1 Thursday, 3 November 2005

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 2.20 p.m.

6 JUDGE PARKER: Good afternoon to you, and would you be good enough

7 to stand and read allowed the affirmation on the card that is given to

8 you.

9 WITNESS: WITNESS P006

10 THE WITNESS: I solemnly declare to speak the truth, the whole

11 truth, and nothing but the truth.

12 [Witness answered through interpreter]

13 JUDGE PARKER: Thank you.

14 Mr. Moore, is it?

15 MR. MOORE: Yes, it is.

16 JUDGE PARKER: Just trying to catch an eye as to who it would be.

17 MR. MOORE: May it please the Court, this is Witness 006. There

18 are confidential matters dealing with this witness and we would make an

19 application for the session to immediately go into private session, and

20 the witness to be shown a document to confirm his particulars, both with

21 regard to his date of birth and location of birth and name.

22 JUDGE PARKER: Private.

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11 [Open session]

12 MR. MOORE:

13 Q. Witness, can I just deal, please, with the individuals that you

14 saw being taken away? You say that you saw one come back. What about the

15 other three that you mentioned? Did you ever see them again?

16 A. No. Never again. They are still listed as missing persons, as

17 far as I know.

18 Q. And when you used the phrase "they took them away," who are you

19 referring to?

20 A. I'm referring to the soldiers. I'm referring to people wearing

21 military uniforms.

22 Q. And are you able to tell us approximately what time of day it was

23 that they were taken away?

24 A. I can't remember exactly, but I reckon it was late afternoon,

25 probably past 4.00.

1 Q. We are aware in this Court that Dr. Bosanac was at the hospital at

2 the relevant time. Did you ever see Dr. Bosanac on the 19th?

3 A. No.

4 Q. What other things did you see occur on the 19th, please?

5 A. I can't be certain, but I think this, too, was on the 19th: I saw

6 Dr. Ivankovic's son arrive wearing camouflage uniform. On his right arm

7 he had the White Eagles patch. He asked him whether anyone had made any

8 threats to him, meaning in order to exact revenge.

9 Q. Can you tell us who spoke to whom? Because you say him and him.

10 Who is speaking to whom, please?

11 A. I apologise. Dr. Ivankovic's son came to him.

12 Q. And did you hear what Dr. Ivankovic replied?

13 A. No. I didn't. He was just shaking his head, meaning no,

14 probably.

15 Q. You've told us you thought that was on the 19th. When you heard

16 that conversation --

17 A. I'm not sure. I'm sorry, I'm not sure if it was on the 19th or

18 the 20th.

19 Q. But can you remember where it was, where you saw this occur?

20 A. Yes. Yes. I remember that. That was at the entrance to the

21 emergency ward near the Crisis Staff room inside the hospital.

22 Q. You've told us about the 19th. Did you see any other JNA officers

23 involved in conversations at night or not?

24 A. Not that night or that evening.

25 Q. Can we move, then, on, please, to the 20th? What do you recollect

1 occurring in the morning of the 20th?

2 A. The morning of the 20th, prior to the evacuation, I saw them take

3 away a journalist named Sinisa Glavasevic. There were two soldiers

4 escorting him. He, Glavasevic that is, had a bandage wrapped around his

5 head, probably as a result of previous shelling. At 7.00 I saw another

6 officer arrive and speak to Dr. Bosanac, saying that she was no longer in

7 charge of the hospital but, rather, that he now was. I can describe for

8 you a man aged between 40 and 50, rather small, stoutish, wearing a JNA

9 uniform.

10 Q. Thank you very much. Now, I want to deal with the gentleman

11 called Glavasevic. Who exactly was he and what was his occupation?

12 A. He was a journalist, working for our Radio Vukovar as a radio

13 journalist.

14 Q. And are you able to say how actively involved he was on Radio

15 Vukovar in November?

16 A. Every evening, he sent out reports on what was going on in Vukovar

17 itself and its surroundings.

18 Q. You said that you saw an officer, you believe on the 20th, the

19 morning of the 20th, at approximately 7.00 a.m., and that officer spoke to

20 Dr. Bosanac. Do you know the name of that officer or not?

21 A. I don't.

22 Q. Can I deal, then, please, with what occurred in the morning? You

23 have told us about Glavasevic at 7.00. What occurred next after that,

24 please?

25 A. Following that, when this officer went to speak to Dr. Bosanac,

1 Mr. Sljivancanin came. He introduced himself to us. He told us that he

2 and his soldiers had come to liberate Vukovar, and then told us that all

3 medical staff had to go to a room, which was in the surgical clinic, the

4 plaster room.

5 Q. Did you consider yourself to be medical staff at that time?

6 A. Since I collected the wounded the entire time, and since I worked

7 in that hospital, yes, I was considered a member of the staff.

8 Q. So did you go, as you were requested, to a separate room?

9 A. After a certain period of time, all medical personnel entered the

10 plaster room and then the drivers wanted to go into the room as well.

11 Dr. Ivankovic stood in the door and told us that the drivers were not

12 medical personnel and that they should go out.

13 Q. And did you go out?

14 A. Yes. All of us drivers went out, outside of that room.

15 Q. And when you went outside, what did you see?

16 A. When they told us to go out -- I apologise, I am a bit anxious.

17 As we were going out from the basement premises, I saw that there were a

18 lot of people there, women and children who had already been separated

19 from the men. The men stood on the left in a line. So from the entrance

20 into the surgical clinic and then to the left towards Gunduliceva street

21 in the hospital yard, that's where it was all going on. Some soldiers

22 told us to get into the line as well so that I went to join the line in

23 the front. We got in the line and then some soldiers came up to us. They

24 frisked us, took our personal belongings from us, money, jewellery. As I

25 stood there in the line, I saw that they were boarding wounded patients

1 unable to walk on to military trucks. Those were seriously wounded

2 patients. First they pushed them out of the building on beds. Then they

3 placed them on stretchers and then put the stretchers on trucks.

4 Q. Thank you. I just want to return to the line. You said already

5 that they had already been separated, women and children being separated

6 the men. I know it's difficult to estimate numbers, but if you were

7 trying to estimate the number of men in the line, would it be in the tens,

8 the fifties, the hundreds? Are you able to give us an impression?

9 A. Over 200 people.

10 Q. I want to now ask you about the people that you described as

11 seriously wounded. Often in a hospital people who are undergoing

12 significant treatment will have such matters as drips, saline drips by the

13 bed, and other medical paraphernalia to assist their recovery. Did you

14 see any of these items accompany the patients that you described as

15 seriously ill or seriously injured?

16 A. I couldn't say. I didn't see that. These people drove in front

17 of me very quickly.

18 Q. Did you recognise any of the individuals being taken out and put

19 into military trucks?

20 A. I didn't recognise a single wounded patient.

21 Q. Did you see any military ambulances being used to take away these

22 seriously injured patients?

23 A. No. Those were military trucks. As I myself was a driver in the

24 former JNA, I recognised the trucks which were 110.

25 Q. I'd like to now deal, please, with the gentlemen or the men who

1 were in the line. You said there were over 200 of them. What happened to

2 them, please?

3 A. This is how it was. As we stood in the line, they told us to face

4 the buses awaiting us in Gunduliceva street, which was beyond the hospital

5 compound. They told us to board the buses in the order in which we were

6 lined up. In accordance with that, I entered the second bus. I took a

7 seat in the third row, an aisle seat, facing front. (redacted)

8 (redacted)

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13 (redacted). The two of us were the only ones who got off the

14 bus. They didn't tell us why we were getting off. They told us to stand

15 next to the hospital fence where there were already three colleagues of

16 ours. After a certain period of time, the buses turned in front of us and

17 then continued on towards the centre of the city.

18 Q. Of the 200 men that you've described, your approximate number, how

19 many were actually allowed to leave the buses, as far as you could see?

20 A. What do you mean? Who else had the hospital ID badge?

21 Q. Well, another way I can put the question is this: How many of the

22 200 were placed on the buses?

23 A. Everybody got on the buses except for the five of us.

24 Q. You've told us that you were told to wait near the fence at the

25 hospital and you saw the buses drive off. When they drove off, was it

1 just the five buses alone or were there any other vehicles accompanying

2 them? Can you remember?

3 A. No. Since the buses turned right there in front of us, there were

4 just those five buses. There were no other vehicles.

5 Q. And the buses themselves, did they have any members of the JNA

6 inside the buses?

7 A. No. Except for drivers. I don't know whether the drivers

8 belonged to the JNA or not.

9 Q. When you were at the fence, did you meet any other person or did

10 any other person approach you?

11 A. Yes. Right there in front of the fence, there were five of us.

12 We were guarded by two JNA soldiers. Then, Mr. Sljivancanin approached us

13 and he asked for our names. He had some kind of a list with names with

14 him. He asked us to see whether our names were on the list and we could

15 see that they were not. Then he himself added our names at the bottom.

16 Additionally, he asked me whether I participated actively in collecting

17 the wounded. I told him that we, the drivers, mostly drove wounded

18 civilians and that the soldiers drove themselves. That was a lie, of

19 course, but at that moment it seemed to be the best thing to say. Then he

20 went to talk to the other four men.

21 Q. Why did you lie to Sljivancanin at that time about picking up

22 soldiers?

23 A. I was very much afraid. On the previous day, they already took

24 some men away, and I was afraid that I would have the same fate.

25 Therefore I lied.

1 Q. The list that Sljivancanin had, were you able to see any names on

2 the list or how many names were on the list?

3 A. It was an A4 sheet of paper with two sides. When he told us to

4 look for our own names on the list, I just looked for my own name so I

5 didn't pay attention to other names and, hence, I didn't remember them.

6 Q. But with regard to the names, if we accept that you weren't able

7 to -- or did not look at the names, was it just one side of the A4 paper

8 or was it both sides? Can you give an indication to the Court how many

9 names were on that list? One or two sides?

10 A. Listen, I can't give you the exact number, but the names were

11 written densely, one below the other, and I think that there were a lot of

12 names on both sides.

13 Q. What did you then do after your names had been added to his list?

14 Can you tell us, please?

15 A. Yes. Once he added our names to the list, and once he finished

16 talking to the other four men, he sent all five of us back to the

17 hospital, or, rather, to the hospital basement. Women and children were

18 still there. I went into the surgical clinic and sat on a bench in front

19 of the plaster room. And then all of a sudden, a soldier appeared in

20 front of me with a long beard, a cockade on his cap and asked me what my

21 name was. He asked me where I was from. When I gave him my name and told

22 him where I was from, he wanted to know from -- in which neighbourhood I

23 lived. I told him I was from Mitnica and then he instantly grabbed me by

24 my hand and went towards the entrance, taking my ID -- hospital ID card

25 away from me. I held my ID card in my hand. When -- as we were walking

1 towards Gunduliceva street, all of a sudden a nurse whom I knew and with

2 whom I'd worked at this hospital appeared in front of us. Her name is

3 Vuka Mikanovic [phoen]. She is still employed as a nurse at the hospital.

4 She came up to him and said something to him. I didn't hear what. But

5 after that, he returned my hospital ID badge back to me. I hugged the

6 nurse and then we went to the buses which were on the other side of the

7 street. Ivo Lola Ribar street facing the main entrance into the hospital.

8 Q. The bus that you went to, how many people were on that bus

9 approximately?

10 A. I don't know how many buses stood in front of the hospital but I

11 got in one of them. As I boarded the bus, I saw that hospital medical

12 personnel were there, women, children and civilians, and (redacted)

13 (redacted). As we had no seats for us, we

14 crouched in the aisle between the seats. At that time, some soldiers

15 started hitting fiercely the windows of the bus and the bus itself,

16 looking for men and saying that all men should go out. As we were

17 crouching in the aisle between the seats, women who were on the bus threw

18 jackets over us and their handbags so that they wouldn't notice us.

19 Q. You have told us that there was yourself and your boss were the

20 only men on the bus. Are you able to approximately give an idea of how

21 many people were actually on the bus? Is it ten, 20, 30, 40?

22 A. A bus has 50 seats. So 50 people plus the two of us. That means

23 52 people.

24 Q. And you say that there were soldiers who were banging on the bus,

25 saying that men should come out, looking for men. When did that actually

1 start? When did the banging and the shouting for men to come out, at what

2 location was that, please?

3 A. That was there where the buses were, in Ivo Lola Ribar street,

4 across from the main entrance of the hospital.

5 Q. And if we are talking about timing, you did mention about 7.00 was

6 the time you saw the journalist taken away. Approximately what time did

7 the buses move away from the hospital?

8 A. I remember clearly, when the buses started turning around. At

9 that time, I was still crouching between the seats. As the buses started

10 moving and turning around there in front of the hospital, it was around

11 noon.

12 Q. I want to deal with the buses for the moment. As far as you're

13 aware, how many buses were there who took people away from the hospital?

14 Can you give us an idea, please, of the number?

15 A. You mean the buses that I was on or you mean the previous

16 occasion?

17 Q. No. I'm just talking about the buses. You refer to buses and

18 you're on a bus and there are other buses. How many do you think there

19 were at that time that departed around mid-day?

20 A. Five to six buses. I don't know exactly, but definitely five to

21 six buses.

22 Q. Now, we know that in actual fact those buses ended up travelling

23 along a route. And I would like you, please, if you could, in your mind,

24 to move on in time to when it came to getting off the bus or buses. Do

25 you remember that occurring?

1 A. When the buses turned around in front of the hospital, we

2 continued towards the centre of the town, towards the barracks, or rather

3 we passed the barracks, Velepromet, and then on to Negoslavci, Oriolik,

4 Tovornik, Sid, and Sremska Mitrovica. In Sremska Mitrovica, the bus

5 stopped near a sports hall. That's what I heard people saying. But I

6 myself did not go out. I was very much afraid and I was afraid to get off

7 the bus. I felt safest in the bus.

8 Q. After Sremska Mitrovica, where did the bus then go to, please?

9 A. That night, or, rather, once we arrived in Sremska Mitrovica, we

10 spent the night there in the barracks. We slept on buses. In the early

11 morning hours, after 7.00 or 8.00 a.m., it was already daylight, the buses

12 set out towards Bijeljina and Bosanski Dvori. This is where the exchange

13 took place. An empty bus would drive up close to our bus. The doors on

14 both buses would open, and we moved from one bus into the other one. And

15 as soon as the bus that we got on was full, it moved away and then would

16 drive to a spot and wait there for other buses so that a column was

17 formed.

18 Q. As far as you're aware, these approximately five or six buses, did

19 they travel in convoy before they were exchanged, the people were

20 exchanged?

21 A. Yes. From the barracks in Sremska Mitrovica to Bosanski Dvori we

22 travelled in a convoy.

23 Q. And the people who eventually got off those buses, all of the

24 buses, are you able to assist the Court how many of the people,

25 percentagewise, were women and children, and how many percentagewise were

1 men who got off those buses? Do you follow the question?

2 A. I do. When the column was formed after a certain period of time,

3 we went to Djakovo. That was the first rest stop. 80 to 85 per cent were

4 women and children. There were very few men among them.

5 MR. MOORE: Thank you very much. I have no further questions.

6 JUDGE PARKER: Thank you. Well, that is a convenient time,

7 Mr. Moore. In view of some redactions, we will need about a half an hour

8 break. We will resume at ten minutes past 4.00.

9 --- Recess taken at 3.43 p.m.

10 --- On resuming at 4.13 p.m.

11 JUDGE PARKER: Mr. Vasic?

12 MR. VASIC: [Interpretation] Thank you, Your Honour.

13 Cross-examined by Mr. Vasic:

14 Q. Sir, first of all I wish to introduce myself. I am

15 attorney-at-law Miroslav Vasic appearing on behalf of Mr. Mile Mrksic. In

16 view of the protection measures, could you please pause after my question

17 so that I could switch my microphone off to prevent your voice from being

18 heard over my microphone? This will also help us with the interpretation.

19 MR. VASIC: [Interpretation] Your Honours, to begin with, maybe it

20 would be convenient to go into private session.

21 JUDGE PARKER: Private session.

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22 [Open session]

23 Cross-examined by Ms. Tapuskovic:

24 Q. Witness 006, good afternoon to you, my name is Mira Tapuskovic,

25 co-counsel for Miroslav Radic. My learned friend asked you to speak

1 slowly for the benefit of the interpreters. Should need arise I may

2 myself have to ask you the same thing but I see that we have been doing

3 quite well so far.

4 There is another thing that I would like to ask you. Whenever you

5 need to refer to any names, please think twice before actually pronouncing

6 the name. I'll be warning you about this same thing. I would not like to

7 see any protective measures compromised, protective measures granted other

8 persons, as they were granted to you.

9 I will go back to some of the same questions that my learned

10 friend, Mr. Vasic, has asked you on behalf of Mr. Mrksic, as these

11 questions are obviously of great relevance to the Defence.

12 After such a long time, are you able to tell us the exact date

13 when you gave your first statement to the investigators of this Tribunal?

14 A. I couldn't give you the date but it was in 1995.

15 Q. Thank you. As you have confirmed to Mr. Vasic, you testified in

16 the Dokmanovic case. Can you tell us the exact date?

17 A. Unfortunately, I can't.

18 Q. Can you please repeat the answer? I didn't catch your answer.

19 A. I said I can't give you the date. I don't remember.

20 Q. I assume that in preparation for your second testimony before this

21 Tribunal, and before this specific Trial Chamber, you have spent about 10

22 days here in The Hague already, have you not?

23 A. Yes, that's true.

24 Q. Will you please tell me whether, over these 10 days you have been

25 shown your own statement, the statement that you gave to OTP investigators

1 in 1995?

2 A. Yes, I have been shown that statement.

3 Q. Sir, do you perhaps remember when you were originally scheduled by

4 the OTP to testify in this case? What should have been your first day

5 appearing before this Trial Chamber to testify?

6 MR. MOORE: With the utmost respect to my learned friend, and --

7 the situation with witnesses, as the Court is well aware, is one does not

8 have a crystal ball and one cannot say exactly to anybody when they will

9 be giving the evidence. It's an unfair question because the witness was

10 not in a position to know. Only the Court was able to know that

11 particular position. And it worked on a day-to-day basis.

12 JUDGE PARKER: That being so, Mr. Moore, the witness would be able

13 to say, "I don't know."

14 Is that your position?

15 THE WITNESS: [Interpretation] Yes.

16 JUDGE PARKER: I think that deals with the objection and the

17 issue.

18 MS. TAPUSKOVIC: [Interpretation] Indeed, Your Honour. Thank you

19 for that comment.

20 Does the witness then perhaps remember, in relation to these last

21 10 days that he has spent here, on which specific day corrections were

22 made to his statement that was then forwarded to us?

23 THE WITNESS: [Interpretation] It was last week, Thursday last

24 week. That was the last time I met Mr. Moore.

25 MS. TAPUSKOVIC: [Interpretation].

1 Q. Thank you. During Mr. Moore's examination-in-chief, you said a

2 couple of things about how these corrections were made but could you

3 please try to be more specific now? Were these corrections made at your

4 personal request or did perhaps Mr. Moore or anyone else from the OTP

5 point out discrepancies in your statements?

6 A. No. It was at my request.

7 MS. TAPUSKOVIC: [Interpretation] Your Honours, I apologise. I

8 need a head set that has a wire that is slightly longer so I don't have to

9 bend all the time. Thank you.

10 JUDGE PARKER: That looks much better.

11 MS. TAPUSKOVIC: [Interpretation] Thank you very much,

12 Your Honours. On account of this slight problem that I had, I didn't

13 catch the last answer and, with your permission, I would like to ask the

14 witness to repeat the last answer.

15 THE WITNESS: [Interpretation] It was at my own request.

16 MS. TAPUSKOVIC: [Interpretation]

17 Q. Thank you. Let us now go back to the events that constitute the

18 reason that you are now appearing before this Tribunal for the second

19 time. In answer to questions from both the OTP and my colleague Vasic,

20 you stated that you had lived in Mitnica. Can you specify the distance

21 between Mitnica then, as now, and the Danube, as the crow flies?

22 A. Between 100 and 150 metres.

23 Q. In your testimony, you said that Mitnica, your neighbourhood, was-

24 the last one to be attacked. Can you perhaps explain that?

25 A. No. I don't think I can. I don't think I can answer that

1 question.

2 Q. As the operations around Vukovar were drawing to a close and by

3 the time they ended, you were inside the hospital, were you not?

4 A. Yes, I was.

5 Q. After the fall of Vukovar, you continued to live there, didn't

6 you?

7 A. No. I joined the convoy to Mitrovica that we were taken from

8 Mitrovica to Djakovo and then Zagreb. I spent seven years in Zagreb but I

9 currently reside in Vukovar again. I have returned.

10 Q. In the meantime did you at any point come across your friends and

11 colleagues from the hospital? Did you perhaps have any opportunities to

12 discuss these events with them before you returned to Vukovar, your shared

13 experience?

14 A. Yes, I have met people.

15 Q. Does it not strike you as logical that you should exchange these

16 unpleasant impressions with them, your unpleasant impressions from those

17 days and months?

18 A. Yes, indeed, it does.

19 Q. You testified that you had served your compulsory military

20 service, how old were you then? 19, 20?

21 A. Yes. I left the army in June 1989.

22 Q. Can you please tell the Trial Chamber what your specialisation was

23 in the army?

24 A. I was a member of the scouts, military police.

25 Q. So in a way you're familiar with military ranks, formations, and

1 units that the former JNA had?

2 A. Yes.

3 Q. You knew what the uniforms of commissioned or non-commissioned

4 officers of the JNA looked like at the time, as well as those of the

5 National Guards Corps, did you not?

6 A. Yes.

7 Q. What about when you returned from military service? Did you

8 engage in any type of political activity in Vukovar or in Croatia as a

9 whole?

10 A. Never.

11 Q. Thank you. You said that you moved to the hospital after you'd

12 driven your parents to Vinkovci, if I remember correctly, and then your

13 parents travelled on to Zagreb but without you?

14 A. Yes.

15 Q. You then subsequently moved to the hospital and you were sleeping

16 in the emergency unit which was part of the hospital, were you not?

17 A. Yes, that's true.

18 MR. TAPUSKOVIC: [Interpretation] I have cautioned the witness to

19 speak slowly but it's obviously me who is speaking too fast and I thank my

20 colleagues for drawing my attention to the fact.

21 Q. In your statement that we have received from the OTP, you stated

22 that in August 1991, the hospital was often targeted. Can you please

23 specify what does "often" mean? And what sort of damage, roughly

24 speaking, was caused?

25 A. The hospital was being shelled. As for specific damage, shells

1 landed on roofs, shells landed in the courtyard and around the hospital.

2 Q. My colleague Mr. Vasic asked you how you had got your job at the

3 hospital. You said it was often the case in that period of time that

4 Serbs left their jobs, gave up their jobs. Please tell us and tell the

5 Trial Chamber: Were Serbs leaving their jobs at the hospital only in

6 Vukovar generally or in fact throughout the region?

7 A. I don't think I can answer that question. When Serbs started

8 leaving the hospital I was not there yet. I worked with a private

9 company. I really don't know.

10 MS. TAPUSKOVIC: [Interpretation] Your Honours, can we please

11 briefly go into private session? Thank you.

12 JUDGE PARKER: Private.

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22 [Open session]

23 THE REGISTRAR: We are back in open session, Your Honour.

24 MS. TAPUSKOVIC: [Interpretation]

25 Q. My colleague Mr. Vasic, Defence counsel for the accused Mrksic,

1 put several questions to you concerning the dates mentioned in your

2 statement given to investigators and in your testimony today. There are

3 several days in a row, 18th, 19th, and the 20th. I would like to revisit

4 the incident involving the journalist, Glavasevic. I will have several

5 questions for you. When describing the events on the 20th, you listed a

6 number of things that took place then. Can you now briefly describe the

7 chronology of the events of the 20th of November?

8 A. The 20th of November?

9 Q. Yes.

10 A. In the morning, before the evacuation, meaning before 7.00 a.m., I

11 saw them, I saw two soldiers leading away journalist Glavasevic. He had a

12 bandage on his head, which was most likely due to the shelling in the

13 previous several days. Then, at 7.00, I saw the gentleman who approached

14 Dr. Vesna Bosanac, telling her that she was no longer in charge of the

15 hospital but that, rather, he was. I said that I could describe him as

16 somebody who was between 40 and 50 years old --

17 Q. You don't need to go into details, just give us the chronology.

18 You saw Glavasevic being led away at 7.00?

19 A. No, not at 7.00 but before the evacuation, before 7.00.

20 Q. I apologise for interrupting you. But let us go back to page 20

21 of today's transcript and see line 18, where you answered to the questions

22 put to you by Mr. Moore. You said it was on the 20th of November at 7.00

23 in the morning. So how come you know now that it was before 7.00 in the

24 morning?

25 A. No. I stated then that it was before the evacuation, and the

1 evacuation started at 7.00. This took place before 7.00.

2 Q. Sir, I have to go into all of these details because it seems that

3 after ten and a half years, the chronology is quite clear in your mind,

4 whereas occasionally, you are unable to remember some dates. Now, please,

5 if you can continue, tell us what happened next.

6 A. This gentleman who addressed Dr. Bosanac was followed by

7 Mr. Sljivancanin. Then we went out, we saw the line, I saw women and

8 children, I saw the line with men, I saw how the wounded patients were

9 boarded on trucks. Then we were frisked, those of us who were standing in

10 the line. Then I got on the bus, I got off the bus, then Mr. Sljivancanin

11 once again, then I went back to the hospital. And then there was a

12 gentleman there who took me aside. Then nurse Vuka, who accompanied me to

13 the bus. Then I entered the bus. And then we travelled to Sremska

14 Mitrovica.

15 Q. Thank you. And you departed at around noon?

16 A. Yes, at around noon.

17 Q. On the 27th of October, in the presence of my learned friend

18 Mr. Moore, and I assume OTP investigators, you gave a statement where you

19 give certain corrections in relation to your 1995 statement. Mr. Vasic

20 asked you about these matters, but I will have to do that as well in order

21 to make sure that everything is clear.

22 You made corrections to two paragraphs of your statement.

23 MS. TAPUSKOVIC: [Interpretation] Your Honours, would you allow me

24 to give the B/C/S version of this statement to the witness so that it can

25 be placed on the ELMO and so that he could read it out so as to avoid me

1 interpreting or misinterpreting something that he stated. Thank you. I

2 will take the English version myself.

3 Your Honours, I think it will be quite easy for you to follow the

4 witness because the document will be placed on the ELMO. It is more

5 important to follow what the witness says than to follow the text on the

6 screen.

7 Page 3, paragraph 5. Here you mention that the event involving

8 the journalist Glavasevic took place on the 20th of November 1991. Did

9 you sign this?

10 A. Yes.

11 Q. Thank you. In the next paragraph in that section, you once again

12 refer to page 3, paragraph 5, and here you confirm that the event with

13 journalist Glavasevic took place on the 20th of November 1991.

14 A. Yes.

15 Q. When giving evidence in the Dokmanovic case, in February, the

16 exact date is the 3rd of February 1998. On page 532, on two occasions

17 when asked by the Defence counsel of the Accused Dokmanovic, you stated

18 that the event involving journalist Glavasevic took place on the 18th, in

19 the evening hours. Can you explain such a discrepancy? Because after

20 all, these are two different dates. And then again there is the

21 discrepancy in the hours.

22 A. I can't explain that. I remember what I told you about the 18th

23 of November. The statement that I received said that Glavasevic was taken

24 away on the 19th and I wanted that to be corrected because it wasn't on

25 the 19th but, rather, on the 20th.

1 Q. Can you tell us today when did this happen, this event with

2 Glavasevic? Because now we have three versions that you gave regarding

3 this.

4 A. It happened on the 20th of November, before the evacuation, before

5 7.00 in the morning.

6 Q. After 14 years, you are quite positive about that?

7 A. Yes, a hundred per cent.

8 Q. Thank you. I would like to put several questions to you

9 concerning Dr. Ivankovic. You knew his son, didn't you?

10 A. Yes. They lived near my street, in the same neighbourhood.

11 Q. Did you socialise with him?

12 A. Yes, but not intensely. Occasionally.

13 Q. Until which time did you socialise?

14 A. Until they moved away from the neighbourhood.

15 Q. When you saw him talking to his father in front of the hospital,

16 can you tell us how far were you from Dr. Ivankovic and his son?

17 A. Three to four metres.

18 Q. Were you surrounded by other people?

19 A. I was.

20 Q. And you could clearly hear the question put by the son of

21 Dr. Ivankovic?

22 A. Yes, because I was watching them.

23 Q. Can you describe how the son of Dr. Ivankovic was dressed?

24 A. He had a camouflage uniform on him, and he had White Eagles'

25 insignia on the left sleeve.

1 Q. I have just one last question for this witness, Your Honours. Can

2 he give us the exact time when, on the 20th of November, the first group

3 of people from the hospital left? Those were the people who were boarded

4 on the trucks. Can you give us the exact hour?

5 A. No. Can I give you an approximate hour?

6 Q. No. Thank you very much.

7 MS. TAPUSKOVIC: [Interpretation] Thank you, Your Honours. I have

8 no further questions for this witness.

9 JUDGE PARKER: Thank you very much, Ms. Tapuskovic.

10 Mr. Lukic? We could break now, if you would prefer that. We will

11 resume, then, at ten minutes to 6.00.

12 MR. MOORE: Before Your Honour rises, before Your Honour rises, we

13 are in a position to call a witness this evening. About that there is no

14 doubt. It's entirely a matter for Your Honour. I'm well aware of the

15 urgings of Your Honour last night. But I wonder if Mr. --

16 JUDGE PARKER: Just pause, Mr. Moore.

17 Mr. Lukic are you able to offer any prediction as to time?

18 MR. LUKIC: [Interpretation] I think that my colleagues have taken

19 away from the questions that I had. They covered a lot of topics. Half

20 an hour? But I can't guarantee because I might come up with new topics.

21 JUDGE PARKER: Half an hour. Perhaps that will bring us to 20

22 past 6.00, Mr. Moore. Do you expect to be long in re-examination?

23 MR. MOORE: I have only one topic at this stage.

24 JUDGE PARKER: I think you better have the other witness standing

25 by.

1 MR. MOORE: Thank you very much.

2 --- Recess taken at 5.30 p.m.

3 --- On resuming at 5.52 p.m.

4 JUDGE PARKER: Mr. Lukic.

5 Cross-examined by Mr. Lukic:

6 Q. Good afternoon. I am Novak Lukic appearing on behalf of

7 Mr. Veselin Sljivancanin. I will continue with our cross-examination. I

8 have several topics to cover, but most of all --

9 MR. LUKIC: [Interpretation] We are in open session, aren't we?

10 Q. Tell me, please, do you have any information or knowledge as to

11 until which point in time the village of Bogdanovci remained

12 Croat-controlled?

13 A. All I can tell you is that Bogdanovci fell at sometime in early

14 October, when our route for the evacuation of those seriously wounded from

15 Vukovar was cut off.

16 Q. You don't know if that village and the road to Vinkovci was under

17 the control of the Serb forces except for the part that had been cut off,

18 but other than that, it was Croat-controlled, wasn't it?

19 A. Yes.

20 Q. All the way up until late November?

21 A. I can't say. I know that Bogdanovci fell in early October and

22 that we were no longer able to leave Vukovar.

23 Q. I will ask you some questions in relation to certain individuals,

24 nothing to do with anybody's identity. I think we can remain in open

25 session for the time being.

1 Did you know about Dr. Crevar's house?

2 A. No.

3 Q. Have you ever heard of Zeljko and Zeljka Duvnjak?

4 A. No.

5 Q. Have you ever heard the name Slobodan Mandic?

6 A. No.

7 Q. He was a driver for Velika Godina [phoen]?

8 A. I don't know him.

9 Q. Domagoj Covic, what about him?

10 A. No.

11 Q. Ivica Boskovic, what about him?

12 A. No.

13 Q. What about the Kasalo brothers, Ivica, Niko, and Drago?

14 A. The names ring a bell.

15 Q. Did you know these people personally or did you only know their

16 names?

17 A. I didn't know them personally but I'm familiar with their names.

18 Q. Do you know that they were members of the ZNG?

19 A. I can't say.

20 Q. What about Ivica Matkovic?

21 A. It's not familiar.

22 Q. Thank you. Can you please explain in some detail whether you

23 personally heard the conversation between that officer you mentioned and

24 Vesna Bosanac at the hospital? When did this take place and where, and

25 did you ever hear the substance of this conversation? Or did anyone

1 perhaps tell you about it?

2 A. I didn't hear about this from anyone. I wasn't told by anyone. I

3 was near enough to hear the conversation. I was three or four metres away

4 from them when it happened. I used to walk around quite a lot in order to

5 me for myself what was going on. At 7.00 in the morning, this gentleman,

6 the JNA officer, spoke to Dr. Bosanac, saying that she was no longer in

7 charge of the hospital but, rather, that he now was. This was at the

8 entrance to the hospital basement, where the surgery rooms were, and the

9 Crisis Staff. Or, rather, the doctor's office.

10 Q. Dr. Bosanac's office, is it near the plaster room on the ground

11 floor?

12 A. Yes.

13 Q. You also described the appearance of my client, Dr. Sljivancanin.

14 You personally hear when he said that everybody should go to a meeting in

15 the plaster room or were you told this by one of the medical staff?

16 A. That was straight after the JNA officer spoke. Mr. Sljivancanin

17 came immediately after that. I was still there. It happened between the

18 doctor's office and the plaster room.

19 Q. You personally heard those words that Mr. Sljivancanin spoke about

20 the meeting in the plaster room?

21 A. Yes.

22 Q. Can we please go briefly into private session?

23 JUDGE PARKER: Private.

24 [Private session]

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23 [Open session]

24 THE REGISTRAR: We are back in open session, Your Honours.

25 MR. LUKIC: [Interpretation]

1 Q. I may be repeating myself, but I have a problem with this

2 timeline, so I apologise in advance if you feel you've already answered

3 any of these questions. Can you tell us approximately when you got off

4 that bus on Gunduliceva street? What time was it?

5 A. It was about 9.00 or 10.00.

6 Q. Can you tell me how long the buses remained there after they left

7 Gunduliceva street?

8 A. They only stayed for about five minutes, very briefly. They

9 turned around right there in front of us and drove back to the centre.

10 Q. How much time elapsed between the time you stood near the fence

11 and the time that Sljivancanin approached you or the time that you were

12 brought to see him? Were you still standing there or did you return to

13 the hospital building?

14 A. Up to an hour, and then Mr. Sljivancanin approached us.

15 Q. Between the time you saw him that morning at 7.00 and the time he

16 came up to you, he never spoke to you between these two times?

17 A. No. He never spoke to us and I never saw him.

18 Q. You described to Prosecutor Moore today what happened with

19 Mr. Sljivancanin. Did he do the same thing in relation to all five of

20 you, check your identity and see if you were on that handwritten list, if

21 I understand you correctly, to see if you were all on the list? Were you

22 in a position to see that?

23 A. Yes, I was. All five of us were standing around Mr. Sljivancanin

24 in order to get a look. He was holding this list and he asked us if we

25 were on the list. The five of us were actually standing around him

1 looking at the list, all five of us realised that we were not on the list,

2 and we said so, and then Mr. Sljivancanin added our names towards the

3 bottom of the page.

4 Q. Do you perhaps remember if he compared -- rather, I don't think

5 I'll be asking that question.

6 After you were, as it were, added to that list, did you still have

7 soldiers escorting you or were you from now on free to move about the

8 hospital?

9 A. We were sent back to the basement, the hospital basement. Rather,

10 those two JNA soldiers walked us back to the hospital basement.

11 Q. So that's where you stayed until you headed for the buses on Ivo

12 Lola Ribar street?

13 A. Yes, but in the meantime --

14 Q. Were you in the basement all this time, the hospital basement,

15 until you left?

16 A. Yes, yes.

17 Q. Just one or two questions remaining, briefly. When you left the

18 basement, in order to be evacuated, if I can put it that way, when you

19 left for the buses that eventually took you to Mitrovica, did you stay for

20 some time in the courtyard or did you go straight from the basement to the

21 buses?

22 A. No. The soldier who took me to one side, I was with him, and then

23 nurse Vuka came. It was then that I came outside, because the women and

24 children and civilians were no longer there. They were already on the

25 buses when -- between the time that I met Vuka and the time I got on to

1 the buses I didn't linger anywhere.

2 Q. Did you perhaps at this time see any European monitors or

3 International Red Cross people anywhere near the spot?

4 A. I don't remember.

5 Q. You described what happened once you got on to the bus. My

6 understanding is, at this point in time, the buses were parked outside the

7 hospital perimeter on Ivo Lola Ribar street?

8 A. Yes, that's right.

9 Q. There were those people banging on your bus and making threats.

10 Did you identify these as regular soldiers or Territorial Defence or

11 volunteers?

12 A. I think they looked more like TO, Territorial Defence.

13 MR. LUKIC: [Interpretation] That concludes my cross-examination,

14 Your Honours. Thank you very much.

15 Thank you, sir.

16 JUDGE PARKER: Thank you, Mr. Lukic.

17 Mr. Moore?

18 MR. MOORE: I have no re-examination, thank you very much.

19 JUDGE PARKER: Thank you.

20 May I thank you for your attendance here and the evidence that you

21 have given. You'll be pleased to know that that concludes your evidence

22 and you're now free to leave and you will be assisted with your return to

23 your home. So thank you very much and you may now be guided by --

24 THE WITNESS: [Interpretation] Thank you.

25 JUDGE PARKER: -- the officer who must first close the shutters.

1 [The witness withdrew]

2 JUDGE PARKER: Yes, Mr. Moore?

3 MR. MOORE: The next witness that we will seek to call is P013. I

4 believe that Mrs. Tuma should be outside, I hope, the door and she will

5 deal with that witness.

6 With regard to the protective measures it is voice distortion,

7 face distortion, and pseudonym.

8 JUDGE PARKER: These shutters need to be down as they come in? I

9 think the answer is yes. So we had better ...

10 [The witness entered court]

11 JUDGE PARKER: Good evening.

12 THE WITNESS: [Interpretation] Good evening.

13 JUDGE PARKER: May I ask you to read aloud the affirmation on the

14 card that is now given to you.

15 WITNESS: WITNESS P013

16 [Witness answered through interpreter]

17 THE WITNESS: I solemnly declare that I will speak the truth, the

18 whole truth, and nothing but the truth.

19 JUDGE PARKER: Thank you. Please sit down.

20 Yes, Mrs. Tuma.

21 MS. TUMA: Yes, thank you, Your Honour. [Microphone not

22 activated]

23 THE INTERPRETER: Microphone, please, for the counsel.

24 MS. TUMA: Thank you. It's late in the afternoon, so ...

25 Okay. Thank you, Your Honour.

1 I would like to request for a private session now because we are

2 dealing with a protected witness and in order to have the witness to

3 confirm some details about the witness.

4 JUDGE PARKER: Yes. We will have private session.

5 MS. TUMA: Thank you, Your Honour.

6 [Private session]

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24 [Open session]

25 MS. TUMA:

1 Q. In August 1991, were you then living in Vukovar?

2 A. Yes.

3 Q. And could you be able -- were you living in your own home at the

4 time? And now I'm talking about August 1991.

5 A. I lived in my own house, yes.

6 Q. And could you stay there further on?

7 A. I lived there until mid-September, until the end of September. At

8 that time, I had to leave because shells kept landing every day in that

9 area, or, rather, throughout the whole city, and in that area as well,

10 including my house.

11 Q. Were there other areas as well that was shelled? Do you have any

12 knowledge of that?

13 A. The whole town was shelled.

14 Q. And any other areas outside the town?

15 A. I didn't go outside the town.

16 Q. Did you hear anything from others talking about if there were

17 other areas outside the city that were shelled at this time?

18 A. I heard from others that all the villages inhabited by Croats were

19 shelled.

20 Q. And you mentioned here that you could not be able to stay in your

21 home from mid-September. What did you do then?

22 A. I went to the hospital, the Vukovar Hospital, because all of us

23 believed that the hospital would be spared from shelling and that we would

24 be safer there. (redacted)

25 (redacted)

1 Q. Okay. Thank you. And I would like to also to remind the witness

2 that we are in open session. So when answering the question, do not

3 reveal your identity.

4 And how was the conditions in the hospital from your point of

5 view, from, let us say, from the time when you arrived there in

6 mid-September until mid-November? Can you give us a picture how it looked

7 like, how it was for you and the other staff in the hospital?

8 A. The situation was very difficult. There was no water, no

9 electricity. There were a lot of wounded persons. Everybody who lived in

10 Vukovar and remained there, if they wanted to go and find some water for

11 themselves, were killed by shells. Every day, very many people were

12 killed. And the wounded were transported to the hospital.

13 Q. We are still in open session now. So how was -- you mentioned

14 here water. Were there any specific difficulties to get access to water?

15 A. There were people who were tasked with that. Firemen went with

16 cisterns to get water. They went and filled water tanks. In addition to

17 that, we also had wells around Vukovar. Every time they went to get

18 water, somebody would report that, and then everybody who went to fetch

19 water would be killed by a shell.

20 Q. Were there any rumours or were there any explanation why it was so

21 that the people that went to fetch water were killed, and the firemen?

22 A. I don't know how to answer your question. Simply -- simply, the

23 Yugoslav army believed that in Vukovar, in the city itself, there were

24 only Ustashas and that all of them ought to be killed.

25 Q. Okay. Thank you. Were there any attempts from the hospital side

1 in order to try to stop the shelling?

2 A. Dr. Bosanac sent appeals on the radio, and I don't know where

3 else. I didn't hear it myself, but I heard that there were appeals on

4 Radio Vukovar to halt the shelling. As for her negotiating with anybody

5 else about stopping the shelling, I don't know about that, because I

6 didn't hear that. However, we heard her talk on the radio, appealing for

7 the shelling to cease and saying that there were many infirm people in

8 town, women and children.

9 Q. Thank you. Can you just describe the intensity of the shelling of

10 the hospital? And now we are talking about from mid-September until

11 mid-November.

12 A. Airplanes flew over the hospital. I was personally present when

13 bombs fell. They said that this bomb was called Krmaca. It's a huge

14 bomb, which fortunately did not explode. It fell on a patient between his

15 legs. He was lying on a bed, and the bomb landed between his legs. The

16 hospital was shelled every day and the area around the hospital as well.

17 Q. Can you describe the shelling? You said he had shelled every day.

18 How intense was it? Was it one time or several times during the day?

19 A. It was so bad that one couldn't get outside from the underground.

20 Whoever got outside was killed.

21 Q. What do you meaning by outside? Outside the hospital building or

22 outside the hospital yard?

23 A. I mean from the underground. We were in the atomic shelter, below

24 the ground level.

25 Q. For how long time period did this continue, that you couldn't go

1 outside or outside the atomic shelter?

2 A. The whole of October, until Vukovar fell.

3 Q. Thank you. Can you describe what happened because of this

4 shelling with the hospital itself? Was it damaged in any way, and in what

5 terms, then?

6 A. The hospital was quite damaged. It didn't have the roof, didn't

7 have the second storey. Everything was damaged. Everybody moved into the

8 atomic shelter underground. Everybody was there. The patients, the

9 wounded, doctors, nurses, everybody was under the ground level.

10 Q. And how about the rest of the floors? What had happened to them?

11 A. Everything above was shelled. We couldn't be there. There were

12 no windows, no doors, no roof.

13 Q. And while you were working there, did you see what -- could you

14 move around in those areas that were accessible, so to say, in the

15 hospital?

16 A. For a while, we could go to the old kitchen, the real kitchen of

17 the hospital. Later on, they kept firing continuously, everything was

18 destroyed. It was full of glass shards. And then we went to that atomic

19 shelter, as I told you. Throughout that entire period of time, I didn't

20 leave the hospital, or rather, this atomic shelter.

21 MS. TUMA: Your Honour, I would like to, just for one question, go

22 into private session.

23 JUDGE PARKER: Private.

24 MS. TUMA: Thank you.

25 [Private session]

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10 [Open session]

11 MS. TUMA: Thank you.

12 Q. How about the rest of the patients in the hospital? Were there

13 different ethnicities of the patients? Can you please describe about the

14 category so to say of the patients in the hospital?

15 A. The shells in Vukovar were not selective. They did not discern

16 among Serbs, Croats, Romas and so on. The shells wounded everybody.

17 Patients were of different ethnicities. All of them were wounded in their

18 own city by shells and shrapnels.

19 Q. Thank you. And how about were there any kind of army, wounded

20 army men in the hospital? And what kind of categories so -- if so?

21 A. I don't know who was there. There was combat going on there, and

22 the soldiers were brought to the hospital but I couldn't tell you who they

23 belonged to.

24 Q. Did you see any arms inside the hospital, weapon?

25 A. I didn't.

1 Q. Thank you. And the hospital, was it marked in any way?

2 A. There was some white fabric or a flag with the red cross or

3 perhaps it was a bed sheet. I'm not sure. But there was something.

4 Q. And do you lap to know where it was located?

5 A. As you come in to the main entrance of the hospital, on the left,

6 there was some kind of an infectious diseases ward, and this is where this

7 flag was. In addition to that, in the yard, there were two huge, huge

8 sheets spread out in the hospital yard.

9 Q. Okay. Thank you. And do you have any knowledge even if you were

10 working with different issues so to say inside the hospital, how the

11 different people -- patients were treated while being patients in the

12 hospital?

13 A. To the extent that I was able to judge, being no nurse or doctor,

14 they were treated in the best possible way. There were precious little

15 supplies to go around, or medicines or medical equipment. There was too

16 little of everything but everybody was helped. I knew several people

17 there. They belonged to different ethnic groups, and they were lying

18 there, their wounds dressed, and what I can say is that everybody was

19 receiving the same treatment. At least that's what I saw.

20 Q. Thank you. And how long did the shelling continue? When did it

21 stop, of the hospital?

22 A. The shelling stopped when the shelling of the town itself stopped.

23 I really can't give you a precise date, whether it was the 17th or the

24 18th. Possibly the 19th. But these are the dates to be considered. At

25 this time, the shelling stopped. The other side were already saying that

1 they had liberated Vukovar, things being said over a PA system, saying

2 that everybody in town should surrender. This began on the 17th,

3 continued on the 18th and the 19th.

4 Q. When this happened, when the city fell, what did -- did that cause

5 any consequences for the hospital itself?

6 A. The consequences were great for the hospital. People were taken

7 away. Everybody was taken away, never to reappear.

8 Q. When the city fell, were you in the hospital at that time?

9 A. Yes, I was.

10 Q. And if I say that the city fell on the 18th November, could that

11 be a correct recollection?

12 A. That would be correct.

13 Q. Did you see any people entering the hospital on that day?

14 A. An enormous number of people came to the hospital on that day.

15 When the town fell, people were frightened because the army was coming in

16 that had been shelling us and killing us for three months. People thought

17 that they would reach salvation once inside the hospital.

18 Q. Did you see the people coming into the hospital?

19 A. Yes.

20 Q. Can you estimate any number from that day, from the first day? We

21 are talking about the 18th of November.

22 A. There were lots of people, 3.000 or 4.000 people, thousands of

23 people. The courtyard was full.

24 Q. Is that how you experienced it, that it was so many people that

25 were arriving during that day?

1 A. Wherever I looked through the window, there were people all over,

2 everywhere inside the hospital perimeter, women, children, the entire

3 population of Vukovar.

4 Q. And what were the -- became the conditions inside the hospital

5 when so many people arrived at the same -- more or less during one day?

6 A. There was panic and great fear, because we didn't know. We didn't

7 know what was in store for us. We were just frightened, scared witless.

8 Q. And why did they come to the hospital? Did you get any knowledge

9 about that?

10 A. Why the JNA came, you mean?

11 Q. I'm sorry, no, the civilians or the people that were arriving in

12 huge mass into the hospital.

13 A. The civilians were normally in the cellars of their own houses.

14 When the announcement came through that Vukovar had fallen, the civilians

15 were afraid that the army would take them somewhere and then they ran to

16 the hospital to seek safety there, in the belief that the army would not

17 be taking anyone away from the hospital in order to kill them.

18 Q. Thank you. And still on the 18th November, did you get any

19 knowledge about an evacuation agreement during that day?

20 A. On that day, I was inside looking out through the window. Some

21 lorries were arriving in the hospital courtyard. People were loaded on to

22 these lorries and taken somewhere but I have no idea where they were taken

23 to.

24 Q. I would like to move on to the next day, and that is on the 19th

25 November. Do you remember what happened during that day? That was the

1 day after Vukovar fell. And please be reminded now that you are in open

2 session so don't mention any names that could reveal your identity.

3 A. On the morning of the 19th -- it's one thing that I forgot to say,

4 it was on the evening of the 18th that the army had arrived and surrounded

5 the hospital. They spent the night there.

6 Q. May I ask you what army are you then referring to?

7 A. The JNA.

8 Q. And how do you know that?

9 A. That it was the JNA? I know because they were armed, they

10 arrived, and they surrounded the hospital.

11 Q. Did you see that?

12 A. Yes, I did.

13 Q. And from where?

14 A. Through the window.

15 Q. When you have referring to from the window a couple of times, from

16 where in the hospital were you that you made those observations?

17 A. When the army surrounded us on the 18th, the shelling had already

18 ceased. We were no longer underground. We were now able to come up to

19 the first floor. We were able to walk around the hospital because we were

20 no longer in danger of being killed by someone. And that's where I saw

21 the soldiers from, a whole lot of soldiers, armed, in the hospital

22 courtyard.

23 Q. When you're referring to the hospital courtyard, is it -- can you

24 explain more where it -- that courtyard is relating to the hospital

25 building or the buildings of the hospital?

1 A. Well, there is the building. You take a staircase and right

2 there. There is the courtyard for you. The perimeter, the perimeter of

3 the hospital.

4 Q. Were there more than one building that the hospital comprised of?

5 A. Yes, the new building and another one that was old. But it's all

6 nearby.

7 Q. And the courtyard, how is that in relation to those two buildings

8 that you just mentioned?

9 A. Well, it's -- between the two buildings, you walk. There is a

10 road of some sort, something like that.

11 Q. Okay. Thank you. So the army was surrounding the -- or you saw

12 the army in the courtyard in the evening of the 18th; is that correct

13 understood of me?

14 A. Yes.

15 Q. Where were you during the night, then, until the 19th November?

16 A. Between the 18th and the 19th, well, I spent the night to the

17 extent that I was able to sleep, hardly slept a wink, as a matter of fact.

18 On the morning of the 19th, it must have been between 6.30 and 7.00 a.m.,

19 we had to leave the hospital building, leave the building, all of us leave

20 the building.

21 Q. How about the patients in the hospital? Were there any patients

22 at that time? You were talking about that civilians were, people arriving

23 to the hospital. Were there patients as well at this time?

24 A. There were patients and an order had come through that all those

25 who were able to walk and who were slightly wounded should leave the

1 hospital, and those seriously wounded remained in their beds.

2 Q. I would like to go back to the 19th November. Do you have a

3 recollection that this happened on the 19th or some other day, that you

4 were just mentioned right now?

5 A. It was on the 19th, the morning of the 19th, at between 6.30 and

6 7.00 a.m. We were still asleep when an order came that we should leave

7 the hospital building, that we should leave the building, leave it.

8 MS. TUMA: Your Honour, this is --

9 THE WITNESS: [Interpretation] Oh, no, no, no. It wasn't the 19th,

10 I'm sorry, no. No. I got the dates mixed up. It was on the 20th. On

11 the morning of the 20th.

12 MS. TUMA:

13 Q. I would like now to go back to the 19th, the day before the 20th

14 November. Do you remember what happened during that day, with any

15 specific that you remember?

16 A. We were all scared. We were inside. There was a lot of

17 commotion. There was still plenty of wounded and civilians all over the

18 place. Nobody any longer knew what they were doing. We were all really

19 scared on the 19th, if that's what you're asking about.

20 JUDGE PARKER: Is that a convenient time, do you think, Mrs. Tuma?

21 MS. TUMA: Yes, Your Honour.

22 JUDGE PARKER: We will adjourn now to resume on Monday next, at

23 2.15 in the afternoon. The following days of the week are to be at 9.00,

24 but on Monday it will be at 2.15.

25 --- Whereupon the hearing adjourned at 7.01 p.m.,

1 to be reconvened on Monday, the 7th day of November

2 2005, at 2.15 p.m.

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