1 Wednesday, 24 August 2005

2 [Open session]

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

4 [The accused entered court]

5 JUDGE AGIUS: So good morning, Madam Registrar, could you call the

6 case, please.

7 THE REGISTRAR: Good morning, Your Honours. This is case number

8 IT-03-68, the Prosecutor versus Naser Oric.

9 JUDGE AGIUS: Thank you.

10 Mr. Oric, can you follow the proceedings in your own language?

11 THE ACCUSED: [Interpretation] Good morning, Your Honour. I can

12 follow everything in my own mother tongue.

13 JUDGE AGIUS: I am not receiving interpretation, but there is a

14 simple explanation to it: I am on number 0. Okay. I thank you,

15 Mr. Oric, and good morning to you.

16 Appearances for the Prosecution.

17 MR. WUBBEN: Good morning, Your Honours, and also good morning to

18 my learned friends of the Defence. My name is Jan Wubben, lead counsel

19 for the Prosecution. I am here together with co-counsel, Mr. Gramsci

20 Di Fazio, Ms. Joanne Richardson, and our case manager, Mrs. Donnica

21 Henry-Frijlink.

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

23 of course, Mr. Wubben.

24 Appearances for Naser Oric.

25 MS. VIDOVIC: [Interpretation] Good morning, Your Honours. I'm

1 Vasvija Vidovic. Together with Mr. John Jones I represent Mr. Oric. We

2 have our legal assistant, Ms. Jasmina Cosic, and our case manager,

3 Mr. Geoff Roberts.

4 JUDGE AGIUS: I thank you and good morning to you as well and to

5 the rest of your team.

6 So any preliminaries before we bring in the witness? I just

7 wanted to alert you to the fact that although two days ago I said and you

8 agreed with me at the time that there was probably no need for a written

9 decision on the protective measures that we discussed at the end of the

10 day. We decided that it is more in conformity of the practice we have

11 been following so far and we handed down a written decision. So you

12 should have received that; I signed it yesterday.

13 Yes, the other thing you had to come back to me, you remember I

14 mentioned to you, saying that it was something that we will deal with

15 first thing on Wednesday morning regarding the CD containing the photos of

16 the site visit. And that I agreed -- or we agreed that it should not be a

17 party exhibit but a Court exhibit.

18 So do you have anything to add in relation to this matter?

19 Mr. Wubben?

20 MR. WUBBEN: Your Honour, regarding that CD, first issue: We

21 consent to accepting the index provided to us this morning as being an

22 accurate reflection of the photos as much as possible. Of course, when it

23 comes to photographs taken from the helicopter, and that's confirmed, I

24 noticed it. That's the first issue.

25 There's a second issue: We want to tender a translation, an

1 English translation, of the book of -- with the title "Srebrenica" by

2 Ibisevic. We already used that book prior to the summer break during the

3 second witness, and that was a part of it. But now we can hand over a

4 total English translation of that book.

5 JUDGE AGIUS: Okay. I thank you, Mr. Wubben.

6 Is there -- are there any remarks from the Defence?

7 MS. VIDOVIC: [Interpretation] No, Your Honours. We have nothing

8 to add in relation to photos and the index. Thank you.

9 JUDGE AGIUS: And -- yeah, and in relation to the translation on

10 the book that the Prosecution is seeking to tender?

11 MS. VIDOVIC: [Interpretation] Your Honours, we would like to thank

12 the Prosecution since we will be using the said book a great deal in the

13 course of the proceedings. At any rate, Your Honours, we will look

14 through the translation, and if we happen to have any comments we shall

15 react accordingly.

16 JUDGE AGIUS: Yeah, obviously. I thank you, Madam Vidovic. So

17 let's close this chapter first -- one moment --

18 MR. WUBBEN: Your Honour, apologies. In addition, for your

19 information, it was accepted that part of the translation was accepted

20 under P564 during that second witness's cross-examination, for your

21 information, to assign a new P number to that. Thank you.

22 JUDGE AGIUS: Yes, I'm going to give it a number. So let's get

23 the help of Madam Registrar. Let's start with this translation of

24 Ibisevic's book. You've heard Mr. Wubben say that it was P564. Shall we

25 give it P564.1 or what do you -- what is your preference in order not to

1 create confusion for you?

2 THE REGISTRAR: Yes, it will be P564E, Your Honour.

3 JUDGE AGIUS: E. So this will be P564E. All right.

4 And the CD-ROM with the photos of the site visit, this will be a

5 Court document so it will be C or a CT? I don't know?

6 THE REGISTRAR: It will be C2.

7 JUDGE AGIUS: C2.

8 THE REGISTRAR: Yeah.

9 JUDGE AGIUS: Thank you. And the typewritten index will be C2.1?

10 THE REGISTRAR: Yes, that's right.

11 JUDGE AGIUS: All right. Good. Thank you.

12 [Trial Chamber and legal officer confer]

13 JUDGE AGIUS: I am also being reminded that some time back I had

14 also suggested that we will also have the CD containing the reconnaissance

15 pictures taken by Mr. Berikoff to be included also amongst the exhibits.

16 If there's no objection to that that will be so admitted and marked as

17 Exhibit C3. Okay. All right. So this will be Exhibit C3.

18 Any further preliminaries?

19 MR. WUBBEN: No, Your Honour.

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

21 JUDGE AGIUS: So, usher, could you please escort the witness into

22 the courtroom.

23 [The witness entered court]

24 JUDGE AGIUS: Good morning to you, Madam Hotic.

25 THE WITNESS: [Interpretation] Good morning.

1 JUDGE AGIUS: Before I proceed any further, I want to make sure

2 that what I am saying in English and what will be said in English later on

3 is being translated to you in a language that you can understand. Can you

4 confirm that?

5 THE WITNESS: [Interpretation] Yes.

6 JUDGE AGIUS: If at any time there are problems with the reception

7 of interpretation, either you're not receiving it or it's too loud or you

8 cannot hear it well enough, please draw our attention straight away and we

9 will rectify the matter.

10 THE WITNESS: [Interpretation] I understand.

11 JUDGE AGIUS: So good morning and welcome to this Tribunal. You

12 have been summoned to give evidence in this trial against Naser Oric.

13 You've been summoned as a Defence witness. And very soon you will sit

14 down and start giving evidence, but before you do so our rules require

15 that you enter a solemn declaration equivalent to an oath in several

16 jurisdictions, domestic jurisdictions, namely that in the course your

17 testimony you will be testifying the truth, the whole truth, and nothing

18 but the truth. The text is contained in a piece of paper which the lady

19 usher standing next to you is going to hand you now. Please read it out

20 aloud and that will be your solemn undertaking with us.

21 THE WITNESS: [Interpretation] I solemnly declare that I will speak

22 the truth, the whole truth, and nothing but the truth.

23 JUDGE AGIUS: Madam, you may sit down and make yourself

24 comfortable. And I'll explain to you very briefly what's going to happen.

25 As I said, you have been summoned by the Defence as one of their

1 witnesses, so it will be the Defence, Mr. Jones precisely, who will be

2 asking you questions. He will then be followed by Mr. Di Fazio, who is

3 appearing -- one of the counsels appearing for the Prosecution in this

4 case.

5 Your responsibility and your obligation under the solemn

6 declaration that you have just made is to answer all questions

7 irrespective of where they are coming from, irrespective of who is putting

8 the questions to you, to answer all these questions fully and honestly and

9 to the best of your ability.

10 Mr. Jones.

11 MR. JONES: Thank you, Your Honour.

12 WITNESS: KADA HOTIC

13 [Witness answered through interpreter]

14 Examined by Mr. Jones:

15 Q. Good morning.

16 A. Good morning.

17 Q. Could you please give the Court your full name.

18 A. My name is Kada Hotic.

19 Q. And if you could confirm for us the following personal details:

20 You were born on the 11th of May, 1945, in Zvornik?

21 A. Yes.

22 Q. Your father went missing during the Second World War and your

23 mother remarried?

24 A. Yes.

25 Q. And growing up you had two brothers, Ekrem Cilovic and Mustafa

1 Cilovic as well as a sister, Rukja?

2 A. Correct.

3 Q. You were married to Sead Hotic in 1965?

4 A. Yes.

5 Q. You had a son called Samir and a daughter Lejla.

6 A. Yes.

7 Q. And your husband, your son, and your two brothers were all killed

8 when Srebrenica fell to the Serbs in July 1995?

9 A. Yes, yes.

10 Q. Did you lose many other relatives in July 1995?

11 A. All my male relatives. Some families -- some family names

12 disappeared altogether. There are no male relatives left bearing that --

13 those family names.

14 Q. Are you involved in any association which is dedicated to

15 preserving the memory of those who died in July 1995?

16 A. Yes. I'm an active member and a deputy president of the movement

17 of the mothers of the enclaves of Srebrenica and Zepa. Those were the

18 enclaves which were under the protection of the UN, and they went through

19 what they went through in 1995.

20 Q. Now, from 1973 until the fall of Srebrenica, did you live in

21 Srebrenica?

22 A. Yes.

23 Q. And where did you live?

24 A. The Marsal Tito Street next to the post office and the hospital.

25 Those two buildings still stand in Srebrenica today.

1 Q. And where did your two brothers live?

2 A. The Stari Grad Street in Srebrenica.

3 Q. Did they know Akif Ustic?

4 A. Yes. We were close.

5 Q. Now, before the war your husband worked in the JNA and then left

6 to study sociology part time, eventually becoming a professor of

7 sociology. Would that be correct?

8 A. Yes.

9 Q. Can you tell us briefly why he left the JNA?

10 A. In 1970 my husband left the JNA service because he felt that there

11 was discrimination against him. He had the wish to go on to higher

12 education, but he was always told that he was good enough for the job he

13 had, whereas his colleagues who were Serbs were sent off to higher

14 education institutions. He was revolted and he left the job, and there

15 were other reasons as well. He could feel that discrimination as early as

16 the 1970s.

17 Q. And this was discrimination against him as a Bosniak?

18 A. Yes, of course, because he was a Muslim.

19 Q. His last job before retiring was at the Ministry of the Interior

20 in Srebrenica. Would that be correct?

21 A. Perhaps you misunderstood me. The Ministry of the Interior --

22 yeah, that's where he worked, at SUP.

23 Q. Right. It might have been a problem with translation. I was

24 referring to the Ministry of the Interior, the SUP. When did he leave the

25 SUP?

1 A. Yes, it was the SUP. He retired in 1991, in the beginning of

2 1991. I can't recall the exact date.

3 Q. Okay. Now, it's not in dispute that war broke out in Bosnia in

4 1992. Were you aware of any events locally prior to war breaking out

5 which were in any way out of the ordinary?

6 A. Some things started to happen which appeared a bit weird. Where I

7 worked, and it was a clothes factory, there were 250 women working there,

8 Serbs, Muslims, Croats, and then rumours started about the Serbs being

9 threatened, about how something had to be done. And occasionally we

10 complained about this. We asked why they felt that the Serbs were

11 threatened. And then there was a problem in Slovenia when the JNA

12 soldiers were attacked. And then we felt sorry for the soldiers, all of

13 us together, because we felt that they were our soldiers, the soldiers of

14 the former Yugoslavia. And then war broke out in Vukovar, and the same

15 army, the JNA, attacked the population of Vukovar and crimes were

16 perpetrated there. And we still believed that war would not come to

17 Bosnia. We still worked together. But during our breaks our Serb

18 colleagues tended to sit apart and they had their own story going. They

19 said that the Serb brethren should be helped. And one of my colleagues

20 was called Rosa said, Oh, I've got a pig that I'm going to send to Knin,

21 there are Serbs living there and they are threatened and they should be

22 helped. And we never quite understood why they needed any assistance and

23 why they felt they were threatened in any way.

24 Q. Thank you. In your factory was there talk about Radovan Karadzic

25 or Slobodan Milosevic?

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1 A. Yes, of course. Those were the top political leaders and they

2 addressed the public through the media. And we always commented on their

3 statements in the course of our breaks. And those of us who were Muslims

4 or Bosniaks never agreed with them because we really did not know why they

5 were spreading that propaganda, according to which the Serbs were

6 threatened, that they should all live in one state. And when Karadzic

7 said that if the Muslims ever resisted they would be wiped off the face of

8 the earth, I mean it was unclear to us why the Muslim people should be

9 made to disappear and why we should be considered obstacles to one other

10 in Bosnia at the time.

11 Slobodan Milosevic was the top political leader in Serbia, and our

12 Serb colleagues applauded his speeches and they adored him. And also

13 there was the radical Serb leader Seselj, and when he got there my Serb

14 colleagues said, Thank God that man has come along who is likely to lead

15 our youth on the right path. But it was still unclear to us what was

16 brewing. We felt that it was going to blow over, that those political

17 changes and speeches and everything would stop. But we were betrayed, in

18 fact, because not a single colleague or friend or boss of some kind or a

19 leader within the municipality of Srebrenica never gave us any hint of

20 what was in the making. They kept everything secret.

21 Q. Thank you, Ms. Hotic. I just want to stop you there to ask you

22 this: Did your husband ever speak to you about events which he noticed

23 occurring locally which caused him alarm?

24 A. Even before the beginning of the war, my husband noticed some

25 things that were not quite clear to him. For example, while he was still

1 working he went out into the field, he went to Skelani, this is on the

2 Drina river in the municipality of Srebrenica, and he noticed a group of

3 people having target practice. They were using ammunition, rifles. And

4 in view of the fact that Savo Aleksic, his chief of SUP was there, he

5 asked Savo, Savo, do you know why they are shooting over there, why are

6 they having target practice, because any firing from a firearm, for that

7 you had to have permission from the SUP. Savo said he had no idea what

8 was going on there.

9 Also, trees were being cut, roads were being cut through the hills

10 around Srebrenica so that my husband also was asking, Why are these trees

11 being cut? Why are these roads being cut through? And they said it was

12 for the export of timber three years before the war broke out. However,

13 the Territorial Defence weapons from the municipality of Srebrenica were

14 withdrawn to the zone headquarters without any explanation why this was

15 being done. Of course, my husband, because he was amongst the prominent

16 people in Srebrenica, was asking why this was happening but he never

17 received an explanation.

18 Q. There's three events you mention, and I'll just try to fix each of

19 them in time. The shooting in the Skelani area, when did that occur,

20 roughly?

21 A. The shooting was in 1991 at the beginning of the year, I think,

22 but please don't ask me for the exact date because I really don't remember

23 the date. I remember the events, but I've forgotten the dates.

24 Q. Thank you. And the woods -- sorry, the roads which were being

25 built through the woods, again when did that occur roughly?

1 A. That was also in 1991.

2 Q. And then finally, the surrender of the weapons of the TO to the

3 district staff which you described, when did that occur?

4 A. That was three years before the war broke out.

5 Q. And in each case your husband asked his superior, Savo Aleksic,

6 what was going on and he received the answer that Savo didn't know. Is

7 that correct?

8 A. Not only Savo Aleksic, he asked him when he was his superior but

9 he was also asking the top men in the Srebrenica municipality. Mostly it

10 was the Serbs who were at these positions. For example, the chief of the

11 Territorial Defence was Miso Stanisaljevic and he asked him about the

12 weapons.

13 Q. And Miso Stanisaljevic and Savo Aleksic are both Serbs. Is that

14 correct?

15 A. Of course.

16 Q. Did your husband draw any conclusions about these activities which

17 he observed?

18 A. It was just suspicious. He didn't really know exactly what was

19 going on, though.

20 Q. In terms of those new roads which you mentioned, subsequently were

21 they used for anything during the course of the war?

22 A. All those roads and the places where the forest was cut through so

23 you could have a view of Srebrenica, the Serbs placed tanks and mortars

24 and other artillery weapons so that they could shoot at Srebrenica. And

25 that is where they fired at Srebrenica, from these positions.

1 Q. Right. Now, I'm going to move on to the war now in early 1992.

2 Was anything done by people in Srebrenica, in Bratunac municipalities to

3 prevent conflict from breaking out in those municipalities?

4 A. Before the conflict broke out, the most prominent men in

5 Srebrenica spoke with the Serbs, first of all with the president of the

6 SDS, Goran Zekic, and with other people in order to reach some kind of

7 agreement to prevent a conflict, to see what they could do in order to

8 continue living together, since we had lived and worked together before.

9 But there were several meetings that took place in Srebrenica, in

10 Bratunac, in the Fontana Hotel, in Ljubovic, at Brioni, and I remember

11 Dr. Sabit Begic, he was a doctor. These were not military people. These

12 were just intellectuals from different professions. Sabit was a doctor,

13 for example, an internist, Gasi Fustic [as interpreted] was a professor at

14 school.

15 Q. I'll stop you there for a moment. It's come out as Gasi Fustic.

16 Is that the correct name? Or could you repeat the name of the person who

17 was a professor at school.

18 A. Yes, yes. Kijasev Ostic [as interpreted] and many people were

19 aware that something was going on and that something had to be done. Of

20 course, they had meetings with Zekic and other Serbs. They spoke with

21 them several times. Even Kijasev was offering his children as a kind of

22 guarantee in exchange for his own children. They would put each other's

23 children in each other's apartment as some kind of safety guarantee. But

24 after a number of meetings, suddenly Dr. Sabit Begic passed by the --

25 along the street and I heard him say, There will be a war, you better save

1 yourselves.

2 Q. Thank you. I think I still need to clarify this name. I'll

3 approach it this way. Earlier I asked you if your two brothers lived

4 near -- or you told us that your two brothers lived near Akif Ustic. The

5 person that you're referring to as being involved in these discussions, is

6 that Akif Ustic or is it some other --

7 A. I apologise, Akif, yes, not Kijasev. Please, forgive me. Akif.

8 I apologise, it's my mistake.

9 Q. And so Akif Ustic, he proposed to Goran Zekic, is that correct,

10 that his children would stay --

11 A. Yes, yes.

12 Q. -- as a sort of guarantee of peace. Is that correct?

13 A. Yes.

14 Q. Did Goran Zekic accept that offer?

15 A. No, no.

16 Q. Why was Akif Ustic involved in these discussions?

17 A. People were simply looking for some kind of solution. The

18 situation was difficult, and of course in order to prevent a war, because

19 Muslims, Bosniaks in Srebrenica did not want a war. They didn't have the

20 means and they have any need for war. We thought that we could live the

21 same way that we lived before. I don't know why we would need to have a

22 war in the first place.

23 Q. Then you told us that Dr. Sabit Begic after a certain number of

24 these meetings said that there will be war, that you better save

25 yourselves. What was the reaction to that announcement?

1 A. There were many people at that time who had a car and who heard

2 that and they left Srebrenica that day. And most of those people are

3 still alive today, including Sabit Begic.

4 Q. And among the people who left Srebrenica, was it all classes of

5 people or was it a particular class or people with a certain level of

6 education?

7 A. It was mostly Muslims. Muslims. There were different profiles.

8 There were educated people, those who understood that they could be in

9 danger and that they should leave in order to save themselves. However,

10 barricades were set up quite soon after that. I was also trying to

11 persuade my husband and my son to leave. My husband said, though, that,

12 I'm not guilty of anything. I don't want to be going all over the place.

13 I think the situation would calm down and we should stay here.

14 Q. So when did the barricades go up and it become impossible to leave

15 Srebrenica?

16 A. The barricades were set up in April 1992 so we couldn't leave

17 anymore. It was in late March and early April; nobody could leave

18 Srebrenica anymore after that.

19 Q. And at a certain stage did the Serbs take over the SUP and fire

20 the Muslims from there?

21 A. In the meantime the Serbs evacuated their families, their wives,

22 and children from Srebrenica, and we were wondering why they were doing

23 that. The people who stayed were men who dressed in former JNA uniforms.

24 My neighbours, Serbs, all dressed in former JNA uniforms. They simply

25 disbanded the police, the milicija, at the time, the Muslims that were

1 there. The chief at the time, Hamed Efendic, was dismissed as well. And

2 they took over all the key structures in Srebrenica.

3 Q. Now, did there come a time when you had to leave your house in

4 Srebrenica?

5 A. Yes, of course. We simply sensed danger because my neighbours,

6 Serbs, had taken up arms, and those who had left Srebrenica had left, and

7 those who had stayed behind, stayed behind. We were simply trying to save

8 ourselves by staying close to the woods. My brothers had a house that was

9 closest to the woods, so we went to their place and we were simply waiting

10 for something to be resolved.

11 Q. Was there ever any specific event which led to you actually

12 spending the night or nights in the woods?

13 A. We were still staying at my brother's place. It snowed even

14 though it was not -- it was still -- it was not the usual time for it to

15 snow. The fruit trees for already blossoming. So we could hear some

16 shelling in the area of Potocari, and my husband said that he assumed that

17 these were mortars because he was an expert in weapons, he knew about

18 weapons.

19 That morning, a neighbour came. We called him our neighbour, he

20 was Drago Andric from Pribicevac. It's a village two kilometres away from

21 Srebrenica, you go through Stari Grad. So he came to my brother's place

22 in order to use the telephone because they didn't have a telephone up

23 there. He had sons in Novi Sad, so we wanted to talk to him. So we asked

24 him, Drago, what is happening? He said, We are attacking the Green

25 Berets. And we said, What Green Berets, Drago? And he said, There are

1 Green Berets. So we said, Well, what are we going to do, Drago? And he

2 said, Well, come back up to my place. And then my brother, my son, my

3 husband and I all went to Pribicevac, to Drago's place, and we spent the

4 night there.

5 During the night a Niva vehicle passed by the road that had been

6 cut through the hills. It was a red Niva car and Drago went out and then

7 he came back laughing. And we said, Drago, what is happening? And he

8 said, Well, they've just brought a mortar over. So I said, What are we

9 going to do with a mortar? And he said, Well, we will set it up at

10 Tri Kralja, that's what the place was called, and that's where we will

11 shell Srebrenica from. And I said, Why would you want to do that? He

12 said, Well, because of the Green Berets.

13 In the course of the night he went out two or three times and then

14 he said the Tri Kralja location is not suitable. Another location,

15 Divlivac [phoen], it's much better to be able to shell Srebrenica. So we

16 spent the night there. And then I told my husband and my brother, let's

17 go home because somebody from the army could come because they were

18 expecting somebody. His wife is making bread and it's only her and her

19 husband who are at home. So I thought maybe some soldiers would come by,

20 and I didn't want anybody to abuse us, mistreat us or maybe mistreat those

21 people because of us. So in the morning I said, Drago, could you please

22 take us through the forest and after that bring us to some place where we

23 could find our own way because I think it would be the best thing to

24 return to Srebrenica.

25 Q. Right. Thank you. So that's -- could you fix the date, first of

1 all, when this event occurred?

2 A. I can't tell you the exact date. It was in late April, I think.

3 Q. Late April 1992, I take it?

4 A. 1992.

5 Q. Drago, can you tell us his ethnicity?

6 A. Drago was a Serb, and the village of Pribicevac had three or four

7 Serb houses. His brother Srecko was there. Also a family called

8 Vukosavljevic. There was also another young man.

9 Q. Do I take it from this -- from what you saw that you saw a mortar

10 being placed in Pribicevac in 1992, being brought to Pribicevac?

11 A. I heard that from Drago. A car passed and Drago said that there

12 was a mortar in it. I didn't go out to look.

13 Q. And subsequently were you aware whether or not artillery was

14 placed on Pribicevac?

15 A. Yes. When we came home that morning, I don't know whether it was

16 on that same day or the next day, we wanted to return to our apartment in

17 Srebrenica. But we came to Lovac and that's where we heard shooting. In

18 front of the Domavija hotel and we returned because of this shooting. We

19 didn't know who was shooting or why. Very soon after that we could hear

20 shouting over a loud speaker through the Petrica and Crni Guber Streets.

21 We were at an elevated point between those two streets, and we could hear

22 clearly that they were asking people who possessed legal or illegal

23 weapons to surrender them, otherwise those people found to be in

24 possession of weapons would be slaughtered.

25 We were in a panic, and all the people in Stari Grad, we all went

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1 to one house in a panic and then we simply all agreed that we would go to

2 the woods. So we fled to the woods although --

3 Q. Yes. Sorry if I cut you off occasionally but you're giving very

4 detailed answers, and actually it would be helpful if you give slightly

5 less detail on -- at least it's not necessary to give as much detail for

6 each of these questions.

7 A. Thank you.

8 Q. The question which I -- which I'd appreciate you answering is

9 whether -- in Pribicevac whether you became aware during the course of

10 1992 of heavy artillery or any sort of artillery being placed there?

11 A. Yes. While we were in the woods. One afternoon, the firing

12 started. They started to shell with mortars, and that day I counted 83

13 mortars fired. And I could hear clearly the instruction from the command:

14 Fire at Karsija. This is a forest. And Akif Ustic, Hakija Meholjic went

15 to that forest as well as a group of young met to think about what they

16 would do, how to set up a defence because we were attacked, and we had to

17 figure out how to defend ourselves. My son still hadn't joined them, he

18 was still with us, but very soon after that he also went there to join

19 them.

20 Q. Yes, thank you. But please just try to answer the question I

21 pose, because I want to stick specifically with Pribicevac for a moment.

22 You mentioned -- you've confirmed that there was artillery in

23 Pribicevac. Did that change during the course of 1992 or was there always

24 Serb artillery in Pribicevac?

25 A. From that place you could see -- actually, that place from the

1 Srebrenica marketplace, the square, you could see where that forest was

2 cut through. That was the place where they fired mortars at the town.

3 Later they also fired tank grenades. There were also PAM and PAT weapons,

4 and these were very large weapons with a range good enough to be able to

5 hit the centre of the town.

6 Q. You say that was the place where they fired mortars, you're

7 referring to Pribicevac?

8 A. Yes.

9 Q. And if someone were to say that in, let's say, the summer of 1992

10 it was perfectly possible for Muslims to pass through Pribicevac to go

11 from Srebrenica to, let's say, Mocevici or Poznanovici, would that be

12 correct?

13 A. It was impossible because you had to pass through their ambushes

14 and how could you do that, the Serb ambushes or the Serb positions were

15 there.

16 Q. Okay. Thank you. Now, you've mentioned that when you came back

17 from going to Pribicevac the first time with Drago that then someone was

18 going around with a speaker telling Muslims, I think it was, to disarm.

19 So I want to ask you a question or two about that. First of all, who was

20 doing that? Who was going around with a megaphone?

21 A. When I mentioned the shooting, because of which we returned and

22 tried to go back to our apartment because we still thought it was possible

23 to stay there, that's when the White Eagles came. Later we found out that

24 the White Eagles went to Srebrenica or entered Srebrenica.

25 After their stay, I don't know how long they stayed, they

1 ransacked all the apartments, houses, looking for weapons. Many women

2 brought out hunting rifles, or if somebody had a pistol or something,

3 because they were afraid that the men would leave. The men were in the

4 forest. So they collected everything and they also took away the cars.

5 And one of my neighbours who asked a young man when she took the hunting

6 rifle to him, she asked him, You are so young and so handsome, please be

7 careful, child, not to get killed somewhere. Don't make your mother cry.

8 And he said, I am paid to do this, and then I will leave. I am not even

9 from here, I am from Nis. Nis is in Serbia.

10 Q. So this young man from Nis in Serbia was a White Eagle?

11 A. Yes. She said he had a nice jacket, a nice clean sneakers, he had

12 a neat haircut, he looked very neat. He wasn't wearing a uniform.

13 Q. And were -- was it only White Eagles who were involved in

14 disarming Muslims in Srebrenica in this period or were local Serbs also

15 involved?

16 A. Of course the local Serbs, too. There was a person, I can't

17 remember his name, we called him Zmiro, Miodrag. He had occupied the SUP

18 at the time and he had men who were asking for rifles. Some of the

19 Muslims bought a rifle for 1500 German marks, and they wanted those rifles

20 to be returned. They would give the number of the rifle, when it was

21 sold, and for how much it was sold, so then they had to return those

22 weapons. They went together to collect the weapons if -- however many

23 pieces of firearms there were.

24 Q. So you're saying that there was a way of knowing which Muslims had

25 weapons because it was registered in some way. Is that what you're

1 telling us?

2 A. Yes. Probably in the beginning people didn't know that all of

3 this was being recorded when they bought the rifles. Later this became

4 clear.

5 Q. Right. Now, going back to the woods, how long did you spend in

6 the woods?

7 A. We spent 11 nights in the forest. After the snow, then it began

8 to rain.

9 Q. Thank you. Now, do you know what happened to Muslims who remained

10 in Srebrenica?

11 A. At one point, Eso Jakupovic came; he was a policeman. He came and

12 told us not to go home at any cost because whatever people were found in

13 Srebrenica were taken in front of the SUP and shot. There were 29 people.

14 Amongst them was a former employee of the SUP. He was walking on

15 crutches, he was an invalid, and they sent him to negotiate about

16 something with Akif Ustic. I don't know what they were talking about.

17 They kept his wife as a hostage, and this man, Eso, had to go back. But a

18 total of 29 people were killed. All the people who remained in Srebrenica

19 and didn't manage go to the woods were killed.

20 Q. Now, you've mentioned a couple of times that Akif Ustic and I

21 think you said Hakija Meholjic were in the woods as well. How many people

22 in your group in total in that part of the woods?

23 A. Akif Ustic and Hakija Meholjic had a group of people from Petrica

24 and Stari Grad. These were places that were close by. However, women,

25 children, and my husband and my brother were on the other side of the

1 woods, so I don't know exactly how many people were in the woods.

2 Q. So the people you were with were those from Stari Grad and

3 Petrica?

4 A. Yes.

5 Q. And were these all men in the woods or were there other women like

6 you, were there children there?

7 A. No, women and children. There were some elderly men. There were

8 also some young men. Later the young men went to join Hakija and Akif.

9 Q. At that time did you have any weapons or anything like that with

10 you?

11 A. No, we didn't have any weapons, the women and the children. Maybe

12 Hakija had some rifles. These were part of the police reserve forces, so

13 they did have something. I know that my son told me that they had a few

14 bullets each in their pockets, but that was all.

15 Q. And what did you do for shelter at night?

16 A. No, well, we didn't have any kind of shelter. We had a piece of

17 tent fabric which we stretched out over the branches in order to cover

18 ourselves or protect ourselves from the rain. We also covered ourselves

19 with leaves and so on in order to stay warm. At night we would sneak back

20 to our homes to bake bread so that we would have something to eat,

21 something to feed our children with.

22 We spent a total of 11 nights in the woods. I think I can give

23 you the date for that. This was the 7th or the 8th of May when there was

24 talk that Goran Zekic was killed. We felt relieved in a way, as if we

25 were saved in a way. So then we spent a few more nights in the forest

1 after that, and then we returned home.

2 Q. And while you were in the woods, did you see any movement by the

3 Serbs in Srebrenica? Did you see what they were doing?

4 A. My brother had binoculars and we could see from the hill down into

5 what was going on in Srebrenica. In Srebrenica there were trucks driving

6 off furniture through Bojna. This was something that we could see, and

7 then you could drive further towards Skelani Bajina Basta and so

8 on.

9 Anyway, they were carting of everything valuable from Srebrenica.

10 Before that the White Eagles had taken away all the cars, so Srebrenica

11 was abandoned. Perhaps a day or two after these things were being carted

12 off, Srebrenica was torched from the entrance to the town all along the

13 two streets. Srebrenica is a town with two streets. The houses that were

14 very close to the woods were not fired -- torched. Everything else was

15 set on fire. And then the Serbs left Srebrenica, and then two or three

16 days after that we slowly started to return to Srebrenica because

17 everything was being robbed.

18 MS. VIDOVIC: [Interpretation] Your Honour, just one remark, my

19 brother said -- she said that my brother is a gajodeta [phoen], a surveyor

20 by profession, and that is something that did not get into the transcript.

21 JUDGE AGIUS: I just want -- I wouldn't have any doubt that she

22 did say so, I just want a confirmation from the witness.

23 Did you say that your brother was a surveyor by profession?

24 THE WITNESS: [Interpretation] Yes, he was a surveyor by

25 profession.

1 JUDGE AGIUS: Yes. One moment, Mr. Jones.

2 Judge Eser.

3 JUDGE ESER: I would have a question just to clarify the area

4 where it was this happened. When you speak of the woods or the forest,

5 was it in the direction to Pribicevac or was it on the other side of

6 Srebrenica? You talked about Pribicevac, where you had Serb mortars

7 located. Now, could you perhaps describe where you, the Muslims, stayed

8 during the night?

9 THE WITNESS: [Interpretation] Srebrenica hills are rather

10 interesting, those are elevations and then creeks. The Pribicevac area

11 was behind us. We were at the foot of the hill called Pribicevac. Shells

12 flew over our heads, and they went in the direction of Karsija, which is

13 the second hill. And all that is pretty close. I can't tell you in any

14 other way.

15 MR. JONES: Perhaps it's useful at this stage to hand up copies of

16 a map which we've put together for this witness. In proofing this

17 witness, I don't think she's particularly keen on locating places on a

18 map. It's more really for our benefit. And just for the record this map,

19 in order to Fakovici on the same map as Srebrenica, we did have to put

20 together two maps, but they are perfectly aligned, I would submit, and one

21 is a topographical map of Zvornik, the scale is 1:100.000, and the other

22 one is a topographical map of Valjevo.

23 JUDGE AGIUS: This is, it seems to me at least, to be identical to

24 D714. It's taken from the same survey map.

25 MR. JONES: Yes. I may use D714 later.

1 JUDGE AGIUS: It's not even a survey map.

2 MR. JONES: And if it's -- yes, it's been placed on the ELMO, but

3 I think we see Bojna south of Srebrenica and Pribicevac to the south-east.

4 JUDGE AGIUS: Should we give it a number straight away,

5 Mr. Jones.

6 MR. JONES: Yes. Thank you, Your Honour. That would be helpful.

7 JUDGE AGIUS: This will be Defence Exhibit D --

8 MR. JONES: I think it might be 716.

9 JUDGE AGIUS: 716.

10 THE REGISTRAR: Your Honour, it will be B715 --

11 JUDGE AGIUS: D --

12 THE REGISTRAR: D.

13 JUDGE AGIUS: D715. Thank you.

14 MR. JONES: Thank you, Your Honour.

15 Q. Now, Ms. Hotic, you were telling us how you went back into

16 Srebrenica. Can you just tell us briefly in what state you found the town

17 when you returned?

18 A. There wasn't a soul in town. There was nobody there. When we

19 entered the town and we walked down the streets we saw burnt down houses,

20 some totally burnt down, some only partially. In some cases half a house

21 was left standing or a couple of rooms were left standing. But all houses

22 had been broken in, all furniture was in disarray, whatever was of value

23 was taken away, and it was a ghost town.

24 And then we all went to our own places and we tried to make at

25 least a little bit of those homes habitable. Only the apartment buildings

1 next to the hospital were not set on fire, but all the houses as of the

2 bus station and higher up, and that part on the way out from Srebrenica

3 was not set on fire, so it was possible for us to spend some time there.

4 But everything had been looted.

5 Q. And did you ever speak to anyone in Srebrenica who had actually

6 been an eye-witness to the burning of houses?

7 A. Yes, I talked to Hasa Selmanagic. She was at the very centre of

8 town near the mosque. She had a house there, and she didn't manage to

9 flee to the woods, and she tried to defend her house and she was trying to

10 put the fire out. There were only two or three people setting fire to

11 houses because we could actually see them using the binoculars. And I

12 even know the guy, he was called Tanto, and he was carrying a pail and he

13 was throwing something into the houses. And Tanto is still in Srebrenica,

14 and this woman almost went mad out of fear and horror. Because when her

15 house was set on fire and another building was set on fire across the

16 street next to the mosque, it was called the forestry building, there were

17 people who were disabled who had stayed in, and they were set on fire

18 alive, and they were burnt alive and they were screaming horribly. And

19 later on we found out that eight people were actually burnt to death and

20 their remains were buried near the mosque in Srebrenica.

21 Q. Now, Tanto you say is still in Srebrenica. Was he a local Serb?

22 A. Yes, yes. And he was called Tanto, it was his nickname, but I

23 never knew what his real name was, and he lived in Carsija.

24 Q. And from what you could see of the local Serbs in Srebrenica with

25 the binoculars when you were in the woods, were they in civilian clothes

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1 or in uniforms?

2 A. Yes. The Serbs were wearing the uniforms of the former JNA.

3 Q. And were the Serbs -- when you refer to local Serbs, is that Serbs

4 only from the town of Srebrenica, or did you at any stage notice or hear

5 of Serbs from surrounding villages who were involved in the torching and

6 looting of Srebrenica?

7 A. Yes, of course. From the surrounding villages, from Orahovica I

8 used to see them. They were together with our local Serbs from

9 Srebrenica, neighbours. And basically they were all our neighbours

10 because it is all in the same municipality. Except for when Arkan's or

11 Seselj's men came along, or the White Eagles, they used to come and go as

12 well.

13 Q. Right. Now, it is not in dispute that Srebrenica was under

14 intensive shelling at the time relevant to the indictment, so I'm not

15 going to ask you about that in detail. I would ask you if you could

16 locate for us where, to your knowledge, some of the locations the Serbs

17 were shelling the town of Srebrenica in 1992.

18 A. From the direction of Pribicevac, Sase, Bratunac, and then

19 opposite -- across Suceska, from Koprivno, from Rogac, from Tara, from all

20 four sides basically.

21 JUDGE AGIUS: Yes, Mr. Di Fazio.

22 MR. DI FAZIO: If Your Honours please, this line of questioning is

23 of course not one that I object to, but I would object to the witness

24 providing this sort of evidence unless there's a foundation for it, the

25 basis upon which she can say to you with accuracy and with reliability the

1 point at which the shells emanated from. That's a complex business as far

2 as I can understand, and unless this witness is qualified and can speak

3 with some authority about that, the answer shouldn't be given.

4 JUDGE AGIUS: I would have imagined, and in fact I was thinking

5 exactly about the same matter, and I was waiting to see whether Mr. Jones

6 actually would follow up with questions as to what basis she can be so

7 categoric.

8 MR. JONES: Yes.

9 JUDGE AGIUS: So I'm sure you will do that, Mr. Jones. If you

10 don't, obviously then -- yeah.

11 MR. JONES: And I certainly will. And maybe at the same time the

12 types of weapons which were firing and how she knows which weapons were

13 fired from where.

14 JUDGE AGIUS: Yes, exactly.

15 I thank you, Mr. Di Fazio.

16 MR. JONES:

17 Q. So we'll go through one by one. How do you know or why do you say

18 that there was shelling from Pribicevac?

19 A. From Pribicevac when they started shelling for the first time I

20 heard the orders. They said, Go on like that, shoot in the direction of

21 the main street, that's where the Green Berets are. Because it was close

22 enough and we were at the foot of the hill from where they were shelling.

23 So those were the first mortar shells. And my husband told me that they

24 were -- I can't remember what exactly the calibre it was. But afterwards

25 the other shells that were coming in from that area, it was coming from

1 the direction of Sase or Koprivno Brdo. Afterwards we found out that the

2 name of the hill was Koprivno Brdo. It was from the opposite direction.

3 So basically shells were landing in Srebrenica coming from four

4 different sides. Weapons of different sizes basically because their sound

5 was different --

6 JUDGE AGIUS: Mr. Jones, you either control her yourself or I have

7 to control her.

8 MR. JONES: Yes.

9 JUDGE AGIUS: She is running. I mean, she did not stick to the

10 direction that you were trying to lead her to. Let's take them one by

11 one, please --

12 MR. JONES: Yes. We've had the answer --

13 JUDGE AGIUS: And let's start with the first one Pribicevac or

14 whatever --

15 MR. JONES: Yes, Pribicevac. To summarise --

16 JUDGE AGIUS: To summarise, you could see it with your own eyes.

17 Is that correct? You could see the shelling coming from there with your

18 own eyes?

19 THE WITNESS: [Interpretation] Of course.

20 JUDGE AGIUS: Let's move to the next one. And you are in charge

21 of her. And she could perhaps indicate on the map -- I haven't already

22 circled it myself, but she could indicate on the map Pribicevac.

23 MR. JONES:

24 Q. Yes. Ms. Hotic, if you wouldn't mind looking to your right

25 there's a map there on the ELMO.

1 JUDGE AGIUS: It's the map on the ELMO that you have to look at.

2 MR. JONES:

3 Q. Now, if you could first of all, and it's only if you can see it,

4 but if you could see Srebrenica first of all and could point to that.

5 A. Yes.

6 Q. Could you point to Pribicevac.

7 JUDGE AGIUS: Wait a minute, let's point to Srebrenica first.

8 THE WITNESS: [Interpretation] This is where Srebrenica is.

9 JUDGE AGIUS: So for the record the witness indicates with her

10 finger Srebrenica on map D715.

11 THE WITNESS: [Interpretation] That's where the Stari Grad is. And

12 that's where Pribicevac is.

13 JUDGE AGIUS: 13 minutes below Srebrenica she indicates

14 Stari Grad, and at 25 minutes further to the east she indicated

15 Pribicevac --

16 THE WITNESS: [Interpretation] Stari Grad is somewhere around here.

17 MR. JONES:

18 Q. Now, let's deal with Sase. Can you locate Sase on the map,

19 please?

20 MR. DI FAZIO: I don't mind if Mr. Jones leads.

21 THE WITNESS: [Interpretation] I can't read it really but it's

22 somewhere here.

23 MR. JONES:

24 Q. Your finger is right there.

25 JUDGE AGIUS: Your finger is almost on Sase.

1 THE WITNESS: [Interpretation] Yeah, that's where it is.

2 JUDGE AGIUS: For the record, the witness indicates Sase on the

3 map.

4 MR. JONES:

5 Q. Now, how do you know, if you know, that artillery was firing

6 specifically from Sase into Srebrenica?

7 A. Because the shells were landing from -- coming from that

8 direction.

9 Q. And how do you know that?

10 A. On the basis of my sense of orientation I know where that is and

11 we could see the shells were coming from that direction. Obviously since

12 Serbs were holding those positions, that was quite clear, and it was quite

13 clear that they were shelling us from Sase or from other surrounding

14 villages or locations where they could place their weapons.

15 Q. Did you -- did you ever go to Sase yourself in 1992?

16 A. After the -- it was freed.

17 Q. Yes --

18 A. Yes.

19 Q. Just to follow His Honour's suggestion that we control question

20 and answer. If I ask a question, you can give a simple answer and then I

21 may follow up with further questions.

22 So really my question is simply this: In 1992 did you go to Sase?

23 A. Yes.

24 Q. And did you -- when you were there, did you or did you not see any

25 evidence that shells had been fired from there?

1 A. Yes. There were different sized cartridges or shells. There were

2 heaps of cartridges. And I couldn't help wondering how we survived since

3 all that had landed upon us.

4 Q. And when did you go to Sase, roughly?

5 A. At some point in autumn, I can't give you the exact date, when

6 Sase was liberated, when the Serbs withdrew. And there was defence

7 activity and Sase was freed.

8 Q. Now, I may not go into all the other locations you mentioned,

9 Koprivno Brdo, Rogac and Tara. Can I just ask you this: Was this

10 something which was discussed among the people in Srebrenica, including

11 fighters, where artillery was firing from?

12 A. Yes.

13 Q. And was that not a source of information to as to where these

14 missiles were coming from?

15 A. Yes. But it doesn't really matter because I could reach that

16 conclusion myself.

17 Q. And then in terms of different types of missiles and artillery,

18 tanks versus Howitzers or multiple rocket launchers, were you or were you

19 not able during the course of 1992 and 1993 to distinguish the different

20 sounds of what you heard?

21 A. Yes. On the basis of the sound and on the basis of the place

22 where the shells landed. Some shells left big craters. And their tail

23 end or sometimes the mortar could fire 36 shells in one go, and they left

24 a mark of a huge tail. There was the tail of the shell that would remain

25 stuck in the ground.

1 Q. Would you if you heard the sound of a missile flying over, would

2 you be able to say, That's a tank, or that's a Howitzer, or that's a

3 heavy-calibre weapon or a small calibre?

4 A. Yes. They had different sounds. Some had a terrible whistling,

5 tearing, whistling sound. And of course the explosion would reverberate

6 much more than a small mortar shell. And also some Howitzers, as they

7 called them. If a house was hit, it would create holes in the walls. It

8 didn't just go off as an explosion, whereas mortar shells exploded as soon

9 as they touched a surface. So we could make a distinction between

10 different types of weapons.

11 Q. All right. Thank you very much. Are you familiar with Zoljas?

12 A. I do.

13 Q. Did you ever come across their use during the war?

14 A. I came to the place where Zoljas landed. They can cause a great

15 deal of damage. For example, in my building a window was broken on the

16 basis of that, and then they make holes in the buildings.

17 Q. Now, you've described how when you returned to Srebrenica in May

18 1992 it was empty, more or less. Did it remain like that?

19 A. For a long time until the UN came and then the Swedes did some

20 repair work. They repaired some roofs and mended some of the holes and

21 the rest stayed the way it was.

22 Q. There might have been a misunderstanding. What I'm referring to

23 is empty of people. You mentioned how it was -- there were very few

24 people in Srebrenica when you came in May 1992. Did Srebrenica remain

25 sparse of people or did people arrive?

1 A. Yes -- oh, no. Already in May people started coming from

2 Bratunac, mostly people from Bratunac who had been chased away from

3 Bratunac. And they told us that they were betrayed there, that they had

4 reached an agreement and they promised that they would remain loyal to the

5 Serbs. And they even got fuel for agriculture and machinery. And then

6 two days later Serbs started arresting people and other people ran through

7 the woods and came to Srebrenica. And people were coming in on a daily

8 basis.

9 JUDGE AGIUS: Yes, Mr. Di Fazio.

10 MR. DI FAZIO: I'm not objecting, again, if Your Honours please,

11 but I just want to follow the evidence carefully. My understanding is

12 that the witness went into the forests on the 8th of May --

13 JUDGE AGIUS: That's when Goran Zekic was killed.

14 MR. DI FAZIO: And was there for a period of 11 days, I think she

15 said in her evidence, eight plus 11, whatever we come to, I understand

16 that she's now talking about these events at some point eight plus 11 --

17 MR. JONES: We can clarify that --

18 MR. DI FAZIO: I would be grateful.

19 JUDGE AGIUS: Thank you, Mr. Di Fazio, and thank you Mr. Jones.

20 MR. JONES: Thank you.

21 Q. Do you know approximately when Goran Zekic was killed?

22 JUDGE AGIUS: Yes. She said already, she mentioned the precise

23 date, she said 8th of May.

24 MR. JONES: Okay. Let me put it this way.

25 Q. How long after the death of Goran Zekic did you return to Sebesic?

1 A. After Goran Zekic's death we stayed only one more day in the

2 forest. Perhaps there was a translation error. We were in the forest

3 before and then we stayed one more night and then we went home.

4 Q. Right. So that would mean you were in Srebrenica around the 9th

5 or 10th perhaps of May. Is it right that you were in the woods for 11

6 days before that?

7 A. Yes.

8 Q. And then you've told us that refugees arrived from Bratunac in

9 May. Is that something you yourself saw?

10 A. Yes, of course. Because they started settling into my building.

11 There were 16 Serb apartments in my building that were deserted by Serb

12 families when they left so they were standing empty and people were moving

13 into those apartments from the villages around Bratunac.

14 Q. Right. Well, let's deal first of all with Bratunac, the town,

15 because you were referring there to an instance I -- instant where the

16 Muslims were -- I think you said that they were tricked, that they were

17 given petrol -- I'll need to check the transcript. But could you just

18 tell us in summary what actually was the fate of the Muslims from Bratunac

19 town in that period May 1992, what actually happened to them?

20 A. When Serbs started arresting people in Bratunac, the ones that

21 could not escape were taken to the school of Vuk Karadzic and 1.700 people

22 were abused there. And Drago Zekic, Goran's father, actually tortured

23 people and he killed them with wooden sticks and firearms. And when he

24 took care of 300 people he said it was enough as revenge for the death of

25 his son in Srebrenica. And then a number of people were exchanged later,

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1 and my -- and Slobodan Amacic from Bratunac, who was related to my husband

2 was killed there. Many people were tortured and the Hodza of Bratunac was

3 tortured a great deal. He was made to drink beer and to say Serb prayers.

4 And also a police officer --

5 Q. Sorry to cut you off, but it's helpful if you give brief answers

6 and then I'll follow up.

7 Firstly, just a clarification. You said Goran's father, when he

8 took care of 300 people, he said it was enough. What do you mean he took

9 care of 300 people?

10 A. What I meant was that he killed 300 people to avenge the death of

11 his son, and then he felt that it was enough.

12 Q. Yes. And how do you -- what's your source of information for

13 these tales of what happened in Bratunac?

14 A. In the beginning, people talked about those events. But as to

15 this number, 300 people, I found out later from a prisoner who was also

16 tortured there and who was exchanged later at Visoko I believe he was

17 exchanged, his name was Bego. And he told me he was an eye-witness when

18 Saudin was killed and he saw the way in which he was killed.

19 Q. Now, dealing with villages in Bratunac municipality as opposed to

20 the town itself, can you name some of the villages where Muslims came

21 from?

22 A. Yes. Zaluzje, Voljavica, Bjelovac, Sikiric, I don't know, maybe

23 Brezovica. And there were a couple of hamlets there from the area along

24 the river Drina. People were flocking to Srebrenica, not all in one go,

25 but gradually.

1 Q. And so you referred to Bjelovac. Is it right, then, that Bjelovac

2 had Muslims there?

3 A. Mixed population lived in Bjelovac.

4 Q. Right. So if someone were to say that there were no Muslims in

5 Bjelovac before the war, that would be false then, would it?

6 A. Of course it would be false.

7 MR. JONES: I wonder if now might be an appropriate moment for a

8 break.

9 JUDGE AGIUS: You've got two minutes left, but of course it's up

10 to you whether you would like to stop here or take another couple of

11 minutes.

12 MR. JONES: In fact, I can ask one or two more questions and then

13 it's a more suitable place.

14 JUDGE AGIUS: Even if we go beyond 10.30 for a couple of minutes,

15 that's not a problem.

16 MR. JONES: Right.

17 Q. Did you receive any information or do you have any idea of roughly

18 how many Muslims were killed in Bratunac municipality in May of 1992?

19 A. I don't know the exact number, but very many people -- I mean, not

20 everything was on record. Quite a few women and children got killed as

21 well. A lorry was noticed that was driven to Serbia and a cousin of mine

22 said that children were being taken by lorries to Serbia. Children were

23 picked up somewhere in the course of those activities, and the exact

24 figure is actually not known but quite a few.

25 Q. When you say "quite a few" or "very many," are we talking about

1 10? 50? 100? 200? 1.000? What roughly are we talking about?

2 A. Several thousand.

3 Q. And when these people came to Srebrenica, these people from

4 Bratunac municipality, did they tell stories of what had happened to them?

5 A. Of course they did. They told us how they were tricked, how they

6 had reached agreement with them, that there wouldn't be a war, that they

7 would stay loyal to Serbs whatever happened, and then they were tricked.

8 And they did not get organised, defend themselves, so they ended up as

9 victims of crimes.

10 Q. And did these --

11 JUDGE AGIUS: One moment because there's a mistake in the

12 transcript. So it will be line 15 on this page 37, that they would stay

13 loyal to Serbs not whatever happened, nothing would happen and they were

14 tricked -- at least the interpretation that I received was not whatever

15 happened but nothing would happen. This was the essence of the trickery,

16 in other words.

17 MR. JONES: Yes.

18 JUDGE AGIUS: That's how I understood it.

19 MR. JONES: That's how I understand it.

20 JUDGE AGIUS: Correct me if I'm wrong, the witness is receiving

21 interpretation. If that is not what she said, please do correct me.

22 Otherwise, we go ahead.

23 THE WITNESS: [Interpretation] If I may, perhaps I'm not going to

24 use exactly the same form of words that I used before, but the meaning is

25 the same, they agreed together, how shall I put it, to cooperate not to go

1 to war against one another. That's the essence.

2 JUDGE AGIUS: Okay.

3 Judge Eser.

4 JUDGE ESER: Just for a matter of clarification. You have been

5 asked how many people have been killed, and you told us quite a few women

6 and children got killed as well as and a lorry was noticed that was driven

7 to Serbia, and a cousin of mine said that children were being taken by

8 lorries to Serbia. And then you were asked whether you could give a

9 figure, 10, 50 --

10 THE WITNESS: [Interpretation] A cousin of mine, yeah.

11 JUDGE ESER: Several thousand. Now, do you mean, several thousand

12 people killed or several thousand people taken some there and, if so --

13 THE WITNESS: [Interpretation] I do apologise. When I mentioned

14 that lorry, I don't know how many children you can fit into a lorry, but

15 what I meant was that in Bratunac many people were killed or went missing

16 in the thousands, but we don't have the exact figures. It is very

17 difficult to put an exact figure to it. But a cousin of mine who fled to

18 Serbia saw a lorry that was driving in the direction of Valjevo, and there

19 was a whole lorry load of children. And she was wondering why the Serbs

20 would be -- would be loading children on to a truck.

21 JUDGE AGIUS: Stop.

22 Please answer the question that was put to you. When you

23 said "several thousands," were you referring to -- did you mean to say

24 several thousands of people were killed or not?

25 THE WITNESS: [Interpretation] Of course if they're not alive

1 today. They're missing persons, but none of them had come back so far.

2 So it means they must have been killed.

3 JUDGE AGIUS: Yes, Mr. Jones.

4 MR. JONES: Yes, I did have one final question to clarify.

5 JUDGE AGIUS: Yes, go ahead, finish it. And I'm sure that the

6 interpreters will agree to go on for just a couple of minutes more and

7 then we'll have the break.

8 MR. JONES:

9 Q. In discussing the trickeries, as you've described it, of the Serbs

10 towards the Muslims in Bratunac, you referred to the Muslims being given

11 petrol. What precisely were you referring to there? What trickery, if

12 any, was involved there?

13 A. In the area of Bratunac there is a great deal of agricultural land

14 and it had to be planted. And since people could not get their hands on

15 any fuel for their tractors and agricultural machinery, the Serbs gave

16 them that fuel, and they were promised that they could work their land

17 freely and that nothing would happen to them, that nobody would come to

18 any harm.

19 Q. So they worked their land and then they were expelled or

20 disappeared. Is that what you're saying?

21 A. Yes.

22 JUDGE AGIUS: Thank you. We will have a 25-minute break starting

23 from now, which means we will start again at 11.00.

24 --- Recess taken at 10.34 a.m.

25 --- On resuming at 11.05 a.m.

1 JUDGE AGIUS: Yes, I recognise Mr. Wubben.

2 MR. WUBBEN: Your Honour, just at the start of the break the

3 interpreter, B/C/S interpreter, contacted me. Prior to that she already

4 contacted Madam Vidovic with a view to that correction done, and I

5 quote "whatever happened," that part of the sentence. And she confirmed

6 to me that it really been said as such by the witness. So "whatever

7 happened" was the right quotation in the transcript. Because of that

8 awareness, she notified me as well as the Defence counsel.

9 MR. JONES: I don't think much turns on it.

10 JUDGE AGIUS: Okay. Let's move.

11 MR. JONES:

12 Q. Just one matter, actually, firstly Ms. Hotic, my apologies if I

13 sometimes seem to interrupt you or cut you off; it's simply because it's

14 easiest for us to follow if we have a short question and a short answer,

15 so I trust you'll understand the reasons.

16 Now, before the break you referred to the agricultural land in

17 Bratunac. Can you just tell us roughly where in Bratunac are you talking

18 about. Is it towards the Drina or towards Konjevic Polje? What part of

19 Bratunac municipality?

20 A. It's in the general direction of the Drina River.

21 Q. Now, I'm moving now from the spring of 1992 to the summer of 1992,

22 and again it's not in dispute that there were terrible conditions, lack of

23 food, shelling, et cetera, in this period. So I simply want to ask you

24 this: Did you ever go out of Srebrenica in order to obtain food?

25 A. Yes. After two months in Srebrenica all the food had run out. We

1 ran out of everything. The people who came from Bratunac, especially from

2 the Zaluzje and Voljavica villages, said that they had lots of grain in

3 storage, that they had food in their houses, and that they managed to

4 sneak out during the night to see whether the Serbs were going around the

5 houses at night and whether it was possible to go and get this food. When

6 they made sure that during the night the Serbs mostly moved along one

7 street down the asphalt street, and that they are not actually going into

8 the houses, they decided to go and collect the food so that other people,

9 too, who were not from Bratunac, because all of us together had spent all

10 of our joint supplies, we went to Voljavica at night to collect the food.

11 I was alone.

12 Q. Okay. Now, you mention an asphalt road. Can you help us with

13 what road precisely that is. Where does it go between, that asphalt road?

14 A. It's the road from Bratunici to Skelani. It goes along the Drina

15 River, and that's the only asphalt road, the main road.

16 Q. And you said -- let me just get this accurately. The Serbs mostly

17 moved along one street, down the asphalt street. When you say "the

18 Serbs," what exactly are you referring to? Are you referring to Serb

19 civilians, Serb military, paramilitaries, what precisely do you mean when

20 you refer to the Serbs in that context?

21 A. It's general knowledge that all the Serbs were mobilised into the

22 army. I don't know if they were called part of the military or a

23 paramilitary groups. It's not important to me. They were all soldiers.

24 They had weapons, they fired, they walked around.

25 Q. When you say they moved although this road, the Bratunac-Skelani

1 road, were they moving on foot or in vehicles?

2 A. They moved in vehicles and they would fire into the air as they

3 passed.

4 Q. And what period does this relate to?

5 A. It was autumn because the corn was ripe. Again, I don't remember

6 the dates. We had taken the corn and the food from the houses and the

7 storage rooms, and then when we ran out of that then we would pick the

8 corn from the fields and along the road until we had picked everything.

9 Q. Now, I want to just digress on one issue. You told us that your

10 son was in a fighting unit. I think you said that at one point he joined

11 Hakija's unit. Is that right?

12 A. Yes.

13 Q. Now, did he encourage you to go out on expeditions to find food?

14 A. No. I did that on my own. I wouldn't listen to my son or my

15 husband because they didn't want me to do that. They said it was

16 dangerous, and I myself knew that it was dangerous. But I thought that it

17 would be even worse to die of hunger.

18 Q. And when we speak about men who were in fighting units, at this

19 time, and by "this time" I mean the latter half of 1992, was it possible

20 just by looking at how a man was dressed, whether he was in civilian

21 clothes or in a bit of uniform, was it possible to tell whether or not he

22 was actually in a fighting unit?

23 A. If you're thinking of Bosniaks, Muslims, there was no difference

24 actually because people just wore whatever they had.

25 Q. Did your son have any uniform or part of a uniform?

1 A. No, he didn't have a uniform at all. He wore jeans, a jacket,

2 trainers.

3 Q. Now, you've told us that it wasn't -- you said it wasn't safe to

4 go on these expeditions. Why not?

5 A. After two or three such expeditions, they noticed that we left

6 traces behind. We left traces behind. They could see our footsteps when

7 we picked the corn. Then the road near Vejzovac, I heard that they set

8 mines there so that people who went that way would set off those mines.

9 And there were casualties. They also had a stronghold at Tara where they

10 would fire bursts of fire. They also fired tracer bullets to light the

11 area. That area was also mined. Three women were injured there. And

12 very often they would also place the mines in the cornfields and the

13 places where we would pass. So there would often be deaths and injuries

14 as a result of that, and there were also prisoners.

15 Q. Thank you. Now, you've mentioned Vejzovac. How far is that from

16 Bjelovac, if you know. You can tell how long it would take in kilometres

17 or how long to walk?

18 A. I couldn't really say. You go into Voljavica directly through

19 Vezovici. It's not far from Voljavica, perhaps a couple of kilometres,

20 but I really can't say exactly.

21 JUDGE AGIUS: Shall we --

22 MR. JONES: Yes, we can see that --

23 JUDGE AGIUS: It shows on the map quite clearly, and to cut it

24 short I think that I will try to indicate to the witness if I have the

25 assistance of the technicians. We move towards the river, please, the

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1 Drina River. Yes. You have to go further up, further up, yes, and more

2 or less focus on the centre of the page of the map as we see it now. To

3 the left a little bit, please, yes. That's it.

4 Now, Madam, you see at the right next to the river there is the

5 village or the town of Bjelovac. If you look to the west more or less in

6 the same latitude you see Neskovici and further west to the left,

7 Vejzovac.

8 THE WITNESS: [Interpretation] Vejzovac, yes.

9 JUDGE AGIUS: These are the two villages that you referred to

10 earlier on. Is that correct?

11 THE WITNESS: [Interpretation] Yes.

12 JUDGE AGIUS: Are you happy with that, Mr. Jones?

13 MR. JONES: Yes, thank you, Your Honour.

14 Q. How many times did you go on expeditions to this area, the

15 Voljavica, area to get food?

16 A. I went seven times with just civilians, regular people, to the

17 Voljavica area.

18 Q. Can you just describe for us -- just give us the names of the

19 places you would go through from Srebrenica to get to Voljavica?

20 A. Through the village of Likari. When you leave Srebrenica and then

21 go up the hill, then the first would be the village of Likari. Sometimes

22 we would take the road, the forest road, just below Tablja, and sometimes

23 we would go through Vejzovac. Sometimes we had to go along the river in

24 order to avoid the mined areas. This was after we had already been a

25 number of times and after people tripped on mines.

1 Q. Are you familiar with the place called Andrici?

2 A. Yes.

3 Q. Was that in -- was that Serb controlled or Muslim controlled in

4 late 1992?

5 A. Of course, they had a bunker at Andrici because there would be

6 shooting from Andrici. They would fire into the air at night.

7 Q. Now, how long roughly would it take you to get to Voljavica on

8 foot --

9 JUDGE AGIUS: We --

10 MR. JONES: I'm afraid Andrici isn't actually on that map.

11 JUDGE AGIUS: I can't see it on this map. Anyway, we have it on

12 other maps.

13 MR. JONES: Yes. I think with one of the witnesses I attempted to

14 locate it. Perhaps I can, if I'm permitted to lead on --

15 JUDGE ESER: May I just ask. The village of Likari and this is

16 the village of Obadi which you took?

17 THE WITNESS: [Interpretation] Yes, Obadi is close.

18 JUDGE AGIUS: Likari you can see. It's to the right of the red --

19 to the road marked in red.

20 MR. JONES:

21 Q. And is Obadi -- is Andrici near or far from Obadi?

22 I'm not sure if you heard the question, Ms. Hotic. Is Andrici

23 near to Obadi or is it far from there?

24 A. I couldn't really say. I didn't really notice where the villages

25 were. It's all close to Sase, it's that area, Andrici, Obadi, it's all

1 the same area. But I -- before the war I didn't really know that area. I

2 never used to go to those villages. I just simply went with the other

3 people, and whatever they said I would do the same.

4 Q. And Caus, the hill Caus which we see there, when you went on these

5 expeditions, was Caus in Serb hands or Muslim hands?

6 A. It was mostly in Serb hands. Before or sometimes it was in our

7 hands, but at the time it was in -- the Serbs were in control.

8 Q. Right. And if you tell us roughly how long would it take you to

9 get on foot from Srebrenica to Voljavica?

10 A. As you go in the direction of Voljavica, it's about three or four

11 hours, maybe three hours because we would be walking through the woods.

12 On the way back, in the morning, only would you reach the outskirts of

13 Srebrenica. You would be walking slowly, carrying things. So a lot of

14 time was needed, but I never actually measured the time in hours.

15 Q. And was there any way to get to Voljavica, apart from on foot, and

16 were people -- Muslims in Srebrenica able to drive by car to that area at

17 this time?

18 A. Yes, in peacetime, yes, it's possible. But in wartime, no, no.

19 Q. All right. Now, do you know a place called Fakovici?

20 A. Yes.

21 Q. I don't think there's any dispute that's -- would you agree that's

22 on the road -- the Bratunac-Skelani road?

23 A. Yes.

24 Q. Did you ever go there in 1992?

25 A. Once.

1 Q. And when you went there, were you there alone or were you there

2 during the course of an action?

3 A. It was an action. We were looking for food, people had run out of

4 food, so that we simply had to go and follow our fighters, even though

5 they were telling us not to go. They kept telling us to return, but we

6 simply had to go. We had to go and get food. So I did go to Fakovici,

7 yes.

8 Q. You say the fighters were telling you not to go. If they didn't

9 want you to go, why didn't they stop you and the other civilians from

10 going?

11 MR. DI FAZIO: Well, if Your Honours please, that's really a

12 matter for the fighters, isn't it? I mean, they can answer. Unless of

13 course --

14 JUDGE AGIUS: She knows.

15 MR. DI FAZIO: -- it was expressed to her, was she ever informed

16 of such matter. But the way the question is framed, I have no objection

17 to the topic of course, but the way the question is framed does invite

18 speculation and that's what I'm concerned about.

19 JUDGE AGIUS: Well, obviously if she speculates, we'll stop her.

20 And especially now that you have made your remarks she knows that she

21 shouldn't to speculate.

22 MR. DI FAZIO: Thank you.

23 MR. JONES: Maybe I can rephrase the question.

24 JUDGE AGIUS: I don't think you even need to, actually.

25 MR. JONES: Maybe I can put it this way --

1 JUDGE AGIUS: Go ahead.

2 MR. JONES:

3 Q. Let me put it this way: Were the fighters able to stop you from

4 going to Fakovici?

5 A. Well, you can imagine a mass of people, thousands of people, who

6 are hungry and stopping every fighter asking, What are we going to do, die

7 of hunger? What are they going to do, kill us all. They simply went

8 their own way and we did what we knew, the best thing -- we did the best

9 thing we could.

10 Q. Now, also to fix the date when you went to Fakovici, again I think

11 there's no dispute there was an action in Fakovici on the 5th of October,

12 1992. Could that have been the date when you were there?

13 A. Probably, yes. As I said, I don't remember the dates, but the

14 plums were ripe, the corn was ready for harvest because the vegetables and

15 fruit ripened later in that area. But, yeah, I think that was around the

16 time when we went to Fakovici.

17 Q. And what made you decide to go to Fakovici on that day?

18 A. To go and bring back food, because of food.

19 Q. Why specifically Fakovici? How did you know to go there?

20 A. Because our fighters had decided to carry out an operation there,

21 and we knew that there was food there because all the Serb settlements had

22 food. And there was no other way to get to a place like that, so we took

23 that opportunity. It was simply the only way to get to the food.

24 Q. I think we had -- might have the issue again of the witness

25 saying "aksija" and it interpreted as "operation." We've had this issue

1 in the past and we say it should be translated as "action" not as

2 "operation."

3 JUDGE AGIUS: I agree with you, and the interpreters please note

4 that whenever the word, Serbo-Croat word "aksija" is used, we would all

5 like to see it translated into "actions" rather than "operations" in the

6 transcript.

7 MR. JONES: Thank you, Your Honour.

8 Q. Now, just maybe a preliminary question. When you went on

9 expeditions to get food, did you go alone or did you go with any

10 particular people?

11 A. With many people. I wouldn't know how to get there. I wouldn't

12 know the way, had it not been for a lot of other people. There were a lot

13 of women.

14 Q. Did you go with any friends, people you actually knew, on these

15 expeditions?

16 A. Yes. One of my neighbours was there, her name was Ismeta. I

17 would always go with her.

18 Q. Now, do you know, and if you're able to help us with this, how

19 word got out or at least how you found out there was going to be an action

20 in Fakovici?

21 A. I don't know exactly how the word got out, but we knew about each

22 action. It would spread very quickly amongst the people. Probably every

23 family had a fighter amongst them. Somebody would find out and that's how

24 it would spread. It was not made public, but it was something that was

25 known. People found out about it.

1 Q. Was there a name given to you and other civilians who went into

2 actions to get food?

3 A. I don't understand the question. What name?

4 Q. Was there a collect --

5 A. Whose name?

6 Q. Was there a collective name given to --

7 JUDGE AGIUS: Do you object, Mr. Di Fazio, if we go direct on

8 this -- yes, Mr. --

9 MR. JONES:

10 Q. Were you ever referred to as a Torbar, Muslims going into action

11 as Torbari?

12 A. Yes. They would call us Torbari or Hapci.

13 Q. Now, for you Torbari -- let's deal with Fakovici specifically.

14 When you went into Fakovici, were you trying to follow the fighters or

15 were you trying to avoid them or were you simply ignoring each other? How

16 did that work?

17 A. The fighters didn't look that much different from us, even

18 fighters who had a rifle and civilians who carried a rifle. Somebody

19 would go to a village and find themselves a rifle even though they were a

20 civilian and they would keep the rifle. But I didn't really notice any

21 differences between the fighters and us, the Torbari, except for the

22 women. I knew that they were definitely not fighters.

23 Q. Now, could you describe for us in Fakovici where you went and what

24 you did on that day?

25 A. Mostly over the hills, through the woods using village paths. I

1 couldn't really describe the exact road we took. Close to Fakovici -- in

2 front of me was the Drina. Some of the houses -- I could see the roofs of

3 houses of part of Fakovici. But I couldn't enter into some of the houses

4 because of the shooting.

5 Q. Okay. Now, let's deal with the shooting then. What precisely --

6 what sort of shooting was it? And if you can tell us, where was it coming

7 from?

8 A. One way which led to Fakovici -- well, many people had already

9 entered Fakovici and I probably tried a little bit later or maybe I wasn't

10 brave enough to be amongst the first people to enter it. And on the

11 left-hand side, in the direction of Drina and Bjelovac, there were --

12 there was a lot of shooting there, and therefore I could not go down that

13 road. And my group, the people I was with, we just couldn't go through

14 because there was constant shooting. And so the hill that we came from

15 was being shelled. There were shells coming from Drina, I think. So that

16 I didn't manage then to Fakovici as such, and there was a house at the

17 outskirts, and I was picking grapes and plums, and I got myself some corn

18 in a field near the house.

19 Q. Okay. Now, you mentioned that you think the shelling were coming

20 from the Drina. Now, obviously that's the river between Bosnia and

21 Serbia. Was the shelling, in your view, coming from the Bosnian side of

22 the Drina or from the Serbian side?

23 A. It couldn't have come from Fakovici because people had already

24 entered the town. It could have been from across the river because we

25 were being constantly shelled from Nemici [phoen] and I don't know what

1 the place is. But there are eye-witnesses to that and there were shells

2 and bullets coming from there.

3 Q. So who was sending the shells then, the Muslims or the Serbs?

4 A. I can state with absolute certainty that Muslims had no mortars,

5 so even if they had held any such positions they wouldn't have been able

6 to shell anyone because they had no mortars. So only the Serbs could have

7 done that.

8 Q. And you mentioned that you weren't able to enter Fakovici because

9 of the shells. Could you see where the shells were actually landing?

10 A. The shells were landing above my head in the hills, but before the

11 sounds of bullets being fired at the same time I was prevented from going

12 down the road that I was intending to take because I would have been fired

13 at.

14 Q. Can you just firstly tell us what time this was roughly in the day

15 that you were in the -- that you were in the outskirts of Fakovici?

16 A. Before noon.

17 Q. And is it right then that at that time there were shells which you

18 saw or heard falling in the area?

19 A. Yes. And that accompanied me the entire time that I needed to go

20 back.

21 Q. Right. Now, did you see houses in Fakovici?

22 A. Parts of houses, parts of roofs and so on.

23 Q. Did you see any houses in Fakovici at that time which were in

24 flames?

25 A. I did not see any flames. I could see some smoke, but when

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1 there's shelling there's always smoke, so it was normal. We could see

2 smoke.

3 Q. Are you -- at that time were you familiar with what it looks like

4 when a house is set on fire as opposed to when it's damaged by shelling?

5 A. Yes.

6 Q. In terms of what you saw in Fakovici, in your opinion what was --

7 which case was it? Was it a house which had been set on fire or which had

8 been damaged by shelling?

9 MR. DI FAZIO: Well, if Your Honours please, I object to the

10 question. Firstly, the witness was asked whether -- if she's familiar

11 with what it looks like when a house --

12 JUDGE AGIUS: She said she saw smoke and not fire.

13 MR. DI FAZIO: Yes. And she was asked if she's familiar with what

14 it looks like when a house is set on fire as opposed to when it's damaged

15 by shelling. And she --

16 JUDGE AGIUS: I --

17 MR. DI FAZIO: She's already said that she didn't see fire.

18 JUDGE AGIUS: I think we are running too fast, Mr. Jones,

19 actually. I think you need to take it stage by stage. There is a point

20 so far we haven't arrived at the stage where she has gone down into the

21 town itself. So --

22 MR. JONES: Yes, and my point obviously was she's -- there's a

23 distinction which she's familiar with --

24 JUDGE AGIUS: Yes. But then you can approach that once you have

25 asked her whether she actually went down to the town herself and what she

1 saw and whether she could distinguish one from the other, if that's the

2 case.

3 MR. JONES: Yes.

4 JUDGE AGIUS: Because she hasn't said it as yet. So let's take

5 it -- I leave it to you, of course, but let's take it stage by stage.

6 MR. JONES:

7 Q. Firstly, did you yourself get into the centre of Fakovici?

8 A. No, I did not.

9 Q. And why not?

10 A. Because of bullets that had prevented me from taking that road.

11 At the spot where I could enter Fakovici, I was prevented from doing so

12 because lots of bullets were being fired at that time. So I simply picked

13 in -- some corn in a field which was next to a house that was at the

14 outskirts of Fakovici and then I went back.

15 Q. And do you know who was shooting?

16 A. I don't understand the question. What do you mean? Who was doing

17 the shelling? Is that your question?

18 JUDGE AGIUS: It's not the shelling now. The shelling you have

19 told us already. It's the bullets.

20 MR. JONES: The bullets being fired.

21 JUDGE AGIUS: -- the bullets that you were --

22 THE WITNESS: [Interpretation] You know, our fighters would not

23 have fired in that direction, so it means it must have been the Serbs.

24 MR. JONES:

25 Q. And from -- from where were they -- were they shooting? Was this

1 from houses, or from across the Drina, or from fields, if you were able to

2 estimate?

3 A. I couldn't see that.

4 Q. Now, I put to you earlier a distinction between -- which you

5 stated that you could distinguish between a house which had been set on

6 fire and one which had been hit by shells. Let's deal with them one at a

7 time. How would you describe the appearance of a house which has been hit

8 by shells? And actually firstly before that, did you see houses damaged

9 by shells before in 1992?

10 A. Yes.

11 Q. Right. And can you describe --

12 JUDGE AGIUS: In Fakovici. Let's make it clear.

13 MR. JONES: Well, I first wanted it to just be clear that the

14 witness had actually seen a house damaged by shells anywhere so that she

15 was familiar with the sight.

16 JUDGE AGIUS: Okay.

17 MR. JONES: And then I want to ask her to describe --

18 JUDGE AGIUS: All right.

19 Q. If you could, Ms. Hotic, what is the appearance of a house when

20 it's been damaged by shells?

21 A. A house damaged by shells has holes in it, holes in the walls, and

22 sometimes the roof may cave in. It depends on the size of the shell, and

23 I saw both. I could have seen that in Srebrenica.

24 Q. And would there be any smoke or dust associated with a house being

25 shelled?

1 A. Of course. Every shell, depending on the size, but at any rate it

2 always creates a lot of smoke. I was suffocating by smoke myself but I

3 hadn't been hit by the shell but there was a lot of dust and smoke.

4 Q. Right. I'll come to Fakovici specifically but I'm still on this

5 distinction. Now, you told us how when you were in -- the words "outside

6 Srebrenica" that the Serbs torched houses. Could you describe for us what

7 is, if any, distinctive appearance of a house that has been set on fire?

8 A. Apart from a spiral of smoke there is red flames and a different

9 kind of sound from the shooting. There is a great deal of noise, and you

10 see red flames shooting up into the sky.

11 Q. And when you say "great deal of noise," what noise is that?

12 A. A kind of breaking noise. I can't explain it, but it's very

13 noisy, but it's not the same sort of sound as firearms being fired.

14 Q. Let's go back to Fakovici now. Firstly, did you see houses which

15 were intact which had no damage to them?

16 A. I saw the roofs of the buildings.

17 Q. And can you estimate how many houses you saw where the roofs, they

18 had their roofs, and they appeared to be intact?

19 A. Several. I saw several houses. I could see several houses from

20 where I was, perhaps three to four.

21 Q. Now, did you see any houses which, according to the description

22 you gave earlier of houses which had been shelled, did you see many houses

23 of that description?

24 A. I was not close enough to those houses in Fakovici in order to be

25 able to see properly. I did see that in other places.

1 Q. Did you in Fakovici see any signs of houses which had been set on

2 fire?

3 A. No.

4 Q. When did you leave Fakovici that day?

5 A. In the afternoon hours.

6 Q. How many hours did you -- did you spend there would you estimate?

7 A. I don't know. From the morning until the afternoon, perhaps four

8 to five hours.

9 Q. And when you left, was the action still ongoing? Was there still

10 combat action ongoing or was it over at that stage?

11 A. Shooting could be heard but not a lot of it. It was just that the

12 shells were still coming and they accompanied us all the way uphill as we

13 were heading back in the direction of Srebrenica.

14 Q. So shells were still being fired in that area when you left for

15 Srebrenica in the afternoon?

16 A. Yes.

17 Q. And do you know if any Muslims were wounded or killed during the

18 Fakovici action?

19 A. I could see very many wounded and some dead bodies as well that

20 were being carried. I mean, one body was being transported on horseback.

21 And there were civilians and women having been wounded, women who entered

22 the village of Fakovici. There were very many wounded.

23 Q. And were these people wounded by shells or shooting or a

24 combination of the two?

25 A. Both.

1 Q. Now, if someone -- if someone were to say, I'll put it to you

2 directly, that the entire village of Fakovici was burnt to the ground the

3 5th of October, 1992, from what you were able to see on that day would

4 that be a true or false statement?

5 JUDGE AGIUS: Why are you using true or false --

6 THE WITNESS: [Interpretation] What I could see --

7 JUDGE AGIUS: One moment before you answer. Because if she wasn't

8 there until the very end of the action she can only answer as to whether

9 that would be an accurate, not necessarily true or false, whether it's an

10 accurate or inaccurate.

11 MR. JONES: Yes. Although as far as the action is concerned, and

12 perhaps I need to revisit it, I understood her answer to be that the

13 action -- the actual fighting of Fakovici was more or less over when she

14 left, but there was still shelling --

15 JUDGE AGIUS: You're free to explore that, of course, but it seems

16 until this point at least since something was happening there --

17 MR. JONES: Yes. I'll --

18 JUDGE AGIUS: I would rather you use the terms "accurate"

19 or "inaccurate" rather than "true" or "false." Because the connotation is

20 there.

21 MR. JONES: Certainly. I'll revisit it with certainly two

22 questions.

23 Q. When you left Fakovici, were there still Muslims in Fakovici

24 fighting or gathering food, or were you all leaving at that point?

25 A. I left, but people were still coming out and heading back. It

1 took a while, I don't know how long exactly.

2 As to buildings having been set on fire, I can't claim that.

3 There are still people there. I don't know.

4 Q. So let me put it this way: When you left Fakovici on the

5 afternoon of the 5th of October, 1992, would it be accurate or inaccurate

6 to say that the entire village had been burnt down?

7 A. I can't claim anything either way. But I suppose not because

8 people were mostly concerned about getting food.

9 Q. Did you see when you left houses in Fakovici which were intact?

10 A. I said I did not enter Fakovici myself. On the basis of the roofs

11 I could see, the houses had not been damaged because since there were

12 roofs that I could see, those roofs had not been damaged.

13 Q. Okay. Thank you. Is -- did you manage to capture any food in

14 Fakovici?

15 A. I said that I went to a field and I picked some corn, and I did

16 not even have time to properly clean it. I just took lots of it as it

17 was.

18 Q. And did you hear whether any weapons or ammunition were captured

19 from the Serbs during this action?

20 A. Afterwards I heard that some captures had taken place, and that

21 was normal.

22 Q. And did anything happen in Srebrenica after the action in

23 Fakovici?

24 A. Yes. There was lots of shelling at all times from all sides at

25 Srebrenica.

1 Q. And did that occur after actions regularly or was this a one-off?

2 A. Yes, of course. After each action.

3 Q. Now, after this action in Fakovici, was there enough food for

4 everyone in Srebrenica to survive on through the winter?

5 A. No. It was just enough for a couple of days or maybe more, ten to

6 15 days depending on how much you managed to get.

7 MR. JONES: I'd like to ask if the witness could be shown D545,

8 please. And this is a document from the -- which purports to be from the

9 subregion War Presidency, dated 20th November, 1992.

10 Q. And it's right, isn't it, Ms. Hotic, that I saw this document with

11 you here in The Hague, so you've seen it once already?

12 A. Yes.

13 Q. Now, I'd just like to ask you to comment on this appeal, as it's

14 titled, and to say whether it reflects the situation in Srebrenica in 1992

15 as you recall it or not.

16 A. If I may, I'd just like to read it through once again to jog my

17 memory.

18 Q. Yes.

19 A. We can continue now -- yeah, you can ask the question now.

20 Q. Well, can you describe for us -- well, firstly are these events

21 reported from November 1992 familiar to you? Is this how it was?

22 A. Yes.

23 Q. And if you could just help us with "generally the situation in

24 November 1992," were there any instants or anything specific in November

25 1992 which you recall relating to the conditions of life?

1 A. There was general hunger. All food had been eaten, and the

2 reserves had been exhausted. And people started to eat anything that they

3 could get their hands on, the husks of the corn or apple peels that used

4 to have been left for the animals, and it was very difficult to digest

5 that. And other -- sometimes elderly people would be taken for hospital,

6 and I myself once ate that stuff and I was ill for a month. And the most

7 difficult situation was for babies. You couldn't even have a spoonful of

8 flour, and you just could not give that roughly ground stuff, basically

9 bran, to little children. So the hunger was terrifying. So we didn't

10 know what to do.

11 Q. May I stop you there, Ms. Hotic, for a moment because I want to

12 follow up on a response that you gave there. You referred to people

13 eating husks of corn or apple peels and that elderly people would be taken

14 to hospital. Did anyone actually ever die from eating indigestible

15 materials, or was it just a case of being taken to hospital and then

16 recovering?

17 A. I know that one man died in hospital. His digestive system just

18 couldn't take it and the doctors could not help him. Even, to be honest,

19 the doctors had nothing -- I mean, it was too late to help this man. I

20 know of cases of death due to this.

21 Q. And did you know -- and again in this time, November/December

22 1992, of people actually dying from hunger?

23 A. Of course. One woman who had two children, she lived in a flat

24 and she didn't go out for a few days, and basically after some time people

25 went in and all three of them had died of hunger. Everybody had become

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1 emaciated. It was a disaster. You could not tell the difference between

2 young and old men, so to say. Everybody looked old. It was an extremely

3 difficult time.

4 Q. Maybe an obvious point, but just to follow up on that. If at this

5 time, November/December 1992, you saw someone who looked emaciated, tired,

6 exhausted even, was that something out of the usual?

7 A. No, everybody looked like that. Nobody looked normal. Both of my

8 men, I mean my husband and my son, were just skin and bones. And my

9 husband showed me how he just -- he rolled up his T-shirt and he showed me

10 his stomach, and there was -- everything was empty. I could count his

11 ribs. And I said, Oh, please, don't let me look at it, it's horrible.

12 They all looked horrible.

13 Q. Thank you.

14 MR. JONES: I'd also like to pass up another exhibit now -- it's

15 not an actually an exhibit yet. It's a document of the command of the

16 Birac Brigade in Milici. I have copies for everyone. There is an ERN

17 which is 04337088.

18 Q. And I'd like to ask you to look at this document because it's

19 dated firstly -- or it refers to events on the 9th of November, 1992. It

20 says: "On November 9, 1992, two Ustashas were killed in the area of

21 Gunjak."

22 Pausing there, when Serbs in that period used the word "Ustasha,"

23 do you know what they were referring to?

24 A. They called Muslims Ustashas. Sometimes they called us balijas

25 and sometimes Ustashas. Those were their names for us.

1 Q. And this refers to an ambush being organised to stop groups of

2 Ustasha, as they were called. From getting food. Let me just ask you

3 this: In November 1992, were you aware of that going on in the Srebrenica

4 area, people going for food and being ambushed?

5 A. Of course. Many people went looking for food in different

6 places. I myself went on such expeditions 19 times altogether, sometimes

7 following actions, following our fighters, and sometimes not on my own but

8 in groups with out women. We were sneaking through the Serb-controlled

9 territory in order to find food. And many women and many persons had

10 actually been taken prisoner and they never came back.

11 For example, in Bratunac whoever was arrested was never ever

12 returned alive by Deronjic. And we don't even know about what happened to

13 some people. They just went missing. Quite a few of those women were

14 probably taken prisoner or killed but they never came back alive.

15 MR. JONES: Could I ask for an exhibit number firstly for this

16 document, please.

17 JUDGE AGIUS: Yes. This document is being tendered and received

18 and marked as Defence Exhibit D716.

19 MR. JONES: Thank you, Your Honour.

20 Q. And just for clarification, you referred to Deronjic. Who are you

21 referring to there? What name and what position, if any?

22 A. Miroslav Deronjic was in Bratunac from the very start of the

23 setting up of the SDS party. He was in the Crisis Staff, and he was in

24 Bratunac throughout that period. He had an important position in

25 Bratunac.

1 Q. Okay. Now, you've mentioned Bjelovac already in your testimony.

2 Did you ever go to Bjelovac during an action?

3 A. Yes.

4 Q. And are you able to locate that roughly in time either by the

5 month or when it occurred in relation to the Fakovici action?

6 A. I can't tell exactly what the period was between Fakovici and

7 that, but this was late in the autumn. It was already winter. It was

8 freezing. I think it must have been in December if I'm not mistaken, but

9 I told you that I could not recall the exact date. When there was an

10 action at Bjelovac, I wasn't there on that date, but I was at Loznicka

11 Rijeka, which is in the direction of Bjelovac.

12 Q. So firstly, you were in Bjelovac when there was -- well, not in

13 Bjelovac specifically the town, but you were in that area when there was

14 an action going on. Is that correct?

15 A. Yes.

16 Q. And you've mentioned a couple of days, so I would like to deal

17 with it day by day.

18 Firstly, again, did your son know that you were going to go to

19 Bjelovac?

20 A. Yes, he did, but he couldn't stop me.

21 Q. But he was -- I take it he was opposed to you going?

22 A. He was always opposed to me going. I told him, You do your job

23 and I will do mine; don't interfere.

24 Q. And you told me on the first day you went to Loznicka Rijeka, and

25 we might just locate that on the map. Again, Ms. Hotic, I'm not sure if

1 you'll be able to locate it on the map; it's not essential that you find

2 it. But for our benefits, it's -- if we Sikiric and Loznica, in between

3 we see written in blue ink Loznica R. So I'll just ask you: The Loznicka

4 Rijeka you refer to, is that -- is that near Sikiric?

5 A. Yes, it's near Sikiric, somewhere around there. It's Bjelovac.

6 You can -- I know all of these places along the road. They are mostly

7 linked.

8 THE INTERPRETER: Could the witness please speak into the

9 microphone.

10 MR. JONES:

11 Q. Yes, if could you just speak into that microphone.

12 A. I entered through the Pirici Brdo, which I see here, and I know I

13 went down into Rijeka through Pirici Brdo. I passed through Brezovica;

14 that's in a valley. There's a hill in front of it. You climb up the

15 Pirici Brdo. It was very dangerous because there was strong shelling

16 there. When there was fighting on in Bjelovac, it was terrible. I had

17 never heard more shooting than I did in that very place.

18 Q. Thank you. I'll come to that. But so we see Sikiric next to

19 Loznicka Rijeka. Roughly how far away would you say Sikiric is? Is it

20 actually a separate location or is it a continuation of Loznicka Rijeka?

21 A. Perhaps a couple of houses and then another village. Those

22 villages usually didn't have many houses. Then you would have fields and

23 so on. I couldn't really say how far it was in kilometres, but everything

24 was close by.

25 Q. And again, did you go alone to Bjelovac or did you go with other

1 people? And if so, could you estimate how many people?

2 A. There were a lot of people. My friend Ismeta was with me, like

3 she was always, she was my comrade in war. I entered a house near the

4 Drina River, near the road in Loznicka Rijeka.

5 Q. I'm come to that in a moment. The people who went to Bjelovac or

6 with whom you went to the Bjelovac area, were these civilians or fighters

7 or a mixture of the two?

8 A. That time I went with the civilians. At that time only, the

9 Torbari or Hapci went. The fighters were already before in the fighting

10 in the Bjelovac area.

11 Q. And was the presence of these civilians, was that something which

12 was organised by the authorities or by anyone or was it just people like

13 yourself going along to the action?

14 A. If I can respond with a question of my own. Which authorities?

15 Which authorities do you mean? We didn't have an authority or

16 authorities, legal authority in that period. It was just people. People

17 organised themselves as they saw fit.

18 Q. Thank you. Now, you've described earlier how at one point you

19 were in Sase and you saw, I think, spent cartridges or something of that

20 nature. Was that on this occasion or was it on some other occasion?

21 A. On this occasion, too, but also before I saw that. Because the

22 first time Sase was freed I was in Sase also. Perhaps I didn't say it

23 before, but I did witness that for myself on two occasions.

24 Q. Did you pass through Sase on your way to Loznicka Rijeka on day

25 one of this action?

1 A. Yes, I was in Sase. I don't know which road we took to go over

2 the hills. I really cannot remember which places we went through, but I

3 know we came to Brezovica and then over the Pirici Brdo hill, and that's

4 how I got to Loznicka Rijeka, through -- by going down that hill.

5 Q. In Sase did you see any burned houses or property destroyed by

6 fire?

7 A. I saw damaged houses, you know, if they're hit by a shell and a

8 wall is knocked down. But I wasn't really looking at the houses. I just

9 walked through very quickly because there was nothing of food in Sase, so

10 I was rushing to get to the next place.

11 Q. Thank you. Now, you described how on day one you went from

12 Pirici Brdo down to Loznicka Rijeka and you also referred to there being a

13 lot of shooting. Can you -- can you describe that for us, as you arrived

14 in Loznicka Rijeka, what sort of shooting, where it was coming from. Just

15 give us a brief synopsis.

16 A. Just over that hill, just going over that hill, I registered four

17 types of heavy artillery. The shells were falling over the hill and then

18 falling further away. I really don't know what type of weapons or

19 ammunition this was, but I know that it was very difficult to go over this

20 hill. The shells were coming from across the Drina River.

21 Q. So from Serbia?

22 A. Yes, from Serbia.

23 Q. And what was the sort of frequency or intensity of the shelling?

24 A. We waited for a kind of lull so that we could run over the hill,

25 but this never happened. And then as we were going there and on our way

1 back we didn't manage to get over the hill without the shelling. It

2 wasn't a big hill, but the shelling was constant.

3 Q. Now, what actually did you do when you got to Loznicka Rijeka?

4 A. I went into a house and I found some other women there who were

5 already looking for the food in the houses. There was a room. It was

6 like a pantry or something, and there was different kind of food in there,

7 sour peppers, bacon, I found rice, I found yeast for bread and that kind

8 of thing. However, a shell hit the house and it broke through a wall, and

9 the whole house shook and there was a lot of dust. So I just crouched

10 down like the others, and we were all still for a little bit until it was

11 over, but I didn't leave the house without taking as much food as I could

12 carry. The same thing was done by my friend and the other women. The

13 shell hit the house and then entered the house and exploded on the other

14 side. That's what happened.

15 Q. Thank you. Now, did you see any planes on that day?

16 A. Yes. You could hear the planes going up river and downstream as

17 well. You could constantly hear the airplanes and see them.

18 Q. Were they doing in anything particular, apart from going up and

19 down the stream?

20 A. The shelling and the shooting was terrible, so I really couldn't

21 tell whether the planes were bombing. There was different kind of

22 shooting that day, and it was in the area of Bjlovci where the fighting

23 was going on. I thought nobody was stay alive over there. We returned

24 over Pirici Brdo, Ismeta and I and some other women. A shell fell very

25 close to us. Some shrapnel flew by my nose. I thought I was wounded. I

1 thought I could feel something dripping, but nothing happened. When we

2 got to Brezovica we sat down to have a rest, but you could hear the

3 shelling further down.

4 I just want to say one more thing. When I was going up

5 the Pirici Brdo hill, there was a small river there, and people were

6 carrying food on horseback. A shell dropped and severed one of the

7 horse's legs. When I turned around to see who was wounded, the people had

8 already gathered around the horse, and they had cut up the carcass and

9 took away the parts of the horse's body. And that's how I understood that

10 they were actually going to eat the horse.

11 Q. Right. Thank you. Now, still dealing with the first day and what

12 you say on that day, did you see any houses on that day that showed signs

13 of burning, having been set on fire, as opposed to having been damaged by

14 shells or bombs, according to the distinction which you drew earlier?

15 A. I state responsibly that no house was burning at that time.

16 Perhaps if a house was hit by a shell, as it happened when I was in that

17 house, but I could see that nothing was burning. I was amongst those

18 houses. You could see smoke from the shelling further away or when a

19 shell struck somewhere on a hill. And you could hear the loud noise of

20 the shelling over there, you could see smoke, that was farther away. But

21 the place where I was was clear. There was nothing there. There was some

22 fighters also there. I could see them carrying a piece of meat, and they

23 were slicing it up to eat it. I don't know if they had some kind of task

24 assigned to them there or something, but I can state definitely that

25 nothing was actually going on there where I was.

1 Q. And there where you were was the Loznicka Rijeka area, as you told

2 us. Could you also see towards Sikiric?

3 A. Yes.

4 Q. Thank you. Now, I have a slightly more general question about

5 the, sort of, houses which you were going into to get food from. And help

6 us with this, if you will: Were there gas ovens in some or many of the

7 houses which you -- which you saw or which are present along the Drina?

8 A. I didn't notice that there were any gas stoves, but there were

9 stoves that used wood or coal. However, many people had butane bottles or

10 gas canisters, and they would use those for cooking. The cooker would be

11 attached to this canister and then the gas would be turned on. That was

12 the usual thing, but I don't know what you are asking me exactly.

13 Q. Well, thank you. Firstly these butane bottles, are they highly --

14 are they flammable, highly flammable, not at all flammable?

15 A. Of course the canister can be sparked off by a blow or something,

16 and if a bullet or something like that hits it, then it can blow up like a

17 bomb.

18 Q. And again from your experience of going -- being in -- present in

19 actions and from what you saw in houses where you went looking for food,

20 would you have any explanation of how a house might go up in flames or be

21 damaged, apart from it being deliberately set on fire?

22 MR. DI FAZIO: That's an invitation to a range of speculations.

23 JUDGE AGIUS: Yes. In fact, I had already looked at you before

24 you even reacted.

25 Could you rephrase your question.

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1 MR. JONES: Well, I wonder if I might lead on a slightly different

2 question. Of course it would be hard for my learned friend to say

3 beforehand.

4 JUDGE AGIUS: On what part would you like to lead?

5 MR. JONES: Specifically I'd like to ask whether this witness had

6 experience of Serbs actually shelling their own warehouses, ammunition

7 dumps.

8 JUDGE AGIUS: Mr. Di Fazio, do you have any objection?

9 MR. DI FAZIO: No.

10 JUDGE AGIUS: Okay.

11 Go ahead, Mr. Jones.

12 MR. JONES: Thank you.

13 Q. Is that something which you are familiar, Ms. Hotic, Serbs

14 shelling their own ammunition dumps?

15 MR. DI FAZIO: By accident? Deliberately?

16 JUDGE AGIUS: One moment. Because again the same officer did it

17 again. I mean --

18 MR. DI FAZIO: Sorry, I didn't realise.

19 JUDGE AGIUS: Make sure that it is switched off, please.

20 MR. JONES: Yes.

21 JUDGE AGIUS: Yes. I apologise to both of you, both Mr. Di Fazio

22 and Mr. Jones, because it irritates me, especially since it's the same

23 person who did it before already.

24 MR. DI FAZIO: If Your Honours please, while that was going on,

25 having looked at the question, I object to it. The question that

1 Mr. Jones wants to ask is specifically: "I'd like to ask whether this

2 witness has experience of Serbs actually shelling their own warehouses --

3 JUDGE AGIUS: Yes.

4 MR. DI FAZIO: -- ammunition dumps." If the question were to be

5 rephrased such that did Serbs' bombs ever land on -- or shells on

6 ammunition dumps, and as long as the witness can tell us how she knew

7 there were ammunition dumps there, then I suppose the witness could

8 describe that phenomenon. But I doubt that she'd be in a position to tell

9 you whether or not the Serbs were deliberately targeting those -- any

10 ammunition dumps that may or may not have existed. So I suggest that way

11 out of the impasse --

12 JUDGE AGIUS: Yes, I think that would be a good way out of this

13 impasse, if it is an impasse at all.

14 Do you have any objection of proceeding along the lines indicated

15 by Mr. Di Fazio, Mr. Jones? I don't think that you should.

16 MR. JONES: I think that's fine.

17 Q. So, Ms. Hotic, if I can put the question again and I'll ask

18 precisely as my learned friend put it. Are you firstly aware or familiar

19 with Serb bombs ever landing on ammunition dumps or depots, either from

20 your own experience or other sources of information?

21 A. Usually in the places where the Serbs were, they had significant

22 quantities of ammunition and they knew about these depots. And when they

23 were forced to leave the places, when we're talking about actions and so

24 on, then they would fire at those depots to prevent them from being

25 captured by Muslim forces. They could have done that from planes or any

1 kind of weapon that had the proper range. That's what they would do.

2 Sometimes I would hear the fighters say that it was very dangerous to

3 torch a Serb house because it was possible that any one of them would have

4 some weapons or something inside which could blow up and endanger people

5 who were walking around looking for food. It was always the case that

6 there were always people walking around looking for food. And the Serbs

7 would then, in these cases when they couldn't take their weapons and

8 ammunition out, fire at these weapons to prevent them from falling into

9 Muslim hands.

10 JUDGE AGIUS: Mrs. Hotic, do you need a rest? Do you need a

11 break?

12 THE WITNESS: [Interpretation] No, no. I apologise. I just have a

13 chronic cough and sometimes I start coughing.

14 JUDGE AGIUS: That's why I am asking you because the system here

15 is that if at any time the witness would like to stop for a few minutes,

16 you just have to say so and we will stop for as long as you wish. So it's

17 no inconvenience to us and no problem to us at all.

18 THE WITNESS: [Interpretation] Thank you. I'm not tired.

19 MR. JONES:

20 Q. Thank you, Ms. Hotic.

21 Now, what was the source of your information or intelligence that

22 the Serbs would do this, this thing of basically targeting their own

23 depots or ammunition dumps when they had to withdraw? How do you know

24 that?

25 A. From other people's experience. I was constantly in touch with

1 other people, constantly talking to others, I was constantly on the move,

2 and simply everybody knew everything.

3 Q. You also said you overheard a fighter saying that it was dangerous

4 to set fire to a house because of the weaponry and ammunition which might

5 detonate. Was he saying this as an observation or as an admonition not to

6 burn?

7 A. Yes, of course it was an observation. It was something that was

8 generally known amongst the fighters.

9 Q. Did you -- let me put it this way: Did you ever hear a

10 conversation in which fighters spoke out against burning -- burning houses

11 or a specific fighter?

12 A. I heard about Hakija Meholjic, that he would issue orders to his

13 fighters not to burn houses. He said, Don't burn the houses. We will

14 need the houses. Where are we going to put all of these people? They

15 will come. They will have a house, they will have a field, they could

16 live there and work the land. This is something that I actually heard

17 from him personally.

18 Q. Okay. Thank you. Now, just dealing with the first day that you

19 were in Loznicka Rijeka, did you -- did you stay in Loznicka Rijeka or did

20 you go back to Srebrenica or did you go somewhere else?

21 A. Yes, I returned to Srebrenica. Afterwards, I went to the

22 Bjelovica area.

23 Q. When was that?

24 A. The next day.

25 Q. On that day were there also civilians with you?

1 A. Of course. There was always a large number of civilians. I would

2 be going with them. I wouldn't go anywhere by myself. I would be going

3 with this large number of people.

4 Q. Right. And on the second day did you actually go to Bjelovac?

5 A. Yes. I was in the area of Bjelovac, but fighting was going on

6 around Kunjerac. There was still shooting. It wasn't as much as the

7 first day. I was in the cornfields picking the corn with Ismeta, with

8 whom I always went. At that point a plane passed overhead that was firing

9 rockets and dropped bombs in the area. I told Ismeta to lie down on the

10 ground, but she said, Well, I hope something hits me so that all of this

11 is over. Finally I've had enough of it. I'm sick of it.

12 Q. Thank you. And did you see houses in Bjelovac that day?

13 A. I did see some houses, white houses were just there. I didn't go

14 into any houses in Bjelovac because I knew that there was no food in the

15 houses, and if there had been food that was probably collected on the

16 first day already.

17 Q. And did -- among the houses you saw, did any of them have signs of

18 burning?

19 A. I didn't notice anything like that, no.

20 Q. Did you find any food in the Bjelovac area that day?

21 A. I found corn. When I brought it home, it was only 11 kilos. But

22 I decided to spend the night in a house in Voljavica with Ismeta, it was a

23 house near the road, and we did spend the night there. Under the stairs

24 in that house, there was a small area and that's where we found a sack of

25 salt used to put that on the roads when it snows. And we decided to take

1 that salt home and then use it for washing by soaking the salt in water.

2 So we were very happy with that salt. We came home, we turned the oven

3 on, and we baked a pumpkin that we had brought back. We didn't find too

4 much food, but we went to the attic of that house and we found some beans.

5 And then when we wanted to divide up the salt, we -- some man came by and

6 he took this salt from us. So in the end, we didn't get the salt; it was

7 taken away.

8 Q. That was in Voljavica, was it, on the second day of this action --

9 or the evening?

10 A. Yes. But this is all connected, that evening, and then the next

11 day I went home. In the morning when we were getting ready to go home, at

12 the crossroads of Bjelovica, Zaluzje, towards Sase, there was a group of

13 women who had found some food. And I don't know, I guess they were

14 discussing to go further. And in the meantime a shell dropped.

15 Q. Thank you, yes. I'm sorry to cut you off but I'm conscious of the

16 time and was going to move to another topic.

17 Were there many -- do you know what sort of casualties were

18 suffered on the Muslim side in the Bjelovac action?

19 A. I think a lot of civilians were hurt. The highest number -- a lot

20 of women were hurt, also a lot of the livestock. It was one of the most

21 serious battles I think that had happened there.

22 Q. Is it right that you -- in Srebrenica you lived near to the

23 hospital?

24 A. Yes, Marsala Tita street, number 86. That number still stands

25 there today.

1 Q. Did you yourself ever help in the hospital or visit there?

2 A. Yes, of course. I took my sheets there, scissors. Whatever could

3 help, I took there. There was so many wounded. They didn't have anything

4 you could help them with because when the Serbs left Srebrenica they took

5 away all the equipment, we didn't have any medicines left, so that we had

6 general practitioners, doctors who had to do everything. They had perform

7 surgeries, dress wounds, they had to do everything. When you go inside,

8 you could smell blood, the flesh, people were wailing, screaming. Limbs

9 were amputated without anaesthesia. They would give them some brandy to

10 lessen the pain a little bit.

11 A few times I was there. When I would start crying they would

12 take me out and they would tell me, Don't come back anymore. You're more

13 of a disturbance than you are of help. And I just felt that it was

14 terrible what was actually happening there.

15 Q. Did you come across Dr. Nedret Mukanovic in hospital?

16 A. Yes, I knew him.

17 Q. Was he doing anything? Was he performing surgery?

18 A. Yes. He performed surgery, but everybody did the impossible, what

19 they knew and what they didn't know. Ivan Ilijaz, who was not a surgeon,

20 did that, and Dr. Avdo and whoever found themselves there.

21 Q. And Ivan Ilijaz, if you can give us his surname, please, just for

22 the record, and Avdo?

23 A. Ilijaz Pilav.

24 Q. And Avdo?

25 A. I can't remember, but I did know him well before the war. I can't

1 remember his family name. His wife is called Zilha.

2 MR. JONES: I'm actually about to move to another topic, so ...

3 JUDGE AGIUS: We'll have a break now and we'll resume at 1.00.

4 --- Recess taken at 12.31 p.m.

5 --- On resuming at 1.04 p.m.

6 JUDGE AGIUS: One very quick matter. In the meantime, you will

7 continue with your examination-in-chief and your colleagues will deal with

8 it; same with Prosecution. Ibisevic's book, this morning we got the

9 English version and it is P564E. I found out now that the Defence has

10 already used various parts from this book, and the relative exhibit

11 is D690. I want to avoid confusion in particular as we go along. So

12 please tell me -- tell us tomorrow whether you want this translation as it

13 should to remain as P564E and what's going to happen later on with -- when

14 you are going to make use of this document, whether you are going to refer

15 to D690 or whether you are going to refer to P564E. I mean, it's

16 something that you need to do.

17 The other thing is my attention has been drawn as to the

18 possibility that there may have already been a C2. You sure there isn't?

19 THE REGISTRAR: No, there is no C2.

20 JUDGE AGIUS: All right. Please check again. I'm told that there

21 may have been a map.

22 THE REGISTRAR: That was C1, Your Honour.

23 JUDGE AGIUS: C1, all right. Okay.

24 Let's proceed.

25 MR. JONES: Right. Thank you, Your Honour.

1 Q. Now, Ms. Hotic, after the action in Bjelovac which you've been

2 describing, did the situation in Srebrenica with regard to food, did it

3 improve, did it get worse, did it stay the same?

4 A. After Bjelovac and after we managed to get some food, it all

5 lasted for a very short time in Srebrenica. Things continued to be

6 difficult. First of all, not everybody could get food, so ...

7 Q. Now, did you -- or firstly, are you familiar with Kravica?

8 A. Yes, I was at Kravica.

9 Q. When were you in Kravica?

10 A. I know that it was on Serb Christmas day. It was the beginning of

11 1993. There was a lot of snow, and it was the worst possible time in

12 terms of hunger for Srebrenica. Also, everything had been covered by

13 snow. There was nothing left and people were literally starving to death.

14 Q. When you say "everything was covered in snow," did that have a

15 bearing on the food situation?

16 A. Of course. And because what was left behind in the fields that we

17 could get our hands on had disappeared because frost and snow had

18 destroyed it all. You could get nothing at all. We, for example, used to

19 go looking for hazelnuts and there were no hazelnuts left, and there was

20 no wood left to burn. There was literally nothing left.

21 Q. Now, when did you hear that there would be an action in Kravica?

22 A. I don't know whether on the day before or on the day that the

23 action took place.

24 Q. And from whom did you hear that there would be an action?

25 A. From the people. That kind of news travels fast, in a low voice,

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1 but everybody gets told.

2 Q. Now, at that time did the place, Kravica, mean anything to you?

3 A. Yes. The place of Kravica meant that it was a big strong Serb

4 military stronghold. It was a threatening place. You did not interfere

5 with that. It was like a nest of hornets, but that was the only way to

6 get food because it was -- you either live or die.

7 Q. Do I take it from that the people in Srebrenica were afraid, in

8 some sense, of Kravica?

9 A. Yes.

10 Q. And at this time in January 1993, or rather what you've described

11 as it a big strong -- Serb military stronghold, a nest of hornets, does

12 that apply to that period, January 1993, or before or what precisely?

13 A. Yes. Well, it was generally well-known about Kravica. Even

14 before the start of the war, we knew that the Chetniks that were left over

15 from the Second World War had stayed there. So that was their area where

16 they had their roots. So people tried to not go too near Kravica and --

17 if you didn't want to meet with these people. So you just avoided the

18 place.

19 Q. And again, as far as you knew or were aware, were the fighters in

20 Srebrenica keen that you and other civilians should go to Kravica or were

21 they opposed or were they indifferent? What was the position?

22 A. They were opposed, the fighters were opposed. First of all, they

23 were even opposed to the idea of launching an action against Kravica. But

24 the people insisted -- they kept begging them to do something. You said,

25 You have to do something, you must do something, otherwise we'll all

1 starve to death. What is this fate that has befallen us? And nobody

2 actually believed in a really good outcome, but it was a must. We were

3 forced to do it.

4 Q. Thank you.

5 MR. JONES: I'm going to be referring to D714 for the map because

6 the previous map doesn't actually have Kravica on it. So again, perhaps

7 if the witness could have that by her on the ELMO. If we could try and

8 have the section which would show Srebrenica and also Kravica. So we have

9 Srebrenica, and if we could just lower it -- lower the paper a little

10 bit -- or sorry, the other way. And a little to the -- well, so the left

11 of the page is visible. Yes. Could we have the left of the page and then

12 lowered slightly. When I say "lowered," a bit higher there, other

13 direction. A bit more, bit more. Yes, thank you.

14 Q. Now, do you see Kravica on that map, Ms. Hotic?

15 A. Kravica is somewhere here.

16 Q. [Previous translation continues] ... there. You were pointing --

17 A. I can see Repovac here, Hranica -- Kravica is in this area but I

18 can't see it written down here. It is somewhere behind Rebrovac.

19 Q. Yes. If you -- I assume there wouldn't be any objection if I

20 direct you --

21 MR. DI FAZIO: No.

22 MR. JONES: Thank you.

23 THE WITNESS: [Interpretation] Kajici, it's in this part because

24 this is from Bratunac --

25 MR. JONES:

1 Q. Wait a minute. You see the road going from Bratunac towards

2 Konjevic Polje?

3 A. Yes, I do.

4 Q. Follow that road along a little bit you'll see Magasici - keep

5 going - you were at Hransaca [phoen]. If you keep your finger running

6 along the road.

7 MR. DI FAZIO: I have no objection to Mr. Jones approaching the

8 witness and pointing her --

9 JUDGE AGIUS: I told him go ahead already.

10 MR. JONES: Yes. I'm just trying to get her there.

11 Q. And a bit further along to your left, you'll see Kajici and then

12 Kravica. Just keep following along, Ms. Hotic, with your finger and

13 you'll see Kravica on your left. A bit further.

14 A. Kajici. Yes, that -- there it is. I do apologise. I don't quite

15 understand the map, but I know the general direction. But now I've found

16 Kravica.

17 Q. Thank you.

18 JUDGE AGIUS: For the record, the witness points at Kravica with

19 her finger.

20 MR. JONES:

21 Q. Now, could you just mention the names. You don't have to trace it

22 on the map; in fact, you can leave the map, Ms. Hotic. We can follow it

23 ourselves. Ms. Hotic?

24 A. Yes.

25 Q. If you could just mention where you went, the villages or hamlets

1 that you went through to get to Kravica on the Orthodox Christmas.

2 A. When I went to Kravica I went in the direction of Potocari from

3 Srebrenica, and in Potocari -- in the direction of upper Potocari.

4 Q. Did you --

5 A. And the people who were with me said that we would go across

6 Susnjari, Jaglici, and then we would go down, down the asphalt road to

7 Kravica.

8 Q. Is that the route you took: Potocari, Susnjari, Jaglici, Kajici,

9 Kravica?

10 A. I think so, yes. Everybody went down that road. We actually

11 created a path in the snow.

12 Q. Is there any reason you didn't continue along past Potocari

13 towards Bratunac? Did anyone give you any directions or any suggestions

14 as to where you should go?

15 A. Of course there were Serbs at Bratunac. As of Zuti Most, we could

16 not go down, and you couldn't take the road down to Potocari through

17 Potocari because we would have shelled from the hill Zvijezda Bratunac.

18 Q. Thank you. Just for the record, I think we should have that hill

19 spelled, Zvijesda. Could you spell it for us letter by letter?

20 A. Z-v-i-j-e-z-d-a.

21 Q. In fact, the stenographer got it right the first time, so ...

22 Thank you.

23 Now, can you estimate just roughly how many people were with you

24 when you went to Kravica, whether it was 10, 100, 1.000?

25 A. I think everybody who could walk actually walked to Kravica. And

1 there were about 60.000 people in the Srebrenica at the time.

2 Q. So we're talking about thousands of people going to Kravica?

3 A. Yes.

4 Q. What time roughly of the day did you arrive in Kravica? We don't

5 need an exact hour, but morning, afternoon, late afternoon, evening?

6 A. Early evening.

7 Q. And was the military action still going on at that time, when you

8 arrived in Kravica?

9 A. No.

10 Q. It was over?

11 A. Yes.

12 Q. When you went on this route which you've described through

13 Jaglici, Susnjari, Kajici, Kravica, did you see any houses burning?

14 A. Yes -- no.

15 Q. I believe the witness was saying yes in the description of the

16 route and then answering no to my question.

17 I'll put the question again. Did you see any houses burning on

18 that route?

19 A. I did not see any houses burning.

20 Q. Thank you. Did you go into the centre of Kravica?

21 A. From the main asphalt road I went into a warehouse, and somebody

22 in that mass of people had told me that there was a lot of food there, but

23 everything had been taken already because from the morning people had set

24 off to Kravica and I had come across people coming back carrying food.

25 Some people were coming back as we were going to Kravica. Only in the

1 area of Jaglici when I was going down, we were shelled. There were shells

2 landing in the direction of Jaglici and we could not hear any other sounds

3 of battle, shooting.

4 Q. Are you familiar with a place called Jezestica?

5 A. Yes, that's close by as well.

6 Q. Close --

7 A. But I don't actually know the village itself. I know where it is

8 approximately, but I've never been to the village.

9 Q. You were describing Jaglici. Do you mean it was close by Jaglici?

10 A. It's not far.

11 Q. How long did you spend in the Kravica area that day?

12 A. I don't know if I spent two hours there.

13 Q. Did you spend the whole time near the road, the

14 Bratunac-Konjevic Polje road, or did you go away from the road into the

15 hills a little?

16 A. Perhaps a couple of houses in the direction of the hills, because

17 the first houses were empty, everything had been taken. So I hurried, I

18 actually ran to a house, and in a pantry or some sort of kitchen I found a

19 great deal of food there, corn and wheat, and I found two-kilo packets of

20 white flour and I took as much as I could.

21 MR. DI FAZIO: If Your Honours please --

22 JUDGE AGIUS: Yes.

23 MR. DI FAZIO: No objection. It's just that perhaps -- in fact, I

24 may be will to assist Mr. Jones and also myself. He asked: Did you go

25 into the centre of Kravica? And the witness gave a long answer. She

1 talked about going into a warehouse. She didn't actually say whether she

2 had gone into the centre --

3 JUDGE AGIUS: I agree with you entirely, Mr. Di Fazio.

4 MR. JONES: Yes. There might be a definitional problem of what

5 the centre is.

6 Q. Are you familiar with where the church is in Kravica?

7 A. The church is at the top. I did not go as far as the church. The

8 only church I know is somewhere on the top. I don't remember. But when I

9 was in Kravica I did not actually know where the church was.

10 Q. Would you be familiar with the primary school or any of the

11 buildings which would be in the town centre in Kravica?

12 A. I really am not able to tell you what the centre of Kravica is.

13 It is not a big village. It might have between 30 and 40 houses, I don't

14 know. Before that I had only travelled down the road through Kravica, but

15 I never paid any attention to where everything was. At that particular

16 time, though, my main aim was simply to get the food.

17 Q. Let me also just ask you this: The warehouse which you've

18 described, was that either before you reached Kravica coming from Kajici,

19 or was it after, on the way to Konjevic Polje, or was it in Kravica

20 itself?

21 A. You mean the warehouses -- warehouse for food? It was at Kravica

22 in the direction facing Bratunac rather than Konjevic Polje. I think

23 that's where it was. As far as I can remember now. I mean, this is ten

24 years ago so -- and at the time I wasn't really thinking in those terms.

25 Q. Just to summarise this, would you say that you were in Kravica

1 that day?

2 A. Yes, I was in Kravica.

3 MR. JONES: I'd like the witness to be shown P400 briefly which

4 comprises a number of photographs. I have a dozen or so. In fact, she

5 can use my copy if it's quicker -- oh, no, we have it ready.

6 Q. Ms. Hotic, I'm simply going to ask you to flick through these

7 photographs and to tell us whether you -- on the 7th of January, 1993,

8 whether you saw any houses which were in this state -- well, let's start

9 with 01087891. When you were in Kravica, did you see any buildings which

10 were in that sort of a state?

11 A. I saw undamaged houses in Kravica. And people running through the

12 houses looking for food and clothes and shoes because they had nothing to

13 wear either, but I saw not a single house looking like this.

14 Q. Thank you.

15 MR. JONES: In fact, I think that disposes of it. That's fine.

16 Q. Now, leaving aside houses for the moment, on that day did you see

17 any other -- did you see any objects which had been set on fire or which

18 were on fire?

19 A. Hay was on fire only, but it provided light for us so we could see

20 where we were going. That was the only thing that was burning. I think

21 where I entered in the direction of Bratunac, not Konjevic Polje, the only

22 thing that was actually on fire was hay.

23 Q. I'm going to ask you about that in a moment. But firstly when you

24 arrived in Kravica, was it light, was it dark, was it twilight? How much

25 natural light was there?

1 A. It was twilight. I could see -- it wasn't pitch dark. It was in

2 the early evening hours, twilight.

3 Q. And --

4 A. Because I could see clearly the road that I was walking along and

5 it was close to a creek. And I could see that the house that I went in

6 was a new one, and this shed that I found the food in had also been new.

7 Q. Now, going back to the haystack for a moment was that --

8 MR. DI FAZIO: Well, if Your Honours please, the witness didn't

9 said "haystack," she said "hay," and it's of some importance.

10 JUDGE AGIUS: Yes, yes, you are right. Yes, I would agree with

11 you.

12 MR. JONES: My apologies. I might have jumped the gun.

13 JUDGE AGIUS: Maybe you can ask her also because I'm still

14 wondering in my mind exactly what we are talking about, because at one

15 point in time she said Kravica is a small place with just about 40 or 50

16 houses.

17 MR. JONES: The town itself, yes.

18 JUDGE AGIUS: If she could identify at least -- if she could, if

19 she couldn't obviously it's not -- then we stop there, any landmark, any

20 particular building that she could distinguish. Say, you mentioned a

21 church, you mentioned --

22 MR. JONES: A parish hall.

23 JUDGE AGIUS: Parish or whatever. If she could identify. I also

24 do realise that she said that she had passed from that area before but not

25 really knew the place. So this --

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1 MR. JONES: Well, perhaps with the warehouse.

2 Q. You mentioned a warehouse, Ms. Hotic, were you actually familiar

3 with a warehouse beforehand as being in Kravica or was that the first time

4 you laid eyes on it?

5 A. No. When I entered Kravica somebody said that there was a

6 warehouse there for food. I did not know about it. I did not have any

7 prior knowledge of that warehouse. I just followed the crowds, but I

8 entered the building. I can't really remember correctly where it was. I

9 just realised that it was empty and I went on, and I hurried to find

10 something that had not been taken away as yet.

11 Q. Let me put it this way: How did you know that you were in Kravica

12 and in Kajici on that day?

13 A. Because everybody was in Kravica and, first of all, there are no

14 other houses in the vicinity of Kravica. You go to Kravica from

15 Konjevic Polje and then you have a string of villages. But yeah, I know

16 where Kravica is.

17 Q. When you're referring to Kravica, are you referring to the commune

18 or the village?

19 A. The village, whether it was called anything else before I never

20 asked. Whether it was a municipality or not, I don't know.

21 Q. Okay. Now, going back to this hay, the hay you saw burning, can

22 you describe that for us. Was this hay lying around on the ground or was

23 it organised in a stack or was it in some other way stored or arranged?

24 A. When I say "hay," what I mean is hay which has been put away for

25 winter, so it is of course haystacks. And a haystack like that was

1 burning and that's what I saw. It's not scattered on the ground. It was

2 in a haystack, if that's what you call it.

3 Q. And this haystack, was that in a field or was it in a barn?

4 A. Well, the houses were there and then there would be an area around

5 the houses, gardens, fields. The houses were not close together, maybe a

6 couple were close together, but they were scattered with gardens and

7 fields around the houses.

8 Q. All right. Dealing then with the haystack, did that generate some

9 smoke, a lot of smoke, no smoke? What sort of smoke was generated by the

10 burning of the haystack?

11 A. I didn't really look to see if there was smoke, but you could see

12 the flames, the red flames. That was what I could see, that there were a

13 lot of flames.

14 Q. And before this day, had you seen haystacks on fire before?

15 A. I don't remember seeing that anywhere.

16 Q. So what I wanted to ask you is if you -- only if you can help us

17 with this, but does it make any difference in your experience to how much

18 smoke is given off by a haystack, whether it's wet or dry?

19 A. Hay smokes a lot, but it was night so you could see the

20 illumination better. I was very close so I could see the flames -- the

21 hay in flames. As far as the smoke, it was mixed up in the air so it was

22 very difficult for me to see exactly. But I do know I saw in other places

23 when something is burning, when a pile of hay is burning that's a little

24 damp, then there is a lot of smoke. If it's not very dry, it can smoke a

25 lot. That's the difference.

1 Q. Right. And on this day, was it --

2 A. That's what the kind of flame would depend on.

3 Q. And on this day, was it -- was the ground dry or wet?

4 A. The ground was covered by snow.

5 Q. Thank you.

6 A. And the hay could have been dry because once it starts burning,

7 the top that's covered by snow -- but, I mean, I wouldn't really discuss

8 it that much. I don't know how important that is. It was hay and it was

9 burning and that's it.

10 Q. Okay. Thank you. Now, I think you've told us, correct me if I'm

11 wrong, that you did actually find some food. Did you -- did you manage to

12 take food back to Srebrenica?

13 A. I took twice as much food that I could carry. I put 30

14 kilogrammes in my backpack, and I counted it because the flour was packed

15 in two-kilogramme bags. It was fine flour. And I packed 30 kilogrammes

16 in my backpack. And then I also put another 30 kilometres [as

17 interpreted] in a plastic crate, and I found a kind of plastic rope or

18 something and attached it to the crate, and I dragged that through the

19 snow. So I took double the load that I could carry, hoping that I would

20 manage somehow.

21 Q. Did you see any other Torbari on that trip bringing food back in a

22 similar fashion?

23 A. Of course people were carrying things and then some of them were

24 coming back again to get food. A man was carrying two 50-kilogramme

25 sacks. He would carry one 10 metres, put it down, and then return to get

1 the other one. And that's how they did it. I asked him, How are you

2 going to carry all of that back? He said, Well, it's worth my while to

3 carry back one week's worth of food because there is nothing else. People

4 were carrying stuff up the hill.

5 I met one 12-year-old girl. Her name was Irena. She was living

6 in my building with her mother and her nine-year-old sister. Irena was

7 carrying some potatoes and sauerkraut on a lid. I said, Irena, couldn't

8 you find any flour? She said, Well, we have some rice. She was only 12

9 years old. She said her mother was lying down, she couldn't get up

10 because she was so hungry. Her mother's name was Nevzeta. And this child

11 had gone on her own together with the other people to look for food. You

12 can imagine what trouble drove her to do something like that.

13 Q. Did you go back to Kravica after that day, the Orthodox Christmas?

14 A. No. When I came home I really couldn't move at all. It took a

15 long time for me to recover. It was very difficult for me to carry and

16 drag that load up the hill. At one point, one young man who was carrying

17 a sack of his own pulled the rope that I had, so he helped me carry that

18 up the hill.

19 I was very thirsty. I ate a piece of roasted meat in Kravica.

20 One of the women probably gave it to me. And it was a long time since I

21 had had anything like that to eat. And I was very thirsty. So on top of

22 all the other trouble, I had to eat snow on the way in order to quench my

23 thirst. But when I got home I was very, very happy. I had come home with

24 60 kilogrammes of flour, but there was no way that I could go back again.

25 Other people, some people, kept going back and forth for two or three days

1 to bring out more food.

2 Q. Thank you.

3 MR. JONES: There's an exhibit which I'd like to hand up now which

4 we have copies of for everyone. It has the ERN 04363125. I should say

5 it's from the Drina Corps archives. And the title is regular combat

6 report. It's from the command of the Bratunac Light Infantry Brigade.

7 Q. And I'd ask you -- firstly --

8 JUDGE AGIUS: One moment, Mr. Jones, let's have a look at it.

9 Okay, go ahead.

10 MR. JONES:

11 Q. Firstly, Ms. Hotic, would you agree that I showed you this

12 document when you came here to The Hague?

13 A. Yes.

14 Q. Now, there are some place names mentioned Polom, Ocenovici,

15 Supotnik. Are you familiar with those places or some of them?

16 A. Yes. Polom is downstream from Bratunac, down the Drina. When you

17 go from Bratunac along the Drina, it's an old road. It's not used anymore

18 because it goes through Konjevic Polje and it goes towards Drinjaca.

19 Q. And Ocenovici, are you familiar with the name at least of

20 Ocenovici?

21 A. I don't remember the name Ocenovici. I hadn't heard of that

22 before.

23 Q. We'll find these places on D714. I simply want to ask you this:

24 Reading this document are you familiar with this phenomenon from 1992 or

25 1993 of Serbs booby-trapping or mining houses in order to kill Muslims

1 when they went for food?

2 A. I know that Serbs would mine places where grain was held, and they

3 would leave that at places where people would try to sneak up during the

4 night in order to get some food. This would happen in places along the

5 Drina River around Bjelovica [as interpreted] because I would come through

6 Orlica before regardless of the combat actions. I would come with the

7 people to the fields looking for food. So that people in their attempts

8 to get to the food would trip mines and that's how people got hurt.

9 Q. Just two questions. You said Bjelovica in the transcript --

10 A. Bjelovac. I'm thinking of the area of Podrinje, that part from

11 Bjelovac. I would go through that area with the people regardless of the

12 combat actions. I went to look for food 19 times during the war.

13 Sometimes it would be along with the action and sometimes it would be

14 separate from that.

15 Q. And -- thank you. And as far as actually houses being mined,

16 mines actually being planted in a house, as is referred to in this

17 document, is that something you ever heard about or understood to have

18 happened?

19 A. Yes, yes. I heard about that. They would place mines along the

20 road as well as place mines in the houses. They were like traps. The

21 house would look attractive, look as if perhaps there was some food there,

22 and many people were killed or injured in places like that.

23 Q. It was a mousetrap [Realtime transcript read in error "house

24 trap"]?

25 A. Yes.

1 MR. JONES: I'd ask for an exhibit number, please, for this

2 document.

3 JUDGE AGIUS: Yes, this will become Defence Exhibit D717.

4 MR. JONES: I actually said "mousetrap" rather than "house trap".

5 JUDGE AGIUS: Yes, I know that, but sometimes there are house

6 traps as well.

7 MR. JONES: There's one more document which I think I'd like to

8 deal with today depending --

9 JUDGE AGIUS: One moment.

10 More or less, Mr. Di Fazio, having heard roughly almost all the

11 evidence, how much time do you think you will require for

12 cross-examination?

13 MR. DI FAZIO: A good part of tomorrow.

14 JUDGE AGIUS: All right.

15 MR. DI FAZIO: If not all of tomorrow.

16 MR. JONES: I think I'll only be another 20 minutes, half an hour.

17 JUDGE AGIUS: All right. Okay. Do you think you would be able to

18 finish with the witness if Mr. Jones takes another 15 or 20 or 30

19 minutes?

20 MR. DI FAZIO: You mean 15 or 20 of tomorrow?

21 JUDGE AGIUS: Yeah.

22 MR. DI FAZIO: I don't think that will be a problem, no.

23 JUDGE AGIUS: Then we can stop here rather than proceed any

24 further because I wouldn't like to keep anyone else beyond the -- unless

25 it is really necessary, and everyone has always been so cooperative. So I

1 would rather we stop.

2 MR. JONES: Yes, that's perfectly fine.

3 JUDGE AGIUS: Thank you.

4 Madam, I thank you so much for bearing with us. We will continue

5 tomorrow morning at 9.00, and we hope to be able to finish with your

6 testimony tomorrow.

7 THE WITNESS: [Interpretation] Thank you, too. It is very

8 important to me, Your Honours, to uncover the truth. I have been fighting

9 for ten years now to uncover the truth.

10 JUDGE AGIUS: One more thing I have to tell you before we leave

11 and that is that between today and tomorrow please do not communicate with

12 anyone and do not let anyone communicate with you on the subject matter

13 about which you are testifying. All right? Thank you.

14 --- Whereupon the hearing adjourned at 1.44 p.m.,

15 to be reconvened on Thursday, the 25th day of

16 August, 2005, at 9.00 a.m.

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