Witnesses: Witness F & Mr Stevan Gligorevic

align Page 1326

1   Thursday, 27th March 1997

2   (10.00 am)

3   Witness F (continued)

4   Examined by MS McHENRY (continued)

5   JUDGE KARIBI WHYTE: Good morning, ladies and gentlemen.

6   Can we have the witness now?

7   (Witness enters court)

8   JUDGE KARIBI WHYTE: Ms McHenry, I think we are on

9   cross-examination, or are we still leading?

10   MS McHENRY: We are still on direct examination.

11   JUDGE KARIBI WHYTE: You are leading the witness.

12   MS McHENRY: Guiding.

13   Sir, yesterday in your testimony you referred to

14   Mr Landzo, called Zenga. Did you know Mr Landzo before

15   you were at the camp?

16   A. (in interpretation): No.

17   JUDGE KARIBI WHYTE: I am not sure we have reminded him he

18   is still on his oath.

19   MS McHENRY: I am sorry.

20   A. Yes. I will continue to speak the truth and nothing but

21   the truth.

22   JUDGE JAN: And the whole truth.

23   MS McHENRY: How did you know -- how did you learn who

24   Mr Landzo was?

25   A. I found that out from the others who were in Number 6,

Page 1327

1   and the nickname "Zenga" I found out very quickly, and

2   later I found his name and last name.

3   Q. How often would you see Zenga at the camp approximately?

4   A. Almost every day.

5   Q. What was his function at the camp?

6   A. He had the role of a guard.

7   Q. Can you describe what he looked like in 1992, while you

8   were at the camp?

9   A. He was shortish. He often had his head shaved, and then

10   he also shaved the sides above the ears and was leaving

11   the top, and then later he shaved his whole head. He

12   was bald.

13   Q. Can you recollect: was he there your entire time that

14   you were in Celebici, or was there a time when you no

15   longer saw him?

16   A. There was a time, and I can't recall the month now, he

17   went somewhere, and then later he reappeared with a

18   white belt. He came on two or three occasions, and was

19   taking out Dusko Bendjo. I don't know what they were

20   talking about, but after that I heard that he was

21   calling him for some German Marks, but he was not

22   appearing at the camp, only at the gate, and then he

23   would leave. I think that was in late August, early

24   September.

25   Q. Yesterday, sir, you also mentioned Hazim Delic. Did you

Page 1328

1   know Mr Delic before you were at the camp?

2   A. No.

3   Q. How did he learn who he was?

4   A. The second day after I was put in Number 6, when we went

5   out, he was sitting to the right, that is the left-hand

6   side, and you could recognise him really well because of

7   the crutches he had on, and I asked Radoslav Vujcic who

8   it was, and he told me it was him. Later I could

9   recognise him because of the crutches. His name -- that

10   is the second -- since the second day I knew his name.

11   Q. Approximately how long did Mr Delic have crutches, if

12   you ...

13   A. I don't remember how long. He had it on for a while,

14   and he sat in Number 6 on a crate down on the right-hand

15   side somewhere to the right, against the tin wall, but I

16   don't know how long it was, because a lot of time has

17   passed since all this occurred, but it was a short

18   period of time. I don't know how long.

19   Q. Can you describe him besides the fact in the beginning

20   he had crutches?

21   A. He was well-built, tall. He also had his hair cut

22   short. At first he had one pistol and one automatic

23   rifle, which was fairly short. It was like a machine

24   gun or something. Then he had an automatic rifle. Then

25   he had another pistol, a bit longer one, on the other

Page 1329

1   side. When we walked, he walked swaggering with his

2   arms apart.

3   Q. How often would you see Mr Delic in the camp?

4   A. Almost every day. He would come every morning to the

5   camp, not the same time every morning, but every morning

6   just about he would come.

7   Q. Do you know what his function was in the camp?

8   A. Because the guards had -- the guard --

9   Q. Excuse me, sir. Can we stop for one minute. I believe

10   we missed some of that last translation. I don't know

11   if the translator can repeat it. I need to have the

12   witness start from the beginning?

13   JUDGE ODIO BENITO: Me too.

14   THE INTERPRETER: You want to start where it was ...

15   MS McHENRY: I am sorry, sir. Because of a problem with

16   the equipment, those of us who do not understand your

17   language did not hear your response. Can you once again

18   start from the beginning and answer, if you know, what

19   Mr Delic's function in the camp was?

20   A. The role of Mr Delic, of Delic, I don't know what it

21   was, but I know that when he would appear, we had to get

22   up, and the guards told us when he would appear. They

23   said: "Here comes the boss", and he would come every

24   morning, and based on that I think that most probably he

25   was the Deputy Commander of the camp.

Page 1330

1   Q. Did you ever see his relationship with the other

2   guards? Were the other guards ever giving him

3   instructions, or vice versa; he was giving the guards

4   instructions, the other guards?

5   A. He was issuing orders to other guards. I can give you

6   an example that I remember very bell: it relates to

7   what I was talking about yesterday. When the policemen

8   were killed near Repovci and later on it was found out

9   it was the Muslims who killed them, he ordered Landzo

10   that this would be breakfast, lunch and dinner for the

11   people of Bradina, and Landzo carried out his orders

12   after that.

13   Q. In addition to what you observed about Mr Delic while

14   you were at the camp, did you learn anything else about

15   who had any responsibility or position in Celebici? For

16   instance, did you ever learn who was in charge of the

17   camp?

18   A. I found out that the head of the camp was Pavo Mucic and

19   that Delic was his deputy. I heard that from people who

20   knew them very well and from our people who were on the

21   outside, and who were delivering us food. For instance,

22   Nenad Kujundic and then Davor Bendjo and others, because

23   when the camp Commander would come, and I only saw him

24   three times, first Hazim Delic would come and would tell

25   us to get up, because the Commander was coming, so we

Page 1331

1   had to get up, and he would go from one person to the

2   next, and I saw him on three occasions in the camp.

3   Q. Do you remember approximately when it was that you saw

4   Mr Mucic in the camp?

5   A. Approximately some time in late June or early July. I

6   wouldn't know exactly. It was after a group was

7   released, and he came then. We got up, and he separated

8   out the sick ones and the elderly and took them

9   somewhere, and later we heard from Nenad and from Bendjo

10   that the guards told them that they would be transferred

11   to Musala.

12   The second time there was a second group that also

13   left. He also came. We got up. He read the names out,

14   and he took them away. The third group, that was the

15   group where I was in, that was mid-October, that was on

16   8th October, yes.

17   Q. Even if you did not see him personally, did you ever

18   hear, while you were at the camp, that Mucic was present

19   in the camp?

20   A. I heard, while I was in the camp, that on one occasion

21   even those who knew him a bit better, when we were

22   beaten, they thought about asking Pavo Mucic whether he

23   knew about these murders and these beatings that were

24   taking place, and to complain to him, but nobody dared

25   ask him that.

Page 1332

1   Q. Did you ever hear from the guards or from noises outside

2   any indication that Mr Mucic was in the camp?

3   A. I did not understand the question.

4   Q. Do you know how Mr Mucic would arrive at the camp, what

5   transportation he would use?

6   A. Yes. To Number 6 he would mostly come on a motorcycle,

7   and I could learn that from the guards. When you heard

8   the sound of the motorcycle, they would say: "Here comes

9   the Commander." They would say: "Just put your hands on

10   your knees." But he would not come in, but from those

11   who were outside, we heard that he did come.

12   Q. Sir, without giving the names of any of the prisoners

13   involved, can you tell the court whether or not you ever

14   observed any sexual mistreatment while you were at

15   Celebici?

16   A. Yes. Two brothers were brought in later --

17   MS McMURREY: I am going to object. The question was

18   whether he ever received any sexual treatment at

19   Celebici. He is not answering her question.

20   Non-responsive.

21   MS McHENRY: If counsel will check her transcript, my

22   question was whether or not he observed any sexual

23   mistreatment.

24   MS McMURREY: I apologise. Ms McHenry is correct. Excuse

25   me.

Page 1333

1   MS McHENRY: Sir, again, please without giving the names of

2   anyone involved, please tell us what you observed.

3   A. I saw two brothers, to whom the guard ordered to put

4   their sexual organs into each other's mouths.

5   Q. Where did this occur?

6   A. In Hangar Number 6 in front of all of us. I think there

7   were over 200 of us there.

8   Q. Do you remember who the guard involved was?

9   A. Yes.

10   Q. Who was the guard involved?

11   A. That was Landzo, Esad Landzo, called Zenga.

12   Q. Sir, did you ever see any prisoners mistreated by use of

13   a detonation cord?

14   JUDGE JAN: Excuse me. Can he give us an approximate date

15   when this thing happened, May, June, July; when?

16   MS McHENRY: Going back to the incident where the persons

17   were made to put their sexual organs into each other's

18   mouths, if you know, approximately when was that?

19   A. I don't know exactly, but I know that it was day-time,

20   but I don't know the time.

21   Q. Do you know approximately what month it was, if you

22   know?

23   A. I can't recall. They were brought in after us. That

24   could be late June or early July. I cannot tell you

25   exactly, but I remember it as if I were seeing it now.

Page 1334

1   Q. I am sorry. Just to clarify, were they brought in in

2   late June or early July, as best you can remember, or is

3   late June or early July when the incident happened?

4   A. They were brought in after us, maybe fifteen, twenty

5   days after us, and they were first beaten and then that

6   was -- I don't know exactly. I think it was early July,

7   maybe late June. I couldn't answer precisely to that

8   question, because a lot of time has passed and I cannot

9   recall exactly.

10   Q. Okay. Thank you, sir. Sir, did you ever observe any

11   mistreatment with use of a detonation cord?

12   JUDGE KARIBI WHYTE: Why are you suggesting the nature.

13   MS McHENRY: I do not know how -- he has already discussed

14   so many kinds of mistreatment that I am trying to draw

15   his attention to something in particular without

16   suggesting.

17   JUDGE KARIBI WHYTE: I think you are. Ask him the type of

18   mistreatment he observed, the types.

19   MS McHENRY: Okay. Sir, besides what you have already told

20   us about, were there other incidents of mistreatment

21   that you observed?

22   A. Yes. I remember well Landzo, called Zenga, had a small

23   bottle filled with gasoline, and he spread it around the

24   concrete and lit up some paper and asked Djordjic to

25   open up his mouth. He was heating the knife on it, and

Page 1335

1   then he was putting also something into his ear. He was

2   begging, but he put it in anyway. When he took him out

3   -- when he took out Nedjo Draganic, when Nedjo came

4   back, he was sitting down from me. The door closed.

5   When he returned, he showed his legs and they were

6   burned. I remember Spasoje Miljevic --

7   Q. Let me go back. If you remember, who was it who took

8   Mr Draganic out?

9   A. Draganic was taken out by Landzo, nicknamed Zenga.

10   Q. Okay. Sir, please --

11   JUDGE JAN: Is it not appropriate to get from him the month

12   so we can be a bit more specific, approximately.

13   MS McHENRY: Sir, if you remember, can you remember when

14   this incident, for instance, with Mr Draganic occurred,

15   what month, if you can tell us?

16   A. It was also in June or maybe early July. I can't tell

17   you the exact dates, because I really can't remember

18   now, but I am telling you the truth. It was, as I said,

19   in June or early July. The same day or next day the

20   same thing happened to Spasoje Miljevic and later I saw

21   blisters on Spasoje Miljevic's hands, but again I don't

22   know the exact date; in June, early July.

23   Q. In respect of the incident where the knife was being

24   heated up, I believe it was with Mr Djordjic and

25   something was put in his ear; do you know when that

Page 1336

1   was?

2   MS McMURREY: I am going to object to the leading form of

3   the question.

4   JUDGE JAN: He has mentioned the incident. We are just

5   trying to find the approximate time when it happened.

6   MS McMURREY: Okay.

7   JUDGE JAN: In fact, it will be of help to you.

8   MS McMURREY: I hope so.

9   MS McHENRY: Always my goal!

10   Sir, if I remember the incident with respect to

11   Landzo heating up the knife and Mr Djordjic, can you

12   approximate when that was, what month, if you remember?

13   A. This was all happening within a day or so, all those

14   instances of burnings, late June, early July. I don't

15   know exactly.

16   Q. Okay. Are there other incidents of mistreatment, sir,

17   that you remember?

18   A. I remember also that Landzo, nicknamed Zenga, took out

19   Jovo Kuljanin and he brought him back with a mask and

20   sat him down on his place, and he sat there for a long

21   time with a mask and then he took off the mask and it

22   was very hard for him to come to. There were many

23   incidents, but it has been a long time and it's hard for

24   me to remember.

25   Q. Sir, was there a time when the camp was visited by the

Page 1337

1   International Red Cross?

2   A. In mid-August the International Red Cross arrived.

3   There was a doctor with them. Then they removed the

4   guards and examined the sick and gave the others the

5   opportunity to communicate with their families, and

6   after the ICRC left, Hazim Delic arrived with five or

7   six other guards, and he ordered us all to face left and

8   to sit down, and then they started beating us on the

9   kidneys, kicking us with their boots. The guards were

10   doing that. Then he said: "I'll give you Red Cross.

11   This is the Red Cross for you." It lasted for a long

12   time.

13   Q. Who was it who said: "This is your Red Cross", sir?

14   JUDGE JAN: Delic, he said.

15   A. It was Hazim Delic. He said: "This is the Red Cross for

16   you have. I'll give you the Red Cross." He ordered the

17   guards to beat us. They beat us and kicked us in the

18   kidneys. They had boots on their feet. They beat all

19   of us in the camp.

20   Then the next day the Red Cross showed up again.

21   We didn't want to talk to them. They were telling us:

22   "Well, say what happened." Somebody probably did tell

23   them what happened. They went to those in the authority

24   and told them not to do that. Then for a while there

25   were no beatings. Instead -- apart from some individual

Page 1338

1   incidents. For instance, Nedjeljko Samoukovic and

2   Vukasin Mrkajic, and then Vukalo, whose first name I

3   can't recall, Dusko Bendjo, and as for us, the others,

4   they let us alone for a while. Then after that on one

5   occasion Hazim Delic came --

6   Q. Sir, let me just interrupt you for one second, if I

7   may. Approximately how long did this while last when

8   there were not a significant number of beatings, if you

9   can estimate?

10   A. For maybe fifteen days, something like that, around

11   fifteen days. Then after that Hazim Delic came in. He

12   had in his hand a shovel. He told us to face away and

13   started beating us on our backs with the shovel. Then

14   he made one round and then another, and then he handed

15   the shovel to another guard. I don't recall his name,

16   and he continued doing that.

17   Then after that he led out Vukasin Mrkajic in

18   front of all of us and he broke the shovel handle. He

19   was beating him on the back and he ordered him to take

20   off his pants and to walk around in the hangar so that

21   we can all see what happened to him.

22   Then they took out other people, such as Dusko

23   Bendjo, Nenad Dragotinovic, Zoran Djordjic, and some

24   others. They took them out and I could hear, although I

25   couldn't see, that they were beaten. Then they were

Page 1339

1   brought back in. Then after that Delic and the guards

2   left, got out, and we all remained there. After that

3   there were individual incidents, when people were taken

4   out, but while I was there there were no other incidents

5   in which all prisoners were beaten.

6   Q. Sir, were you allowed to play cards while you were in

7   the hangar?

8   A. For a while. They made playing cards with the cardboard

9   and the guards saw that. I was not involved in the

10   games but the guards saw them and didn't do anything to

11   them, but then Delic walked in and he asked: "Who was

12   making the cards?" Then he started beating us, all of

13   us. He asked Vukasin: "Who did it." Then, when he beat

14   Vukasin with the shovel, then Vukasin picked out people

15   who did it, and those people were taken out and beaten.

16   I don't know whether that was allowed or not, but the

17   guards saw that and nobody admonished anyone about that.

18   Q. Do you know approximately when it was that these people

19   were beaten for playing cards, what month or ...

20   A. I think it was in September.

21   Q. Sir, did you ever do any kind of work while you were at

22   the camp?

23   A. I did. We were taken out in groups and we went to

24   unload the weapons that had been brought in to two

25   tunnels. It was also in the compound.

Page 1340

1   Q. Do you know --

2   A. In the camp compound. So we went up there and unloaded

3   those weapons in groups.

4   Q. Do you know approximately when it was that you would

5   unload the weapons, what month, for instance?

6   A. It was in June and July.

7   Q. Okay.

8   A. I went there in July, I think in early July, and the

9   younger ones went before that, and later on there was

10   more of it, so we went there in groups, and we even had

11   to unload those weapons at night.

12   Q. Okay. Mr. F, how long did you remain at Celebici? When

13   was it that you left Celebici?

14   A. I left Celebici on 8th October and then I was

15   transferred to Musala. First a guard came and read out

16   our names and said -- he said: "Sit down." Then Hazim

17   Delic came. He read out those same names and told us to

18   step out, and he asked us our names and whether we had

19   fired any shots. Then he changed a couple of names and

20   told us to sit down. Then Delic and Pavo came

21   together. Our names were read out again and then in two

22   groups we were taken to Musala. I was in the second

23   group. We were driven in a Iveco van.

24   Q. How long did you remain at Musala?

25   A. I stayed there until 17th November, a month and eight

Page 1341

1   days, nine days.

2   Q. Were you released then when you left Musala?

3   A. I was released to the collection centre in Donje Selo,

4   where I stayed until 1st February 1993. Then I was

5   exchanged to Trnovo, through Igman to Trnovo. I did not

6   spend a long time there. I just spent one night there.

7   Then I was exchanged at Kalinovik.

8   Q. Either at the time you left Celebici or at the time you

9   left Musala, did you receive any kind of release

10   document?

11   A. Yes. I received a release form. It was signed by Hazim

12   Delic. I didn't take it with me. I don't have it here,

13   but it had his signature. My release form was signed by

14   him.

15   Q. Did you get the release form when you left Celebici or

16   when you left Musala?

17   A. Musala. After Musala we were taken back to Celebici.

18   We spent two or three hours there until the nightfall

19   and then Delic distributed the release forms to us.

20   Then he took us to Donje Selo and left us there. Then I

21   went to my wife's brother's house. There were three

22   other families there. I have lived with them for three

23   months.

24   Q. Sir, during the time that you were at Celebici or even

25   at Musala, were you ever charged with any offence?

Page 1342

1   A. No.

2   Q. Okay. One second, your Honour, please. Your Honour, I

3   have no more questions for this witness. Thank you.

4   JUDGE KARIBI WHYTE: Have you agreed on the order of

5   cross-examination?

6   MR O'SULLIVAN: Yes, your Honour. We will proceed in this

7   order. First, counsel for Mr Mucic; second, counsel for

8   Mr Delic; third, counsel for Mr Landzo, and fourth,

9   counsel for Mr Delalic.

10   JUDGE KARIBI WHYTE: Mr Greaves, you can ask your

11   questions.

12   Cross-examined by MR GREAVES

13   MR GREAVES: Thank you very much, your Honour. Mr F, I am

14   going to call you by the name, Mr F. You will

15   understand the reasons for that, will you not?

16   A. Yes.

17   Q. Thank you very much. Mr F, I want to ask you, first of

18   all, about the initial visit of police and military to

19   your village, when you were arrested. That was at the

20   village of Bradina, was it not?

21   A. Yes.

22   Q. Can you help me about this, please: amongst the group

23   of police officers that you recognised was a man called

24   Zvonko Zovko. Forgive my pronunciation, please.

25   A. In Bradina, no. I didn't even mention him. When we

Page 1343

1   were arrested in Bradina I mentioned a foreign national,

2   and I did not mention the police. Those were people who

3   arrested us; those were people in black uniforms and

4   camouflage uniforms. Among them there was a foreign

5   national and among the people who I knew was Redzo

6   Balic.

7   Q. Did there come a time when you saw Mr Zovko?

8   A. I did not mention Zovko there. I mentioned him in the

9   camp, not there.

10   Q. Was he someone who took part in the beatings at the date

11   of the camp?

12   A. By what my father told me, and he was about five people

13   away from me, he said: "Why are you beating me, Zovko?"

14   He said: "Who is Zovko?" Then he cursed his mother.

15   That is all I know. Afterwards he beat my father.

16   That's what he told me, and he said he would put a sock

17   in his mouth to gag him.

18   Q. From what you were told, that police officer was someone

19   who took part in the beatings at the gate of the camp?

20   A. Yes.

21   Q. What happened at the gate, that was the worst thing that

22   happened to you and your fellow citizens?

23   A. Yes.

24   Q. I am sorry. Please finish answering the question.

25   A. That was the most -- the hardest thing that I could

Page 1344

1   imagine could happen to me. I asked three times to kill

2   me, and now that you are reminding me, I forgot to say

3   that Gojko Miljanic was beaten there and he was taken to

4   Number 6 and died in the arms of his son, Savo. Now you

5   reminded me, Petko Gligorevic also died there, and it is

6   unbelievable that one man could do that to another.

7   Q. Is it right that the people doing the beating up at the

8   gates were a mixed group of police and soldiers,

9   military men?

10   A. I said that I did not know who these people were,

11   because as soon as we were lined up against a wall,

12   facing it, with our hands leaning against a wall. Now

13   who beat whom -- there was a lot of them and they took

14   turns, and they beat until the exhaustion.

15   Q. Was a man called Sefko Niksic amongst those police

16   officers at the gates of the camp?

17   A. I could not recognise anyone, because already in Bradina

18   I had been beaten there, and as I came, I could not

19   recognise anyone.

20   Q. Mr F, I want to ask you now please about your knowledge

21   of Mr Mucic. Is it right that the time when you were

22   most aware of him was the time when releases were taking

23   place from the camp?

24   A. The first group he released, as I said. That was late

25   June, early July. They went somewhere, and then later

Page 1345

1   we found out that they went to Musala. The second group

2   was also taken to Musala, and I was in the third group.

3   Q. Mr F, quite a lot of the evidence that you have given to

4   this Tribunal has been of a kind where you are uncertain

5   about dates. Would you accept that?

6   A. Yes, because a lot of time has passed.

7   Q. Of course, and I mean no criticism of you. It is nearly

8   five years, is it not, since this all happened?

9   A. Yes.

10   Q. To be fair, would you accept that your memory as to

11   specific dates is really not very good at all?

12   A. I did not understand that.

13   Q. Your memory for dates concerning the incidents which

14   happened at Celebici, your memory is not very good as to

15   precise dates?

16   A. I cannot recall specific dates. If I could, I would not

17   be -- I would not have been abused as much, but we were

18   in such fear, and we thought whether we would be taken

19   out or not. I mean, this was my feeling. It was very

20   difficult to remember, and now it's very difficult to

21   remember that.

22   Q. Of course, Mr F, and I make it plain to you that I am

23   not criticising you in any way at all for being unable

24   to remember dates. What I want to suggest to you is

25   that the time of the releases from the camp was, in

Page 1346

1   fact, in August 1992. Would you accept that that may

2   well be right?

3   A. When they were released to be exchanged, or when they

4   were leaving Number 6? I did not understand that

5   question.

6   Q. Let me make it plain that it is being released either to

7   go to Musala or being released totally?

8   A. The prisoners who were being released to Musala, it was

9   first the elderly and the sick ones, and that was in

10   late June, early July. That was the first group. The

11   second group was, I think, late July, early August, and

12   I was released in October, but the first group was the

13   elderly and the sick, were late June, early July.

14   Q. Mr F, I suggest to you that the releases were, in fact,

15   taking place in August, and that you are mistaken about

16   these dates?

17   A. We were all brought in, the elderly and the sick, and

18   all of us were all brought to Number 6, and later, after

19   a period of time, they separated out the elderly and the

20   sick, and took them somewhere. Later we found out they

21   went to Musala. That was in June and early July,

22   because they were not with us any longer. Among them

23   was my father.

24   Q. Mr F, can I move now to the information that you had

25   about Mr Mucic? Would you accept that you were

Page 1347

1   dependent almost entirely on what other people told you

2   for information about Mr Mucic?

3   A. With respect to Mr Mucic, when he arrived for the first

4   time, I did not know him, but because he stayed a longer

5   period of time, he was walking around, he stood in front

6   of me and asked me: "Who are you? What is your name?

7   Where are you coming in?" Then he said: "Okay. Sit

8   down." Later he said: "Are you all right? Are you

9   healthy? ." Boro Gligorevic was next to him and I helped

10   him get up. He said: "What does this one have?" We

11   said: "Such and such." He said: "Step out." He went on

12   and on, one by one, and then those people were moved to

13   Musala.

14   Q. Would your Honour just give me a moment, please?

15   Mr F, apart from that occasion when you physically

16   saw Mr Mucic, much of your other information has come

17   from other people; would you accept that?

18   A. Yes. That is what I was told. That was Mr Mucic.

19   Q. Thank you. Mr F, amongst the prisoners who were talking

20   about the beatings and what they should do about it,

21   what you have told us is that they were keen to tell

22   Mr Mucic about it or perceived him as the person to whom

23   they could speak about the beatings?

24   A. Yes.

25   Q. But were frightened to do so because the guards would

Page 1348

1   find out that they had reported it and beat them again?

2   A. I couldn't tell you why they did not tell him. Those

3   were people who knew him, who had known him from before,

4   so they thought of asking him, but did not ask him. I

5   don't know why. I would not dare ask him. I would not

6   dare come over to him to ask him, and I also did not

7   have an opportunity to do so.

8   Q. Was that because you were frightened that the guards

9   would take revenge for what you had done?

10   A. No, no, no. I was afraid of everyone down there.

11   Whoever walked in, I was afraid of them, and prayed to

12   God not to be taken out, because I was not sure that I

13   would come back alive if I were taken out.

14   Q. You have told us earlier that when beatings were taking

15   place and the Commander was reported as coming, it would

16   stop immediately; is that right?

17   A. Yes.

18   Q. Was that because the guards wanted to conceal from the

19   Commander what they had been up to?

20   MS McMURREY: Your Honour, I am going to object. That

21   calls for speculation. He cannot know what the guards'

22   purpose was.

23   MR GREAVES: Perhaps I may be permitted to explore it as to

24   whether he heard anything from the guards as to why they

25   wanted to conceal it.

Page 1349

1   MS McMURREY: Thank you.

2   MR GREAVES: Did you become aware of why it was the guards

3   stopped beating you when the Commander came.

4   MS McMURREY: Your Honour, I am going to object. The way

5   he has phrased it again calls for speculation. If he

6   asked him if he heard from the guards, that is a

7   different story?

8   A. I didn't know that.

9   MS McMURREY: He is asking "were you aware." If he heard

10   it, that is fine. He is calling for speculation what

11   the guards' intention was. If he heard it, that is a

12   different question.

13   MR GREAVES: I rather think if he heard it, he has become

14   aware of it.

15   MS McMURREY: Would you ask that question, please?

16   MR GREAVES: Did you hear why it was the guards would stop

17   beating and was it because the Commander had arrived?

18   A. In all probability, but I don't know.

19   Q. Thank you. Can I just return for one question, please,

20   to the initial period of your detention and ask you

21   about one particular person? Do you recall during the

22   course of your detention and beatings seeing a man

23   called Mr Vekic?

24   A. When we were detained in Number 6, five or six of them

25   arrived and he introduced himself as Vekic. He says:

Page 1350

1   "You need this, you Serbs, and you will be left with

2   nothing, maybe a little bit of the Belgrade Pashaluk."

3   That I remember very well.

4   Q. After the Red Cross had visited in August 1992, in

5   August generally, was there an improvement in the

6   conditions, such as food and medicine and so on?

7   A. With respect to the medicine, there was nothing there

8   except for those in number 22. I think that the doctors

9   could explain that better, the doctors that will come.

10   I only remember asking for a pill once for diarrhoea and

11   I received it, and for the rest I do not know about the

12   medicine, who they were giving them to. I remember we

13   had dysentery at one point and so this is what we asked

14   for at one time.

15   Q. All right. Thank you very much, Mr F. I have no

16   further questions for you.

17   A. You are welcome.

18   MR MORAN: Your Honour, if I could use the podium, it might

19   be a lot easier.

20   JUDGE KARIBI WHYTE: You will question him for fifteen

21   minutes and we will go for a break and come back at

22   11.45.

23   Cross-examination by MR MORAN

24   MR MORAN: May it please the court.

25   JUDGE KARIBI WHYTE: Thank you.

Page 1351

1   MR MORAN: Good morning, sir.

2   A. Good morning.

3   Q. My name is Tom Moran, and, as I am sure you have

4   guessed, I am one of the defence attorneys. I am going

5   to ask you a few questions, and if you would listen to

6   my questions, and if you have a problem understanding

7   them, let me know and I will repeat them and rephrase

8   them. If you just answer the questions, I think this

9   might go a little quicker. Can we do that, sir?

10   A. Yes.

11   Q. That will be fine. Let me start at the very end of the

12   direct examination, the questions Ms McHenry asked you.

13   One of the questions she asked you was whether you were

14   ever charged with an offence; do you recall that?

15   A. Yes. Can you repeat the question?

16   Q. Yes, sir. Do you recall she asked you if you had ever

17   been charged with an offence, with a crime?

18   A. No. She didn't ask me that, but I hadn't been charged

19   with anything.

20   Q. Sir, you remember meeting with an investigating

21   commission while you were in Celebici, did you not? You

22   testified yesterday that a man asked you about whether

23   or not you had firearms, things like that. You remember

24   that, do you not?

25   A. I remember.

Page 1352

1   Q. And that man wrote down what you said, and you signed a

2   document for him, did you not, about the interrogation?

3   A. I did sign it. I did sign something, but I don't know

4   what he wrote there, because it wasn't read out to me

5   after I told him those things.

6   Q. I understand, and you are not disputing the fact you

7   possessed an automatic rifle, are you?

8   A. No.

9   Q. And you are not disputing the fact that you had that

10   with you when you were initially arrested, initially

11   captured, are you?

12   A. Yes.

13   Q. You are disputing that? You are disputing the fact that

14   you had it when you were arrested, or you did have it

15   when you were arrested?

16   A. I had the rifle when I was arrested, and I surrendered

17   the rifle together with the ammunition.

18   Q. In fact, you had two, 30-round magazines, did you not?

19   A. No. I had two magazines with 60 bullets, and I

20   surrendered all the ammunition that I had.

21   Q. That is true. Sir, I am not familiar with the law on

22   possession of automatic weapons in your country. I am

23   much more familiar with it in my own, but in my country

24   it is a serious offence to have an automatic weapon.

25   How about in the former Yugoslavia?

Page 1353

1   JUDGE KARIBI WHYTE: Actually your question was whether he

2   was convicted of any offence, was it not? That is what

3   you are driving at.

4   MR MORAN: No, your Honour. My notes reflect he was asked

5   if he was charged with an offence. I am just trying to

6   bring out he possessed an automatic weapon.

7   JUDGE KARIBI WHYTE: Yes. He has admitted that.

8   JUDGE JAN: Why do you not just ask him if he had a permit

9   for that automatic rifle?

10   MR MORAN: Did you have any kind of permit from officials

11   to have that automatic rifle?

12   A. No.

13   Q. And you are not claiming you were a soldier or anything

14   like that, are you?

15   JUDGE JAN: He is a cafe owner. He runs a cafe. At least,

16   that is what I understand.

17   A. No.

18   MR MORAN: Yes, your Honour, that is what I understand.

19   Sir, let me go back to when you initially arrived

20   at Celebici. First, you were beaten severely before you

21   got there, were you not?

22   A. Yes.

23   Q. When you got to Celebici, you were lined up against that

24   3-metre high wall, were you not?

25   A. Yes.

Page 1354

1   Q. At that point the soldiers there told you: "Now you

2   learn the Koran." Is that not what they did?

3   A. Yes.

4   Q. Those were the guards at the camp; right?

5   A. Yes. When we got in, I also forgot to say that. They

6   told us that we would learn the Koran now. They said

7   things and then we repeated them. We said "Selam

8   Aleikum Merhaba", "Praise the Lord!", and other kinds of

9   greetings. Then we had to repeat everything after them.

10   Q. Then some people came up from outside the camp. Some

11   soldiers and police started to arrive, is that not

12   right, from outside the camp?

13   A. Yes. They kept coming from all over the place. There

14   were many of them as we were standing lined up against

15   the wall. I just know that they took turns and they

16   beat us until they got tired.

17   Q. Those were the people that came up in the vehicles from

18   outside the camp. Is that not right?

19   A. Well, some were already in the camp when we got there,

20   and as for the others, there were some vehicles coming

21   in, but I was not allowed to turn around. I was facing

22   the wall. I couldn't turn around.

23   Q. In fact, it was the first night that you were in hangar

24   6 with this man -- I am going to spell the name because

25   I will have a hard time pronouncing it -- V-E-K-I-C --

Page 1355

1   is that Vekic?

2   A. Yes.

3   Q. It was the first night that you were in hangar 6 that he

4   came in and introduced himself and started beating

5   people; is that not right?

6   A. I don't know. I don't remember if it was the first

7   night. Maybe the second or the third night he

8   introduced himself as Vekic, and he said that this is

9   what we Serbs need and the only thing we would be left

10   with would be the Belgrade Pashaluk. He beat one or two

11   people. I don't remember because this was at night. I

12   just heard the moans. Maybe it was one person or two

13   people. I just heard them scream: "Oi!, Oi!" I think

14   it was raining and they had small flashlights in their

15   hands and they showed those lights, and they had

16   raincoats on.

17   Q. Now, those people were from a unit in Sarajevo, were

18   they not?

19   A. I don't know.

20   Q. Well, did they not -- they were not associated with the

21   camp, though, were they?

22   A. Most likely they weren't, because they never came back.

23   Q. So they appeared in the camp on one occasion and they

24   were never seen again?

25   A. I don't know. I don't think that I saw them again.

Page 1356

1   There were some other people from Mostar, who came into

2   the camp, and they went from one person to another

3   asking: "Is there anyone here to work in Mostar?" I

4   also remember that there was a man by the name of Miso

5   Zuza. Miso he was a small man, maybe 40, 50 kilos. He

6   said that he was up to it, and then they told him to do

7   push-ups, and then he was -- he beat him in the

8   stomach. Then later on Landzo, nicknamed Zenga, used

9   the same method.

10   Q. Okay. By the way, was it the first night that you were

11   in hangar 6 that they brought the people from tunnel 9

12   into the hangar; is that not right?

13   A. No. It was not the first night. It was after several

14   days. I don't remember how many days, but it wasn't the

15   first night. We were there on our own on the first

16   night. It was several days later.

17   Q. The people brought from tunnel

9   were pretty well beaten

18   up when they arrived at the hangar, were they not?

19   A. Yes.

20   Q. In fact, one of the people you mentioned was Mirko

21   Kuljanin; is that not right?

22   A. Yes.

23   Q. In fact, his head was bandaged, was it not?

24   A. I think that it was, yes. I think. They were covered

25   in blood and all swollen, black and blue under and above

Page 1357

1   their eyes.

2   Q. But you are not telling the judges that these people

3   were beaten at Celebici, are you?

4   A. They were brought to Celebici. That's what I heard

5   later. They were brought in on 26th May and I was

6   brought in on 27th. They were taken to Number 9 and

7   then they were -- I am sure that they went through the

8   same thing as we did. I heard it from them that they

9   were beaten in the Celebici camp, just as we were.

10   Q. Well, if someone were to say that these people had been

11   severely beaten before they arrived at Celebici, you

12   would not know whether that was right or wrong, would

13   you?

14   A. On the occasion of their being brought in from Bradina,

15   when they were brought in on 26th from Bradina, until

16   the time when I saw them, it is most likely that they

17   were beaten there en route from Bradina to the camp,

18   until the time when I saw them. That's where they were

19   beaten.

20   Q. En route from Bradina to the camp?

21   A. Yes, and in the camp itself, in the camp itself. That's

22   what I heard from them, that they were also beaten in

23   the camp, and when they were brought in.

24   Q. But they would know more about that than you would,

25   would they not?

Page 1358

1   A. I think that there will be witnesses who were in the

2   first group, and that they would be able to provide more

3   details about that.

4   JUDGE KARIBI WHYTE: I think it is convenient to stop now.

5   So we will break now and reassemble at 11.45.

6   (11.15 am)

7   (Short break)

8   JUDGE KARIBI WHYTE: Yes. You can continue with your

9   cross-examination.

10   MR MORAN: Thank you, your Honour.

11   Sir, are you back on the interpretation now? Can

12   you understand me, sir?

13   A. Yes.

14   Q. A couple of questions, I think, and we will be done.

15   Sir, at some time, at some point in time while you were

16   being held at Celebici in hangar Number 6 were beds ever

17   brought into the hangar, maybe bunk beds?

18   A. While I was there, no.

19   Q. Okay, sir. Did there come a time when people were

20   allowed visits from their families or family members

21   could bring them things like food and clean clothing?

22   A. I don't know about visits, and as for the food, people

23   started bringing food at the gate, and then the guards

24   distributed them. The food was in the bags and there

25   were names put on the bags, and then the food was

Page 1359

1   distributed but when I myself left, I asked my wife why

2   she didn't send me anything and she said that she did,

3   but I received the food very seldom.

4   Q. All right, sir. Thank you very much, your Honour. I

5   will pass the witness.

6   Cross-examination by MS MCMURREY

7   JUDGE KARIBI WHYTE: Yes, Ms McMurrey. It is your turn.

8   MS McMURREY: Yes, your Honour. I have to change some

9   headsets around here.

10   May it please the court. May I proceed?

11   JUDGE KARIBI WHYTE: Yes.

12   MS McMURREY: Dobodan, Mr F. No, it is Doboutra.

13   A. It's all the same. Good morning.

14   Q. Just for clarification purposes, you have made three

15   different statements since May of 1992, have you not?

16   A. No.

17   Q. Okay. Let me just --

18   A. What three statements are you referring to?

19   Q. Okay. You made a statement in Celebici on June 2nd,

20   1992, did you not?

21   A. That is the first statement, yes.

22   Q. The second statement you gave to the prosecution on

23   February 27th, 1996, did you not?

24   A. Yes.

25   Q. And the third statement you gave just a few months ago,

Page 1360

1   November 14th, 1996, did you not?

2   A. I don't know about the third statement, about the date.

3   I gave just two statements. I gave just two statements.

4   Q. So you are saying that Ms McHenry, Sabine Manke and an

5   interpreter named Savic did not record a statement of

6   yours on November 14th, 1996?

7   A. On 14th November 1996, 14th November, one, two, three --

8   one was in Konjic, that is in Celebici. The second one

9   was in 1996. Then you said in which month of -- yes,

10   yes, that is correct. Three statements.

11   Q. Okay. Thank you very much. Mr F, I was wondering, you

12   have never looked over here. Do you think you could

13   maybe look at us when you are testifying, because I am

14   going to be asking you questions and so you are going to

15   be talking to me. I don't know if that is possible?

16   A. All right.

17   Q. Thank you very much. Just a few questions here. Number

18   one: the Prosecutor called you and told you that we

19   would like to have an opportunity to talk to you also,

20   did they not?

21   A. Yes.

22   Q. You refused to allow us to discuss the case with you

23   until today; is that right?

24   A. That you talk to me? Well, I was called the first time

25   and now I am talking to you. I haven't had an

Page 1361

1   opportunity to talk to you before.

2   Q. So the prosecution did not tell you that we wanted an

3   opportunity to visit with you ahead of time?

4   A. No, there was no need for that, nor did they tell me

5   that.

6   MS McHENRY: Your Honour, if I may clarify, we have made it

7   clear both in court and in proceedings with respect to

8   some witnesses we go through a representative. In fact,

9   we do not ourselves have even the contact information,

10   and that is why with respect to our Pleadings and in our

11   representation we indicate that representations have

12   been made to us either by the witnesses or their

13   representatives. So I believe that this may be a reason

14   for this confusion.

15   JUDGE KARIBI WHYTE: Now if you had actually listened and

16   relied on his answers, he said there was no need for

17   that. He said so. So I do not see why you need bother.

18   MS McMURREY: I am trying to make a record.

19   JUDGE KARIBI WHYTE: He indicated there was no need for

20   speaking to you. He said so.

21   MS McMURREY: I am just trying to get it on the record of

22   this trial that we have made an effort --

23   JUDGE KARIBI WHYTE: Everything he says will be on record,

24   not only what you say, what he says too.

25   MS McMURREY: May I clarify the question as to how Ms

Page 1362

1   McHenry explained it to me, so maybe he can respond --

2   JUDGE KARIBI WHYTE: That is not part of the proceedings.

3   Ask him the questions.

4   MS McMURREY: Your Honour, this is cross-examination and I

5   have a right to --

6   JUDGE KARIBI WHYTE: You are not cross-examining Ms

7   McHenry.

8   MS McMURREY: No, I am cross-examining the witness.

9   JUDGE KARIBI WHYTE: Go ahead and ask him the questions.

10   MS McMURREY: Okay. Mr F, you did not allow the defence

11   the same courtesy as you did the prosecution as far as

12   having advance interview with you, did you?

13   A. There was no need for that.

14   Q. That is your opinion; correct?

15   A. Yes.

16   Q. You listed your employment as unemployed; is that

17   correct?

18   A. Yes, for the time being, yes, temporarily.

19   Q. In fact, you have been unemployed since May of 1992,

20   have you not?

21   MS McHENRY: Your Honour, I am going to object as to

22   relevancy.

23   MS McMURREY: Your Honour, I will respond. Where he is

24   getting paid during this period of time is --

25   JUDGE KARIBI WHYTE: Ask him -- you go ahead and respond.

Page 1363

1   I am not familiar with this type of behaviour. If you

2   ask a question, you expect an answer.

3   MS McMURREY: Yes. That is what I would like to have.

4   JUDGE KARIBI WHYTE: Then you listen and get the answers

5   before you get on.

6   MS McMURREY: Yes.

7   JUDGE KARIBI WHYTE: I do not know. The jurisdictions in

8   which you practise, you behave differently, but I am not

9   familiar with that.

10   JUDGE JAN: Ask your question of the witness.

11   MS McMURREY: Okay. You have been unemployed since May of

12   1992, have you not?

13   A. Yes.

14   Q. Can you tell us how you have been subsidised and how you

15   have been living since that date, please?

16   A. All the jobs that I could do, I did not shirk any kind

17   of a job in order to get some money to be able to

18   support myself and my family, and if some had thought

19   about that before, then I would still have my old job

20   and I would be my own master. Everything I had was

21   burnt -- not even the hen house is there -- and now I

22   have been forced to go from one relative to another and

23   do all kinds of most difficult jobs in order to survive

24   and to support my family.

25   Q. Mr F, you were a waiter before, were you not, and this

Page 1364

1   is a fairly common job, is it not?

2   A. Yes.

3   Q. So you are saying that you are living with your

4   relatives; nobody else is making payments to you to live

5   during this period, are they?

6   A. Again I am telling you I do all kinds of jobs that I am

7   able to do, wherever they may be, regardless of what

8   kind of a job it is, in order to survive and support my

9   family.

10   Q. Other than what you make are you being subsidised by the

11   Commission for Serbs in Belgrade or some other form?

12   That is what I am asking.

13   A. I have worked and managed to support my children, and if

14   you mean my coming here, we received some assistance

15   from an association of the detainees, that is correct,

16   yes, former prisoners.

17   Q. I thank you. I am not talking about your travel here.

18   I know that is supposed to be paid for by the Tribunal.

19   I am asking you: between 1992 and today has another

20   organisation subsidised your living expenses other than

21   what you were able to earn to support your family?

22   MS McHENRY: Your Honour, I believe that this is improper

23   and really an affront to his dignity. If the defence

24   counsel wants to ask whether or not he is getting paid

25   in exchange for his cooperation with the Tribunal or

Page 1365

1   something, I have no objection to such a direct

2   question, but bringing out the fact that these people

3   are maybe refugees -- I mean, I do not know the exact

4   answer to this, but I think it is unfair to put the

5   witness through this. If she has a direct question

6   about whether or not his cooperation has resulted in him

7   getting money that he would not otherwise have received,

8   I do not object to that question, but in general I

9   object to the whole line of questioning.

10   MS McMURREY: Your Honour, my question has nothing to do

11   with his testimony here in the Tribunal. It has to do

12   with the motive for fabrication. If he is being paid by

13   the SDS or if he is being subsidised by the Belgrade

14   Commission for Serbs, then there is a motive there that

15   could taint his testimony somewhat. That is why I am

16   asking the question.

17   JUDGE KARIBI WHYTE: Put the question to him directly.

18   MS McMURREY: I do not know how to ask it any more

19   directly.

20   JUDGE KARIBI WHYTE: You have already formulated it. You

21   have mentioned the organisations which are likely to do

22   so. Ask him those questions.

23   MS McMURREY: Mr F, have you been paid money as living

24   expenses during this period other than what you have

25   earned and other than what the Tribunal has provided for

Page 1366

1   you to come here, to take part in this proceeding, by

2   any other Serbian organisation?

3   A. No. I am speaking the truth and nothing but the truth.

4   I did not receive anything from any organisation, nor is

5   there an organisation such as this. We were called by

6   the Association of Prisoners to come here and to speak

7   the truth before this Tribunal, and I did not receive

8   any money for that.

9   Q. Thank you very much. That is exactly what I was

10   asking. Thank you. I wanted to ask: you were born in

11   Bosnia, were you not -- I am sorry --

12   Bosnia-Herzegovina?

13   A. Yes.

14   Q. In what village were you born?

15   A. In the village of Bradina.

16   Q. As such, you are really a Bosnian Serb, are you not?

17   A. A Serb, yes, I am a Serb, yes.

18   Q. And you are also a Bosnian Serb, are you not?

19   A. I was born in Bosnia, but I am Serb by nationality.

20   Q. Thank you. In fact, in the referendum of March 1st,

21   1992 you had the opportunity to vote and you could have

22   voted if you had wanted to in that referendum, could you

23   not?

24   A. I did vote.

25   Q. Thank you very much. You are an -- in 1992 you were an

Page 1367

1   active member of the SDS, were you not?

2   A. In 1992 I was a member of the SDS, yes. From January

3   1992.

4   Q. I believe you have stated that you were armed during

5   1992; is that correct?

6   A. Yes.

7   Q. You also stated that on May 25th 1992 a military action

8   began against the town of Bradina; is that correct?

9   A. On 25th May we came under attack from Muslim and

10   Croatian coalition. It was a sudden attack and

11   immediately on 26th May the men from the village of

12   Donje Bradina were killed, as I learned later, and

13   everything was burnt. By 27th only a few of the houses

14   were left standing, that had not been burnt by then.

15   Q. You were captured in May of 1992, were you not?

16   A. I was arrested in May, yes, on 27th May.

17   JUDGE KARIBI WHYTE: Actually the question is: you were

18   captured. That is the question; not: you were arrested?

19   A. I was arrested, yes. I was arrested.

20   MS McMURREY: When you were arrested, you had an automatic

21   weapon with ammunition in your possession, did you not?

22   A. When I was arrested, I had with me a rifle and

23   ammunition.

24   Q. Now, you also stated, I believe, to Ms McHenry yesterday

25   that you had purchased that rifle in the parking lot of

Page 1368

1   the restaurant; is that correct?

2   A. Yes.

3   Q. And you had purchased it some time in December of 1991;

4   is that correct?

5   A. Yes.

6   Q. You stated that there were growing tensions around

7   December of 1991, did you not?

8   A. Yes.

9   Q. Those growing tensions in 1991 were directly related to

10   the speech that your leader, Radovan Karadzic, had made

11   on October 14th 1991 in the Sarajevo Assembly, was it

12   not?

13   A. No. The reason why I did that was because the media had

14   reported that in 1991 the HOS and SDA were already

15   formed, and there were attacks on the army, and since my

16   village had at the time, according to the 1991 census,

17   602 or 604 inhabitants, and we were surrounded by Muslim

18   villages, there was a fear in me that my house would be

19   attacked. So the only reason why I took the weapon was

20   to protect my house, my child, and my family.

21   Q. I am going to leave the military discussion to another

22   person, who is much more knowledgeable than I am about

23   this, but you did state that there was no resistance in

24   Bradina. Is that not what you stated?

25   A. There was no resistance at all. If there had been any

Page 1369

1   resistance, then the people would not have been captured

2   and taken to the Celebici camp on 26th May already.

3   Q. There were many forces, combined forces, there in the

4   attack at Bradina, were there not? The HVO, the TO and

5   the MUP, the military police, were all participating in

6   this, were they not?

7   A. Bradina was attacked by HOS, and they had the assistance

8   of our Muslim neighbours and Croats that lived around

9   us.

10   Q. What you are saying is that with all of these forces

11   attacking Bradina, it took them three days to capture

12   you and to liberate this town. Is that not what you are

13   saying?

14   A. No. As far as I am concerned, since I was on the

15   opposite side of Bradina at the exit towards Sarajevo,

16   on 26th in the morning they had already burnt Lower

17   Bradina. It was already on fire. On 26th in the

18   evening I went to the larger village of Barakusa,

19   because my village had only eight houses. We spent the

20   night there, and then in the morning at around 8.00 or

21   9.00 am we were arrested there. I surrendered my weapon

22   and then we were taken further on.

23   Q. You told Ms McHenry yesterday that when you surrendered

24   your weapon, you turned over your weapon and 45 bullets

25   and that your gun had not been fired. Is that not what

Page 1370

1   you told her yesterday?

2   A. Yes. I surrendered my weapon and 60 bullets. I had not

3   fired a single bullet. This foreign national on the

4   occasion of my arrest, he verified that and he noted

5   down the first name and last name together with all the

6   others who were there.

7   Q. The truth is in your statement on June 2nd, 1992 you

8   stated that you had 270 rounds and that you had fired

9   your weapon that day, when the fighting started, did you

10   not?

11   A. That is not true. I did not say that. I said the same

12   thing down there. I said that I did not fire a single

13   bullet, and as for what they wrote there, I don't know

14   about that. I signed something but I don't know what it

15   was that I signed. I did not state this.

16   Q. Well, I am going to leave that line of questioning

17   also.

18   The day that you were arrested from Upper Bradina

19   and taken to Celebici, it is true that the worst torture

20   of you, other than the fact that you saw your father

21   being beaten, was from the time you were arrested in

22   Bradina until the time you got to Celebici, is it not?

23   JUDGE JAN: He has already answered that question earlier.

24   Why do you want it again?

25   MS McMURREY: I guess I maybe was not paying attention

Page 1371

1   earlier. If we have that on the record, then I accept

2   that. Thank you.

3   Now you also said, when you were arrested, after

4   your initiation at the front gate, you said you did not

5   see and could not identify any of the guards. Is that

6   not what you said?

7   A. Yes, because I was facing the wall.

8   Q. You also have stated that not only were Croatian

9   soldiers, military police, the guards and civilians

10   present; civilians were also coming in to participate in

11   this beating of the new prisoners from Upper Bradina; is

12   that correct?

13   MS McHENRY: Objection. This has been asked and answered

14   both on direct and on prior cross-examination. He has

15   stated on numerous times that he was facing the wall and

16   he doesn't know exactly where those people were from.

17   MS McMURREY: I believe he did state there were some

18   civilians coming in. I wanted to clarify it was not

19   just military action. There were civilians being

20   brought in at the time also.

21   JUDGE KARIBI WHYTE: Actually if you want him to say again

22   what he answered in respect of questions by other

23   counsel, you can repeat as many of them as you want.

24   MS McMURREY: Thank you. Mr F, there were also civilians

25   that participated in the beating that night on May 27th,

Page 1372

1   were there not?

2   A. On 27th May 1992, on that night I did not say that. I

3   did not say that for that night. When we were brought

4   in Number 6, I did not say that. I just said that Vekic

5   and his men came and he introduced himself, and I

6   already said what he had said to us.

7   Q. I am sorry. I maybe did not make my question clear. I

8   am talking about the beating against the 3-metre wall at

9   the gate of Celebici camp. You stated that there were

10   civilians that participated in that beating, did you

11   not, when you arrived at 1.00 pm in the afternoon?

12   JUDGE KARIBI WHYTE: Actually, if he said they were all

13   facing the wall and did not look back, I do not know

14   whether he could have seen civilians or soldiers.

15   MS McMURREY: If he knows. If he does not know --

16   JUDGE KARIBI WHYTE: How could he from behind? Has he eyes

17   from behind?

18   JUDGE JAN: But he would know who is beating him and who is

19   beating the others.

20   MS McMURREY: I am just asking him, if he knows, did he

21   notice that civilians came?

22   JUDGE KARIBI WHYTE: If they were among those who were

23   beating him.

24   MS McMURREY: Yes, your Honour.

25   JUDGE KARIBI WHYTE: Put it to him.

Page 1373

1   MS McMURREY: Were civilians among the people that beat the

2   prisoners at the entrance gate to Celebici camp on May

3   27th, 1992?

4   A. Again I have to tell you that I was facing the wall. I

5   don't know how many and who it was, but they beat us as

6   much as they could, as much as they wanted. We stood

7   there until nightfall, because when we came to Number 6,

8   they put the lights on, and it was about 7.00 o'clock.

9   Q. Let me ask you: the person you said beat your father,

10   the one person you did recognise, I believe his name was

11   Zvonko Zovko, and I apologise for my pronunciation?

12   MS McHENRY: I am going to object. This was gone into with

13   last defence counsel. He said this is what happened to

14   his father. I do not think it is fair to have the exact

15   same question put to him.

16   MS McMURREY: Your Honour, it is not the same question.

17   That man was a Croatian, was he not?

18   A. Yes.

19   Q. Thank you. Now, you said you were taken to Hangar

20   Number 6, but I want to go back a little bit. You said

21   there was one person. I think his name was Miro Vujcic,

22   who was shot trying to escape; is that correct?

23   A. Yes.

24   Q. That was the afternoon of May 27th, 1992?

25   A. Yes, on 27th May. He stood to my left and when he saw

Page 1374

1   what I had been through, the torture, in order to end

2   his own suffering, he couldn't bear it any more, and he

3   had been beaten before, he started to run. I don't know

4   how far, because I had been beaten myself and I heard

5   the burst of fire and he was killed.

6   Q. Thank you very much. You witnessed that also, did you

7   not?

8   A. Yes.

9   Q. You also stated, I believe, on your testimony yesterday

10   that when you went to hangar 6 you were the first people

11   brought into hangar 6; is that correct?

12   A. Yes.

13   Q. But you were not the first prisoners brought to

14   Celebici, were you?

15   A. On 26th, the first ones were brought, but they were

16   taken to Number 9. I only heard of that later, when

17   they came over to us.

18   Q. The other towns that were liberated before Bradina were

19   Bjelovcina, Cerici and Donje Selo; is that correct?

20   A. Yes.

21   Q. They were already at Celebici, were they not?

22   A. Yes, but as far as I heard in number 22, this is what I

23   heard but did not see.

24   Q. Mr F, I just wanted to ask you: I want to make an

25   agreement with you. I will question you a lot shorter

Page 1375

1   and we will get this over with a lot faster if we are

2   clear. The questions I am asking you, I only want you

3   to tell me what you personally know and what you have

4   personally seen or heard. What other people have told

5   you is another question. I want to find out what your

6   knowledge is in this case. So if you answer me

7   directly --

8   A. Yes.

9   Q. -- then I will be finished before lunch and so will

10   you. Thank you.

11   A. Yes.

12   Q. Now you also stated in Hangar Number 6 that they turned

13   the lights on. Is that not what you stated?

14   A. At our arrival, yes. That was on 27th in the evening.

15   Q. So you are saying that there was electricity in Hangar

16   Number 6 on May 27th, 1992?

17   A. Yes.

18   Q. I hope you will forgive me with my pronunciation of

19   these Bosnian names, because they are very alien to me

20   but you did testify that someone named Pero Mrkajic

21   was thrown into Hangar Number 6 and you saw him badly

22   injured; is that correct?

23   A. After a while -- we had been there two or three days --

24   a group was brought in that had been captured. I heard

25   later it was at Igman --

Page 1376

1   Q. Excuse me. Remember this about what you heard later. I

2   am just asking you about what you saw and what you

3   personally experienced. If we can leave it to that,

4   then this will be very short.

5   A. Yes. Pero Mrkajic was among them and at night he came

6   and he dropped right on my feet and feet of Pero

7   Gligorevic. We pushed him away from us. We didn't know

8   who he was. Somebody at the door said: "Where is Pero

9   Mrkajic? Curse his mother."

10   Somebody else said: "He's had enough." After the

11   door closed we asked him who was he, and he barely was

12   able to say "Pero", and I could barely recognise him,

13   because I knew him for so many years.

14   Q. He was in very bad condition at that time; is that what

15   you are saying?

16   A. When the dawn broke, he was in no shape at all. He

17   couldn't eat. He just took a small drink of water. He

18   was there for about a week and then was transferred to

19   number 22, and later there he died, which is what the

20   doctors who were present there will testify to.

21   Q. Okay. Now I am still asking you about your personal

22   knowledge. You saw his injuries, but you personally do

23   not know where or who or the circumstances behind how he

24   was beaten, do you?

25   A. No.

Page 1377

1   Q. Thank you very much?

2   A. That was before the arrival into the hangar.

3   Q. You also stated that the guards never came into the

4   hangar at night and during the day they only came into

5   the hangar in twos; is that correct?

6   A. At night they would not enter into the hangar. They

7   would just come to the door and call out from there, and

8   people had to come out as they were called out. During

9   the day they would come in, two of them, at a time. One

10   would stand at the door and the other one would go

11   around, or if he beat people, he would beat them, or he

12   would call people to come out.

13   Q. Now, what I want to find out here is: you have testified

14   to Ms McHenry about a lot of people that were beaten and

15   then died from their injuries, etc. Now, most of these

16   people, other than a very few of them, were beaten

17   outside the hangar, and you were not able to go outside

18   the hangar and witness who or what or the circumstances

19   of these beatings, were you?

20   A. Yes. I could not see, but you could hear. You could

21   hear their wails and their screams.

22   Q. You mentioned a Mr Jovanovic and you specifically stated

23   yesterday you recognised the distinctive voice of Esad

24   Landzo, but you did not see anything about the beating

25   and you did not see who hit him. You just heard

Page 1378

1   Mr Landzo's voice. Is that not your testimony?

2   A. I heard the voice, because his voice is distinctive.

3   It's a characteristic voice. When he was speaking

4   outside, we knew immediately that he was coming, and we

5   already were in fear, because his voice is high-pitched.

6   Q. My question is that you still did not view the beating,

7   so you do not really know who hit or the circumstances

8   of the beating of Mr Jovanovic, do you?

9   A. I don't know who beat him. I did not say who beat him.

10   I just said who called him out and this was all outside.

11   Q. Thank you very much. Now you also stated yesterday in

12   your examination and in your examination today by

13   Ms McHenry that the guards followed Mr Delic's orders,

14   did you not?

15   A. Yes.

16   Q. You each used an example of the military police, that

17   Mr Delic ordered Mr Landzo and the other guards to beat

18   the people from Bradina for breakfast, lunch and

19   dinner. Was that not your testimony?

20   A. Yes. He ordered the guards; that is he ordered to

21   Landzo. I did not mention the police. He ordered

22   Landzo when he was there, coming in after him, he said:

23   "Zenga, from today on this is their breakfast, lunch

24   and dinner."

25   Q. In fact, you did state also today that Mr Landzo carried

Page 1379

1   out the orders of Mr Delic, did you not?

2   A. He did it on his own as well, even when Delic was not

3   around.

4   Q. But when Delic was not around, you do not know that

5   Mr Delic did not order him to do that ahead of time, do

6   you?

7   A. I don't know that.

8   Q. I would like to ask you a few questions on your other

9   statement. You have never described Mr Landzo. You

10   described a few other people in your statement, but you

11   never described Mr Landzo. Mr Landzo was about 18 years

12   old at the time, was he not, in 1992?

13   A. I don't know how old he was, but he behaved as if he was

14   older. I described yesterday how Landzo appeared. I

15   described him last night.

16   Q. Yes. I am just saying in your other statement you never

17   described him and I am just asking: you left out his age

18   in 1992. He was very young at the time, was he not?

19   A. I don't know how old he was, but he looked to me serious

20   and also he looked terrible to me, because he beat -- I

21   don't know how old he was and I was not enquiring then

22   but I know that we were all afraid of him.

23   Q. When you saw Mr Landzo in the presence of Mr Delic, you

24   could tell that Mr Delic had control and extreme

25   influence over Mr Landzo, could you not --

Page 1380

1   MR MORAN: Objection, your Honour. This calls for

2   speculation.

3   MS McMURREY: Your Honour, I am asking what he saw. If he

4   saw that, then he is able to testify.

5   JUDGE KARIBI WHYTE: This is opinion, is it not?

6   MS McMURREY: If he saw that, yes. You can tell --

7   JUDGE KARIBI WHYTE: Do not ask him his opinion.

8   MS McMURREY: Were you able to recognise the control that

9   Mr Delic had over Mr Landzo?

10   MR MORAN: Same objection, your Honour.

11   MS McMURREY: He is his superior. I think he is testifying

12   as to --

13   JUDGE KARIBI WHYTE: Who said so?

14   MS McMURREY: Okay. That will be my next question.

15   Mr Delic was Mr Landzo's superior, was he not, in the

16   camp?

17   MR MORAN: We object. Calls for speculation, unless he has

18   some personal knowledge of the chain of command in the

19   camp.

20   JUDGE JAN: But I think he has said already something on

21   this, that orders were obeyed. I think in direct

22   examination the question was put to him. Mr Delic was

23   treated as a sort of a commander in the sense that the

24   other guards obeyed him. I think this is a question

25   which has already come on the record. I do not think

Page 1381

1   that Ms McMurrey has to have it again.

2   MS McMURREY: I am asking again: could you recognise the

3   relationship between Mr Delic and Mr Landzo? Was it one

4   of control?

5   MR MORAN: Same objection, your Honour. Calls for

6   speculation and opinion.

7   JUDGE KARIBI WHYTE: Actually this witness is not in a

8   position to tell you what the relationship is. Find

9   someone else to do that, not him.

10   MS McMURREY: Well, may I ask him to describe how Mr Landzo

11   acted at Mr Delic's orders?

12   JUDGE KARIBI WHYTE: That is suggesting that Mr Delic is

13   giving him orders. That is what you are suggesting.

14   MS McMURREY: Your Honour, he has already testified that he

15   responded to the orders of Mr Delic.

16   JUDGE JAN: I think something did come in the direct on

17   this relationship between Delic. Can we have that

18   particular passage?

19   MS McMURREY: I have it written down.

20   JUDGE KARIBI WHYTE: Let us get your questions. If all you

21   are asking is the structure, I am not sure this witness

22   is the right person to tell you the structure in that

23   organisation. He is not the right person.

24   JUDGE JAN: I think something has already come on the draft

25   transcript. Ms McHenry is checking up.

Page 1382

1   MS McHENRY: Your Honour, yesterday the draft transcript

2   reveals at least on one occasion -- I do not know about

3   other things -- that the witness reported with respect

4   to Hazim Delic:

5   "He came and said: 'What are you guys doing up

6   there? They are killing our police officers.' He cursed

7   our mother. Then he started beating people one by one

8   and he ordered Zenga: 'This is what the people from

9   Bradina are to get for breakfast, lunch and dinner',

10   and from that day on we did not receive any dinner."

11   MS McMURREY: If you read further, it says Landzo carried

12   out his orders, I believe.

13   JUDGE KARIBI WHYTE: The witness in his answers confirmed

14   that Landzo could do it even without being ordered.

15   MS McMURREY: If he is testifying to what Mr Landzo does, I

16   have a right to know whether he did it under orders,

17   your Honour. That is what I am asking him.

18   JUDGE KARIBI WHYTE: It is not through him. He would not

19   know who gave him orders.

20   MS McMURREY: If he was present, he would, and if he can

21   testify that he did not know whether he was ordered at

22   other times, then that raises the issue that he was

23   probably acting under orders.

24   JUDGE KARIBI WHYTE: I do not think he is obliged to answer

25   even this question. He is not obliged to.

Page 1383

1   MS McMURREY: I do not know what I am allowed to question.

2   JUDGE JAN: Ms McHenry, you also asked him questions about

3   the position of Delic in the camp, if I remember

4   correctly. He did say something.

5   MS McHENRY: Yes, your Honour. I believe that came up the

6   first thing this morning, and he certainly said that he

7   understood that Delic was -- I do not want to say the

8   exact -- I can possibly find it in the transcript from

9   early this morning but I do not have it from yesterday.

10   Thank you. I will look it up.

11   MS McMURREY: Your Honour, if I might, I will rephrase the

12   question, where it might be --

13   JUDGE KARIBI WHYTE: You are trying to complicate the

14   position between the accused persons. Now when a person

15   is giving evidence, you ask him questions within the

16   scope of his knowledge. You do not go about asking

17   people questions which are not within the scope of their

18   knowledge. Even whatever he says is a matter of

19   guesswork.

20   MS McMURREY: In our motion for separate trial, we told you

21   there would be inconsistent defences in this case and

22   there are inconsistent defences. I am not trying to

23   raise problems with the court or the other defence

24   attorneys. I am trying to represent my client to the

25   best of my ability. That is what I am here to do.

Page 1384

1   JUDGE KARIBI WHYTE: I have told you from the beginning

2   perhaps your ability might be more detrimental to him.

3   Ask him the questions. Ask him.

4   MS McMURREY: Mr F, when Mr Delic ordered Mr Landzo to

5   carry out orders, can you tell me what his demeanour

6   was, Mr Landzo's demeanour?

7   A. Landzo both on orders of Delic, on his own did things

8   that a regular person would never think about. For

9   instance, when he tied a cord around Vukasin Mrkajic,

10   and then when he had the other one run around the

11   hangar, when he took people out and inside Number 6 --

12   MR MORAN: Your Honour, this is not --

13   JUDGE KARIBI WHYTE: He is answering the question which he

14   was asked. Let him answer the question. Say as much as

15   you know about what happened.

16   A. For instance, to do push-ups, to hit him in the

17   abdominal area, that is what he did. Maybe nobody even

18   knew about these things. Other things he did on orders,

19   which is what I already stated.

20   MS McMURREY: My next question to you is even when

21   Mr Landzo was carrying out things in -- outside the

22   presence of Mr Delic, you do not know that they --

23   whether he was acting under orders or not, do you?

24   A. I don't know about that.

25   Q. Now I would like to ask you about -- you had mentioned a

Page 1385

1   Nenad Cecez and a Davor Bendjo, I believe, in your

2   earlier testimony. Is that not correct?

3   A. Yes.

4   Q. Those were prisoners with you in hangar 6, were they

5   not?

6   A. Yes. They distributed food to us and brought it, and

7   they were outside of the hangar. That is one was

8   inside, one was outside, and when we were to go to

9   urinate, they were at one time given instructions that

10   they could take people one by one to go and do that.

11   Q. In fact, they were really considered the organisers of

12   the prisoners, and any communication you had with the

13   guards, you would tell these people and they would

14   inform the guards; is that not correct?

15   A. Yes. I don't know what they were, but they were among

16   us, and we needed to go to them if we wanted to go to

17   the toilet, urinate and other things.

18   Q. In fact, their duties really started at 6.00 am in the

19   morning until after dark and after dark they were

20   allowed outside the hangar, were they not?

21   A. No, they were not allowed out.

22   Q. Okay. I want to go to the -- you had testified earlier

23   about two brothers who were brought to the camp,

24   (REDACTED) is that correct? I

25   am very sorry. Can we -- I did not ask any questions

Page 1386

1   about what they were referring to. I will come back to

2   that.

3   You have testified about a lot of different

4   tortures, and I know that Ms McHenry had said that her

5   goal was to help me clarify all this, and I appreciate

6   that. When you testified about Spasoje Miljanic and

7   Nedeljko Draganic, you told us about some injuries that

8   they sustained, but the truth is that you were not

9   outside the hangar and you did not witness what actually

10   happened to these people, did you?

11   A. That was not Spasoje Miljanic. It was Spasoje Viljavic

12   and Nedjo Draganic. I was not outside and I did not

13   even state that. I was in Number 6 when they returned.

14   Their trousers were seared through. I saw on Draganic's

15   legs and he shouted to us and Spasoje Miljanic after a

16   while -- at first he was silent and later he showed us

17   his hands and we saw -- I saw blisters -- burns on his

18   palms.

19   Q. Okay. Thank you very much. Now you also testified, I

20   believe, that -- I may need to ask how to refer to

21   certain things, and I do not know how to refer to it,

22   but you testified that there were some people who were

23   forced to do some sexual acts; is that correct?

24   A. Yes.

25   Q. In fact, those people were not brought to Celebici until

Page 1387

1   after the murder of the military police on July 12th,

2   were they?

3   A. Yes.

4   Q. In fact, their being brought to Celebici was in

5   connection to the murder of the military police, was it

6   not?

7   A. No, no. That's not how I stated it. They were brought

8   in -- I don't know why they were brought in, and again I

9   must say that this is what I heard. You told me not to

10   say what I have heard but this is what I heard. They

11   were brought to Number 6, and every morning Zenga beat

12   them, and after all that, he ordered them to get up in

13   front of all of us and one of them put out the sexual

14   organ and put it into the other's mouth, and then they

15   switched. One was made to kneel and do it. We could

16   all see this, because this is what happened in Number 6.

17   Q. My question is: this all happened after 2th July 1992,

18   did it not, after the death of the military police? I

19   believe you already answered "yes", if I am correct?

20   When did this happen?

21   A. I do not recall, but I know they were brought in after

22   us, most probably after that. If you will allow me, I

23   can tell you I do not know that, but from that village

24   there were some women the same last name, and Balic

25   Redzo was killed there at that time, and later it turned

Page 1388

1   out that those policemen were killed by the Muslims from

2   Repovci, if you really want to know about that.

3   Q. At the time when the incident occurred, since nobody

4   really knows what happened to the military police, the

5   TO and the people from Celebici were told that the

6   Serbians had killed the military police, were they not?

7   MS McHENRY: Your Honour, she has already -- at one point

8   she frequently tells the witness not to answer things he

9   cannot know himself. At other points she asks things

10   that it is clearly obvious he would have no way of

11   knowing. I must object.

12   MS McMURREY: Your Honour, all he has to say is he does not

13   know. If he does not know, then I will move on to the

14   next subject.

15   JUDGE KARIBI WHYTE: You are doing the answering for me.

16   MS McMURREY: I am sorry. I was responding.

17   MS McHENRY: Your Honour, not with respect to any of the

18   recent testimony, previously with respect to some

19   testimony we would like to formally request a redaction.

20   MS McMURREY: I agree. There is no problem with that.

21   JUDGE KARIBI WHYTE: What is your next line of

22   questioning?

23   MS McMURREY: Well, I am not finished with this line of

24   questioning. If he knows, I am asking him: that day of

25   July 12th, Mr Landzo went to the scene where the

Page 1389

1   military police were killed, did he not?

2   A. I don't know that.

3   Q. Okay. You also testified, when the attorney for

4   Mr Mucic was cross-examining you, that there was an

5   outbreak of dysentery and that you asked for medication

6   and you received it, did you not?

7   A. Yes.

8   Q. You also testified when the attorney for Mr Delic was

9   questioning you that early on in May of 27th -- I don't

10   remember the name because it doesn't show up here --

11   someone named Poso Miljevic was forced to do push-ups

12   and he was killed, I believe -- I am not sure what your

13   testimony was. You also stated that Mr Landzo used the

14   same method later, not in May; is that not correct?

15   A. I can repeat that for you. When they came, and these

16   persons --

17   Q. Just tell us who they are?

18   A. -- were unknown to us, the unknown persons from Mostar,

19   they entered Number 6 and they asked whether there was

20   somebody there who was from Mostar. The little Zuza

21   answered, and then he said: "Okay. Now do push-ups." He

22   hit him -- actually he kicked him in the abdominal area

23   and then later that same method was used by Landzo on

24   other inmates who were in the camp.

25   Q. In fact, that question that night by the Mostar Croatian

Page 1390

1   forces, who were those were that came in, that question

2   was designed to find out who in the building was a JNA

3   reserve soldier, was it not?

4   A. I did not say that the Croats were coming. I said they

5   were unknown persons. They came and they did what they

6   did.

7   Q. Thank you. Could I have Prosecution Exhibit number 1, I

8   believe, which is the drawing of the inside of Hangar

9   Number 6, so that we can put it on the ELMO, and I would

10   like to ask Mr F to show us exactly where he was

11   sitting, please.

12   First I would like to ask you: does this look

13   like an accurate representation of Hangar Number 6?

14   A. I think it is. This is the entrance. This is how you

15   get in, and I sat right here in the middle, facing the

16   entrance door.

17   Q. Okay. Thank you very much. I would like the record to

18   reflect that he pointed at the back left-hand wall,

19   since I do not have a drawing to introduce into

20   evidence. Thank you. Also I would like to ask you a

21   couple of questions about Hangar Number 6. You already

22   identified the one door. That was the only door that

23   was used for Hangar Number 6, was it not?

24   A. Yes. This was the door that was used for entering the

25   hangar. There were other doors that could be opened,

Page 1391

1   but they were never opened until the arrival of the

2   International Red Cross. You could get in with a

3   truck. This was the large door and that door was opened

4   twice after the arrival of the Red Cross. Then they

5   were again opened when it was called, but the entrance

6   door, this door was used most of the times.

7   Q. The side where those big hangar doors were, when they

8   were closed, there were no holes you could look out of,

9   were there?

10   A. I don't know. I didn't look.

11   Q. There were windows in the hangar that were about 3

12   metres up, where nobody could see out; is that not

13   correct?

14   A. I don't know how high they were, but I know they were

15   quite high. They were on the upper side and nobody

16   could do anything about them. I think there were also

17   small windows above the door or maybe not. I know that

18   there were doors on the upper parts and there was a door

19   on the lower part.

20   Q. But the only door that was ever used was the one that

21   you indicated on the drawing that you were just shown;

22   is that correct, except when the Red Cross was there?

23   A. Yes.

24   Q. Now, you were --

25   A. Yes.

Page 1392

1   Q. -- sitting against the outside wall of this hangar. Is

2   it not true that the hangar was sealed on the bottom?

3   A. Yes.

4   Q. There was no way for you to stick your hand out or get

5   air or anything from the bottom, was there?

6   A. Yes. Water. I know that when it was hot, I don't know

7   who it was of the guards, I can't remember, he sprayed

8   water on the roof and also down there where people were

9   sitting, and they were not allowed to get up. I

10   remember that.

11   Q. So you are saying there was maybe enough -- it was not

12   sealed enough to prevent rain water or water from

13   dripping in. Is that what your testimony is?

14   A. The water could get in, but only when it was sprayed in

15   through a hose, and the rain water fell on the roof. I

16   could tell you that I didn't really have an opportunity,

17   nor did I dare to look. When I was leaving the hangar,

18   I did that with my head down. When I was going to the

19   hole that had been dug up for our toilets, and I went

20   back to the hangar with my head down.

21   Q. Well, my question is: you could not stick your hand out

22   at the bottom of the hangar, could you?

23   A. I don't know. I didn't try to do that. So I don't

24   know.

25   Q. That brings me to the toilets. There were holes dug.

Page 1393

1   As you came out the door and you were facing Hangar

2   Number 6, to the right-hand side towards the back there

3   was something, a makeshift toilet of some sort, was

4   there not?

5   A. On the right-hand side? On the right-hand side there

6   was a machine gun nest and then at the exit of the

7   hangar there was also a machine gun nest on the hill,

8   and behind the hangar, maybe five steps to the right of

9   that hill, there was first one hole, the second hole,

10   the third hole and so on. When they would fill up, we

11   would cover them and dig new ones. It was not on the

12   right-hand side.

13   Q. Okay. Thank you. There were only two guards guarding

14   about 240 prisoners in each shift; is that not correct?

15   A. There were more of them. I don't know how many of them

16   were outside, but there were two machine gun nests, one

17   to the right of the entrance and one on that hill at the

18   entrance. In fact, to the right of the entrance door

19   and then opposite of the tarmac, opposite the entrance

20   there was a machine gun nest.

21   Q. As far as the guards that were on duty guarding Hangar

22   Number 6, you only saw two at a time, did you not?

23   A. Yes.

24   Q. I want to ask you about this person named Zjelko

25   Klimenta. You know that he was killed by a gunshot

Page 1394

1   wound, but you know that that was an accidental

2   shooting, do you not?

3   A. I don't know about that.

4   Q. The guard was crying after that happened, was he not?

5   A. I don't know about that.

6   Q. Okay. Thank you. The statement you made -- you

7   testified today that you saw Mr Landzo in August or

8   September at Celebici with a white belt on; is that not

9   correct?

10   A. Yes.

11   Q. That white belt represents a member of the military

12   police, does it not?

13   A. Yes, most likely.

14   Q. I believe you stated that he came to talk to Dusan

15   Bendzo; is that not correct?

16   A. Yes.

17   Q. They had a conversation outside of the hangar, did they

18   not?

19   A. Yes.

20   Q. So you did not personally hear what the conversation was

21   about, did you?

22   A. No.

23   Q. Thank you. Mr Landzo could have been a member of the

24   military police even earlier than August, could he not?

25   A. I don't know. He would probably have worn the white

Page 1395

1   belt.

2   Q. In fact, you made a statement in November that Mr Landzo

3   was in Celebici camp all the way through October, did

4   you not, and that was not correct, was it?

5   A. I did not say in November. I said that some time in

6   late August and early September -- I don't know exactly

7   when -- that he left the hangar, in fact, Number 6, and

8   that then he would be seen from time to time wearing a

9   white belt, and that he called out Dusko Bendjo.

10   Q. You also stated in your written statement to Ms McHenry

11   on November 14th -- and this is the translation; it is

12   not in your language -- you stated:

13   "I am sure that Zenga was in the camp until I was

14   transferred to Musala, which I believe to have taken

15   place at the beginning of November 1992."

16   Is that not what you testified to before?

17   A. November? I left in October. I left Number 6 in

18   October, but he was seen, that's what I stated. He was

19   seen while I was there. People could see him. He came

20   there and he visited the camp, but he had a white belt

21   at that time.

22   Q. So what you are telling us is that the statement that

23   was given on November 14th is incorrect; is that

24   correct?

25   MS McHENRY: Your Honour, he has not said that. There is

Page 1396

1   nothing incorrect about it. I object to her putting

2   words in his mouth. The statement as she read it says:

3   "I am sure he was in the camp."

4   He has just stated that he was in the camp. I

5   object to her suggesting that there is inconsistencies

6   when there are not.

7   MS McMURREY: Your Honour, Ms McHenry is omitting the part

8   where it says:

9   "I am sure he was in the camp until I was

10   transferred at the beginning of November".

11   That is what I am trying to make clear here. Now

12   the witness is saying that is incorrect. If the

13   statement is incorrect from November 14th, I have a

14   right to ask him to state that for the record.

15   That statement was incorrect, was it not?

16   A. That statement is correct. I repeat again: I saw

17   Landzo on several occasions. I don't know if he had

18   gone away from the camp or that he was there, but that

19   we could only see him more seldom, and he had a white

20   belt. I don't know when he went and to where he went

21   to, but I know that he took Dusko Bendjo out several

22   times. I don't know what else do you want me to tell

23   you. He was there. I saw him.

24   Q. You testified that you saw him in August and September.

25   Now he could have had the white belt and been with the

Page 1397

1   military police earlier than that, could he not?

2   JUDGE KARIBI WHYTE: I think the Trial Chamber will now

3   rise and we will come back and reassemble at 2.30 --

4   A. No.

5   JUDGE KARIBI WHYTE: -- for cross-examination to continue.

6   (1.00pm)

7   (Luncheon adjournment)

Page 1398

1   (2.30 pm)

2   JUDGE KARIBI WHYTE: Good afternoon, ladies and gentlemen.

3   We are back from lunch now. Ms McMurrey is still

4   cross-examining.

5   JUDGE JAN: Before you do that, I have a question to ask

6   from the witness. You have shown us the place in the

7   hall -- in this hangar where you were present. Where

8   were the two brothers who were forced to commit those

9   obnoxious acts? Where were they sitting in this

10   hangar? You have got the ELMO?

11   A. On the opposite side, facing near the entrance door, to

12   the right of it.

13   JUDGE JAN: If you could indicate the place, please, on the

14   ELMO?

15   A. This is where they sat.

16   JUDGE JAN: Thank you.

17   JUDGE KARIBI WHYTE: That is by the door, is it? They sat

18   by the door?

19   A. Yes.

20   JUDGE KARIBI WHYTE: Now how were the acts done? They were

21   called out from where they were sitting or they still

22   remained where they were sitting?

23   A. They got up from the place where they were sitting and

24   they did it in front of all of us.

25   JUDGE KARIBI WHYTE: Thank you very much.

Page 1399

1   A. You are welcome.

2   JUDGE JAN: The names of the brothers have been excised

3   from the record.

4   MS McMURREY: Thank you very much, and I do apologise to

5   the court.

6   JUDGE KARIBI WHYTE: Thank you. We knew it was a slip. It

7   was not intentional.

8   MS McMURREY: Witness F, Mr F, I wanted to ask you back.

9   The rifle that you described you bought, you bought that

10   rifle in front of your restaurant or the restaurant

11   Zjelko that you worked in in Bradina; is that correct?

12   A. In front of the restaurant Zjelko where I worked.

13   Q. The people you brought it from were SDS Serbs, were they

14   not?

15   A. No. These persons were not known to me. When I asked

16   them who did I buy it from, and they said: "This is not

17   something you should be asking. If you want to buy it,

18   buy it. If you don't want to, don't do it."

19   Q. I want to go to a person -- you did know a man named

20   Gojko Miljanic, did you not?

21   A. Yes.

22   Q. Mr Miljanic was an older man born in about 1931, was he

23   not?

24   A. Yes.

25   Q. Mr Miljanic died approximately on May 27th, 1992, did he

Page 1400

1   not?

2   A. He was beaten on 27th May 1992, and then he was brought

3   in later into the Number 6, and he lay there to the left

4   of the entrance, and he was showing some sign of life

5   for maybe 12 hours, maybe a bit longer, and he died

6   there.

7   Q. So he died some time way before 1st June then, did he

8   not?

9   A. Yes.

10   Q. And this Mr Miljanic, he was from Bradina, was he not?

11   A. Yes.

12   Q. In fact, the whole time that you were at Celebici, there

13   was no other person with the last name Miljanic that

14   died there, was there?

15   A. No. I don't know of any other person.

16   Q. Thank you. Now, you mentioned a lot of incidents in

17   your testimony yesterday and today, and the only names

18   of any guards that you mentioned during this exercise

19   were, of course, Esad Landzo and Mr Delic. You omitted

20   to mention the other guards that you knew participated,

21   did you not?

22   A. Well, it's been a long time. I don't remember them -- I

23   remember them very well, because Landzo and Delic were

24   getting inside the hangar most frequently. I know a

25   dark man with fingerless gloves. He also took people

Page 1401

1   out and beat them. There was a guy by the name of

2   Forjak. I don't know his name. I don't know who beat

3   people, of all those guards, and I don't know the names.

4   Q. But you did know the names at one time, did you not?

5   A. I knew their nicknames and for some of them I knew their

6   names too.

7   Q. In your testimony you also have described how after the

8   Red Cross came to Celebici for about fifteen days there

9   were not many beatings. The Red Cross came

10   approximately on August 12th, did they not?

11   A. Yes. The Red Cross came in mid-August. I think it was

12   on 12th August; that is right, yes, on 12th.

13   Q. In fact, after about fifteen days you said everybody was

14   beaten again, did you not, and that includes you?

15   A. Yes.

16   Q. You also know that Esad Landzo was not present after the

17   Red Cross visit in Celebici, was he; not as a guard?

18   A. He was there as a guard after the visit of the Red

19   Cross.

20   Q. Your testimony yesterday was that you had been beaten

21   once before, and then you had been beaten by Mr Landzo a

22   second time -- another time. You were only beaten by

23   Mr Landzo once. Your testimony yesterday was that he

24   kicked you a couple of times; is that correct?

25   A. Yes, he kicked me. That is correct.

Page 1402

1   Q. That was --

2   A. That is what I stated yesterday.

3   Q. That was before August 12th, was it not?

4   A. It was when the Red Cross came. That's when those

5   people were killed, the police officers. It was after

6   that. It was after that. That's when he kicked me

7   twice; two or three times he kicked me in my shin.

8   Q. In fact, that's the only time that you testify that

9   Mr Landzo beat you personally, is it not?

10   A. Well, I don't remember. I think it was the only time.

11   Q. Okay. Thank you.

12   Your Honours, I have some new notes that have been

13   passed to me. May I just have one moment? (Pause).

14   I have one more question. As far as Mr Landzo's presence in

15   the camp, you never saw Mr Landzo in Celebici before the

16   end of June, did you?

17   A. That's not what I said.

18   Q. Well, you did not see him in Celebici when you first got

19   there, did you?

20   A. He showed up after our arrival there.

21   Q. Okay. I pass the witness, your Honour.

22   JUDGE KARIBI WHYTE: Thank you very much.

23   Ms Residovic, I think. You can now take over the

24   cross-examination.

25   Cross-examination by MS RESIDOVIC

Page 1403

1   MS RESIDOVIC (in interpretation): Thank you, your Honour.

2   Good afternoon to you, sir. My name is Edina

3   Residovic. I am the defence counsel for Mr Zejnil

4   Delalic. Mr F, you have answered a number of questions

5   so far, the questions asked by my colleagues. I will

6   try not to repeat what you have already been talking

7   about. However, Mr F, the two of us, we share a

8   problem, and our colleagues did not have that problem

9   when they talked to you. We understand each other and

10   we could -- I could actually ask you questions, you

11   could answer very fast, but the judges and all the

12   others present here would then not be able to follow our

13   exchange. So I would like to ask you, and we have been

14   asked to do so by the Tribunal, if after my question you

15   could wait for this question to be interpreted and then

16   after you give me your answer, I will again wait for a

17   while so that everybody is able to understand what we

18   are talking about. I think that we agree on that?

19   A. Yes.

20   Q. Thank you very much. You have already confirmed that

21   you gave a statement in addition to the one that you

22   gave in Celebici in February 1996 to a representative of

23   the Office of the Prosecutor?

24   A. Yes.

25   Q. You speak before this Trial Chamber of many events. You

Page 1404

1   were probably shaken by your memory of it?

2   A. Yes.

3   Q. So I think that you will agree that your memory in

4   February 1996 was maybe a bit more fresh than your

5   memory right now, today. I will, therefore, repeat some

6   questions just to get clarification and I would

7   appreciate if you could answer those questions as

8   briefly as possible?

9   A. Yes.

10   Q. First of all, you testified that you lived in the

11   village of Krc?

12   A. Yes.

13   Q. You testified also that you had been arrested in the

14   hamlet of Barakusa?

15   A. Yes.

16   Q. So from the beginning of the fighting in Bradina you

17   left your village and you were moving towards some other

18   places; is that right?

19   A. Yes.

20   Q. Can you please tell us how far apart is Barakusa from

21   Krc?

22   A. 1 km, maybe a little bit more.

23   Q. Can you please tell us was it in Barakusa when you were

24   arrested that you surrendered the weapon that you had in

25   your possession?

Page 1405

1   A. Yes.

2   Q. So it is true that you left your house with the weapon

3   that you had?

4   A. Yes.

5   Q. Mr F, could you please confirm that it is true that in

6   your testimony you also stated that on 25th May, that on

7   that day some groups separated and tried to cross over

8   to the Serbian side; is that correct?

9   A. Yes.

10   Q. Is it correct that some of these groups were those that

11   were arrested later on in Igman and in the -- around the

12   village of Ljuta and were brought to Celebici when Pero

13   Mrkajic was brought there?

14   A. Which one was the one that you mentioned?

15   Q. It is one of those groups that had separated?

16   A. Yes.

17   Q. And who attempted to cross over to the Serbian side?

18   A. Yes.

19   Q. Thank you. It was not clear to me, because I know that

20   you testified that some groups had set off on 25th and

21   that you did not join those groups?

22   A. Yes.

23   Q. So we are in agreement about that?

24   A. On 26th some groups started. Maybe some did on 25th

25   already, but I know about the morning of 26th, that some

Page 1406

1   groups left.

2   Q. You know that Pero Mrkajic was in one of those groups;

3   Zara Mrkajic was there, Djordjic and the others?

4   A. Yes, that's what I heard.

5   Q. That is what you heard. All right. Thank you very

6   much. Is it correct, Mr F, that you testified that you

7   were attacked from the direction of Repovci by HOS and

8   HVO special forces and by the units from Buturovi Polje?

9   A. No, I said we were attached by the HOS units, who were

10   joined by our neighbours from the village -- living

11   around us, and they attacked Bradina, joining the forces

12   from Buturovic Polje.

13   Q. Thank you very much. You also confirmed that some of

14   them had camouflage uniforms, that some had black shirts

15   and trousers, and that those with black shirts and

16   trousers had black hats too?

17   A. Yes, hats.

18   Q. Thank you very much. I would also like you to confirm

19   whether it is true that in Dragan Subotic's house that

20   you were lined up and searched, that money, documents

21   and similar objects were taken from you. Is that

22   right? Is that what you said?

23   A. In front of Miso Kuljanin's cafe and women from in front

24   of Subotic's house. The houses are adjoining and maybe

25   they are 10 metres apart from one another. We were in

Page 1407

1   front of Miso Kuljanin's cafe.

2   Q. In your testimony given on February 23rd, 1996, when you

3   were speaking about these events, you said the

4   following, that among the people who were watching the

5   search, you recognised Zvonko Zovko among others; is

6   that correct?

7   A. No. I mentioned that in relationship to the fact when

8   he was beating my father.

9   Q. We will go back to that, Mr F. I am now referring to

10   the events in the village of Bradina. I have your

11   statement here and I wish to clarify this matter. In

12   this statement you said that among the people who were

13   present there you recognised Zvonko Zovko, your

14   neighbour from Podorasac; is that correct?

15   A. In front of Miso's cafe, yes.

16   Q. So in front of Miso's cafe you recognised your neighbour

17   from Podorasac, Mr Zvonko Zovko, and since this fact was

18   a bit unclear, thank you for the clarification. Also in

19   your statement you said that you recognised a man by the

20   name of Bosnak, whose first name you do not know. Is

21   that Zladko Bosnak from the police?

22   A. I don't know his name. He was a policeman. He used to

23   be a policemen. I don't know his name. He used to be a

24   policeman.

25   Q. His name is Bosnak. It is not a designation of his

Page 1408

1   nationality.

2   A. That's what he was called. I don't know if that was his

3   real name or his given name, but he used to be in the

4   police.

5   Q. Thank you, Mr F. For further clarification, taking into

6   account a number of events and your condition even here

7   today as a witness, I would like to ask you to remember

8   once again for additional clarification the events

9   surrounding your father. In your testimony so far, not

10   before this Trial Chamber but to the Prosecutor, you

11   said your father was three rows away -- apologies -- he

12   was the third person away from you?

13   A. Fifth or sixth. He was down the line from me.

14   Q. He was so close to you that you could see every word

15   that he said and every moan?

16   A. I heard him moan, but I could not hear every word he

17   said.

18   Q. Well, taking into account the small discrepancies, I

19   would not like to confront you now, but so much time has

20   passed. So please can you confirm that you heard on

21   that occasion that your father said: "Don't do that

22   Zvonko. We know each other." Then Zvonko said: "Who

23   knows you? Fuck his mother", and he then put a sock

24   inside his mouth to gag him; is that correct?

25   A. Correct.

Page 1409

1   Q. Thank you very much. Mr F, you have already said quite

2   a lot about your knowledge regarding Gojko Miljanic and

3   Petko Gligorevic. I would just like to ask you on that

4   day together with you from Bradina to Celebici were

5   Petko Gligorevic and Gojko Miljanic brought there with

6   you?

7   A. Yes.

8   Q. Gojko Miljanic died the next morning or during the

9   night?

10   A. Yes, in the morning.

11   Q. Petko Gligorevic also died as soon as he arrived?

12   A. After the beating he remained by the wall and he stayed

13   there.

14   Q. So it is clear that they were not with you in Hangar

15   Number 6 after that?

16   A. Yes.

17   Q. They died immediately after that or several hours later?

18   A. Yes.

19   Q. Thank you very much. Please allow me to go back to some

20   other issues. Your Honours, just a moment. These were

21   just some clarification issues.

22   You testified that the next day after your arrival

23   the seriously wounded people were all called out and

24   taken to the 3rd March school; is that right?

25   A. It wasn't the next day. It was within several days. I

Page 1410

1   don't know exactly how many days, but they were taken

2   there and later I heard that it was in the 3rd March

3   school.

4   Q. Is it correct that these persons were given some kind of

5   medical treatment?

6   A. After I was released, I heard that they were given some

7   pills, but I don't know. I did not see that.

8   Q. Is it correct that your father was also taken to the 3rd

9   March school?

10   A. Yes.

11   Q. Is it correct that your father was kept there for a

12   while for treatment?

13   A. Yes.

14   Q. Is it correct that your father never went back to

15   Celebici?

16   A. Yes, he did return and he gave a statement in Celebici,

17   and later he again went to Musala.

18   Q. Yes. After his statement he was not detained in

19   Celebici any more?

20   A. He was -- I don't know how many days he was. I can't

21   recall that exactly, but he was -- maybe after being

22   released -- after being released from 3rd March I think

23   he was there for a few days, and then he returned to

24   Musala.

25   Q. Mr F, you were also called after a couple of days and

Page 1411

1   you gave a statement?

2   A. Yes.

3   Q. You signed that statement; is that correct?

4   A. Yes.

5   Q. You stated in that statement that you were a member of

6   the SDS and that you had weapons?

7   A. Yes, yes.

8   Q. You also said in your statement that you were issued 270

9   bullets?

10   A. No.

11   Q. And that you used your weapon?

12   A. No, that is not correct.

13   Q. Your Honours, may I show this statement to the witness

14   to have him verify that it is his handwriting --

15   actually his signature, not his handwriting. Please

16   could you show this to the witness and provide the Trial

17   Chamber and everybody else with a translation?

18   JUDGE JAN: There are only two copies and we are three

19   sitting here.

20   MS RESIDOVIC (in interpretation): I am sorry.

21   MS McHENRY: I believe I have extra ones, if defence

22   counsel would like.

23   MS RESIDOVIC (in interpretation): This is the translation

24   done by the defence, since the translation provided by

25   the prosecutor contains several -- it was illegible in

Page 1412

1   several places. So it does not contain the translation

2   of the entire statement.

3   MS McHENRY: May I ask that the prosecution be given a copy

4   of this? Let me just say in the future -- obviously it

5   is not the prosecution who does the translation. It is

6   the Registrar's and we have no way of knowing. So we

7   have given the translations we have previously to the

8   defence. If they notice there are errors, it would

9   certainly be helpful for us if they would notify us in

10   advance. For now I would at least please like to see a

11   copy of the defence counsel's translation. Thank you.

12   Mr F, do you recognise your signature on this

13   statement?

14   A. It may be my signature. I recognise that I signed it.

15   It is my handwriting. However, what is written there,

16   that is not the statement that I gave. The statement

17   was not read out to me. I remember what I stated.

18   Q. Thank you very much. The defence wishes to tender this

19   as defence exhibit.

20   Mr F, in your testimony given to the Prosecutor --

21   JUDGE JAN: Mark it as a defence exhibit. It will be

22   defence Exhibit Number?

23   THE REGISTRAR: This is defence 1/1.

24   MS RESIDOVIC (in interpretation): We tender this as

25   evidence proposed by the Delalic defence, so this is our

Page 1413

1   proposal.

2   Your Honour, do you accept this evidence, the

3   statement given in the Celebici camp.

4   JUDGE JAN: This bears his signature admittedly. Whatever

5   its value, whatever its probative force, that can be

6   seen later.

7   JUDGE KARIBI WHYTE: You are tendering it as his

8   statement?

9   MS RESIDOVIC (in interpretation): All right. Thank you

10   very much.

11   Mr F, can you please confirm before this court

12   that Bradina is a village that is located on the main

13   route M17?

14   A. What do you mean M17?

15   Q. Main route that's called M17. Maybe you don't know its

16   name but it's the main route from Konjic to Sarajevo?

17   A. I don't, but yes.

18   Q. Can you confirm that it is the only blacked-up road and

19   the shortest road between Konjic and Sarajevo?

20   A. Yes.

21   Q. Could you please confirm that the railroad line linking

22   Sarajevo to Ploce also goes through Bradina?

23   A. Yes.

24   Q. Can you confirm that by blocking this road the normal

25   traffic and communication from Konjic to the places on

Page 1414

1   the other side of the Ivan mountain in Sarajevo is

2   disrupted?

3   A. If the roads are blocked, then also no other way to go.

4   Q. Can you confirm that from Tarcin, and that is the first

5   village on the other side of the Ivan mountain, to

6   Konjic it usually takes about half an hour to travel

7   there by car, between those two places?

8   A. That is correct.

9   Q. Can you please confirm that if this road is blocked, the

10   only way to go from Tarcin to Konjic is on a tarmac road

11   through Fojnica and Djusina, and that is more than

12   fifteen hours?

13   A. I never went there, but I heard about that road.

14   Q. Mr F, you know that the population of Konjic was mixed?

15   A. Yes.

16   Q. Can you testify before this court that the villages and

17   hamlets are mixed in such a manner that it is impossible

18   to separate them without endangering the people in other

19   villages and in Konjic?

20   A. I don't know in what way.

21   Q. In any way, so that each hamlet, each house, is

22   divided. Is it not virtually impossible? I mean, we

23   saw how it is possible by war. Everything is possible

24   if you do it by war, but under normal circumstances is

25   it possible to divide Konjic in such a way that people

Page 1415

1   do not bother each other if you block the roads, if we

2   do not allow each other to pass? Is the structure of

3   Konjic such?

4   A. Yes.

5   Q. Please, Mr F, do you know that the Konjic authorities on

6   several occasions tried to achieve a peaceful solution

7   to the problem and to effect the surrender of the

8   weapons?

9   A. I am not familiar with that, because if I may say this,

10   in early April the tunnel leading towards Bradina from

11   the direction of Sarajevo was blocked because they put

12   the lumber and put sand in there, and on the other side

13   they put explosives in a vehicle and by remote control

14   the tunnel in Bradina was blown up. This is what our

15   neighbours did. Somebody else may be a good witness to

16   testify to that, but I only know that that night Sefko

17   Niksic, Rale and Nusko, that's Rale Musinovic, they

18   came. They came to Pero's cafe and they were the last

19   ones who passed through that tunnel. That tunnel was

20   blown up and Bradina was blocked.

21   Q. Sir, you know that Bosnia-Herzegovina became independent

22   on 6th April?

23   A. I don't know that.

24   Q. Do you know that in April mobilisation was proclaimed?

25   A. I don't know that either.

Page 1416

1   Q. Did you and your family -- did anyone from your family

2   report -- answer that call-up? You would like to say

3   something, my colleague?

4   A. You mean the mobilisation?

5   Q. The TO in Konjic.

6   A. I know that the police, the police reserves, there were

7   four people from Bradina. When they pulled out, they

8   were by themselves: Nicon, Shojan, Seponjan, Lipoz.

9   None of them came any more.

10   MS McHENRY: I am sorry. I do not want to interrupt. Could

11   I ask you to clarify what his answer was with respect to

12   Bosnia-Herzegovina becoming independent on 6th April. I

13   am not sure.

14   JUDGE JAN: He said "yes".

15   MS McHENRY: He said "yes" and to the next question he

16   said: "I don't know that either." I want to clarify

17   there is not a translation error. If you could clarify

18   that matter, so the record is clear?

19   MS RESIDOVIC (in interpretation): We can repeat this

20   exchange. Do you know that Bosnia-Herzegovina was

21   recognised as an independent state by the international

22   community?

23   A. No.

24   Q. Do you know that mobilisation was proclaimed in April?

25   A. No.

Page 1417

1   Q. The next question was: did anyone from Bradina respond

2   to the call-up and join the Territorial Defence in

3   Konjic?

4   A. I am not familiar with that.

5   Q. You or any member of your family did that?

6   A. No, I didn't know about that and I don't know what

7   mobilisation and who wanted the mobilisation. That I

8   don't know. It's not clear to me.

9   Q. Thank you. Yet you had a weapon?

10   A. Yes.

11   Q. So you did know something. Did you know Strahinja Zivak

12   from Bradina?

13   A. No.

14   Q. Did you know Rajko Djordjic?

15   A. Yes.

16   Q. He was one of the ringleaders, one of the organisers of

17   the defence in Bradina?

18   A. There was no defence in Bradina. There was no lead

19   organiser, nor was there any defence. I think I already

20   said that twice. On 25th May we were attacked. On 26th

21   May people were already in the camps. The houses were

22   burnt. Everything was destroyed. People, livestock,

23   property -- everything around was destroyed, especially

24   from Lower Bradina, starting on 26th, and until 27th it

25   reached the Upper Bradina.

Page 1418

1   Q. Mr F, you said now that there was no resistance. Why

2   would 3,000 men, as you stated, take three days to

3   capture a small village?

4   A. This is what I heard when I was released, that there

5   were 3,000-3,500 men there. Why? You could notice that

6   when the shooting started on 25th and the shells, if

7   there had been any resistance in Bradina, nobody would

8   think of that. I think that in the census of 1991 there

9   was only 4,000 to 6,000, and I think out of that small

10   number of Serbs and the rest Muslims and Croats, and if

11   there were only 200 people in Bradina, what could they

12   do against 40,000 people?

13   Q. I forgot to ask you. A little while ago when you

14   mentioned the person by the name of Bosnak, can you

15   please remember, since you testified about that earlier,

16   that you witnessed when Bosnak beat Radoslav Kuljanin?

17   A. This is what I was told by Radoslav. It happened at

18   night. I asked him several days later. I said: "Who

19   beat you so bad?", because everybody at Celebici could

20   hardly hear me, and he said: "Bosnak".

21   Q. You said something in front of this court, then you made

22   a mistake, so it is true according to your knowledge

23   that it was Bosnak who beat Radoslav Kuljanin. That is

24   what you heard from Radoslav Kuljanin?

25   A. Yes.

Page 1419

1   Q. Can you please tell me: do you know Ranko Kuljanin?

2   A. No, no. Ranko Kuljanin, no.

3   Q. The security officer in the military factory in Igman in

4   Konjic?

5   A. Oh, no, I did not know him.

6   Q. Did you hear about him?

7   A. I don't remember him that much.

8   Q. Can you please tell me: did you know that Ranko Kuljanin

9   went by helicopter from Bradina to Belgrade at that

10   time?

11   A. I also heard that but I don't know that. I could not --

12   I did not see that. I don't know where I was when I

13   heard that, but I don't know that.

14   Q. Thank you very much. Maybe just one or two questions.

15   Did you in April and May go to Konjic?

16   A. In April, yes. That was in early April. I think I went

17   to the office, to the administration office, to be given

18   the vacation time.

19   Q. You were a member of the Secretariat of the SDS for the

20   village of Bradina; is that correct?

21   A. No, I was a member of the SDS but not of the Executive

22   Board. I was a member of the SDS.

23   Q. Do you know in April there was a decision forming the

24   Serbian municipality of Konjic?

25   A. 1992?

Page 1420

1   Q. Yes, in 1992?

2   A. No.

3   Q. So you did not go to Konjic in May? Do you have any

4   knowledge of intensive shelling of Konjic in that time?

5   A. No.

6   Q. Thank you, Mr F. This concludes my cross-examination.

7   JUDGE JAN: Madam Residovic, I just want to find out. To

8   what force do the black uniform people belong? Any

9   idea? I am sure of one thing. They are not lawyers.

10   MS RESIDOVIC (in interpretation): Your Honours, I -- yes,

11   they were not lawyers and not in the court room, that's

12   for sure. I believe that some experts, military

13   experts, will be able to explain that or other

14   witnesses. My assumption is that the Trial Chamber will

15   learn that in the course of the presentation of the

16   evidence.

17   JUDGE KARIBI WHYTE: Any re-examination?

18   Re-examination by MS McHENRY

19   MS McHENRY: Just one question in clarification. When you

20   just testified about Mr Radoslav Kuljanin being beaten

21   and he told you it was by a person named Bosnak, was

22   that the only incident of beating of Mr Kuljanin that

23   you are aware of?

24   A. No. There were multiple beatings of him. As he was

25   recovering, he sat to the left of the door about seven

Page 1421

1   or eight days and then he sort of came about. Later he

2   was beaten by Hazim Delic and on another occasion he was

3   taken out, and I think that there will be other

4   witnesses who may be able to tell much more about him,

5   who may know better, but so much time has passed that I

6   forgot a lot of things now. Some are coming back to me,

7   but these things one forgets during all this time that

8   has passed.

9   Q. Thank you. I have no further questions.

10   JUDGE KARIBI WHYTE: You do not require this witness any

11   longer? So he could be discharged.

12   JUDGE JAN: Put down the shutters so that he can go out.

13   JUDGE KARIBI WHYTE: Thank you very much. You have been

14   very helpful. Thank you.

15   (Witness withdrew from court)

16   Have you any other witness for today?

17   MR OSTBERG: Yes, your Honour. We are prepared to call our

18   next witness.

19   JUDGE KARIBI WHYTE: This time not a protected one?

20   MR OSTBERG: No.

21   JUDGE KARIBI WHYTE: I think the Trial Chamber will rise

22   and come back at 4 o'clock and carry on with the next

23   witness.

24   (3.25 pm)

25   (Short break)

Page 1422

1   (4.00 pm)

2   JUDGE KARIBI WHYTE: You can invite the witness now.

3   MR OSTBERG: Thank you, your Honour. I call Mr Stevan

4   Gligorevic.

5   JUDGE KARIBI WHYTE: Please let him take the oath.

6   MR STEVAN GLIGOREVIC (sworn)

7   Examined by MR OSTBERG

8   JUDGE KARIBI WHYTE: Take your seat, please.

9   MR OSTBERG: May I proceed, your Honour?

10   JUDGE KARIBI WHYTE: Yes, you can.

11   MR OSTBERG: Thank you. Will you please state your full

12   name?

13   A. (In interpretation): I am Stevan Gligorevic.

14   Q. And your date of birth?

15   A. 5th February 1950.

16   Q. Thank you. What is your occupation, your profession?

17   A. I am of a teacher, elementary school, first through

18   fourth grades.

19   Q. Thank you. Will you tell the court where you lived at

20   the end of May 1992?

21   A. At the end of May 1992 I lived in Hadzici. That is one

22   of the Sarajevo municipalitites, but I found myself in

23   my place of birth, because I had some property which I

24   worked in and I found myself there.

25   Q. Where is your place of birth?

Page 1423

1   A. Where I was born, that was in Bradina. I was born in

2   Bradina.

3   Q. So by the end of May 1992 you found yourself in Bradina?

4   A. Correct.

5   Q. What is your ethnical background?

6   A. Serbian.

7   Q. How many Serbs did live in Bradina at this time, by the

8   end of May 1992?

9   A. I don't know exactly, but from the census of 1991 there

10   was approximately 602 persons living there.

11   Q. All Serbs? My question would be: were other people

12   than Serbs living there?

13   A. In Bradina itself very few. There may have been three

14   or four Croatian families and two Muslim families.

15   Q. Thank you. Will you tell the court what happened in the

16   end of May in Bradina when you were there?

17   A. Well, this is what happened approximately.

18   Q. Yes, please.

19   A. Bradina was attacked from all sides somewhere around the

20   evening of 25th May. At first there was some heavy

21   shelling and the next day those units entered Bradina.

22   They burnt the side from which they arrived at, which

23   was called Suljina Strana. On that occasion, as I found

24   out later, because I was not there at the time,

25   approximately 20-30 people were killed. They were

Page 1424

1   unarmed and at close range.

2   My hamlet, Upper Bradina that is, those units

3   entered the Upper Bradina the following day, which was

4   27th May. I was at home and I was arrested there. They

5   collected us all in the middle of the village, which is

6   a part called Barakusa. Some soldiers in camouflage

7   uniforms came there and in black uniforms.

8   Q. Sorry to interrupt, Mr Gligorevic. Who were these

9   units? What kind of units were they? You did not name

10   them as far I could hear?

11   A. Those were Muslim units, I suppose, because some

12   recognised their own classmates from Konjic.

13   Q. Were there other than Muslim units?

14   A. I don't know exactly. Probably yes. As I said, some

15   wore camouflage uniforms and some black uniforms. Some

16   had the chequerboards on their heads and others wore a

17   half moon and a star.

18   Q. Was there any defence against attacks on the village?

19   A. It's hard to talk about defence, because there were

20   village watches, like everywhere else in Bosnia at that

21   time. There was no defence and I don't see any logic of

22   it, because Bradina was surrounded completely, from all

23   sides, by Muslim villages. So it stood no chance to

24   survive as such.

25   Q. Did you yourself do anything to defend yourself or

Page 1425

1   others?

2   A. No.

3   Q. Did you, for instance, have a weapon of some kind?

4   A. No.

5   Q. Have you ever been a soldier?

6   A. No. I should have done my military duty in 1968, but I

7   was released because of the poor eyesight. That was to

8   be in the former Yugoslav army. So I actually never did

9   my national duty.

10   Q. Thank you. Can you continue your account of what

11   happened to you?

12   A. They lined us up, formed a column, and we started

13   towards the centre of Bradina. The first collection

14   point was midway between my village and the centre of

15   Bradina in front of a cafe which was along the road and

16   it was called Miso. We stood there for a while while

17   the soldiers were taking things out of the cafe. That

18   is they were looting it. Then in a stolen Golf car --

19   it belonged to a cousin of mine -- a soldier arrived and

20   he started beating everybody. He had a long stick. I

21   don't know. There was a pipe or something. He started

22   beating people down to the ground. I don't know what

23   his name was. I only know that in the end one of his

24   superiors I guess -- I don't know who it was --

25   cautioned him, and he said: "Enough, Barba." I guess

Page 1426

1   his nickname was "Barba." I don't know his name. Later

2   I heard a young man, Muslim -- I heard that he was a

3   young man Muslim from the Celebici village.

4   After that we continued in the column towards

5   Bradina. We were at the tunnel where the railroad

6   tracks crossed the road, and we saw a group that was

7   already lined up against the wall, because there is a

8   retaining wall there, because there is a hill going up.

9   We were lined up there as well. We had to give our

10   personal data. Then we had to take off our shoes. We

11   were searched. We had to turn in all the valuables that

12   we had, rings and bracelets and everything. Then there

13   was a truck with canopies already parked there. Then

14   about three soldiers started calling out people.

15   Q. Before you start entering the truck and telling us what

16   happened, you said that you were giving your personal

17   data. Was somebody questioning you, or give us some

18   explanation as to how you were apprehended, or how

19   should I understand this, giving your personal data?

20   A. No. It was only name, the last name and the first name.

21   Q. So they did make a list of the people who were

22   apprehended?

23   A. Yes.

24   Q. How many were you? Do you have any evaluation of how

25   many people you were there?

Page 1427

1   A. Maybe -- I don't know the exact number, but 85, 86

2   approximately.

3   Q. Okay. Please continue the account.

4   A. The procedure that followed was that one by one we would

5   approach the back of the truck and then the order was to

6   -- this was now early May, and Bradina is 760 metres

7   above the sea level, so it was pretty fresh, and people

8   had to take off everything they had, and some elderly

9   people did not, and they beat them. Then they had to

10   climb up into the truck. I was next to the last and

11   behind me was Slovko Golabovic.

12   When I stood in front of them, first I had to take

13   off my glasses. I had to drop them on the road and then

14   jump on them. So they broke, and I only had a twisted

15   frame. Then I had to stand upright and the three of

16   them started to kick me, beat me with the rifle butts,

17   with their hands, and that lasted for several minutes.

18   Then they told me to get onto the truck.

19   That first time I climbed into the truck I still

20   had some strength and I weighed at around 104 kilos.

21   Then after my cousin Slovko was in, then they ordered me

22   to get off again. I got off again and then the same

23   game started with them. I had to stand upright and I

24   got a lot of beatings, and when I wanted to climb in, I

25   could not this time.

Page 1428

1   I took a running start again, tried again. Then

2   somebody offered me a hand from up in the truck and

3   somehow I climbed in. Then they lowered the back of the

4   canopy. They tied it securely. The truck was there for

5   a while. They -- maybe the engine was not in order,

6   because they were starting it and turning it off. Then

7   we eventually started towards Konjic.

8   Since the canopy was well tied up and there was

9   sun and there was a lot of us on the truck, I was losing

10   my breath, I was losing my air, because I was one of the

11   last. Maybe I was in a better position, because some

12   people were already suffocating further down. One of

13   them, who had some health problems before, was rolling

14   his eyes, because everybody was so packed one next to

15   another, and was uttering some inarticulate noises. We

16   were all drenched with sweat.

17   After a drive we arrived at Celebici. When we

18   entered through the gate we got out and they lined us up

19   against a wall, which was near the gate. At that time

20   the worst thing started.

21   We had to stand leaning against a wall both with

22   our chest and the stomach area, with our hands raised

23   high. At first that was not a problem, but later for me

24   it was more of a problem than the beatings that I

25   received, because it is terrible, terrible pain to keep

Page 1429

1   about seven hours to keep the hands up. You can't stand

2   -- you can't do that any more, because your arms just

3   keep sliding by themselves. Boro Koprivica was near me

4   and his balance centre was already damaged before and he

5   kept falling down, and myself and Slobodan Gligorevic

6   who was on the other side of him had to help him. That

7   was helpful because we were able to lower our arms at

8   that time.

9   There were three younger men in uniforms. I don't

10   know them. I know very few people there in Konjic.

11   They went around cursing. One of them was beating with

12   a rifle butt. The other one with the front part, and

13   the other one had a handle of a pickaxe, which was

14   broken off. Then a fourth one -- I don't know if that

15   was the same team or they took turns. One was pulling

16   out the piece from the rifle and was beating us up with

17   it. One of them had a large piece of stone or pebble

18   from the river Neretva and was hitting us in the back

19   with it. So that dragged on for hours. Some were

20   falling and standing up again.

21   Some people at that time were being taken out of

22   the line-up and made to lie down and then blows were

23   raining on them. We could not turn even for a moment to

24   see. All this was accompanied by curses, by mocking,

25   and I think that with all that physical torture it was

Page 1430

1   also the verbal humiliation, because for a while some of

2   the young men that were there were shouting loudly

3   something like: "Praise the Lord!","Merhaba, Selam

4   Aleikam!" Then we had to repeat it in unison. Then they

5   were saying -- they were asking which religion was the

6   best in the world. We all had to say that it was the

7   Muslim one. Then they were saying prayers from the

8   Koran and we had to repeat them.

9   With all that physical torture and humiliation I

10   also had great thirst. I was dehydrated by the hours of

11   being in a truck coming to Bradina. After I don't know

12   how many hours nearby there was a water pump and then

13   one would pump and we lined up against a little canal,

14   which was full of refuse, and since it was spring, it

15   had all the things that fall off the trees. I saw Petko

16   Gligorevic; I saw two streams of blood down his nose. I

17   also saw on the ground Gojko Miljanic, who lay there

18   motionless as well. I don't know what time it was, but

19   I assume it was around 9 o'clock. We went to the Hangar

20   Number 6. The lights were on. It was late May and it

21   was nearing --

22   Q. Just some more questions about what happened at this

23   wall. You mentioned -- did I get you right? -- you

24   mentioned the number of seven hours standing against

25   this wall; is that correct? You stood up for seven

Page 1431

1   hours?

2   A. Yes, you understood me correctly, because we came there

3   at around 2.00 pm and we got into the hangar at around

4   9.00 pm. That's Hangar Number 6.

5   Q. Were people forced to stand with their hands up all this

6   time?

7   A. Yes, precisely. An especially bad example is my

8   relative Radko Kuljanin, whose -- he couldn't extend his

9   fingers, and he could not do that next to the wall, and

10   then he was beaten with rifle butts, and Stanko Kuljanin

11   -- he is deaf and dumb from birth -- and they would

12   issue orders to him to keep his hands up, and he

13   couldn't hear them, and then he would be beaten even

14   more than the others.

15   Also the example of Miroslav Vujcic was pretty

16   bad. He was taken out of the line-up and to lie down on

17   the ground. He was beaten and he couldn't go through

18   this torture any more. He refused to go through this

19   humiliation. He jumped up and started running. That's

20   at least what I think, because we couldn't turn around

21   and look what was happening. They fired some shots and

22   killed him.

23   When we headed off towards the Number 6, I saw him

24   lying there in the grass.

25   Q. You have now named three persons. The one you last

Page 1432

1   talked about was shot. What about the two other persons

2   you named? Did you see what kind of -- the effect of

3   the treatment they had?

4   A. Well, death. That resulted in death. Petko was already

5   dead and Vujcic was dead. As for Gojko Miljanic, he was

6   in a coma. He was unconscious, so we transported him in

7   some kind of a wheelbarrow. It's used in construction

8   work. It's used to transport concrete when you're

9   building things, and we lay him down on a long crate in

10   Number 6 that was used for rifles, to store rifles. He

11   never regained consciousness, and the next afternoon, 24

12   hours later, he moved about. He uttered some

13   inarticulate sounds and he just died. He stayed with us

14   for 24 hours and he was taken away the next day.

15   Q. I have some more questions about what happened along

16   this wall. You said that different people took turns in

17   beating you; is that right?

18   A. Well, I do not know that, because we were not allowed to

19   turn around. I don't see how just three people could

20   keep doing that for such a long time. I don't know if

21   that was the same group. I managed to see one with the

22   end of my eye. He was a large person, large man, with

23   closely -- with a crew cut. They told me later, those

24   who recognised him, that it was a police officer from

25   the village of Japoluk near Tarcin, ex-police officer.

Page 1433

1   He used to be a police officer in former Yugoslavia.

2   Q. Were you aware of somebody being in command of these

3   people who beat the captured Bradina people?

4   A. I don't know. As for those who arrested us in Bradina,

5   they probably had a commander. As for those in

6   Celebici, whether some of them was a Commander, I don't

7   know. The only thing that I heard a voice admonishing

8   them. It is probably someone in command, that we

9   shouldn't be beaten on the head, because the first group

10   from Bradina had been taken the day before, and they

11   were beaten on the head, on their heads very severely,

12   and when they were transferred to Number 6 the next day,

13   their heads were injured.

14   We were beaten from our necks down to the bottom

15   of our backs.

16   Q. Thank you. Then you said you were taken to building

17   Number 6, Hangar Number 6; is that right?

18   A. Yes.

19   Q. Did somebody tell you something about where they were

20   taking you and informing you what was going to happen to

21   you or where you were being kept or something like that?

22   A. No.

23   Q. Did all of you go to Hangar Number 6?

24   A. Yes.

25   Q. And you named a figure something between 80 and 90.

Page 1434

1   Were there still that amount of people except for the

2   dead, of course?

3   A. Well, of all of those, Petko remained there because he

4   was dead. Miroslav Vujcic was also dead and we carried

5   Gojko with us into Number 6.

6   Q. Were there any other people in Number 6 when you arrived

7   there?

8   A. No. We were the first ones.

9   Q. In front of you you have -- if you stand up, you can see

10   a model of the camp, if you will have a look at it?

11   A. Yes.

12   Q. Can I ask the usher to give Mr Gligorevic something to

13   point with, and I will ask him if he can tell us

14   something about where he was placed: my first question

15   is: do you recognise this as a model of the camp in

16   Celebici?

17   A. Yes.

18   Q. Can you point to the wall where you were lined up after

19   your arrival at the camp?

20   A. We were approximately -- this is the wall where it

21   happened, (indicating) this wall here, and then after

22   that we were taken here between the command building and

23   number 22, and we went to Number 6 by this route, and

24   since I entered inside with the first group, I was

25   placed here by this wall, somewhere around the middle of

Page 1435

1   that wall.

2   Q. Thank you very much. You may sit down again.

3   Now, your Honours, I would like to introduce a

4   sketch to show that to the witness and I will have that

5   marked for identification. I have copies for the court

6   and for the defence: if authenticated, I plan to tender

7   this as evidence.

8   Mr Gligorevic, do you recognise this sketch?

9   A. Yes.

10   Q. Did you make it?

11   A. Yes.

12   Q. When did you make it?

13   A. I made it at the investigator to whom I gave a statement

14   last year.

15   Q. At the time when you were interrogated by a

16   representative from this Tribunal. Thank you. Will you

17   now on this sketch identify -- you can start by

18   identifying the door through which you entered these

19   premises?

20   A. How do you want me to show?

21   THE USHER: The ELMO?

22   MR OSTBERG: Yes, of course. So if you can diminish it a

23   bit so we can see the whole sketch maybe. A bit more.

24   A bit more. There we are. If you can make it a little

25   higher. There we are. Thank you.

Page 1436

1   Can you start with pointing at the door through

2   which you entered?

3   A. Yes, I can. (Indicates).

4   Q. Thank you. Where were you then put?

5   A. I was here at the top, on the opposite end, here, right

6   here near the middle of the shorter wall.

7   Q. Where there is a cross on the sketch, that's your place?

8   A. Yes.

9   Q. Did you stay at this place all the time you spent in

10   Celebici camp?

11   A. Yes, while I was in Celebici that is where I was

12   sitting.

13   Q. For how long time was that? When did you leave Celebici

14   camp?

15   A. I left Celebici on 4th October 1992 and then I was

16   transferred to Musala.

17   Q. Yes. Thank you. So in principle you spent the time

18   from 27th May 1992 to the beginning of October 1992 in

19   this very place?

20   A. Yes.

21   Q. Were you allowed to go and sit in any other place in

22   this building?

23   A. No. It was prohibited.

24   Q. Were you allowed out every now and then by need of

25   nature or something like that?

Page 1437

1   A. At the beginning, yes, during the first ten days or so,

2   from time to time, but let me tell you right now there

3   was not a great need for that. I don't know what

4   happened, whether it was because of a mental shock or

5   inadequate food. There was virtually no food at all.

6   Many people did not feel the need to defaecate. I, for

7   instance, only went out to defaecate after 13 days, and

8   I was among the first to do so. There were people who

9   did not have a bowel movement for 40 days. I can't

10   understand how a man can bear that, but that was what

11   happened. Some people had a bowel movement after as

12   many as 40 days.

13   Q. But when you were allowed out, say, after 13 days, as

14   you say, were you -- did they take you out in groups or

15   one by one?

16   A. Yes.

17   Q. They took you out in groups?

18   A. No, one by one.

19   Q. One by one. After you have been outside did somebody

20   follow you out and follow you back?

21   MS McMURREY: Your Honour, I am going to object to the

22   leading form of the questions that he is asking, both of

23   the questions now.

24   MR OSTBERG: I am trying to have the witness tell us what

25   happened, when he has just testified that he stayed in

Page 1438

1   this place, and I will see what exceptions there was

2   from this perpetual staying there. That is all my goal

3   with this line of questioning.

4   JUDGE KARIBI WHYTE: You can improve on that.

5   MR OSTBERG: Yes, your Honour. I will do that.

6   When you were allowed to go out, did someone

7   accompany you back?

8   A. There was not an escort, because the guard was nearby.

9   Just behind the hangar on a hill they dug out a septic

10   tank and there were two planks thrown over it and that's

11   where we defecated. As for the urination, we did that

12   into a ditch, a concrete ditch behind the hangar next to

13   a road, and there was water inside that ditch. That was

14   at the beginning. Then later on, when Mr Delic became

15   the Commander, he forbade that and then we were allowed

16   to go out twice a day in his presence, in the morning

17   when he came and then in the evening.

18   As for what it looked like, let me give you an

19   idea. He would say -- he would determine a group of

20   30-40 people, and they had to line up, and then they had

21   to run out of the hangar, stand next to the ditch and

22   those who were able to urinate, they did that, because

23   it was a very short time, and the next order was: turn

24   around and go back. One was not allowed to linger.

25   My problem was that I was always at the end of

Page 1439

1   this line and I was always the last to go out and I

2   didn't have enough time to do that, but maybe it was

3   also some kind of a psychological block, because I was

4   always expecting this order: "Turn around"; and I found

5   it very hard to do that.

6   So we ran back and then the other group would

7   follow us, and the same procedure was followed at

8   night.

9   In the meantime, whose who felt the need to

10   relieve themselves, if the guard was one of the good

11   ones, and if the Commander was not there in the camp,

12   then they would allow people to go out during the day.

13   If not, then they wouldn't be allowed to leave.

14   Q. Were you ordered to return to the same spot?

15   JUDGE JAN: He has already said that.

16   A. Yes, to the same spot.

17   MR OSTBERG: Thank you. When we are talking about the

18   general conditions in the camp, you may go on and tell

19   us something about the food, water supply and other

20   conditions.

21   A. The food was very bad. We would get a piece of bread

22   and at the beginning there was some vegetables too. At

23   first we left -- we went out and there was a crate right

24   next to the door, a rifle crate, and there was an army

25   can of some sort; I don't know what it's called. There

Page 1440

1   were five spoons, and so we would go out in groups of

2   five, and the amount of this too was we could eat about

3   one, two or three spoonfuls and then we would go back

4   and another group would come out. Later on we ate

5   inside. In the time when we were eating outside many

6   people were beaten, so some people did not dare to go

7   out at all. It was very strictly prohibited to take

8   more than what was the ration, and then later on this

9   was also -- we did not receive that. We only received

10   thin slices of bread, 14-16 slices per loaf.

11   Then approximately in mid-July, I think, even the

12   bread grew scarce, and then at one time we did not

13   receive any food for three days. People turned into

14   skeletons. You could hardly recognise them. Many could

15   not even stand up. They had to lean against something,

16   and if they stood up, they would fall down.

17   Then after that we began receiving some more food

18   again. I don't know what the reason was for that, and

19   another problem was water supply.

20   Q. Yes.?

21   A. You can imagine this was a hangar made of tin. The roof

22   and the walls were made of tin. There was just a small

23   door and in July and August, you can feel the influence

24   of the Mediterranean climate. It's very hot. It was

25   especially hard for us, for our group. We were placed

Page 1441

1   on the opposite side of the door and the heat was very

2   intense. There was not enough water, although there was

3   water flowing outside without any control.

4   Q. Thank you.

5   May I ask the usher to lower the ELMO; I cannot

6   see the witness from the point where I stand.

7   This document, now having been authenticated, I

8   ask permission to tender it in evidence.

9   JUDGE KARIBI WHYTE: The document is admitted.

10   MR OSTBERG: Thank you.

11   On the sketch we could see that there were lots of

12   small dots, being, I suppose, people sitting there.

13   Could you estimate -- you have told us already that

14   there were something like 80 persons brought there in

15   the first place. How many were you at the most in this

16   hangar during your stay?

17   A. Well, approximately when those from Number 9 were

18   brought in, they had been brought in the day before, and

19   when some other people from the village of Brdjani were

20   brought in for a time, there were about 240 people

21   inside that hangar. These people sat around next to the

22   walls and there were two rows down the middle. These

23   people, for the entire time, when they stayed there they

24   couldn't lean against anything.

25   Q. I see. Thank you very much. I will now turn your mind

Page 1442

1   to incidents, if any, that took place. Was there some

2   kind of mistreatment of the detainees?

3   A. Yes.

4   Q. Would you please tell us about it?

5   A. There are many instances of abuse. At the very

6   beginning, I think it was the second or third evening, a

7   group came in. They were looking for people from

8   Sarajevo. A cousin of mine stood up, Stravko Gligorevic

9   -- he really did live in Sarajevo -- and a man by the

10   name of Milosz, who lived in Sekilovic Kolonija in

11   Sarajevo, but he was originally from Bradina. So they

12   answered, and one of them approached this Milosz and

13   said: "Well, we are neighbours. I am also from

14   Sekilovic Kolonija." He wanted to shake hands with

15   Milosz and then he started beating him. He threw him

16   down on to the concrete floor and beat him mercilessly.

17   Another one beat Stravko in the meantime. They

18   picked them up and took them away. We learned later --

19   I don't know if it is true or not -- that Milosz was

20   killed on Igman and Stravko reached a prison in

21   Strasniza, where he was killed later.

22   For the first ten days there were no mass

23   beatings. That was the period when they were

24   questioning us, some kinds of judges were questioning,

25   and we were giving statements.

Page 1443

1   Q. Can we stay with that for just a moment and you tell the

2   court about this interrogation you were submitted to?

3   A. Well, it was like this. I went to see a man in

4   uniform. I did not know him. I do not know if he was a

5   judge. I do not think so. It was done behind the

6   building opposite the building number 22, that was the

7   command building. We squatted down and I had to confirm

8   whatever he put to me. I had to admit that I had a

9   rifle, although I did not have a rifle. I came from

10   Hadzici and I did not have any kind of weapon. I had to

11   also admit that I fired shots, although I didn't. I had

12   to sign in Cyrillic alphabet to make it more credible,

13   although I wanted to sign my name in the Roman alphabet,

14   because you couldn't even -- you couldn't use Cyrillic

15   alphabet at all down there. They simply said whoever

16   was up there had to have a weapon and you had to either

17   sign or to be beaten.

18   Q. And you signed?

19   A. Yes, I had to.

20   Q. Was this just a brief interrogation, or did it last for

21   some time? Did they go into details?

22   A. There were no details. No details were mentioned.

23   Well, as I already told you, we did that squatting down

24   on the pavement behind that building. It was a

25   confession made under duress that I had a weapon, that I

Page 1444

1   discharged the weapon. Where I was, where I came from.

2   This is just what I was telling you about, that I lived

3   in Hadzici and I went to Bradina, and that was it.

4   Q. Was this the only type of interrogation you were taken

5   to?

6   A. As far as I am concerned, that was the only one. I was

7   not interrogated again.

8   Q. Did they tell you why you were arrested, or did they

9   charge you with any crime at this time?

10   A. Well, nobody gave us any explanation, and we were not

11   allowed -- we did not dare to ask.

12   Q. Thank you. Can we now go back to the incidents that

13   took place during your stay in the Hangar Number 6?

14   A. Well, when those -- let's call them judges but they were

15   not real investigative judges -- when they completed

16   their task, then the prisoners started to suffer.

17   First, they were taken out at night and beaten. This

18   was really horrible. When the night fell, since the

19   door, the entrance door, did not have a lock, we used a

20   wooden plank to prop it up, and then they would put a

21   heavy rifle crate against it, and then when it became

22   really dark, when you heard that plank hit the asphalt,

23   when they started dragging it, dragging the crate along

24   the asphalt, then you knew what would happen.

25   The door would open and they would start calling

Page 1445

1   people out and taking them out. Many people were taken

2   out. They walked in. Then they would put them

3   somewhere, and then the next morning we would sprinkle

4   water over them and if somebody had some salt, they

5   would also apply that to the bruises. So it was really

6   horrible. Every night was a horror.

7   One morning -- I don't know the exact date -- I

8   think it was in mid-June -- they took out Milorad

9   Kuljanin. He was a young man from Bradina. They took

10   him behind the hangar and beat him and then we heard a

11   shot -- two shots I think it was, and they killed him.

12   Q. When you say "they took him out", did you ever see

13   somebody special taking anybody out?

14   A. No. I did not see anyone, because I was up there on the

15   opposite end of the hangar, and at that time the first

16   group, that was my group, we were going out for

17   urination in the morning, but some of the group were

18   already out there and one of them who saw that was

19   Zjelko Cecez, and he was killed that same evening.

20   Q. Did you see that killing?

21   A. No. I was inside. I was sitting at my place.

22   Q. You said that at night it was usual that somebody was

23   called out and guards came to take somebody. Can you

24   estimate how many times that happened, that prisoners

25   were taken out at night? Any way of estimating how many

Page 1446

1   times this happened?

2   A. Well, it happened many times, virtually every evening.

3   I remember very clearly the night when they were taking

4   people out there was a thunderstorm, a really bad

5   thunderstorm, and that night nobody was taken out. The

6   door was not opened, and we were very happy about that,

7   and that was because of the thunderstorm; nobody could

8   be taken out because of that. It lasted until, with

9   some brief interruptions, until the arrival of the Red

10   Cross, and during that period, in addition to the two

11   people I mentioned, Milorad Kuljanin and Zjelko Cecez,

12   Simo Jovanovic was also killed, and so was Scepo

13   Gotovac, Nedjo Magazin and Bosko Samoukovic, and Zjelko

14   Klimenta, I think, nicknamed Keljo.

15   Q. You have now named some of the people who were killed.

16   Did you yourself witness some of these killings?

17   A. I personally saw -- well, in fact, 240 people at least

18   saw that. That was the killing of Bosko Samoukovic.

19   Q. Can you tell us about what you and the others saw?

20   A. It happened in this way. The guard in our prison -- I

21   think his name is Esad and last name Landzo, nicknamed

22   Zenga, he would enter virtually every day when his shift

23   was on. It was from noon on. He entered the hangar and

24   then he would pick out somebody, and he would beat them.

25   Q. Would beat them inside the hangar or outside the hangar?

Page 1447

1   A. Yes. In the beginning at night when they were taking

2   people out at night, in which he took part, he would not

3   come into the hangar, because we were a lot in there.

4   There was no light in there, so maybe he did not dare.

5   Later the beating started in day-time, and people were

6   taken out and people were tortured. They were burnt.

7   Their ears were pierced. People were forced to eat

8   grass, and there were false executions. But all these

9   other things he did inside.

10   People in camouflage uniform came. They

11   introduced themselves as having come from Mostar.

12   Whenever somebody would come from outside, we would have

13   to get up and stand very still, ready, and look down

14   then, awaiting who they were going to beat, who knows

15   for what reason. One of them said his speciality was

16   that the prisoner would lie down and do push-ups, and

17   whenever he would raise himself, he would kick him.

18   After he left, the same practice was used by the same

19   guard, Zenga, and that became his speciality.

20   The other speciality was the plank that I said was

21   used to close the door. I don't know how. It was about

22   1.2 metres, about 5 cms thick, 10 cms wide, which he

23   would turn so that the narrower side would be down, and

24   the prisoner would have to come to where we were taking

25   food, and he would have to stand there, and he would

Page 1448

1   beat him in the rib cage area.

2   Q. You say "he" would beat him. Who was "he" in that

3   sentence?

4   A. Yes, I am talking about this guard Zenga, Esad Landzo.

5   Bosko was taken out the same way. He put his hands

6   behind his -- on his neck behind. He beat him a number

7   of times. He was moaning and then finally he fell down

8   and started to mumble, gurgle, and then he was taken out

9   so that he could come to a little bit. However, he

10   continued to gurgle. Then they took him to this Number

11   22 and shortly thereafter he died.

12   Q. Who was that person you now talked about? Did you give

13   a name to him? I did not get it?

14   MS McMURREY: Your Honour that is asked and answered.

15   MR OSTBERG: I did not get it, so for my information I would

16   like to hear it again.

17   JUDGE KARIBI WHYTE: What was the answer?

18   JUDGE JAN: Bosko was the name.

19   MR OSTBERG: Thank you.

20   JUDGE JAN: It has come on the record.

21   MR OSTBERG: Yes, yes, yes. You have now told the court

22   about the different kinds of methods used to mistreat

23   detainees. Was this an exhaustive account of the

24   methods used to mistreat them?

25   A. Well, no. One of the specialities of this guard Zenga

Page 1449

1   was to burn people. For instance, to Dusko Bendjo, and

2   I saw this with my own eyes, that is Zenga, at that time

3   he always had a little bottle filled with gasoline.

4   Then he would -- he poured -- from the knee down to the

5   ankles he poured this gasoline and set it on fire and

6   did not allow him to put it out, so later terrible

7   wounds developed and we all thought that he would lose

8   both of his legs. I think he still must have bad scars

9   from it. He also burnt -- that was the next thing.

10   Sometimes he would burn paper. Then he would heat a

11   knife on it and then he forces the --

12   MS McMURREY: I am going to object. Did this person say he

13   saw this second occurrence that he is talking about,

14   personally viewed it, or is he speaking from something

15   that he has heard from somebody else? This next

16   incident --

17   JUDGE KARIBI WHYTE: Why do you not allow them to interpret

18   what he is saying? Let us hear him before you object.

19   MS McMURREY: I would just like to know --

20   JUDGE KARIBI WHYTE: Let him make his statement. Then if

21   you object, we will hear your objection.

22   MS McMURREY: Then it is too late.

23   JUDGE KARIBI WHYTE: How do you object when you do not even

24   hear what he is saying.

25   JUDGE JAN: It all happened inside the hangar.

Page 1450

1   JUDGE KARIBI WHYTE: Please state what you are saying.

2   MR OSTBERG: Please go on and tell us: what you now have

3   accounted for, did that take place in the hangar or

4   outside the hangar?

5   A. With Dusko Bendjo, that was in the hangar and we all

6   watched it. Some others, like Nedjelko Draganic and

7   Spasoje Miljanic, to them it was happening outside.

8   Later on we all saw big wounds and blisters on hands. I

9   personally saw when to Mirko Djordjic, who was about

10   two, three places away from me in the same row, when he

11   burst his ear with a pincer. He couldn't hear. He

12   often beat him and he didn't bother to take them out to

13   the door but he would just beat them right there. He

14   would say: "Come and do push-ups." Then he started

15   kicking him. To Momir Kuljanin he was burning palms.

16   He had big blisters on his palms for days.

17   Q. Did you ever witness any sexual assaults to people? If

18   you saw this, please do not use any names.

19   A. Yes. That too happened. Some time in mid-July they

20   brought in two young men, whom I knew very well, because

21   I was their teacher in Bradina. They were two

22   brothers. They were singled out by Zenga for torture.

23   He beat them and then they had to slap each other's

24   face, for instance, and if the slaps were not strong

25   enough, then he would show them how it's really done.

Page 1451

1   One day they had to suck each other's penis.

2   Q. Again who is "he" in this account?

3   A. That was the guard Esad Landzo, Zenga.

4   Q. Did this take place just once or did it happen more than

5   once?

6   A. The beatings were very frequent, and the things I am

7   saying about, that sexual abuse, that was once, as far

8   as I know.

9   Q. Thank you. I will now ask you some questions about how

10   this camp was run. Have you any idea who was the

11   Commander of the camp?

12   A. As far as we knew, and in the beginning we didn't know,

13   I know that Hazim Delic was there every day. I assume,

14   and later we heard from the guards as well, that he was

15   the Deputy Commander of the camp. Who the Commander

16   was, at first I really don't know. I later heard that

17   it was Mr Pavo Mucic. However, he really would come

18   very seldom to Number 6, and I did not know him from

19   before. I assume that he was.

20   Q. Did you see any of these now named persons exercising

21   command in the camp?

22   A. Yes, I saw Delic, because we all had to obey him,

23   because all the guards had to obey him, and they were

24   even afraid of him. I don't know about Pavo Mucic. I

25   cannot recall when I saw him for the first time. I

Page 1452

1   cannot remember exactly, but I think it was somewhere

2   late June or early July.

3   MR GREAVES: Your Honour, if I can interrupt please for a

4   moment? I can see that the transcription is not

5   recording accurately the translation that was given. It

6   says "I cannot remember whether I saw him for the first

7   time."

8   The answer given was: "I cannot remember when I

9   saw him for the first time." I am anxious to make that

10   clear. That is not a correct transcription.

11   JUDGE JAN: What he said in the transcript is: "I can't

12   remember exactly but I saw him late in June and July."

13   That has come in the record. That has come in the

14   record. That is a fair translation of what he said.

15   MR GREAVES: I am anxious about the earlier use of the word

16   "whether" in the transcript. That is not what was

17   translated. It was "when" was the word.

18   JUDGE KARIBI WHYTE: It is "whether I saw him for the first

19   time".

20   MR GREAVES: That is what I heard being said over the

21   interpretation.

22   MR OSTBERG: So did I.

23   MR GREAVES: I am grateful to my learned friend Mr Ostberg

24   for saying that.

25   MR OSTBERG: That leads me to the question: did you see him

Page 1453

1   many times?

2   JUDGE KARIBI WHYTE: Excuse me. Repeat the question and

3   let him say what he wanted to say. Repeat this.

4   MR OSTBERG: Then I repeat my question this way: did you

5   see Mucic in the camp?

6   A. I saw him, but I cannot determine the exact time. I

7   think it was somewhere at the end of June or early July,

8   when the first groups were being transferred to Musala.

9   Q. Did you then continuously see him? I mean, to what

10   extent did you see him?

11   A. He came to Number 6 rather infrequently.

12   Q. Rather infrequently?

13   A. Yes, relatively seldom, but he was in charge of the

14   camp, the Camp Commander. You could infer that from the

15   guards who referred to him when he would arrive on a

16   motorcycle, and he arrived on motorcycles: "Here comes

17   the Commander", and everybody had to be in their

18   places. Even if there was beating going on, that would

19   stop, and the prisoner would be put back into the

20   hangar.

21   MR OSTBERG: Thank you. Now, tell us about if and in what

22   way you saw Mr Delic exercising his command?

23   A. That was obvious. There was no question there. I would

24   say all guards -- as I said, all guards were afraid.

25   When he was there, they all had to be in their places

Page 1454

1   and in front of him. We had to get up when he would

2   enter the hangar. We had to stand at attention and look

3   down before us. We couldn't look straight, and from all

4   that we inferred that he had a certain function and then

5   later we heard that he was a Deputy Commander.

6   Q. Okay. Did he use to come to Hangar Number 6?

7   A. Yes. He would come very often.

8   Q. Can you tell us about some -- were there some obvious

9   reasons for his visits to the hangar?

10   A. Well, probably to control his guards, to control us, and

11   to abuse us. Delic was one of those who also took a lot

12   of people out and beat them also inside the hangar

13   itself too. Sometimes he beat everybody one by one.

14   Sometimes he would skip someone. Sometimes he had his

15   own, as we called it, patients, and he beat them only,

16   like Dusko Bendjo, Vukasin Mrkajic. Most often those

17   were the blows: "Turn around, put your hands on your

18   neck", and then he would hit them a few times, or even,

19   because this Mrkajic was in the middle row, he didn't

20   have to get up. He would just sit and he would hit

21   him. It came to the point where Mrkajic's ribs were

22   fractured and blue, and when Delic would come in, he

23   would start begging: "Please don't, Mr Commander."

24   Q. Can you specify how he hit them? With hands or with

25   some instrument or in what way this happened?

Page 1455

1   A. Most often he would kick them and when there were mass

2   beatings, most often he used whatever he had, either a

3   broomstick or a shovel, which would be somewhere around,

4   something that was at hand. Sometimes he would have two

5   -- sometimes he would break two handles against the

6   bodies of prisoners.

7   Q. Just a moment, your Honour. I am just checking my

8   papers. I will ask again about Delic. You named he

9   used swords and you mentioned also -- I have to check --

10   can you remember other instruments he used?

11   A. What I mentioned is what he used most frequently. For a

12   while, it is interesting, and that was only for one

13   prisoner, he used a gadget which produced electric

14   shocks. That was used on Davor Kuljanin. He used that

15   rarely on anybody else. What we remembered in

16   particular was that famous baseball bat, which he

17   carried around a long time, and when he showed up in the

18   hangar with it, it was then known that somebody was

19   going to get beaten with it.

20   Q. When you described this, have you any possibility to

21   remember in which time-frame it took place? Was this

22   some special time during your stay in Celebici? If you

23   can try to name a month or length of time from this

24   treatment from Delic, so we know how to place it in

25   time?

Page 1456

1   A. That was during the summer, I think in July and in

2   August, when he carried that out. I don't know exactly

3   when it was when he brought it in the first time, but it

4   was present for a long time.

5   Q. A long time is a very general description. Could you

6   tell us: are we talking weeks, a month?

7   A. About a month and a half maybe.

8   Q. You told us a lot of mistreatment committed by Zenga,

9   Esad Landzo. Can you also put that in a time period of

10   some kind?

11   A. All these crimes, the killings, happened between

12   mid-June until early August. In the second half of July

13   I believe Milorad Kuljanin and Zjelko Cecez and Scepo

14   Gotovac were killed, as well as Simo Jovanovic and Nedjo

15   Milosevic, and I think somewhere towards the end in the

16   second half of July there was also the killing of Bosko

17   Samoukovic, and around that time, right after that is

18   correct, I think it was just after that, Zjelko Klimenta

19   was killed. That's about the time period.

20   I forgot to mention a strange death. That was

21   Cedo Avramovic, who was with us several nights only. He

22   was arrested somewhere in Konjic and brought there. We

23   did not hear anybody coming in and leaving. It was

24   totally dark and everybody was asleep. I heard some

25   rumble and something like a running between the rows,

Page 1457

1   and then I heard some dangling, something like as if

2   there was a wire, as if a wire was rubbed against some

3   metal object, and then there was a blunt blow, and then

4   everything was quiet, and in the morning when it grew

5   light between the rows Cedo's clothes were folded. It

6   was very neat, as if it was going to be put in a

7   suitcase, and several metres away from me he was there

8   lying dead, stripped to the waist. What happened we

9   never knew. We speculated that he just went insane and

10   that's what happened, I think.

11   Q. So there was no-one in the Hangar Number 6 to kill him

12   or to reach this effect?

13   A. We really literally didn't see anyone.

14   Q. You mentioned initially that you stayed in this camp

15   until 4th October 1992. Can you tell us what -- the

16   circumstances around your leaving the premises?

17   A. Occasionally groups of 20 or 30 people would be

18   transferred to the Musala prison in Konjic. Usually the

19   Commander would come, the camp Commander, Mr Pavo Mucic,

20   and the Deputy, Mr Delic, and then we all had to stand

21   at attention and they determined who they were going to

22   transfer to that camp in Musala. My turn came. I was

23   selected and on 4th October we were transferred to

24   Musala.

25   Q. How long did you stay there then?

Page 1458

1   A. I stayed until 6th October 1994, so I don't know what

2   period it is. About two years. Otherwise I was there

3   two years, four months and nine days in total.

4   Q. Thank you. I am ready to conclude my -- have I missed

5   some? Maybe.

6   Mr Gligorevic, you have in your account mentioned

7   many names of people being killed, but in some instances

8   you haven't given any direct details of what happened,

9   what you saw yourself or heard yourself. That brings me

10   back to take up some of these names to put some

11   questions to you. I have three persons on this list and

12   I ask your Honours if that maybe could be put on when we

13   continue examining this witness, the time now being

14   5.30.

15   JUDGE KARIBI WHYTE: I thought you had reached the end of

16   your examination-in-chief, but since you are still

17   continuing we will then have to adjourn until Tuesday at

18   10.00 am.

19   MR OSTBERG: Thank you.

20   JUDGE KARIBI WHYTE: You will have to continue to this

21   witness?

22   MR OSTBERG: Yes, before I give it to the

23   cross-examination. We will still have him nevertheless.

24   JUDGE KARIBI WHYTE: Thank you very much. This is as far

25   as we can go today. The witness is still available so

Page 1459

1   when he comes on Tuesday, we will continue with him.

2   MR OSTBERG: Thank you. The Trial Chamber will now adjourn

3   until Tuesday at 10.00 am.

4   (5.30 pm)

5   (Hearing adjourned until Tuesday morning at 10.00 am)