the

10 particular words of Mr. Selak that he's been referencing, and you have

11 not permitted him to do so.

12 JUDGE ORIE: Mr. Ivetic, you're invited to clarify this issue in

13 the way I did it because I do understand that I do it not as you consider

14 it to be appropriately done. Please be aware that the statement, as it

15 is now, lacks sufficient basis, and you're invited to clarify this

16 viva voce because you are claiming, if I understand you well, that you

17 better know how to do that and I gladly accept that.

18 Please proceed.

19 MR. IVETIC: I do not know better than you, Your Honour. You

20 have asked questions and the witness has started to answer them.

21 JUDGE ORIE: Mr. Ivetic, I said that you may proceed. Would you

22 please proceed.

23 MR. IVETIC: I would, Your Honours, and I would also direct

24 Your Honours to paragraphs 64 through 68 of the statement that deal

25 particularly with Mr. Osman Selak.

Page 29484

1 Q. Now, Colonel, could you please answer what the Judge did not let

2 you answer: What particular parts of Mr. Selak's statement are you

3 referencing in your discussion in paragraphs 39 and 40?

4 A. Your Honours, I apologise. I didn't make a distinction. I

5 really don't know the distinction between a transcript and a statement.

6 It probably will be a statement. But what am I talking about? In that

7 statement by Osman Selak, I found a part where he describes the situation

8 in the prisoner of war camp at Manjaca. He says that there was inhumane

9 treatment, ill-treatment, and even killings of prisoners. He says: I

10 don't know, but I was told that by people from Merhamet. He continues to

11 say that in that camp, according to them, about 40 people were killed. I

12 referred to that part of the statement and I provide my answer

13 accordingly. I did not make up anything. I did not add anything.

14 Your Honours, I was surprised for that person to say some 40. In our

15 language 40 is 40, and some 40 could be 39 or 41 or any other unspecified

16 number of people who were killed.

17 JUDGE ORIE: Just for my information, do you think "some 40"

18 could also be 18 or 65, or would be it be, well, let's say, anywhere

19 between 35 and 45?

20 THE WITNESS: [Interpretation] This is my problem exactly,

21 Your Honour. When he says "some 40," he means around 40. I really can't

22 tell you with certainty whether it is anything between 35 and 45. It is

23 a very non-specific piece of information which cannot be pin-pointed.

24 JUDGE ORIE: Well, you said "or any other unspecified number,"

25 which would range from whatever, whereas I understand "some 40" to mean

Page 29485

1 in the range of approximately 40, that would be at least anywhere between

2 30 and 50, but I asked you this because you said it could be any

3 unspecified number which is a far wider range than the one I put to you,

4 as my understanding of what "some 40" means.

5 THE WITNESS: [Interpretation] Let me tell you sincerely,

6 Your Honour, I don't know what he meant. This is just my objection.

7 This is an important piece of information and still he presents it in a

8 very non-specified way. He may have had in mind 39 or 41, he is not sure

9 about this figure, 40. Still, it's a very important piece of information

10 and to tackle with such recklessness --

11 JUDGE ORIE: Well, as a matter of fact, Mr. Ivetic, as I said

12 before, if the witness can tell us anything specific which contradicts or

13 supports or -- about the same events, we'd like to hear. But to -- for

14 the witness to tell us what is appropriately accepted into evidence or

15 not may not be the most important thing to hear from a witness.

16 Please proceed.

17 MR. IVETIC: Thank you. Now I'd like to move to page 9 in

18 English and page 10 in Serbian, and we should then be looking at

19 paragraphs 44 through 45.

20 Q. And here you describe bringing an ICRC and international

21 humanitarian representative delegation to the Mali Novi Logor barracks to

22 show them that this was not a prisoner of war camp. First of all, who if

23 anyone came with you and these officials to the barracks on this

24 occasions?

25 A. Your Honours, in the Banja Luka garrison, there is and there was

Page 29486

1 the Mali and Novi Logor barracks, Logor meaning a camp. And there was an

2 association with the war camps. In the Mali Novi Logor there was a

3 military investigation prison where military personnel was kept while

4 they were waiting to be tried or investigated. That facility was a

5 military prison or a detention unit. I inspected it with General Mladic

6 with representatives of the International Red Cross with our host from

7 the barracks who was responsible for the control and care of that

8 facility. We showed everybody everything. We opened all the rooms and

9 as we were passing through the facility, we also had brief conversations

10 with the people who were kept there. We entered everything single room,

11 we saw every single person, we controlled the corridor, and finally we

12 opened the area in -- below the staircase where brooms were kept in a

13 little closest just to show everybody that we were not hiding anything.

14 The representatives of the Red Cross and some other people who were

15 there, and I don't know which organisation they belonged to, did not have

16 anything to say to everything that they had seen. They did not have any

17 comments.

18 Q. Now I'd like to move to --

19 JUDGE ORIE: Mr. Traldi.

20 MR. TRALDI: Can we get a date for this visit.

21 MR. IVETIC:

22 Q. Do you recall the year or date or time of year for this visit to

23 the Mali Novi Logor barracks?

24 A. Mr. President, I would not want to speculate, but it was in the

25 month of August 1993. I think it was on the 27th of August or during

Page 29487

1 that period of time.

2 Q. Thank you. Now I'd like to look at paragraph 46 on the same

3 page. Here you talk of the Croat population running from Muslim forces

4 in Central Bosnia. Can you be a bit more specific precisely what region

5 these Croats were coming from? What is the name for that region?

6 A. Mr. President, the answer to this question goes as this. I

7 received a task from my superior command, it was signed by Mr. Mladic.

8 It was to receive the population from Central Bosnia who were threatened

9 and more specifically from the Lasva valley around the town of Travnik.

10 Am I making myself clear?

11 Q. Yes, yes. If I --

12 A. The population that was threatened and members of the Croatian

13 Defence Council were simply fleeing before Muslim forces and they were

14 seeking refuge in our territory. That was approved. And then we --

15 Q. If I can interrupt. If I can interrupt, we do have some of that

16 in your statement. I have two more questions I'd like to get to

17 hopefully before we take the first break.

18 Sir, in paragraph 49 on the next page in English and page 10 in

19 the Serbian, you talk about HVO members that surrendered their weapons

20 and --

21 JUDGE ORIE: Mr. Mladic should not speak at an audible volume.

22 MR. IVETIC:

23 Q. -- and were temporarily accommodated in Manjaca. How long did

24 they stay in Manjaca and where did they go after?

25 A. Mr. President, members of the HVO, around 300 of them, decided to

Page 29488

1 surrender. They their own lists. They surrendered their weapons. With

2 their consent they were taken to facilities of the former camp, and at

3 that moment it was no longer a camp and they did not have the status as

4 prisoners of war. They stayed there not more than ten days, and during

5 that time the further procedure was organised. Upon the order of our

6 superior command, we used lorries with tarpaulin to transport them to the

7 area of Vares. They had to move across our territory, and those who

8 wanted to go to Ilijas and Sarajevo, we could not meet that request

9 because those areas were under the control of Muslim forces, so they

10 faced further problems there if they had been sent there.

11 Q. Sir, now I'd like to look on the same page in English and the

12 next page in Serbian, and my last question deals with paragraph 62.

13 MR. IVETIC: And if we go to the next -- pardon me. We should go

14 to page 12 in the English and page 12 in -- page 13 in Serbian. And

15 paragraph number 62.

16 Q. Here you say about General Mladic:

17 "All that I heard and pictured about him earlier was proven right

18 about his personality when I was on an official visit to the Knin Corps."

19 What precisely had you heard and pictured about General Mladic

20 which was proven true and from whom had you heard it?

21 A. During the regular visit to the Knin Corps with my previous

22 commander, with a view to an exchange of experience, I spoke to the

23 assistant commander for morale of that corps whose name was

24 Mesud Hasotic. He was a colonel and he was assistant commander for

25 morale for that corps. Since I did not know the name or surname of the

Page 29489

1 head of the quartermaster's division, and that is what I was interested

2 in, he took me to the chief whose name was Ibro. I could remember his

3 last name. He was a colonel, too. We talked about all sorts of things,

4 and they told me about Mr. Ratko Mladic who was then Chief of Staff of

5 that corps who was a real soldier's man, a man's man who asked for

6 discipline and order and all on the basis of the personal example that he

7 set. As a soldier, I recognised my own attitude and fitting into

8 requirements, although I didn't know that he would be my commander in the

9 coming period too.

10 May I proceed now?

11 Q. If you could also tell us the ethnicity of Mr. Mesud Hasotic and

12 Ibro while continuing.

13 A. Mr. Mesud Hasotic is a Muslim. He still lives in Banja Luka.

14 And Colonel Ibro, as I've already said I cannot remember his last name,

15 he is also a Muslim, but I don't know where he hails from and where he

16 lives right now.

17 Q. And have you completed your description of how they described

18 General Mladic to you as you later found to be proven right?

19 A. Well, naturally. The first time I met General Mladic, that was

20 the day of the assembly when the Army of Republika Srpska was

21 established, when the Main Staff was established, the Main Staff of the

22 Army of Republika Srpska, and when he was appointed commander of that

23 staff. I met him in front of the hall and at first sight all of this was

24 confirmed and a lot more than that; namely, he that is very resolute,

25 energetic, and above all he showed this decisiveness and this fairness by

Page 29490

1 his own example. I was really inspired by that. And later on we would

2 see each other as we carried out our tasks, either when I went to report

3 to him in the Main Staff or he would come to me command. We did such a

4 lot of work together. And never, really, he never disappointed me. I

5 had great confidence in him. We did so many things together and I saw

6 that he had confidence in me too and that he appreciated what I did as

7 well.

8 Q. Colonel, sir, on behalf of General Mladic and the rest of the

9 Defence team, I thank you for answering my questions today.

10 MR. IVETIC: Your Honours, that completes the direct examination

11 and I see we're -- I thank the translators for the indulgence of the

12 extra five minutes.

13 JUDGE ORIE: Yes, thank you, Mr. Ivetic.

14 Mr. Traldi.

15 MR. TRALDI: I recognise the time. I have one question for the

16 Defence for the record before --

17 JUDGE ORIE: Do we need the witness for that?

18 MR. TRALDI: We don't need the witness, Your Honour.

19 JUDGE ORIE: So then we would first -- I would have one question

20 for you, Witness.

21 You told us about your role in the -- to provide food and all

22 kind of facilities for the Manjaca prisoners of war camp. Could you tell

23 us exactly until when you performed that duty? I mean, on -- when did

24 that stop.

25 THE WITNESS: [Interpretation] In my statement, Mr. President of

Page 29491

1 the Trial Chamber, it says exactly the 14th of February, 1993, when I

2 took over another duty. It was 1993. It was 1993. Yes, sorry. And

3 then Colonel Bulic took over from me. And this was after the Serbian new

4 year.

5 It's written in the statement. I don't like to guess as far as

6 dates are concerned. I am afraid that I may make a mistake and then it

7 may turn out to be on purpose when it's not, and you really have it in

8 the statement and --

9 JUDGE ORIE: Witness.

10 Mr. Ivetic, could you help me exactly where if I find it? And I

11 don't know whether it's phrased in a similar way as I asked or whether I

12 should conclude that from other information.

13 MR. IVETIC: The 14th of February 1993 date is in paragraph 2 of

14 the statement, Your Honours.

15 JUDGE ORIE: Paragraph 2. Let me just have a look.

16 MR. IVETIC: When he was appointed assistant commander for

17 logistics on 14th February 1993.

18 In relation to --

19 JUDGE ORIE: Yes, I now understand that I have to understand that

20 change in position as the point in time.

21 Are -- you are saying that when you were appointed assistant

22 commander for logistics, which was on the 14th of February, 1993, that

23 your duties in relation to providing food -- well, whatever, to Manjaca

24 ended.

25 Then one more question. Did your successor take over that

Page 29495

1 JUDGE ORIE: Yes. Having clarified this, Mr. Traldi, are you

2 ready to cross-examine the witness?

3 MR. TRALDI: Yes, Mr. President.

4 JUDGE ORIE: To the extent not limited by what we discussed

5 earlier.

6 Witness, you'll now be cross-examined by Mr. Traldi. You'll find

7 Mr. Traldi to your right. Mr. Traldi is counsel for the Prosecution.

8 And may I ask you to very much focus on the question. If there's

9 anything to be added wait for follow-up questions, and if at the very end

10 something needs to be added you will have an opportunity to do so. But

11 start by answering the questions.

12 Please proceed.

13 Cross-examination by Mr. Traldi:

14 Q. Good morning, sir. Can you hear me in a language you understand?

15 A. Good morning. I can hear you very well.

16 Q. Sir, I want to start with some questions about the structure of

17 the 1st Krajina Corps. You say in paragraph 10 of your statement, now

18 Exhibit D847, and I'm providing the reference for the record, I have a

19 very simply question. You say that primary command post was in

20 Banja Luka. Where was that?

21 A. We call that the primary command post. It is in building of the

22 former command, otherwise in the centre of the town of Banja Luka.

23 Whoever is familiar with that area will know that we did not change that.

24 And then depending on operations and tasks, this was in the function of

25 the forward command post too.

Page 29496

1 Q. Sir, at this point and I'd ask you to focus very closely on the

2 question. I'd asked you only about the primary command post, or what you

3 describe as the primary command post. When you say "it is in the

4 building of the former command," you're referring to the former command

5 of the 5th Corps of the JNA; right?

6 A. That's right.

7 Q. What was that building called?

8 A. I don't understand that question.

9 Q. I'll move on then. You mention a forward command post was

10 established in Prnjavor in your statement. That forward command post was

11 established in the middle of June 1992; right?

12 A. Yes, that's right. Further on, from June onwards it was in

13 Prnjavor, the forward command post.

14 Q. You mention in paragraph 10 of D847 that the commander and the

15 Chief of Staff of the 1st Krajina Corps were at that forward command post

16 in Prnjavor. That refers to General Momir Talic and General

17 Bosko Kelecevic; right?

18 A. That's right.

19 Q. Now, even during the period when they were based in Prnjavor,

20 General Talic and General Kelecevic would sometimes come back to

21 Banja Luka for meetings or to carry out command responsibilities;

22 correct?

23 A. It's not a rule, but most often reporting would take place where

24 they were, and they would come, in connection with important tasks and

25 activities, to Banja Luka for these meetings.

Page 29497

1 Q. When they came to Banja Luka, would they ever come to the

2 Kozara barracks?

3 A. I find that question to be unclear, not defined.

4 Q. When General Talic and General Kelecevic came to Banja Luka

5 during the period of the war, would they ever visit the Kozara barracks?

6 A. Well, that's what I asked to be defined. They could go there on

7 a task because there were units there that were subordinated. And the

8 buildings where these units were, if necessary they could visit, but I

9 cannot say how often and when. At any rate, they came to the building of

10 the command where I was too because of their own business that they had

11 to carry out and --

12 JUDGE ORIE: Witness, the simple question was whether they ever

13 went to that barracks when visiting. I do understand from your answer

14 that they did.

15 Yes, that would have been the simple answer.

16 Please proceed, Mr. Traldi.

17 MR. TRALDI:

18 Q. You mentioned they also visited the building that you were based

19 in. What building was that?

20 A. Precisely this building of the command of the 5th Corps. I don't

21 see what you're asking me. You're asking me for a name, and I don't know

22 what the name of that might have been.

23 JUDGE MOLOTO: You know the street address of this building?

24 THE WITNESS: [Interpretation] Well, the street next to it is

25 called Prvi Krajiski Korpus, and it is perpendicular to this street, this

Page 29498

1 lane, of the former JNA. Well, I never received mail on that address, so

2 I cannot say on the basis of this postal address. I received mail at the

3 military post code and I was there for ten years and even more, and now I

4 cannot tell you the address just --

5 JUDGE MOLOTO: Thank you, sir. Thank you, sir. Thank you. You

6 don't know the street address.

7 Thank you, Mr. Traldi.

8 MR. TRALDI: Thank you, Your Honour.

9 Q. You were based in this building as chief of the quartermaster

10 service. Was the logistics organ of the 1st Krajina Corps based in this

11 building?

12 A. Yes. Your Honours, the logistics organ and the command of the

13 logistics base. And some other organs, I mean, that were there, but ...

14 JUDGE ORIE: Witness, you've answered the question.

15 Please proceed, Mr. Traldi.

16 MR. TRALDI:

17 Q. So Colonel Tepsic was also based in this building at the

18 beginning of the war; right?

19 A. Yes.

20 Q. You mentioned the commands of the logistics base. Colonel Selak

21 was also based in this building at the beginning the war then; right?

22 A. Yes.

23 Q. And after he left in July, Colonel Skondric would have been based

24 in the same building as you?

25 A. Correct.

Page 29499

1 Q. Were any of the other organs of the 1st Krajina Corps command

2 based in that building? And I'm referring specifically to the security

3 and intelligence organ, the legal morale and religious affairs organ, the

4 civilian affairs organ, or any other organs you may want to discuss.

5 A. Except for those that were the forward command post, all of those

6 who were from the command of the 1st Corps were there.

7 Q. You mentioned it's on Prvi Krajiski Korpus Street. That's

8 1st Krajina Corps Street; right?

9 A. Now it is called that. I mean, the street that is on the western

10 side. That one is what I know for sure. But as for the rest that you

11 ask me about, I cannot say that with certainty because I don't know

12 street names.

13 Q. Do you recall what street was called before the war?

14 A. Well, now you're asking me something that I cannot remember, yet

15 again.

16 Q. I'm going to turn now to your responsibilities as chief of the

17 quartermaster service in the 1st Krajina Corps. From whom would you

18 directly receive your tasks when you were chief of the quartermaster

19 service?

20 A. From a disciplinary and organisational point of view, from

21 Colonel Tepsic, the assistant commander for logistics.

22 Q. Did General Talic ever task you directly or were you always

23 tasked through Colonel Tepsic?

24 A. Almost always and always through my immediate superior who was

25 his assistant commander, Colonel Tepsic.

Page 29500

1 Q. To whom would you report on your work?

2 JUDGE ORIE: Mr. Traldi, could you please seek clarification of

3 "almost always and always," which I have some difficulties to understand.

4 MR. TRALDI:

5 Q. Sir, did you mean to say you were always tasked through

6 Colonel Tepsic, your immediate superior, or almost always tasked but

7 sometimes tasked directly by other people?

8 A. Only Colonel Tepsic. But I wouldn't be surprised if I were to

9 find a document here that had to do with my professional line of work

10 containing an order that was issued by my second superior officer.

11 Although, I cannot say Karic. It would be Tepsic always.

12 Q. Would you also report on your work to Colonel Tepsic?

13 A. Yes.

14 Q. He received his taskings and reported on his work from

15 General Talic, the corps commander; right?

16 A. Correct.

17 Q. Aside from the quartermaster service, the logistics service also

18 had a technical service; right?

19 A. Right.

20 Q. In the beginning of May 1992, the chief of the technical service

21 was Colonel Muharem Talic; right?

22 A. Wait a minute. Muharem Talic? I don't think that would be the

23 last name. Check that.

24 Q. Do you recall the gentleman's last name?

25 A. Well, I cannot recall. But I don't think that it's the same last

Page 29501

1 name as my commander.

2 MR. TRALDI: Well, let's have 65 ter 16612, please, and we can

3 check my notes.

4 Q. While it comes up, in June 1992, the chief of the technical

5 service became Lieutenant-Colonel Dragoljub Jankovic; right?

6 A. I see the signature here. Correct.

7 Q. And this is the note handing over duty or reflecting the

8 hand-over of duty from Colonel Muharem Talic to

9 Lieutenant-Colonel Jankovic; right?

10 A. I allow for the possibility that I was wrong when I said what I

11 said. I really don't remember that that was his last name. We

12 communicated on a first-name basis and that is how we addressed each

13 other.

14 Q. This gentleman you called Muharem, what was his ethnicity.

15 A. Muslim.

16 Q. And Colonel Dragoljub Jankovic was a Serb; right?

17 A. Correct. He had a mixed marriage.

18 MR. TRALDI: Your Honours, I tender 65 ter 16612.

19 MR. IVETIC: No objection.

20 JUDGE ORIE: Madam Registrar.

21 THE REGISTRAR: Document 16612 receives exhibit number P6986,

22 Your Honours.

23 JUDGE ORIE: Admitted into evidence.

24 MR. TRALDI:

25 Q. Now --

Page 29502

1 MR. TRALDI: And I'm done with this document.

2 Q. In 1993 when you became assistant commander for logistics, you

3 would then receive your tasks from General Talic; right?

4 A. I was his assistant commander, and I received my tasks from him.

5 Q. And you would report on your work to him; right?

6 A. I to him, and the chiefs to me.

7 JUDGE MOLOTO: This is Muharem Talic?

8 MR. TRALDI: This is -- just for clarity, I'm referring to

9 General Momir Talic, the corps commander.

10 Q. Was that how you understood me, sir?

11 A. Yes.

12 Q. When you were assistant commander for logistics, you would

13 receive information about upcoming operations from the corps commander,

14 General Talic; right?

15 A. At the collegium and with the commander, we always examined such

16 information.

17 Q. And based on the information you received, you would assess

18 logistical needs of the units which would be carrying those operations

19 out; right?

20 A. That's right. On the basis of their reports and requests, we

21 would not assess that. We would have cumulatively the needs of all, and

22 then we would apply ourselves to the meeting of these needs.

23 Q. You'd do that by assigning subordinate logistical units to fill

24 those needs; right?

25 A. I did not assign them within my --

Page 29503

1 THE INTERPRETER: Interpreter's note: Could the witness please

2 repeat the answer. Come closer to the microphone and speak distinctly.

3 Thank you.

4 JUDGE ORIE: Witness you're invited to come a bit closer to the

5 microphone to repeat your answer.

6 You started by saying, I did not assign them within ... and could

7 you then repeat from what you said?

8 THE WITNESS: [Interpretation] The gentleman asked me whether I

9 gave assignments to someone. The 14th Logistics Base was the mainstay of

10 my activity, and I would submit my needs to them for realisation.

11 MR. TRALDI:

12 Q. And I'm going to look at just one example, sir.

13 MR. TRALDI: Can we have 65 ter 18346.

14 Q. And this is coming from the 5th Corps, it's dated the 9th of May,

15 1992, signed by your superior Colonel Tepsic. So it's before the

16 transformation.

17 A. Yes.

18 Q. We read here:

19 "On the basis of demonstrated need, and with the goal of raising

20 the level of combat readiness of the Territorial Defence units, pursuant

21 to a verbal order by the commander of the 5th Corps."

22 And then we see that Colonel Tepsic is ordering the distribution

23 to the Kotor Varos Municipal Territorial Defence Staff of a number of

24 weapons and other supplies.

25 This is how the provision of logistical resources to subordinated

Page 29504

1 forces is supposed to work as a standard matter in the JNA and the VRS;

2 right?

3 A. It's not the best example, but in principle this is one of the

4 examples.

5 MR. TRALDI: Your Honours, I tender this document.

6 JUDGE ORIE: Madam Registrar.

7 THE REGISTRAR: Document 18346 receives exhibit number P6987,

8 Your Honours.

9 JUDGE ORIE: P6987 is admitted.

10 MR. TRALDI:

11 Q. I'm going to turn now to the meetings of the corps commander that

12 you mention in your statement. You refer to a regular meeting at 0715

13 hours in the morning. Where was that meeting held, as of May 1992?

14 A. I have to answer you by saying that I don't know. From May 1992

15 onwards, I was not in that role, and I did not take part in the role of

16 my superior.

17 Q. So you began attending that meeting in February 1993; right? The

18 commanders' morning meeting.

19 A. That goes without saying.

20 Q. Did the assistant commanders of security and intelligence, legal,

21 morale, and religious affairs, and civilian affairs also attend the

22 commanders' morning meeting at that time?

23 A. In principle they did, and they were supposed to be there. If

24 you are mentioning what happened before my take-over of duty, I don't

25 know, but afterwards they did.

Page 29505

1 Q. And at that point, the assistant commander for civilian affairs

2 was Gojko Vujinovic; right?

3 A. That's right.

4 Q. The assistant commander for security and intelligence was

5 Colonel Bogojevic; right?

6 A. Bogojevic Stevan, that's right.

7 Q. And the assistant commander for legal, morale, religious affairs

8 was Milutin Vukelic; right?

9 A. That's right.

10 JUDGE FLUEGGE: Mr. Traldi, I'm not sure if all names are

11 correctly recorded.

12 MR. TRALDI: One has just been corrected.

13 Q. Colonel Bogojevic's last name, that's spelled B-o-g-o-j-e-v-i-c;

14 correct, sir?

15 A. Yes. Are you asking me? Yes. As far as I know his name is

16 Stevan, exactly.

17 Q. General Talic ran these meetings; right?

18 A. It was always the corps commander. In his absence when he was

19 prevented from attending, it would be the Chief of Staff.

20 Q. And that was General Kelecevic?

21 A. Correct.

22 Q. Would he also attend the meetings even when General Talic was

23 there and running them?

24 A. Yes, correct.

25 Q. And General Talic, or General Kelecevic if he was replacing him,

Page 29506

1 could hand out tasks at these meetings; right?

2 A. In principle, that would be correct. Because that was briefing.

3 Issues were discussed and tasks were handed out.

4 Q. When you say "issues were discussed," would the different sectors

5 report on the work they'd been doing?

6 A. Every chief of sector submitted a report on the work of his

7 sector.

8 Q. Now, I'm going to shift now to a different type of meeting. You

9 mentioned a moment ago a group called the corps commanders' collegium

10 that I understand met weekly. Aside from the chiefs of sector that you

11 mentioned a moment ago, who else would attend these meetings?

12 A. In principle, it was an inner circle: The commander, the Chief

13 of Staff, and his assistants.

14 Q. Did the head of the 14th Logistics Base also attend these

15 meetings.

16 A. First of all, he was not the commander of the 14th Logistics Base

17 and he was not a member of the 1st or the 5th Corps. He was never

18 duty-bound do attend those meetings, nor he did. The commander could

19 have invited him when he considered some common issues or when he had the

20 time to give him.

21 MR. TRALDI: Well, could we have paragraph 66 of D847 for the

22 witness.

23 JUDGE ORIE: Witness, when you said he was not the commander, who

24 did you have on your mind?

25 THE WITNESS: [Interpretation] You did not understand me. He was

Page 29507

1 the commander of the 14th Logistics Base but he was not an organic member

2 of the corps. He was subordinated to his superior command as the --

3 THE INTERPRETER: Could the witness slow down, please.

4 JUDGE ORIE: Witness, first of all, you're invited to slow down.

5 But it's still not clear to me whether he was or was not. But who did

6 you have on your mind when you said, as you now clarified, was the

7 commander of the 14th Logistics Base?

8 THE WITNESS: [Interpretation] He was the commander of the 14th

9 Logistics Base.

10 JUDGE ORIE: Who is "he"?

11 THE WITNESS: [Interpretation] Osman Selak.

12 JUDGE ORIE: Thank you.

13 Please proceed.

14 MR. TRALDI:

15 Q. Now, in paragraph 66 of your statement here, and can you see it

16 on the screen, you say:

17 "As the commander of the base, he was obliged to attend the

18 weekly meetings of the corps commander's collegium... "

19 That's the statement that you reviewed, made corrections to, and

20 swore was truthful. Do you stand by what you've said here in

21 paragraph 66 of your statement?

22 A. This is a misinterpretation. He could attend. He should have

23 attended once a week. But not at the time when the commander discussed

24 issues with his immediate subordinates.

25 Q. Sir, I'm going to stop you.

Page 29508

1 A. He could have invited him at any other moment --

2 Q. I asked you would the commander of the logistics base attend the

3 collegium. You said back at transcript page 41, line 15, he was never

4 duty-bound to attend those meetings. You say, in paragraph 66, the

5 commander of the logistics base was obliged to attend the weekly

6 meetings.

7 So I'm not asking you about what issues were discussed at what

8 time. I am asking you now, having said in your statement that the

9 commander of the logistics base was obliged to attend and then said in

10 your testimony that he was not, which of those answers you stand by,

11 whether the commander of the logistics base was or was not obliged to

12 attend the weekly meeting of the corps commander's collegium.

13 A. When it comes to the collegium meetings, they were chaired by the

14 commander. The questions and issues that he dealt with together with the

15 commander of the logistics base, he found time with the collegium or

16 without the collegium in the way and according to the nature of the tasks

17 that he had to deal with.

18 JUDGE ORIE: Witness, in your statement, to which you attested,

19 you say that the commander of the base was obliged to attend these

20 meetings. Today in your testimony, you told us that he was not obliged.

21 Which of the two is your evidence now today, which of the two is true?

22 THE WITNESS: [Interpretation] When the commander invited those

23 who were not on the collegium, they had to attend. They did not have to

24 attend all the collegium meetings organised by the commander.

25 JUDGE ORIE: So he was only obliged to attend when invited but

Page 29509

1 not as a routine.

2 THE WITNESS: [Interpretation] Of course. And only for those

3 issues that had to be dealt with together with him.

4 JUDGE ORIE: Please proceed, Mr. Traldi.

5 MR. TRALDI:

6 Q. Now, you wouldn't know -- let me actually re-start that question.

7 Did you attend in May and June 1992 the weekly meetings of the corps

8 commander's collegium?

9 A. No, not in May and June 1992.

10 Q. Now, while we're on this area of your statement, you mention in

11 paragraph 65 that prior to the formation of the VRS and --

12 MR. TRALDI: Actually, sorry, paragraph 64.

13 Q. That prior to the formation of the VRS, Colonel Selak would go to

14 Belgrade to brief General Vladan Sljivic, the commander of logistics of

15 the JNA, and his superior. After the VRS was established, Colonel Selak,

16 and then Colonel Skondric who succeeded him, would similarly brief

17 General Djordje Djukic as to the functioning of the 14th Logistics Base

18 in the VRS; right?

19 A. You were mistaken when you read that he was subordinated to the

20 JNA. When he went for briefings in Belgrade with General Sljivic, it is

21 true that when he was commander of the 993rd Logistics Base he was

22 directly subordinated to the assistant commander for logistics, and then

23 when the 14th Logistics Base was set up it was part of the Army of

24 Republika Srpska, and it is understood that as a commander he was

25 duty-bound to report to the assistant commander for logistics of the

Page 29510

1 Main Staff of the Army of Republika Srpska.

2 Q. Now, I'm going to turn now to the supplies available to the

3 1st Krajina Corps.

4 MR. TRALDI: Could we have 65 ter 09168.

5 Q. As it comes up, Colonel Selak was a Muslim and Colonel Skondric

6 who succeeded him was a Serb; right?

7 A. Correct.

8 Q. And you mentioned Colonel Hasotic a moment ago. He was succeeded

9 by Colonel Vukelic. Colonel Hasotic was a Muslim and Colonel Vukelic was

10 a Serb; right?

11 A. What you're asking me, I believe that that was the case but I'm

12 not sure. But that -- because that happened while I was absent. I know

13 about Hasotic and his duties in the 5th Corps, but I'm not sure what to

14 say about what you are claiming. I believe that that was the case.

15 Vukelic came later.

16 Q. In fact, Vukelic came right around the time that the 5th Corps

17 transitioned to the 1st Krajina Corps; right?

18 A. If that's on the record, which I'm not sure of, then I believe

19 that that was the case.

20 Q. Okay. I'll leave that topic and turn to this document. Now, we

21 see here a report from the 1st Krajina Corps to the Main Staff dated the

22 9th of October, 1992, reporting on the consumption of material in the

23 1st Krajina Corps between May and the beginning of October, 1992. Now

24 directing your attention to the second point, we see total usage of

25 ammunition, and we see immediately below that the 1st Krajina Corps had

Page 29511

1 used about 3.350.000 from 7.62-millimetre automatic pistols during that

2 period; right?

3 A. That's what it says. But obviously this is for automatic rifles,

4 7.62. I can't read anything else. I can't interpret it differently.

5 Q. Well, shortly below that we see a note that almost 24 million

6 rounds were used from a 7.62-millimetre automatic rifle; right?

7 A. I've not seen this before. I see it only now, yes.

8 Q. Turning to page 2 in the English and at the very bottom of page 1

9 in the B/C/S, under support ammunition, we see about 175.000 total mortar

10 shells denoted with MB have been used by the 1st Krajina Corps during

11 this period; right?

12 A. I can't find that. Please guide me to that part. I don't have

13 the second page. I apologise. Mortars 82, is that what you said?

14 Q. It's the bottom of the first page in the B/C/S. And let's take

15 it step by step. I was adding the three numbers together, but we see --

16 A. Yes, I can tell you were adding things.

17 Q. We see about 77.000 60-millimetre mortars have been used, about

18 93.000 82-millimetre mortars, and just over 10.000 120-millimetre

19 mortars; right?

20 A. That's right.

21 Q. And now turning to page 3 in the B/C/S, staying on page 2 in the

22 English. In the middle of the page in the B/C/S we see, combining the

23 two different types of rockets, that about 1800 rockets have been fired

24 during this period; right? By the 1st Krajina Corps.

25 A. Your calculation is good, yes.

Page 29512

1 MR. TRALDI: Your Honours, I tender this document.

2 JUDGE ORIE: Madam Registrar.

3 THE WITNESS: [Interpretation] Please, can I see the whole of the

4 document? Can I see the signature as well? Show me the entire document

5 including the signature.

6 MR. TRALDI:

7 Q. Sir, there will be times when it's necessary to direct your

8 attention but this is a pretty brief document.

9 MR. TRALDI: So if we could turn to the last page in both

10 languages.

11 THE WITNESS: [Interpretation] So what do I need to do? What am I

12 supposed to do here.

13 MR. TRALDI:

14 Q. Here I'm simply showing you this is signed by Colonel Jankovic,

15 the chief of the technical service; right?

16 A. Thank you. This is what I needed, yes.

17 JUDGE ORIE: Madam Registrar.

18 THE REGISTRAR: Document number 09168 receives exhibit number

19 P6988, Your Honours.

20 JUDGE ORIE: Admitted into evidence.

21 Mr. Traldi, may I take it where the witness apparently says that

22 he sees this document for the first time that -- I mean, for him to

23 confirm that a document reads what it reads, we don't need a witness for

24 that. This Chamber can read itself. Unless there's any follow-up which

25 links the witness -- and you have not asked him whether this might be

Page 29513

1 accurate numbers or not. You didn't ask anything apart from is this what

2 the document reads.

3 MR. TRALDI: Well, I have just one more question about it,

4 Mr. President.

5 JUDGE ORIE: Then we'll wait for that.

6 MR. TRALDI:

7 Q. In your statement, you emphasise the logistical difficulties

8 facing the 1st Krajina Corps. It's clear from Colonel Jankovic's report

9 that during this period, the summer of 1992, the 1st Krajina Corps had

10 sufficient resources to use these millions of rounds of ammunition;

11 right?

12 A. Your question is quite ambiguous and I have to answer. As far as

13 I'm concerned, I've not seen this document before. The chief of service,

14 Jankovic, was in charge, and my superior was Tepsic. You said a lot or a

15 sufficient ammunition, how intensive the fighting was, during what

16 period. Your question and the answer about excessive quantity, always

17 relative.

18 Q. Let me rephrase it very precisely. It's clear from this document

19 that the 1st Krajina Corps had millions of rounds of ammunition,

20 thousands, tens of thousands of mortars, almost 2.000 rockets. It's

21 clear from this document that they had all that because Colonel Jankovic

22 is reporting that they used all of that in this period between May and

23 September; right?

24 A. Excellent. It is possible for the period from May to September.

25 It's a long period.

Page 29514

1 Q. Now, I want to talk about how the logistics sector arranged for

2 logistical supplies now. You discuss the importance of opening the

3 corridor in your statement. One thing opening the corridor allowed the

4 VRS to do was transport material and equipment from Belgrade to

5 Banja Luka; right?

6 A. You're confusing me once again. The line of procurement before

7 the corridor was closed was normal in that way. When the Army of

8 Republika Srpska was established and when the structures were

9 established, the 14th Logistics Base were in charge, and all the

10 requirements by units of the 1st Krajina Corps were reported to the

11 logistics base and then via the Main Staff. It used resources and

12 reserves from the SRJ, i.e., the Federal Republic of Yugoslavia. If this

13 is not a complete answer, go on. Tell me what else I need to tell you.

14 Q. That's exactly what I was asking, sir. I'm going to look briefly

15 at one example.

16 MR. TRALDI: Could we have 65 ter 08385.

17 THE WITNESS: [Interpretation] Yes. And your question is what?

18 MR. TRALDI:

19 Q. Well, first, we see there's a request to you dated the 14th of

20 April, 1994. And we can see at the bottom it's coming from Novak Stanic.

21 Do you recall his position at that time.

22 A. I'll tell you quite precisely. This document was issued by the

23 OG Doboj. It's a regular request for resources. Stanic was a member of

24 the logistics organ of the OG Doboj, I don't know what his duty was, and

25 he submitted a legal request to the corps command with his requirements

Page 29515

1 since during that time, as it seems, he could not --

2 JUDGE ORIE: Witness, the only thing --

3 THE WITNESS: [Interpretation] Excellent, excellent. Go on. I'm

4 listening.

5 JUDGE ORIE: The only thing you were asked is what the position

6 of Mr. Stanic was at that time. Nothing more. Could you answer that

7 question.

8 THE WITNESS: [Interpretation] I can't see it here, Judge. But I

9 really believe that he was a member of the logistics sector because he

10 sent me such documents as well.

11 MR. TRALDI:

12 Q. When you say the logistics sector, you're saying he was a member

13 of the logistics sector of Operational Group Doboj; right?

14 A. Correct.

15 Q. That was a formation subordinated to the 1st Krajina Corps at the

16 time; right?

17 A. Correct.

18 Q. Now, we see at the bottom of the page in the B/C/S and on the

19 second page in English that he's received information from military post

20 1089-18 in Belgrade that:

21 "We can take over the said spare parts and ammunition only with

22 approval of the VRS Main Staff ..."

23 I have two questions for you about this language specifically?

24 First: It's correct that requests for logistic assistance to the

25 FRY had to be routed through the VRS Main Staff; right?

Page 29516

1 A. There's no doubt about that. That's correct. Go on. The next

2 question?

3 Q. And he's sending it to you as his superior to send it up the

4 chain and get the necessary approvals; right?

5 A. Correct.

6 MR. TRALDI: Your Honours, I tender this document.

7 JUDGE ORIE: Madam Registrar.

8 THE REGISTRAR: My excuses. Document 08385 receives exhibit

9 number P6989, Your Honours.

10 JUDGE ORIE: Admitted.

11 MR. TRALDI: Can 65 ter 31725 be brought to the screen.

12 THE WITNESS: [Interpretation] Mr. President of the Trial Chamber,

13 can I put a question about the previous document, please.

14 JUDGE ORIE: No. You're not in a position to ask questions.

15 THE WITNESS: [Interpretation] Very well.

16 JUDGE ORIE: Please proceed, Mr. Traldi.

17 MR. TRALDI:

18 Q. We see here a request dated 20 July 1993 to the military

19 accounting centre in Belgrade, submitting data for active military

20 personnel entitled to an increase in NTS. So my first question for you:

21 What does NTS stand for?

22 A. Let me find it, NT ... a compensation for service, I suppose.

23 Q. And turning to page 2 in both languages.

24 A. I will be happy to see it.

25 Q. We see you signed this request; right?

Page 29517

1 A. Correct. Pursuant to rules and pursuant to the request, I

2 forward this request to my superior, yes.

3 Q. And you're sending it to the military accounting centre in

4 Belgrade because these soldiers in the VRS were being paid by the VJ;

5 right?

6 A. That's correct. That's what the title says. That's how things

7 were done. And this is correct.

8 Q. You yourself were also being paid by the VJ; right?

9 A. Yes, correct.

10 Q. So were General Talic and Colonel Kelecevic?

11 A. Yes, this is correct. It's implied.

12 MR. TRALDI: Your Honours, I tender this document.

13 JUDGE ORIE: Before deciding on it, could the witness tell us

14 what AVL stands for?

15 THE WITNESS: [Interpretation] Active Duty Serviceman.

16 JUDGE ORIE: Thank you.

17 Madam Registrar.

18 THE REGISTRAR: Document number 31725 receives exhibit number

19 P6990, Your Honours.

20 JUDGE ORIE: Admitted.

21 JUDGE FLUEGGE: And to clarify another abbreviation, at the end

22 of the document in the last paragraph, you see "the compensation of the

23 above listed AVS." What is that?

24 THE WITNESS: [Interpretation] Active service. Active military

25 service. That should be it.

Page 29518

1 JUDGE FLUEGGE: Thank you.

2 MR. TRALDI: Can 65 ter 31684 be brought to the screen.

3 Q. And as it comes up, sir, in paragraph 60 of your statement, D847,

4 you mention the destruction of the Ferhadija mosque in Banja Luka. That

5 was not the only mosque destroyed in Banja Luka during the war, was it?

6 A. I learned that it was not the only one. However, I can't tell

7 you how many such facilities were destroyed. I am not in a position to

8 know that, so I can't say anything for a fact.

9 Q. Well, this is a report that you sent to the Main Staff of the VRS

10 and the forward command post of the 1st Krajina Corps on the 7th of May,

11 1993, and it reflects that two other mosques, the Arnaudija mosque and

12 the mosque in Gornji Seher, were destroyed at about the same time as the

13 Ferhadija mosque; right?

14 A. I can see that.

15 Q. Now, in fact, the Chamber has received evidence that there were

16 16 mosques in Banja Luka before the war, and none of them survived the

17 war undamaged. That's true, isn't it?

18 A. I can't say that. I don't know. I just told you that. I don't

19 know if any survived and how badly damaged the others were. However,

20 what you -- you -- we see before us, I signed this document -- can I say

21 something else, please?

22 JUDGE ORIE: Please limit yourself to answering the question.

23 THE WITNESS: [Interpretation] I am -- I signed this as the leader

24 of the duty team based on a report that I received from the field. I

25 only saw that now. I didn't realise that that was the case.

Page 29519

1 MR. TRALDI: Your Honours, I note it's time for the break. I'd

2 tender this document as the next public Prosecution Exhibit.

3 JUDGE ORIE: Madam Registrar.

4 THE REGISTRAR: Document 31684 receives exhibit number P6991,

5 Your Honours.

6 JUDGE ORIE: And is admitted into evidence.

7 Mr. Amidzic, we take a break. We'd like to see you back in 20

8 minutes.

9 [The witness stands down]

10 JUDGE ORIE: We resume at 20 minutes past 12.00.

11 --- Recess taken at 12.00 p.m.

12 --- On resuming at 12.21 p.m.

13 MR. IVETIC: Your Honours while we're waiting for the witness, I

14 can provide some additional information in relation to the inquiry by

15 Mr. Traldi.

16 First of all, the Krajisnik transcript of 25 May 2005, which also

17 is not in evidence in our proceedings, was given to the witness in the

18 B/C/S language.

19 In relation to the paragraphs that Mr. Traldi asked about

20 paragraphs 64 through 71, I can report as follows. In relation to

21 paragraph 66 of the Amidzic statement, I would refer to P244,

22 paragraph 48. In relation to paragraph 65 of the Amidzic statement, I

23 would refer to P244, paragraphs 53, 60, 54. In relation to paragraph 70

24 of the Amidzic statement, I would refer to P244, paragraphs 65 and 83.

25 And in relation to paragraph 71 of the Amidzic statement, I would refer

Page 29520

1 to P244, paragraph 52. And P244 being, of course, the statement of

2 Mr. Selak which was introduced in evidence in our proceedings.

3 And I'm still working on the remaining inquiries that

4 Your Honours had asked about.

5 JUDGE ORIE: Thank you for that, Mr. Ivetic, for that quick

6 response.

7 [The witness takes the stand]

8 Mr. Traldi, if you're ready, you may continue.

9 MR. TRALDI: Yes. And our thanks to Mr. Ivetic as well, of

10 course.

11 Q. Sir, I want to turn now to the military remand prison at

12 Mali Logor which you mention in your statement. Now, you don't mention

13 this in your --

14 JUDGE FLUEGGE: Which paragraph?

15 MR. TRALDI: 42 through 45.

16 JUDGE FLUEGGE: Thank you.

17 MR. TRALDI: Of D847, Your Honour.

18 Q. Now, you don't mention this in those paragraphs, but in 1992

19 non-Serbs were detained there and some were abused; right?

20 A. Please repeat the question, especially the introduction to the

21 question. You did not specify the facility or the prison which you're

22 referring to. I don't know which facility you're talking about.

23 Q. Sir, I did specify but I'm happy to do it again. In 1992

24 non-Serbs were detained in the military remand prison in Mali Logor and

25 some were abused there; right?

Page 29521

1 A. No.

2 MR. TRALDI: Can we have Exhibit P3696. It should not be

3 broadcast but can be addressed in open session.

4 JUDGE ORIE: Mr. Traldi in order to avoid whatever possible

5 confusion, you said -- one second. You said Mali Logor. Is that the

6 same as Mali Novi Logor for you or as it's later said Novi Mali Logor?

7 MR. TRALDI: That's how I understand it, but I'll ask the

8 witness.

9 JUDGE ORIE: Yes.

10 MR. TRALDI:

11 Q. Mali Logor and Mali Novi Logor, those aren't two different

12 facilities, are they?

13 A. Your Honour, the full name of the barracks is Mali and Novi

14 Logor.

15 JUDGE ORIE: And that's one facility?

16 THE WITNESS: [Interpretation] Yes.

17 JUDGE ORIE: Please proceed, Mr. Traldi.

18 MR. TRALDI:

19 Q. So this is daily report from the Manjaca camp operations team to

20 the 1st Krajina Corps command dated the 9th of November, 1992. It refers

21 to processing prisoners of war. Looking at the first paragraph, the

22 second sentence, we read:

23 "There weren't any particularly interesting security intelligence

24 and information that came out from that processing except that it has

25 been noted that prior to arriving to the LRZ, the prisoners have been in

Page 29522

1 prison in Banja Luka where they have been physically abused; they are

2 wearing visible injuries. This is a problem for us because the MKCK

3 delegate from Geneva has access to all such cases and we are then blamed

4 for committing such acts. Please, take measures through the competent

5 organs that during their stay in the VIZ," and that's military remand

6 prison as I understand it, "or other prison in Banja Luka prisoners are

7 not maltreated, i.e., are not physically abused if that would result in

8 virtual injuries."

9 So my question to you is just was this information that prisoners

10 at Manjaca had been abused in Banja Luka in Mali Logor beforehand

11 something you were aware of before your testimony here today?

12 A. Your Honours, the report that I have before me, I've not seen it

13 before. From the Manjaca camp, it was sent by the security organ to his

14 superior in the 1st Corps command. This kind of information is not

15 broadcast. It is sent only to the security organ who then sends it to

16 his own superior.

17 JUDGE ORIE: Witness, whatever it is, the question was whether

18 you were aware of this having happened. If you are, please say yes; if

19 you were not aware --

20 THE WITNESS: [Interpretation] No.

21 JUDGE ORIE: Okay. That's an answer --

22 THE WITNESS: [Interpretation] No.

23 JUDGE ORIE: -- to the question.

24 THE WITNESS: [Interpretation] No.

25 JUDGE ORIE: No one blames you for not knowing.

Page 29523

1 THE WITNESS: [Interpretation] I understand.

2 JUDGE ORIE: It's just that we'd like to know.

3 Please proceed, Mr. Traldi.

4 MR. TRALDI:

5 Q. And in the third paragraph here, we see a note about an emergency

6 in the LRZ. That's referring to Manjaca; right?

7 A. Correct.

8 Q. It says a prisoner was wounded because he accidentally came into

9 the minefield where he stepped on a mine which cut off both his legs.

10 There were mines around Manjaca camp; right?

11 A. I assume that on the basis of this report because that is what is

12 written.

13 MR. TRALDI: I'm done with this document.

14 Q. And, sir, I'm going to focus now on Manjaca. As an introductory

15 matter your evidence appears to be, and this is in paragraph 38 of your

16 statement, that Manjaca was closed in the presence of the ICRC in

17 November 1993 [sic]. Now you are referring to the release of over 700

18 prisoners on or about the 14th of November of that year; right?

19 A. I am not referring to 700. I am referring to the disbandment and

20 to the principle of all for all. That is to say, full release.

21 Q. Let me stop you there.

22 A. Full release of POWs from the camp and --

23 Q. What I'm going to put to you, and I'll show you a couple of

24 documents about this in a moment, what I'm putting to you is that you're

25 mistaken that while 700 or so prisoners were released in November, the

Page 29524

1 camp, in fact, was closed in December. That's true; right?

2 A. Please, could you show me where I referred to 700 in my

3 statement?

4 Q. I think perhaps you've misunderstood my question. I'm going to

5 ask again and ask you to focus on it as I'm asking it right now. Sir, it

6 is not true that Manjaca was disbanded in November. In fact, while 700

7 people were released then, Manjaca was only disbanded in December 1992;

8 right?

9 A. I had this information and I used that and I stand by it now.

10 Whether it is correct, you can check. If you have exact information then

11 we have to trust that. I wrote this statement and used the information

12 that I had.

13 MR. TRALDI: Well, just very briefly let's have P3886.

14 Q. This will be a daily combat report from the 1st Krajina Corps

15 dated the 18th of December, 1992, signed by Colonel Jankovic. And it

16 notes at point 3 --

17 A. If you show me the second page, I will see who signed this.

18 Q. Sir, I'm directing your attention at the moment to point 3, and

19 that says:

20 "With the release of 419 prisoners from the Manjaca camp, the

21 camp was disbanded."

22 So this, in December 1992, this is, in fact, when the camp was

23 disbanded; right?

24 A. It sounds that way. This is information from this report, and I

25 believe that that's the way it is.

Page 29525

1 Q. Now, you weren't personally involved in the disbandment, it

2 appears; is that right?

3 A. I wasn't.

4 Q. So when you say it was disbanded in the presence of the

5 Red Cross, the Chamber has received evidence that, in fact, several

6 hundred prisoners were transferred to other camps and hidden from the

7 Red Cross. Were you aware of that?

8 A. I cannot say. I didn't know that and I don't know it now because

9 this is the first I hear of it. You're the first person who has just

10 said this to me.

11 JUDGE FLUEGGE: Mr. Traldi, I have -- I think there is something

12 you should clarify.

13 It is a regular combat report. Under item 2, I see: "No major

14 changes since the last report," and then, "3, with the release of the 419

15 prisoners," and so on.

16 Which period was covered by this report because there is no date

17 when these prisoners were released?

18 MR. TRALDI:

19 Q. Sir, based on your knowledge, how often were these regular combat

20 reports sent from the 1st Krajina Corps to the Main Staff?

21 A. It says here that it's a regular combat report. It was sent on a

22 daily basis.

23 Q. Now, I want to turn to the re-opening of Manjaca camp in 1993.

24 You discuss this in paragraph 49 of your statement, D847.

25 MR. TRALDI: And I'd ask that Exhibit P245 be brought to the

Page 29526

1 screen.

2 While it is, you say, in pertinent part:

3 "I would like to note that they," these members of the HVO who

4 were held in Manjaca in 1993, "did not have the status of war prisoners,

5 nor was Manjaca at that time functioning as a camp for prisoners of war."

6 Is that your evidence?

7 A. Correct.

8 Q. Now, this is an order from General Talic dated the 7th of June,

9 1993. We see it's sent to the assistant commander of logistics of the

10 1st Krajina Corps. On the 7th of June, 1993 that was you; right?

11 A. Yes.

12 Q. This order is titled: "Opening a Camp for Prisoners of War at

13 Manjaca." In point 1, General Talic orders you to:

14 "Prepare an area for HVO prisoners of war at Manjaca ..."

15 In point 2, he designates Colonel Bozidar Popovic camp commander.

16 It's -- it's clear that General Talic considered these people

17 prisoners and considered himself to be ordering you to open a prisoner of

18 war camp; right?

19 A. No, that's not right.

20 Q. When he says "prepare an area for HVO prisoners of war" in point

21 1, he's discussing the people who were held at Manjaca in June of 1993,

22 and he's referring to them as prisoners of war; correct?

23 A. No. Dear gentleman, this is what it says here:

24 "Prepare the premises where POWs had been put up before."

25 That means, Judges, Your Honours, may I continue? It means that

Page 29527

1 the premises were supposed to be prepared so that people who would come

2 in a completely different situation but their stay in these premises

3 should be ensured through the security service until solutions are found,

4 the ones that I spoke to earlier.

5 After an order concerning co-ordination - may I proceed? -

6 everything should be prepared for their evacuation to their units; that

7 is to say, their security service and the POW camps should be prepared

8 for these people. I categorically state that they did not have the

9 status of POWs and the camp was not used for these purposes, and they

10 were not processed either.

11 JUDGE FLUEGGE: Could you please read item 7 of this order. Just

12 read that for us so that we understand what is written there. Read it

13 aloud, please.

14 THE WITNESS: [Interpretation] I see what is it written there

15 but --

16 JUDGE FLUEGGE: Please read aloud what is written there.

17 THE WITNESS: [Interpretation] "Treat the prisoners of war

18 completely in accordance with the provisions of the Geneva Convention."

19 Again, I'm saying they surrendered. They surrender their lives

20 to us and we were duty-bound to --

21 JUDGE FLUEGGE: I'm not asking you to explain your understanding.

22 I just wanted to know, did you just read prisoners of war?

23 THE WITNESS: [Interpretation] What is written.

24 JUDGE FLUEGGE: Prisoners of war?

25 THE WITNESS: [Interpretation] That's what's written.

Page 29528

1 JUDGE FLUEGGE: Thank you.

2 THE WITNESS: [Interpretation] But ...

3 MR. TRALDI: Could we have 65 ter 30196.

4 Q. Now, this is a daily combat report from the 1st Krajina Corps to

5 the Main Staff dated the 8th of June, 1993, the next day.

6 MR. TRALDI: Turning to page 2 in the English but on page 1 in

7 the B/C/S and at the bottom of section 2 in both languages.

8 Q. General Talic reports:

9 "An LRZ has been formed at Manjaca ..."

10 An LRZ is a prisoner of war camp; right?

11 A. That's what we said.

12 Q. He says that camp "... will put up 529 HVO ... and 380 civilians

13 fit for combat, who surrendered to the units of OG Vlasic. They were

14 transferred to the Manjaca LRZ."

15 So it's clear that these 900 or so people were being held in a

16 prisoner of war camp at Manjaca; right?

17 A. That's not right.

18 Q. I'd like to you explain that answer, sir.

19 A. The name is still LRZ but the people there are a completely

20 different category. They were not sent there as POWs and they were not

21 processed, and I see that it is still being called a POW camp, but their

22 function -- I mean, its function at that time was not fully that of a POW

23 camp and members of the HVO were not treated as POWs.

24 Q. The civilians it says deemed fit for combat were ethnic Croats;

25 right?

Page 29529

1 A. These civilians, sir, were within the population that was being

2 saved, together with those who had fled from the Lasva river valley and

3 they, as military-age men, would be sent with members of the HVO in

4 accordance with the aforementioned.

5 Q. I have two questions about that. First, it's correct that they

6 were ethnic Croats; right?

7 A. According to this, and according to my information, that is

8 correct.

9 Q. Second, you say they, as military-age men, would be sent with

10 members of the HVO and were sent with members of the HVO to the prisoner

11 of war camp at Manjaca. It's correct, isn't it, that in 1992, when

12 Manjaca had previously been opened, it also housed a large number of

13 military-age men who were sent there together with fighters but were not

14 themselves fighters; right?

15 A. You have so complicated this question. Let's deal with this

16 element by element.

17 Q. Sure. You said a moment ago, at transcript page -- temporary

18 transcript page 63, lines 16 through 18, that these civilians were sent

19 to Manjaca camp together with members of the HVO.

20 So you made clear military-age men who were civilians were being

21 sent there.

22 My question for you is: In 1992, the same thing happened.

23 Military-age men who were civilians and not fighters were detained at

24 Manjaca in large numbers; right?

25 A. I cannot assert that because I did not have this information.

Page 29530

1 And this category, I mean -- I mean, of POWs, they were brought in by the

2 civilian police as well. And I'm not sure about what you have been

3 claiming and which category this is and when this happened. But what you

4 are claiming is possible. At one point in time the civilian police did

5 bring in able-bodied men, whether they wore civilian clothing or

6 uniforms, I cannot say. And also I cannot say where it was that they had

7 been taken prisoner.

8 JUDGE MOLOTO: Can I ask a few questions, please.

9 Sir, you talked about people of Croat ethnicity surrendering and

10 being kept at Manjaca but not as a military camp.

11 When did this take place when these people surrendered to you?

12 THE WITNESS: [Interpretation] Well, the information I have here

13 is June 1993.

14 JUDGE MOLOTO: 1993. Not 1992.

15 THE WITNESS: [Interpretation] Well, it's written that way.

16 JUDGE MOLOTO: No, I'm asking you from your knowledge, not from

17 what you are reading. You told -- you testified about people

18 surrendering and being kept at Manjaca. When was that?

19 THE WITNESS: [Interpretation] Well, precisely, I'm linking this

20 to the date when I wrote this.

21 JUDGE MOLOTO: And I'm asking you was it June 1992 or 1993?

22 THE WITNESS: [Interpretation] Well, it's written there, 1993.

23 JUDGE MOLOTO: 1993. 1993. Thank you so much.

24 How many times did people surrender to you during June 1993 --

25 surrender to Manjaca during 1993, in June?

Page 29531

1 THE WITNESS: [Interpretation] Judge, sir, this is not -- or

2 rather, this is not surrender but basically salvation for people from

3 threatened areas. They wanted to save their own lives and the lives of

4 their family members. And then for the time being, we put them up on the

5 premises of the former POW camp because we had no other premises. I've

6 already said this, and --

7 JUDGE MOLOTO: thank you so much. Thank you so much. Okay.

8 They voluntarily turned in -- your statement says prior to that they

9 voluntarily turned in their personal weapons and the list of personnel.

10 What did they do? Didn't you say they surrendered? They just came there

11 to ask for refuge, isn't it?

12 THE WITNESS: [Interpretation] Well, precisely, Judge.

13 JUDGE MOLOTO: Thank you.

14 THE WITNESS: [Interpretation] But also they made up their own

15 list and handed over their personal weapons and they were no longer

16 capable. And then they --

17 JUDGE MOLOTO: Thank you. Thank you so much. You've answered my

18 question. I'm asking you these questions because this paragraph that you

19 were referred to where it says prisoners of war, the LRZ, has been formed

20 in Manjaca which will put up 529 HVO and 380 civilians fit for combat.

21 It says these people had surrendered to the units of the OG Vlasic.

22 It looks like are you talking about the same -- this -- these

23 people are the same people that you are referring to in your testimony.

24 THE WITNESS: [Interpretation] Judge, sir, I don't see where the

25 problem is. They were seeking salvation and they came to the line of our

Page 29532

1 forces and they surrendered together with their civilians and families.

2 And they were seeking salvation. Of course that they turned themselves

3 into our hands so that we could take care of them. There wasn't any

4 combat there for them to surrender.

5 JUDGE MOLOTO: Thank you so much.

6 JUDGE FLUEGGE: I just would like to ask you why then, you said

7 on page 64, lines 21 and 22, and I quote:

8 "And I also --" sorry.

9 "And also I cannot say where it was that they had been taken

10 prisoner."

11 This is what you just said a minute ago.

12 THE WITNESS: [Interpretation] Judge, sir, I was speaking of that

13 category that the Prosecutor mentioned, that during 1992 these categories

14 or groups were brought in and they were civilians. I'm speaking about

15 these people. A year before that it was the civilian police that brought

16 them in, and I don't know where they had been taken prisoner and under

17 what circumstances and whether they had been tortured, and I don't know

18 about all the things that happened.

19 JUDGE FLUEGGE: Thank you for that clarification.

20 MR. TRALDI: Your Honours, I'd tendered this document.

21 JUDGE ORIE: Madam Registrar.

22 THE REGISTRAR: Document number 30196 receives exhibit number

23 P6992.

24 JUDGE ORIE: Admitted into evidence.

25 MR. TRALDI:

Page 29533

1 Q. Now I'm going to focus, sir, on events at Manjaca in 1992.

2 In paragraph 37 of your statement, you say:

3 "Moreover, we clearly informed everyone that the conditions we

4 provided were the maximum that we could do and that anything that can be

5 additionally arranged through humanitarian organisations was allowed, and

6 they put it in practice."

7 I think it's clear from your testimony but I'd just ask you to

8 confirm, the 1st Krajina Corps informed people that you believed you were

9 doing all you could because there were complaints about the conditions in

10 Manjaca camp; right?

11 A. You can take it that way too, but I was personally in the

12 presence of all of those who followed me, and when there would be any

13 objections to security - and I said this personally - in terms of

14 improving life and conditions, everything you can, secure that. That

15 will be allowed. Your arrivals. It is sufficient for you to announce

16 yourselves and you will be allowed to come. I don't know of any offers

17 to be made to POW camps that had been refused. That's what we did.

18 Q. Well, let's look at one occasion that you went to Manjaca.

19 MR. TRALDI: Could we have 65 ter 30223, please.

20 Q. This is a daily report from Manjaca camp dated the 18th of June,

21 1992. Directing your attention to page 2 in both languages.

22 A. I don't see the second page.

23 Q. I can say at the bottom of the first page in the B/C/S, it begins

24 discussing a visit to the camp by members of Merhamet. Here at the

25 top --

Page 29534

1 JUDGE ORIE: Could we move back to the first page in B/C/S.

2 You would like the witness to look at --

3 MR. TRALDI: I -- actually, the sentence that I wanted to point

4 him to is right here at the top of page 2.

5 JUDGE ORIE: Yes. And the previous page, the Merhamet is

6 mentioned. The visit of the camp by members of Merhamet.

7 Yes, please.

8 MR. TRALDI:

9 Q. Here at the top of page 2, we read:

10 "From our side, the talks were attended by Colonel Tepsic,"

11 that's your immediate superior, right, at the time?

12 A. Tepsic. Yes.

13 Q. Colonel Amidzic, that's you; right?

14 A. Correct.

15 Q. And Lieutenant-Colonel Andric. What was his position?

16 A. Lieutenant-Colonel Andric, he was -- now I cannot say exactly,

17 but in the logistics base, the quartermaster service for food provisions.

18 Q. Now, below --

19 A. I beg your pardon. Logistics base, yes.

20 Q. Is that the 14th Logistics Base?

21 A. Yes.

22 Q. Now, below that the report describes what the members of Merhamet

23 saw, and I'll get to that in a second. But first, you recall being part

24 of this visit; right?

25 A. I cannot recall a specific visit but this is possible because I

Page 29535

1 went several times. I claim that and I stand by that.

2 Q. Do you recall going with members of Merhamet including

3 Adil Mehic, Esad Bajric, Imam Haljo Halilovic and lawyer Amir Djonlic

4 just a couple of weeks after the camp was opened?

5 A. As for the names of the persons who went to visit, I cannot

6 remember them. Especially consisting of several members, well, that is

7 correct and it's possible that it's the names that you read out.

8 Q. We read here:

9 "The members of Merhamet toured all the pavilions and the field

10 kitchen and saw for themselves what the prisoners' living and working

11 conditions were like. They talked briefly to a group of prisoners who

12 spoke of the problems they and other prisoners had. They spoke of the

13 poor quality of food and living quarters (leaking) and that they were not

14 able to contact their families."

15 You were aware as of mid-June 1992 that prisoners in Manjaca were

16 reporting they were receiving a poor quality of food; right?

17 A. That's why I said what I did. The food was poor for them as well

18 as it was for our fighters. That was all we could give them. But then,

19 I told everybody that everything that could be provided for this category

20 of people should be provided for them, and if you want to bring

21 something, they will be given that. In the field kitchen in the presence

22 of those people whom I can't name or say, that those were the people who

23 were listening to me when I said that.

24 Q. I take it you were aware that they were reporting they were

25 receiving poor quality food. Were you also aware as of mid-June 1992

Page 29536

1 that prisoners in Manjaca were living in quarters that were leaking?

2 A. The information about the roofs leaking, I didn't know then, I

3 don't know it now. I remind you and the Judges that this is a report

4 from the intelligence organ to which was sent along the line of security

5 to the chief of the service in the corps. That's why I did not see the

6 document before.

7 Q. So this is one of the times that you discussed at temporary

8 transcript page 12 today when you said that some of the people who

9 escorted you to Manjaca described differently what they saw there than

10 you did. This time it's the staff of Manjaca camp itself that's

11 describing the conditions differently than you are; right?

12 A. This is in the report that I did not see before. I don't know

13 who they said that to. We saw the same thing. However, we described

14 things differently and we wrote about them differently.

15 MR. TRALDI: Your Honours, I tender 65 ter 30223.

16 JUDGE ORIE: Madam Registrar.

17 THE REGISTRAR: Document number 30223 receives exhibit number

18 P6993, Your Honours.

19 JUDGE ORIE: Admitted into evidence.

20 One question, Witness. Did you see that the accommodation was

21 leaking, or did you not?

22 THE WITNESS: [Interpretation] Your Honour, I inspected all the

23 rooms where they were. I didn't enter all the buildings, but in any case

24 I didn't see any such thing.

25 JUDGE ORIE: Thank you.

Page 29537

1 Mr. Ivetic.

2 MR. IVETIC: Your Honours, just for clarity of the record when

3 Prosecution counsel at temporary transcript page 70, lines 21 through 25,

4 asked the question of the witness, he is misrepresenting the evidence on

5 two scores: The witness has already testified in a previous line that he

6 did not see this document before, therefore it could not be the basis of

7 his comments in the statement; and the witness testified rather clearly

8 today that his comments in relation to paragraphs 39 and 40 related to

9 the statement of Osman Selak, not some other statement.

10 So I think that the question mis -- as represented misstates the

11 record on two scores.

12 MR. TRALDI: I disagree, Your Honours. At first, I don't believe

13 I suggested that this document was the basis of the witness's comment

14 that people who visited him described the camp differently. I believe I

15 suggested it was an example of occasion when people who were there and

16 saw the same things described them differently. In this case, the staff

17 of the camp.

18 Secondly, the witness's comments that I referred to were at

19 temporary transcript page 12, where he used the words, I'm afraid I'm

20 paraphrasing, that I used. I understand and agree with Mr. Ivetic that

21 paragraphs 39 and 40 he's clarified refer to Colonel Selak only.

22 MR. IVETIC: And paragraph 12 -- sorry. Temporary transcript

23 page 12 is precisely asking about these paragraphs.

24 MR. TRALDI: I -- I'd be inclined to leave it there, unless

25 Your Honours wish further submissions in that respect.

Page 29538

1 JUDGE ORIE: If you give me one second to re-read the relevant

2 portion. Well, the question was about Selak. The answer, unfortunately

3 not.

4 You may proceed.

5 MR. TRALDI:

6 Q. The Chamber has received evidence --

7 MR. TRALDI: And I refer, for instance, to Exhibit P3873.

8 Q. -- that after this visit, members of Merhamet met with

9 General Talic and told him that the prisoners they saw at Manjaca were

10 peaceful citizens, that they'd been beaten up and starved, and 30

11 per cent of them had serious injuries, and that in that their view the

12 accommodation in the camp was clearly contrary to the regulations of the

13 Geneva Convention.

14 So, Merhamet also described this visit very differently than

15 you're describing it to the Trial Chamber today; right?

16 A. No, that's not right. As far as I know, and I was not present at

17 that meeting with the mufti and a number of intellectuals, the attendees

18 discussed the entire situation. They complained about other camps, and

19 they implored with the commander, if possible, to try and improve the

20 living conditions of those people as well. As far as I know, in that

21 part, the commander did promise that he would try to exert influence on

22 Mr. Zupljanin and send a request to him to that effect.

23 Second of all, this was an integral part of what is the

24 characteristic of Manjaca camp itself. They thanked us for the most

25 appropriate treatment that inmates were receiving in that camp. In

Page 29539

1 return, the commander told them and implored with them to control Muslim

2 extremists, because they didn't have anything against the army, the

3 Muslim army itself. It was just the Muslim extremists that had to be

4 controlled in order to maintain peace.

5 And as for such characteristics of Manjaca at that time, I did

6 not come across any of them and -- and I can't confirm the allegations

7 therefore.

8 JUDGE ORIE: Witness, could I seek clarification.

9 You said you were not present at that meeting, and then you told

10 us what happened at the meeting, they complained about other camps and

11 they implored with the commander if possible to try and improve the

12 living conditions of those people as well.

13 Now, there are two questions: First of all, how would you know

14 if you were not present? Let me first ask you that.

15 THE WITNESS: [Interpretation] I read the notes made by the

16 assistant for morale guidance who was present, Mr. Vukelic. I can't tell

17 you from what archives, but I know that that note mentions the mufti and

18 others. If you were to ask me to repeat their names, I could not. But

19 as for the contents of the note, I can give you a whole list of the

20 things that were noted.

21 JUDGE ORIE: Now, the question simply was whether the report is

22 contradicting the other reports not on what happened. And now I have

23 another question.

24 You said that they would try and improve the living conditions of

25 those people as well.

Page 29540

1 If you say as well, those people, would then the Manjaca people

2 also have been discussed, or were just others discussed?

3 THE WITNESS: [Interpretation] Judge, sir, all the issues were

4 discussed. Those that they wanted to discuss. I did not find as many

5 objections against Manjaca. I came across their request -- requests for

6 the improvement of conditions in the other camps that were controlled by

7 civilians, i.e., the civilian police.

8 JUDGE ORIE: What objections against Manjaca you found?

9 THE WITNESS: [Interpretation] Nothing of any significance.

10 JUDGE ORIE: You said: I did not find as many objections against

11 Manjaca. Whether significant or not, what --

12 THE WITNESS: [Interpretation] That is okay, yes.

13 JUDGE ORIE: -- did you -- yes, but what did you then find as

14 objections against Manjaca?

15 THE WITNESS: [Interpretation] Let me tell you, please.

16 There were objections, first of all, that people were kept there

17 who were under age and who were over the age of 60. That there are some

18 sick people at -- this is a priority and that this should be dealt with

19 on first release. The commander expressly said that they would be

20 transported as soon as the commission processed and triaged them and sent

21 their proposal to the International Red Cross for the problem to be

22 resolved as soon as possible.

23 JUDGE ORIE: Please proceed, Mr. Traldi.

24 MR. TRALDI:

25 Q. I have a couple of follow-up questions on that material, sir.

Page 29541

1 First, who provided you Colonel Vukelic's notes of the meeting to

2 review?

3 A. In some archives or at the command. They were not sent to me. I

4 just had them. I was interested in that.

5 Q. Roughly what year did you locate them in the archives in the

6 command?

7 A. I can't say. I was still in service. Those notes were

8 handwritten. I can remember that. The memorandum issued by the

9 gentleman who visited the general also exists. I'm sure that it is in

10 the archives somewhere. Their own memorandum, and I'm sure that it

11 mentions what the situation was, as well as their requests. Also the

12 notes that I read, the handwritten notes, mention that memorandum.

13 MR. TRALDI: Well, let's look at P3873 then.

14 And, Your Honours, I admit I've forgotten whether I tendered this

15 document, and if I have not I would ask to do so now.

16 JUDGE ORIE: Madam Registrar.

17 MR. TRALDI: I'm told by my boss that I have remembered to tender

18 it.

19 JUDGE ORIE: Yes. Then there's no need to do it again. But

20 perhaps it would be time for a break.

21 Could you give us any estimate, Mr. Traldi, as far as time is

22 concerned?

23 MR. TRALDI: I expect approximately 10 or 15 minutes after the

24 break, Your Honour.

25 JUDGE ORIE: Yes.

Page 29542

1 Witness, we'll take a break, and we will resume at -- after 20

2 minutes.

3 [The witness stands down]

4 Mr. Ivetic, could you give us an indication as far as timing is

5 concerned?

6 MR. IVETIC: Yes, Your Honours. I would think 15 to 20 minutes.

7 JUDGE ORIE: Yes. Which leaves it open whether the next witness

8 should remain stand by or not.

9 MR. IVETIC: Correct, correct. I think we should probably keep

10 on stand by.

11 JUDGE ORIE: Yes.

12 MR. IVETIC: I --

13 JUDGE ORIE: Well, 10 to 15 minutes brings us to ten minutes to

14 2.00. Another 15 to 20 minutes brings us to five minutes after -- ten

15 minutes after 2.00.

16 MR. TRALDI: I can say I'll be more like 15 than 10,

17 Mr. President. [Overlapping speakers].

18 JUDGE ORIE: Then I think we should inform the Victims and

19 Witness Section that we'll not start the examination of the next witness

20 today.

21 MR. IVETIC: Thank you, Your Honour.

22 And if I can also give information. This may help Mr. Traldi in

23 his cross. The source for paragraphs 39 and 40 of this witness's

24 statement is the 2001 statement of Mr. Selak, which we have just uploaded

25 and released as 1D5307 so that it is available to be viewed.

Page 29543

1 JUDGE ORIE: Yes. And is therefore not evidence.

2 MR. IVETIC: Not in evidence, that's correct.

3 MR. TRALDI: And we thank Mr. Ivetic.

4 JUDGE ORIE: Yes. We take a break and we resume at 25 minutes to

5 2.00. And I would urge the parties to see whether we can conclude the

6 testimony of this witness today.

7 --- Recess taken at 1.17 p.m.

8 --- On resuming at 1.39 p.m.

9 JUDGE ORIE: While waiting for the witness to enter the

10 courtroom, I'd like to briefly deal with D773, which is a document which

11 was initially MFI'd pending an English translation.

12 The translation has since been received and there are no

13 objections to the translation, if the Chamber understands well.

14 Therefore, Madam Registrar is hereby instructed to add doc ID 1D19-0081

15 to D773. In an informal communication, the Prosecution requested to be

16 permitted to make further submissions in relation to this document before

17 the Chamber decides on submission, and the Chamber hereby sets a deadline

18 of the 19th of December, 2014, for these submissions.

19 [The witness takes the stand]

20 JUDGE ORIE: Mr. Traldi, please proceed.

21 MR. TRALDI: Thank you, Mr. President. Could we have P3873,

22 please.

23 Q. While it comes up, sir, I'm going to be focusing on the meeting

24 that the Merhamet representatives had with General Talic. You said aside

25 from Manjaca they had more serious complaints about other camps as far as

Page 29544

1 you knew. What other camps do you know them to have complained about

2 during that meeting?

3 A. I don't know.

4 Q. Okay. Then I'll look at what they did say about Manjaca, and

5 this is a document coming from Merhamet and summarising this meeting,

6 these talks, on the 22nd of June, 1992. Directing your attention to the

7 fourth paragraph, reads:

8 "Gratitude was expressed to the general for enabling a visit to

9 the 'captured' Muslims and Croats who were in the military base in

10 Dobrinja, (Manjaca). The general was informed of a few particular

11 characteristics: (A) the overwhelming majority of the captives are in

12 fact peaceful citizens who were previously been called to a meeting in

13 their local communes (Gornja Sanica Sanski Most and others) by the

14 current Serbian authorities, and were then arrested en mass or were

15 picked up from their houses and so on; (B) they were treated terribly

16 when they were delivered to the camp. They were missing shoes, missing

17 some the their clothes, beaten up, starved, and so on. About 30 per cent

18 of them had serious injuries (fractured ribs, jaws, hands)."

19 My question to you is: How is it that you did not also learn of

20 these problems on the same visit four days earlier that the Merhamet

21 representatives made to Manjaca?

22 A. Whose information is this?

23 Q. Document comes from Merhamet. And if we can see the signatures,

24 we'll see it's signed by several of the people mentioned on the top.

25 A. I can see that. Yes, yes, I can see that. I did not attend at

Page 29545

1 that meeting. I read information in a way I did, and I've told you about

2 that. And let me answer this last part of your question -- or rather,

3 the first part of your question which is much more interesting: Those

4 who arrested and brought people in, all that happened outside of the POW

5 camp Manjaca before those people were taken over, and this statement

6 refers to the thereafter. I could not be aware of all those details. It

7 was not in the nature of my work to pay so much attention to so many

8 details in order to be able to be aware of them.

9 Second of all, Talic did not invite me to that meeting and

10 therefore I can't tell you anything else that I -- than I did. I

11 understand. Originally I did not have this information, so I cannot

12 interpret this, nor can I testify about how I couldn't. Simply that

13 information was not accessible to me.

14 Q. That completes my questions on this document.

15 MR. TRALDI: Could we have Exhibit P2880 now.

16 Q. And, sir, to try to finish your testimony today, I'm going to ask

17 that you follow my direction to the portions of the document that I'm

18 interested in asking about.

19 This is going to be a letter dated the 7th of August from the

20 Red Cross, forwarded from the Red Cross, to President Karadzic.

21 A. Okay.

22 MR. TRALDI: Can we have page 3 in the English and 5 in the

23 B/C/S.

24 THE WITNESS: [Interpretation] Okay. Is that the page you want?

25 I still have -- okay.

Page 29546

1 MR. TRALDI:

2 Q. So here we've got -- this is not the page I'm looking for, I'm

3 afraid.

4 MR. TRALDI: So I'll ... just on -- at -- out of the possibility

5 that I might have asked for the wrong page, I'm looking for a number 2

6 describing what they've seen on detainees.

7 JUDGE FLUEGGE: In English, you mean?

8 MR. TRALDI: It -- we'll do that my both languages. My notes

9 suggest that that's on page 3 in the English and 5 in the B/C/S. I'm

10 told it's 6 in the B/C/S and not 5. Let's work from the B/C/S in the

11 interests of time.

12 Q. Below the number 2, do you see that the Red Cross is saying

13 they've observed frequent and widespread traces of recent and often

14 severe beatings on the detainees?

15 A. In which paragraph is that? I can't find it.

16 Q. Second paragraph under point 2, treatment. "All eight delegates

17 present in camp observed on detainees frequent and widespread traces of

18 recent and often severe beatings; these most often were fresh hematomas

19 inflicted in a time-period since arrival at Manjaca."

20 So I take it you've seen it. The Red Cross is also describing

21 what they saw on their visits very differently than you do; right?

22 A. And your question to me is what?

23 Q. Like -- like Merhamet and the camp guards, the Red Cross has a

24 very different description of what they saw on their visits to Manjaca

25 than you have; correct?

Page 29547

1 A. Not correct. I said what I did about what I saw, and here the

2 Red Cross wrote to the president what they saw. One should take a look

3 of the records when those people entered the camp and when they were

4 processed and then compare them with these here. Then I could say

5 something. Then I could tell you what they saw and I didn't, and vice

6 versa, what I saw and they didn't.

7 Q. Did --

8 JUDGE ORIE: Witness, could I ask you a simple question. They

9 report that they saw a lot of people with visible remains of being

10 beaten. Now you told us that you went to the camp as well and that you

11 were there. You never saw anyone with the bruises and the signs of

12 having been beaten recently?

13 THE WITNESS: [Interpretation] I can't say that I did not see it.

14 But I did not see the traces of recent beatings. I didn't see that.

15 That's not the way I saw things.

16 JUDGE ORIE: Yes. Now, so you saw people with visible signs of

17 having been beaten?

18 THE WITNESS: [Interpretation] I told you, Your Honour, one should

19 take a look at the documents which were drafted by the organs who were

20 responsible for the triage of those persons on their admission.

21 JUDGE ORIE: Witness -- Witness, I'm not --

22 THE WITNESS: [Interpretation] I don't -- I don't have any other

23 answer, sir.

24 JUDGE ORIE: Witness, don't tell us what we have to look at.

25 We'll certainly look at everything that is available. Don't worry about

Page 29548

1 that. I just wanted to establish that you had seen people in Manjaca

2 with visible signs of having been beaten. Is that well understood? And

3 if so, could you tell us?

4 THE WITNESS: [Interpretation] No, you misunderstood me. I did

5 not see visible signs of people having been beated. I'm talking about

6 the circumstances under which the International Red Cross wrote to the

7 president and told him that they had seen things. I believe that they

8 paid more attention and saw many more details. But, Your Honour, I

9 cannot affirm that in just one sentence or one word. I did not see any

10 such thing.

11 JUDGE ORIE: Witness, I asked you the following. I said:

12 "You never say anyone with the bruises and signs of having been

13 beaten recently?"

14 And then you answered:

15 "I can't say that I did not see it," which is understood by me

16 that you may have seen it or have seen it.

17 And now at the same time when specifically asked whether you saw

18 it, you say, no, I didn't see it. That is confusing me slightly. Did

19 you see any persons in Manjaca camp with visible signs of having been

20 beaten such as bruises, hematoma.

21 THE WITNESS: [Interpretation] To be very concrete, I didn't see

22 that.

23 JUDGE ORIE: Okay. Fine.

24 THE WITNESS: [Interpretation] I was with those people --

25 JUDGE ORIE: Yes. I -- that's an answer to my question.

Page 29549

1 Please proceed, Mr. Traldi.

2 MR. TRALDI:

3 Q. Sir, I'm going to be very focused and just simply put to you this

4 next point. The Chamber has received evidence that the 1st Krajina Corps

5 was informed that prisoners Esad Bender and Omer Filipovic had been

6 killed there. Were you also aware of that?

7 A. No.

8 Q. So information about the abuse or murder of prisoners at Manjaca,

9 that wouldn't have been shared with you in your capacity as the chief of

10 the quartermaster service?

11 A. The answer could be this: The information was not available

12 to -- it -- me because of its confidentiality. This information went

13 along the security line, and we could not provide the information because

14 that information was forwarded to the command of the 1st Krajina Corps,

15 i.e., to its Chief of Staff.

16 Q. Finally and directly related to logistics, the Chamber has

17 received evidence that the 1st Krajina Corps was aware --

18 MR. TRALDI: And I'm referring now to Exhibits P232 and 3128.

19 Q. -- that the water supply system in Manjaca wasn't working. Were

20 you aware of that?

21 A. There were occasional problems with providing water and the rest.

22 Whenever there were problems of that kind, I was informed about that

23 along the lines of communication.

24 Q. And, sir, just to be fair to you, I'm going to put to you, it is

25 not credible that all these people on visits with you saw signs of fresh

Page 29550

1 bruising on prisoners and you didn't see anything. Your evidence on that

2 is not credible, is it?

3 A. No.

4 MR. TRALDI: Your Honours, I have no further questions.

5 [Trial Chamber confers]

6 JUDGE FLUEGGE: I have one brief matter to ask the witness about.

7 Earlier this morning, sir, you challenged the term "about 40"

8 people were killed, the term used by Mr. Selak. How many, if any, people

9 were killed in Manjaca to your knowledge?

10 THE WITNESS: [Interpretation] I said a while ago, Your Honour, I

11 was not informed about the murder of any one person in Manjaca. This

12 document that was shown to me explains how that information was --

13 JUDGE FLUEGGE: I'm not asking you about any document. To your

14 knowledge how many, if any, were killed?

15 THE WITNESS: [Interpretation] No, didn't [as interpreted]. I

16 know that I don't know of any case of murder in the Manjaca camp.

17 JUDGE FLUEGGE: Thank you. You don't know that. You know that

18 you don't know. Thank you.

19 JUDGE ORIE: I have one short follow-up question.

20 You used the expression "murder" --

21 THE WITNESS: [Interpretation] I apologise.

22 JUDGE ORIE: One second.

23 THE WITNESS: [Interpretation] Excuse me.

24 JUDGE ORIE: You used the expression "murder." Were you -- you

25 do not understand me? You now do?