1 Wednesday, 9 February 2005

2 [Open session]

3 --- Upon commencing at 9.06 a.m.

4 [The accused entered court]

5 JUDGE AGIUS: So, Mr. Registrar, could you call the case, please.

6 THE REGISTRAR: Yes, thank you, Mr. President. Case IT-03-68-T,

7 the Prosecutor versus Naser Oric.

8 JUDGE AGIUS: I thank you, and good morning to you.

9 Mr. Oric, good morning to you, too. Can you follow the

10 proceedings in your own language?

11 THE ACCUSED: [Interpretation] Good morning, Your Honours, ladies

12 and gentlemen. Yes, I can.

13 JUDGE AGIUS: I thank you.

14 Appearances for the Prosecution.

15 MS. SELLERS: Good morning, Your Honours. My name is Patricia

16 Sellers of the Prosecution. I'm accompanied by co-counsel, Ms. Joanne

17 Richardson, and our case manager is Donnica Henry-Frijlink. Good morning

18 to Defence counsel also.

19 JUDGE AGIUS: I thank you, and good morning to you and your team.

20 Appearances for Naser Oric.

21 MS. VIDOVIC: [Interpretation] Good morning, Your Honours. Good

22 morning to my learned friends and colleagues from the OTP. I'm Vasvija

23 Vidovic. Together with Mr. John Jones, I appear for Mr. Naser Oric. We

24 have with us our legal assistant, Ms. Jasmina Cosic, and our case manager,

25 Mr. Geoff Roberts.

1 JUDGE AGIUS: I thank you, and good morning to you, too.

2 Now, any preliminaries before we bring in the witness? I see

3 none.

4 Usher, please.

5 [The witness entered court]

6 WITNESS: ANDJA RADOVIC [Resumed]

7 [Witness answered through interpreter]

8 JUDGE AGIUS: Good morning, madam.

9 THE WITNESS: [Interpretation] Good morning.

10 JUDGE AGIUS: And welcome, once more. Please take a seat, and we

11 will proceed with your testimony.

12 Yes, Ms. Sellers.

13 Examined by Ms. Sellers: [Continued]

14 Q. Good morning, Ms. Radovic. I would like to resume my questioning

15 concerning your arrival in Srebrenica, and I believe you testified that

16 you arrived with four of the other persons who were prisoners from Cerska,

17 and brought by Mr. Zulfo Tursunovic and two other armed and camouflaged

18 men. I would like to ask you, when you arrived in Srebrenica, did you

19 immediately go and register your names with any agency?

20 A. First they brought us to a room. Two men beat us there,

21 especially the three men. And then later, in the evening, and at night, a

22 man took me to the women's room and he took them to the men's room.

23 Q. Well, when you were in the room where the people beat yourself and

24 the other men, could you please tell me what clothes, if any, were the men

25 who beat you wearing?

1 A. Black uniform and black shades.

2 Q. Were any of the men wearing camouflage uniforms or civilian

3 clothing?

4 A. Srebrenica, you mean, or my men --

5 Q. No, I'm sorry, I'm talking about the men you met when you came to

6 Srebrenica, in that room where you were beat.

7 A. They were all in uniform.

8 Q. Now, was Zulfo Tursunovic and the other two men who had escorted

9 you from Cerska, were they in the room while you were beat?

10 A. No.

11 Q. Would you please describe for the Trial Chamber the type of

12 beating that you received and the type of beating that the other men - I

13 imagine you're referring to Jakov Dzokic, Mr. Ilic - received in the room

14 also.

15 A. You mean in this room where they brought us or in the prison in

16 general?

17 Q. No, I'm talking about in the room where they brought you when you

18 first arrived. The other person would be Rado Pejic, excuse me. What

19 type of beating was administered in that room when you first arrived?

20 A. The other person, Rado Pejic, they kicked him and slapped him.

21 His head was bleeding because he had banged his head against a cupboard.

22 Q. Did Zulfo Tursunovic return to the room where he had left the four

23 of you?

24 A. Yes.

25 Q. Did he make any remark concerning the physical appearance of

1 yourself or of the other men he left with you, the imprisoned men?

2 A. He showed aggression against those two uniformed men.

3 Q. Was he mad that they had beaten you?

4 A. Probably, when he saw those men bleeding.

5 Q. Now, when you say "he saw those men bleeding," are you referring

6 to Mr. Pejic, Mr. Ilic?

7 A. Dzokic too.

8 Q. And Mr. Dzokic. So it's your testimony that Mr. Tursunovic

9 visibly saw injuries, and then was mad at the men in uniform --

10 A. Yes.

11 Q. -- who administered them. Now, just to recap a bit, when you

12 arrived in Srebrenica, you stated that it was the evening; is that

13 correct?

14 A. Yes.

15 Q. And also, you stated -- you testified prior that it was the 26th

16 of January, 1993; is that correct?

17 A. Yes. Yes.

18 MS. SELLERS: Your Honour, I would like to show the witness an

19 exhibit that's priorly been marked P15.

20 Q. Ms. Radovic, I'd ask you to look at the document that's in front

21 of you. And would you just confirm for the Trial Chamber that the date at

22 the top of that document corresponds to the date that you arrived in the

23 Srebrenica prison? I'm sorry, corresponds to when you arrived in

24 Srebrenica.

25 A. It says here the 9th of January, 1993, and that is not correct.

1 Q. I'm sorry, could I see the document that you're referring to.

2 JUDGE AGIUS: It's on the screen.

3 MS. SELLERS: I'm sorry, this is not the correct document. Your

4 Honours, could you give me one minute, please.

5 [Prosecution counsel confer]

6 MS. SELLERS: Excuse me, for clarity's sake, it's part of P15. It

7 would be ERN 01239555. Could we please show that to the witness.

8 THE WITNESS: [Interpretation] The 26th of January, 1993, that is

9 the exact date.

10 MS. SELLERS:

11 Q. And would you also look below where it says "hour," and it says

12 between 1400 and 2200. Would you agree that you arrived in Srebrenica

13 between 1400 hours and 2200 hours?

14 A. We arrived in the evening. It was dark. I cannot remember the

15 exact time. I did not have a watch. But it was dark, and there were

16 already lights on, so we couldn't really distinguish anything when they

17 brought us into the prison.

18 Q. Now, would you look at that document where it says number 1, and

19 next to it, it says "Dzokic." Is this the person who you were referring

20 to, who you were in the stable with, who you walked between Cerska and

21 Srebrenica with, and was now with you in the room when the beating was

22 administered?

23 A. Jakov Dzokic. That evening, he was not in the prison with me, but

24 he had been with me in the stable. He had been taken to the men's room.

25 We heard him moan outside the door. Someone told me, You're no longer

1 going to be helping the army. But we could only hear very little of what

2 was going on because the door was closed, and we were in the women's room.

3 Q. Would you look at the person's name next to number 2. It says

4 "Ilic." Is this the Ilic who you were in prison with in Cerska and who

5 came down to Srebrenica with you on the 26th of January, 1993?

6 A. Yes. Dragan Ilic, son of Ljubinko.

7 Q. I'd also ask you to look at number 3. Is this the same Pejic that

8 you testified about who was in prison with you in Cerska, who came down to

9 Srebrenica with you on the 26th of January of 1993?

10 A. Rade Pejic, yes, he came with me, or rather, with us to

11 Srebrenica.

12 Q. And number 4, does that person refer to you, that name?

13 A. Yes.

14 Q. Now, Ms. Radovic, had you transferred or given any information

15 concerning your date of birth, where you had lived, where you had

16 originally been captured, to Zulfo Tursunovic any time from his arrival in

17 Cerska to your arrival in Srebrenica?

18 A. I provided information in Bajrici when they captured me and

19 brought me to that room. I gave them all my personal information, as well

20 as details stated on my ID.

21 Q. And the night that you arrived, is it your testimony that you did

22 not personally give any information to someone whose name is Fahrudin

23 Delic, the name you see at the bottom of this document.

24 A. No. The next morning, they took me away. I can't remember the

25 man's name, but they took me away the next morning. I told them whatever

1 I told them, and he then said, You are free to go. He treated me in a

2 fair manner, and it was a brief thing.

3 MS. SELLERS: Your Honour, I'm finished with this document at the

4 moment. It's already been marked and is an exhibit.

5 I'd also like to be able to tender the complete English

6 translations of the document. I believe people have the first page.

7 Co-counsel, Gramsci Di Fazio, I believe, might have used the document, but

8 we were not able at that point in time to hand up the complete English

9 translations.

10 Q. Thank you, Ms. Radovic. After...

11 A. Please go ahead.

12 Q. After Zulfo Tursunovic --

13 JUDGE AGIUS: And this was P15 -- was it P15?

14 MS. SELLERS: P15, yes.

15 JUDGE AGIUS: Yes. Thank you.

16 MS. SELLERS:

17 Q. Ms. Radovic, after Zulfo Tursunovic came back to the room where

18 you had been held and where there was a beating, did he then take you and

19 the other males to another building or another location?

20 A. That man was taken out and then someone else was brought along.

21 But it was dark, so we couldn't see. They were taken as far as the door

22 to the rooms.

23 Q. Could you please describe the other building that you were taken

24 to, and whether you met other prisoners there.

25 A. I can only describe across the way, I didn't see a single

1 prisoner. I only went into a single room where the man was. I didn't

2 know his name. The name was stated there, but I didn't see any other

3 prisoners there --

4 Q. Excuse me, I'm referring to the previous night, the night of the

5 26th, when you testified that Zulfo Tursunovic took you and the other men

6 to another building.

7 MR. JONES: I'm not sure if she actually did say that Zulfo

8 Tursunovic took her to a building, or it's not even clear yet that she had

9 been taken to the building.

10 MS. SELLERS: I'll withdraw that question.

11 JUDGE AGIUS: I think you're right, Mr. Jones.

12 MR. JONES: If my friend could lead as little as possible at this

13 stage when we come to the prison.

14 JUDGE AGIUS: Certainly. I'm sure Ms. Sellers knows how to do

15 that.

16 MS. SELLERS:

17 Q. Ms. Radovic, you testified that you were in a room with the other

18 male prisoners where they were beaten up, and afterwards you testified

19 that Mr. Zulfo Tursunovic came back to that room and that he appeared

20 angry to the men who had beaten you up. My question now is: Did you, Mr.

21 Ilic, Mr. Dzokic, and also Mr. Pejic, were you then taken from that room

22 and taken to another place in Srebrenica that night?

23 A. That night we were taken to the prison only. I was placed in the

24 women's room and they were placed in the men's room.

25 Q. Would you please describe what the women's room in the prison

1 looked like.

2 A. The room was quite high. The windows were very large. It was

3 cold in it. There were a number of women there. We slept on the floor.

4 We only had one blanket to go around, to lie on and to protect ourselves

5 with. We had some timber from a barrel, but we didn't have a stove to

6 make a fire.

7 Q. Now, you stated that you were taken to this building. Could you

8 please tell the Trial Chamber, who took you or escorted you to this

9 building where the women were in the prison?

10 A. Zulfo took us outside that other room, and then I don't know who

11 it was that took us over, in a manner of speaking, because it was

12 nighttime.

13 Q. Now, in this other building where you met the other women, was it

14 your impression that these women were imprisoned?

15 A. Yes.

16 Q. Were you placed in a room where the door was locked? Or was the

17 door open and you had free access to go in or out of the room?

18 A. The door was not locked, but the door was locked from our side.

19 We couldn't leave. They, on the other hand, could go in and out as they

20 pleased.

21 Q. Now, when you referred to "they," could you tell the Trial Chamber

22 who "they" were?

23 A. Those guards who were on duty, and whoever else wanted to come in.

24 Q. Now, the guards on duty, could you tell the Trial Chamber whether

25 they were dressed in a uniform or whether they were wearing civilian

1 clothes?

2 A. They were all in uniform.

3 Q. And was their uniform similar to the uniform that Zulfo Tursunovic

4 was wearing or the other men who escorted you from Cerska?

5 A. Those guards who were there had no insignia on their sleeves, or

6 armbands.

7 Q. Could you please tell the Trial Chamber, if you remember, how many

8 guards were outside of the door where the women were?

9 A. They all sat across the way in the corridor outside our room.

10 They were usually two -- there were usually two a shift, but I couldn't be

11 sure because we weren't allowed to go out and look.

12 Q. Now, inside the room where the women who you had the impression

13 were imprisoned, did you have the ability to learn the names of at least

14 some of those female prisoners?

15 A. Yes.

16 Q. Please tell the Trial Chamber, if you remember, the names of the

17 female prisoners.

18 A. Dostana Filipovic, from Bjelovac. Milka Tomic from a place near

19 Bratunac. Milisava Nikolic from Kravica. There were two women named

20 Milena from Skelani. Zivana, with a daughter Svetlana, nicknamed Svetsa.

21 There was Zeljko there too. But the women slept in the house and not with

22 us. Mira Filipovic, Dostana's sister-in-law, she lived in the house with

23 two small children; Olivera was three, and Nemanja was six months old.

24 There was an old women named Danica and Aunt Stojanka. I called her

25 Stojanka, but I never saw those women. I went to visit Dostana in the

1 hospital. She died, and --

2 THE INTERPRETER: The interpreter didn't get the last name of the

3 person who stayed alive and is from Kravica.

4 MS. SELLERS:

5 Q. Could you please state the name of the person who was from

6 Kravica, who stayed alive?

7 A. Milisava Nikolic, from Kravica, she survived, but her nerves were

8 damaged badly. Dostana Filipovic, from Bjelovac, on the other hand, died.

9 THE INTERPRETER: Correction: It should read the boys lived in

10 the house, not the women lived in the house.

11 MS. SELLERS: Thank you, interpreter.

12 Q. Could you tell the Trial Chamber, during your stay at the prison,

13 was there enough room for the women to lie down and sleep in that room?

14 A. Well, yes, there was enough room on the floor. I can't say

15 otherwise. We had an agreement to put two blankets on the floor so that

16 we wouldn't be cold, and then three of us would sleep on those two

17 blankets and cover ourselves with the third blanket so as not to be cold.

18 Q. And were you also given food on a daily basis while you were in

19 the prison?

20 A. We would receive food in the evening and in the morning, in the

21 course of 24 hours. We would receive food regularly in Srebrenica.

22 Q. While you were in the prison in Srebrenica, were you ever beaten

23 or physically assaulted?

24 A. I was slapped twice by one man, but I cannot remember any other

25 details about him.

1 Q. Did you, at times, receive visits from people, such as Muslim

2 women, while you were in the prison?

3 A. Yes. They used to come, two girls, whose names I don't know.

4 When we went to be exchanged, they stayed quite a long time with us. They

5 bid us goodbye, very properly. We said goodbye to them. They wanted to

6 move to Tuzla.

7 Q. So would it be your testimony that, although conditions were very

8 bad, that while you were at the prison in Srebrenica, the women did not

9 suffer any physical attacks but just endured the hardship in terms of the

10 limited space and limited food?

11 MR. JONES: I hate to object, but the witness never said the

12 conditions were very bad, she never said anything about hardships. Again,

13 this inference on my learned friend's --

14 MS. SELLERS: You're right, that might be characterisation.

15 JUDGE AGIUS: Objection sustained. Rephrase your question,

16 Ms. Sellers.

17 MS. SELLERS: Right.

18 Q. Ms. Radovic, would you agree that during your time period in the

19 gaol in Srebrenica, the prison in Srebrenica, that although your food was

20 limited to once a day, I believe your testimony --

21 JUDGE AGIUS: Twice a day.

22 MS. SELLERS:

23 Q. -- twice a day, and that you slept on the ground with three on a

24 blanket, but that you were never assaulted or otherwise physically injured

25 while in the prison.

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1 A. I was not assaulted. I was slapped only twice. As for the other

2 women who I found there in prison, I don't know.

3 Q. Now I'd like to ask you about the men who came with you from

4 Cerska. Do you know whether they were placed in the same building or not?

5 A. Yes, in the same building, but they would take a different hallway

6 or they would go straight through the hallway, whereas I was right across

7 from the hallway.

8 Q. Do you know approximately how far away they were from the women's

9 room in that same building?

10 A. Well, two and a half to 3 metres.

11 Q. Were you able to hear them in the room that you were in with the

12 other women?

13 A. Yes.

14 Q. Did you ever hear what appeared to be, from your point of view,

15 sounds of suffering or sounds that implied infliction of pain?

16 A. We heard moans, but we couldn't tell who moaned, we couldn't

17 recognise the voices.

18 Q. Do you know whether the moans were coming from male prisoners or

19 coming from people who were not imprisoned in the building?

20 A. Most likely from the prisoners. Nobody else could have come in.

21 Q. Did you ever hear any names, or something that would give you the

22 impression that you might have known one of the prisoners who was moaning?

23 A. Well, I told you that I heard when they beat Jakov, asking him,

24 Well, whose army are you going to serve now, whose army are you going to

25 serve in now.

1 Q. Do you know whether the beatings took place where the men were

2 held or whether they took place in the corridor or some other place in the

3 building?

4 A. Several times we heard in front of our door, but we couldn't see

5 anything, because we couldn't see through the door.

6 Q. And could you tell the Trial Chamber what it is that you heard

7 near the door?

8 A. Moans, as I told you.

9 Q. Now, would you hear this on a frequent basis, on a daily basis, or

10 was this only occasional, once or twice during your stay?

11 A. Every other night.

12 Q. How long a period of time would you estimate that you heard these

13 sounds, the moans?

14 A. Well, in terms of the time, I couldn't really tell you. I didn't

15 have my watch. But it could be around one hour or 45 minutes.

16 Q. You've testified that you spoke to other persons on forms of

17 questioning.

18 MS. SELLERS: I would like to now show another Prosecution

19 exhibit, but I will need to ask for a number for this exhibit.

20 Q. Ms. Radovic, I'd ask you to look at the document, please. When

21 you were taken to be asked questions during your stay at the Srebrenica

22 prison --

23 MR. JONES: Your Honour, I just don't recall the witness saying

24 she was taken for questioning when she was in Srebrenica prison. It's

25 being suggested to her. I can check the transcript, but I just don't

1 recall that.

2 JUDGE AGIUS: Yes, Ms. Sellers.

3 MS. SELLERS: Your Honour, I believe she did say that.

4 JUDGE AGIUS: I think she did say at one point in time she was

5 asked questions.

6 MR. JONES: From the prison, I'm not sure. I'll have a look. If

7 not, it's a suggestion on my learned friend's part.

8 MS. SELLERS: Well, let me ask.

9 Q. Were you ever taken, while you were staying at the Srebrenica

10 prison, for questioning?

11 A. Once, as I told you, on the second day after my arrival.

12 Q. And when you were taken for questioning, were you treated --

13 A. In the morning, at around 9.00.

14 Q. -- were you treated respectfully?

15 A. Yes.

16 Q. And the person who asked you questions, was that person wearing a

17 uniform other was that person dressed in civilian clothes?

18 A. Uniformed.

19 Q. And was that the same uniform or the similar uniform to that worn

20 by the guards or Zulfo Tursunovic or the men who escorted you to the

21 prison?

22 A. The person in civilian clothes --

23 THE INTERPRETER: The interpreters didn't understand what the

24 witness said. Could she please repeat.

25 JUDGE AGIUS: Madam Radovic, the interpreters could not hear what

1 you were saying. Could you please repeat your answer. They only heard

2 you say "The person in civilian clothes ..."

3 Let me repeat the question to you.

4 MS. SELLERS: Yes.

5 THE WITNESS: [Interpretation] I don't know Ivanka, and the rest of

6 it is correct. I don't know for the bottom part of it.

7 JUDGE AGIUS: You were asked the following question: "The person

8 who asked you questions, was that person wearing a uniform or was that

9 person dressed in civilian clothes?" And you answered "Uniformed." "And

10 was that the same uniform or the similar uniform to that worn by the

11 guards of Zulfo Tursunovic or the men who escorted you to the prison."

12 And you had started answering that question. I would like you to answer

13 that question. In other words, you are being asked whether that was the

14 same uniform or a similar uniform to that worn by the guards of Zulfo

15 Tursunovic or the men who escorted you to the prison?

16 THE WITNESS: [Interpretation] He was in a uniform. I think that

17 the uniform was blue, although my recollection is not the best.

18 JUDGE AGIUS: All right.

19 [Trial Chamber confers]

20 JUDGE AGIUS: Go ahead.

21 MS. SELLERS:

22 Q. Ms. Radovic, the person who asked you questions, did he ask you

23 questions where you were able to confirm information, such as, were you

24 arrested on a certain date?

25 A. Yes.

1 Q. Did it appear that he already knew something about the

2 circumstances of your arrest and prior detention?

3 A. He most likely had the papers. He received them when we arrived,

4 at night.

5 THE INTERPRETER: The interpreter didn't hear the rest of the

6 answer.

7 MS. SELLERS:

8 Q. Could you just speak up a bit. The interpreter wasn't able to

9 hear the last part of the answer. You said, "He received them when we

10 arrived, at night," and then you were continuing.

11 A. Well, when he took us from Cerska, he most likely took our papers

12 for Srebrenica, and most likely turned them over to that man either that

13 evening or the following day.

14 Q. Thank you. And you would just confirm that the paper that you had

15 in front of you --

16 MS. SELLERS: Could I ask the usher to please hand it back.

17 Q. -- that what is written under your name coincides with the

18 information that you gave him or that he had about you.

19 A. These -- I gave this information, and it's all correct. But I

20 don't know for the upper portion of what is written in this document. I

21 don't know Ivanka Mitrovic. I don't know this lady.

22 JUDGE AGIUS: I don't blame you for getting confused on that,

23 because it shouldn't have been given to us, it shouldn't have been

24 translated in the first place, or it at least shouldn't have appeared on

25 this document in any case.

1 Don't worry about it, Madam Radovic, that that happens to be

2 there, because in the original, the two persons were dealt with on the

3 same page and therefore the translators translated the entire page and did

4 not limit themselves to what was written about you. So don't worry about

5 it.

6 MS. SELLERS:

7 Q. Ms. Radovic, I just want to ask you one further question about

8 this document. In it, the document states that you were at your job, at

9 the Vezionica. Isn't it true that at the time that you were arrested,

10 that you had stopped working at your job due to the blockades that you

11 testified about earlier?

12 A. I said that I stopped going to work and then they called me to go

13 and work. And we went across the Drina to Mali Zvornik, to Karakaj. We

14 went in a boat. I mentioned that. And if you don't believe me, you can

15 ask Kadrija because everybody saw me that night when I came to fetch my

16 clothes. You can call everybody in the village and ask them. There's

17 nothing for me to be ashamed about, because I have spoken only the truth.

18 And I have said that I only want to say the truth.

19 Q. Thank you very much.

20 MS. SELLERS: Your Honours, I would ask that this document be

21 admitted into evidence and receive a number.

22 JUDGE AGIUS: Yes, registrar, this will be 4 ...?

23 THE REGISTRAR: 491.

24 JUDGE AGIUS: Prosecution Exhibit 491.

25 MR. JONES: For the record, we object to the authenticity of this

1 document.

2 JUDGE AGIUS: All right, thank you. Ms. Guibert, please make a

3 note of that so that when we come later to the question of objections, we

4 will have a complete record.

5 MS. SELLERS: Your Honour, I'd like the witness to be shown what

6 has been referred to as P19. I believe it's currently in Sanction.

7 Q. Ms. Radovic, you testified that there were male prisoners or men

8 in the prison, and you knew some of their names, and also you testified

9 about the names of some of the female prisoners. I would like you to look

10 at the document in front of you, and would you look at number 10 on the

11 document.

12 A. Yes.

13 Q. Would you agree that that refers to you and how you came to the

14 detention centre in Srebrenica?

15 A. Yes.

16 Q. Would you please look at number 17 on the list.

17 A. Yes.

18 Q. Would you also agree that that refers to the Rado Pejic that you

19 have referred to, and that that is how he came to the detention centre in

20 Srebrenica?

21 A. Yes.

22 Q. Would you please look at number 1 on the list.

23 A. Yes.

24 Q. Could you also confirm the typewritten information there?

25 A. Yes.

1 Q. And also, number 2 on the list that refers to Branko Sekulic,

2 could you confirm the typewritten information?

3 A. Yes.

4 Q. Now, do you see other people's names on the list who were with you

5 in the Srebrenica prison?

6 A. I can say that you didn't mention Dragan Ilic, number 3.

7 Q. Would you confirm that that information is correct concerning him?

8 A. Yes, Dragan Ilic, the information is correct.

9 Q. Do you recognise other names on that list?

10 A. Filipovic Dostana.

11 Q. And would you also confirm that the information concerning her is

12 correct?

13 A. Yes. Ilija was there. He used to bring in firewood for us. He

14 was disturbed. Milisava, but it says Milanovic, not Nikolic.

15 Q. You're now referring to number 8 on the list. And priorly, did

16 you refer to number 7 on the list, as Ilija?

17 A. Ivanovic, Ilija, son of Radenko, was exchanged together with me.

18 He used to bring in firewood for us, into the prison. I don't know where

19 he was from, but I know that he used to come into our women's room and

20 bring in firewood.

21 Q. So would you confirm, then, that information that's given under

22 number 7?

23 A. Yes. Yes.

24 MS. SELLERS: Your Honours, I will ask that the document be taken

25 from the witness at this point.

1 JUDGE AGIUS: Yes.

2 Judge Eser.

3 JUDGE ESER: Ms. Sellers, the document is dated the 3rd of

4 February, 1993. Now, if you go to number 17, it gives some information on

5 March 17.

6 MS. SELLERS: Yes, Your Honour --

7 JUDGE ESER: -- Three months later. How can it --

8 MS. SELLERS: We're in the situation where the document that we

9 have in translation in English is completely typewritten. The original

10 document that the witness is using, and it might be illustrative to show

11 that, the information that post-dates the 3rd of February is handwritten.

12 It is now on Sanction, Your Honour. You can see that.

13 JUDGE AGIUS: Yes.

14 [Trial Chamber confers]

15 JUDGE AGIUS: Yes. Do you need this document any further? I

16 heard you say you don't.

17 MS. SELLERS: We don't need the document any further. I'm going

18 to ask a couple of clarifying questions, but the document can be removed.

19 Q. Ms. Radovic, would you please tell the Trial Chamber the date you

20 arrived at the Srebrenica prison and the date that you left the Srebrenica

21 prison.

22 A. The 26th of January, 1993. The agreement was signed on the 5th of

23 February, 1993. We were exchanged on the 6th of February, 1993, in

24 Veznik, in Skelani.

25 Q. So the information that we saw on that document, that you

1 confirmed as being correct to the Trial Chamber, is that information that

2 you're knowledgable about between the 26th of January, 1993 and the 6th of

3 February, 1993?

4 A. Yes.

5 Q. Thank you. I would now like to turn your attention back to the

6 prison and ask you: Did you know who was in charge of the prison?

7 A. No.

8 Q. Had you ever heard anyone's name being given as being the

9 authority in the prison?

10 A. No.

11 Q. And did you ever see anyone come to the women's cell in the prison

12 and say that they were in a position of authority?

13 A. No.

14 Q. Did anyone ever tell you who might be in a position of authority?

15 A. No.

16 Q. Now I would like to ask you about the time period leading up to

17 your exchange, or to when you left the prison. You just testified that on

18 the 5th of February, an agreement was reached. Tell the Trial Chamber

19 what agreement you're referring to.

20 A. I think that the agreement on exchange was signed. Gedza informed

21 us about this. I think he was from Srebrenica. He came one evening and

22 said, Hey, are you celebrating, women? You are to be exchanged tomorrow.

23 Q. Now, this person you've mentioned as Gedza, could you tell the

24 Trial Chamber, did he say this personally to the women?

25 A. Yes, he came into our room and told us that.

1 Q. Could you tell the Trial Chamber how he was dressed?

2 A. He was in uniform, but he always treated us respectfully and

3 fairly.

4 Q. Was he one of the guards, or did he work in any other capacity in

5 the prison section?

6 A. No, I don't think so, I don't think he was a guard. I don't know,

7 though, whether he had some other role.

8 Q. Now, on the day that he announced that you would be exchanged,

9 were you able to visit any of the men in the prison?

10 A. No.

11 Q. That evening, prior to the exchange, were you able to visit any of

12 the men that had come with you from Cerska?

13 A. No.

14 Q. Did you ever see Branko Sekulic, Rado Pejic, Dragan Ilic, or Jakov

15 Dzokic prior to your leaving the prison in Srebrenica?

16 A. I asked Gedza, rather, I asked him whether I could go in and say

17 goodbye to them. I went into the room, and that was it. Later on, I saw

18 Rado when he was set free.

19 Q. Well, when you went into the room, would you tell the Trial

20 Chamber, how did those men look, physically, to you?

21 A. Terrible. They were black and blue, all swollen up. I got scared

22 when I saw them, because when we had arrived, they didn't look that way.

23 Therefore, I really got stared when I saw them.

24 Q. Did Rado Pejic look as if he had been black and bruisened?

25 A. Yes.

1 Q. And also, did Branko Sekulic look as if he had been black and

2 bruisened?

3 A. Yes.

4 Q. Could you also state the same for Mr. Dzokic?

5 A. Yes.

6 Q. And would that also be true for Dragan Ilic?

7 A. Yes.

8 Q. Now, that night you were able to say goodbye to them, how close

9 were you standing from those men?

10 A. That was in the morning, that wasn't at night. We stood perhaps a

11 metre from each other. We simply extended our hands for a handshake.

12 Q. So you were able to physically touch them; is that your testimony?

13 A. Yes, I mean we shook hands.

14 Q. And were you able to see them clearly, even though your eye had

15 been injured previously?

16 A. Yes, I was able to see them. I had spent a long time with them.

17 I was very scared because they were really in bad shape, badly beaten.

18 Q. And then were you taken back to the women's cell?

19 A. No.

20 Q. Where were you taken to next?

21 A. They took us outside the prison. There was some sort of a green

22 kiosk outside. We waited for a lorry, and then a van came. But the

23 ignition didn't work so a lorry came. There were people there, locals,

24 who were spitting at us; some were just silent. And then we were picked

25 up, loaded onto a lorry, and then we were off to Veznik, to wait for our

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1 exchange.

2 Q. When you say that there were locals who were spitting at you, are

3 you referring to people who were Bosnian Muslims or Bosnian Serbs or

4 another ethnic group?

5 A. Muslims.

6 Q. Were they saying anything to you when they were spitting at you?

7 A. Well, they were saying things but I forgot all about myself at

8 that time. I was not really fully aware of what was going on, because I

9 thought we weren't being taken to an exchange. My suspicion is that we

10 would soon meet our end, all of a sudden.

11 Q. By that, do you mean that you thought that it was possible that

12 you were being taken to be killed?

13 A. We were all convinced about it. We weren't thinking anything

14 else.

15 Q. Now, did any of the men in camouflage who were at the prison

16 accompany you to the exchange?

17 A. Three men came, Zulfo and two other men. I don't know their

18 names. They handed us over to our forces. They carried lists with the

19 names of people to be exchanged.

20 Q. And was it after that time period that you entered back into

21 Bosnian Serb territory and were no longer a prisoner?

22 A. When we came to Veznik, when we were being exchanged, I was no

23 longer a prisoner.

24 Q. Did you ever have the chance to see Rado Pejic after your

25 exchange?

1 A. I saw him when he arrived at the hospital. He called me and I

2 came over for a visit. It was in the Zvornik Hospital.

3 Q. When you saw Rado Pejic, could you tell the Trial Chamber what he

4 physically looked like at that time?

5 A. He was in a bad shape. He was unable to walk. He told me and the

6 police officers that SFOR had brought him there. He was in a very bad

7 shape. When I left detention, I weighed 37 kilos myself, and I simply

8 couldn't believe that I would survive.

9 Q. Do you remember what month and what year it was that you saw Rado

10 Pejic?

11 A. It was in 1993, but I can't give you the month.

12 Q. Did you ask him about the other men who had stayed in the stable

13 with you in Cerska? Branko Sekulic?

14 A. Yes, I asked him what had become of Branko, Dragan, and Jakov, and

15 he just told me, They all met a tragic end, they succumbed to the

16 beatings. That was all he said. We couldn't say anything more because we

17 felt so bad. We had been so close during our time in captivity.

18 Q. Do you know whether they succumbed to the beatings while at the

19 Srebrenica prison, or did this occur after an exchange?

20 A. In the Srebrenica prison. They never reached the hospital, or at

21 least that's what Rado told me.

22 Q. Ms. Radovic, I thank you for your testimony.

23 MS. SELLERS: Your Honours, I have no further questions.

24 JUDGE AGIUS: I thank you, Ms. Sellers.

25 Now, Madam Radovic, you're going to be cross-examined by Madam

1 Vidovic. You both speak the same language, and it's important that,

2 because of that, that in order not to make it difficult for the

3 interpreters to be able to give us a good interpretation, to allow an

4 interval, a short interval of time between question and answer.

5 Unfortunately, it happens when two of us are speaking the same language,

6 be it English or be it Serbo-Croat. So please do allow a short interval.

7 Madam Vidovic.

8 Cross-examined by Ms. Vidovic:

9 Q. [Interpretation] Good morning, Ms. Radovic.

10 A. Good morning.

11 Q. It is your testimony that you were a civilian and that you were

12 distributing food to the Serbs who remained in Novo Selo to defend the

13 Serb houses; is that correct?

14 A. I said I worked when I came. Over the weekend, I did distribute

15 food to civilians. That is true.

16 Q. In actual fact, those people were not civilians, were they?

17 A. What do you think they were? They were wearing civilian clothes.

18 What else do you think they could have been?

19 Q. Mrs. Radovic, can you please just simply answer my questions.

20 This is no place for us to argue. If you could just confine yourself to

21 answering my questions, please.

22 They were a well-organised Territorial Defence unit, they were

23 part of the Zvornik TO, weren't they?

24 A. How could they have been well organised? There weren't sufficient

25 men there to begin with. Wearing civilian clothes, how can anyone call

1 that an army? Please, just tell me one thing: This is a civilian court,

2 I have no reason to hold back. Have you ever seen a soldier wearing

3 civilian clothes?

4 JUDGE AGIUS: One moment, because I think -- I notice that the

5 atmosphere has suddenly changed in this courtroom.

6 Madam Radovic, please try to remember what I told you yesterday

7 when you were about to start giving your evidence: That once you have

8 taken your place there on that chair, right in front of us here, you are

9 no longer a witness of the Prosecution but you are a witness of this

10 Tribunal. And I told you also that it is important that, in the course of

11 your testimony, you treat the questions from the Prosecution and the

12 questions from the Defence the same. I encouraged you to do your best not

13 to discriminate between Prosecution and Defence. Madam Sellers is doing

14 her duty here, and Madam Vidovic is doing her duty too. She has a right

15 to ask you questions, and you have a duty to answer them.

16 Unfortunately, I see that you have already picked up on each

17 other, and that rather than answering the questions, that you are

18 contesting Madam Vidovic and the way she is asking you questions. She has

19 a right to put any question that she likes, and you have a duty to answer

20 that question and not to argue with the lawyer. If the question that is

21 put to you is not procedurally acceptable, the three of us will

22 immediately ask you not to answer that question. But if we do not

23 intervene, your duty is to answer that question. And please refrain from

24 arguing with the lawyers, who are here doing their duty.

25 Did I make myself clear?

1 THE WITNESS: [Interpretation] Yes.

2 JUDGE AGIUS: And I thank you for your cooperation.

3 Yes, Judge Eser.

4 JUDGE ESER: May I make an additional remark in order to soften

5 the situation? I don't know whether it's a question of translation, at

6 least in the English version, it appears that the Defence counsel is

7 contending that certain things had happened, for instance, whether the

8 actual fact was those people were not civilians, that's the contention,

9 and so far I think we do not have evidence for this, so I would suggest

10 that you put your questions as questions and not as contentions. That way

11 it will make it easier for the witness to answer.

12 JUDGE AGIUS: Yes, I agree with you, Judge Eser.

13 MS. VIDOVIC: [Interpretation]

14 Q. The Zvornik TO unit, from the very beginning of the war, was, in

15 fact, a well-equipped unit that had all sorts of equipment at their

16 disposal, including tanks; is that not correct?

17 A. I don't know.

18 Q. You weren't telling the truth, were you, when you said that the

19 soldiers at Novo Selo and Drinjaca had no weapons or uniforms?

20 A. Drinjaca is not close to where I live. I never spoke about

21 Drinjaca, I was just speaking about Novo Selo. And the answer to your

22 question is no.

23 Q. Therefore, your testimony would be that the soldiers at Novo Selo

24 had no weapons or uniforms.

25 A. They did have weapons but not uniforms.

1 Q. It's true, in fact, isn't it, Mrs. Radovic, that they were a

2 well-armed unit, with uniforms, weren't they?

3 A. They did not have uniforms.

4 MS. VIDOVIC: [Interpretation] Your Honours, can I have the usher's

5 assistance, please. Madam Usher, could you please place on the ELMO an

6 excerpt from a document. This is an excerpt from a Zvornik

7 Brigade document, "Salaries for June 1992, 2nd Battalion of the Zvornik

8 Brigade." The title page of the excerpt bears the following number

9 1776899. Can the witness please look at page 01776956. 01776956. The

10 heading is "List for the Drinjaca Lijesanj Mortar Platoon."

11 Q. Can you please look at the names of these 11 people. Do you know

12 any of these persons?

13 A. My dear, I don't.

14 Q. Can you turn the page now to 01776991, the 2nd Battalion armoured

15 units. If you can please look at the names of these persons here. Do you

16 know any of these?

17 A. No, sweetheart.

18 Q. Mrs. Radovic, you were captured in the Drinjaca area.

19 A. Novo Selo, Drinjaca, the distance is 6 kilometres.

20 Q. That's right. Do you not agree that if we look at this list, the

21 Drinjaca area had a whole mortar platoon, even an armoured unit?

22 A. Sweetheart, I can agree with the case you're putting to me, but I

23 don't know any of these people. Drinjaca is 6 kilometres from where I

24 live.

25 JUDGE AGIUS: One moment, one moment, one moment. I don't know

1 whether it's a question of interpretation or not, but in answering the

2 last three questions, in answering the last three questions, at least the

3 interpretation tells us that not only has the atmosphere cleared up but

4 that now the witness is referring or addressing Madam Vidovic

5 as "sweetheart." Is it acceptable in your own language, or is it

6 something that you object to? Because in my language, in these

7 circumstances, that means -- that has a very ironic and cynical

8 connotation. So I will stop it.

9 MS. VIDOVIC: [Interpretation] Your Honours, it definitely does

10 have ironic overtones, but what am I supposed to do about it? I can't say

11 I mind particularly.

12 JUDGE AGIUS: The first time, I thought maybe it's a problem of

13 interpretation, or that I was not really giving -- but then it was

14 repeated.

15 Madam Radovic, and this will be the last time I will say this --

16 MS. SELLERS: Excuse me, Your Honours, I'm sorry to intervene, and

17 I certainly don't think it's a precursor for Valentine's Day, but I would

18 suggest that we might want to take a break at this point and then resume

19 under calm conditions.

20 JUDGE AGIUS: All right. But before we take the break, I must

21 make it clear that Madam Radovic, when you answer the questions, you are

22 put a question -- you have a question forthcoming from Madam Vidovic, but

23 then you address us, not Madam Vidovic. When you answer the question,

24 you don't address the lawyer directly, you address us. And when you

25 address us, you don't need to address us at all by any adjective or by

1 any noun, just answer the question. If you choose at any moment to

2 address Madam Vidovic, please address her as counsel or Madam Vidovic,

3 but not as sweetheart.

4 We'll have a 25-minute break.

5 Just one moment. Madam Usher, could you escort the witness out,

6 please, first.

7 JUDGE AGIUS: All right.

8 --- Recess taken at 10.20 a.m.

9 --- On resuming at 10.52 a.m.

10 JUDGE AGIUS: Yes, could you bring the witness in, usher, please.

11 Madam Vidovic --

12 THE INTERPRETER: Microphone for the President, please.

13 JUDGE AGIUS: -- you made use, before the break, of this document,

14 the first page of which has ERN 01776899. Do you wish to tender that

15 document?

16 MS. VIDOVIC: [Interpretation] Yes, Your Honour, thank you.

17 JUDGE AGIUS: Yes. That will be Defence Exhibit D189. Thank you.

18 Now, let's proceed, and I hope that I had made myself clear enough

19 before the break, and that I will not have the need to intervene again as

20 we go along.

21 Yes, Madam Vidovic.

22 MS. VIDOVIC: [Interpretation]

23 Q. Mrs. Radovic, is it true that all of the logistics, including

24 weapons, equipment, and food, came to the units in Novo Selo and Drinjaca

25 from Serbia.

1 A. Drinjaca, yes, but I don't know about Serbia, because that was far

2 away.

3 Q. You remember you gave a statement to the OTP in 2000.

4 A. Yes.

5 Q. On page 3 of that statement, page 3, paragraph 3 in the English,

6 you said: "Food came from Serbia to Drinjaca on boats," and then from

7 Drinjaca food was transported by car to Novo Selo.

8 A. No.

9 Q. Do you remember saying that?

10 A. No.

11 Q. Thank you. Mrs. Radovic, you were a soldier too, weren't you?

12 A. No.

13 Q. You were the chief cook in your unit, weren't you?

14 A. No.

15 Q. Back in 2000, you told the OTP that you had given a statement to

16 the Skelani police on the 7th or 8th of February, 1993; is that correct?

17 A. When I was released from captivity, you mean?

18 Q. Yes.

19 A. Yes.

20 MS. VIDOVIC: [Interpretation] Can I have Madam Usher's assistance

21 now, please. I would like to show the witness the official note on the

22 statement. The date is the 7th of February, 1993.

23 Q. Mrs. Radovic, can you look at paragraph 2 of this note. I will

24 quote. You said:

25 "Muslims captured me on the 17th of September, 1992, in Novo Selo,

1 near Drinjaca. I worked as the chief cook for soldiers of the Zvornik

2 Territorial Defence."

3 Do you remember saying that?

4 A. No.

5 MS. VIDOVIC: [Interpretation] Can the usher now please again show

6 the witness the document that we looked at a while ago, salaries for June

7 1992, 2nd Battalion.

8 Prior to that, Your Honours -- actually, this document is D189,

9 Defence Exhibit D189.

10 JUDGE AGIUS: Yes. In the meantime, do you want to tender this

11 last document, Madam Vidovic?

12 MS. VIDOVIC: [Interpretation] Yes, Your Honour.

13 JUDGE AGIUS: Yes. May I suggest to you that, because of some

14 other information that it contains, that it be tendered and kept under

15 seal? Is there any objection on your part?

16 MS. SELLERS: Your Honour, there's no objection. Just a point of

17 clarification, are we referring to the Zvornik statement or --

18 JUDGE AGIUS: Yes, yes, yes, to the Zvornik statement. All right.

19 You have no objection to that?

20 MS. VIDOVIC: [Interpretation] No, no, Your Honour. I understand.

21 JUDGE AGIUS: So this document is being tendered and received as

22 Defence Exhibit D190, and will be kept under seal.

23 MS. VIDOVIC: [Interpretation]

24 Q. Mrs. Radovic, can you please look again at this document, payment

25 of salaries for June 1992, 2nd Battalion. Can you look at page 101776954,

1 2nd Battalion, Drinjaca Company, additional list. If you can look at the

2 name under number 7, "Andja Radovic, cook." Is that your name here?

3 A. Yes, that's what it says. But I explained I'd never been

4 mobilised. But if you want to have it that way, yes, it's my name.

5 Q. Mrs. Radovic, it is still your submission that you were a civilian

6 and that you were cooking for civilians in Novo Selo.

7 A. Yes.

8 Q. Mrs. Radovic, it is true, in fact, that not only were you not a

9 civilian, but you were even captured wearing a uniform with a camouflage

10 shirt. That is correct, isn't it?

11 A. No.

12 Q. You were aware of the situation of the Territorial Defence in the

13 area of Drinjaca and Novo Selo.

14 A. Not in relation to Drinjaca. That's 6 kilometres from where I

15 was, and Zvornik is 8 kilometres.

16 Q. You were familiar with the general situation of the Territorial

17 Defence in Novo Selo, were you not?

18 A. Yes.

19 Q. Mrs. Radovic, I will now show you a map.

20 MS. VIDOVIC: [Interpretation] Can we please have the map placed on

21 the ELMO. It's the Military Geography Institute. The map is for the

22 Zvornik area.

23 Q. As we will be mentioning the names of certain places, would you

24 please take a look at the map and tell the Trial Chamber, show them in

25 fact, certain places so that we can orient ourselves. In order to make

1 your task easier, I marked these places in yellow. There's a pointer in

2 front of you, so please point to Zvornik, Cerska. Can you see Zvornik,

3 Mrs. Radovic?

4 A. [Indicates].

5 Q. Now Cerska, please.

6 A. [Indicates].

7 Q. Very well, thank you. Now please show Novo Selo to the Trial

8 Chamber.

9 A. [Indicates].

10 Q. Drinjaca.

11 A. [Indicates].

12 Q. Drinjaca is below that, Mrs. Radovic. Further below.

13 A. [Indicates].

14 Q. There, thank you. Please show us Divic.

15 A. [Indicates].

16 Q. Thank you. Show us Sapotnik, please.

17 A. [Indicates].

18 Q. Further below, Mrs. Radovic.

19 A. [Indicates].

20 Q. Kostjerovo?

21 A. [Indicates].

22 Q. Dzevanje?

23 A. [Indicates].

24 Q. Gornje Snagovo.

25 A. [Indicates].

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1 Q. Liplje.

2 A. [Indicates].

3 Q. And please show us the village which Muslims call Pahljevici and

4 Serbs called Paljevici. That's where it is.

5 A. [Indicates].

6 Q. Thank you, Mrs. Radovic. Perhaps you could now put your initials

7 at the corner of the map, just as we did with the previous witness,

8 because we would like this map to be tendered into evidence.

9 A. [Marks].

10 MS. SELLERS: Excuse me, Your Honour, we have no objection, but of

11 course, just stating for the record, that the witness has merely

12 identified things that have been premarked by the Defence on the map.

13 JUDGE AGIUS: I think we went through this before, Ms. Sellers. I

14 don't know whether it was -- whether you were present or not at the time,

15 but I thought it best to let it go rather than waste or lose time.

16 Yes, this will be Defence Exhibit --

17 THE INTERPRETER: Microphone, please, Your Honour.

18 JUDGE AGIUS: -- yes. This will be Defence Exhibit D191.

19 MS. VIDOVIC: [Interpretation]

20 Q. Mrs. Radovic, I will put certain questions to you related to these

21 villages. You've lived for a long time in that area, haven't you?

22 A. In Novo Selo. However, before the war, I didn't live there

23 between January and September.

24 Q. You lived in the Zvornik area for quite a while, didn't you?

25 A. In Petkovci.

1 Q. Very well. Mrs. Radovic, it's true, isn't it, that before the

2 war, Drinjaca had an ethnically mixed composition. There were a lot of

3 Muslims living there.

4 A. I've already told you that I had nothing to do with Drinjaca,

5 which is 6 kilometres away from where I was.

6 Q. Yesterday, you told us yourself that 150 Muslims lived in Novo

7 Selo; is that right?

8 A. Yes.

9 Q. It's true, isn't it, that the local Muslim population of Drinjaca,

10 Novo Selo, and some other villages, in the course of May and April of 1992

11 -- in April, the Muslim residents of Novo Selo were expelled, their

12 property looted, and houses burned out; is that true?

13 A. No.

14 Q. Many of your neighbours, Muslims, were killed, imprisoned in

15 camps; is that right?

16 A. No.

17 Q. The same happened to the Muslim population of Sopotnik,

18 Kostjerovo, Liplje, Dzevanje, Gornje Snagovo, and other Muslim villages in

19 the vicinity.

20 A. I don't know about that. I only know about Novo Selo.

21 Q. Is it true that Liplje is quite close to the area where you lived?

22 A. I think that Liplje is close to Divic.

23 Q. Do you want to say, or would you please say how far is that from

24 the place where you lived?

25 A. Three kilometres.

1 Q. There, in April and May of 1992, was a camp in which there were

2 500 people imprisoned, many of whom were later killed. Have you ever

3 heard of that?

4 A. No, I don't know about that.

5 Q. Mrs. Radovic, you moved about in that area. All of these things

6 were happening to the Muslims, residents of Zvornik, and of the Zvornik

7 area. Are you claiming that you don't know that, you're not aware of

8 that?

9 A. Well, the roads were blocked, and there was no way for me to know

10 what was happening.

11 MS. VIDOVIC: [Interpretation] I apologise, I didn't realise that

12 you've already given a number to the exhibit.

13 Now, would the technical booth be so kind as to show us a video.

14 This is the video we showed during our opening statement. This is footage

15 recorded by Mr. Martin Bell, a BBC journalist, in April 1992.

16 Your Honours, we need just a few more minutes. It seems that we

17 are having problems with the audio side of this tape.

18 [Videotape played]

19 MS. VIDOVIC: [Interpretation] We can see the footage on our

20 monitor, but I don't think that the rest of you can see it.

21 JUDGE AGIUS: No, let's go through it again. We saw -- I saw

22 something, but it came and it went, so I don't know what the position is.

23 And I could hear, of course, the audio. Let's try it again. I am on

24 computer evidence, that's what I am using. No, at the moment, we

25 certainly don't have anything.

1 [Videotape played]

2 JUDGE AGIUS: Again, it's ...

3 MS. SELLERS: Your Honours, while we're waiting for the technical

4 problems to be solved, is this a video that's being tendered into

5 evidence. I know we've seen several clips during the opening statement,

6 and another clip that was shown with another witness. Is this one that's

7 proposed to be submitted into evidence?

8 MS. VIDOVIC: [Interpretation] Yes, it will be.

9 MS. SELLERS: Thank you.

10 JUDGE AGIUS: I think, Madam Vidovic, if it is at all possible for

11 you to proceed with some other question for the time being until a

12 technician comes over and solves this problem for us, I would appreciate

13 that. If you prefer to wait, not to disrupt the sequence of your

14 questioning, then obviously we will have a short break until this

15 technical problem is fixed. It's up to you. I mean, it doesn't create

16 any problems for us.

17 MS. VIDOVIC: [Interpretation] Your Honours, I have a number of

18 questions related to this video.

19 JUDGE AGIUS: Yes. So we will have a short break. Let's see

20 whether it is at all possible to redress -- to fix this problem now,

21 without the need for us to leave the courtroom. One moment. Let's give

22 it another try. It says "playing" now. I had the same problem at home

23 yesterday evening, and I couldn't fix it, so maybe I will learn something

24 now.

25 Yes, in the meantime, Judge Eser would like to put a question. To

1 who?

2 JUDGE ESER: To the Defence. Just to ask the -- on this map, do

3 we have the place of birth of the witness on this map? What is it called,

4 Petkovci?

5 MS. VIDOVIC: [Interpretation] Yes, Your Honours. That's to the

6 north -- no, no, no, no, Your Honours, it's outside of this map. It is

7 not shown on this map. It is to the north of Zvornik. I can see it on

8 another map but not on the one that was tendered.

9 JUDGE ESER: And how many kilometres distance from Zvornik?

10 Perhaps you could ask the witness.

11 MS. VIDOVIC: [Interpretation]

12 Q. Mrs. Radovic, your village, can you tell us, how far is it from

13 Zvornik?

14 A. Twelve kilometres.

15 MS. VIDOVIC: [Interpretation] Your Honours, perhaps I could turn

16 to the questions pertaining to the arrest, and then we will come back to

17 this issue, although it's not very logical. I think it's a better option

18 than wasting time.

19 JUDGE AGIUS: No, no, no, logic should not be sacrificed at all,

20 and I see that you have a preference that this be fixed first before you

21 proceed. So let's see if it can be fixed.

22 [Videotape played]

23 MS. SELLERS: Excuse me, the Prosecution has no picture. I don't

24 know if anyone else has --

25 JUDGE AGIUS: No, no, we just have a black screen, the window of

1 the software. And now we have moved to ...

2 [Technical difficulty]

3 [Trial Chamber confers]

4 JUDGE AGIUS: Madam Vidovic, I don't quite know whether, in the

5 course of the playing of this video, you will be relying on the visual as

6 well as on the commentary. If you are running on the commentary, do you

7 have a -- do you happen to have a transcript of it? I mean, I know that

8 it is in English, but is there a transcript?

9 MS. VIDOVIC: [Interpretation] Unfortunately, Your Honour, we don't

10 have the transcript, because this was a report by Martin Bell, in

11 English. The words spoken in Bosnian are translated in subtitles, and I

12 would like you to hear the words uttered by Mr. Bell.

13 JUDGE AGIUS: Okay, thank you.

14 Where do we stand? Perhaps the technician can give us an

15 indication whether we ought to remain here or whether we ought to leave

16 the courtroom, have a short break? It's up to you. Do you think you can

17 solve it within the next couple of minutes?

18 THE TECHNICIAN: No, Your Honours.

19 JUDGE AGIUS: You need more than 10 minutes. Let's have a break

20 of a few minutes. Let's do it this way: Registrar, please contact us in

21 our chambers as soon as it is time to come back, okay? Thank you.

22 Madam Radovic first. Yes, please. Sorry about this, Madam

23 Radovic, but we have a technical problem, and there's no use sitting here

24 looking at one another in this courtroom until it is solved, if it is

25 solved.

1 --- Break taken at 11.25 a.m.

2 --- On resuming at 11.45 a.m.

3 JUDGE AGIUS: Again, I'm sorry for all this. It was nobody's

4 fault. It was a technical problem that we had. It seems with the laptop

5 or notebook that you were using, Mr. Roberts, I understand that has been

6 fixed to your satisfaction, because it's important that you do have a

7 notebook that is in full functioning condition, all right?

8 If you have any problems, do let us know. In the meantime, I kept

9 the technician outside just in case we encounter further problems.

10 Yes, shall we start with the playing of this video-recording? I

11 want to know one thing: While the video is being played and it running

12 commentary in English, as I explained before, will the interpreters be

13 translating into B/C/S for the benefit of the witness, or is there a

14 transcript in B/C/S of this video-recording?

15 MS. VIDOVIC: [Interpretation] Your Honour, as Mr. Martin Bell and

16 other people are speaking in English, there will be a subtitle running in

17 the Bosnian language.

18 JUDGE AGIUS: Yes. But I have followed some of this subtitling in

19 the various videos we have seen, and most of the time, they are not a

20 complete subtitling of what is being said. I mean, it's -- a lot is

21 skipped. I can follow the language, although not completely, but I can

22 also see that most of what is being said is missing.

23 So what I suggest, if it does not create big problems to the B/C/S

24 -- to the translation -- interpretation booths, do you think you'll be in

25 a position to interpret the running commentary from English into

1 B/C/S? Because the witness is going to be asked questions.

2 I need a feedback from the B/C/S booth or the English booth.

3 THE INTERPRETER: Feedback is on its way, Your Honours. We're

4 just switching channels.

5 This is the B/C/S booth, Your Honour. The commentary in English

6 is quite fast. Without a transcript, we are afraid that the booth will

7 not be able to cover everything in any case.

8 JUDGE AGIUS: And you don't have a transcript into English -- in

9 English of this running commentary, do you?

10 MS. VIDOVIC: [Interpretation] No, Your Honours.

11 JUDGE AGIUS: All right.

12 MS. VIDOVIC: [Interpretation] What we can do is produce a

13 transcript at a later stage. As for my questions to the witness, they

14 will be of a general nature, so that I think she will be in a position to

15 answer all my questions. But we shall see.

16 JUDGE AGIUS: Let's do it in a somewhat personalised manner. If

17 there are any sectors of this video that you would like to base your

18 questions upon, and I mean mostly the running commentary and not the

19 visual, because the visual, you see it once, and you've seen it, but the

20 running commentary, if it is not completely translated at the time may

21 create problems. So in that case, could you please ask the technicians to

22 stop the playing of the video, to rewind and then play back the section

23 you want to concentrate your question or questions upon so that the

24 interpreters will have then sufficient time to catch up with what they

25 might have missed earlier on, all right.

1 MS. VIDOVIC: [Interpretation] Thank you, Your Honour. I will do

2 so.

3 JUDGE AGIUS: All right.

4 So, Madam Radovic, you are going to watch a video-recording which

5 goes back to April of 1992. This is a BBC video. And I would kindly ask

6 you to pay absolute attention to what you see and what you hear, because

7 then you are going to be asked questions by Madam Vidovic based on what

8 you see and what you hear. If you have any problems with following this

9 video, both the visual and the audio part, please draw our attention

10 straightaway and we'll try to rectify it, all right? Did you understand

11 me?

12 THE WITNESS: [Interpretation] Yes.

13 JUDGE AGIUS: So let's start with the video-recording. Thank you.

14 [Videotape played]

15 JUDGE AGIUS: Yes, Madam Vidovic.

16 MS. VIDOVIC: [Interpretation] Thank you.

17 Q. Mrs. Radovic, during your testimony yesterday, you mentioned that

18 at some point in April 1992, you were not able to go to work. You

19 mentioned a place called Karakaj. What you have now seen in this video,

20 was that the reason you were not free to move about?

21 A. This wasn't something that I could see. It was too far away. We

22 couldn't even go as far as the first tunnel, let alone any further.

23 Q. Mrs. Radovic, it's true, isn't it, that what you saw in this video

24 is something that happened precisely in the villages that you indicated on

25 the map. Some of those villages were only a kilometre from your own

1 village. Is it possible that you saw none of this?

2 A. Yes.

3 Q. Are you familiar with the fact that the entire Muslim population

4 of the area was expelled in April and May 1992?

5 A. Not Novo Selo. I don't know about the rest.

6 Q. It's true, in fact, isn't it, that 150 Muslims of Novo Selo were

7 driven out. Some managed to return to the area in early June. Isn't that

8 a fact?

9 A. I'm not sure if some escaped. I didn't know that many of them. I

10 know there were quite a number of them.

11 Q. The local Serb population of Drinjaca and Novo Selo, which is

12 where you lived, units from Dzevanje and Kamenica, that is the list, or

13 rather, that is the unit that we showed you a while ago. Your name is on

14 that list. They were involved in the ethnic cleansing of the Muslim

15 population, were they not?

16 A. I don't know.

17 Q. As early as June 1992, the local Serb population, including Serbs

18 from Novo Selo, was part of the 2nd Battalion of the Zvornik Brigade; is

19 that not correct?

20 A. Yes, the civilians. Yes.

21 MS. VIDOVIC: [Interpretation] Can I have the usher's assistance,

22 please. I would like to show the witness a document.

23 MS. SELLERS: Your Honour, it's unclear to me at this time. Are

24 we finished with the video questions, are we tendering that, or are we

25 moving on to a subsequent document.

1 JUDGE AGIUS: Madam Vidovic, you can answer that question.

2 MS. VIDOVIC: [Interpretation] Your Honour, the questions to follow

3 will be related to what was shown on the video, and I will certainly make

4 it clear that I wish to tender the video. My question was whether these

5 units were involved in ethnic cleansing. That was my question.

6 Q. Mrs. Radovic, please look at this document. It's a document by

7 the Zvornik garrison command. The date is 3rd of August, 1992. The

8 number is 017766815. Salaries -- recapitulation of paid salaries to

9 members of units of the Zvornik infantry brigade for June 1992.

10 Can you please look at this document. Look at the list under the

11 unit name, and you will see there brigade command, headquarters: 1st

12 Battalion, 2nd Battalion, 3rd Battalion, liaison platoon, military police,

13 engineers, tank detachment, Divic, and so on and so forth.

14 A. As I said, I know nothing of Divic and Drinjaca. As for the 2nd

15 Battalion, they used to come over to Drinjaca and probably to Novo Selo.

16 The 3rd Battalion, I know nothing about them.

17 Q. You do agree, don't you that it would have taken a great many

18 soldiers to expel the Muslim population of the entire area.

19 A. I agree, but we were the first to be expelled.

20 Q. Is it your testimony that the Serbs were the first to be expelled,

21 and only then the Muslims? Is that what you're trying to say?

22 A. Well, yes, of course. On the 17th, we all left and they stayed.

23 And I know nothing about what happened after the 17th of September.

24 Q. Mrs. Radovic --

25 MS. VIDOVIC: [Interpretation] I would like now, at this point in

1 time, to tender the video into evidence and be assigned an exhibit number,

2 please?

3 MS. SELLERS: Your Honour, the Prosecution would just like to

4 state that what was said in the video, be it in English or B/C/S, was only

5 for the purpose that it was said and not necessarily for the truth of it,

6 stated for --

7 JUDGE AGIUS: Obviously. I take it for granted that by now,

8 having started this trial in October, you're both familiar with the fact

9 that we are three professional Judges here, and by no means we are looking

10 at what Mr. Bell states or what is said in the commentary as evidence of

11 what was happening at the time.

12 MS. SELLERS: Thank you. I just make it for the record's sake.

13 JUDGE AGIUS: No, it's obvious. So you can put your mind at rest,

14 because most of you will be making use of this kind of evidence, all

15 right? So the position is made very clear. I think I made it clear from

16 the very outset that it's like that.

17 Yes, in the meantime, I think --

18 MS. VIDOVIC: [Interpretation] Your Honour --

19 JUDGE AGIUS: Yes, Ms. Vidovic.

20 MS. VIDOVIC: [Interpretation] Your Honour, if I may explain, in

21 order to avoid further confusion and objections of this kind, videos and

22 other types of evidence is something I show witnesses to comment on. As

23 for our Defence case, we're not going to be proving something we think

24 needs proving.

25 Your Honour, I'm not sure if we have been assigned a number or

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12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.

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1 not.

2 JUDGE AGIUS: No, not yet. This will be Defence Exhibit D192.

3 We're talking, just for the record, we're talking of the document which,

4 in the B/C/S version, has ERN 01776815 -- 6815, and consists of two pages,

5 the second of which is the English translation of the same.

6 The video, I think, has already been tendered. No?

7 MS. VIDOVIC: [Interpretation] No, no, Your Honour. That is

8 precisely why we have requested a number.

9 JUDGE AGIUS: So you are tendering this video. Can I have the

10 technical indications of it? It is Michael Bell?

11 MS. VIDOVIC: Martin Bell, BBC.

12 JUDGE AGIUS: Martin Bell, April 1992, in Zvornik. So the

13 video-recording which was played earlier, namely, the BBC -- having the

14 title "BBC, Martin Bell, April 1992 - Zvornik" is being tendered in

15 evidence by the Defence and is being admitted and marked as Defence

16 Exhibit D193. D193.

17 Do you have any objections?

18 MS. SELLERS: Your Honours, no, we don't have any objections. We

19 would just request a copy of the video from the Defence to make our files

20 complete.

21 JUDGE AGIUS: Yes, I'm sure that will be done, Madam Vidovic. I

22 thought this had been done because this was shown.

23 MS. VIDOVIC: [Interpretation] By all means, Your Honour. Thank

24 you.

25 Q. Mrs. Radovic, you and your husband were members of the 2nd

1 Battalion of the Zvornik Brigade from June 1992 onwards, were you not?

2 A. My husband was. As for myself, I'm not sure how many times I have

3 to repeat this: I was put on some sort of list, that's true, but I don't

4 know who did it on my behalf. My husband did have a rifle but not a

5 uniform.

6 Q. Thank you, Mrs. Radovic. The 2nd Battalion was a large unit, was

7 it not? It had about 1.200 soldiers.

8 A. Twenty-three in Novo Selo, 23 men and seven women, would you call

9 that a large unit? I don't think so.

10 Q. Your husband, Stanoje Obradovic, was, in actual fact, a member of

11 the Kamenica unit.

12 A. No, he was in Novo Selo. He never budged from me. Whenever I

13 came home, I would always find him there, our house or our

14 brother-in-law's house, which is 800 metres from our house.

15 MS. VIDOVIC: [Interpretation] Can I have the usher's assistance

16 now, please, to place on the ELMO an extract from the Zvornik Brigade

17 document, 01776899, which is salaries for June 1992, 2nd Battalion. If

18 the witness can please be shown the page 01776964. If you could look at

19 the section where the name of the unit of the 2nd Battalion is stated, the

20 Dzevanje Kamenica Company.

21 Q. And then if you could turn the page, please, 01776968, and look at

22 number 85.

23 A. Stanoje?

24 Q. Is that your husband's name?

25 A. Yes.

1 Q. Can you now please look at the last page of this document, and the

2 number is 01776970. If you could look at the figures in relation to

3 members of this unit, it's 126, isn't it, 126. This unit was a large unit

4 for a small village like that, was it not?

5 A. Excuse me, I have no idea who Sreten Micic is, for example, Milos

6 Dragutinovic, Dragan Micic, Milan Micic, Milenko Ristanovic, Ivan Lukic,

7 Milos Mirkovic, Ivan Mirkovic, Miso Mirkovic, Mitar Stojanovic, Zivoin

8 Ivanovic, Marjan Zecevic, I know this one. Dusan Milicevic, I don't know

9 these people. I can't say anything against them.

10 Q. Mrs. Radovic, I don't expect you to speak against these people.

11 My question is as follows: Please, it is true that the units of which

12 your husband was a member had a lot of people from outside, more people

13 from outside than locals; isn't that correct?

14 A. As I said, I wasn't there all the time. I only know the people

15 from my village, but I don't know any of the others. Probably, when the

16 attack took place, they came over. I can't say they didn't.

17 MS. VIDOVIC: [Interpretation] Can this exhibit now be assigned a

18 number.

19 JUDGE AGIUS: Of course, Madam Vidovic. This is being tendered

20 and admitted as --

21 [Trial Chamber and the registrar confer]

22 MS. VIDOVIC: [Interpretation] I don't think it's the same

23 document.

24 JUDGE AGIUS: Look at it, Madam Vidovic. The first page of D189

25 is, indeed, 01776899, like this one. The second page is 6954. What's

1 happening, registrar, is the first page is the same, because it shows the

2 title of the document itself, but the rest isn't, so it has to be given a

3 different number.

4 So this document is being tendered by the Defence. There is no

5 objection, I take it, Ms. Sellers?

6 MS. SELLERS: Your Honour, there's no objection to the document.

7 JUDGE AGIUS: Okay, there is no objection forthcoming from the

8 Prosecution, and it is being admitted and marked as Defence Exhibit D193

9 -- 4? 194, D194. Oh, yes, D193 was the video.

10 Let's proceed. We can finish this witness -- yes, Judge Eser

11 would like to put a question.

12 JUDGE ESER: Before we leave this exhibit, witness, would you draw

13 your attention to number, what was it, number 85 on the ELMO. Do we still

14 have it on the ELMO? The last exhibit.

15 THE WITNESS: [Interpretation] Yes.

16 JUDGE ESER: You told us that this is the name of your husband.

17 THE WITNESS: [Interpretation] Yes.

18 JUDGE ESER: On the same line, you'll see a signature. Can you

19 recognise this signature?

20 THE WITNESS: [Interpretation] I don't understand.

21 JUDGE ESER: Line 85, we have the name of your husband, and at the

22 end of this line there is a signature. Now, do you recognise this

23 signature? Do you know who may have signed this? Is it the signature of

24 your husband?

25 THE WITNESS: [Interpretation] I don't know.

1 JUDGE ESER: It's just interesting that there are signatures, the

2 same type, quite a few of them above them, and after -- starting with 88,

3 there have been signatures also by the same person. Thank you. So you

4 would not recognise this signature as that of your husband?

5 THE WITNESS: [Interpretation] No.

6 JUDGE ESER: Thank you.

7 MS. VIDOVIC: [Interpretation] Your Honour, if I may, since this is

8 a situation that is likely to happen again, I asked for information on

9 these documents. If a military unit was on the ground, then someone else

10 would have been entitled to receive their salaries and then forward them

11 to the persons that the salaries belonged to. That was the explanation we

12 got, but we shall be calling on witnesses in our case that will be in a

13 position to provide more accurate explanations on documents such as these.

14 JUDGE AGIUS: For the time being, I do agree with Madam Vidovic

15 that we have had one witness who gave an indication that there were

16 instances where there was someone with a power of attorney who was drawing

17 salaries on behalf of -- but as to the rest, we don't have evidence. So

18 what you have stated in regard to this submission cannot be taken, in any

19 way, as evidence, Madam Vidovic.

20 Yes, let's proceed.

21 MS. VIDOVIC: [Interpretation] Thank you, Your Honour.

22 Q. Mrs. Radovic, even before the war, and especially after the war

23 broke out, local Serb residents underwent intensive military training in

24 the centre in Divic, including your husband.

25 A. My husband, in Divic? No. The two of us went to work together,

1 and would come back before the roads became blocked.

2 Q. Are you claiming that the local Serb residents were not trained in

3 the training centre in Divic, which is located near your village?

4 A. I don't know. I don't think that was the case. How could they

5 have organised training in Divic? I don't know about that.

6 MS. VIDOVIC: [Interpretation] Could the usher please put an

7 excerpt from a document of the Zvornik Brigade on the ELMO. The ERN

8 number is 01776862, "Payment of Salaries for June 1992, Brigade Staff and

9 Divic Training Centre."

10 JUDGE AGIUS: We have an extra copy here, register.

11 MS. VIDOVIC: [Interpretation]

12 Q. Were you able to take a look, Mrs. Radovic? Please take a look at

13 the document. It says there that in June, there were 14 people at this

14 training centre. Have you ever heard of this fact?

15 A. I don't know any of the people on this list.

16 Q. Thank you.

17 JUDGE AGIUS: One moment, one moment. The question also included

18 whether you knew of the existence of this training centre in Divic. Did

19 you ever hear or come to know of a training centre in Divic? I take it

20 that Divic is a place, no, a place name.

21 MS. VIDOVIC: [Interpretation] Yes, yes, Your Honour.

22 THE WITNESS: [Interpretation] I did not understand the question.

23 JUDGE AGIUS: The question was twofold. Let me put the two

24 questions to you separately.

25 Madam Radovic, did you ever hear about a training centre in Divic?

1 THE WITNESS: [Interpretation] No.

2 JUDGE AGIUS: Okay. So the second question: Look at the list of

3 the persons that you find on the second page of the document that you have

4 been handed. Do you know any of those persons?

5 THE WITNESS: [Interpretation] I don't know any of them, Jokic

6 Dragan, or any others.

7 JUDGE AGIUS: Not even Miladin Obradovic.

8 THE WITNESS: [Interpretation] No.

9 JUDGE AGIUS: So I don't think it's the case of putting the third

10 question, because obviously she won't be in a position to answer it.

11 So do you want to tender this into evidence?

12 MS. VIDOVIC: [Interpretation] Yes, Your Honour.

13 JUDGE AGIUS: This will be D195; correct?

14 THE REGISTRAR: Yes.

15 JUDGE AGIUS: Thank you.

16 MS. VIDOVIC: [Interpretation]

17 Q. Mrs. Radovic, it is your testimony that soldiers of the 2nd

18 Battalion, for whom you cooked, or people from the 2nd Battalion, for whom

19 you cooked, sat peacefully in their homes in June of 1992 and onwards; is

20 that right?

21 A. They had to protect their homes, in civilian clothes. How shall I

22 put it to you? They did not have uniforms. They were there, protecting

23 their homes. I was away from my home, so what was there for me to

24 protect?

25 Q. The truth is, Mrs. Radovic, that, starting in June 1992 and

1 onwards, the people from Novo Selo terrorised the Muslim residents of the

2 village of Pahljevici who attempted to continue living in their homes, as

3 well as part of Novo Selo and the village of Bajrici to which the Muslims

4 returned in 1992. You lived there.

5 A. I don't know where Pahljevici is. I don't know whether that's in

6 the direction of Drinjaca or Zvornik. I really don't know that.

7 Q. Do you know that Serbs from Novo Selo and Drinjaca started

8 something called St. Vitus's offensive against the Muslims, and that this

9 offensive was started in June of 1992?

10 A. I just told you that I knew nothing about what was going on in

11 Drinjaca. That was 6 kilometres away.

12 Q. However, I asked you about Novo Selo as well. A large number of

13 Serb troops were stationed in Novo Selo, in June of 1992, and from there

14 they launched an offensive against Muslim villages; is that right?

15 A. We didn't leave in June. I don't know, I simply don't remember.

16 Q. Very well, Mrs. Radovic. Now I will turn to something else,

17 namely, your arrest.

18 The people who arrested you wore black uniforms; is that right?

19 A. Yes.

20 Q. In the statement you gave to the Prosecutor in 2000, you stated,

21 and you confirmed it yesterday, that the men in black uniforms were called

22 Zenges and belonged to special forces. That's what you said.

23 A. Yes, that's what I said, and that's what I heard when I got to

24 this place. Yes, that's right.

25 Q. ZNG, actually, are units of the Croatian army; is that right?

1 A. No, I never inquired about that. I was very fearful, so I never

2 asked anyone about that.

3 Q. However, it is a well-known fact in our region, isn't it, Mrs.

4 Radovic?

5 A. What do you mean, a well-known fact?

6 Q. That members of ZNG are actually members of the Croatian army.

7 A. To tell you the truth, I didn't ask anyone. It's just that when

8 my neighbour asked me, Do you know who had hit you, I said that I didn't

9 know, and then he explained to me that the man who hit me was Zenge or a

10 member of ZNG.

11 Q. When speaking of Muslims in the village, you said they wore

12 camouflage uniforms and that all their people were in civilian clothes.

13 A. Yes.

14 Q. Local Muslims never wore black uniforms; isn't that right?

15 A. Yes, that's right.

16 Q. When you were arrested, you were beaten by Zenges, members of the

17 ZNG; isn't that right?

18 A. Yes.

19 Q. Actually, local Muslims saved you and helped you in that

20 situation; is that right?

21 A. Yes, that's right. Kadrija helped me.

22 Q. In the Muslim hamlet, they treated your wounds.

23 A. Yes, that's right. Refik, who was the nurse.

24 Q. Moreover, the Muslim family Sahbaz and his wife gave you Muslim

25 clothes and tried to hide you in their home.

1 A. No, no, I apologise, I forgot to mention this: I was given

2 pantaloons when I was in the shelter. As for Sahbaz and his wife, they

3 helped me and they took me into their house on the 4th of October. That's

4 when they helped me.

5 Q. Is it your testimony that they wanted to humiliate you by giving

6 you Muslim clothes to wear and assigning a Muslim name to you, or do you

7 think it was done for some other reasons?

8 A. It was done to humiliate me.

9 JUDGE AGIUS: Madam Vidovic, I have been following and trying to

10 hope for an improvement, but you are not allowing for an interval between

11 question and answer, and I am actually really surprised that the

12 interpreters are succeeding in catching up with what is going -- with what

13 is being said. It's being made very difficult for them. So if you could

14 please slow down, both of you, and allow a short interval, I'm sure that

15 you will make everyone's life a little easier. Thank you.

16 MS. VIDOVIC: [Interpretation]

17 Q. Mrs. Radovic, they actually took off the uniform that you wore at

18 the time so that somebody didn't -- so that people wouldn't kill you

19 because of the uniform.

20 A. No, that's not right. Anybody can confirm that I wore a skirt and

21 a shirt, and also some shoes.

22 JUDGE AGIUS: One moment, because I need the cooperation of

23 everyone here. It just occurs to my mind, as we approach 12.30, which is

24 usually the time for the next break, that we have had stoppages during

25 this session, so I don't quite know whether it's the case of having the

1 break as scheduled at 12:30 and then we'll resume, of course, after 25

2 minutes, or whether it's the case of proceeding. I don't know, I mean

3 it's -- because it involves technicians, interpreters, and I see that the

4 sitting is proving to be a little bit heavy.

5 Okay. Madam Vidovic, just for your direction, for your

6 information, we will be stopping in about two, three minutes' time, so you

7 choose the time when -- or we will be stopping because we need to. Then

8 we will have a shorter break, we will have a 20-minute break rather than a

9 25-minute break, and try to catch up.

10 Do you think you will be able to finish with this witness today or

11 not?

12 MS. VIDOVIC: [Interpretation] I think so. I think I will be able

13 to.

14 JUDGE AGIUS: Okay. So shall we have the break now, or do you

15 want to go on -- proceed with a couple of other questions?

16 MS. VIDOVIC: [Interpretation] Perhaps a couple more questions,

17 very brief.

18 JUDGE AGIUS: All right.

19 MS. VIDOVIC: [Interpretation]

20 Q. Mrs. Radovic, we just mentioned the Muslim family, Sahbaz and his

21 wife. It is true, isn't it, that you spent at least seven days with them,

22 as long as it was safe for you to remain there; is that right?

23 A. Yes, that's right.

24 Q. Mr. Mehmed Juzunovic, a local Muslim resident, gave you his wife's

25 sweater, whereas his wife Ajka brought food to you in the shelter where

1 you were, milk and sugar; is that right?

2 A. Yes.

3 Q. While in shelter, there was an attempt to attack you which was

4 prevented by Mehmed, a local Muslim; is that right?

5 A. Yes.

6 Q. I mentioned Omer, local Muslim. That was his name; is that right?

7 A. Yes.

8 Q. At that time he said, If something happens to her, I will kill

9 five of your men; is that right, that those were the words he directed to

10 the members of the ZNG?

11 A. Yes.

12 Q. You also said that while you were in the shelter, that two people

13 tried to attack you. One of them was a woman with a foreign accent, known

14 as Hosovka.

15 A. Yes.

16 Q. Those were also the people who were not local Muslims.

17 A. That's right. I believe that they were not.

18 Q. It is true, isn't it, that the local Muslims saved you on that

19 occasion as well?

20 A. Yes.

21 MS. VIDOVIC: [Interpretation] Your Honours, we can have our break

22 now.

23 JUDGE AGIUS: All right. We will have a 20-minute break, starting

24 from now. Thank you.

25 --- Recess taken at 12.30 p.m.

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1 --- On resuming at 12.56 p.m.

2 JUDGE AGIUS: Let's proceed. Yes, Madam Vidovic.

3 MS. VIDOVIC: [Interpretation]

4 Q. Mrs. Radovic, when you came to the prison in Cerska, which is what

5 you called the stable, you found Branko Sekulic there, as well as Jakov

6 Dzokic, Dragan Ilic, and Rado Pejic, called Miso; isn't that right?

7 A. Yes.

8 Q. When you saw them around the 5th of October, they were already in

9 fairly bad shape; isn't that right?

10 A. Yes.

11 Q. On page 8 of your statement given to the investigators of this

12 Tribunal, on the last page of the Bosnian version, which is page 9, you

13 described them in the following way: "They were all pale, covered in

14 bruises. They had been beaten severely. All of them said that, prior to

15 my arrival, a lot of soldiers beat them every day."

16 A. No. They were pale, but they did not have bruises at that time.

17 Q. Mrs. Radovic, did you state something like this to the

18 investigators?

19 THE INTERPRETER: The interpreters didn't hear what the witness

20 answered.

21 JUDGE AGIUS: One moment, Madam Radovic, the interpreters couldn't

22 hear your answer. What was the answer? The question was: "Mrs. Radovic,

23 did you state something like this to the investigators?" And you said --

24 I heard you say -- I heard you say something, but it's the interpreters

25 who need to translate it to us.

1 THE WITNESS: [Interpretation] They were pale. They were not

2 bruised. They were pale and exhausted when I arrived at the stable.

3 JUDGE AGIUS: So the question remains: Did you, at any time, tell

4 the investigators that, prior to your arrival, a lot of soldiers had

5 beaten them every day? Did you ever say these words to the investigator

6 of the Office of the Prosecutor?

7 THE WITNESS: [Interpretation] They told me that that was so, most

8 likely, but I don't remember that.

9 JUDGE AGIUS: All right. Yes, okay, thank you.

10 Madam Vidovic, let's move.

11 MS. VIDOVIC: [Interpretation]

12 Q. In your 2000 statement, you also said that Branko Sekulic had been

13 wounded and that his wound was infected, that there were maggots, and that

14 that was the situation as you found it when you arrived.

15 A. Yes.

16 Q. You also said that a certain Alaga, in your presence, beat Branko

17 with fists, kicked him, and beat him with a wooden bat, so that his blood

18 sprayed throughout the whole stable, that blood leaked from his mouth and

19 nose.

20 A. And ears too.

21 Q. Alaga beat even you.

22 A. Yes.

23 Q. You described in detail daily beatings of these four men in the

24 stable. You even said that, due to these blows, Sekulic became deaf and

25 was barely able to walk.

1 A. Yes.

2 Q. In that stable, it was generally very cold.

3 A. Yes.

4 Q. There was no heating.

5 A. No.

6 Q. It was dirty.

7 A. Yes.

8 Q. The men had old coats on them, shoes with holes. They didn't have

9 any socks on.

10 A. Savko Huric occasionally brought some socks to us. Otherwise, we

11 didn't have any socks.

12 Q. The men were in such bad shape that they couldn't even shave when

13 the local Muslims brought them in soap and razors.

14 A. We never received soap or razors.

15 Q. Mrs. Radovic, is it your testimony that you never mentioned

16 anything of this nature to the investigators?

17 A. Nobody ever asked me whether the men shaved. I didn't see them

18 shaving while I was there. They didn't have any shavers.

19 Q. Very well. Mr. Sekulic was in such a poor shape that, on the way

20 between Cerska and Srebrenica, he and some soldiers had to stay behind and

21 spend the night in a stable.

22 A. Yes, he stayed behind with one soldier.

23 Q. Mrs. Radovic, it is true, isn't it, that these men actually

24 arrived in Srebrenica half dead from the beatings which frequently

25 resulted in them fainting.

1 A. Yes.

2 Q. Bearing in mind what you told us about the conditions at the

3 stable in Cerska, would you be surprised -- would you have been surprised

4 if some of these men died shortly thereafter as a result of the conditions

5 and injuries they had received while staying at the stable?

6 A. Nobody died at the stable. All of us went to Srebrenica, Dragan,

7 Jakov, Rado, and I. Branko stayed behind. After I was released, Jakov,

8 Dragan, and Branko died.

9 Q. I will repeat my question. Mrs. Radovic, please listen carefully

10 to my question. I asked you something else entirely. In view of what you

11 have told us about the conditions prevailing in that stable, I asked you

12 whether you would have been surprised had one of these men died shortly

13 thereafter as a result of the conditions at the stable. I'm not claiming

14 that they, in fact, died, I'm just saying whether you would have been

15 surprised whether, due to injuries and difficult conditions there, they

16 died.

17 A. Had we stayed longer there, perhaps, yes.

18 Q. Yesterday, you told us that you were slapped and beaten as well at

19 the stable.

20 A. You mean Alaga?

21 Q. Yes.

22 A. Yes.

23 Q. Rado Pejic was also in the stable when you were slapped and

24 beaten, wasn't he?

25 A. Yes.

1 Q. You said that other prisoners told you that you lost consciousness

2 as a result of a blow that Alaga dealt you.

3 A. Yes.

4 Q. Rado Pejic was there.

5 A. Yes.

6 Q. What's more, you say that he was the one who told you that Alaga

7 had hit you so hard that you, in fact, lost consciousness.

8 A. The other three men told me. Branko was the only one who was

9 unable to even speak.

10 Q. The essence of my question was: You said that Rado Pejic told you

11 that you had received such a hard blow; is that correct?

12 A. Yes.

13 Q. You also said in your testimony yesterday that you were moved from

14 the stable on the 26th of January, 1993. You were very specific about the

15 date.

16 A. Yes.

17 Q. How do you know what the date was of your transfer to Srebrenica?

18 A. Of course I know about the 26th of January, 1993.

19 Q. What happened, in fact, is that you were shown documents to jog

20 your memory, were you not?

21 A. No.

22 Q. Based on what is it, then, that you are sure about the date, that

23 it was the 26th of January?

24 A. I was that conscious. I still remember the date I was captured,

25 the date I was exchanged.

1 THE INTERPRETER: Microphone, Your Honour.

2 JUDGE AGIUS: That's okay. For a moment, I needed to check the

3 transcript, to check whether I had heard well or not. But I did hear

4 well. Okay, thank you.

5 MS. VIDOVIC: [Interpretation]

6 Q. Mrs. Radovic, did you keep track of the dates during your time in

7 --

8 A. You mean in captivity?

9 Q. Yes.

10 A. No, we didn't keep track on a daily basis. But we were aware of

11 some of the dates, and we specifically remembered the 26th of January as

12 the date we left the stable.

13 Q. Very well. The person who introduced himself as Zulfo Tursunovic

14 and said that he would take you to the prison in Srebrenica in order to be

15 exchanged, this person saw you in Cerska, didn't he?

16 A. Yes.

17 Q. Therefore, this person did not come to the stable itself; isn't

18 that correct?

19 A. No. He took us outside of the stable.

20 Q. In your statement from the year 2000, page 13, paragraph 2 of the

21 Bosnian version, in the English it's page 13, paragraph 5, you said, I

22 quote:

23 "Two soldiers wearing camouflage uniforms escorted us to the

24 centre of Cerska. The men had been badly beaten, and we were all in a

25 very poor condition. In the centre, we were met by three Muslim soldiers

1 with camouflage uniforms, carrying three automatic rifles. One of these

2 men said, 'I am Zulfo Tursunovic and I will take you to the prison in

3 Srebrenica for exchange.' Zulfo had grey hair, and was about 190

4 centimetres tall."

5 So what you told the investigators on that occasion is essentially

6 that Zulfo took you over in Cerska. What is correct, then?

7 A. Maybe Zulfo took us away and walked with us all the way to

8 Srebrenica. I can't remember specifically.

9 Q. You said in relation to that person, Zulfo Tursunovic, that he had

10 grey hair, or greying hair, rather. That's what you told the

11 investigators, didn't you?

12 A. Yes.

13 Q. When you described him yesterday, you provided a very different

14 description. You said that he had black hair, which is quite different.

15 A. I said he was tall, I said he was burly. He carried an automatic

16 rifle, a pistol, and a Motorola. And he was very fair to us. And I abide

17 by what I said.

18 Q. I'm not trying to challenge that, but you described the same

19 person to the investigators as someone with greying hair, and yesterday

20 you said black hair. Do you agree with me that these are two different

21 things?

22 A. Well, my dear lawyer, do you think that 12 years later, you

23 yourself would be able to focus on all the details?

24 Q. Is it possible, Mrs. Radovic, precisely for that reason, that you

25 saw Zulfo for the first time in Cerska?

1 A. Yes.

2 Q. You said that you had walked from Cerska to Srebrenica in one day;

3 is that correct?

4 A. Yes.

5 Q. Do you know - I assume you must know - that the distance is about

6 40 kilometres, across hillside, during war?

7 A. We walked through hills, but we didn't keep track of the exact

8 distance. We spent the whole day travelling, and we came there late in

9 the evening. It was nighttime; we couldn't see anything.

10 Q. Is it your testimony that you walked all the way?

11 A. Yes.

12 Q. You were all in a poor condition. It is your submission that you

13 were able to actually walk the distance in a single day?

14 A. We had no choice.

15 Q. Rado Pejic, too, walked along with you, didn't he? The whole day.

16 A. Yes.

17 Q. And you say that Branko Sekulic stayed behind and did not reach

18 Srebrenica with you.

19 A. Yes.

20 Q. You arrived at the prison in Srebrenica on the 26th of January,

21 1993, you claim, and you stayed there for 12 days.

22 A. Yes.

23 Q. You watched what was going on around you, didn't you?

24 A. All I could see was what was in my room, but nothing else.

25 Q. You were in that room together with other women.

1 A. Yes.

2 Q. Including Milena Mitrovic.

3 A. No, I don't remember Milena Mitrovic, I remember the ones I've

4 mentioned. She may have been there, but I just don't remember now.

5 Q. You said yesterday that there were two women called Milena in the

6 room with you.

7 A. Yes, there were two, but I don't know their last names. One was

8 captured together with her daughter, and her daughter was injured.

9 Q. Very well. During your stay in Srebrenica, you were only

10 interrogated once, were you not?

11 A. Yes.

12 Q. You were interrogated by a rather young man. This was, in fact,

13 the only person who ever interrogated you at the prison in Srebrenica.

14 A. No, not inside the prison, it was behind the prison.

15 Q. Mrs. Radovic, my reference is to the period of time that you spent

16 in prison, and my question is: Did I understand you correctly when you

17 said that this man was wearing a blue uniform?

18 A. He had a uniform. I can't remember the colour. He was fair and

19 he was respectful, and he asked me a number of questions.

20 Q. You said he wore a blue uniform. Could this have been a police

21 uniform from the former Yugoslavia?

22 A. I really can't say.

23 Q. You said today that you, too, were slapped by someone in the

24 prison, in Srebrenica.

25 A. Yes. A young man came in and slapped me twice, but I don't know

1 who he was.

2 Q. But, Mrs. Radovic, in your earlier statements, and again I'm

3 referring to a statement you made to OTP investigators, you failed to

4 mention, in fact, that anyone had hit you at all. What's more, you stated

5 that you had not been beaten in the prison in Srebrenica.

6 A. I did say yesterday clearly that I was slapped twice, didn't I?

7 No one can take this away from me, the beating that I suffered. I know

8 all of the beating; I remember every single time I was slapped. Please

9 forgive me if you found this insulting.

10 Q. Essentially, my question is this: This is very difficult to bear,

11 slaps and blows. I wonder why it was that you failed to mention anything

12 about it to the investigators of this Tribunal when you were questioned by

13 them?

14 JUDGE AGIUS: Madam Vidovic, if you look at the witness statement

15 of the 24th, 25th, 27th of March, I'm referring to the English version,

16 page 13, last paragraph, third, fourth, and fifth line: "One of the

17 soldiers was wearing sunglasses, although it was dark in that room. He

18 had a very short haircut. He slapped me and he beat the other three men."

19 So she has made the distinction, and she has -- between slapping

20 and beating, and she has also stated that she was slapped. So I don't

21 think it's the case of you suggesting to her that she never mentioned to

22 the investigator that she was slapped.

23 Then, if you look at the second page -- the next page, page 14,

24 you see the third paragraph before the end: "I was not beaten or sexual

25 assaulted at the Srebrenica prison. I was slapped the first day, but not

1 after that."

2 So if anything, there is an affirmation that she was slapped once

3 and not more than once, and that's the only thing that you can suggest to

4 the witness.

5 MS. VIDOVIC: [Interpretation] Your Honours, if I may be allowed to

6 clarify. The witness' statement in relation to the slapping was about the

7 SUP building. When she spoke about what happened in the prison itself,

8 where there were men too, she said as follows: "I was not beaten in the

9 prison in Srebrenica or sexual assaulted." She was quite specific about

10 that. As for what happened first, she spoke about this as about something

11 that happened in the MUP building, so maybe that's what has caused this

12 misunderstanding.

13 MS. SELLERS: Excuse me, Your Honour, I don't believe the witness

14 has ever mentioned the word "MUP" or "SUP", and I think she might be

15 referring generically as her imprisonment as a prison. But we can clarify

16 that.

17 JUDGE AGIUS: I quite agree with you, Ms. Sellers, and at the end

18 of the day, what difference is it going to make? Anyway, let's proceed.

19 MS. VIDOVIC: [Interpretation] Thank you, Your Honour.

20 Q. Mrs. Radovic, you did not see the male prisoners after you were

21 separated from them; is that a fact?

22 A. Yes.

23 Q. In your statement to the OTP, you never mentioned that you

24 exchanged greetings with them, did you?

25 A. Yes, I did say that we exchanged greetings on the 6th, when we

1 left. I did say that, I'm positive.

2 Q. I mean the statement you made to the investigators, Mrs. Radovic.

3 A. I clearly said that I'd asked Gedza, in the evening, he allowed me

4 to shake hands and to exchange greetings.

5 Q. Very well, thank you. Mrs. Radovic, it's true, isn't it, that

6 there was a woman who was wounded in the room with you.

7 A. It was a girl.

8 Q. A girl, fair enough. She was given medical assistance, wasn't

9 she?

10 A. Not in the room. I'm not sure if they ever took her anywhere

11 else, but no medical assistance came to our room. I don't want to speak

12 about anything else. I only spent a very short time with them, and that's

13 all I feel I can talk about.

14 Q. Is it your testimony, then, that no doctors ever came to the

15 prison at the time?

16 A. Not to our room, for as long as I was there.

17 Q. In your testimony, you mentioned Ilija Ivanovic. You do remember

18 that, don't you?

19 A. Yes.

20 Q. You said that he had been exchanged with you on the 6th of

21 February, 1993; is that correct?

22 A. Yes.

23 Q. You're absolutely positive that Ilija Ivanovic was exchanged with

24 you on that day.

25 A. I am absolutely positive. He had been captured near Ovaci. He

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1 couldn't speak properly; he had epilepsy or something like that.

2 Q. Okay, I'll ask you something else now. I'll just ask you another

3 question about the conditions in the prison. You said that there was a

4 stove there, but you didn't have any firewood, so there was no heating in

5 the room; is that correct?

6 A. Yes.

7 Q. There was no heating at all, you mean?

8 A. In the evening we heard we were going to be exchanged, Gedza came

9 and ordered some firewood to be used and make a fire. But that was very

10 rare.

11 Q. But you did say that one of the prisoners --

12 A. I said Ilija. I know what I said, I'm very clear about that.

13 Q. You said that firewood had been brought to you, but you also say

14 that there was no heating except once or twice. Now, which is true?

15 A. It was very seldom that there was any heating. Ilija would be

16 allowed to go outside and fetch firewood.

17 Q. I'll ask you a different thing now.

18 MS. VIDOVIC: [Interpretation] Can the witness please be shown a

19 document shown by the Prosecutor, P491. The number is 02075668. This

20 document should be a document of the Srebrenica armed forces staff, 19/23,

21 dated the 6th of February, 1993. If the witness could please have a look.

22 Q. Mrs. Radovic, I have several questions about this. After you left

23 the prison, you spoke to many people from Republika Srpska about what had

24 happened to you in captivity; is that correct?

25 A. No, I talked to no one. The international court came to my

1 mother-in-law's place, and they took me to the Drina Hotel.

2 Q. Is it true that you gave a statement to the Ministry of the

3 Interior, to the security service, at Skelani?

4 A. I think I did when I was first captured. I think I did, but I

5 can't remember.

6 JUDGE AGIUS: When you were first captured or when you were first

7 released? I don't know, it may be a question of translation.

8 THE WITNESS: [Interpretation] When I was released.

9 JUDGE AGIUS: Okay.

10 MS. VIDOVIC: [Interpretation]

11 Q. It's true, isn't it, that you then gave them your personal

12 information: Date of birth, place of birth, husband's name?

13 A. Yes.

14 Q. You described in detail how you were captured and who the persons

15 were who came with you from Cerska to Srebrenica.

16 A. Yes.

17 Q. You mentioned your husband too. This is something you've said

18 before. Your husband had no official military assignment in Karakaj, did

19 he?

20 A. I don't know. We had no access to Karakaj.

21 Q. You didn't say this to any of the people who interviewed you at

22 any time, the Muslims who asked you questions or interrogated you in the

23 prison.

24 A. I don't know.

25 Q. You said, and when asked you confirmed, that the young man who

1 interrogated you was fair and respectful, and that the interrogation took

2 a brief while only.

3 A. Yes, that's correct.

4 Q. It's true, isn't it --

5 A. Yes.

6 Q. It's true, isn't it, that you were not interrogated about the Serb

7 military units or their commanders?

8 A. Well, they had my documents right there to see.

9 Q. Mrs. Radovic, my question is: Did the Muslims ask you questions

10 about Serb units and their respective commanders?

11 A. I don't remember. It was 12 years ago.

12 Q. At any rate, can you now please focus on this: In your 2000

13 statement, you said that you had been interrogated a day after you had

14 been brought to Srebrenica, which you confirmed today; is that correct?

15 A. No, it's not correct. No one questioned me a day after I got to

16 Srebrenica.

17 Q. Is it true, Mrs. Radovic, that you were questioned or interrogated

18 one day after you arrived in Srebrenica?

19 A. No, no one interrogated us. They only told us that we would be

20 exchanged.

21 Q. At any rate, Mrs. Radovic, can you please look at this document in

22 front of you. The heading is: "Republic of Bosnia-Herzegovina Armed

23 Forces, Staff Security Organ 19/23." The date is 6th of February, 1993.

24 It's true, isn't it, that you did not give any statements on or about that

25 date in Srebrenica?

1 A. On the 19th, I gave no statements whatsoever to anyone. 19/23,

2 6th of February, I gave no statement at all. The 6th of February is when

3 we left.

4 Q. But something else is also true, isn't it?

5 MS. VIDOVIC: [Interpretation] If the witness can please now be

6 shown the statement -- actually, this is P190 -- or D190. D190. You can

7 use my copy, if that's convenient.

8 Q. Please take a look at this, Mrs. Radovic. Please take a look at

9 the first sentence. It's true, isn't it, that on that day, the 6th of

10 February, 1993, you gave a statement to the Ministry of the Interior of

11 Republika Srpska, Public Security Station in Skelani. Please take a look

12 at this. The first sentence says:

13 "On the 6th of February, 1993, an interview was conducted with

14 Andja Radovic."

15 My question is as follows: Do you agree that, immediately upon

16 your exchange, you talked to the Serbian police in Skelani?

17 A. Most likely I did, although I don't remember that, because we went

18 to a hotel there.

19 Q. Thank you.

20 JUDGE AGIUS: One moment. Usher, I just want to make sure,

21 because I was following the transcript and not the video, I want to make

22 sure that you do not put that document on the ELMO. All right, okay.

23 Thank you.

24 Yes, my apologies to you, Madam Vidovic. Could you proceed,

25 please.

1 MS. VIDOVIC: [Interpretation] Could the witness now please be

2 shown document P19.

3 Q. Mrs. Radovic, would you please briefly take a look at this

4 document. So it's document P19, first page. The title is "Persons Kept

5 in Detention Locally and Measures Undertaken with Respect to Them."

6 Mrs. Radovic, we have heard here that you knew Rado Pejic as well,

7 and that you saw him alive upon leaving the prison; is that right?

8 A. Yes.

9 Q. Please take a look at number 17. The name there, it says "Rado

10 Pejic, son of Mihajlo." To the right is a notation, "died." The first

11 date is not clear, but the second date says "03/92."

12 A. Rado is alive, Rado didn't die.

13 Q. Thank you. When answering the questions put by the Prosecutor

14 today, you said that it was nighttime when you arrived. But prior to

15 that, would you please take a look at another document, P15. P15,

16 please.

17 You told us that what you arrived in Srebrenica, it was nighttime;

18 is that right?

19 A. Yes.

20 Q. Would you agree with me, then, that it could not have been 1700

21 hours, or 5.45 p.m.?

22 A. I did not have my watch, so I didn't know what time it was. I

23 just knew that it was dark.

24 MS. SELLERS: Excuse me.

25 JUDGE AGIUS: Yes, Ms. Sellers.

1 MS. SELLERS: Your Honour, I just want to bring the Trial

2 Chamber's attention, she said she remembered the lights were on, that it

3 was getting dark. And in her mind, it might have been approaching

4 nighttime. I don't think it had any relationship to the exact time of

5 day.

6 JUDGE AGIUS: Yes, thank you, Ms. Sellers.

7 MS. VIDOVIC: [Interpretation] Your Honours, I was about to put

8 that question, and I ask that I be allowed to complete my questions. I

9 don't see the point of an objection of this nature, because I wasn't

10 finished with my question.

11 JUDGE AGIUS: Go ahead, Madam Vidovic.

12 MS. VIDOVIC: [Interpretation]

13 Q. Mrs. Radovic, at 1745 hours, it is usually not dark in our region,

14 is it?

15 A. What do you mean it's not? It is.

16 Q. So you are telling us that in February, in our region, it is

17 usually dark at that hour; is that what you're claiming?

18 A. Yes.

19 Q. Very well. You also told us that the lights were on.

20 A. Yes.

21 Q. Do you wish to say that, in Srebrenica, at that time when you

22 arrived, there was electrical power?

23 A. There was no electricity, but the candles were lighted.

24 MS. SELLERS: I do have to interrupt again, and I give my

25 apologies to Defence counsel. I believe that we're talking about January,

1 when she arrived, and not February.

2 JUDGE AGIUS: I think you are right. Knowing something about the

3 subject, I think I have a very clear idea what time it gets dark in that

4 region, also because I don't live far away from there, and I have sailed

5 to the region so I know exactly what time difference there is and how it

6 affects daytime and nighttime.

7 You do have also -- that is something that I don't know, but do

8 you apply summer time -- or in 1992 and 1993, did you apply summer time in

9 your country, like the rest of Europe, or not?

10 MS. VIDOVIC: [Interpretation] Your Honours, I'm not sure about

11 that. However, it is the same season as it is now, and in Sarajevo, it is

12 not dark at that hour. It is possible that the situation is somewhat

13 different in that region, but it wasn't my intention to mislead the

14 witness. If I said February, it is possible that I simply --

15 JUDGE AGIUS: Forget that and let's proceed. Let's move, because

16 we've got five minutes left for this session.

17 MS. VIDOVIC: [Interpretation] All right. I will put just one more

18 question to the witness.

19 Q. Mrs. Radovic, today, or perhaps yesterday, you mentioned the fact

20 that you talked to Rado Pejic at the hospital.

21 A. Yes.

22 Q. And you're sure that he told you that Jakov Dzokic had died.

23 A. Jakov, Dragan, and Branko, yes.

24 Q. So you're sure that he told you that Jakov Dzokic had died.

25 A. Yes.

1 MS. VIDOVIC: [Interpretation] Your Honours, I've concluded my

2 cross-examination.

3 THE WITNESS: [Interpretation] I don't know these people here.

4 JUDGE AGIUS: I thank you, Madam Vidovic, particularly for your

5 cooperation in finishing well within the time limit we had.

6 Is there a re-examination, Ms. Sellers?

7 MS. SELLERS: Yes, Your Honour, I'll try to make it as brief as

8 possible.

9 I would like for the witness to be given Defence Exhibit 190.

10 Again, I believe this is the one that we do not want to put on the ELMO.

11 JUDGE AGIUS: Yes. This, you must not put on the ELMO.

12 Re-examined by Ms. Sellers:

13 Q. I would just like to ask, Ms. Radovic, if you look toward the

14 bottom of this statement given to the Public Security Station in Skelani,

15 would you tell me whether you have signed the bottom of this statement or

16 not? Do you see your signature?

17 A. No, this is not my signature. I can show you my signature. This

18 here is not my signature. Do you want me to sign something now?

19 Q. No, thank you. Thank you very much for the answer.

20 MS. SELLERS: Also, I'd like to go to Defence Exhibit D189, and we

21 will turn to the page number that ends in ERN 54.

22 MR. JONES: Your Honours, could I just say quickly, for the

23 record, that for the last document, it doesn't purport to be a signature

24 either, so there's no question of a forgery of her signature, just so

25 that's clear.

1 JUDGE AGIUS: I agree with you, Mr. Jones, and I mean, I think the

2 answer that the witness gave was the answer that Ms. Sellers was

3 expecting, in any case.

4 MR. JONES: Yes. I just didn't want it to be thought that

5 someone had tried to forge her signature.

6 JUDGE AGIUS: No, it's okay. Thanks.

7 MS. SELLERS:

8 Q. Would you look on line number 7. I believe that your name is

9 written there, and would you follow that line along to the other side of

10 the page and tell the Trial Chamber whether you signed this document

11 concerning salaries.

12 A. Yes.

13 Q. Is that your signature there?

14 MS. SELLERS: Could I ask the usher possibly to assist, please.

15 JUDGE AGIUS: Yes, page 6994 --

16 A. No, no, this is not my signature. Do you want me to sign

17 something now so that all of you can see what my signature looks like? I

18 really want to be of assistance to you so that you can see what my

19 signature looks like.

20 MS. SELLERS:

21 Q. No, I believe that's fine. I just wanted to see --

22 JUDGE AGIUS: We already have your signature, Madam Radovic,

23 because you signed two statements which you gave to the Prosecution, so we

24 don't need your signature.

25 THE WITNESS: [Interpretation] Well, you can compare the

1 handwriting. If it is necessary, Your Honour, I can sign both in Cyrillic

2 and Latinic script.

3 JUDGE AGIUS: It's not necessary. I think it shows that you don't

4 have expertise of what these proceedings are. Ms. Sellers is precisely

5 expecting you to say no, that is not my signature. That's why she put the

6 question.

7 Yes, Ms. Sellers.

8 MS. SELLERS:

9 Q. I would also like to ask you, concerning the uniformed people that

10 are referred to as the Zenge, were they assisting the people in camouflage

11 uniforms that you've described as Muslim soldiers when you were arrested

12 and then subsequently imprisoned? Was that your impression, that they

13 were assisting them?

14 A. Yes.

15 Q. And was it also your impression that even the Muslims, who were

16 very kind and treated you with considerable respect while you were in Novo

17 Selo and then in Cerska, related to you that they were unable to release

18 you or to no longer make you an imprisoned person?

19 A. They didn't dare.

20 Q. And were you imprisoned by people in camouflage uniform who were

21 Bosnian Muslim soldiers?

22 A. In camouflage uniforms.

23 Q. And then my last question, I would just like to go back to Exhibit

24 P15. On this exhibit, I would like to draw your attention to what is the

25 bottom of the first page that I have in the English, and where it states

1 that "it is improbable that she knows any reliable information about the

2 Chetniks that could be of significance. She only knows of," and then the

3 name of one person, "allegedly a commander from the Chetnik units."

4 Was this, or does this appear to be the conclusion that the

5 questioner, interrogator, reached after speaking to you in the Srebrenica

6 prison?

7 A. I didn't understand your question.

8 Q. Let me rephrase the question.

9 JUDGE AGIUS: I don't think it is fair to ask this question to the

10 witness, because how can she answer -- confirm or not confirm, whether

11 this was the conclusion. It was the conclusion. That's what it says.

12 MS. SELLERS: I'll withdraw the question.

13 JUDGE AGIUS: She didn't draw up this document, she's not the

14 author of the document, and she doesn't even remember who the person was.

15 MS. SELLERS:

16 Q. One last question, and that concerns the prisoner Ilija Ivanovic.

17 Would you describe that person as having been handicapped or crippled, the

18 person who was exchanged with you?

19 A. Yes. I didn't know that he was epileptic, but when we started

20 out, he wasn't stable on his feet. And when we were on the truck, he

21 almost fell on me, and I pushed him away. And then I was afraid that I

22 had injured him. And then a woman helped me -- helped him, and he

23 regained his composure.

24 MS. SELLERS: Your Honour, I have no further questions. I do want

25 to make one comment about a Prosecution exhibit, and it's P19, to inform

1 Your Honours that the date that is on this exhibit in the English says 3

2 February 1993. We are asking for a revised translation. After having

3 spoken to the translators, it's uncertain as to whether that's 23 February

4 or 3 February. And I would like to advise you that we will be submitting

5 another translation.

6 JUDGE AGIUS: All right. I thank you. No questions?

7 Judge Eser.

8 Questioned by the Court:

9 JUDGE ESER: Mrs. Radovic, I would like to bring you back to the

10 meetings with Zulfo Tursunovic. You met him at least on two occasions,

11 one in Cerska when you have been exchanged -- when he came and he told you

12 that you would be exchanged, and then you would say -- the question is:

13 Was it -- did you have the impression that he said so, that it was his own

14 decision that you should be exchanged, or did you have the impression that

15 he was somehow advised by somebody else? You mentioned that he was acting

16 on somebody else's instructions - that was what I have in English - on

17 somebody else's instructions. What to you mean by that?

18 MR. JONES: Could Your Honour just refer us to that part because I

19 don't remember that part of her testimony.

20 JUDGE ESER: I have it here on somebody else's instructions.

21 MR. JONES: I also wonder whether she could really assist with

22 whether Zulfo Tursunovic was acting on his own or on any orders. I don't

23 know if it's something she can help with.

24 JUDGE AGIUS: She did mention something for sure along those

25 lines. But anyway, we can direct the witness to answer the question.

1 Should I read the question out to you again, Madam Radovic?

2 THE WITNESS: [Interpretation] Yes.

3 JUDGE AGIUS: Judge Eser asked you the following question, he told

4 you: "I would like to bring you back to the meetings with Zulfo

5 Tursunovic. You met him at least on two occasions, one in Cerska when you

6 have been exchanged -- when he came and told you that you would be

7 exchanged, and then you would say -- the question is: Was it -- did you

8 have the impression that he said so, that it was his own decision that you

9 would be exchanged, or did you have the impression that he was somehow

10 advised by somebody else to tell you that you would be exchanged." Do you

11 recall whether he had told that -- that he was telling you that you would

12 be exchanged because someone else had advised him that this would be the

13 case?

14 A. He simply told us that he had to bring us alive to Srebrenica. He

15 didn't tell us whether it was on somebody's orders. We had to cover all

16 that distance on foot. It's hard to say.

17 JUDGE ESER: Now, on the second occasion, when you have been in

18 Srebrenica, you told us that Zulfo Tursunovic left the room for a moment,

19 when you have -- or some of you have been beaten, and when he returned,

20 that he was angry against the other people. And did you have the

21 impression that he had some sort of authority with regard to the people,

22 to the persons, who maltreated you in this room?

23 A. Yes, yes.

24 JUDGE ESER: Thank you.

25 JUDGE AGIUS: Thank you. I take it that there are no further

1 questions, which means that your testimony comes to an end here. I will

2 just say a few words.

3 First of all, I would like to thank you, Madam Radovic, on behalf

4 of Judge Brydensholt and Judge Eser and also on behalf of the Tribunal,

5 for having come over to give testimony in this case. I know that

6 testifying on these events is never easy, particularly for someone like

7 you. And I want to assure you that, as soon as you leave this courtroom,

8 you will receive all the attention and all the assistance you require to

9 enable you to return home without any undue delay. I also wish to wish

10 you a safe journey back home, on behalf of everyone here. Thank you.

11 THE WITNESS: [Interpretation] I would like to greet everybody

12 here, wish you success and happiness in your further work, and I'm very

13 glad that I was able to spend this time here with you.

14 JUDGE AGIUS: Okay, I thank you, madam. You may now withdraw.

15 Before we rise, I should like to express the Chamber's gratitude

16 to all the officers of this courtroom, not only those present inside the

17 courtroom but, of course, the technicians, the interpreters. We have

18 exceeded our time limit by about eight minutes. I did not seek your

19 permission before we did so, so I apologise for that, and I thank you for

20 having cooperated so that we could finish with this witness and send her

21 back home as early as possible, and without keeping her here unnecessarily

22 for another day.

23 I thank you. We will reconvene tomorrow. We'll have the new

24 witness. Please try to make an effort to finish with the new witness

25 tomorrow. The reason is that you know that on Friday, we have a Plenary

1 and I, for sure, will not be able to -- we won't be sitting while we are

2 having a Plenary. So, if possible, we'll try to finish with the witness

3 tomorrow so that he doesn't have to -- he will not have to spend the

4 weekend here, all right?

5 Yes, Madam Vidovic.

6 MS. VIDOVIC: [Interpretation] Your Honours, we discussed it

7 amongst us and agreed that the Prosecutor will not take as much time as

8 initially envisaged. This witness will testify about the system, and this

9 witness is very important for us. And we will be able to conclude our

10 cross-examination only if the OTP shortens the direct examination. They

11 promised to do so, and I thought it was important to say so for the

12 record.

13 JUDGE AGIUS: Yes, Ms. Sellers.

14 MS. SELLERS: I would like to say that it will be co-counsel

15 Gramsci Di Fazio, and he has assured me that he will try to streamline

16 this direct testimony, and that is as a result of the discussion, I

17 believe, with the Defence.

18 JUDGE AGIUS: All right, thank you.

19 So we'll all meet tomorrow morning at 9.00 -- tomorrow afternoon.

20 Tomorrow, the sitting is in the afternoon, yes. Thank you.

21 --- Whereupon the hearing adjourned at 1.54 p.m.,

22 to be reconvened on Thursday, the 10th day of

23 February, 2005, at 2.15 p.m.

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