Tribunal Criminal Tribunal for the Former Yugoslavia

Page 6113

1 Tuesday, 28 May 2002

2 [Open session]

3 [The witness entered court]

4 --- Upon commencing at 9.01 a.m.

5 [The accused entered court]

6 JUDGE AGIUS: Can you call the case, please, Madam Registrar.

7 THE REGISTRAR: Yes, Your Honour. This is the case number,

8 IT-99-36-T, the Prosecutor versus Radoslav Brdjanin and Momir Talic.

9 JUDGE AGIUS: Good morning, Mr. Brdjanin. Can you hear me in a

10 language that you can understand?

11 THE ACCUSED BRDJANIN: [Interpretation] Good morning, Your

12 Honours. I hear and I can understand you in a language I know.

13 JUDGE AGIUS: Thank you. Please sit down.

14 General Talic, good morning to you. Can you hear me in a language

15 that you can understand?

16 THE ACCUSED TALIC: [Interpretation] Good morning, Your Honours.

17 And I can hear you in a language that I understand.

18 JUDGE AGIUS: I thank you, General Talic. You may sit down.

19 Appearances for the Prosecution.

20 MR. CAYLEY: Good morning, Mr. President, Your Honours. Andrew

21 Cayley for the Prosecution with case manager Denise Gustin.

22 JUDGE AGIUS: Thank you, and good morning to you.

23 Appearances for Radoslav Brdjanin.

24 MR. ACKERMAN: Good morning, Your Honours. I'm John Ackerman.

25 I'm with Tanja Radosavljevic and Milan Trbojevic.

Page 6114

1 JUDGE AGIUS: Good morning to you.

2 Appearances for General Talic.

3 MS. FAUVEAU-IVANOVIC: [Interpretation] Your Honours, I am Natasha

4 Fauveau with Masson Fabien. I represent General Talic.

5 JUDGE AGIUS: They confused your gender and your name this

6 morning.

7 Yes. Good morning, sir. We are going to continue with your

8 testimony today. And before we do so, I would kindly ask you to repeat

9 the solemn declaration that you made yesterday. Thank you.

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

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


13 [Witness answered through interpreter]

14 JUDGE AGIUS: I thank you. You may sit down.

15 Mr. Cayley, when you're ready, you may start.

16 MS. FAUVEAU-IVANOVIC: [Interpretation] Mr. President.

17 JUDGE AGIUS: I'm sorry, Mr. Cayley.

18 Yes, Madam Fauveau.

19 MS. FAUVEAU-IVANOVIC: [Interpretation] Simply to inform the

20 prosecutor that I reviewed the statement of the witness yesterday

21 regarding the killing in Kraljevica. As far as I understand, that

22 statement contains information that we do not accept, and I would like the

23 witness to appear. If nevertheless the Prosecutor wishes to tender the

24 statement through 92 bis, I would request that the witness be present for

25 the cross-examination.

Page 6115

1 JUDGE AGIUS: Mr. Cayley, I know that this is more -- is it your

2 compartment or is it Ms. Korner's?

3 MR. CAYLEY: I can deal with this, Your Honour. We'll call the

4 witness. We'll call the witness. But it does mean -- I'll deal with the

5 order of witnesses at the end, because that witness, 7.76, was actually

6 the third witness in the list after this witness. But now we're going to

7 have to rearrange the list. But I'll give you the definitive list at the

8 end of today's session.

9 JUDGE AGIUS: If necessary, since -- anyway, we'll come to that

10 when we come to it. So the witness will be brought over.

11 MR. CAYLEY: Yes.

12 JUDGE AGIUS: Thank you. You may proceed with your examination of

13 the witness, please. Thank you.

14 MR. CAYLEY: Thank you.

15 Examined by Mr. Cayley: [Continued]

16 Q. Mr. Karabeg, let me just remind you where we left off yesterday.

17 We had reached the 19th of April of 1992, and you had just started to

18 speak about the ultimatum that you had received from Mr. Rasula. Could

19 you tell the Judges of the events as you remember them of what happened in

20 the municipal building after you received that ultimatum and what you did.

21 A. On the 19th of April, 1992, somewhere approximately 9.30 p.m.,

22 Rasula called Suad Sabic and said that he is setting an ultimatum and that

23 by 22 hours we go out of the building and go into the park, lay down the

24 arms, hand ourselves over, and that nothing will happen to us. But if we

25 don't do that, we -- the building of the municipality will be attacked.

Page 6116

1 We accepted the ultimatum to think over what our options are. We were on

2 the windows -- looking through the windows, and through the windows we

3 could see the movement on the right side of the building. And he said

4 from the direction of Djedovaca a bigger column of cars is coming. We

5 knew that that was Colonel Basara from Lusci Palanka with the 6th Krajina

6 Brigade, which was stationed there. At that point we agreed to exit from

7 the side exit door, and most of us left for the village of Sehovci the

8 nearest village to Sanski Most, and a smaller group left for Gornja

9 Mahala, upper Mahala.

10 MR. CAYLEY: If the witness could be shown Prosecutor's Exhibit

11 757.2, which is the map of Sanski Most.

12 Q. But while that is being taken care of, let me ask you a question.

13 You said in your evidence "and he said from the direction of Djedovaca, a

14 bigger column of cars is coming." Who said that a column of cars was

15 coming from Djedovaca?

16 A. A -- a person who was looking through the window and could see

17 this column of vehicles.

18 Q. If you could put the map of the projector next to you. Now, did

19 you yourself see this column of vehicles?

20 A. Yes, indeed I did.

21 Q. Now, you were in Sanski Most. Can you show the direction from

22 where this column of vehicles was coming from.

23 A. The column of vehicles was coming from the direction of Lusci

24 Palanka. So it's -- along the normal road would be Lusci Palanka,

25 Miljevci, Gorica, Naprelj, Kamengrad, Donji Kamengrad, Podbrijezje.

Page 6117

1 Meanwhile this column was coming from the opposite direction, from Lusci

2 Palanka to Jelasinovci, Stanici, Djedovaca, Sanski Most. The map doesn't

3 show this road. Lusci Palanka to Jelasinovci, Gonji Dabar and Sanski

4 Most.

5 Q. At what point on that route were you able to observe these

6 vehicles?

7 A. We could notice the column of vehicles maybe some five minutes

8 after receiving the ultimatum.

9 Q. Whereabouts was the column of vehicles when you saw it? How far

10 away from Sanski Most?

11 A. This column was at a distance of some 2 kilometres from Sanski

12 Most. That's the hill -- a hill, and they were descending the hill

13 towards the valley of Sanski Most.

14 Q. So the column was 2.000 metres away from where you were observing

15 it from; correct? Approximately.

16 A. Yes, approximately.

17 Q. How high from the ground were you when you were observing this

18 column?

19 A. I was on the first -- standing on the first floor of the municipal

20 building. So there's the ground floor and the first floor of the

21 building.

22 Q. Now, you say that you knew it was the 6th Brigade. Why did you

23 and others conclude that the column of vehicles was the 6th Brigade coming

24 to Sanski Most?

25 A. Well, such a big column couldn't be anything else but a column of

Page 6118

1 the army, the column of the 6th Krajina Brigade. And we assumed, and 99

2 per cent were convinced, that it go -- that it was going around this other

3 route, Dabar, Celavica [phoen] and a round about way to then Sanski Most.

4 Q. Now, you stated in your evidence that you eventually withdrew from

5 the building to Sehovci. Do you know what happened at the municipal

6 building after you left?

7 A. After we left -- it was somewhere around 10.00 p.m., 22 hours. We

8 could hear shell fire and explosions, because also the village of Sehovci

9 are some 2 to 3 kilometres from Sanski Most. Also in the village of

10 Podlug, which are vis-a-vis the village of Sehovci, we could hear there

11 were bursts of gunfire, shooting, explosions, and also vulgar songs at the

12 expense of Bosniaks and Croats.

13 Q. If you could just point on the map to the village of Sehovci, just

14 to show its proximity to Sanski Most. If you can see it there.

15 A. [Indicates]

16 Q. Yes.

17 A. Yes, it's here.

18 Q. Thank you.

19 A. And Podlug is here.

20 Q. Now, I know subsequently you had sight of the municipal building.

21 And we'll come to that in a moment. I'd like to move to the next day, the

22 20th of April of 1992. What happened on that day?

23 A. After arriving to Sehovci, we spent the night there and somewhere,

24 at about 7.00 a.m., five past 7.00, Rasula called us. More concretely, he

25 called Redzo Kurbegovic. And he said that we should come for talks to the

Page 6119

1 municipal building in Sanski Most exactly at noon, that also General Talic

2 would be coming.

3 Q. Did you go to that meeting?

4 A. Well, yes, we did go. But I wanted to say that we refused this

5 invitation because he said he would be coming and that their police would

6 be escorting us. We said we wouldn't go if we will not be escorted by our

7 legally appointed police as our escorts. And we then didn't come to an

8 agreement. And then exactly at 8.00 p.m. -- 8.00 a.m., Rasula called

9 again. He said he agreed that we come accompanied and escorted by our

10 police, the regular police. We accepted this, and we went and attended

11 that meeting.

12 MR. CAYLEY: If the witness could be giving Prosecutor's Exhibit

13 759, please, which is, Your Honours, Rasula's diary.

14 Mr. Usher, I'll need to find the page from this document.

15 Q. Now, Witness, this is the diary that we looked at yesterday. I'm

16 aware that you don't recognise the handwriting, but this diary gives an

17 account of a meeting at apparently which you were present. So I want to

18 go through the entries of the diary and then I want to ask you what you

19 remember from your memory of what happened that day.

20 Now, do you recall where the meeting was held?

21 A. It was held in the building of the municipality, in the room --

22 the premises of the chief, Rasula.

23 MR. CAYLEY: Your Honours, it's on page 15 of the English

24 translation.

25 Q. Now, the meeting indicates that those present were General Talic,

Page 6120

1 Colonel Basara, Major Zeljaja and representatives of the SDS, SDA, and

2 HDZ.

3 Now, on the next line it states present, Mirzet, Redzo, Sabic,

4 Ante, and Vlado. Now, who is the Mirzet referred to there?

5 A. It refers to me.

6 Q. Redzo?

7 A. The president of the SDA party, Kurbegovic Redzo.

8 Q. Kurbelovic or Kurbegovic?

9 A. Kurbegovic Redzo.

10 Q. Sabic?

11 A. Suad Sabic.

12 Q. Ante?

13 A. Ante -- I cannot remember the surname. Oh, it's Tunjic. Tunjic

14 Ante.

15 Q. And the last one, Vlado, do you remember who that was?

16 A. It must have been Vlado Vrkes.

17 Q. Next line then reads -- and I'm not going to go through all of it,

18 because it's not, I know for you, very easy to read. But in particular,

19 what I want to go to is the -- where it states "demand." And that is on

20 page 16, Your Honours.

21 "Items. 1: Guarantee of the public safety of citizens and their

22 property.

23 "2: The establishment of the organisation and functioning of the

24 legal public security service and police station by finding the

25 appropriate facilities and dividing resources. Deadline, immediately.

Page 6121

1 "3: The functioning of the legitimate municipal assembly and its

2 organs. Deadline, immediately."

3 I'm not going to read 4. It's dealing with the economy.

4 "5: The establishment of activity by all public institutions and

5 company -- and companies with special emphasis on the work of the radio

6 station with parity programming. Deadline, immediately.

7 "6: The determination of the sequence of events on 18 and 19

8 April, 1992 through the work of a mixed committee with the presence of

9 European Community observers and representatives of the regular army.

10 "Objection. A, against the military police. Mostly from Prijedor

11 without having criminal individuals involved, Jovic [phoen], Lukac. B,

12 Colonel Basara's driver irritates them."

13 Now, Witness, those demands, are they broadly what you remember

14 the demands being at that meeting on the 20th of April of 1992?

15 A. Yes, yes.

16 Q. Do you remember anything else that was demanded, apart from these

17 matters referred to here?

18 A. Well, there was the demand that General Talic directly goes to the

19 radio station of Sanski Most and to present the conclusions, so that the

20 public would be informed.

21 Q. We'll come to that in a moment. Do you remember any discussion of

22 checkpoints at the meeting?

23 A. Yes. Yes, they were discussed.

24 Q. What did the representatives of the SDA demand in respect of

25 checkpoints, if anything?

Page 6122

1 A. Well, that the checkpoints be withdrawn and that the -- also the

2 army be withdrawn from the checkpoints. And this was one of the first

3 items on the conclusion side.

4 Q. Was -- were the activities of the 6th Brigade discussed at the

5 meeting?

6 A. Yes, it was.

7 Q. And what activities were discussed specifically of the 6th Brigade

8 with General Talic?

9 A. First, that the checkpoints be removed, disbanded, and that the

10 shooting stop so that it won't be -- there would be no more intimidation

11 of the population, that there be no drinking bouts, no more drinking

12 bouts. And these were the main items.

13 Q. Was anything discussed about the numerous explosions that had been

14 taking place in Sanski Most during the past few months?

15 A. Yes. Also that the explosions should stop, as up till then we had

16 42 explosions. And normally -- and this was being carried out by the

17 legitimate bodies of law and order to detect who the perpetrators were and

18 that they be brought to justice.

19 Q. And here you're talking about the perpetrators of the explosions

20 within Sanski Most.

21 A. Yes, yes.

22 Q. Let's now move on through Rasula's diary. And you are quoted in

23 it. And again, this is not a transcript. This is a summary of somebody

24 else's understanding of what was said at the meeting. But I'm going to

25 read out apparently an abbreviated version of what you said. "Mirzet:

Page 6123

1 The result of cooperation is last night's success. We received a telex

2 from the Territorial Defence about its mobilisation, but we were in the

3 process of reaching agreement. Ignored the national structure

4 percentages. The SDS party is taking the SUP building and the president

5 says you have no place here any longer.

6 "Moving into the building as a temporary solution, we have accepted

7 everything that was rested from us, but we are still being given new

8 demands. Let us divide ourselves to the least possible extent and what

9 about our workers in Rudnik Famos. The question of the army, but who is

10 in it? The SDS can do nothing to the military police."

11 Now, I know again we're talking about events that took place ten

12 years ago -- over ten years ago. Do you remember speaking of any of those

13 matters in that meeting on the 20th of April of 1992?

14 A. I remember.

15 Q. Now, just one matter that arises. I mentioned to you a moment ago

16 that it was stated that Colonel Basara's driver irritates them. Now, is

17 that the Colonel Basara's driver that put a gun to your head in the

18 municipal building?

19 A. Yes. Macola.

20 Q. Now, let us go to the final part of the meeting and

21 General Talic's apparent comments, concluding remarks. And I'll read it

22 to you and then I'll ask you specifically what you remember.

23 MS. FAUVEAU-IVANOVIC: [Interpretation] Mr. President.

24 JUDGE AGIUS: Yes, Madam Fauveau.

25 MS. FAUVEAU-IVANOVIC: [Interpretation] It's simply for the record

Page 6124

1 that this part -- we'd like to know which part Mr. Cayley is referring to

2 now.

3 JUDGE AGIUS: Do you have the B/C/S version in front of you or the

4 English, Madam Fauveau?

5 MS. FAUVEAU-IVANOVIC: [Interpretation] Yes, the B/C/S version,

6 yes.

7 JUDGE AGIUS: [Previous translation continues] ... Mr. Cayley,

8 perhaps --

9 MS. FAUVEAU-IVANOVIC: [Interpretation] I'm referring to my

10 cross-examination of the previous witness.

11 MR. CAYLEY: It's the final part of the --

12 MS. FAUVEAU-IVANOVIC: [Interpretation] Excuse me. There seems to

13 be a serious problem with the interpretation. What I wanted to say is

14 that we contest the authenticity of this part of Rasula's diary -- alleged

15 Rasula's diary. And I am relying on the cross-examination that I had with

16 the previous witness.

17 MR. CAYLEY: Well, I mean, I can make no comment. She'll bring a

18 handwriting expert to say that just that piece is being forged or

19 something. We'll wait and see.

20 JUDGE AGIUS: Anyway, in other words, you're not querying the part

21 of this diary alleged to originate from Rasula? You know which part he's

22 putting his question from. No?

23 One moment. What's the problem, general?

24 THE ACCUSED TALIC: [Interpretation] I contest the entire diary as

25 the accused. It's inaccurate. It's incorrect. And what the Prosecutor

Page 6125

1 is quoting was never mentioned. That was never mentioned at the meeting,

2 the question of the United Nations and things like that. I was present at

3 that meeting, and it is not mentioned anywhere in the witness statement.

4 I apologise.

5 JUDGE AGIUS: It's okay.

6 THE ACCUSED TALIC: [Interpretation] Please forgive me.

7 JUDGE AGIUS: You have every right if you want to put an

8 interjection somewhere, provided you do not make statements or take over,

9 instead of your lawyer, you have every right.

10 I think we -- more or less we know where we are. I mean,

11 initially I thought you wanted a clarification from Mr. Cayley as to the

12 relevant part of the alleged diary of Mr. Rasula where he was referring --

13 where he was referring to, to which the question referred. But I

14 understand that's not your problem. Your problem is that you -- you

15 wanted to put for the record that you are contesting this particular part

16 of the diary. And now as General Talic puts it, the entire diary. This

17 is the situation as I see it now.

18 MS. FAUVEAU-IVANOVIC: [Interpretation] If I may clarify --

19 JUDGE AGIUS: Okay, general. You may sit down. Thank you.

20 MS. FAUVEAU-IVANOVIC: [Interpretation] This part of the diary is

21 clearly forged. On the other hand, it is quite clear that if a part of a

22 diary, one doubts seriously that a part of the diary has been forged, then

23 one doubts the authenticity of the entire diary. So we contest it.

24 JUDGE AGIUS: Yes, okay. That's --

25 MR. CAYLEY: So my --

Page 6126

1 JUDGE AGIUS: Am I on the record --

2 MR. CAYLEY: To whole diary is challenged.

3 JUDGE AGIUS: That's how I take it. That's how I take it.

4 MR. CAYLEY: Fine.

5 Q. Let me just read --

6 JUDGE AGIUS: It doesn't stop you from putting questions,

7 obviously. I mean, it's --

8 MR. CAYLEY: No. It's for the Defence and General Talic to bring

9 evidence to suggest it is a forgery, Your Honour.

10 JUDGE AGIUS: But do inform -- because I think you ought to tie up

11 with Ms. Korner on this, because she was here conducting the testimony

12 of --

13 MR. CAYLEY: I read that section.


15 MR. CAYLEY: Of the transcript.

16 Q. Now, let me read to you, Witness, what apparently General Talic

17 said. And I'll read the -- I think it's six or seven lines.

18 "General Talic, concluding remarks. Reach agreement but without

19 undue delay. The police added -- military police from Prijedor shall

20 remain and if need be from Banja Luka. We do not recognise the

21 paramilitary formations. We are not allowing barricades to be put up.

22 The JNA, Yugoslav People's Army, will guarantee the peace of the citizenry

23 and the security of property. We are asking for your help. Added,

24 otherwise you will see/ "see" crossed out/ don't call anyone for help

25 otherwise you will have Kupres, Bosanski Brod, Vukovar. The Banja Luka

Page 6127












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 6128

1 Mufti has appealed for peace. Listen to him."

2 MR. CAYLEY: Your Honour, I think Ms. Fauveau has an interjection.

3 JUDGE AGIUS: Yes. Sorry. I was trying to --

4 Yes, Madam Fauveau.

5 MS. FAUVEAU-IVANOVIC: [Interpretation] Apparently there really is

6 a serious problem with this part of Rasula's diary, because the previous

7 witness -- the text of what is written here -- [In English] "Do not ask

8 for the help." [Interpretation] Now, Mr. Cayley says that in this part of

9 the diary it says we are asking for your help and previously it said we

10 are not asking for your help.

11 MR. CAYLEY: No. In the English translation it actually says

12 both.

13 JUDGE AGIUS: Yes, exactly.

14 I think it -- I understand what you mean, Madam Fauveau. But I

15 think what's important for the time being for us to be able to follow is

16 what is contained in this bottom line and a half on page 17 of the alleged

17 diary. And that way we can leave it at that. I mean, I know what the

18 previous witness said. I suppose Mr. Cayley knows too, from what I

19 gather. So I think you can -- you may proceed with the next question.

20 MR. CAYLEY: Shall we find out what this witness has to say?

21 Q. Now, Mr. Karabeg, you've heard those concluding remarks, and

22 you've also heard all of the objections being raised. From your

23 recollection, from your memory of ten years ago, what do you remember

24 being said by General Talic?

25 A. Well, let me see. These words from the diary were spoken by

Page 6129

1 General Talic in that context, because the agreement was that we get

2 together in the municipal building alone at 6.00 p.m. after he left. And

3 I remember that we were saying goodbye. We shook hands. And when I shook

4 hands with Colonel Hasetic, he held my hand tightly. I felt that this

5 had a meaning to it, but I made no comment. But after they had left, me,

6 Suad, and Redzo got together and I said, "Redjo and Suad, did Colonel

7 Hasetic grip your hand firmly?" And they said yes. And this was a sign

8 as if to let us know that we should take care. And General Talic was

9 threatening, mentioning Kupres, Vukovar, something to that effect.

10 Q. And that is your best recollection of what was said on that day.

11 A. Yes. Yes.

12 Q. Now, did General Talic subsequently go on to the radio and

13 announce the demands that apparently had been agreed?

14 A. When we requested that these conclusions be announced on the

15 radio, the director of Radio Sana, Mr. Orlovic, said that was unfeasible,

16 and General Talic said that he was in a hurry, and we said, "Well, that's

17 simple. Pick up the telephone and the general could make the announcement

18 live over the telephone," so that it wasn't announced over the radio.

19 Q. Now, the agreement was to get together again at the municipal

20 building at 6.00 p.m. That evening; correct?

21 A. Yes. All of us - General Talic with his associates left for Banja

22 Luka. And we as representatives from all the parties from the territory

23 of Sanski Most municipality were supposed to meet in the municipal

24 building at 6.00 p.m.

25 Q. Did you in fact meet in the municipal building at 6.00 p.m.?

Page 6130

1 A. I went there, and I found the iron hedgehogs in front of the

2 building, and the police there -- obstacles, in fact. And I was told,

3 "What kind of a meeting? Who told you about it?" So no meeting was

4 held.

5 Q. Now, after that meeting, were the checkpoints removed from around

6 the town?

7 A. No. The situation worsened that very evening, that very day.

8 Q. How did it worsen?

9 A. The situation got worse. First of all, in respect of increased

10 intimidation, shooting into the air, bursts of fire into the air, we also

11 saw larger numbers of army members.

12 Q. What about explosions in and around Sanski Most? Was there a

13 decrease or an increase?

14 A. Let me tell you. I can't say for that particular evening, but now

15 the explosions occurred every four or five days, not every 15 or 20 days.

16 Now they occurred every four or five days.

17 MR. CAYLEY: If the witness could be shown Prosecutor's Exhibit

18 622, please.

19 Q. Now, this is a regular combat report from 5th Corps command from

20 General Talic's command. It is signed on behalf of General Talic. The

21 paragraph that interests me is paragraph 3. And the relevant part -- this

22 is the second paragraph, Your Honours.

23 "The situation in the areas where excesses occurred is now under

24 control, and the visit of the Corps Commander to Sanski Most and his tour

25 today of Babanovci have had a calming effect on the situation."

Page 6131

1 Now, you were in Sanski Most during these days. In your view, did

2 General Talic's visit to Sanski Most have a calming effect on the

3 situation?

4 A. It had the opposite effect. The least of all was it a calming

5 effect. The situation became worse.

6 Q. Now, subsequent to your meeting with General Talic, did you have

7 any more communications with him after the 20th of April of 1992?

8 A. I forgot to mention that on the 20th of April, as we parted

9 General Talic addressed me as the representative of the civilian

10 authorities and said, "President -- Mr. President, if the situation gets

11 worse, here is my telephone number. Please feel free to call me." And I

12 noted down his telephone number.

13 Q. Did you call him?

14 A. I didn't call him on Tuesday, that is, the next day, because I

15 thought that the people from the SDS would do as they were told. But as

16 the meeting didn't take place at 6.00 p.m. when it was scheduled, I

17 thought that probably they would call us the next day. This didn't

18 happen. And then on the 27th -- actually, on Wednesday I dialed

19 General Talic's telephone number. I was surprised and was glad that

20 within 15 or 20 minutes I was managed to reach him. That is, they

21 connected him to me. I managed to get in touch with him. We talked. The

22 first thing I said was that the scheduled meeting for 6.00 p.m. had not

23 been held, that Rasula did not schedule another meeting, and that the

24 situation in Sanski Most was worsening. His response was -- he swore at

25 them -- he swore at Rasula, that he's cheeky, that he's impudent, that

Page 6132

1 he's an extremist. And hearing that, I was glad. He sounded honest and

2 sincere to me. However, the next day, as I was watching the daily news

3 programme on television, I think there was a short clip from the previous

4 night, a celebration in Banja Luka. I saw General Talic with all of these

5 others, Karadzic, Krajisnik, Plavsic cordially greeting each other,

6 hugging each other. And then in the large group I also noticed Rasula.

7 And then I thought to myself well, this man is really lying to us. He's

8 misleading us. They're saying one thing and doing another. And after

9 that, I never saw him or heard him again until yesterday.

10 Q. After your contact with General Talic, did you have any more

11 contact with Colonel Basara?

12 A. I did.

13 Q. Can you tell the Judges about your contacts with Colonel Basara.

14 And before you answer that question, was it your understanding that

15 Colonel Basara was the subordinate of General Talic? And if you don't

16 know, just simply say, "I don't know."

17 A. He should have been, because at the meeting that we attended one

18 could see that Colonel Basara was subordinate to General Talic, when we

19 were in the municipal building on the 20th of April.

20 Q. Now, again, if I could repeat my question: Can you tell the

21 Judges about your contacts with Colonel Basara after the 20th of April of

22 1992.

23 A. I can. You see, we had several meetings with Colonel Basara

24 because he was our only hope and our only way of communicating with the

25 SDS, though they refused any contact persistently. The same occurred with

Page 6133

1 Colonel Basara. We even came out with a proposal, or specifically Fuad

2 Kurbegovic did, on behalf of the League of Communists, that Basara be

3 proclaimed honorary citizen of Sanski Most municipality. He made a lot of

4 promises. He promised that he would keep the army under control, that

5 there would be no searches at the checkpoints, that there would be no

6 drinking bouts, that there would be no bursts of fire. And in fact, the

7 opposite occurred: The number of checkpoints increased; there were

8 machine-gun nests set up; two APCs in the municipality; and it all came to

9 a head with an explosion one day. Actually, there was an explosion every

10 night, so it wasn't every three or four nights but every night now. So

11 the situation became worse and worse. It went from bad to worse.

12 MR. CAYLEY: If the witness could be shown Prosecutor's Exhibit

13 626, please.

14 Q. Now, Witness, this is a conclusion of the meeting of the Crisis

15 Staff of the Serbian municipality of Sanski Most held on 28 April. And

16 the gist of it -- I'll read paragraph -- I won't read all of it. "All

17 citizens in the area of Sanski Most municipality who possess any kind of

18 weapon shall hand it in to the public security station, the closest unit

19 of the Yugoslav People's Army, or the staff of the Territorial Defence of

20 the Serbian municipality of Sanski Most." And then it gives times for the

21 handing in of weapons, and then it says: "Citizens who have private

22 weapons with a licence from a competent organ and members of armed

23 Territorial Defence formations, active service and reserve police and the

24 Yugoslav People's Army are exempt from this decision."

25 Were you aware of this decision at the time?

Page 6134

1 A. I was not.

2 Q. Were you aware that the population was being disarmed at the end

3 of April of 1992?

4 A. I was.

5 Q. Were all ethnic groups within the population being disarmed as far

6 as you remember? Were Serbs, Croats, and Muslims being disarmed at this

7 time?

8 A. Only the non-Serbs were being disarmed. Only those people who

9 were not Serbs. That means Bosniaks and Croats and others.

10 Q. How do you know this?

11 A. I know because that is what was being done, and I saw it with my

12 own eyes.

13 Q. Now, the last paragraph of this document states that: "The Crisis

14 Staff of the Serbian municipality of Sanski Most meet with the commander

15 of the 6th Krajina Brigade, Colonel Basara, and start regulating the

16 relationship between the armed forces of the Serbian Territorial Defence

17 and the Yugoslav army." Did you know at this time, at the time that you

18 were meeting with Colonel Basara, that he was also meeting with the Crisis

19 Staff of the Serbian municipality of Sanski Most?

20 A. I didn't know.

21 Q. Do you still have Rasula's diary?

22 MR. CAYLEY: Does he still have 759?

23 This, Your Honours, is on page 37 of the English translation, and

24 it is a meeting of the Crisis Staff on the 24th of May of 1992. That's

25 how it is represented.

Page 6135

1 Q. Now, I'll read it to you, Witness, if it's not possible for you to

2 read it.

3 "Item 3: The operation was successful. So far only in the case

4 of weapons belonging to the Territorial -- Territorial Defence and the

5 republican police, while nothing has been done about weapons from illegal

6 sources."

7 Witness, is that referring to the disarmament process that was

8 taking place at the time?

9 A. Yes.

10 Q. The next line reads: "Colonel Basara proposed a strike at the

11 strongest point. Colonel Anicic suggested Bojancic [phoen], Demasevici

12 [phoen], Vrci, and Okrec [phoen].

13 The next line, this is on page 38, Your Honours.

14 "Colonel Basara will prepare an operation against Dimitrovici

15 [phoen]" -- next word is illegible. "The proposal was not accepted. It

16 was decided that it should take place on Tuesday morning."

17 Now, Witness, if this was -- this meeting was held on the 24th of

18 May of 1992, which was a Sunday, would you agree that the following

19 Tuesday, certainly by my calendar, must have been the 26th of May of

20 1992?

21 A. Yes.

22 Q. Who was Anicic, Colonel Anicic? Do you know who that was?

23 A. I met Colonel Anicic. I don't know him too well. He was born in

24 Sanski Most -- the municipality of Sanski Most, but he served out of

25 Sanski Most. So I knew him superficially.

Page 6136

1 Q. Do you know what his function was at this time within Sanski

2 Most?

3 A. Well, you see, at the time and in those contacts, I had no contact

4 with him. But as far as I was informed and as far as we knew, he headed

5 the Crisis Staff of the municipality of -- that is, the Serbian

6 municipality of Republika Srpska.

7 Q. Did you ever meet with him?

8 A. No, I hadn't.

9 Q. Do you know whether or not he was in the Territorial Defence?

10 A. At the time, he was not.

11 Q. As far as you know.

12 A. Yes.

13 MR. CAYLEY: If the witness could be shown Prosecutor's Exhibit

14 638.

15 Q. Now, I don't want you to read all of this document, but if I could

16 just direct you to the stamp and signature at the top where it states,

17 "approved by Serbian Territorial Defence commander Colonel Nedeljko

18 Anicic." And then by the side of that it states, "Strictly confidential.

19 Grmec 92."

20 Now, I just want to read a couple sections of this combat order.

21 And I'll ask you some questions in a moment.

22 Paragraph 3 of the order, and the subject matter of the order is

23 disarmament operation in Sanski Most. Paragraph 3: "The 6th Brigade in

24 coordinated action with the STO units -- Serbian Territorial Defence

25 units -- is undertaking combat operations in Sanski Most municipality area

Page 6137

1 in order to disarm enemy forces by placing its main forces on the Skuceni

2 Vakuf, Kamengrad-Dolina valley. Sanski Most Vrhpolje access with emphasis

3 on the general sector of Sanski Most."

4 Over the page on page 2 of the English version, Your Honours. And

5 this is in your version, Witness, is paragraph 4, where it reads, "I have

6 decided." And then in the next paragraph, it states: "Once the positions

7 have been taken, use Serbian Territorial Defence units to prevent the

8 insertion and operation of sabotage groups in the Serbian villages. After

9 artillery preparations, disarm the settlements of Mahala, Otoke, Muhici,

10 Marije Bursac the Omladinsko neighbourhood, Alagica neighbourhood. In

11 coordination with the 6th Brigade units, in order to cause the enemy great

12 human, materiel, and technical losses."

13 And then in the next paragraph: "Engage the main forces for tasks

14 in the Sanski Most sector. Re-subordinate the sector staffs along with

15 the Dabar, Lusci Palanka, Budimlic Japra units and the Koprivna, Ostra

16 Luka and Usorci Territorial Defence units to the 6th Brigade command for

17 operations along the secondary axis of attack."

18 Paragraph 9, the second sentence. This is the part, Your Honours,

19 dealing with artillery preparations for the operation. "Upon completion

20 of artillery preparations with the remodelled Georgi vehicle and in

21 coordination with armoured combat vehicle from the 6th Brigade, it will

22 neutralise the remaining fire targets and search the Mahala sector further

23 towards the Ekonomija." And then the order goes on to essentially task

24 them for intervention on separate orders once this order is complete.

25 Do you see the section at the bottom, Witness, that states

Page 6138

1 "deliver reports on" -- it's on the last page, on page 5. It's on the

2 final page. Do you see that? It says "deliver reports on," and then

3 colon, "readiness for the attack at 0500 hours on the 26th of May." Do

4 you see that, Witness?

5 A. Yes, I see it. I see it.

6 Q. Do you recall a moment ago I read out to you from Rasula's diary

7 that the attack was postponed until the 26th of May, that Colonel Basara's

8 suggested attack was postponed by them until the 26th of May? Do you

9 recall that?

10 A. Yes, I do. I remember it.

11 Q. Do you still have Rasula's diary with you?

12 MR. CAYLEY: Is it in front of the witness? Yes.

13 A. I have it.

14 Q. And if you can -- I don't know if you'll be able to find it. But

15 the part that deals -- it's actually the next day, the 25th of May of

16 1992. And I can read this out to you, because there's not very much in

17 there that I want to direct you to.

18 MR. CAYLEY: But this, Your Honours, again is on page 38 of the

19 English translation.

20 Q. And it's headed, again, "Crisis Staff, 25 May 1992."

21 "1: Information on security of important features."

22 "2: Report on the developments in the municipality over the past

23 24 hours."

24 "3: The disarmament plan and its beginning."

25 "4: Preempting enemy operations. A, arrest of leaders. B,

Page 6139

1 detention facilities. Miladin Papic and Mico Krunic."

2 "Item 4: Take into custody Adil Draganovic in Mahala." 30 pieces

3 were returned -- that he failed to turn in, arrest Redzo Kurbegovic,

4 Mirzet Karabeg. And then there's a whole list of names that I won't read

5 out.

6 "Item 3, Tuesday at 6.00 or 7.00 the operation begins. The

7 fighting will not stop until they surrender. Take no prisoners if armed.

8 Captured civilians to be used for exchanges."

9 Mr. Karabeg, what happened to you on the 25th of May of 1992?

10 A. On that day, I was arrested, and I was taken to the headquarters

11 of the police station. Two vehicles came with eight armed individuals.

12 Q. Whereabouts were you taken?

13 A. I was taken to the police station and precisely to the detention

14 facility in the police station.

15 MR. CAYLEY: I just have a set of photographs, Your Honours, which

16 I'd like to show to the witness.

17 Can you give copies to the Defence and to the Judges, please.

18 Q. Do you recognise this building, Witness?

19 A. Yes, I do.

20 Q. What is this building?

21 A. This building is the police building in Sanski Most.

22 Q. And is this where you were taken on the 25th of May of 1992?

23 A. Yes, indeed.

24 Q. Where were you taken in the police station?

25 A. The prison facility there, which is located behind this building.

Page 6140

1 Q. So the prison facility can't be seen in this photograph.

2 A. No. No, it cannot be seen.

3 Q. And whereabouts within the prison facility were you taken?

4 A. It was cell number 2.

5 Q. Who was in the cell with you?

6 A. I found two people already in this cell, Ibro Kuzelj, Katkic Meho,

7 a retarded person, Atlija Marinko, and in the next cell I heard that Ismet

8 Jakupovic was there, Ismet Alagic, Stipe Catic, Adil Draganovic, and

9 Fikret Saletovic.

10 Q. You say that one of the people that was in the prison with you was

11 a retarded person. What was he doing in the prison with you?

12 A. Even I personally really don't know. But -- because he wasn't a

13 Serb.

14 Q. Was he subsequently released?

15 A. Yes, he was. The next day.

16 Q. What happened to you on the day that you were taken to your prison

17 cell on the 25th of May, if anything at all worthy of note?

18 A. Let me say I was taken there in the hall. A policeman took me

19 over. He took my belongings, my wallet, my belt, shoelaces from the

20 shoes, and then he took me to the cell number 2. Nobody hit me and nobody

21 mistreated me. Nobody beat me.

22 Q. What happened the next day, on the 26th of May, 1992?

23 A. On the next day, the 26th of May, 1992, we received visits from

24 the SDS, Boro Savanovic, Papric Miladin, and Tripkovic Nemanja. They

25 talked to us, and I told them, "Well, okay if you arrested us, but why --

Page 6141

1 what's wrong -- what wrong did this man commit? He knows nothing. He's

2 retarded. It would be proper if you let him go." And in fact, on that

3 day in the afternoon he was freed and they let him go.

4 Q. And his name again, the man that was retarded?

5 A. Meho Katkic, also known as Znojko.

6 JUDGE AGIUS: Here I'm getting confused. Before, when he first

7 referred to -- in answering your question who was in the cell with you, he

8 said -- I found two people already in the cell, Ibro Kuzelj, a retarded

9 person, and Atlija Marinko. And in the next cell I heard that -- et

10 cetera, et cetera. We're not interested in those.

11 MR. CAYLEY: I think it was a generic description of a person

12 without a name, Your Honour. That's why I was asking --

13 JUDGE AGIUS: Okay. But that would make it three -- or four and

14 not two persons in the cell.

15 MR. CAYLEY: I'll clarify it.

16 JUDGE AGIUS: Yes, please.


18 Q. When you arrived, Mr. Karabeg, how many people were in cell number

19 2 and what were their names?

20 A. Three people. Ibro Kuzelj, Katkic Meho, also known as Znojko, a

21 sick, retarded person, and Atlija Marinko, as well as then I joined them

22 as the fourth.

23 MR. CAYLEY: Unfortunately, Your Honour, we're going to -- there's

24 going to be a lot of this people in cells, who they were. I mean let's

25 face it. It's ten years ago. I don't remember who I was in two weeks

Page 6142












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 6143

1 ago.

2 JUDGE AGIUS: No. It's not important, Mr. Cayley. What's

3 important is I did get the impression initially when he was answering your

4 first question that although we were being told that he was saying two

5 persons, in actual fact I did understand that there were -- there were

6 more than two -- there were more than two persons. So now it's clarified

7 and you can proceed.

8 MR. CAYLEY: Thank you.

9 Q. Now, did Mr. Papric say anything on this occasion, on the 26th of

10 May?

11 A. Well, I will return to the previous question. But let me tell

12 you, in that cell we spent -- seven of us spent the night, because after

13 that some other people were also placed in the same cell.

14 Now a concrete answer to your question, yes, Miladin Papric turned

15 to Redzo, who came to -- was placed in a cell, and he said, "There you

16 see, Redzo, what you wanted to do was get national -- a party of your own,

17 and look -- look what happened." And so this is what they were doing.

18 Q. When you are referring to Redzo, are you referring to Redzo

19 Kurbegovic?

20 A. Yes, yes, Redzo Kurbegovic.

21 Q. Now, you've not mentioned him as being in your cell at the police

22 station. Where did Papric speak to Redzo?

23 A. He was talking in cell number 2, but he was brought -- he spent

24 the night with me in that cell but he -- and he was brought in later in

25 the evening, on the 25th of May.

Page 6144

1 Q. So let's make this absolutely clear. On the night of the 25th of

2 May, what was the total number of people that were in the prison cell with

3 you?

4 A. Seven.

5 Q. So not including the three that you've already mentioned, who were

6 the other four that were brought in?

7 A. I have mentioned the three who were there already before me.

8 Myself, the fifth was one Haso Osmancevic, Nedzad Muhic, the sixth person,

9 and Redzo Kurbegovic was the seventh person to be placed in that cell that

10 evening.

11 MR. CAYLEY: Is that clear to Your Honours?



14 Q. And it was on the 26th, the next day, that Papric had the

15 conversation with Kurbegovic; correct?

16 A. Yes, it was.

17 Q. Now, who, if you know, was in charge of the prison at the SUP

18 station?

19 A. The head of the police station for the -- Vujanic Drago and Krunic

20 Mico, they were responsible for the prison facility.

21 Q. And at this time on the 25th, 26th of May, 1992, who was in charge

22 of the police in Sanski Most, if you know?

23 A. I apologise. May I correct myself?

24 Q. Of course.

25 A. I have -- I mixed up the police station and the prison facility

Page 6145

1 with the camps, and that is why I have mentioned these two persons, Mico

2 Krunic and Drago Vujanic. For the police, there was the police chief who

3 was the responsible person in authority.

4 Q. And what was his name, if you can remember?

5 A. Vrucinic Mirko was the head of the police.

6 Q. And because I don't fully understand what you've said. Who did

7 you understand to be in charge of prison facilities at the SUP on the 25th

8 and the 26th of May 1992?

9 A. Papric. Papric Miladin.

10 Q. Did there come a time when he ceased to be the commander of the

11 prisons? Was he ever replaced? If you don't know, simply say "I don't

12 know."

13 A. Well, you see, this was chief of police who was already retired.

14 And on -- at the time he was reinstated, activated.

15 Q. Who are you speaking of now? What is the name --

16 A. I'm speaking of Papric Miladin.

17 Q. We'll come back to this point on whether he was replaced a bit

18 later on in your evidence.

19 Now, whilst you were in your cell on the 26th of May, did you hear

20 anything significant?

21 A. On the 26th of May, 1992 exactly at 8.00 I began hearing the

22 shelling of the municipality of Sanski Most from heavy artillery weapons.

23 JUDGE AGIUS: Mr. Cayley, may I suggest you stop here and resume

24 after the break.

25 MR. CAYLEY: Yes, Your Honour.

Page 6146

1 JUDGE AGIUS: I think it's a suitable moment to stop, in any case.

2 MR. CAYLEY: Yes.

3 JUDGE AGIUS: Thank you. We'll have a 30-minute break, resuming

4 at just before 11.00. I thank you.

5 MR. CAYLEY: Your Honour, one matter.

6 JUDGE AGIUS: Yes, Mr. Cayley.

7 MR. CAYLEY: I've spoken with Ms. Fauveau, and she's not ready to

8 cross-examine today. I may actually finish, I think, before the end of

9 the session today, but I'm perfectly happy for her to start tomorrow if

10 that leaves her better prepared.

11 MS. FAUVEAU-IVANOVIC: [Interpretation] Mr. President, I can begin

12 today, but I will not complete it. I have a part of the cross-examination

13 for which I'm quite ready, and I think that will take up the rest of the

14 time today.

15 JUDGE AGIUS: So that's a practical way of dealing with it.

16 Mr. Cayley, please, when we resume, do tell us the number --

17 exhibit number of --

18 MR. CAYLEY: It's 798, Your Honour.

19 JUDGE AGIUS: 798?

20 MR. CAYLEY: Yes.

21 JUDGE AGIUS: I thank you.

22 --- Recess taken at 10.30 a.m.

23 --- On resuming at 11.00 a.m.

24 MR. CAYLEY: Mr. President, before we begin, again I wanted to

25 make a few comments about General Talic's comments about the diary, and

Page 6147

1 simply about the order and presentation of evidence in this case.

2 As you know, Rule 85 of the Rules of Procedure describes the

3 order of evidence, and evidence is called in a common law fashion,

4 evidence for the Prosecution, evidence for the Defence, Prosecution

5 evidence and rebuttal and so on.

6 In your guidelines that you yourself stated to us, on the 23rd of

7 January of 2002 you in essence stated at page 672 that the accused

8 wherever possible, you said, "It was desirable that the accused should

9 give evidence before the evidence of any other witnesses." And you

10 mention that in some cases this hadn't happened that, witness -- the

11 accused had decided to give evidence at the end of the case.

12 I would also mention to you Rule 90, which deals with the

13 testimony of witnesses and within Rule 90(G) gives the Prosecution the

14 right of cross-examination of any witness, including the accused, when

15 statements like these are made. And what I would say is, whilst knowing

16 that in civil law trials, accused are able to rise and make comments about

17 the evidence, at that point in time General Talic was giving evidence.

18 JUDGE AGIUS: No, he wasn't.

19 MR. CAYLEY: He was making a comment --

20 JUDGE AGIUS: Mr. Cayley, if that is your assertion, I'm telling

21 you to stop because the Trial Chamber does not consider what General Talic

22 stated as part of his evidence.

23 MR. CAYLEY: Thank you. That makes me content.

24 JUDGE AGIUS: I'm making it clear. I allowed General Talic to

25 stand up first because I didn't know what kind of complaint, if --

Page 6148

1 complaint it was. Secondly, because respective of common law or civil

2 law, whatever, if at any given moment the accused feels that his point of

3 view is not being presented in accordance with his wishes or in accordance

4 with his instructions or in accordance with his opinion, he has every

5 right to point that out. He can ask to do it directly with counsel,

6 asking for a break, or as happened earlier on today the way he did it, but

7 don't take it that the Trial Chamber is considering his statement as part

8 of his evidence.

9 MR. CAYLEY: That makes me content, because as you know, I'd like

10 to cross-examine him on this.

11 JUDGE AGIUS: No. Definitely not.

12 MR. CAYLEY: If he makes statements such as these.

13 JUDGE AGIUS: He has the right to give evidence or not to give

14 evidence at the right stage.

15 MR. CAYLEY: Yes.

16 JUDGE AGIUS: Between now and then, if he has -- he or even

17 Mr. Brdjanin -- I mean, I'm -- what I'm saying is not limited to

18 General Talic. If any one of them want to rise and make a statement under

19 the direction and control of the Trial Chamber -- and I want to make

20 myself clear on this -- I will not allow a situation to arise whereby the

21 accused will take over from the Defence counsel.

22 MR. CAYLEY: I'm content, Your Honour. You've made it clear it's

23 not evidence, so that's fine.


25 MR. CAYLEY: And if that's the position for future comments, then

Page 6149

1 I'm content.

2 JUDGE AGIUS: Definitely not evidence, no.

3 [Trial Chamber and registrar confer]

4 JUDGE AGIUS: Yes, Mr. Cayley.

5 MR. CAYLEY: Thank you, Your Honour.

6 Q. Now, Witness, before the break you had stated that you had heard

7 the shelling of Sanski Most. Now, just to be absolutely clear about this,

8 you didn't see the shelling take place because you were in a cell in the

9 police station; correct?

10 A. Yes, I didn't see it.

11 MR. CAYLEY: Now, if the witness could be shown Prosecutor's

12 Exhibit 641.

13 Q. Now, this is a document dated the 26th of May of 1992, Sanski Most

14 Serbian municipality civilian protection municipal staff. And this is an

15 order given pursuant to the conclusions of the Crisis Staff and the

16 civilian protection staff. And the order is that the displaced population

17 which withdrew from the Mahala, Muhici, and Otoke settlements to the

18 Krkjevci is to be transferred by a Sana Trans DB socially owned enterprise

19 bus to the sports hall for care and accommodation. Serbian Territorial

20 Defence military police shall provide security for the column.

21 Now, Mr. Karabeg, when if at all, did you find out that the

22 displaced population from these areas had been moved to the sports hall in

23 Sanski Most?

24 A. They were transferred on the 27th of May, 1992.

25 Q. That's not the question I asked you. The question I asked you

Page 6150

1 is: When did you personally find out that the population had been moved,

2 bearing in mind that you were in a prison cell behind the police station.

3 Do you recall?

4 A. I do recall it. I learnt about the transfer of the population --

5 I don't know whether it was the 27th or the 28th of May. During a visit

6 by Tomo Delic and Nemanja Tripkovic and Boro Savanovic who came to visit

7 us in the prison.

8 Q. How did you learn about the transfer of the population during

9 their visit to you?

10 A. They visited us in the prison about 8.00 p.m. to treat us with

11 some coffee and brandy, and they saw the smoke from the houses burning in

12 Gornja Mahala, because Gornja Mahala is in the immediate vicinity on the

13 other side of the Sana River and Tomo Delic informed us that their heroes,

14 as he put it, had liberated Gornja Mahala and Otoke from extremists, that

15 Gornja Mahala had been set on fire and that he had a videotape showing the

16 burning of Gornja Mahala. And that his father had said that the Serbs

17 would control Sanski Most for the next 500 years and that only -- not more

18 than five Serbs would die; that from Krkojevci they had transferred the

19 population, who had apparently fled their houses, and Krkojevci is right

20 next to Gornja Mahala, 1 kilometre away.

21 Q. Can you just remind the Court who were Tomo Delic, Nemanja

22 Tripkovic, and Boro Savanovic.

23 A. Boro Savanovic and Nemanja Tripkovic were in the executive board

24 of the SDS of Sanski Most, the highest body of the SDS party in Sanski

25 Most.

Page 6151

1 Q. And Tomo Delic?

2 A. And Tomo Delic also. He was also a member. He came in uniform

3 with the helmet on his head. At the time I didn't know, but he headed the

4 Serbian defence forces in Sanski Most.

5 MR. CAYLEY: If the witness could be shown Prosecutor's Exhibit

6 643.

7 Q. Now, in the Mahala in late May of 1992, there were Muslims --

8 there were Muslim individuals who had weapons; correct?

9 A. Yes.

10 Q. Now, you were not there at the time, but did you subsequently hear

11 from anybody about the strength or otherwise of the resistance of those

12 armed Muslims who were in the Mahala when it was attacked?

13 A. There was no resistance.

14 Q. Who did you hear that from?

15 A. I heard it from Tomo Delic himself, among others. He never

16 mentioned any fighting in Mahala. He didn't say, "I have a video

17 recording of the combat in Mahala" but he said, "I have a video recording

18 of the burning of Mahala."

19 Q. Can you read this exhibit in front of you. And the part that

20 interests me are the first two paragraphs of the order. "The terrain in

21 the area of Mahala --" and again, it's a conclusion pursuant to a decision

22 of the Crisis Staff of the Serbian municipality. And it states: "Order.

23 The terrain in the area of Mahala, Otoke, and Muhici should be sanitized

24 in order to carry out this out, the following shall be done. Bodies must

25 urgently be recovered, identified, and buried in the designated place, a

Page 6152

1 marked burial site."

2 When did you discover that individuals had been killed in these

3 three locations?

4 A. I learnt it while I was in prison, because we had a young man who

5 objected to all this, and when he was on duty he would tell us about what

6 was going on in Sanski Most. And in October 1995, during the liberation

7 of Sanski Most I was present when this grave site was unearthed and

8 attended the burial and identification of the people killed in those

9 days.

10 Q. Concentrating on May of 1992 for the moment, did you know at the

11 time how many people had been killed in these places that are mentioned in

12 this order?

13 A. I did not.

14 Q. Did you subsequently find out?

15 A. Subsequently I did find out. I couldn't in May because I was in

16 the prison and I had no contact.

17 Q. How many people, if you can remember -- if you don't know, say you

18 don't know. But how many people were killed in these three places as far

19 as you know?

20 A. Forty-two.

21 MR. CAYLEY: If the witness could be shown Prosecutor's Exhibit --

22 if the witness could be shown Prosecutor's Exhibit 646, please.

23 Q. Just one last point. Where were those bodies buried pursuant to

24 this order that's in front of you? Do you know? Again, if you don't

25 know, just say you don't know. Do you know where the burial site was?

Page 6153

1 A. I do know where they were buried, because in 1995 I was present

2 during the unearthing. It is Greda -- Greda in Sanski Most. The location

3 is Greda, where a hole had been dug and the corpses thrown in.

4 MR. CAYLEY: Your Honours, do you have that in front of you?


6 MR. CAYLEY: Yes.

7 Q. This, witness, is a regular combat report by General Talic. And

8 the paragraph that interests me -- it refers to a number of matters

9 concerning the 1st Krajina Corps at the time, but I just wish to read a

10 couple of paragraphs from this particular report.

11 In paragraph 1 in the seventh -- eighth line, it states the

12 following: "There is still some weak resistance to confiscation of

13 weapons in the wider area of Prijedor, Sanski Most, and Kljuc. The armed

14 formations have been broken up, but some of their components from

15 individuals to squads are still resisting the army of the Serbian Republic

16 of Bosnia-Herzegovina as they flee. A large number of armed rebels have

17 been captured in these towns."

18 Now, Witness, when you were arrested in Sanski Most on the 25th of

19 May of 1992 did you have a weapon with you?

20 A. I did not.

21 Q. Do you know whether the mentally retarded man that was in the

22 prison cell with you was armed when he was arrested?

23 A. He was not.

24 Q. Were any of the people that were in a cell with you armed when

25 they were arrested? Do you know? If you don't know, simply say "I don't

Page 6154

1 know."

2 A. Not a single person was armed.

3 Q. Paragraph 2: "The units of the 1st Krajina Corps are holding the

4 positions taken earlier and the front line has not moved. Cooperation

5 with the Serbian Republic of Bosnia-Herzegovina MUP in mopping up the

6 terrain and confiscating weapons from illegal formations in the area of

7 Prijedor, Sanski Most, and Kljuc continues."

8 Mr. Karabeg, in May of 1992 at this time did you see the police

9 and the army working together, as it states in this report, to the Main

10 Staff of the Bosnian Serb army?

11 A. Did I see it? I did not.

12 Q. Who was running the police station where you were? Who was

13 running the prison cells where you were, the police or the army?

14 A. Let me tell you. There were both the army and the police. In the

15 compound, there were some army members as well.

16 Q. Do you know whether those army members were members of the local

17 Territorial Defence or of the 6th Brigade? And again, if you don't know

18 the answer to that question, simply say "I don't know."

19 A. I don't know, because they wore all kinds of insignia. They even

20 had three or four different insignia on their uniform. It was considered

21 a kind of heroism.

22 Q. Now, you mentioned that you saw in and around the prison that

23 there were members of the military police. How did you know they were

24 military policemen?

25 A. Well, you see, until then and in those days we knew what the

Page 6155

1 police uniforms were like and we also knew what the army uniforms were

2 like, and we distinguished them by their uniforms because in those days

3 the policemen did not wear camouflage uniforms. They all -- they were

4 still wearing those old uniforms, the uniforms worn by the regular police

5 while it existed.

6 Q. Now, when you say that you saw members of the army, what colour

7 uniforms were they wearing?

8 A. Some of them had these new camouflage uniforms, but quite a number

9 of them were wearing those old SMB or olive/grey uniforms.

10 Q. These are the uniforms that you were familiar with from the JNA,

11 correct, the SMB?

12 A. Yes, yes, yes. Those uniforms. Those are the ones I had in mind.

13 Q. What colour were the new camouflage uniforms, if you can remember?

14 A. There were several colours.

15 Q. Now, the police, what colour uniforms were they wearing?

16 A. The police were still wearing those old uniforms made of blue

17 cloth. But around the second half of July I started seeing policemen

18 wearing camouflage uniforms as well.

19 Q. Blue camouflage uniforms or green camouflage uniforms?

20 A. Well, there were blue camouflage uniforms. There were green

21 camouflage uniforms. There was sort of a yellowish greenish camouflage

22 uniforms. Those are the colours I can remember.

23 Q. Now, there came a time, I think after the 29th of May of 1992 --

24 and I may have got the date wrong, so correct me if I have -- where you

25 were asked to write a statement with Kurbegovic. Do you recall that

Page 6156

1 time?

2 A. I do.

3 Q. What were you asked to put into that statement?

4 A. Well, it was like this, you see: The people possessed arms. They

5 had weapons in their possession, individuals, that they had purchased from

6 Serb reservists.

7 Q. Which people are you talking about? You're talking about the

8 Muslim people?

9 A. I beg your pardon?

10 Q. When you say "the people possessed arms," which people are you

11 referring to?

12 A. Individual Muslims and Croats. Which they had purchased from Serb

13 reservists with a registration number on them. There was the number and

14 the name to whom the weapon had been sold. And they insisted that I,

15 Redzo, and Suad write a statement which would be broadcast on Radio Sana

16 saying that the people should return those weapons. The same was done

17 with Faik Biscevic, who was captured at Magarice by members of the army.

18 And according to what he said and which was confirmed by others, a pistol

19 was leant at his -- on his forehead. He was given a telephone receiver so

20 that he should tell the people over Radio Sana that the people should

21 return and surrender their weapons. So you see, they knew by name, each

22 citizen -- a non-Serb citizen that owned a rifle, because he had purchased

23 it from their reservists. And on this list the name was noted down as

24 well as the number of the rifle.

25 JUDGE AGIUS: Yes, Mr. Ackerman.

Page 6157












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Page 6158

1 MR. ACKERMAN: Your Honour, the transcript says "according to what

2 he said and which was confirmed by others, a pistol was leant at his -- on

3 his forehead." That must be a mistranslation. I have no idea what that

4 means.

5 JUDGE AGIUS: Yes. Sir, could I ask you to explain this. We

6 may -- it may just be and probably it is a mistake in the interpretation.

7 What were you told by Faik Biscevic or others when he was -- relating to

8 when he was asked or forced to pick up the telephone and make the appeal

9 that has been -- that you have mentioned to the people over Radio Sana?

10 What I want is the clarification from you as to how does a pistol fit in

11 all this. Did someone put a pistol next to his temple, to his head, or

12 what?

13 THE WITNESS: [Interpretation] I try to demonstrate it. It wasn't

14 on his forehead but here to the side, to his temple.

15 JUDGE AGIUS: You were told that someone put a pistol to his

16 temple.

17 THE WITNESS: [Interpretation] Yes.



20 Q. Who told you that?

21 A. Faik was the first to tell me about it, who was brought to the

22 prison in the night of the 28th of May from Magarice.

23 Q. Now, the statement that you were forced to make, you did not

24 personally make that statement on the radio. It was read out by somebody

25 else; correct?

Page 6159

1 A. Yes. We wrote it on a piece of paper. We signed it. Somebody

2 took it to the radio station and read it there.

3 Q. Did you hear it yourself, the statement being read out, or not?

4 A. No, I didn't hear it. We didn't have that possibility of

5 listening to the radio.

6 MR. CAYLEY: If the witness could be shown Prosecutor's Exhibit

7 656, please.

8 Q. Now, Witness, this is an order, as you can see, of the Crisis

9 Staff of the Sanski Most municipality, and it is an order given --

10 apparently an order adopted on the 30th of May of 1992. And the only

11 paragraph that interests me in this particular order is the first one.

12 "The director of the public utilities enterprise is ordered to provide

13 machinery and manpower for the burial of persons killed in combat

14 operations in Vrhpolje and Hrustovo."

15 When did you find out that there had been combat operations in

16 these two places? Bearing in mind again that you were in a prison cell

17 behind the police station.

18 A. I heard it when I left for the Manjaca camp.

19 Q. And that was in August of 1992.

20 A. Yes, yes. Precisely on the 28th of August 1992.

21 Q. And what did you hear had happened in Vrhpolje and Hrustovo?

22 A. I heard that people had been killed, women, children, and old

23 people. I heard that the -- in the Merdonovic family, 17 people had been

24 killed, women, children, the old man Merdonovic, his four sons, who were

25 otherwise working abroad in Switzerland.

Page 6160

1 Q. Who did you hear about this from?

2 A. I heard this from the camp inmates, the detainees who were in the

3 camp there and who were originally from these areas.

4 Q. And when you're referring to "the camp," you're referring to

5 Manjaca?

6 A. Yes, yes. I'm referring to the Manjaca camp.

7 Q. And did they say who was responsible for these killings at

8 Manjaca?

9 A. Yes, they did. Members of the military, of the army.

10 Q. Which army?

11 A. It was the army -- the JNA, the Yugoslav People's Army, at the

12 time.

13 MR. CAYLEY: If we can look at Prosecutor's Exhibit 657 very

14 briefly. I just really want to draw Your Honours' attention to this

15 document. I'm not going to ask the witness any questions.

16 And if --

17 JUDGE AGIUS: Which --

18 MR. CAYLEY: Prosecutor's 657, Your Honour.

19 JUDGE AGIUS: Yes, which part of the document.

20 MR. CAYLEY: Paragraph 3, line 5.

21 And if Prosecutor's 661 could be made ready.

22 Q. And this is again a regular combat report of the 1st Krajina Corps

23 command to the Main Staff of the Serbian Republic of Bosnia-Herzegovina.

24 It's dated 2nd June.

25 "The wider area of Sanski Most, Prijedor, and Kljuc are under the

Page 6161

1 control of our units. Mopping up of the area is underway."

2 Now, if we can now refer to P661. Do you have 661 in front of

3 you?

4 A. I have it.

5 Q. Now, this is a set of conclusions of the Crisis Staff, the Serbian

6 municipality of Sanski Most, at a session held on the 4th of June, 1992.

7 And it reads as follows:

8 "1. Mirko Vrucinic, Nedeljko Rasula and Colonel Nedjo Anicic

9 shall be in charge of resolving the issue of prisoners and their

10 categorisation and deportation to Manjaca. First category, politicians.

11 Second category, nationalist extremists. Third category, people unwelcome

12 in Sanski Most municipality. In view of this, have a talk with Colonel

13 Stevilovic from the 1st Krajina Corps."

14 Now, Witness, whilst you were in prison at the police station did

15 you ever hear talk of these categories of prisoners?

16 A. No, I had not.

17 Q. Now, if you were to categorise yourself, which category would you

18 place yourself in?

19 A. I would place myself in the category of a non-Serb, because I'm

20 not of Serb ethnicity.

21 Q. Are you saying, then, that the reason for your deportation was

22 simply because you were a non-Serb?

23 A. Yes, because I'm a Bosniak, a balija, or a Croat Ustasha.

24 Q. Are you aware that you appear on a list where you are categorised

25 as an extremist? And we'll look at that list in a moment.

Page 6162

1 A. Well, let me tell you. I had seen no lists. I was arrested among

2 the first. Maybe they had an opinion on me concerning this. And the

3 first arrest began on the 25th of May, and I was arrested among the

4 first. But in the prison I already found that retarded person, Meho, also

5 known as Znojko, who is also a Bosniak, a balija just like I am.

6 Q. Now, in paragraph 2 of this document -- and we'll get to the list

7 in a moment. But in paragraph 2 of this document, it says: "The Crisis

8 Staff hereby decides to appoint Drago Vujanic prison warden. Dismiss

9 Papric."

10 Now, you stated earlier in your evidence that when you arrived at

11 the prison that Papric was in charge. Were you aware at any time that he

12 was replaced by Drago Vujanic as the prison warden?

13 A. I didn't hear about that, but I could assume so by the visits.

14 Q. You saw Drago Vujanic at the police station; correct?

15 A. Yes, I did.

16 Q. Now, up until the 10th of June -- 9th, 10th of June of 1992, was

17 there any violence against any of the prisoners at the police station

18 cells, if you can recall? Up until that time.

19 A. Up to the 10th of June, we who were imprisoned, nobody even

20 touched us.

21 Q. Would you say you were treated well until the 10th of June?

22 A. Well, they didn't treat us badly.

23 Q. Now, if I can just show you Prosecutor's Exhibit 663. And this is

24 a document to the commander of the Manjaca military training facility

25 command, and it is the last paragraph of this document which interests

Page 6163

1 me.

2 "We wish to let you know that we are still holding several

3 persons in the detention rooms in the public security station and that we

4 shall also send them to you for further procedure after the operative

5 processing."

6 A simple question: On the 6th of June of 1992, were you in the

7 detention rooms of the public security station in Sanski Most?

8 A. Yes, I was, in prison, which is in the courtyard of the police

9 station, the public security service.

10 Q. And if you can remember, how many other Muslims were with you at

11 that time, on the 6th of June, at the public security station?

12 A. All of those who I had listed; however, the number increased.

13 Q. To how many approximately, if you can remember?

14 A. I believe that there were 14 or 15 of us. In one of the cells, 7;

15 and the other cell, I believe 8. However, in the meantime, Meho, the one

16 I talked about, they let him go. That also -- Marinko -- Marinko had been

17 set free, as well as Ibro.

18 Q. Now, it says at the beginning of this order that "In accordance

19 with the agreement reached with the Banja Luka Corps command, Colonel

20 Stevilovic and the chief of the police department of the Banja Luka

21 security services centre, Stevan Markovic, we are sending you a group of

22 persons who were captured during combat operations in the municipality of

23 Sanski Most, as well as the persons who cooperated with them in the course

24 of preparations for an armed uprising in the municipality of Sanski

25 Most."

Page 6164

1 Are you aware that on or about the 6th of June of 1992 there was a

2 transfer of prisoners from Sanski Most to Manjaca?

3 A. Yes, I am aware of that. It was the second group of prisoners

4 from Sanski Most which were transferred to Manjaca.

5 Q. Again, only if you can recall this matter, do you know what date

6 this second group were transferred?

7 A. On the 3rd of June.

8 Q. Now, the date of this order is the 6th of June of 1992, so how is

9 it possible that they were sent on the 3rd of June of 1992?

10 A. Well, I do not know. I cannot tell you. However, the first group

11 was transferred to Manjaca on the 3rd of June, approximately 152

12 individuals from the school of Hasan Kikic; and the second group,

13 approximately 172 persons, on the 6th of June from the prison, from the

14 Betonirka, and from the hall Dvorana [phoen] in Sanski Most.

15 Q. Now, again, bearing in mind that you were in a prison cell while

16 this was taking place, when did you find out that these transfers had been

17 made?

18 A. Well, at -- to tell you -- I can tell you on the same day, because

19 the people from the cells were transferred to the prison. Ibro Kuzelj was

20 released, and he was already in Manjaca with the first group on the 3rd of

21 June.

22 Q. Again, I'm not -- I don't understand the answer to that question

23 fully. Again, I'm asking you how did you know that these groups, these

24 two groups, had been transferred from Sanski Most to Manjaca camp if you

25 were in a prison cell behind the police station?

Page 6165

1 A. Well individual persons from the cells were sent -- transferred

2 to Manjaca. Concretely from the cell number 1, Stipe Catic, Saletovic

3 Fikret, Ismet Jakupovic, Ismet Alagic were sent and transferred to

4 Manjaca. They were called out, taken, and we immediately assumed, which

5 turned out to be right, that they were sent and transferred to Manjaca.

6 Q. Did you subsequently meet up with these people at Manjaca?

7 A. Yes. Yes, I met them there all, all of them.

8 Q. Now I want to move to the period of the 9th or 10th of June of

9 1992, when I know conditions changed for you at the police station. Can

10 you tell the Judges what happened around that time to you.

11 A. Up till the 9th of June, I was in the prison. Once I was called

12 for questioning by Dosenovic, who was carrying out the inquiry. With

13 him I had -- I had a correct questioning session, even a pleasant one. He

14 asked me about my past work, about the work of the executive board. He

15 asked me questions. And on Christmas on the 24th and the 25th of

16 December, 1991 I went to Croatia. That was one of the questions, why did

17 I go? And I went, in fact, to Croatia because for the central heating for

18 Sanski Most we ordered a big boiler from the TPK. And after that

19 Christmas, the exchange rate changed between the dinar in Croatia and the

20 rest of Yugoslavia. The exchange rate of dinar in Croatia was 1 to 2,

21 compared to the rest of Yugoslavia. And so in order not to pay a double

22 price for these -- this heating boiler, we went to Croatia to re-confirm

23 that contract and to have this order re-confirmed.

24 On the 9th of June, I was called out --

25 Q. Now we're talking about 1992 now.

Page 6166

1 A. Yes, I'm speaking of 1992. Yes, that was 1991, and now I am going

2 back to 1992, on the 9th of June, 1992. At 10.30 I was called for what

3 they call processing. Osmancevic Haso, Kurbegovic Redzo, and Faik

4 Biscevic. We were interrogated separately, individually, each one in a

5 separate room. The interrogation was carried on by Stanic Rajko, also

6 known as Rajkica, who began by saying, "Do tell us what you had been

7 doing. But first let me ask you a question: Do you know where Adil

8 Draganovic is?" I answered, "No, I don't know." "But let me tell you.

9 Adil Draganovic is in Manjaca. He wants to join a single nation -- party,

10 and that is where he is now." This is the way we talked. Otherwise

11 Rajkica and I, we were acquaintances. I asked them, "What do you want to

12 know?" And he said, "You know, I want to hear what you want -- what I

13 want to know." Then he left, and three persons who were here, they

14 started beating me. They really beat me, and I concluded that the beating

15 took an hour. And then Rajkica would tell me -- say again, "Tell me

16 again." So we talked another three to five minutes. It wasn't like

17 that. And then Rajkica left the room, and again they were beating me for

18 about an hour's time. The third time he came in, he said -- he said,

19 "Mirzo, write it down." And then I wrote Mirzo Karabeg from Sanski Most,

20 member of the SDS. He said "No, Mirzo, this isn't it." So he left, and

21 again they continued to beat me. But I was sitting on a chair, and they

22 brought another chair through which I had to push my legs. Two were

23 beating me on my head, my shoulders, my back, and the third one was

24 beating me on my soles, the soles of my feet, and on my legs and with full

25 force.

Page 6167

1 After that, some -- an hour passed, and Rajkica returned. And he

2 said, "Mirzo, get down. Go down and think it over." I went down to the

3 ground floor. I went to the corner, sit down, look in the corner -- and

4 raise -- I had to raise my head and look on the wall. I -- people were --

5 I don't know how the people heard. But anyway, they were still beating me

6 with fists. Then I don't know from where, a cable. After that they took

7 me back, and after all of this I asked whether I could drink a bit of

8 water. They gave me a pitcher like this and I drank the water. Then a

9 policeman came, and he said, "Take your things." I collected my

10 belongings and from the prison went to the Betonirka facility.

11 Q. Witness, can you stop there, because I have a few questions to ask

12 you. Stanic, who was he?

13 A. Stanic Rajko used to be a judge, the municipal judge in the

14 municipal court in Sanski Most. And in that case, he was the investigator

15 who was doing the interrogations.

16 Q. Do you recall the names of the people that were beating you in the

17 interrogation room?

18 A. Yes.

19 Q. What were their names?

20 A. Zoric. He's also an investigator in the police. I just can't

21 remember his first name. Mico Krunic. And there was a third, younger man

22 whose name I cannot recall but who was wearing -- and I saw that very

23 well -- a very neat military uniform with Chetnik insignia, the cockade,

24 and some other symbols indicating Serb-hood.

25 Q. What kind of physical condition were you in prior to leaving for

Page 6168

1 Betonirka?

2 A. Well, I was all beaten up. It is very hard to describe the

3 condition I was in. I was in terrible condition. You see, it was the

4 first time in my life to get a beating, the first time.

5 Q. Now, you said on the final occasion you went downstairs and that a

6 number of people came off the streets to beat you. Who were these people?

7 A. Well, you see, I didn't dare turn around. I wasn't allowed to see

8 them. But judging by the comments I heard, I heard that individuals came

9 and asked, "Who is that?" I am not a hundred per cent sure, but I am 99

10 per cent sure that it is someone called Kudro, a neighbour of mine, who

11 replied, "It's my neighbour, Mirzo." I didn't dare turn around to see who

12 was beating me, because maybe if I had turned around that moment I

13 wouldn't be sitting here today. I would have been killed.

14 Q. What were you beaten with when you were on the ground floor when

15 you're at this point in time?

16 A. With fists, feet, pieces of electric cable, and wooden poles,

17 wooden planks -- a pole, actually, as we call it in our jargon.

18 MR. CAYLEY: Mr. Usher, if you could hand these photographs out.

19 This is P799, Your Honour.

20 Q. Could you put that on the projector next to you, please,

21 Mr. Karabeg. What is this place?

22 A. These are the garages of Betonirka.

23 MR. CAYLEY: And perhaps for the record, the witness is referring

24 to Prosecutor's Exhibit 799.

25 Q. Whereabouts were you detained in this set of garages?

Page 6169

1 A. I was detained in the third one. One, two, three, this one.

2 Q. So the witness is indicating the red door of the garages on the

3 left of the photograph, the end door on the left as one looks at the

4 photograph.

5 A. May I with your permission add, in those days these garages did

6 not have this roof, and this part here was missing too. It was built

7 after the war. So there were just these three garages, without any roof,

8 with a flat concrete slab on top.

9 Q. How big was the room that you were kept in at Betonirka,

10 approximately? I mean, I suppose you --

11 A. Well, approximately 3 metres by 6 metres. 3 metres wide, 6 metres

12 long.

13 Q. Until what point in time were you kept in this room?

14 A. Until the 7th of July, the 7th of July, 1992.

15 Q. How many prisoners were kept in this cell with you? The least

16 number and the most, if you can remember.

17 A. The least were there when I arrived. I found four people there.

18 The largest number was 36.

19 Q. So at a point in time, there were 36 people in a room that was 6

20 by 3 metres; is that what you're saying?

21 A. Yes. Yes.

22 Q. What was the food that you received like? What was the quality of

23 the food?

24 A. We were given food in the morning and in the evening. Usually it

25 was leftovers from their men who were working round the prison or the MUP.

Page 6170

1 What was left over was distributed amongst us.

2 Q. What was the sanitary conditions like?

3 A. The sanitary conditions were dreadful. We were shut up in this

4 cell. We would be released in the morning for five to ten minutes and in

5 the evening for five to ten minutes. We had to relieve ourselves in the

6 garage, both to urinate and for our bowel movements. But when we were

7 allowed outside, we could use the field toilet that was there within the

8 compound of this camp. We slept on the concrete. We had nothing as a

9 cover. Once we were given some styrofoam. But I think this was

10 intentionally done because when you lie down on this foam, it breaks, it

11 cracks and then you have to remove it because it hurts you. It's like

12 pieces of stone or sand bothering you as you lie down, so you have to put

13 it away.

14 Q. Now, you said earlier in your evidence that you'd been beaten

15 before you arrived at Betonirka. What medical facilities were made

16 available for the treatment of your injuries at Betonirka?

17 A. We had none.

18 Q. Now, you've said already there were 36 people in this room. How

19 was the room ventilated? How did you get air in this room?

20 A. To the side, there was a small window and that was all. But the

21 problem was that people complained of -- especially in the central

22 garage, there was no window at all, in the garage in the middle.

23 Q. In your room, did you have sufficient air?

24 A. Not at all. There was not sufficient air. There was 36 in that

25 one room inside all day long.

Page 6171

1 Q. How did you manage to sleep with 36 people in one room?

2 A. Well, let me tell you. It was like this: Due to the

3 mistreatment, the conditions, sometimes one falls asleep but they wouldn't

4 let you fall asleep even then. There was a man called Milan Martic who

5 was the worst. And when he was shift leader, he would designate one of us

6 in the garage to watch so that all of us would remain standing all night.

7 And as a reward, the person watching can sit down. We were loathe to

8 accept, but if you didn't accept you would get beaten. And then every 15

9 minutes he would send a policeman in to check, to peep in and to check

10 with a flashlight whether we were still on -- all on our feet. This went

11 on like this from 7.00 in the evening, when his shift started, until 7.00

12 in the morning, when it ended.

13 Q. Who did you understand was in the charge of the camp at Betonirka?

14 A. Well, the main person in the camp was Vujanic Drago and his deputy

15 Mico Krunic.

16 Q. Do you recall the names of any of the guards?

17 A. I recall many names of guards, but just now for the moment the

18 names don't come to me. But unfortunately these were all people I knew.

19 These were all people from Sanski Most.

20 Q. Let us talk about the physical violence at Betonirka. And if you

21 can give a summary of what happened to you in that camp to the Judges.

22 A. When the interrogation ended in the prison and the mistreatment

23 there --

24 Q. And here you're talking about the public security station now.

25 A. No. I'm talking about the 9th of June on -- 9th of June, 1992. A

Page 6172












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Page 6173

1 guard told me, "Pick up your things and move to Betonirka." When I got

2 there, I was told, "Go to garage number 3." I left my things there that

3 same moment I was called out for beating. This man Martic started

4 beating me immediately, and he was the first one to ask me, "What did you

5 want to do to our children," he said. That was the first time I heard of

6 it. And he beat me until 11.00 in the evening. That day, the 9th of

7 June, I was beaten from 10.30 in the morning until 11.00 in the evening.

8 I don't know whether there was perhaps a pause of two hours in between.

9 If we were to add up all the pauses of five to ten minute, maybe they

10 would amount to two hours. And the time it took for me to move from the

11 prison to Betonirka, which is about a few hundred metres away, and it took

12 me about 15 minutes to get there.

13 Q. Now, when he was asking you about what you wanted to do to our

14 children, what was referring to?

15 A. On the radio, they started reporting that I had lists for

16 circumcision of young boys of three and a half and for raping Serb girls.

17 At first they said of six, eight, ten, twelve years of age, and they said

18 that they had found those lists in my drawer. Afterwards I learnt --

19 because you know what people are like -- nobody asked themselves whether

20 these lists really existed, but everyone said, "How could he have been so

21 crazy as to keep those lists in his drawer?" So you can imagine the kind

22 of propaganda they had. To preempt everything, they said that there were

23 these lists that they had found in my drawer.

24 Q. Had you written these lists?

25 A. Of course not. It never occurred to me.

Page 6174

1 Let me add, the last time I went into my office was on the 19th of

2 April, 1992, and I was arrested on the 25th of May, 1992, which means that

3 if there had been any lists, they would have been disclosed. No

4 reasonable or intelligent man ever had any such ideas. But let me repeat,

5 their propaganda was that they had found those lists in my drawer, and the

6 people residence reaction was, "How could he have been so crazy as to have

7 kept those lists in his drawer," lists that had never existed nor had the

8 compiling of any such lists ever occurred to anyone.

9 Q. Now, you've talked about when Martic beat you. And now I want to

10 move on to the time that you refer to when Martic and Kajtez beat you.

11 Can you tell the Judges what happened on that occasion.

12 A. After, I think, about two days, Nihad Kljucinic was suspected of

13 the same thing, who was with me in Betonirka but not in the same garage.

14 About 7.00 in the evening we were allowed out, but Martic and Kajtez were

15 beating Nihad. "Where are those lists," they said. After beating Nihad,

16 they called me and they said to Nihad, "Here is your pal. You will find

17 out from him where his lists are." They ordered me to kneel down like a

18 donkey, on my -- go down on my hands and knees. They gave Nihad a stick

19 to beat me with. As he started to beat me gently, they picked up the

20 stick and continued beating him, swearing at him, and then hitting me a

21 couple of times as well. After that, they let Nihad go and they continued

22 beating me, the two of them, with these batons.

23 And there was a car that Martic drove, and they pushed me against

24 the car. Martic took a stick and put it under my chin. Kajtez took a

25 knife as if to cut off my ear. Then they continued beating me. I don't

Page 6175

1 know what kind of a system they had, but as I was between the two of them,

2 one would -- would hit me with his behind and the other one would hit me

3 with his stick and vice versa. They went on beating me like this for all

4 of two hours. And you know what was typical? They beat me within the

5 compound of Betonirka, and the people from Kruhari -- and this is a

6 neighbourhood inhabited 99 per cent by Serbs -- behind the wire fence were

7 watching this, and they were rooting as if they were watching a match, of

8 course in their favour. "Beat him, the motherfucker. What did he want to

9 do to our children," they were saying. "People like that should not be

10 allowed to walk on this earth."

11 Q. Were you ever told why you were being beaten?

12 A. I told you. Because of this list. I had a list. But did they

13 find the list in my drawer? And they're beating me and demanding the list

14 of me.

15 Q. Now, I don't want to go through every beating up until the 7th of

16 July, when you left Betonirka camp, but was there a day during the time

17 that you were there when you were not beaten?

18 A. Let me tell you. I believe that it might have been on the last

19 and one but last day that I spent in Betonirka that I wasn't beaten, and

20 that could have been the 6th and 7th of July, because around 11.00 when

21 they had vacated Betonirka and sent everyone to Manjaca, there were six of

22 us left from Betonirka that were sent on to prison.

23 Q. Were you ever beaten by somebody called Tonci at Betonirka?

24 A. No.

25 Q. Now, on the 7th of July of 1992, where were you moved to?

Page 6176

1 A. To the prison.

2 Q. Now, you're talking about the public security station in Sanski

3 Most; correct?

4 A. Yes, yes. Yes, the prison that I was in prior to Betonirka.

5 Q. And how long did you stay in this building? What was the period

6 of time that you remained here?

7 A. From the 7th of July until the 28th of August, 1992.

8 Q. And how were you treated at the public security station during the

9 period from the 7th of July until the 28th of August of 1992?

10 A. Well, the treatment was the same, but the beatings became rarer

11 after representatives of the International Red Cross arrived and after we

12 were registered.

13 Q. Why did the beatings become less regular after members of the

14 International Red Cross arrived?

15 A. Well, I am unable to give you an answer, but all I could say is

16 that that very moment when I was registered by the International Red Cross

17 I started to live with a little more hope of survival, that I wouldn't be

18 killed, because representatives of the International Red Cross after

19 interviewing us -- when interviewing us would not allow anyone from the

20 police to be present. We were alone with them, and with each one of us

21 they conducted a frank and honest interview. They inquired about the

22 conditions we were living in, our health, whether we had any contact with

23 our families. And from then on, we were allowed every Saturday to meet

24 with members of our family within the prison compound for 10 to 15

25 minutes.

Page 6177

1 Q. Do you recall the beating that you got on the 22nd of August of

2 1992 just before you left for Manjaca?

3 A. Yes.

4 Q. Can you describe that beating.

5 A. It was like this: When I said that they started beating us less

6 frequently, they beat us on Saturday evening so that we could recover by

7 next Saturday, when our family members came to visit us. On that 22nd of

8 August, I remember very well it was a Saturday evening. We had been

9 accustomed to this portion of beatings that we would get until next

10 Saturday came. And five of us, we were in cell number 2 in the prison,

11 myself, Osmancevic, Nihad Kljucinic, Osman Talic, and Franjo Ilicic. Just

12 then we had been released to go and wash, to the toilet, and we went to

13 the toilet to wash. We returned to the cell and one of the policemen

14 asked our names. I said my name was Mirzet Karabeg, and everyone else

15 gave his name. And when it came to Osmancevic's turn, he asked him, "Is

16 that who you are?" And he started beating him. And he came back to the

17 cell, and we asked why he beat him, and he said, "I don't know. He asked

18 me my name, and he hit me about ten times. He kicked me and he hit me

19 with his fists." We sat down in the cell. First Osman Talic was called

20 out. We thought that Osman Talic was going to clean up his canteen and to

21 be in the fresh air for a while at least. After --

22 JUDGE AGIUS: Mr. Cayley, I think we better stop here for the time

23 being, and the witness can have a rest too.

24 And Mr. Karabeg, you will continue after the break, because we

25 need to break now because we have certain standards that we have to keep.

Page 6178

1 Thank you.

2 Thirty minutes.

3 --- Recess taken at 12.31 p.m.

4 --- On resuming at 1.01 p.m.

5 JUDGE AGIUS: Before we continue, Mr. Cayley. As you see, we are

6 just two of us now. Judge Janu is temporarily indisposed. She will

7 hopefully be with us tomorrow. In the meantime, we are applying the

8 special rule that we have and continuing with just the two of us here.

9 Yes, Mr. Cayley.

10 Yes, Mr. Ackerman.

11 MR. ACKERMAN: Just for the record, Your Honour, I want to state

12 an objection to continuing with just two Judges. I just want to make it a

13 matter of record.

14 JUDGE AGIUS: Yes. Okay.

15 MS. FAUVEAU-IVANOVIC: [Interpretation] Mr. President.


17 MS. FAUVEAU-IVANOVIC: [Interpretation] I join Mr. Ackerman in his

18 objection.

19 JUDGE AGIUS: Okay. Yes, Mr. Cayley, do you have to say anything

20 about -- are you objecting too?

21 MR. CAYLEY: No. I'm not objecting, but I obviously have respect

22 for the Defence's objection. I -- could you remind me of the rule,

23 because I don't really have it to hand. I remember in a previous case in

24 which this happened, we -- it was done under Rule 70(B) as a deposition.

25 But I know after judge Riad's long illness that the rules were changed to

Page 6179

1 allow continuation --

2 JUDGE AGIUS: There are -- we're talking of Rule 15 bis. And

3 there are three or four different scenarios, the first scenario being that

4 under capital A, "If a Judge is, for illness or --" in this case, it is

5 illness as you may have noticed in the course of -- Judge Janu wasn't

6 feeling well yesterday, and she wasn't feeling well this morning, and she

7 still isn't feeling well. "If a Judge is, for illness or other urgent

8 personal reasons, or for reasons of authorised Tribunal business, unable

9 to continue sitting in a part-heard case for a period which is likely to

10 be of short duration, and the remaining Judges of the Chamber are

11 satisfied that it is in the interests of justice to do so, those remaining

12 Judges of the Chamber may order that the hearing of the case continue in

13 the absence of that Judge for a period of not more than three days."

14 The second option is under B, "If a Judge is, for illness or

15 urgent personal reasons, or for reasons of authorised Tribunal business,

16 unable to continue sitting in a part-heard case for a period which is

17 likely to be of short duration, and the remaining Judges of the Chamber

18 are not satisfied that it is in the interests of justice to order that the

19 hearing of the case continue in the absence of that Judge, then those

20 remaining Judges of the Chamber may nevertheless conduct those matters

21 which they are satisfied it is in the interests of justice that they be

22 disposed of notwithstanding the absence of that Judge, and the Presiding

23 Judge may adjourn the proceedings."

24 The third scenario I don't think I need to read because I do not

25 have an indication that Judge Janu's illness is one which is expected to

Page 6180

1 be longer than of a short duration. So I will -- you will spare me having

2 to read that. Yes, that's the position.

3 MR. CAYLEY: So you're making the order in --

4 JUDGE AGIUS: We are -- we are applying, A -- 15 bis (A) --

5 applying A -- 15 bis (A). In other words, we are satisfied that it's in

6 the interests of justice to continue hearing today in the absence of

7 Judge Janu and then we'll take stock again of the situation tomorrow. But

8 I have an indication from Judge Janu that tomorrow she will be here.

9 MR. CAYLEY: Yes, Your Honour. Thank you.

10 Q. Witness, if I could remind you where we were prior to the break.

11 And I would like to try and finish your evidence by quarter to 2.00. So

12 we have 40 minutes left. You were explaining the 22nd of August, 1992.

13 And a man by the name -- I think you said Osman Talic was called out. Can

14 you briefly explain what happened to him and then explain very briefly

15 what happened to you on that day.

16 A. As I have said, Osman was called out. We thought he'd clear out

17 the canteen and the yard, the yard of the police station and the prison.

18 Some 40 minutes passed, and Osman returned to the cell, beaten up, holding

19 his hand, and as he told us, one of the wardens took his hand and put it

20 under a tap of -- turned on the hot water and we saw that from that hot

21 water the skin and the tissue was scorched to the bone. After that, Nihad

22 was called, Franjo, also beaten up. After that, I was called out. From

23 the cell to the yard, it's some 20 metres, and I was escorted by a

24 policeman, and two persons were talking among themselves. I came closer

25 to them. I expected that they would be hitting me. One kicked me. He

Page 6181

1 hit me, and then one of them said, "Look at Alija's warrior. Let me see

2 if Alija taught you how to pray and to kneel." So I did kneel. I also

3 placed my hands forward. I didn't see it, but he held in his hand a

4 wooden leg of a table. He hit me like this. As I was kneeling, the

5 second one in boots, he kicked me and said, "Get up. Your balija's

6 mother. Bend again, kneel again, you balija." And they hit me again.

7 But it was the other side of my shoulders. And so this lasted some 40

8 minutes. They took me back to my cell. I thought that I wouldn't survive

9 that night and that I would die due to the pain. I sat out the whole

10 night. We were, all of us, beaten up and in the morning when I got up, I

11 then tried to lie down on my belly, on my stomach. I lay down, and in the

12 morning when they let me go out to relieve myself and to wash up, I looked

13 at myself in the mirror. On my back, the capillaries were like if you

14 took a red marker and just drew some lines. And so for the next 20 days I

15 was sleeping on my stomach. There was no chance of sleeping on my back or

16 sideways.

17 After 20 days, I could sleep for a time on my back but not on the

18 sides. Neither on the left side nor on the right side, so that I had

19 quite a few problems in sleeping. I had pains for about half a year. And

20 even today I wake up in pain when I turn on my left side -- to sleep on my

21 left side.

22 Another characteristic aspect: One of them -- a person I didn't

23 know -- he was a military officer, and another one, a policeman. His

24 surname was Mauda but I don't know his name.

25 Q. Witness, you say one of these individuals kicked you with his

Page 6182

1 boot. Where did he kick you?

2 A. Right here -- on the face and my head. As I was bending down.

3 But don't think -- when the doors opened, I always took off first my

4 glasses because they would certainly also break the glasses. I had a

5 warden, in fact, who entered a cell at the Betonirka. He found my

6 glasses. He took off my glasses and broke them.

7 Q. What was his name?

8 A. Dane Kajtez.

9 Q. What injuries did you suffer as a result of being kicked in the

10 face and the head?

11 A. I don't have a single tooth. I have artificial prosthesis. And

12 if need be, I can show that but only to the Judges.

13 Q. No. I think the Judges are satisfied that you've had your teeth

14 kicked out of your head.

15 On the 28th of August, you moved to Manjaca; is that right?

16 A. Yes, indeed.

17 Q. Did anybody that was with you at the police station remain at the

18 police station?

19 A. We were a group of 15 in the cells in the prison. Thirteen of us

20 were taken out, and we were told to get on the bus and to remain. Kamber

21 Hasib and Seferovic Emir.

22 Q. So the two individual that is you've name right hand the two

23 individuals that remained at the police station prison; correct?

24 A. Yes, in the prison.

25 Q. What happened to them, if you know?

Page 6183

1 A. They were killed.

2 Q. Do you know who by?

3 A. I do not know who killed them, but I do know that they were

4 killed. Their places -- they were disinterred, and then they were

5 officially buried. And I was there when the exhumation took place and I

6 saw them dead.

7 Q. You arrived at Manjaca camp. What was the first thing that

8 happened to you when you arrived at Manjaca?

9 A. I would only like to make a comment. I believe that also among

10 the Serbian nation there were also people with common sense and fine

11 people. One of the wardens who escorted us -- and there were four of

12 them -- when entering the bus, he said, "Sit in the bus and sit wherever

13 you wish to sit on the bus."

14 Q. You're talking now about the trip from Sanski Most to Manjaca.

15 A. Yes, from Sanski Most to Manjaca. "You will be taken to Manjaca.

16 I'm escorting you. Nobody is allowed to say anything bad against you and

17 nobody dare touch you." And that is how it was, until we arrived to

18 Manjaca.

19 When we arrived to Manjaca, there were 49 of us on the bus: 13

20 from the police prison and the rest from the hall Krings. And when we

21 arrived to Manjaca, we were -- we went off the bus, and they told us that

22 there was another bus which will be taking the released detainees from

23 Manjaca. And that's true. Because Klucinic Nihad came to Manjaca. And

24 his father, who was 70 years, was leaving Manjaca. They didn't allow them

25 to establish contact. They just waved to each other, waved hands.

Page 6184

1 When we came to Manjaca, we were told that we would be going for a

2 medical check-up in groups of eight. The eight of us in that group in

3 which I was also, we had to undress completely. And two doctors, two

4 physicians, who were also detainees from Sanski Most, were checking us,

5 asking for our names, surname, place of birth, date of birth, and whether

6 we have any injuries. And behind them, the guards of Manjaca, Serbs, were

7 checking our belongings to see whether we have any money, any gold, or

8 anything of any valuables among these objects that we brought in. After

9 that, we dressed. After they checked our belongings and after they

10 collected what was of value, they took us to a place where we then waited.

11 After everybody has been examined, we were taken to the Manjaca camp, camp

12 number 2. There was one camp but which was then divided into two with

13 wire.

14 Q. Witness, if you could stop there for a moment. And I just want to

15 ask you a couple of questions. You said that the guards of Manjaca were

16 checking your belongings to see whether you had any money, any gold, or

17 anything valuable. Now, you also went on to say, "They collected what was

18 of value." Why were they collecting these items? What for?

19 A. Well, to appropriate these objects. Well, it was something which

20 they wanted to take for themselves, their loot, because these things they

21 took we've never seen them.

22 Q. Do you recall if you personally had anything taken from you?

23 A. Well, you see, I succeeded in hiding a valuable watch. It was a

24 momento and it was a Tissot watch. I've never seen it again. I didn't

25 have any money, and I had no other valuables, because they were already

Page 6185

1 collected in Sanski Most in the prison and in the Betonirka.

2 Q. So this watch that you had was taken from you at Manjaca by the

3 camp guards; correct?

4 A. Yes.

5 Q. I'd just like to show you a series of photographs which you

6 haven't seen before and just to see if you recognise any of them.

7 MR. CAYLEY: Mr. Usher.

8 Q. These are some digital photographs that have been taken.

9 If you could put it on the ELMO. And if you could take the map

10 off, Mr. Karabeg. Sorry to ...

11 Do you recognise these photographs?

12 A. Yes, I do recognise it.

13 Q. Could you tell the judges what it is.

14 A. These are the barns where we were housed in Manjaca.

15 Q. Now, again -- and only if you remember -- do you recall which barn

16 you were housed in? Is it one of the three that's portrayed in this

17 photograph?

18 A. Well, let me put it this way: As I told you, there were two parts

19 of the camp. I was in camp 2, in the barn number 2. And if this is it,

20 then it would be the central barn in the middle.

21 MR. CAYLEY: So the witness is indicating on this photograph that

22 he believes that if this is camp number 2, then he was in the barn

23 portrayed in the middle of this photograph.

24 What is the exhibit number for this?

25 JUDGE AGIUS: 800.

Page 6186

1 MR. CAYLEY: 800. And this is Prosecutor's Exhibit 800.

2 If I could show to the witness the next photograph.

3 Q. Now, this is the interior of one of the barns. And they were all

4 the same. Can you indicate in this photograph -- as I say, it may not be

5 the barn that you were located in, but can you indicate on this photograph

6 the area that you occupied whilst you were a prisoner at Manjaca?

7 A. Well, first the door where one enters is here. And I was on the

8 left very close there to the upper part at the beginning, and that is

9 where I stayed and I slept also.

10 MR. CAYLEY: So the witness is indicating on this photograph of a

11 barn on the -- at the end on the left by the door in the centre of the

12 photograph. And that is Prosecutor's Exhibit 801.

13 Q. Witness, when you arrived at Manjaca at the end of August of 1992,

14 how would you describe conditions there?

15 A. Let me put it this way: First when I came to Manjaca, what I

16 observed was that there were many people who were just bones, skin and

17 bones, very thin. And there were certain individuals who couldn't stand

18 on their legs. And those very thin would then be picked up by two

19 people -- they'd make like a seat with their hands and carry these very

20 thin people.

21 As far as the conditions are concerned, when you -- let me

22 tell you. When you sleep on a concrete floor and you have nothing to

23 cover yourself with, when you don't have sanitary conditions to maintain

24 your personal hygiene, when you cannot -- there's no place to relieve

25 oneself, where you're followed your every step and you have to be careful

Page 6187

1 not to make a move which wouldn't please them, you cannot describe it

2 otherwise as terrible conditions. When individuals are being beaten.

3 Q. Was there violence that you were aware of at Manjaca at the end of

4 August and onwards until the time that you left?

5 A. Yes, there was. Yes.

6 Q. Can you describe the physical violence that you were aware of that

7 was taking place in the camp during this time.

8 A. Well, you see, it was like this: A detainee was beaten twice

9 because he spoke to his brother across the wire fence. There was Begisba

10 [phoen], a detainee who slept close to me went with a group of other

11 detainees under escort to fetch water, to bring it back in a jerrycan, and

12 he tried to pour clean water into the can and a guard approached him and

13 beat him up because of this, and I saw him covered in blood. His name was

14 Semin Vajzovic. And people continued to be taken for interrogation and to

15 isolation cells for beatings. A group was brought in, I believe, of some

16 126 people from Kotor Varos and almost all of them were beaten. And we

17 continued to hear screams during the night from the beatings in the

18 isolation cell.

19 Q. Were you personally the victim of any physical violence at

20 Manjaca?

21 A. Once a guard hit -- kicked me in the back because I was going to

22 collect rain water in my can near the canteen where this was possible. I

23 didn't see, as it was raining and I had a hood on my head, and he

24 approached me from behind, kicked me, so I fell into the mud. And he

25 said, "Get lost from there," and he swore at Alija -- Alija's mother.

Page 6188

1 Q. Now, did you know the names of any of the guards at Manjaca that

2 were dishing out these beatings to the prisoners?

3 A. Well, I knew them by their nicknames. There was one called --

4 they called Spaga, another one they called Tito. And while I was at

5 Manjaca, I avoided moving around very much. I tried to move as little as

6 possible so as to emerge alive and well from there.

7 Q. Did you speak whilst you were at Manjaca to prisoners who had been

8 there since June of 1992?

9 A. I did.

10 Q. Did they describe what conditions were like then?

11 A. They did.

12 Q. How were conditions in June of 1992 at Manjaca? Better than in

13 August, worse than in August?

14 A. Well, let me put it this way: In June 1992 the people who arrived

15 there first suffered some horrors. First of all, they were starved.

16 Secondly, they had to do work duty. They were frequently beaten,

17 especially cries could be heard from the isolation cell at night. And

18 they called this interrogations. Furthermore, they frequently were

19 subjected to a kind of call-out. They would take out all the detainees

20 from all three stables. They would call out their first and last names.

21 And then the other guards would enter the stables and search around to see

22 if they could find anything of value to appropriate for themselves. I

23 also attended such a call-out when I arrived at Manjaca. It was sometime

24 the second or third day. So it could have been the 29th or the 30th of

25 August when this happened.

Page 6189

1 Food was given to them in the morning and in the evening, a small

2 slice of bread.

3 Q. Did conditions improve between June and August of 1992, as far as

4 you're aware, from your conversations with the inmates?

5 A. Well, it was like this: Talking to fellow inmates, they all said,

6 and I felt it myself, that changes had occurred with the arrival of the

7 International Red Cross. First of all, to start with the food. It was a

8 great thing then to get a quarter of a loaf of bread in the morning and

9 another quarter in the evening. The International Red Cross also

10 conducted medical examinations.

11 I had a case when a detainee Omer Kalic had some medical problems,

12 and he asked me to talk to a young lady who was the interpreter there, to

13 ask her if he could see a doctor who spoke German and he too spoke German.

14 And he asked that with a group of patients who were being prepared for

15 treatment in London that he be one of that group. And when the doctor

16 examined him, he put him on that list. But that was the only way he could

17 go. He had no other chances, because he had reported that he had this

18 drainage tube fitted and his health problems, but they did not agree to

19 have him examined, so this was one way in which the International Red

20 Cross helped us. And it was mostly thanks to the International Red Cross

21 that we survived.

22 MR. CAYLEY: If the witness could be shown Prosecutor's Exhibit

23 668.

24 JUDGE AGIUS: Yes. You have five more minutes, Mr. Cayley.

25 MR. CAYLEY: I see, Mr. President.

Page 6190


2 MR. CAYLEY: 668, yes.

3 And if you could hand it to me and I'll -- all right.

4 Q. Now, Witness, here in front of you, you see a list.

5 MR. CAYLEY: And if that list could be placed in English on the

6 ELMO, please.

7 Actually, it's the other English list. They're the same, but

8 they're numbered slightly different. Just so we have the same as the

9 witness.

10 Excuse me, Mr. President. Sorry.

11 Q. Now, this is a list entitled "List of the most radical extremists

12 in the area of Sanski Most." Do you see that?

13 A. I do, yes.

14 Q. Who is number 50 on this list?

15 A. Karabeg Mirzet, me. That's me.

16 Q. Now, can you go through this list and indicate whether or not

17 these individuals ended up at the Manjaca camp, as far as you know. If

18 you don't know, just say "I don't know." So just go through 1 to 50 and

19 identify whether those people were at Manjaca camp.

20 A. Let me see. Talic Elhad, Malovcic Fikret - I'm just reading

21 the names of the people with whom I was in the camp - Burnic Ferid,

22 Sahmovic Eniz, Hodzic Rahim, Kamber Dzevad, Avdic Ismet, Handanagic Vahid,

23 Karabeg Rasim, Smajlovic Ferid, Makic Husein, Supuk Bajro, Supuk Senad,

24 Lovric Zdravko, Hromalic Mujo, Bahtic Rifet, Islamcevic Hakija, Celic

25 Emsud, Kugic Senad, Omic Mehmed, Halilovic Nijaz, Sarcevic Fehim, Skripic

Page 6191

1 Andjelko, Kolakovic Ismet, Marijan Josip, Krupic Omer, Besic Enver,

2 Halimovic - not Halilovic - Midho, Sarajlic Salahudin, Zukic Esef, Krupic

3 Ismet, Kuzelj Ibrahim, Maric Jakov, Lovic Sefik, Kamic Mirzet, Pasic

4 Ibrahim, Zukic Asim, Karabegovic Samir, Kurbegovic Nedzo, Biscevic Fajko,

5 Osmancevic Hase, Kljucinic Nihad, Talic Osman, Burnic Semso, Kicin Jusuf,

6 Okcic Nesib, Karic Remzo, Sahic Suad, Karabeg Mirzet. I know all of them.

7 They were all there.

8 Q. They were all at Manjaca?

9 A. They were all at Manjaca, all of them. They were all from Sanski

10 Most.

11 Q. Would you describe these people as radical extremists?

12 A. These people, their only fault is that they were not Serbs, that

13 they were Bosniaks -- of Bosniak and Croat ethnicity.

14 MR. CAYLEY: Mr. President, I've now completed my

15 examination-in-chief and I can offer the witness for cross-examination.

16 JUDGE AGIUS: [Microphone not activated] That will be tomorrow, of

17 course.

18 MR. CAYLEY: Yes.

19 JUDGE AGIUS: [Microphone not activated] I thank you, Mr. Cayley.

20 THE INTERPRETER: Microphone, Your Honour.

21 JUDGE AGIUS: Yes, I'm sorry.

22 I thank you, Mr. Cayley. Cross-examination will commence

23 tomorrow.

24 I assume that Madam Fauveau will be starting. Yes.

25 MS. FAUVEAU-IVANOVIC: [Interpretation] I will begin, and I'll

Page 6192

1 certainly be using most of tomorrow's hearing time.

2 JUDGE AGIUS: So Mr. Karabeg, we are stopping here for today. We

3 will resume tomorrow morning at 9.00. And tomorrow you're going to face

4 the first of the two cross-examinations that will take place. It will be

5 the Defence team for General Talic that will cross-examine.

6 I thank you once more, and you will now be escorted out of --

7 outside this courtroom. Thank you.

8 [The witness stands down]

9 JUDGE AGIUS: All right. We'll meet tomorrow morning at 9.00.

10 Thank you.

11 MR. CAYLEY: Yes, Your Honour.

12 --- Whereupon the hearing adjourned

13 at 1.46 p.m., to be reconvened on Wednesday,

14 the 29th day of May, 2002, at 9.00 a.m.