1 Wednesday, 12 October 2005

2 [Open session]

3 --- Upon commencing at 2.21 p.m.

4 [The accused entered court]

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

6 please.

7 THE REGISTRAR: Good afternoon, Your Honours. This is the Case

8 Number 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 afternoon, Your Honours. Yes,

12 I can follow the proceedings in my mother tongue.

13 JUDGE AGIUS: Thank you, and good afternoon to you.

14 THE ACCUSED: [Interpretation] Thank you.

15 JUDGE AGIUS: Appearances for the Prosecution.

16 MR. WUBBEN: Good afternoon, Your Honours, and also good afternoon

17 to my learned friends of the Defence. For the sake of the transcript, my

18 name is Jan Wubben, lead counsel for the Prosecution, and I'm here

19 together with co-counsel, Mrs. Patricia Sellers, Mr. Gramsci Di Fazio, and

20 our case manager, Ms. Donnica Henry-Frijlink.

21 JUDGE AGIUS: Thank you, and good afternoon to you and your team.

22 Appearances for Naser Oric, also for the record.

23 MS. VIDOVIC: [Interpretation] Good afternoon, Your Honours. I am

24 Vasvija Vidovic. Together with Mr. John Jones I appear for the Defence of

25 Mr. Naser Oric. With us is Ms. Adisa Mehic, our legal assistant, and our

1 case manager, Mr. Geoff Roberts.

2 JUDGE AGIUS: I thank you, and good afternoon to you and your

3 team.

4 Any preliminaries before we touch on ours? No.

5 You -- we are expecting from you, Mr. Jones, a reply on two

6 matters related to the forensic examination motion -- documents motion.

7 One is what kind of lighting is envisaged or is anticipated to be used by

8 your expert, and the other one is an estimate of when he expects to be

9 able to hand to you his report.

10 MR. JONES: Yes.

11 JUDGE AGIUS: I don't really care much when he finishes his

12 forensic tests, but --

13 MR. JONES: Yes.

14 JUDGE AGIUS: -- I am much interested in knowing when he will hand

15 you the report so you can then transmit the or file it.

16 MR. JONES: Yes. Yes, indeed, Your Honour. Well, firstly on the

17 first question, spectrometry will be used by the expert and my inclination

18 is that he will use standard instrumental and visual methods of

19 examination that will not affect the documents in any way, including

20 infrared and ultraviolet lights and he'll also perform photography.

21 That's the information I have.

22 I did notice, Your Honour, just for what it's worth that the

23 Prosecution expert also in their report used infrared luminescence

24 examination and ultraviolet luminescence characteristics, that's from

25 the -- the method set out in the report of their expert, ERN reference

1 03523858 [Realtime transcript read in error "03523538"]. So I take it

2 there'll be no objection to those same techniques being used.

3 Secondly, the indications are that once the experts receive the

4 documents, there are 35 documents which he'll be examining, that he'll

5 need at least two weeks to examine them and to prepare his report.

6 If you give me a moment, Your Honour, I'll just consult my

7 colleague.

8 [Defence counsel confer]

9 MS. VIDOVIC: [Interpretation] Your Honour, may I just add

10 something. He will require two weeks to examine the documents and then an

11 additional two weeks to write his report. So that is a total of one

12 month. At any rate, he'll keep the documents for two weeks.

13 JUDGE AGIUS: Okay. All right. That's what we needed to --

14 rather than speaking of one month, we're speaking of four weeks because,

15 to be honest with you, every day counts in these circumstances, especially

16 if it comes to a point where we will need to appoint our own expert. So --

17 MR. JONES: Just a reference to the ERN, it's wrongly recorded,

18 it's 03523858 just for the record. That's the --

19 JUDGE AGIUS: That's the Prosecution --

20 MR. JONES: Yes.

21 JUDGE AGIUS: Okay.

22 Yes, Mr. Di Fazio, do you wish to add anything on your part?

23 MR. DI FAZIO: I'm just saying that we've -- just now I was asking

24 that -- arranging matters to get instructions on what Mr. Jones has just

25 raised so that we can give our -- what I expect to be our final agreement

1 tomorrow.

2 JUDGE AGIUS: Right. Tomorrow?

3 MR. DI FAZIO: Yes, if that's all right.

4 JUDGE AGIUS: Yeah, if you can give it today I think it will be

5 better because we can hand down our decision today, if that is the case.

6 MR. DI FAZIO: Yes.

7 JUDGE AGIUS: Well, I take it -- I mean, it's just a suggestion

8 and I'm --

9 MR. DI FAZIO: Well, if --

10 JUDGE AGIUS: -- that if it's being suggested to you that the tests

11 that are going -- the methodology and tests that is going to be adopted in

12 this case is practically the same test that your expert --

13 MR. DI FAZIO: Then there should be no problem.

14 JUDGE AGIUS: Then there should be no problem. But, please, I

15 understand you have to take --

16 MR. DI FAZIO: I just want to cover ourselves, Your Honour, that's

17 all. I expect there will be no problem.

18 JUDGE AGIUS: Last thing I would do is deprive you from that

19 opportunity.

20 MR. DI FAZIO: Yes.

21 JUDGE AGIUS: But please try and do that at the earliest. I don't

22 think it should --

23 MR. DI FAZIO: Well, I've told people to make sure we can give you

24 an answer by tomorrow morning.

25 JUDGE AGIUS: That's perfect. If you can give it earlier, it

1 would be appreciated.

2 So, Mr. Dedic -- Madam, can you please bring him in?

3 Today we are sitting to the same schedule, if you agree, that we

4 adopted yesterday and the day before, a schedule to finish at 6.15 or

5 thereabouts. It could be a few minutes more depending on how much time we

6 lose in the meantime between now and then.

7 [The witness entered court]

8 JUDGE AGIUS: Good afternoon to you, Mr. Dedic.

9 THE WITNESS: [Interpretation] Good afternoon.

10 JUDGE AGIUS: I hope you had a good rest and that you are in a

11 position to proceed with your examination-in-chief. And then hopefully

12 tomorrow we'll start with the cross-examination. We'll try to do our best

13 to finish you by the end of our sitting on Friday. Okay? Again, I'm

14 just reminding you as a formality that you are testifying under oath, or

15 rather pursuant to your solemn declaration. And secondly, that you --

16 it's being suggested to you to use the time that we have more -- are there

17 problems with interpretation?

18 THE WITNESS: [Interpretation] It's fine.

19 JUDGE AGIUS: That you confine your answers to the questions that

20 are put to you rather than volunteer more information than you are asked

21 for. All right? Okay. Thank you. Please, take yourself comfortable

22 and Ms. Vidovic with proceed with her examination-in-chief now.

23 THE WITNESS: [Interpretation] Thank you.

24 JUDGE AGIUS: Ms. Vidovic.

25 WITNESS: EJUB DEDIC [Resumed]

1 [Witness answered through interpreter]

2 Examined by Ms. Vidovic: [Continued]

3 Q. [Interpretation] Good afternoon, Mr. Dedic.

4 A. Good afternoon.

5 Q. We will continue from where we broke off yesterday. Yesterday I

6 started asking you about the organisation of defence in Cerska itself,

7 that is, and my question to you is the following. Can you describe the

8 organisation of the Defence in Cerska for the Trial Chamber.

9 A. The defence of Cerska was organised locally only.

10 Q. Could you please what you mean by that, locally.

11 A. Yes. There were smaller or bigger armed units that rallied around

12 their leaders.

13 Q. Can you tell the Trial Chamber what the names of these groups

14 were.

15 A. Most often these groups were named after the villages they came

16 from, where they had been established. For example, Cerani, Rogosani,

17 Skugurcani [phoen], and so on.

18 Q. During 1992 did you call them the Territorial Defence or not?

19 A. No, not in 1992 and not later. We always used the names that I

20 referred to just now, depending on their origin, what villages they came

21 from.

22 Q. Did I understand you correctly that certain villages had their own

23 local leaders and their local armed groups?

24 A. Yes.

25 Q. Did it happen from time to time or not that in a single village

1 there would be, say, two groups?

2 A. Yes. I know very well the example of the village of Kokurtovici

3 [phoen] which had two local groups that had rallied around two local

4 leaders. Often they had poor cooperation or no cooperation whatsoever.

5 Q. Could you please describe to the Trial Chamber what this

6 cooperation was like in 1992 in general terms between these groups in

7 Cerska, including Skugrici.

8 A. The cooperation between these groups in 1992 and 1993 was always

9 on a voluntary basis only.

10 Q. In other words, if somebody wanted to help someone, that's what

11 they did. Did I understand you correctly?

12 A. Yes, precisely.

13 Q. Please, can you tell the Trial Chamber what the role of Ferid

14 Hodzic was?

15 A. Yes. Ferid Hodzic came from Vlasenica to Cerska at the end of May

16 or beginning of June. He tried to unite the local groups that we referred

17 to a few moments ago that were active in the villages and hamlets in the

18 area of Cerska.

19 Q. When you say he came to Cerska at the May or beginning of June,

20 were you referring to 1992 or --

21 A. Yes, it was 1992.

22 Q. Please, did he manage in this effort to unite the local groups or

23 not?

24 A. No. It failed. It was just an attempt.

25 Q. Please, did Ferid Hodzic have anything to offer to people so that

1 they would be interested in listening to him at all? Were there any

2 logistics in Cerska?

3 A. There were no logistics in Cerska and he had nothing to offer in

4 that respect.

5 Q. Did you have any barracks in the area of Cerska?

6 A. No. In the area of Cerska before the war and during the war,

7 there were no barracks whatsoever.

8 Q. Did you have any uniforms?

9 A. We didn't have any uniforms.

10 Q. Can you describe to the Trial Chamber the role of Semso Salihovic.

11 A. Semso Salihovic was a brave man. He worked in the bauxite mine in

12 Milici before the war, and he had around him a group of armed young men

13 from Cerska. Since he was a brave man, they listened to him and they

14 stood by him.

15 Q. Do you recall Becir Mekanic, who you referred to before, coming to

16 the area of Cerska at some point? And if so, when did this happen?

17 A. Yes, I remember this very well. This was the summer of 1992. He

18 came to the area of Cerska along with a small group of armed men who were

19 with him before, too.

20 Q. Please, can you tell us whether they got along, Semso Salihovic,

21 Becir Mekanic, Semso Salihovic, did they work in concert, did they agree

22 or disagree?

23 A. As far as I know there was quite a bit of disagreement among them.

24 I think that they were in competition. They were vying for the top

25 position in that situation.

1 Q. Where did you spend most of your time in 1992, in which area, in

2 which part of Cerska?

3 A. In 1992 I stayed in Skugrici and Cerska, and I remained there

4 until the area fell.

5 Q. Was there an armed group in Skugrici?

6 A. Yes. In Skugrici there was an armed group.

7 Q. Who headed that group?

8 A. This group in Skugrici was headed by Mirsad Sulejmanovic, Skejo,

9 that was his nickname.

10 Q. Please, do you remember how many armed men were in this group?

11 Can you describe this to us, what it looked like in the beginning, in May

12 1992, and all the way up to the fall of Srebrenica -- or rather, the fall

13 of Cerska, how all of this evolved.

14 A. This group of Mirsad Sulejmanovic, Skejo, in May and June of 1992,

15 I remember very well, had a total of 30 weapons available to them -- I'm

16 sorry. Just before the area fell, that is to say in 1993, after some

17 weapons had been seized or made at home, there was a total of 80 weapons

18 that they had.

19 Q. Please, now we're only talking about the group of Mirsad

20 Sulejmanovic, Skejo. This group that you belonged to, did it have any

21 type of military command for itself?

22 A. No, absolutely not. Not then, not later.

23 Q. Did the commander have assistant commanders, a deputy?

24 A. No, absolutely -- almost all the groups that we mentioned were

25 identical or similar. They had a leader, around whom they rallied, and no

1 other organs.

2 Q. Did you have a particular post in this group?

3 A. No. I had no particular position in this group except for the

4 fact that I was its member.

5 Q. Please, during 1992 were you a member of the staff of the armed

6 forces of Vlasenica during 1992?

7 A. No. I'm not aware of any such staff existing there.

8 Q. After August 1992 or at any time until Cerska fell, were you

9 assistant commander for morale?

10 A. No. I was no one's assistant ever. I cannot even explain this to

11 you what an assistant commander for morale is or does.

12 Q. Where were you, in which area, during the course of 1992? Where

13 did you spend most of your time, in which region?

14 A. During the course of 1992, I spent most of my time with my group

15 in Skugrici. When necessary, I went to other groups when we helped each

16 other out.

17 Q. Please, according to what you know, after August 1992 was there

18 some kind of staff or headquarters in Vlasenica that had its organ, for

19 example, an assistant commander for morale that had its own staff units,

20 et cetera?

21 A. No. I've never heard of any such staff and any kind of organs

22 that you referred to just now.

23 Q. Do you know whether Ferid Hodzic tried to organise something like

24 that?

25 A. Yes. I'm aware of his attempts, but I wish to repeat that that is

1 what they were, attempts only.

2 Q. Please, in the course of 1992 in Cerska, did you have trained

3 personnel or qualified personnel who could be staff members and make it

4 possible for that staff to function from a military point of view?

5 A. No, there were no trained personnel. I think that I already

6 mentioned once that in the entire area there was not a single professional

7 military man. The leaders of these groups and the members of these groups

8 for the most part were craftsmen, workers, factory workers, and so on.

9 Q. Please, were you a reserve officer, you yourself?

10 A. Yes, I myself was a reserve officer.

11 Q. Can you describe your actual line of work.

12 A. Yes. Atomic, biological, chemical warfare was my specialty and I

13 was trained for the detection of radiological rays and chemical agents,

14 and that's the only thing that I was trained for in the JNA.

15 MS. VIDOVIC: [Interpretation] Could the Prosecutor -- could the

16 usher please show us Prosecution Exhibit P123. This is a document issued

17 by the District Staff of the Tuzla defence dated the 29th of August, 1992.

18 Q. Could you please look at the heading where it says "Republic of

19 Bosnia and Herzegovina, Tuzla district Defence Staff," and then it

20 says: "Report on established staffs, institutions, and units of the armed

21 forces."

22 I will quote a part of the first paragraph which reads as follows,

23 this is the third sentence: "In connection with item 2 of your order, we

24 hereby inform you that we do not have the order to form units for any of

25 the staff of the Supreme Command of the Republic of Bosnia and

1 Herzegovina."

2 Mr. Dedic, from what I have just read, do you agree that it

3 follows from this that this document was compiled in Tuzla?

4 A. Yes, I agree.

5 Q. Would you now please look at page 4 in Bosnian.

6 MS. VIDOVIC: [Interpretation] Your Honours, that's page 9 in

7 English. The part that says "Vlasenica Defence Staff."

8 Your Honour, I do apologise; it's 6 in English.

9 JUDGE AGIUS: Page 6 -- page 6, usher, not 9.

10 MS. VIDOVIC: [Interpretation] Yes.

11 Q. Mr. Dedic, please look at the subtitle "Vlasenica municipal

12 Defence Staff." Look at items 4, 5, and 6, first of all. It

13 says: "Vlasenica TO detachment, Cerska TO detachment, and the Djile TO

14 attachment."

15 And then look at these numbers 439, 439, 439, referring to the

16 number of members, and then look at 1st Kladanj TO Company, 2nd Kladanj TO

17 Company, and under 9, Pobudje TO Company.

18 Please, can you comment on this document, this part of the

19 document, that is?

20 A. Yes. What it says here under point 4, Vlasenica TO detachment, in

21 my view might refer to a group from Vlasenica led by Mr. Hodzic. Under

22 number 5 where it says Cerska TO detachment I think it refers to the group

23 of Mr. Semso Salihovic.

24 And under point 6, Djile TO detachment, I think this refers to the

25 group led by Mr. Mekanic. The 1st Kladanj TO Company, however, and the

1 2nd Kladanj Company, I don't know what this might refer to because Kladanj

2 was about 80 kilometres away from Vlasenica and we had no connection

3 whatsoever with Kladanj. So I fail to understand why this is listed here.

4 Under 9 it says "Pobudje TO Company." I mentioned Pobudje

5 yesterday. There were armed groups there, but before the war and after

6 the war, Pobudje was part of Bratunac municipality and had nothing to do

7 with Vlasenica municipality. For this reason, I find this document odd

8 and strange. I think it's unreliable.

9 Q. Thank you. In the field in Cerska, did you use the

10 phrase "Territorial Defence"? I'm asking you about this because it's in

11 the document.

12 A. I wish to repeat. We never used such titles on the ground. The

13 names of the groups were exclusively linked to their places where they

14 operated.

15 Q. I will ask you the following now: During summer and autumn of

16 1992, the groups that you have just described, your groups, were they part

17 of the Srebrenica armed forces?

18 A. No. The groups I mentioned and described were never, either then

19 or later on, until the fall of these areas, part of any group from

20 Srebrenica.

21 Q. And with respect to your armed groups, were they part of the

22 Konjevic Polje groups?

23 A. No, they weren't.

24 Q. Did you help the people from Konjevic Polje sometimes or did they

25 help you?

1 A. Yes. There was assistance on both sides, but I wish to repeat

2 these instances of assistance were always and exclusively voluntary.

3 There was no order that we had to provide assistance to one another.

4 Q. Have you ever heard of a man called Nurif Rizvanovic?

5 A. Yes, I have.

6 Q. Can you tell Their Honours who he was?

7 A. Yes. This was a man who, in early August 1992, I think this was

8 on the 4th of August but I can't be a hundred per cent certain of the day,

9 arrived in Konjevic Polje from Tuzla. With him there arrived a group of

10 uniformed and armed men and, as I learned later, there were about 400 of

11 them.

12 Q. Have you heard of the name of this group of men which arrived with

13 him then? Was it a kind of Muslim brigade or not?

14 A. Yes, I did hear it. I heard that these were men from the 16th

15 Muslim Brigade.

16 Q. Did you personally have any contact with Nurif Rizvanovic ever?

17 A. Yes. I had contacts with him on two occasions personally. The

18 first time was in September 1992 and the second time in the same year but

19 in early October.

20 Q. Do you remember your first contact with him? Can you describe

21 this to Their Honours?

22 A. Yes. Mr. Rizvanovic from Konjevic Polje arrived in Cerska to see

23 Mr. Ferid Hodzic. After that, Mr. Hodzic summoned a certain number of

24 leaders of local groups and eminent people to a meeting in Cerska. At

25 this meeting, Mr. Rizvanovic introduced himself as the commander of some

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1 sort of Drina division, and he kept repeating to us that he had been sent

2 by some sort of command from Tuzla to form this division and that he was

3 its commander.

4 Q. Did you personally attend this meeting?

5 A. Yes, I did.

6 Q. Please, did he explain on that occasion what area the Drina

7 division was supposed to cover?

8 A. Yes, he did. He said that this division was supposed to cover the

9 areas of Zvornik, Vlasenica, Bratunac, and Srebrenica municipalities.

10 Q. Did he say whether he had a plan?

11 A. Yes. He mentioned this plan of his and the main focus of that

12 plan was that all these areas should be united, all the groups in those

13 areas should be brought together and the Drina division should comprise

14 all these groups.

15 MS. VIDOVIC: [Interpretation] Would the usher now please show a

16 document to the witness. This is document -- a document issued by the

17 defence administration of the Tuzla canton. The title is "The Republic of

18 Bosnia and Herzegovina, Armed Forces of Bosnia and Herzegovina, Command of

19 the Drina Division."

20 The document was signed by the commander of the Drina Division,

21 Nurif Rizvanovic and it's addressed to the attention of Mr. Ahmic. I will

22 quote part of it. It says here: "Pursuant to decision number 1-7/92 of

23 the 5th of September 1992, I was appointed commander of the Drina Division

24 for the municipalities of Bratunac, Zvornik, Vlasenica, and Srebrenica.

25 In view of this I would like to ask you to help me implement the following

1 decisions. A stamp should be made" --

2 JUDGE AGIUS: One moment because it's before she what you said,

3 Ms. Vidovic, I am sorry to interrupt you, but I think that this is

4 important. What you said was interpreted to us "to help me implement the

5 following decisions." What I have in the document or in the translation

6 of the document that you are seeking to tender says: "To help me

7 implement this decision." There is a slight difference, but I want to

8 know exactly what you said because I suppose you're reading, no?

9 MS. VIDOVIC: [Interpretation] Your Honour, this is an official

10 translation, but I will read again precisely what it says in the original.

11 It says: "In view of this, I ask you to make it possible for me to

12 implement these decisions," in the plural.

13 JUDGE AGIUS: All right. Okay. All right. Thank you.

14 MS. VIDOVIC: [Interpretation] 1 is: "Mass media should keep

15 repeating the order of the 9th of September, 1992, strictly confidential,"

16 I don't have to read every detail. Under 2: "A stamp should be made in

17 accordance with the decision and sent to me by courier.

18 3: "I hereby authorise Sead Djozic to open giro account on

19 behalf of the command. Itemise this for individual brigades from the

20 decision.

21 And then, for example, under 8: "I request to be given concrete

22 decisions by the command of the armed forces in Tuzla for the further work

23 of the division command in the free territory between Snagovo and Suceska

24 and Luka."

25 Mr. Dedic, first of all, do you know who Mr. Ahmic is.

1 A. Yes. Mr. Edhem Ahmic was the commander of some kind of groups

2 from Bratunac in Tuzla. He wasn't in Cerska, Konjevic Polje, or Skugrici

3 in that area.

4 MS. VIDOVIC: [Interpretation] Your Honour, my colleague has drawn

5 attention -- my attention to the fact that under 8 I request to be given

6 concrete decisions in Tuzla for further work of the division command in

7 the free territory from Snagovo to Suceska and Luka -- Suceska and Luka

8 are both mentioned in the original --

9 Q. And I apologise to you, Mr. Dedic, you have explained who

10 Mr. Ahmic was and I will ask you the following now. What it says in the

11 document, this document that is, "I have been appointed commander of the

12 Drina Division," does it correspond to what you were told by Nurif

13 Rizvanovic when he arrived in Cerska in 1992?

14 A. Yes, fully.

15 Q. Please, at that time in Cerska did he behave like someone who had

16 been authorised by a higher command to issue orders to you on the ground?

17 A. Yes, that's precisely how he behaved. In my contacts with him,

18 that was always the feeling I had.

19 Q. When did you see him again? What was the next time you met Nurif

20 Rizvanovic, could you describe it?

21 A. My second contact with Mr. Rizvanovic was in early October 1992 in

22 Skugrici. On that occasion he was visiting all the groups in the Skugrici

23 and Cerska areas.

24 Q. Did he say anything to you then?

25 A. Yes. On that occasion he observed how we had dug the trenches,

1 how we had made the lines, and he yelled at us. He told us it was no

2 good, and he gave us instructions as to how we should do this.

3 Q. Did you from Skugrici discuss this with Ferid Hodzic and other

4 people from Cerska, especially Ferid Hodzic?

5 A. Yes, we did. I and we talked to him and others, and we learned

6 later on that he had visited most of the groups in this area.

7 MS. VIDOVIC: [Interpretation] Your Honour, before I move on to the

8 next question, could we have an exhibit number for this document?

9 JUDGE AGIUS: Yes. What's the next number, please? D8 --

10 THE REGISTRAR: D822, Your Honour.

11 JUDGE AGIUS: Thank you. So this document which consists of two

12 pages in handwritten format without an ERN number in Serbo-Croat and a

13 corresponding translation into English on one page is being tendered,

14 received, and entered into the records as Defence Exhibit D822.

15 Yes, Mr. Wubben.

16 MR. WUBBEN: Your Honour, for the record we object to this

17 document regarding the authentication. We notice that it is the --

18 JUDGE AGIUS: You can do that when the witness is not present.

19 All right. I mean, just --

20 MR. WUBBEN: I will, Your Honour.

21 JUDGE AGIUS: Make a mental note of it and then you object to it

22 later.

23 MR. WUBBEN: Thank you.

24 JUDGE AGIUS: Yes, Ms. Vidovic, I'm sorry for the interruption.

25 MS. VIDOVIC: [Interpretation] Your Honour, I explained the source

1 of the document very clearly for the record and I believe that the

2 Prosecutor has the same document in their archives.

3 JUDGE AGIUS: Let's avoid discussion on this in the presence of

4 the witness, please, both of you. Let's proceed.

5 MS. VIDOVIC: [Interpretation] If the usher could give the witness

6 document 01837567. This is a document issued by the Republic of Bosnia

7 and Herzegovina, BH Armed Forces, combined Bratunac-Vlasenica-Zvornik

8 units command, and the date is the 26th of October, 1992. The title of

9 the document is "Combat Order."

10 Q. Witness, I will read the whole document to you.

11 "Having assessed the political and security situation in the free

12 territory of Bratunac, Vlasenica, and Zvornik municipalities, I have

13 decided to attack Grobic on the night of 27th to 28th October and return

14 it to the hands of the BH Armed Forces. Company commanders will introduce

15 the units of the attack from the rear by the way they know, after which

16 the soldiers will deploy for small arms combat and return to Grobic.

17 Commanders Semso, Becir, and Ferid are to take all necessary steps for

18 units to mount a general attack from the rear at 0700 hours in the

19 morning. According to this order, no soldier who was mobilised by the

20 general instrument of the 23rd of June may refuse. Anyone doing so will

21 be shot.

22 "Signed, Commander Nurif Rizvanovic."

23 I will ask you once again, when did Nurif arrive in your area, and

24 when he arrived did he behave as a commander issuing orders when visiting

25 your group, for instance?

1 A. Yes, he did. He always behaved like a commander, as the leader of

2 all the groups who had been active before his arrival. I often heard the

3 group leaders saying that he was issuing orders to everyone he had contact

4 with, acting like a commander.

5 Q. Thank you.

6 JUDGE AGIUS: One moment, because he hasn't answered specifically,

7 once you've ask the question again, when did Nurif Rizvanovic arrive in

8 your area. When was it that he showed up in your area?

9 THE WITNESS: [Interpretation] I didn't understand whether the

10 question was when did he arrive in the area or when did he arrive in

11 Skugrici, where I spent most of my time.

12 MS. VIDOVIC: [Interpretation]

13 Q. My question was -- well, you first described how Nurif Rizvanovic

14 arrived in Konjevic Polje in early August. You said the 4th of August.

15 Is this correct?

16 A. Yes.

17 Q. Then you described your first meeting with him in September 1992.

18 Is this correct?

19 A. Yes, it is.

20 Q. Your second meeting with him, when did it take place?

21 A. In early October in Skugrici. He arrived according to the plan he

22 kept talking about to tour the groups active in the field.

23 MS. VIDOVIC: [Interpretation] And my question, Your Honour, I

24 don't know how it was interpreted was:

25 Q. When he came to visit you in early October 1992, did he behave

1 like a commander and issue orders or not?

2 A. The answer to this question is: Yes, he acted like a commander.

3 Q. Thank you.

4 MS. VIDOVIC: [Interpretation] And, Your Honours, if this document

5 can be given on exhibit number.

6 JUDGE AGIUS: Yes. This document which consists of two pages, one

7 in Serbo-Croat with ERN 01837567 and the other one in -- corresponding

8 translation into English thereafter is being tendered, received, and

9 marked as Defence Exhibit D823.

10 MS. VIDOVIC: [Interpretation] Would the usher now show the witness

11 document P232, P232. This document is entitled "report by the commander

12 of the Vlasenica armed forces on the combat readiness of these armed

13 forces." And the number is 010828342 [as interpreted].

14 Q. Witness, would you please look at the beginning of the document

15 where it says: "From the beginning of the war in the area of organising

16 the units of the armed forces," it's a little illegible, "of Bosnia and

17 Herzegovina, we applied on several occasions to the competent staffs from

18 this part of the free territory, but the Tuzla District Staff of the armed

19 forces failed to find a way to cooperate so that five months into the war

20 a unified security and information service and RIK have not been

21 activated."

22 Can you explain to Their Honours what RIK means.

23 A. Yes, that is a unified system of control and command.

24 Q. Can you turn to page 2 of this document, please, and where it

25 says "conclusions," there are several bullet points. And the third of

1 these from the top says: "I hereby protest and do not accept the coerced

2 appointment of Nurif Rizvanovic of the Drina Division because it does not

3 reflect the situation." And this is signed by the Vlasenica OS commander,

4 Ferid Hodzic. Do you see this?

5 A. Yes.

6 Q. In connection with this I wish to ask you the following. Did the

7 local group leaders whom you referred to accept Nurif Rizvanovic as their

8 commander? Did they ever accept him as their commander, if you know?

9 A. No, certainly, never, because they thought he was imposed from the

10 outside. The local leaders, until his arrival, had had lots of problems

11 to deal with and had dealt with them without him.

12 Q. In your estimation, did the arrival of Nurif Rizvanovic worsen the

13 situation as far as the local leaders in Konjevic Polje and Cerska were

14 concerned or not?

15 A. To the best of my knowledge, after his arrival and after his

16 touring of certain groups, the situation grew worse. There was confusion

17 because he was imposing himself as the main leader of all the existing

18 groups in the area.

19 Q. One more question about this document. What it says here in this

20 document, does it -- does it confirm Ferid Hodzic's attitude to Nurif

21 Rizvanovic?

22 A. Yes, certainly it does.

23 Q. Thank you.

24 JUDGE AGIUS: Yes, can you, usher, put, please, the original -- or

25 the B/C/S version on the ELMO. The last page where the signature is,

1 please.

2 Mr. Dedic, are you familiar with Mr. Ferid Hodzic's signature?

3 THE WITNESS: [Interpretation] What I see before me -- well, it's

4 not very clear, so I couldn't say with certainty that it was his

5 signature. His signature was similar to this, yes, but I cannot be

6 absolutely certain it's his signature because it's not very clear here.

7 JUDGE AGIUS: All right. And what do the words just above the

8 name Ferid Hodzic and the signature mean, "komandant OS Vlasenica," what

9 does that mean?

10 THE WITNESS: [Interpretation] As far as I know and as I mentioned

11 earlier, Mr. Hodzic was the leader of a group of men who arrived with him

12 from Vlasenica and the settlements around Vlasenica. The other armed

13 groups in the area did not accept him. His idea until -- throughout the

14 time before the fall of these areas was to unify them, but let me repeat

15 he never succeeded in this.

16 JUDGE AGIUS: But I just asked you a very simple question that you

17 didn't answer. What is the meaning of the words "komandant OS Vlasenica"?

18 THE WITNESS: [Interpretation] What it says here, if he signed

19 this, he signed himself as the commander of the armed forces of Vlasenica.

20 JUDGE AGIUS: All right. And are you familiar with that stamp,

21 which seems to be of the municipality of Vlasenica? Do you recognise that

22 stamp?

23 THE WITNESS: [Interpretation] I can't see quite clearly what it

24 says here. "Municipal." I can't see every word here. It does

25 say "municipal staff," yes, "Vlasenica."

1 JUDGE AGIUS: Yeah, okay. Thank you.

2 Yes -- any further questions on this document, Ms. Vidovic?

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

4 JUDGE AGIUS: Then you can take it away, please, Ms. Usher,

5 Madam Usher, and then we can proceed.

6 MS. VIDOVIC: [Interpretation]

7 Q. Please, now I'm going to ask you something different. Do you

8 remember whether the beginning of November 1992 there were attempts to

9 link up the armed groups of Cerska, Konjevic Polje with those of -- and

10 Kamenica with Srebrenica -- sorry. I just need to go back to something

11 else that the Judge asked you about. The commander of the armed forces of

12 Vlasenica. Did I understand you correctly that your explanation was that

13 Ferid Hodzic headed the refugee groups that had come to Cerska from

14 Vlasenica?

15 A. Yes, precisely.

16 Q. Thank you. Now I am going to ask you this other question. At the

17 beginning of November 1992, attempts were made -- or rather, were attempts

18 made for the armed groups of Cerska, Konjevic Polje, and Kamenica to be

19 linked up to the Srebrenica armed groups?

20 A. Yes. Such an attempt was made.

21 Q. Do you remember what happened with this attempt and when?

22 A. Yes. I remember that we from the area of Skugrici and the area of

23 Cerska, at the beginning of November 1992 were invited to some meeting

24 that was held at the elementary school in Konjevic Polje.

25 Q. Please, do you remember who went from Cerska to Konjevic Polje?

1 A. Yes, I remember well. The leaders of some groups were there.

2 Among them was Mr. Besir Aljukic, Mr. Saban Muminovic, Mr. Ferid Hodzic.

3 I was there and some other prominent persons from Cerska and Skugrici were

4 there and at this moment I cannot remember their names.

5 Q. Do you remember who you found there?

6 A. Yes. We came there during the night because it was always risky

7 to go from Cerska to Konjevic Polje. We found a group of people from

8 Konjevic Polje there. Among them I recognised Mr. Veiz Sabic,

9 Mr. Dzemail Becirovic and Mr. Hamed Salihovic from Srebrenica --

10 Q. Do you remember whether anyone else from Srebrenica was there with

11 Mr. Hamed?

12 A. Yes. He was sitting in the middle. Next to him were two men whom

13 I do not know. They were from Srebrenica, they came from him. I don't

14 know their names.

15 Q. Did you know Hamed Salihovic from before?

16 A. Yes, I knew Mr. Salihovic from before. He was a teacher, a

17 geography teacher. I knew him from before the war, too.

18 Q. Do you remember whether Naser Oric was present during the meeting?

19 A. No, Mr. Oric was not at that meeting.

20 Q. Did you know Mr. Oric from before that?

21 A. I did not know Mr. Oric personally then or before the war either.

22 Q. Tell me, had you heard of Naser Oric before that?

23 A. Yes, I had heard of him during the war, that he was some very

24 young man from Potocari who was fighting like a lion, like a dragon from

25 Potocari.

1 Q. Did you hear of anyone else who was fighting in the area of

2 Srebrenica?

3 A. Yes. In addition to Mr. Oric, in the area of Srebrenica in a

4 village called Suceska, Zulfo Tursunovic was fighting. His nickname was

5 Cica. He had around him a certain number of armed men who were resisting

6 the enemy forces.

7 Q. How come you know that. Did you hear about that from someone?

8 A. Yes. I heard that during the summer from Mr. Mekanic. He was in

9 the area before he had to leave. He was near Suceska and he is the one

10 who told me about this, that there was a very brave, old man there

11 resisting the enemy.

12 Q. Now, I will take you back to the meeting that you mentioned that

13 you had come to. Do you remember whether Naser Oric was mentioned at that

14 meeting at all?

15 A. Yes, mentioned he was. Mr. Salihovic then gave some ideas to the

16 effect that Mr. Oric could, according to Salihovic's idea, be commander of

17 all the forces from Cerska, Kamenica, Konjevic Polje, and Srebrenica.

18 Q. Do you remember who did most of the talking at that meeting,

19 generally speaking?

20 A. Yes, absolutely. At all meetings related to such matters it was

21 Mr. Salihovic who did most of the talking.

22 Q. What was his idea then? Can you tell the Trial Chamber.

23 A. Yes. His idea was that all armed forces -- or rather, armed

24 groups from Skugrici, Cerska, Kamenica, Konjevic Polje, and Srebrenica

25 should be brought together, placed under a single command, because in his

1 opinion that was the only way to resist the enemy. Because this was a

2 time of very intensive attacks by the Serb forces in this area. To be

3 quite honest, I thought that this was a very good idea and a very

4 reasonable idea.

5 Q. During the month of November, did you attend any other such

6 meetings?

7 A. Yes. I attended two other meetings. We made a humongous effort

8 in order to get to Konjevic Polje because the situation was worsening by

9 the day. I think we managed to do that sometime by mid-November, but

10 after that we no longer managed to meet up.

11 Q. Do you remember these two meetings that you attended, do you

12 remember whether Oric was present?

13 A. As far as I know, no, or at least I did not see him where I was

14 sitting. I never saw him.

15 Q. What about the Hamed Salihovic?

16 A. Yes, he was always at all the meetings.

17 Q. Please, at these meetings were any decisions reached?

18 A. Yes.

19 Q. What kind of decision?

20 A. A decision was made to set up a War Presidency of the subregion,

21 and the president of this War Presidency would be Mr. Salihovic. And to

22 establish a staff of the armed forces of the subregion that would be

23 headed by Mr. Oric, as commander. And the Chief of Staff would be

24 Mr. Ferid Hodzic.

25 MS. VIDOVIC: [Interpretation] Could the usher please show the

1 witness an exhibit. It is P181. This is a decision of the War Presidency

2 dated the 4th of November, 1992. It was reached in Konjevic Polje.

3 Q. Can you see that?

4 A. Yes.

5 Q. Is that one of the meetings that you attended?

6 A. Precisely.

7 Q. I am going to quote part of this decision where it says: "The War

8 Presidency of the subregion of the municipalities of Srebrenica, Bratunac,

9 Vlasenica, and Zvornik at the session held in Konjevic Polje on the 4th of

10 November, 1992, municipality of Bratunac, reached a decision on joining

11 the armed forces of the municipalities of Srebrenica, Bratunac, Vlasenica,

12 and Zvornik into the joined armed forces of the subregion of the

13 municipalities of Srebrenica, Bratunac, Vlasenica, and Zvornik."

14 And the next part: "The armed forces of the municipalities of

15 Srebrenica, Bratunac, Vlasenica, Zvornik shall be subordinated to the

16 staff of the armed forces of the subregion of the municipalities of

17 Srebrenica, Bratunac, Vlasenica, and Zvornik."

18 In connection with this I will ask you the following: Does this

19 decision reflect what you said a few moments ago in terms of what had been

20 decided to join up the armed forces in the area?

21 A. Yes, fully.

22 Q. Were certain people elected to particular positions then?

23 A. Yes.

24 Q. You explained that Hamed Salihovic was elected president of the

25 War Presidency, Naser Oric and Ferid Hodzic to certain positions as well.

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1 So let us not repeat that. But I shall ask you the following. Were you

2 given some assignment there?

3 A. Yes. I was given an assignment to deal with certain

4 administrative matters in the subregion.

5 Q. All right. Please, to the best of your knowledge, did Hamed

6 Salihovic try as much as he could or did he not try to get this subregion

7 working?

8 A. Yes, absolutely.

9 MS. VIDOVIC: [Interpretation] Could the usher please show the

10 witness another document now.

11 Q. Just a moment, please. Perhaps this answer is not clear enough.

12 Please, my question was: To the best of your knowledge, did Hamed

13 Salihovic try to do everything that was within his ability to get this

14 subregion working and functioning?

15 A. Yes. My answer was yes. He worked on that. He wanted to get it

16 working. I repeat that this was his idea and remained his idea.

17 Q. Thank you. Can we now look at this document, please. This is a

18 document of the Republic of Bosnia and Herzegovina, Armed Forces of the

19 free territory from the 6th of November, 1992. The Prosecution number is

20 02995666, and it is a document that was signed on the left-hand side by

21 the president of the War Presidency of the subregion Hamed Salihovic and

22 it says: "To Commanders Oric and Semso Salihovic."

23 It says: "Order.

24 "In order to resolve the -- resolve the Srebrenica-Cerska

25 communication issues, you must provide accommodation and meals for (Halil

1 Mehmedovic). In this way the planned communications would be ready and we

2 would have a communications centre for Srebrenica. Together with the

3 above-named person, Senahid Baibic whom you have sent to be trained shall

4 work together with the above-mentioned person. It is necessary for you to

5 have two or three persons who will charge the generator and be in charge

6 of securing energy for the radio station. Persons who shall be

7 professionally competent to carry out these tasks. The person we are

8 sending has the professional expertise and has been trained to work since

9 it would take too long to train this person. Any problems that occur

10 shall be resolved by agreed communications."

11 Now, in relation to this document I'm asking you the following:

12 First and foremost, have you seen this document -- or rather, before I

13 showed it to you?

14 A. No.

15 Q. Do you know Hamed Salihovic's signature?

16 A. I do not.

17 Q. Please, do you know whether Hamed Salihovic did everything he

18 could for the communications service to start functioning between

19 Srebrenica and Cerska?

20 A. Yes. He tried to get this communication working because before

21 there were no communications between Cerska and Srebrenica. However, this

22 communication was never established, not even later.

23 Q. You understand that we are talking about radio communications

24 here?

25 A. Yes, yes, radio communications.

1 Q. Please, do you know about any orders being issued by Hamed

2 Salihovic to that effect?

3 A. Yes.

4 Q. Do you know this name Senahid?

5 A. Very -- I know it very well. He was a ham radio operator. He

6 went there on Mr. Salihovic's orders. He was supposed to be trained

7 there, but I repeat once again this communication was never established.

8 Q. All right.

9 MS. VIDOVIC: [Interpretation] Your Honours, may this document

10 please be given a number.

11 JUDGE AGIUS: Yes, certainly, Vidovic. This document which

12 consists of two pages, one in the Serbo-Croat language with ERN 02995666.

13 And the other with a corresponding translation into English is being

14 tendered, received, and marked as Defence Exhibit D824.

15 MS. VIDOVIC: [Interpretation]

16 Q. In relation to this area I'm going to put another question to you.

17 Did you talk to Mr. Semso Salihovic about Hamed Salihovic ever? In other

18 words, do you know that Hamed tried to issue orders to Semso in this

19 period?

20 A. Yes. Mr. Salihovic often said to me, That man is boring me to

21 tears with all his orders. I remember those comments.

22 Q. All right.

23 MS. VIDOVIC: [Interpretation] Could the usher please show the

24 witness D267. This is a report of the subregion of the municipalities of

25 Srebrenica, Vlasenica, Bratunac, and Zvornik, dated the 18th of November,

1 1992, sent to the Main Staff and to the public and it says "Subject:

2 Report."

3 Q. I am going to quote some of this document to you. It

4 says: "Facing the same problems and endangered by the same enemy, the

5 armed forces of Srebrenica, Bratunac, Vlasenica, and Zvornik have joined

6 ranks and placed themselves under one command. This is all because these

7 areas have been endangered both by Serbia and by the extremist part of the

8 SDS and are in -- are completely surrounded. Lately the aggressor has

9 been building up his armoured mechanised units along the Drina river,

10 particularly in Skelani and on the bridge across the Drina near

11 Bratunac."

12 And please, you can see down here it says: "President of the

13 subregional War Presidency, Salihovic," and you can see it says

14 here "received ham radio station, Sarajevo."

15 In connection with this I shall ask you the following. You said

16 to us a few moments ago that a decision had been passed to establish the

17 subregion on the 4th of November 1992. Is that correct?

18 A. Yes.

19 Q. Please look at this document now dated the 18th of November, 1992,

20 and it says there armed forces of Srebrenica, Bratunac, Vlasenica, and

21 Zvornik have joined ranks and placed themselves under a single command.

22 My question in relation to this is the following: Was this actually the

23 case, these units, these forces, these groups, call them what you will,

24 did they place themselves under a single command on the ground by the 18th

25 of November, 1992, that is to say within those 12 days? All of these

1 groups of Srebrenica, Bratunac, Vlasenica, and Zvornik. What is your

2 comment in relation to this?

3 A. I wish to note that the period when this document was written,

4 namely the 18th of November, 1992, was a period of intensive Serb attacks

5 at these areas. When communications were practically interrupted between

6 Konjevic Polje, Cerska, and Skugrici. It is practically impossible, at

7 least for me as a person who was a professional soldier, that somebody

8 could within 14 days carry out this kind of assignment, joining up armed

9 groups from four very distant municipalities, or rather four parts of

10 municipalities because these were not the entire prewar municipalities.

11 Over such a short period of time, in my opinion, that is impossible. It

12 is undo-able. On the contrary, as far as I know the situation on the

13 ground was far worse. People were even more separated from one another

14 because of enemy activities.

15 Q. Did I understand you correctly? In other words, are you saying

16 that the content of this document is not correct?

17 A. The content of this document is absolutely incorrect.

18 Q. Thank you. I'll ask you something else about this. You said that

19 Ferid Hodzic was elected Chief of Staff of the armed forces of the

20 subregion. In fact, to your knowledge did he ever start carrying out

21 these duties of Chief of Staff of the armed forces of the subregion?

22 A. No. He never carried out these duties. He was carrying out the

23 same tasks that he did from the moment he came to Cerska until its fall.

24 He was there and he was never in the role of Chief of Staff of the

25 subregion, as you said in your question.

1 Q. Please, you said that you were given some assignments in terms of

2 some administrative work for the staff. Did you ever do anything that had

3 to do with the subregion, any kind of work?

4 A. No. As far as that particular work is concerned, I did not write

5 a single word. May I just say one more thing? It's not that I wouldn't

6 want to do that, but it was impossible. I repeat once again, this was a

7 time of great difficulty and isolation for the area. So communication

8 always involved casualties and loss of human life.

9 Q. We're talking here about the 18th of November. Could you even get

10 to the area of Konjevic Polje?

11 A. From mid-November 1992, we were practically cut off from Konjevic

12 Polje, too. From time to time, people who were either very brave or, if I

13 may say so, totally crazy managed to get from one place to another.

14 Q. Thank you.

15 MS. VIDOVIC: [Interpretation] Could we now play D72, please. This

16 is part of the footage about the establishment of the Bratunac Brigade,

17 the 14th of November, 1992. Could it please be played from 00.02.27 until

18 the end. I think -- or rather, this is a video with subtitles. This is

19 the speech of General Milenko Zivanovic, the commander of the Drina Corps,

20 and you can see the translation there. Could you please play it now.

21 JUDGE AGIUS: Here he is. Let's proceed.

22 [Videotape played]

23 MS. VIDOVIC: [Interpretation]

24 Q. Please, Mr. Dedic, did you hear General Zivanovic in this speech

25 of his referring to the encircled 80.000 Turks of Podrinje? Did you hear

1 that?

2 A. Yes, I heard that.

3 Q. Tell us, please, do you agree that this word "the Turks" pertains

4 to the Muslims of the area?

5 A. Yes, that's what they called us throughout the war.

6 Q. The Serbs?

7 A. Yes, the Serbs.

8 Q. Please, did you notice the commander of the Drina Corps

9 saying "the Turks of Cerska cannot join up with the Srebrenica Turks nor

10 can the Kladanj Turks go to Cerska." This speech of his from November

11 1992, does it reflect the real situation regarding the encirclement of

12 Cerska and the isolation of Cerska and Srebrenica on the ground?

13 A. Yes.

14 Q. When you described the reasons for the impossibility of the

15 subregion beginning to function, was the main reason for this

16 impossibility the physical isolation between Srebrenica and Cerska, as

17 mentioned in this video?

18 A. Precisely so. The main reason was the total isolation of these

19 areas; they were cut off from each other.

20 JUDGE AGIUS: Yes, Mr. Wubben.

21 MR. WUBBEN: Objection, Your Honour, to the way, the manner, the

22 question is put to the witness. This is a form of guiding because so far

23 the witness hasn't used the word "impossibilities" and "reasons for

24 impossibility" and so forth. So at least it is a leading question, but

25 also it's guiding the witness to a certain extent.

1 JUDGE AGIUS: You're repeating what General Milenko Zivanovic

2 stated in his speech, that these people could no longer reach or

3 communicate with each other because they were encircled.

4 MR. WUBBEN: No, Your Honour, I refer to the first part of the

5 question, and I quote on line 30 -- no, page 35, line 14: "Question:

6 When you described the reasons for the impossibility of the subregion

7 beginning to function," those are not words that are used by --

8 JUDGE AGIUS: What had he stated before? What had he stated

9 before? He was asked whether this subregion ever functioned, whether

10 Ferid Hodzic ever functioned as Chief of Staff, whether this one ever

11 functioned or that one ever functioned. He was very categoric.

12 MR. WUBBEN: With all due respect, Your Honour, it's an

13 impossibility --

14 JUDGE AGIUS: Yes, Madam Vidovic, yes.

15 MS. VIDOVIC: [Interpretation] May I?

16 JUDGE AGIUS: Yes, I'm asking you.

17 MS. VIDOVIC: [Interpretation] May I respond, Your Honour? In

18 lines 25 and 26 in answer to my question, the witness said very clearly

19 that it was not possible for the subregion to start functioning.

20 JUDGE AGIUS: Which lines of which page?

21 MR. JONES: Your Honour, actually our sequence is maybe slightly

22 out because the answer was --

23 JUDGE AGIUS: Because I am less advanced than you are and my page

24 arrived to line 25 on each page. It never goes to 26.

25 MR. JONES: No. In fact, as I say, the reference which we have

1 here is -- in terms of page and line is not the best one. I think the

2 time should be correct, 15.37 ... In any event, the answer is, when he

3 was asked whether he did any of that kind of work. He said: "No, as far

4 as that particular work is concerned, I did not write single word. May I

5 just say one more thing? It's not that I wouldn't want to do that, but

6 it was impossible. I repeat again this was a time of great difficulty and

7 isolation of the area, so communication always involved casualties and

8 loss of human life." So he did mention an impossibility, at least for

9 him, to perform these functions.

10 JUDGE AGIUS: Anyway, I think we are wasting time.

11 Do you insist on your objection, Mr. Wubben?

12 MR. WUBBEN: No, Your Honour.

13 JUDGE AGIUS: Let's proceed.

14 THE INTERPRETER: Microphone, please.

15 MS. VIDOVIC: [Interpretation]

16 Q. Witness, let's clarify this once again. Please, in mid-November

17 1992, was it possible for any communication to take place between

18 Srebrenica and Cerska? And is the description provided by

19 General Zivanovic correct?

20 A. The description of the situation provided by General Zivanovic is

21 correct.

22 Q. Under such conditions, to the best of your knowledge, was it

23 possible for the subregion to function?

24 A. Absolutely not.

25 Q. Thank you. You described for us the situation of physical

1 isolation and separation in this area. Do you know of any cases where

2 some people did manage get through to Cerska from other areas?

3 A. Yes. There were such instances, but I know of only two.

4 Q. And what would happen for the most part with people trying to go

5 from Cerska toward Kladanj, for example, or from Cerska toward Konjevic

6 Polje and Srebrenica? What would happen to those people?

7 A. Unfortunately most such people never arrived at their destination,

8 and their fate remains unknown to this day.

9 Q. You told us that you knew of two instances where people managed to

10 pass through. Can you explain this to Their Honours?

11 A. Yes. A young man, whose nickname was Jastreb set out from Cerska

12 to Srebrenica. While I was in Cerska, he did not return. When Cerska

13 fell and I arrived in Srebrenica, I thought I would find him there. But

14 several months later I learned that he had again set out to Cerska but

15 never arrived there. Another case I know of is that of Mr. Kadir

16 Hamidovic, who sometime before Christmas 1993 arrived from Glogova to

17 Skugrici. He arrived alive.

18 Q. Very well. We'll come back to him, but let me ask you another

19 question pertaining to the subregion. After the fall of Cerska and your

20 arrival in Srebrenica, did you personally have occasion to talk to Hamed

21 Salihovic?

22 A. Yes. I spoke to Mr. Hamed Salihovic and he told me that

23 throughout that time he had been trying by way of Tuzla or Sarajevo to get

24 some kind of assistance for the people of Cerska and Konjevic Polje. He

25 was not, however, successful in this.

1 Q. Do you know whether he threatened the authorities of Bosnia and

2 Herzegovina with secession?

3 A. Yes. In the end he told me that he had even tried to get people

4 to understand the seriousness of the situation by saying that, but he was

5 not successful.

6 Q. Very well. I'll move on to another topic now.

7 MS. VIDOVIC: [Interpretation] Would the usher please show the

8 witness document P213, P213. The document is entitled "Republic of Bosnia

9 and Herzegovina, Srebrenica armed forces staff." The date is the 13th of

10 February, 1993, and the document reads as follows: "Pursuant to the

11 decree law issued by the Presidency of the Republic of Bosnia and

12 Herzegovina on general mobilisation and pursuant to the decision of the

13 War Presidency of the subregion on the general mobilisation of conscripts

14 from Srebrenica, Bratunac, Vlasenica, and Zvornik municipalities, as well

15 as with the consent of the chief of the Main Staff of the

16 Bosnia-Herzegovina army, Sefer Halilovic, I hereby order:

17 "All conscripts from the areas of Srebrenica, Bratunac, and

18 Vlasenica municipalities who are subject to military service and who are

19 at the front in the BH Army 2nd Corps area of responsibility shall come

20 immediately to the free territory of the subregion with their weapons.

21 "All organised units from the area of the above-mentioned

22 municipalities are to be informed about this already, namely the

23 following: Ahmet Duric, Latif Zalfalori, and others."

24 And this is allegedly signed by the Srebrenica armed forces

25 commander, Naser Oric. First of all, I will ask you the following. In

1 Cerska did you hear of any order issued by the subregion War Presidency on

2 general mobilisation in February 1993?

3 A. No, never. February 1993 was a period when no one could leave the

4 area in any direction. The whole area was pockmarked with shell holes,

5 and it would have been incredible for someone to bring such a document

6 there without getting killed.

7 Q. In the course of 1992, 1993, 1994, did you ever hear of the

8 existence of a decree law issued by the Presidency of the Republic of

9 Bosnia and Herzegovina, either in Cerska or Srebrenica, up to 1995?

10 A. No. I never heard of such a decree and, to be quite honest, the

11 first time in my life I heard of a decree law was in 2004 when I retired

12 under such a law.

13 Q. Did you ever hear of the existence of a decree law from anyone in

14 Srebrenica in 1992, 3, or 4?

15 A. No. I never heard of such a thing. And in 1995 when I went over

16 to the free territory, I never saw anything like that.

17 Q. Thank you. Would you now look at this part of the document where

18 it says that: "All conscripts from the areas of Srebrenica, Bratunac, and

19 Vlasenica municipalities who are liable for military service and who are

20 at the front in the area of responsibility of the BH army 2nd Corps should

21 immediately come with their weapons to the free territory of the

22 subregion."

23 Please, according to what you know about the situation in the

24 area, would this have been feasible?

25 A. By your leave, this order looks very odd to me. It's incredible.

1 For somebody from Srebrenica to issue orders to soldiers in the area of

2 responsibility of the 2nd Corps, that's one point; and another point is

3 that they should come immediately I travelled from Srebrenica to Tuzla for

4 eight days and eight nights. I don't know if that means immediately. To

5 me, in my view, "immediately" means something different.

6 Q. Have you ever heard of Ahmet Duric and Latif Zalfalori as some

7 kind of important people to whom such an order should be conveyed?

8 A. No, I never heard of either of these. And Zalfalori, as it says

9 in this document, I've never heard of such a name. This looks like Greek

10 to me. I never heard of anyone with such a name in the area where I

11 lived, Zalfalori.

12 Q. Very well. And on the basis of what you have seen, can you accept

13 this document as correct?

14 A. No.

15 Q. Thank you.

16 MS. VIDOVIC: [Interpretation] Your Honours, this is a convenient

17 moment.

18 JUDGE AGIUS: Yes. Let's have a half an hour break starting from

19 now. That means we will reconvene at 4.30. Thank you.

20 --- Recess taken at 3.59 p.m.

21 --- On resuming at 4.36 p.m.

22 JUDGE AGIUS: So --

23 MR. DI FAZIO: Your Honours --

24 JUDGE AGIUS: Yes, he's got good news. Mr. Di Fazio is --

25 MR. DI FAZIO: Yes, yes, yes.

1 JUDGE AGIUS: Yes.

2 MR. DI FAZIO: Good news. Yes, there's no problem. We can go

3 ahead with those tests to be conducted. I suggest that the case manager

4 from the Defence contact our case manager and we're in the process of

5 arranging the protocol or documentation that we intend to create to trace

6 the documents from here, from our possession --

7 JUDGE AGIUS: All right. Okay.

8 MR. DI FAZIO: -- to Sarajevo and back again and we'll get that

9 material ready and it can now go ahead.

10 JUDGE AGIUS: Just a moment. Perhaps you could copy and paste

11 this straight away and send it to Wade.

12 The other thing is, just to prepare you more or less for what the

13 decision will provide. The decision will provide first and foremost that

14 the registrar must communicate to us and to both of you the name of the

15 special representative that will actually be the one appointed to be in

16 charge of collecting the documents from your custody and handing them over

17 to the expert which will be -- who will be mentioned in the order itself.

18 Okay?

19 Secondly, there will be nothing in the order itself authorising

20 your expert to do anything, because that's your responsibility. We are

21 not appointing him, you are appointing him.

22 Thirdly, the -- that before delivery is affected, your expert will

23 need to identify himself, in other words the special representative must

24 be satisfied of the identity of the person who will receive these

25 documents, that is being the same person that is being appointed by you.

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1 And then when delivery is affected, is completed, then the special

2 representative of the registry will communicate to us the date and time so

3 that the month that we will be establishing for the completion of this

4 exercise will start running from that day. This is basically in essence,

5 et cetera, we were waiting for your information and now this needs to be

6 included in the draft that I handed to Mr. Pittman earlier on during the

7 break. Because, as you know, when we say we'll have a half an hour's

8 break, we usually don't include ourselves. And we end up doing work as

9 well. So let's continue with Mr. Dedic.

10 Do you think you will finish with him today or not, Ms. Vidovic?

11 I'm not calling upon you to finish with him today, but it's just a

12 question of trying to find out whether he can anticipate to go home on

13 Friday.

14 MS. VIDOVIC: [Interpretation] Your Honour, it might be possible to

15 finish today, but if I don't I will take only a brief time tomorrow.

16 JUDGE AGIUS: All right. That's perfect. So let's continue.

17 MS. VIDOVIC: [Interpretation]

18 Q. Mr. Dedic, I will go back to the events of Christmas 1993. In

19 your testimony you said that just before Christmas Kadir Hamidovic arrived

20 in Cerska from Glogova. Is that correct?

21 A. Yes, that's correct.

22 Q. Did he have any contact with you personally? Did you personally

23 have contact with him?

24 A. Yes, I did have personal contact with him because Mr. Hamidovic

25 has a sister who is married in Skugrici, and he would occasionally come to

1 visit her.

2 Q. Please, what exactly did he say to you when he arrived on the 7th

3 of January in Cerska, before the 7th of January that is?

4 A. Yes, he arrived before the 7th of January. And he told me that

5 the population of Glogova was taking refuge in Glogova Mountain, that they

6 were exposed to the cold. Quite a few of them had no footwear and no

7 food, and that they were living in very difficult conditions. He also

8 said that a group of people from the village of Glogova were in the

9 village of Cizmici where the leader of the group was, Mr. Ejub Golic.

10 Q. Did he tell you about any fighting in late December 1992?

11 A. Yes. Yes, he did. The inhabitants of Glogova who had been cut

12 off from each other were trying to link up again. And thanks to Mr. Golic

13 and the armed men with him, he managed to break through some Serb lines

14 and link up with the population of Glogova which was in the area of

15 Glogova and Glogova Mountain.

16 Q. Do you recall whether or not he mentioned any Serb units of

17 Kravica?

18 A. Yes, he did. He said that there were numerous forces in Kravica,

19 that apart from the local population of Kravica, there were also policemen

20 from Bijeljina, some units from the Krajina, and he even mentioned the

21 name of a certain Mauzer as far as I can recall.

22 Q. Do you recall whether he arrived only to visit his sister or

23 whether he brought some kind of message from Ejub Golic to somebody?

24 A. Yes, according to what he said I think that he only visited his

25 sister by the way, and that in fact he had come to ask for assistance for

1 the people whom I have just mentioned who were living in very difficult

2 conditions. And he also mentioned that Mr. Golic had sent people to other

3 places to ask for assistance because the inhabitants of Glogova were

4 surrounded, exposed to attacks and shelling, and the attacks were

5 especially fierce from Kravica.

6 Q. Please, did you find out whether anyone went from Cerska to

7 Kravica to help these people; and if they did, how did you find out about

8 it?

9 A. Yes, there were people from Cerska who went to help, because

10 Mr. Semso Salihovic, whom I mentioned before, was visiting the armed

11 groups looking for volunteers to go and help Mr. Golic and the population

12 of Glogova.

13 Q. Did Semso come to Skugrici looking for volunteers?

14 A. Yes. He spent some time in Skugrici, and he asked for men from

15 our group who wanted to volunteer and go to Kravica with him.

16 Q. Do you recall Semso's precise words which he said to you when he

17 came to see you in Skugrici? How did he explain the situation?

18 A. Yes. We spoke at length, and he told us that Mr. Golic and the

19 population of Glogova needed help. He also mentioned that it was in our

20 interests as well in Cerska to help the population of Glogova because we

21 were frequently shelled from the area of Kravica. Also, we found

22 ourselves in a very difficult time when there was literally no food in the

23 area. The only way to extend the agony by a few days or months was to try

24 and obtain weapons and food from the area.

25 Q. Very well. From this conversation with Semso Salihovic or with

1 Kadir, who you mentioned, who described the situation in Glogova to you,

2 did you gain the impression that the preparations for going to Kravica, as

3 asked by Semso Salihovic or Kadir, had anything to do with a decision of

4 the subregion or anyone's decision?

5 A. Absolutely not. We had not succeeded in contacting either the

6 subregion or anyone else in Srebrenica at the time.

7 Q. To the best of your knowledge, did you get any orders to go to

8 Glogova and Kravica?

9 A. Certainly not at that time, and I don't remember having received a

10 written order at any time to perform any kind of task.

11 Q. Do you know whether the fighters of Cerska went there, the armed

12 men of Cerska. Did they go there to the best of your knowledge?

13 A. Yes, I'm aware of that fact and I know that they did go to

14 Kravica.

15 Q. How many men went there, do you recall?

16 A. I don't know the exact number, but I think there were about 50 of

17 them.

18 Q. Were there people from Skugrici among them?

19 A. Yes. In this group there were men from Skugrici, I think very few

20 of them, only five or six.

21 Q. Please, were these men who volunteered to go there or did they

22 receive an order from someone to go there?

23 A. I wish to repeat once again, these were men who went there

24 exclusively as volunteers. In that period, nobody could have ordered

25 anyone to go to Kravica and carry out the task in Kravica.

1 Q. When Semso Salihovic was in question, could he have ordered you in

2 Skugrici to go to Glogova or Kravica? I'm referring to your group, not to

3 individuals.

4 A. Certainly not. Had anyone issued an order I'm sure they wouldn't

5 have obeyed it.

6 Q. Why not?

7 A. Because throughout this period all activities were voluntary and

8 because the men trusted the leaders who had been with them throughout this

9 time.

10 Q. Now I'm going to ask you something about that group in particular,

11 the one that went there. Were you in this group of people who went with

12 Semso to the area of Glogova and Kravica?

13 A. As for this group with Mr. Semso Salihovic, I was not there.

14 Q. To your knowledge was Besir Aljukic there?

15 A. No, Besir Aljukic was not there.

16 Q. Do you remember whether the people of Cerska followed this group

17 of armed people or not?

18 A. Yes. I can never forget that. People from all sides went in the

19 direction of Konjevic Polje, or rather Kravica. I think that at that

20 moment no one had stayed at home; everybody set out.

21 Q. Please, as far as Skugrici is concerned, did you try to stop the

22 people from Skugrici, telling them not to go? Did you consider that to be

23 risky?

24 A. Absolutely, yes. It was highly visible, there was snow. The

25 artillery could target them. We tried to prevent them from going but

1 absolutely did not succeed in this. I'm only sure that they could have

2 been stopped at gunpoint, that was my impression.

3 Q. Do you remember where you were on the 7th of January, 1993? You

4 were describing columns of people. Where did you watch this from, do you

5 remember?

6 A. Yes. Yes, I remember very well. On the 7th of January, 1993, I

7 was at Tumace, I mentioned that locality earlier on as well, and from

8 there, there is an excellent view of most of the area of Skugrici, Cerska,

9 Konjevic Polje, and the area towards Kravica. I repeat once again that it

10 was snowy. The visibility was very good. So from all sides vast masses

11 were moving about, men, women, children, et cetera.

12 Q. Except for these columns of civilians, women, children, et cetera,

13 could you see what was going on in Kravica? Did you have binoculars on

14 you or not?

15 A. Yes. I had a pair of binoculars from the beginning of the war.

16 My relative who was a hunter gave me these binoculars and that's how I

17 managed to see what was going on. I saw quite clearly how projectiles

18 were being fired from Kravica itself, from Siljkovici and from the

19 surrounding hills. Soon after that there was a great deal of noise

20 throughout the valley.

21 Q. How long did you stay at Tumace?

22 A. On that day, that is to say the 7th of January, 1993, I was at

23 Tumace almost until night fall.

24 Q. Please tell the Trial Chamber why were you at Tumace actually?

25 A. I went there for a single reason with a group of armed men. If

1 there were to be any Serb attacks, we could intervene on time and we could

2 not be caught by surprise.

3 Q. If I understood you correctly, you spent the day at Tumace. On

4 that day, the 7th of January, 1993, until night fall, did you see Kravica

5 burning?

6 A. No. I did not see Kravica burning at all. On the surrounding

7 hills I saw one particular plume of smoke or two, but I don't think that

8 it came from Kravica.

9 Q. Please, when these people came back, these people who had left

10 Skugrici as volunteers, that's what you said, did you talk to them about

11 fighting?

12 A. Yes.

13 Q. What did they tell you? Where was it that they fought?

14 A. They told me that together with a group led by Mr. Semsudin

15 Salihovic they fought at Siljkovici. And from there, they managed to

16 repel the Serb forces.

17 Q. Is this the same Siljkovici you mentioned as the location from

18 where the artillery was constantly firing at Cerska?

19 A. Yes, that is the place from where Cerska was being shelled all the

20 time until then.

21 Q. Do you remember whether you found out from them whether they

22 managed to capture an artillery piece or any weapons?

23 A. Yes, I know about that. Quite a bit of infantry weaponry was

24 seized - I don't know the actual numbers - and also a ZIS was brought in

25 from Siljkovici. This is the gun that we mentioned yesterday, if I

1 remember correctly.

2 Q. In the Serb document?

3 A. Yes, the document that you showed me, yes.

4 Q. Please, do you remember what was going on over the following days.

5 Were you at Tumace or not?

6 A. During the following days - practically the following ten days,

7 I'm almost sure of that - columns of people, thousands of people were

8 streaming towards Kravica trying to get food and trying to continue the

9 agony of their lives, as I mentioned a few moments ago, as there was a

10 total shortage of food where they lived.

11 Q. How come you know that civilians went there over the seven days

12 after the 7th of January, 1993?

13 A. I repeat that I lived in the area. I saw civilians who brought

14 food in, transported it in different ways. So there was a lot of snow, as

15 I said, but then they managed to drag supplies from Kravica on the snow.

16 Q. Do you know whether civilians got killed this way?

17 A. Yes, of course. There were many such cases. I remember one

18 particular case. I attended his memorial service. Aljo Korkutovic is the

19 name of the deceased. He went to Kravica and he didn't come back for a

20 day or two. Later on his wife and his relatives found out that a corpse

21 was there. They brought him back from Kravica dismembered. He was at the

22 entrance into a Serb house.

23 Q. Did you find out what his actual cause of death was?

24 A. I cannot confirm that with any degree of certainty, but on the

25 basis of what the body looked like, most probably he tried to enter a

1 house that had been mined because there was visible damage on the house

2 where he got killed, too.

3 Q. Please, this case of house-mining, was it an isolated case or have

4 you heard of other such cases?

5 A. No, there was not an isolated case. Unfortunately there were

6 many, many more such cases.

7 Q. Apart from food that you said was brought in from Kravica, did you

8 notice civilians bringing something else in over the next several days?

9 A. Yes. I did notice that a lot of people brought roof tiles because

10 an enormous number of houses had their roofs damaged from the shelling.

11 Also, they brought in doors and windows in particular because there was

12 very, very little glass on any windows. They were all shattered during

13 the shellings of Cerska and Skugrici in the spring and summer. Also

14 people brought in cattle feed and many other things they could find there.

15 Q. All right. As you were describing the situation there, the broken

16 roofs, the lack of doors and windows, you meant the roofs and windows and

17 doors in Cerska. Right?

18 A. Yes, Cerska, Konjevic Polje, Skugrici, that is to say in Muslim

19 settlements.

20 Q. Thank you. Please, now I'm going to ask you about something

21 different. Did you have any knowledge as to whether anyone had planned an

22 attack on Kravica?

23 A. No. I had no knowledge whatsoever, and I'm not aware of anyone

24 ever planning any kind of activity like that.

25 Q. Did you know anything about the role of Ferid Hodzic that could be

1 linked to these events in Kravica?

2 A. No.

3 Q. Did you know anything about the role of Muhamed Cikaric in these

4 events?

5 A. No. As for Muhamed Cikaric I did not even know him at the time.

6 Q. Did you know anything about the role of Naser Oric in these

7 events?

8 A. I absolutely did not know anything.

9 Q. Now I'm going to ask you the following. Did you work as an

10 investigator on a project of the General Staff of the Army of Bosnia and

11 Herzegovina in 1996 and 1997 that has to do with combat operations of the

12 Army of Bosnia-Herzegovina?

13 A. Please, this question is not clear to me at all. Can you clarify

14 what this means, being an investigator.

15 Q. Did you research data on a project of the General Staff of the

16 Army of Bosnia-Herzegovina that had to do with the combat operations of

17 the Army of Bosnia-Herzegovina during the war? During 1996 and 1997, did

18 you work on that project?

19 A. No, no, never. I never worked on any such project.

20 MS. VIDOVIC: [Interpretation] Could the usher please show the

21 witness P88. This is a form, a list of combat operations pertaining to

22 Kravica, and it also has an ERN number, 02621529.

23 Q. Could you please look at the last page, the first entry where it

24 says "Ejub Dedic." Could you please have a look at this. It says "Ejub

25 Dedic," and then underneath it says "researcher."

1 Is that your name?

2 A. Yes, that is my name.

3 Q. Is that your signature?

4 A. No, this is not my signature.

5 Q. Please, could you look at the handwriting on this entire form.

6 Did you fill it out?

7 A. No. This is not my handwriting.

8 Q. Please take a look at everything that is written on the left-hand

9 side of the last page of the document. Can you tell whether the

10 handwriting is the same or not? Everything that is written underneath

11 your name, 1, 2, 3.

12 A. Truth to tell, the handwriting on the left-hand side seems very,

13 very similar to me. I think that this is the handwriting of a single

14 person.

15 Q. All right. Can you recognise anybody's signature here?

16 MS. VIDOVIC: [Interpretation] Yes, perhaps we could place the

17 document on the ELMO.

18 JUDGE AGIUS: I think -- that's why I was intervening because I

19 think that is appropriate for us to be able to follow better and for the

20 public to be able to follow better.

21 MS. VIDOVIC: [Interpretation]

22 Q. Please, I asked you whether you recognised any of the signatures

23 of the other signatories.

24 A. No. I don't recognise any of these signatures.

25 Q. Please look at the date here. Tuzla, the 29th of May, 1997. And

1 it says "the 28th Division" down here.

2 Can you remember May 1997 and who the commander of the 28th

3 Division was at the time?

4 A. Yes. I remember very well. The commander of the 28th Division in

5 the period that you are referring to now was Mr. Salih Malkic, nickname

6 Sale.

7 MS. VIDOVIC: [Interpretation] Could the usher please try to raise

8 the document a bit so that the signature can be seen. Fine. Thank you.

9 Q. Please, did you have occasion to see Salih Malkic's signature, the

10 commander of the 28th Division?

11 A. Yes, many times.

12 Q. Is this his signature?

13 A. Absolutely no, it doesn't even bear a resemblance to his

14 signature.

15 Q. Thank you. Thank you. Now I'm going to ask you whether you know

16 anything about this particular form and similar forms. Is there anything

17 that you can recall in relation to this?

18 A. Yes.

19 Q. Can you tell the Trial Chamber what it is that you can remember.

20 A. I remember that in the mentioned period, in the period that is

21 written in the document, Mr. Aljukic and I were asked to come to the

22 division by a young man. I can't remember his name. I think he worked at

23 the 28th Division. We sat with him and he told us that in the Army of

24 Bosnia-Herzegovina there was a project underway about some activities and

25 that units -- or rather, about what units and groups did during the course

1 of the war. According to what he said, it was my understanding that he

2 wanted Mr. Aljukic and me to try to help him in that endeavour so that he

3 could do the job. After that, he went on talking about that, and in

4 relation to these documents pertaining to the project, as you mentioned,

5 he referred to Kravica most of the time.

6 Q. Did I understand you correctly that he asked you about particular

7 battles, Kravica included?

8 A. Yes. He mentioned other ones, but Kravica most of the time.

9 Q. Did I understand you correctly that he was asking about how these

10 combat activities evolved?

11 A. Yes. He had a notebook, and he put some questions to us in terms

12 of what happened and how things happened, where, how many people were

13 there, how many weapons were there, questions of that nature. Since

14 Mr. Aljukic and I pointed out that neither one of us were direct

15 participants in this activity, we said that we could not give him this

16 kind of information.

17 Q. Please, I'd like to ask you the following now. Did you tell this

18 gentleman the same things that you told us today in relation to Kravica,

19 that you only viewed certain things going on from a distance?

20 A. Yes.

21 Q. So what did you tell him exactly?

22 A. I told him the date, I told him where I was, I told him what the

23 tentative number of people involved was, because I didn't know the exact

24 number, when they went, when they came back, what happened after these

25 activities in Kravica. Only what I told you during the course of the

1 proceedings, before I received this document.

2 Q. Do you remember what Mr. Besir Aljukic said, a person you know

3 well, right?

4 A. Yes, I remember very well that he said the same thing that I said

5 to you just now, that he was not a participant there, that he cannot give

6 any information regarding what this gentleman was interested in.

7 Q. All right. To the best of your knowledge, did Besir Aljukic work

8 on this project?

9 A. No, absolutely. He worked at an elementary school at the time.

10 He was not in the military at all. He worked in an elementary school.

11 Q. All right. But what I'm asking you is the following: After

12 talking to this particular man from the 28th Division, did you ever talk

13 to Mr. Besir Aljukic about this? Did you ever comment on this project?

14 A. Yes. After we left this gentleman, we discussed the project and

15 this document, what was -- what this was all about. I didn't quite

16 understand it anyway.

17 Q. I'm just wondering if I have understood what you said. You are

18 talking about a form. Did you see a form that was filled out the way we

19 see it here and now or did you see an empty form?

20 A. Until now I did not see this kind of filled-out form. There's

21 some numbers here --

22 Q. We'll get to the numbers.

23 A. No, no. I just held an empty form in my hands. It was not filled

24 out, no.

25 Q. Please, you mentioned these numbers now. Can you have a look at

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1 these numbers. For example, look at page 1 where it says the forces of

2 the subregion and then number 150 and the Kamenica detachment number 100,

3 then Bratunac-Milici Brigade, 500. Then please move on to page 3. Look

4 at the engaged forces, 250; and then manpower, about 500 Chetniks; and

5 then light weapons, about 500; heavy weaponry, 20. Could you please tell

6 us something about these numbers. Can you give us your comment. Are the

7 figures always rounded off? Do you have a comment in this regard?

8 A. It's incredible that all the numbers were rounded off, as you just

9 said. Personally I think that they were written just like that. It's

10 absolutely arbitrary, unfounded. Somebody just wrote it pro forma in

11 order to have this form filled out.

12 Q. For example, did you hear of 50 Serb combatants being killed in

13 Kravica?

14 A. No. This is the first I have ever heard of this.

15 Q. Thank you.

16 MS. VIDOVIC: [Interpretation] You can take the document from the

17 witness now.

18 Could the usher please somehow the witness another document now.

19 JUDGE AGIUS: Yes. While the document is prepared -- which

20 document do you want to show the witness so that we prepare it?

21 [Trial Chamber confers]

22 JUDGE AGIUS: Which document is it? Is it a new document or an

23 existing exhibit?

24 MS. VIDOVIC: [Interpretation] New document, a new one.

25 JUDGE AGIUS: Go ahead with your question, Judge Eser.

1 JUDGE ESER: Just for clarification, could you please put back the

2 last page of the Bosnian version. This is signatures.

3 Now, Mr. Dedic, you told us that the names on the left side are

4 written -- seem to be written by the same hand. Do you only refer to the

5 very left side or would you also say that the names right of the left

6 side -- to the left side are of the same hand? Do you know what I mean?

7 You see your name, Ejub Dedic, and then right further on you see it again,

8 and the same is done in all the other cases.

9 THE WITNESS: [Interpretation] Yes.

10 JUDGE ESER: And would you suppose that all of these names are

11 written by the same hand, the left line as well as the right column of

12 names?

13 JUDGE AGIUS: In other words, if you allow me --

14 THE WITNESS: [Interpretation] Yes.

15 JUDGE AGIUS: I think he's understood it.

16 I just want to make sure one thing, that what you're saying

17 basically means that whoever wrote down the names on the left-hand side of

18 the left part of this document also, according to you, wrote those

19 signatures afterwards or next to those names? Is that what you're saying?

20 THE WITNESS: [Interpretation] Yes. Yes, Your Honour. It's very

21 similar. I find the handwriting under number 1 and 2 very similar on the

22 right-hand side, whereas the third one is a bit less discernible because

23 it's very small.

24 JUDGE AGIUS: I just want to make sure that I am understanding

25 correctly because your question, Judge Eser, is very important.

1 Look at the first two, all right. There is under [B/C/S spoken]

2 there is number 1, Ejub Dedic. And then next to it there is Dedic. While

3 Ejub Dedic is an indication of the name, "Dedic," which is next to it

4 seems to be the signature of that person. Then there is Mirsad

5 Sulejmanovic, and that indicates who the person is. And then next to it

6 there is Sulejmanovic, a signature of supposedly this Mirsad Sulejmanovic.

7 Are you telling us that you believe that all this, all that appears under

8 number 1 and 2, that is the indication of the name plus the signature, was

9 done by one person and not by two different persons?

10 THE WITNESS: [Interpretation] Your Honour, as far as I can see, I

11 think that it is the handwriting of a single person.

12 JUDGE AGIUS: Okay. All right. And are you also as categoric as

13 you have been so far with regard to the next list now -- no, no, no,

14 it's -- sorry, the name side. Besic and -- I can't read it -- Becirevic

15 and Mevludin. There you see -- what is KC and KV? What does that mean?

16 Ms. Vidovic, if you can help us, what does KC and KV mean?

17 MS. VIDOVIC: [Interpretation] I think that KC could mean commander

18 of a company and KV could be [B/C/S spoken], platoon commander, as far as

19 I understand this. However, Your Honour, I think there may be a

20 misunderstanding. I asked the witness whether he signed it and I asked

21 him about the names that were written; I did not deal with it this way.

22 JUDGE AGIUS: He did make a statement that to him the handwriting

23 on both sides was identical or similar, and we need to clear this because

24 if what is -- he is saying is correct it is a forging of signatures and

25 you can't classify it in any other different manner.

1 MR. JONES: He's not an expert at the same time, Your Honour.

2 JUDGE AGIUS: But he's telling us that according to hip --

3 MR. JONES: I trust Your Honours aren't trying to take a point of

4 credibility against this --

5 JUDGE AGIUS: No, not all; I'm just establishing what he wants to

6 tell us. I'm just establishing what he wants to tell us. Because telling

7 us that it's the same signature on the right and on the left to us is not

8 exactly clear, and that's why I thought the question by Judge Eser was

9 very pertinent and important. And now he's confirming that, according to

10 him at least, as regards 1 and 2, whoever wrote it -- according to him --

11 I'm not taking it as an expert opinion or -- or an affirmation of -- that

12 this is so. He is not -- and I don't think he's come here pretending to

13 be a calligraphic expert.

14 MR. JONES: I'm trying to follow the relevance.

15 JUDGE AGIUS: The relevance being that he is telling us that these

16 documents are not to be taken as genuine documents signed by the persons

17 who are allegedly to have signed them.

18 MR. JONES: But only an expert can say whether a signature is a

19 forgery.

20 JUDGE AGIUS: Certainly, yes.

21 MR. JONES: He said what he said about the documents.

22 JUDGE AGIUS: We're not moving further than this. It's just to

23 establish what he meant when he said that the handwriting on both sides

24 was similar. Right.

25 Yes, let's continue.

1 MS. VIDOVIC: [Interpretation]

2 Q. Let's just clarify what you saw. Is it in your handwriting and is

3 the signature yours? Let's clarify that. When it said "Dedic, Ejub," was

4 that your handwriting and was the signature your signature?

5 A. As for the first and last name Ejub Dedic and the signature that

6 follows it, this is certainly not my handwriting.

7 Q. Thank you. And you're quite sure that it's not the signature of

8 the commander of the 28th Division down here?

9 A. I'm absolutely sure, 100 per cent.

10 Q. Thank you, Mr. Dedic.

11 MS. VIDOVIC: [Interpretation] Would the witness now -- could the

12 witness be shown a document issued by the command [Real time transcript

13 read in error "commander"] of the Drina Corps. It's a combat order the

14 number is 0284986.

15 JUDGE AGIUS: The commander or the lieutenant colonel? Because

16 the commander, I think, was someone else - no? - of the Drina Corps?

17 MS. VIDOVIC: [Interpretation] Your Honour, I am saying the command

18 of the Drina Corps.

19 JUDGE AGIUS: I got it as the commander, at least if you look at

20 line 10 it says "witness be shown a document issued by the commander of

21 the Drina Corps." That's why I pointed that out. I accept it that you

22 mean the command. Let's proceed.

23 MS. VIDOVIC: [Interpretation] The command, yes.

24 Q. Witness, this document bears the number 04284986 and the title

25 is "combat order" issued by the Drina Corps chief of artillery to the

1 commander of the KAG. And I will quote point 1.

2 "In counter-offensive operations the enemy has managed to take

3 part of the territory that had previously been controlled by corps units

4 and has inflicted serious losses on our units, the sector of Sase,

5 Kravica, Mount Glogova, Skelani, Sehitovi [phoen], the general Rudo

6 sector."

7 Mr. Dedic, you were familiar with the situation in the Cerska area

8 and you had information about what was happening in Glogova, which you

9 received from the person you mentioned, and you spoke to the men fighting

10 in the Kravica area. So my question is as follows: To the best of your

11 knowledge, according to what you saw and heard, is it correct what it says

12 here that the enemy - and this refers to the Muslims - has managed in

13 counter-offensive operations to take part of the territory that had been

14 controlled by corps units including the area of Kravica and Glogova.

15 According to your experience was this a Muslim counter-offensive

16 operation?

17 A. Yes. The content of this document in this respect is correct;

18 that is, what is mentioned in this order in this connection is correct.

19 Q. Thank you. I will now out paragraph 2 of the same document.

20 "The task of our Corps is to use auxiliary forces on the current

21 lines to tie-up the enemy forces as much as possible, and to use main

22 forces to switch to active combat operations on the following axes:

23 Milici - Suceska - Podravanje village, Zvornik - Kamenica - Cerska,

24 Olovo - Kamenica village, Rudo - Medjedja village, and Rogatica - Medjedja

25 village. Be in a state of readiness defence immediately and for attack by

1 0600 hours on the 24th of January, 1993."

2 Please, do you remember January 1993 in the Cerska area were you

3 attacked on the 24th or thereabouts in 1993?

4 A. Yes, I remember well. We were attacked throughout January 1993

5 but towards the end of this month the attacks grew much more intense.

6 Q. And finally I will read paragraph 3 of this documents which

7 says: "The KAG composed" -- and you told us that KAG -- well, can you

8 tell us again what KAG refers to, if you know.

9 A. Yes. The acronym means corps artillery group.

10 Q. "The KAG group, composed of the 133-millimetre Howitzer battery

11 bVBR, 122-millimetre shob, 152-millimetre th, shall support the active

12 operations of the Corps' main forces on the following axes: Milici -

13 Suceska village - Podravanje village, and Zvornik - Kamenica - Cerska as

14 required, and shall use barrage fire if requested to prevent surprise

15 breaches by strong enemy forces at the main points of effort in the

16 defence."

17 In these attacks in January 1993, did Serb infantry attacks get

18 support from artillery, as mentioned in this document?

19 A. Yes in this respect what the document states is correct.

20 MS. VIDOVIC: [Interpretation] Your Honour, may this document be

21 given a Defence Exhibit number?

22 JUDGE AGIUS: Yes, this document, Ms. Vidovic, will be given

23 Defence Exhibit number D825. It consists of two pages in the Serbo-Croat

24 and two pages in English. The ERN number is 04284986 to 987.

25 MS. VIDOVIC: [Interpretation]

1 Q. Witness, do you remember what happened from end of January 1993

2 onwards in the areas of Cerska and Konjevic Polje, briefly?

3 A. The situation from the end of January onwards deteriorated very

4 fast.

5 Q. This entire area of Cerska, Pobudje, Konjevic Polje, did it come

6 under attack?

7 A. Yes. The entire area was attacked on a daily basis, and the

8 encirclement grew ever tighter.

9 Q. What happened in mid-February 1993 or around that time, do you

10 recall?

11 A. Yes. Around the middle of February the situation in Skugrici and

12 Cerska areas became so bad that it was really a cause of concern because

13 there was constant shelling -- there were constant infantry attacks. The

14 population began to flee towards Konjevic Polje. They couldn't get

15 through. They came back. And unfortunately, many of them were killed or

16 seriously wounded.

17 Q. Tell Their Honours when the Serbs finally managed to break down

18 the resistance of Cerska?

19 A. The resistance of Cerska was finally completely broken down at the

20 end of February and in the first ten days of March, 1993.

21 Q. What happened to the people?

22 A. After the takeover of this area by the Serb forces, the people set

23 out toward Konjevic Polje -- excuse me. May I go on? Before the arrival

24 of these unfortunate people, they were already deluged with refugees and

25 had problems similar to ours.

1 Q. Do you recall any events at the crossroads on the way to Konjevic

2 Polje?

3 A. Yes. The crossroads at Konjevic Polje, which links Zvornik,

4 Vlasenica, and Srebrenica, was a place where dozens of people were killed

5 or wounded. I saw corpses and carcasses along the road. A lot of

6 personal effects scattered about, parts of human bodies. According to

7 what I saw, there must have been at least 50 dead in one day.

8 Q. Dead?

9 A. Yes.

10 Q. Do you remember what happened to the elderly and infirm who on

11 that day did not manage to flee from Cerska, including the old men who

12 remained in the Cerska primary school?

13 A. Yes. As the situation had rapidly deteriorated I went to Cerska

14 where my brother was. He was working in the Cerska doctor surgery, and we

15 barely managed to reach the school which was some 200 to 300 metres away

16 from the health centre. And we couldn't get in because there was shelling

17 from all sides. As I had been in Cerska before, I knew that there were

18 about 20 elderly and infirm people inside the school. They couldn't move.

19 We were unable to help them unfortunately and they remained behind.

20 Q. Do you know what happened to them?

21 A. Unfortunately I don't -- or rather, unfortunately I don't know

22 that any of these people survived. I'm not aware that any of them turned

23 up alive afterwards.

24 Q. After the war, to this day?

25 A. No. To this day I don't know of any survivors from that group.

1 Q. Are you personally aware of the fact that the events in Cerska,

2 including the murder of the elderly men in the primary school in Cerska,

3 was reported to Philip Morillon? Who arrived at that time.

4 A. Yes, I'm certain of that. I personally saw Mr. Morillon and at

5 that time he went to Cerska in an APC escorted by several uniformed

6 soldiers wearing blue helmets on their heads. He went there at our

7 request, the request of the local people, to see what was happening in

8 Cerska.

9 Q. Mr. Dedic, before we go on, my question to you was, it's not all

10 in the record: Did you know that Philippe Morillon who had arrived there

11 with his collaborators had been informed of this?

12 A. Yes, I knew very well that he was aware of that.

13 Q. And his collaborators, were they told of this?

14 A. Yes, they were.

15 Q. Can you tell us what you know about what Mr. Philippe Morillon,

16 with his associates, did in this connection?

17 A. Yes. By your leave I'll repeat briefly what I said. He and his

18 associates went in an APC in the direction of Cerska, and in Cerska he

19 stayed only a few hours, in my estimation. And I was there when he came

20 back from Cerska, and I recall well that he said that the situation on the

21 ground in Cerska was not nearly as bad as the Muslims had described, that

22 it was much better, that there were many houses which could be inhabited,

23 although there were houses on fire.

24 Q. And how did you, Muslims, respond to this? What was true in fact,

25 what you are telling us today or what Morillon said then?

1 A. Unfortunately, Mr. Morillon, in my view, didn't see what was going

2 on there or didn't want to see what was going on. The truth is what I'm

3 telling you.

4 MS. VIDOVIC: [Interpretation] Would the usher now please play a

5 video clip. It's part of P427 [Realtime transcript read in error "P426"],

6 3284122. I wish to mention that we have prepared a transcript which we

7 will distribute and we have also given it to the interpreters so that the

8 interpreters can read it in accordance with Your Honour's ruling of

9 yesterday. We are now waiting for the transcript to be distributed.

10 JUDGE AGIUS: Thank you, Madam Vidovic. The Trial Chamber

11 appreciates that.

12 MS. VIDOVIC: [Interpretation] I'm not hearing the interpretation.

13 Q. Witness, are you receiving interpretation of what His Honour said?

14 A. No.

15 MS. VIDOVIC: [Interpretation] Your Honour, let's make sure that

16 the interpretation is functioning properly.

17 JUDGE AGIUS: All right. Thank you for pointing that out. I

18 couldn't have known about it if the witness himself doesn't --

19 MS. VIDOVIC: [Interpretation] It's all right now.

20 JUDGE AGIUS: Are you receiving -- okay.

21 Mr. Dedic, are you receiving interpretation of what I'm saying?

22 THE WITNESS: [Interpretation] Yes.

23 JUDGE AGIUS: All right. So we can go ahead.

24 Thank you, Madam Vidovic.

25 MS. VIDOVIC: [Interpretation] Can you play the video, please.

1 [Videotape played]

2 MS. VIDOVIC: [Interpretation] Your Honour, we will show part of a

3 video clip beginning on 44.12 to 46.52.

4 [Videotape played]

5 MR. JONES: I think we need to ask the booth for sound.

6 JUDGE AGIUS: Yes, I'm not receiving any sound myself.

7 [Videotape played]

8 THE INTERPRETER: The interpreters note that the sound is too low

9 and that we can't hear.

10 JUDGE AGIUS: On the part of the Prosecution, do you contest the

11 transcript in English that we have here? Because if you don't accept it

12 as reflecting what is being said in Serbo-Croat on the screen, we

13 obviously have to find a remedy.

14 MR. WUBBEN: Please bear me a moment.

15 [Prosecution counsel confer]

16 [Trial Chamber confers]

17 JUDGE AGIUS: I don't know if it is possible -- what I can suggest

18 is this because I know that the media player that is being used has a

19 limit, and beyond that it doesn't go. But our earphones, they can amplify

20 the reception. So if -- I'm just suggesting for a while that we go

21 through the first part again when allegedly Semso Salihovic is speaking,

22 and everyone tries to augment or to increase the sound level of the

23 earphones that we are using.

24 MS. VIDOVIC: [Interpretation] Your Honour, it would be very

25 important for the witness to have the volume turned up.

1 JUDGE AGIUS: Yeah, but usher can help him. In the meantime,

2 please, while this is being done I suggest that no one speaks so that we

3 take care of each other's eardrums.

4 [Videotape played]

5 THE INTERPRETER: [Voiceover] "This is what they're going to do

6 with the Chetniks up there. They're going to ask for how many days these

7 people are going to be able to keep up? These people have no where to

8 go ... Is Serbia really stronger than the world, or has the world decided

9 to choke these people? Really if you could make any sense of it, could

10 you tell me?

11 "I'm only one Dusko. I'm not the whole world.

12 "I know you're not."

13 Your Honour, the interpreters note that this is inaudible.

14 JUDGE AGIUS: Hold it for a moment. I agree. I mean, I have got

15 my volume full on and I can't hear a word in -- that is being said on the

16 screen. Yeah, but the important thing is that the witness needs to hear

17 the words that both this gentleman over here and allegedly Semso Salihovic

18 are saying. I mean, I could follow part of Semso Salihovic's speech, but

19 I couldn't go any further than that.

20 [Prosecution counsel confer]

21 JUDGE AGIUS: I don't know if there is. I mean, I'm not a

22 technical man. I mean, I can use my ...

23 MS. VIDOVIC: [Interpretation] Your Honour, in fact it's what Semso

24 Salihovic is saying that matters to us, but I think we heard this well in

25 Bosnian. I did. Let's hear what the witness says.

1 THE WITNESS: [Interpretation] Yes, I heard what Mr. Salihovic was

2 saying very well.

3 JUDGE AGIUS: All right. Do you want to proceed and -- yes --

4 okay.

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

6 JUDGE AGIUS: Please, the interpreters will bear with us. Again,

7 I suggest that we try to increase the volume to the maximum and that no

8 one speaks after we have done that.

9 [Videotape played]

10 THE INTERPRETER: [Voiceover] "Does the world know that these

11 people are choking? ... The world knows what to do to choke Islam in this

12 region. The world sends Philippe Morillon, who is a true Chetnik ... And

13 what the people here are fighting with, 30.000 people? They are fighting

14 with small guns. Do you know how many fighters I lost for this gun?

15 Exactly ten fighters."

16 MS. VIDOVIC: [Interpretation] That's sufficient. Thank you.

17 Q. Witness, please, did you manage to hear what Semso Salihovic was

18 saying?

19 A. Yes, I heard well.

20 Q. First of all, is this Semso Salihovic, can you confirm that?

21 A. Yes, absolutely, this is Mr. Semso Salihovic.

22 Q. Please, from this part of the video clip from what he himself is

23 saying, did you understand him to be saying that the international

24 community is -- has been tolerating the actions of the Serbs for a year

25 and that they have been given permission to destroy the Muslims in the

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7

8

9

10

11

12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.

14

15

16

17

18

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20

21

22

23

24

25

1 area? Did you hear that?

2 A. Yes, and I heard and understood that very well.

3 Q. His standpoint, his attitude of mistrust towards Morillon and his

4 associates, does it reflect the attitude of the people in the areas of

5 Cerska and Konjevic Polje toward Morillon and his associates, at least to

6 the best of your knowledge?

7 A. Yes, to the best of my knowledge -- the answer is absolutely yes.

8 Q. Mr. Dedic, is it quite clear from what Semso Salihovic said to the

9 representatives of the international community that the Muslims in the

10 area were being faced with extinction?

11 A. Yes, that's quite clear.

12 Q. And did this extinction actually occur?

13 A. Unfortunately, yes, it did occur.

14 Q. According to what you who were in the area during 1992 and 1993

15 saw and experienced, was it completely clear to all of you that you were

16 threatened with destruction?

17 A. Yes. I'm completely sure of that, yes.

18 Q. Please, Semso Salihovic said here -- he said something else as

19 well. He showed a rifle and he said: "Can you see ten people were killed

20 for this rifle?"

21 Tell Their Honours to what extent this is correct, what

22 Mr. Salihovic was saying, that people paid for weapons with their lives?

23 A. I cannot confirm with certainty that ten men were killed for the

24 rifle that Mr. Salihovic was showing. He probably knows that. But I am

25 quite certain that not a single rifle we captured or took from Serb

1 soldiers in various ways fell into our hands without being paid for by at

2 least one human life.

3 Q. How many men in your estimation after the events we saw on this

4 video clip and after the Konjevic Polje and Cerska, how many people went

5 to Srebrenica in early March 1993?

6 A. I couldn't tell you the exact number because no one knew the

7 precise number of these people. But I am sure that there were several

8 tens of thousands.

9 Q. Can you tell Their Honours briefly what happened in March and

10 April 1993 in the entire area.

11 A. Yes. The arrival of vast numbers of refugees from Zvornik,

12 Vlasenica, and Bratunac municipality in Srebrenica was followed by

13 continued Serb attacks on the Srebrenica area. Very soon after that, the

14 Serb forces succeeded in taking control of most of Srebrenica municipality

15 so that thousands of additional people who had been living in their

16 villages in Srebrenica municipality now came to the centre of the town of

17 Srebrenica. In these attacks, the Serb forces were so close to the town

18 of Srebrenica on one side that they could target people with a

19 submachine-gun in front of the department store which is in the centre of

20 the town of Srebrenica.

21 Q. And what could you say about March 1993, what word would you use

22 to describe it, in Srebrenica?

23 A. March of 1993 in Srebrenica meant the total encirclement and

24 blockade of Srebrenica. It was completely, hermetically cut off.

25 Q. After these events, according to your knowledge, was the

1 Srebrenica area demilitarised?

2 A. Yes. After this there following the demilitarisation of the

3 Srebrenica area; I know that well.

4 Q. And for you who had weapons, what did demilitarisation mean?

5 A. For me personally and for other people who had weapons,

6 demilitarisation meant that we had to hand over our rifle and sleep

7 peacefully because the war was at an end. There would be no more military

8 activity in the area. That's what I understood it to mean.

9 Q. And did you hand over your weapons?

10 A. Yes, I did.

11 Q. But were there people who did not hand over their weapons and what

12 happened to these people? Can you describe the actions of the

13 international forces and especially of DutchBat in relation to these

14 people?

15 A. Yes. I know very well that a large number of men who had weapons

16 handed over their weapons right away, but there were also those who didn't

17 want to do that for various reasons. However, I noticed and observed

18 personally that members of DutchBat very often -- very soon began forcibly

19 confiscating weapons from individuals who had weapons. Let me mention one

20 example by your leave, something I saw personally. When Dutch soldiers

21 caught a young man who was carrying a rifle, they pulled him about to such

22 an extent that all the buttons came off his jacket. They confiscated his

23 rifle and then they beat him with fists and with the rifle on his face,

24 and I saw this with my own eyes. And there were other cases like this.

25 Q. When did you personally learn for the first time about the

1 attempts of a military organisation in Srebrenica?

2 [Trial Chamber confers]

3 THE WITNESS: [Interpretation] The -- I learned about such an

4 attempt in early 1994.

5 MS. VIDOVIC: [Interpretation]

6 Q. On the basis of what did you find this out, do you remember?

7 A. Yes, I did. People were saying that an order had arrived in

8 Srebrenica from Tuzla that units were to be established comprised of men

9 who had arrived in Srebrenica from various sides.

10 Q. Do you remember the name of this formation?

11 A. Yes, I remember well. In the documents that arrived from Tuzla,

12 this formation was supposed to be called the 8th Operations Group of

13 Srebrenica, and it was supposed to comprise light brigades.

14 Q. Before the 1st of January, 1994, did you know of any military

15 activities in Srebrenica, you personally?

16 A. Yes. I knew about the activities of the members of the

17 international forces. They were there, they were moving about, doing

18 things, but those were the only activities I observed or knew about.

19 Q. Thank you?

20 MS. VIDOVIC: [Interpretation] Your Honours, before I move on to my

21 next question, can this transcript be given an exhibit number?

22 JUDGE AGIUS: Yes, certainly, Madam Vidovic. But before we do

23 that I must register something with regard to the transcript. It seems

24 that -- I don't know which line it is, now I have lost track of it. But

25 the video that we -- an extract of which we followed came on the

1 transcript as -- shown in the transcript as being Exhibit 426, P426. In

2 actual fact it is P427. So for the record that is a correction that I am

3 making myself.

4 This would be now 427.1 --

5 MS. VIDOVIC: [Interpretation] 27.

6 JUDGE AGIUS: Registrar, how would you prefer this to be marked,

7 the transcript of --

8 THE REGISTRAR: Yes, Your Honour, it's a Defence exhibit, so D826.

9 JUDGE AGIUS: D826. So this transcript in both languages, in

10 Serbo-Croat and in English consisting of two pages in toto is being marked

11 as Defence Exhibit D826.

12 MS. VIDOVIC: [Interpretation] Thank you very much, Your Honour.

13 Q. Please, did Ferid Hodzic come with you from Cerska to Srebrenica,

14 do you remember?

15 A. Yes. I remember very well. Mr. Hodzic, when Cerska fell into

16 Serb hands, did not go towards Srebrenica. With a rather large group of

17 men, I think that there were about 200 of them based on what we've known

18 since then, went in the direction of Kladanj and actually arrived there

19 with them.

20 Q. Did Mirsad Sulejmanovic, in this case named Skejo, the leader of

21 the group from Skugrici go with you?

22 A. No, Mr. Mirsad Sulejmanovic, Skejo, when this group fell took an

23 even larger group of people, most of them young, armed, went to Tuzla via

24 Baljkovica. So he was not there either and he didn't try to enter

25 Srebrenica.

1 Q. Do you remember what happened to the group from Kamenica?

2 A. Yes, yes, I do remember. Also, a large group people from Kamenica

3 did not come to Srebrenica. They went to Tuzla. I'm sorry, let me just

4 finish. Among the groups that were leaving this area that were not going

5 to Srebrenica, there were people from Konjevic Polje, too.

6 Q. Let us just clarify the matter. When we are talking about these

7 groups, is it your understanding that I'm asking you about armed groups.

8 Do you understand this?

9 A. Yes, yes, armed groups. Because covering a couple of hundred

10 kilometres unarmed would have been totally impossible and unacceptable.

11 Q. Thank you.

12 MS. VIDOVIC: [Interpretation] Could P31 please be shown to the

13 witness now. This is a document of the 1st of January, 1994, from the

14 General Staff of Sarajevo. It is called organisational changes, formation

15 of RJ, in the zone of responsibility of the 2nd Corps.

16 Q. Witness, please, look at this document. It is dated the 1st of

17 January, 1994. "I hereby order:

18 "Organisational Changes:

19 "Formed the 8th Operations Group in Srebrenica," and then the

20 light brigades that you mentioned. And finally I will stop at

21 subparagraph F.

22 "Establish the 284th Eastern Bosnian Light Brigade with its

23 headquarters in Srebrenica, according to T-412.240. The newly formed

24 brigade will have numerical code and T-31329 and VJ number 6342, its

25 mobilisation duration will be 20 hours. A unit in charge of the

1 mobilisation plan will be 284th Light Istocnobosanska Brigade. The 284th

2 Light Eastern Bosnian Brigade will consist of the 114th Eastern Bosnian

3 Brigade, the 1st Cer Detachment and the 6th Detachment of Kamenica."

4 Please, as you were giving evidence a few moments ago, you said

5 that a large number of people precisely from these groups out of which the

6 284th Light Brigade was supposed to be established went to Tuzla and

7 Kladanj, including the commanders, the persons you called leaders of

8 groups, rather. Ferid Hodzic, Sulejmanovic, Skejo. Please, as you read

9 this document, can you reach a conclusion as to whether people in Tuzla

10 and Sarajevo had the right kind of information at all about the situation

11 in Srebrenica on the 1st of January, 1994, when this was written, when

12 this order was written.

13 A. Absolutely not. Because most people who took part in the war who

14 were young, who were able-bodied, who had weapons, left. It is primarily

15 people who did not dare venture on such a journey came to Srebrenica. So

16 they came for completely different reasons. So there were very few people

17 in Srebrenica at all who had participated in the war in Cerska before its

18 fall.

19 Q. Please, what about the 114th Eastern Bosnian Brigade, what did

20 that denote, if you know?

21 A. I think that this was the name for armed groups from Konjevic

22 Polje.

23 Q. Please, while giving evidence several times you said that you had

24 occasion to travel to Konjevic Polje. During the course of 1992 until the

25 fall of Konjevic Polje in March 1993, to your knowledge was there a

1 brigade there from a military point of view, in the military sense of the

2 word?

3 A. No, no, never. I wish it did exist, though. What was there had

4 nothing to do with what a brigade would really look like from a military

5 point of view. There would have to be military facilities, barracks,

6 trained personnel. A brigade has to have professionals, proper personnel.

7 They'd have to have logistics, too, and they didn't have any because

8 Cerska -- it was under a total blockade.

9 So there was no appropriate personnel and there weren't any

10 logistical possibilities for establishing a brigade. It could have only

11 existed in name, but there really was nothing that could be called a

12 brigade there.

13 Q. Please, during January in 1994, were you called somewhere to talk

14 about the establishment of the 284th Brigade?

15 A. Yes, I was called by Mr. Veiz Sabic. I remember he was there.

16 Then I remember there was a man from Kamenica. Trso was his name. His

17 leg was shorter. I don't remember his first name. We sat there and

18 talked about the establishment of brigades in Srebrenica.

19 Q. Please, do you know whether any of you had received orders in

20 writing in terms of an appointment to any post in this brigade?

21 A. As for myself, I can say for sure that I never received any order

22 appointing me to any post in this brigade. As far as I know, I'm not

23 aware of anyone else having received such orders either.

24 Q. Can you remember what Veiz told you about what you were supposed

25 to be in that brigade?

1 A. Yes, I remember. He said to me that in that brigade I should be

2 appointed Chief of Staff of that brigade.

3 Q. Please, did you take any measures? Did you do anything that can

4 be related to the establishment of this brigade?

5 A. Well, yes, we did work. We started making lists of these persons,

6 able-bodied men, who arrived from these areas to Srebrenica. We wanted to

7 see who it was that arrived, what age they were, et cetera. In my

8 opinion, this was a list of men who were in the territory of Srebrenica

9 and that's what it was basically.

10 Q. Please, when you wrote these lists of these men who would belong,

11 say, to the 284th Brigade, did you have in mind any previous participation

12 in fighting or did you simply make lists of people who were present there

13 right then?

14 A. No, no, no. We simply recorded people who arrived in Srebrenica,

15 who happened to be there after these persecutions, nobody else.

16 Q. When you say "people," are you referring to able-bodied men?

17 A. Yes, able-bodied men who had come to Srebrenica.

18 Q. Please, to the best of your knowledge, what about the other

19 so-called brigades that you saw on paper here, was the same done

20 basically? Were such lists made?

21 A. We talked amongst ourselves because we were in a relatively small

22 area. The situation was the same, identical, in other cases, too.

23 Q. Please, can you describe to the Trial Chamber how in this

24 situation of demilitarisation this brigade functioned until the fall of

25 Srebrenica, with the exception of what you said just now that you listed

1 the persons or personnel involved.

2 A. I repeat once again very clearly, there were no military

3 activities as far as this brigade is concerned or any other brigade.

4 Everything that was done in this domain was to list able-bodied men, and

5 I've already spoken about that.

6 Q. In other words, everything that was done was -- was it on paper

7 or --

8 A. Yes. Everything that was done in relation to the brigade that is

9 mentioned here was only on paper. There was absolutely nothing in

10 practice.

11 Q. And let me ask you now, as regards this brigade, the 284th

12 Brigade, did you ever get your own barracks, logistics?

13 A. No, no. I wish to point out once again that in Srebrenica there

14 are no barracks. The only logistics we had in Srebrenica at all was

15 Operation Parachute. Most of us made torches out of paper and cellophane

16 and went out at night, and those were the greatest activities that we were

17 engaged in, in Srebrenica.

18 Q. Please, do you remember whether you report reports to anyone about

19 the activities of the brigade higher up, say to this 8th Group?

20 A. I don't see any point. Why should we write reports when we did

21 nothing? I don't remember writing any report except that perhaps

22 sometimes we may have said to someone, We have the list that was required.

23 Q. Please, did you have a military police and a security organ

24 established as such? I am referring to the 284th Brigade.

25 A. No. There was no military police then because the existence of

1 the military police and its functioning was explicitly forbidden once the

2 international forces arrived.

3 Q. Security organ?

4 A. As far as I can remember, there was one man, one person, who was

5 appointed security organ on this list that I mentioned, Fadil Dedic, a man

6 who worked in the bauxite company. On paper he was there, but he didn't

7 do anything in this regard.

8 Q. Please, in 1993 and 1994, what did you do yourself? Did you do

9 anything else except for what you told us now about Operation Parachute?

10 A. In Srebrenica, when possible, I also worked at the elementary

11 school because I am a teacher by profession. So that was what I mainly

12 did, working at school and providing food for myself and for my family.

13 MS. VIDOVIC: [Interpretation] Your Honours, I would like the

14 witness to look at a document now, unless it's too late. I don't know

15 what your plan is. How long should we work today? Well, then P280 can be

16 shown to the witness.

17 JUDGE AGIUS: If I were to voice the wish of everyone present, I

18 would probably ask you to stop here. But however, I think we can

19 afterward to dedicate a couple of more minutes to finish with this next

20 document and then you can wind up for the day. All right. How long is it

21 going to take you?

22 MS. VIDOVIC: [Interpretation] Your Honour, I would be very happy

23 to break off at this point because I am a bit tired myself and I believe

24 that the witness must be tired, too.

25 JUDGE AGIUS: Yes, I don't blame you, Madam Vidovic. I think

1 everyone is.

2 So we'll give you a rest, Mr. Dedic.

3 How much more time will you require tomorrow, more or less? I'm

4 asking you in order to give Mr. Wubben an indication.

5 MS. VIDOVIC: [Interpretation] Up to half an hour, not more than

6 half an hour, Your Honour.

7 JUDGE AGIUS: All right. Given that Ms. Vidovic is -- sticks to

8 that schedule, do you think you would be in a position to finalise your

9 cross-examination by the end of business on Friday, Mr. Wubben?

10 MR. WUBBEN: Of --

11 JUDGE AGIUS: I'm asking you so that if you're not we'll make

12 arrangements.

13 MR. WUBBEN: I'm not in a position to give you a guarantee like

14 such, but it seems to me what whenever it is 30 minutes that I might --

15 might finalise, and I'll do my best for that. But again, no guarantees

16 given.

17 JUDGE AGIUS: Thank you.

18 So Mr. Dedic will now be escorted out of the courtroom. Please,

19 may I remind you of my recommendation to you, or my order to you, not to

20 communicate or let anyone communicate with you with regard to the subject

21 matter that you are testifying about. Thank you.

22 Tomorrow we are sitting in the morning. I think it's in this same

23 courtroom. Yes. 9.00 in the morning. Thank you.

24 --- Whereupon the hearing adjourned at 6.15 p.m.,

25 to be reconvened on Thursday, the 13th day of

1 October, 2005, at 9.00 a.m.

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