1 Monday, 11 June 2007
2 [Open session]
3 [The accused entered court]
4 [The witness entered court]
5 --- Upon commencing at 9.04 a.m.
6 JUDGE ROBINSON: In the absence of Judge Mindua, Judge Harhoff and
7 I sit pursuant to the provisions of Rule 15 bis.
8 Mr. Tapuskovic.
9 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honours. Good
11 WITNESS: WITNESS T-53 [Resumed]
12 [Witness answered through interpreter]
13 Examination by Mr. Tapuskovic: [Continued]
14 Q. Witness T-53, last time we began the examination-in-chief and you
15 spoke about what you saw from the place from which you were looking at
16 Pofalici. In addition to what you already said, you mentioned a friend of
17 yours and his parents. How did this whole episode in Pofalici end, in
18 terms of what you saw and what you learned?
19 A. What I saw with my own eyes was that the Serbian houses were set
20 on fire, that it gradually moved to the hill above Pofalici. Later, I
21 learned that a terrible crime had been committed there, that many
22 residents of Pofalici were killed and that their bodies had not been found
23 and buried to this date. I cited an example of the parents of a friend of
24 mine about whom I know for sure that haven't been buried to this very day.
25 Q. Thank you. How long did you stay in this place that you mentioned
1 last time? If we can please have the map on the screens, the map that was
2 shown to the witness last time. It's 65 ter 02829, and it already
3 contains certain markings.
4 So the map, 65 ter 02829.
5 JUDGE ROBINSON: Will it ever appear? Is there a problem?
6 Because I don't see how we can wait much longer. Ah, it's here finally.
7 MR. TAPUSKOVIC: [Interpretation] Witness, last time you explained
8 and put certain letters relating to something that you were asked about.
9 Tell me, how long did you remain in these positions as a fighter?
10 A. Until the 28th of May 1992 is the date by which I remained in this
12 Q. Thank you. Can you please tell the Judges where did you move
13 after that?
14 A. After the 28th of May, 1992, due to certain circumstances, I
15 started, so to speak, my service in the logistic organ of the
16 Sarajevo-Romanija Corps, its technical service.
17 MR. TAPUSKOVIC: [Interpretation] Your Honours, can we now move
18 into a private session?
19 JUDGE ROBINSON: Private session.
20 [Private session]
11 Pages 6391-6402 redacted. Private session.
6 [Open session]
7 THE REGISTRAR: Sorry to interrupt, Your Honours, we are back in
8 open session.
9 MR. TAPUSKOVIC: [Interpretation]
10 Q. In that respect, were you able to take any action on your own with
11 respect to fuel, ammunition, et cetera? Who took care of that?
12 A. I, as an individual and as a desk officer in the technical
13 service, was not able to do anything on my own initiative. Everybody
14 knows what a desk officer is in charge of. However, due to the
15 intelligence that indicated that the BH army was to launch attacks,
16 meetings were held with company managers; that is to say the companies
17 situated in the area of Serbian Sarajevo. They earmarked some money from
18 the money they had in their accounts in order to procure and buy fuel for
19 the units. The problem was that laws and regulations were in force saying
20 that 30 per cent of the fuel should be allocated for other structures, and
21 the corps was very far away where fuel was available.
22 Q. Thank you. Let us not leave aside now food and clothing. Let us
23 concentrate on ammunition now. Did you find anything about what kind of
24 requisition orders issued for ammunition?
25 A. The standard and usual communication with units was that units,
1 based on their needs, would submit a request to the command of the
2 Sarajevo-Romanija Corps, i.e. to the logistics organ of the command of the
4 Q. Did you know who was the person in charge, the main decision
6 A. The requests received and processed by the logistics department
7 for the Main Staff of the army of Republika Srpska were approved by the
8 technical service of the Main Staff of Republika Srpska. The munition was
9 stored in the depots of the 27 logistics base which was in charge of
10 supplies of the Sarajevo-Romanija Corps and the Drina Corps of the VRS.
11 Q. Can you explain to the Judges what kind of ammunition was
12 available at the time in light of everything that you mentioned? Were
13 there any problems in that respect?
14 A. There were problems, but the Main Staff in most cases gave its
15 approval for infantry ammunition. That was the time when the truce was in
16 place and when the artillery was to be placed in the exclusion zone, I
17 don't know at exactly what distance. Therefore, there was no need for
18 artillery ammunition.
19 Q. Maybe you didn't understand me. What I meant was, at the time
20 when you learned about the imminent attack, what happened after the attack
21 at Zlatiste? What happened next?
22 A. The attack on Zlatiste that took place some time in the latter
23 part of May. From that moment on, it became obvious that units had to be
24 replenished with fuel and ammunition. In that period the units received
25 certain amounts of ammunition and fuel from the Main Staff and were more
1 or less prepared to encounter the BH attack.
2 Q. Thank you. Tell me, do you know anything about - and I'm going to
3 ask you this directly - about air bombs?
4 A. Some time in early June, requests kept coming in -- started --
5 correction, started coming in for air bombs.
6 Q. Were you ever in a position to do something about this? You
8 A. The requests were forwarded to the Main Staff of Republika Srpska
9 army. At the time, I knew that there was no need for these type of
11 Q. Thank you. Did you ever see a report about these weapons being
12 used some place -- somewhere, whether these air bombs were used?
13 A. The reports on the use of ammunition, as a rule, were submitted to
14 the operations organ. Sometimes they were submitted to the logistics
15 organ as well. But I personally did not see these reports. Since the
16 rears -- the logistics was in Pale and I was in Lukavica, I couldn't --
17 had no opportunity to see these reports. The consumption of the
18 ammunition at that period was so minimal that there was no need for these
20 Q. I'm going to ask you -- show you a document. You said that you
21 arrived there in late December and you started working in early January.
22 I'm going to show you a document and ask you whether perhaps you had an
23 opportunity to see it, and it's 65 ter 03222.
24 JUDGE HARHOFF: Mr. Tapuskovic, while we wait for this document to
25 come up, could I ask the witness why he said that according to his
1 evaluation, there was no need for these type of weapons? Speaking about
2 the air bombs.
3 Mr. Witness, why did you think that there was no need for these
4 weapons? What was the basis for your estimation of that?
5 THE WITNESS: [Interpretation] The Sarajevo-Romanija Corps
6 naturally didn't have aircraft or air force. There was no need,
7 therefore, for air bombs. I have never seen an air bomb myself. It was
8 not stored in depots of the Sarajevo-Romanija Corps. So I never had any
9 contact with this type of ammunition.
10 JUDGE HARHOFF: But were you aware of the possibility of launching
11 these weapons from ground positions?
12 THE WITNESS: [Interpretation] I didn't know that at the time. A
13 month later, after the BH army commenced its attack on the units of the
14 Sarajevo-Romanija Corps, at one point, while listening to the news of the
15 BH federation or the Muslim radio, I don't know how it was called at the
16 time, I heard, and there was a live programme on, and I heard a person who
17 phoned in from Kosevo and who said that some kind of air bomb had dropped
18 but that did not explode. After that, another person phoned in, I think
19 he or she was living in Alipasino Polje and said that a bomb had dropped
20 on Alipasino Polje, that there were no wounded people but that shrapnel
21 were as big as buckets. That is the first time that I heard about air
22 bombs. That's it.
23 JUDGE HARHOFF: And when was that?
24 THE WITNESS: [Interpretation] It was sometime in early July 1995.
25 JUDGE HARHOFF: Thank you very much. Well, the document is on the
1 screen so let's move on.
2 MR. TAPUSKOVIC: [Interpretation]
3 Q. Can you please look at this document? Did you perhaps ever see a
4 document like this? And you can also take a look at who issued this
5 document and what it pertains to. I'm not going to lead you about what
6 this document is about. Can you please read it out loud?
7 A. "To the SRK command, based to --
8 THE INTERPRETER: Could the interpreters have the proper page in
9 English, please?
10 THE WITNESS: [Interpretation] Based on the oral --
11 MR. TAPUSKOVIC: [Interpretation]
12 Q. Can you now please look at item 12? We are talking about November
13 and December 1994 and it shows the consumption, and item 2 is aerial
14 bombs. It says, "3 pieces." Were you aware that sometime in November or
15 December 1994, three aerial bombs were used? Did you know anything at all
16 about that?
17 A. I didn't. I was living at the time in Pale, as I said. I was a
18 civilian. And I had no way of knowing whether this was used or not.
19 Q. So what happened next during 1995, after this offensive was
21 JUDGE ROBINSON: Are you going to ask the witness about the source
22 of the document?
23 MR. TAPUSKOVIC: [Interpretation] This is document 65 ter, and the
24 source, I think, should be explained by the Prosecutor.
25 Q. Witness, can you please --
1 JUDGE ROBINSON: Who signed it?
2 MR. TAPUSKOVIC: [Interpretation] Yes. That is something that I
3 omitted to ask.
4 THE WITNESS: [Interpretation] This document was signed by
5 Lieutenant-Colonel Milivoje Solar assistant commander for logistics. And
6 he sent this document to the assistant commander of logistics.
7 Mr. Milivoje Solar was stationed in Lukavica and the command post,
8 the rear command post, was at Pale.
9 JUDGE ROBINSON: Thank you. Move on.
10 MS. ISAILOVIC: [Interpretation] Mr. Chairman, Mr. Chairman, I'm
11 sorry, there is a serious mistake. It's on page 20, line 10. The rear
12 command post was in Pale.
13 [Interpretation] The witness didn't speak about this. He said the
14 command post of logistics, not the rear command post. And it's not quite
15 the same. The rear command post but not in Pale.
16 JUDGE HARHOFF: Thank you very much. I have noticed that same
17 mistake earlier on in the transcripts and I suspect it will be corrected
18 later on.
19 MS. ISAILOVIC: [Interpretation] I didn't realise it popped up
21 JUDGE ROBINSON: Let's move on.
22 MR. TAPUSKOVIC: [Interpretation]
23 Q. Since His Honour, Judge Robinson, asked a question relating to
24 this document, in your opinion, the document as it is with the letterhead
25 and the signature and the contents, is something that you have no doubts
2 A. Of course I don't. It's been properly registered. It's been
3 signed, and I have no doubts about this document.
4 Q. Can you then please explain this to the Judges? What was the
5 situation in May, June, July, in the wake of the conflicts or actually
6 what were the conflicts like at the time?
7 A. The conflicts started on the 16th of June 1995, when the BH army
8 attacked Iljas, Vogosca, and they were the fiercest ones from the
9 beginning of the war. According to the information obtained by the army
10 of Republika Srpska, the strongest forces were brought to the positions of
11 the BH army from all of their units. In the previous six months or a
12 year, I watched on the BH television reports provided by certain officers
13 about the attacks. My personal opinion, and thanks to the command of
14 General Milosevic, the positions of the units in -- of Republika Srpska
15 army in the region of Sarajevo were defended. If you ask me how do I know
16 that it was precisely the 16th, I remember that day because that was my
17 wife's birthday, and they attacked Vogosca, Iljas, on that day. After
18 that the attacks were shifted to the area of Kijevo near Trnovo, then to
19 the area of Zlatiste and Lukavica. In all these places, the BH army
20 initially shifted their lines. However, owing to the engagement of the
21 personnel who were defending their homes and their families, the BH army
22 forces were repelled in these first two days.
23 JUDGE HARHOFF: Mr. Witness, can I just ask you one additional
24 question in relation to the attack of the ABiH in June 1995? Did you have
25 any information about the reasons why the ABiH launched this attack? What
1 was the purpose of the attack?
2 THE WITNESS: [Interpretation] The BH army had their own
3 objectives. A unified Bosnia-Herzegovina with no Serbs in it. They
4 wanted to beat the Sarajevo-Romanija Corps, conquer the territory defended
5 by the Serbs who had lived in the area for centuries. If you want more
6 information, I'll be happy to provide it. Look at my family. We had
7 lived in this place since 1880, according to official information. I at
8 one point drew up a family tree and I know this. We have been living in
9 the same place for the last 130 years. The address changed many times,
10 but the place remains essentially the same.
11 JUDGE HARHOFF: I have no doubt about the right of the Serbs to
12 remain in the areas which they have inhabited. That's not the issue. The
13 issue is whether you were aware or whether you had gathered intelligence
14 or knew of any intelligence that had been gathered about the specific
15 situation in Sarajevo, because I assume that what you just told me or told
16 the Chamber was the general purpose of the ABiH. But what was the
17 specific purpose of these attacks in relation to the situation in
18 Sarajevo? That was my question.
19 THE WITNESS: [Interpretation] My answer to that question is this:
20 The BH army was out to beat the Sarajevo-Romanija Corps in order to attain
21 its objectives. I don't know about their specific objectives. I think
22 they should know, not me.
23 MR. TAPUSKOVIC: [Interpretation] If Your Honour, Judge Harhoff,
24 has finished with his question, perhaps I was going to ask you, but I
25 don't think there is any point now.
1 Q. I'm asking you this instead: How did the civilians feel, the
2 people behind the lines held by the army of Republika Srpska, civilians in
3 their flats, houses, with their children, families, what exactly were
4 those people feeling? And if you could also tell us what the civilians in
5 Sarajevo itself were feeling at the time?
6 A. I can tell you about the civilians in the Serb parts. My family,
7 my neighbours, were all concerned about what was going on. They were all
8 concerned about their lives. However, everyone down to the last man were
9 determined to fight and defend what was theirs. Throughout the war, most
10 of the population never left their homes at all. They were perfectly
11 capable of defending their own homes, and they were prepared to sacrifice
12 their lives to avoid leaving their respective areas. The same thing
13 happened during the June 1995 attack. All the forces were concentrated on
14 defending the Serb areas and that's why the areas were eventually
15 defended, for that reason alone. There were other areas where units from
16 other corps came and those units sometime abandoned their positions.
17 Everyone rose to defend the Serb positions, from those aged 18 to senior
18 citizens who were still strong enough to carry a weapon. Rest assured
19 that this was the only reason that the area was actually defended. The BH
20 army operations were incredible, mind boggling, the fiercest since the
21 beginning of the war. Only those who were determined to defend their
22 homes could remain.
23 Q. Witness, you told us about what those people were feeling. I
24 wasn't going to ask you about this but still, were there any casualties
25 among the soldiers and civilians in the places that you went, where you
1 were or your position?
2 A. Of course there were casualties. Back in May, when the first
3 attack was launched, I went back home to see how my family were doing.
4 Just below the fort at Zlatiste. I saw that hundreds of shells had
5 fallen, launched by the Muslims. Just outside my home, I was looking at
6 this, and I could not understand how they had got hold of all the
7 ammunition given the problems that we had with ammunition shortage. I
8 don't know how they got their ammunition, but I know that their supplies
9 at the time were far better than ours. I don't have any information to
10 indicate that to any degree of specificity. But what I saw there and then
11 would seem to suggest that they had enormous amounts of ammunition.
12 Q. All right, witness. You're telling me about ammunition, and I'm
13 asking you about human lives. What about casualties among soldiers and
14 civilians to the extent that you were able to observe?
15 A. Reports on those killed never reached my department, my service,
16 but I know that on the 17th of June, at one point in time, during that
17 morning, five soldiers were killed along the front line. Two of those
18 were my relatives. There were other civilians who were killed, but I'm
19 hard put to tell you anything about those. I wasn't there and my
20 information is hardly appropriate.
21 Q. Just to wrap this up, can you tell us what happened in August,
22 September, October? What exactly happened?
23 A. In late August -- you're probably going to laugh, but I was off to
24 my honeymoon on the 29th of August. The 30th of August is my birthday.
25 So just the day before my birthday, we were off on our honeymoon in
1 Montenegro. During our stay there, swift intervention units attacked,
2 units of the corps. After I was back from the sea coast, I reassured
3 myself that nobody was hurt among my neighbours but the -- substantial
4 material damage had occurred. I got my orders to make an assessment of
5 damage to the buildings inside the Lukavica barracks. I don't have the
6 information at my fingertips but I know that damage was severe, especially
7 that which occurred to maintenance buildings where we repaired vehicles.
8 There was one particular building in the Lukavica barracks where vehicle
9 repairs were being carried out and there was a lot of damage there.
10 Q. Sir, can you finally tell me this --
11 JUDGE ROBINSON: I was going to ask you to remind us again how you
12 weave all these attacks by the Serb forces into the defence, into your
13 case. It's very important for me to understand it and as you go along, I
14 am trying to work it out, you know? It seems to me, and you have said
15 this before, that what you are saying is that it's not just that the --
16 sorry, the ABiH forces were responsible for attacks, but that the attacks
17 with which the Serb forces are charged in the indictment leading to the
18 charges of murder as a crime against humanity, inhumane acts, a crime
19 against humanity, and so on, that the Serb forces, in all cases, acted
20 responsively to attacks by the ABiH and that is how we arrive at the
21 allegations made by the Prosecution.
22 Because, of course, you know that it's not sufficient to show that
23 the ABiH forces also committed crimes. So I presume you're going further
24 than that, and it is -- it is in that area that I am seeking clarification
25 and I'm only seeking clarification in trying to understand how the defence
1 is putting its case. So we have just listened to the witness narrate a
2 series of attacks by the ABiH forces, and in some cases he did speak of
3 the Serbs defending their positions, defending themselves. But can you
4 just let me know again how the case is being put?
5 MR. TAPUSKOVIC: [Interpretation] Your Honours, I will try to be as
6 brief as possible since my time is running out, and I'm going to try to
7 reply to this. You know that --
8 JUDGE ROBINSON: [Microphone not activated] Explanation that you
9 give in response to a question like this will not count against your time.
10 MR. TAPUSKOVIC: [Interpretation] What I think I should tell you
11 right now, if we look at the indictment, and I don't have one handy, the
12 most important count is the fact that the army of Republika Srpska had a
13 single objective, that of killing civilians, deliberately, by design and
14 by direct targeting. The most important thing being its objective was to
15 spread terror among the civilian population. My -- I have told you a
16 number of times and needless to say, I will always try and explain this.
17 What exactly the situation was between the beginning of August and the end
18 of 1994?
19 JUDGE ROBINSON: I'm sorry, Mr. Sachdeva?
20 MR. SACHDEVA: Mr. President, I'm terribly sorry to interrupt but
21 I was wondering if my learned friend was going to be providing an answer
22 to your question that this could be done in the absence of the witness,
23 lest there be any possibility for prejudice before my cross-examination?
24 JUDGE ROBINSON: I don't see the need for that, Mr. Sachdeva. You
25 have seen this done before in the Tribunal?
1 MR. SACHDEVA: I have actually in the previous case that I worked
2 on, the Galic case, I know that when issues of substance were discussed
3 which impacted directly on witnesses' testimony, sometimes the witness
4 would be asked both by the Defence and the Prosecution to be taken out of
5 the courtroom. It's simply a submission, and I obviously defer to your
6 rulings. But it has been done in the past in my experience.
7 JUDGE ROBINSON: I will not follow that practice in this case
8 because I frankly don't see the need for it. So I'm going to ask
9 Mr. Tapuskovic just to explain briefly the situation that I raised.
10 MR. TAPUSKOVIC: [Interpretation] Your Honours, in our view, and
11 this is something that we were going to show during our case, there was a
12 peaceful period between the end of December and May or June, during which
13 there were few incidents, and one certainly couldn't say that anyone at
14 all was subjected to terror in that period. If we speak of terror in the
15 circumstances of a war such as this one, then this terror can't be in one
16 area and not in another. As we keep adducing evidence, I will show you
17 how terror was forced on the Serb population outside these areas, and this
18 cannot be considered a tu quoque. There was terror on both sides in both
19 population groups; fear of war, everybody wanted the war to stop, but the
20 war was renewed in the most intensive way possible in May and June not
21 thanks to any efforts on the part of the army of Republika Srpska. And
22 atrocities continued because of these renewed operations.
23 By this time there would probably be no more fear, no more
24 terror, had the offensive by the BH army not taken on these dimensions.
25 Whatever the BH army did throughout this period of time, and I'm not
1 talking about any time before this, I'm looking at the period and the
2 circumstances under which Mr. Dragomir Milosevic operated at the time and
3 particularly during this specific offensive, there were not sufficient
4 weapons, there was no ammunition, there was only the hope that whatever
5 was done was done in extreme necessity, and the hope that no one would be
6 jeopardised by direct targeting. I will be dealing with each of the
7 incidents separately stated in the indictment, saying that crimes were
8 perpetrated by direct firing, directly targeting the civilians. We will
9 be dealing with that and I'm sure that we shall be successful in proving
10 that in most cases it was not proved beyond a reasonable doubt that the
11 incidents were committed the way that it is claimed.
12 As for terror, that prevailed throughout the war, this was due to
13 a fierce offensive launched by the BH army and nothing else. Had that not
14 occurred, the war would probably have been over by May any way, possibly
15 even earlier, regardless of any strategic political and historical
16 circumstances surrounding this situation, which is not something that I'll
17 be dwelling on. The facts of the case are peace had been going on for
18 sometime and had this offensive not occurred, it would have stayed like
19 that. Any reaction was absolutely called for. There had to be some
20 reaction. They couldn't just sit on their hands. But the objective of
21 this reaction was not to threaten anyone or put anyone's lives at risk, as
22 to any forms that occurred later on or whatever may have happened --
23 JUDGE ROBINSON: From what you have said, I think the important
24 submission is that as for terror that prevailed throughout the war this
25 was due to a fierce offensive launched by the army and nothing else. I
1 presume you mean launched by the BiH army.
2 MR. TAPUSKOVIC: [Interpretation] At the time, certainly, had it
3 not been for that offensive nothing else would have happened. The
4 previous five months, according to our information, had been filled with
5 peace. No incidents. In the autumn of 1994, when offensives occurred and
6 clashes occurred along front lines that were remote and far from any urban
7 centres. There were sporadic acts of provocation more than anything. So
8 that is what really characterises that period of time, and the army of
9 Republika Srpska didn't do much. Some say it's because they'd already
10 taken by this time what they were aiming at. But there was no option at
11 this time and witnesses will show this to launch any sort of action at
12 all. The objective was to simply remain where they were and that was
13 about it.
14 [Trial Chamber confers]
15 JUDGE ROBINSON: Before you move on, I just want to correct
16 something. When I started by asking the question I referred to the Serb
17 forces, and the reference should have been to the BiH forces.
18 Please continue. And please note that you are now beyond the time
19 that had been allocated.
20 MR. TAPUSKOVIC: [Interpretation] Your Honour, Judge Robinson, I am
21 glad that I had another opportunity to say it in response to your request
22 and it is my duty to offer this kind of explanation. However, I think
23 that in redirect, I will have an opportunity to clear and clarify
24 some things with the witness. I wanted to show him certain documents, but
25 I think we should leave it for a later stage and at this point I would
1 like to finish my examination and give the floor to my learned colleague,
2 the Prosecutor.
3 JUDGE ROBINSON: Yes. Well, we just have two minutes. We'll take
4 the break now.
5 --- Recess taken at 10.27 a.m.
6 --- On resuming at 10.53 a.m.
7 JUDGE ROBINSON: Yes, Mr. Sachdeva.
8 MR. SACHDEVA: Thank you, Mr. President.
9 Cross-examination by Mr. Sachdeva:
10 Q. Good morning, to you Witness. My name is Manoj Sachdeva and I am
11 a lawyer for the Prosecution, and I will ask you some questions today.
12 You know that you have protective measures, so I will refer to you as T-53
13 or Witness.
14 Just to start with, is it possible to have that document, the
15 previous document, up on the screen again, please?
16 Witness, Defence counsel just showed you this document, and I
17 recall that in your evidence, you said that this was a correct and valid
18 document from the SRK; is that right?
19 A. I can only say that I'm looking at a report which was compiled in
20 keeping within the regulations. As for the accuracy, I wouldn't know. I
21 was not there at that moment, and I can't tell you whether this is
22 accurate or not. But judging by everything I see, it should be the case.
23 Q. And if we can just scroll down to the bottom on the English
24 version, the signature there -- perhaps we can go into private session,
25 Mr. President?
1 JUDGE ROBINSON: Yes, private session.
2 [Private session]
25 [Open session]
1 THE REGISTRAR: Your Honours, we are back in open session.
2 MR. SACHDEVA:
3 Q. Witness, I just want to get a proper understanding of your
4 movements from May 1992 throughout the conflict. You told the Court that
5 you moved from various places to various places. I understand that on the
6 28th of May in 1992, you were posted at Lukavica barracks for about 15
7 days; is that right?
8 A. Yes.
9 Q. And after that, you moved to a place called Tilava, am I right?
10 A. Yes.
11 Q. And then from September 1992 through to 1st of April 1994, you
12 were at Pale?
13 A. Yes. In the facility that you've mentioned, which is Turist
15 Q. Right. And then after that from the 1st of April 1994 up until
16 January 1995 or December 1994, you told the Court that you went back to
17 the factory that you used to work for before the war, and am I correct in
18 saying that would be the Famos factory?
19 A. I didn't have enough time to explain things to Mr. Tapuskovic's
20 question. Two or three years before the war, the car factory in Sarajevo
21 was split into several facilities. And when this happened, I became
22 affiliated with the factory of special vehicles. I returned to that
23 factory. It's very difficult to explain. And those people who lived
24 there didn't understand it. I did not want to go into that much detail in
25 front of the Court. So the correct -- the accurate name of that factory
1 would be the factory of special vehicles.
2 Q. Was that factory at the Famos location?
3 A. That factory -- actually, Famos was located in several places.
4 Most of it was in the locality call Hrasnica, in the lower part of the
5 eastern Sarajevo. Whereas another part of the factory, the overhaul part
6 of the factory, was in Pale. In 1994, from the 1st of April to the end of
7 that year, I spent in Pale. This is where I resided. I resided in Pale.
8 I got married when I did, as I've told you, which took place in Grbavica.
9 I would go there occasionally, maybe once or twice in a fortnight, to see
10 my parents, and then I would return to Pale.
11 Q. Just continuing with the Famos factory in Hrasnica. Through your
12 work, were you aware of what was made in that factory at Famos in that
13 period, 1994-1995?
14 A. There was no production in the Famos at that time. The separation
15 line between the army of Republika Srpska and the BiH army went through
16 the factory itself at the time.
17 Q. Nevertheless, the Famos factory was controlled by the VRS in that
18 period, was it not?
19 A. I said that the separation line went through the Famos perimeter.
20 One part of the facility was under the control of the BH army and the
21 other under the control of the VRS army. On the 7th of April 1992, was
22 the last time when I was in that part of the factory where I had worked.
23 On that day, I took my leave, and I never returned to the factory until
24 the end of the war.
25 Q. Did you hear during your time at the factory and also after the
1 conflict broke out that optical sights for rifles were produced at the
2 Famos factory? Did you ever hear that?
3 A. Famos never produced optical sights for the rifles. Maybe I could
4 tell you where they were produced. Would you be interested in that?
5 Q. Why don't you tell the Court where they were produced.
6 A. Optical sights were produced in the Zrak factory in Sarajevo which
7 was under the control of BiH army. Famos never manufactured optical
8 sights, never ever.
9 Q. Now, I want to concentrate on your time at the Lukavica barracks
10 from January 1995 through to, I understand, the end of August 1995.
11 That's the time you were there, was it not?
12 A. It is not completely correct. I was there until the end of the
13 war. Until the moment the command of the Sarajevo Corps was moved to
14 Pale, and I don't know the exact date. From the 1st of January 1995 up to
15 sometime in December 1995, I would say.
16 JUDGE ROBINSON: Just a minute.
17 [Trial Chamber confers]
18 JUDGE ROBINSON: Witness, may I ask you about the evidence that
19 you gave concerning the optical sights being produced not in the Famos
20 factory but at a factory in Sarajevo that was under the control of the BiH
21 army? What period is this that you're talking about?
22 THE WITNESS: [Interpretation] The Zrak factory in Sarajevo, I
23 don't know when it was incepted, but my late cousin -- up to 1992, I'm
24 sure. I don't know what was going on in the war. I was never at that
25 factory, but I know that up to 1992 it manufactured optical sights for the
1 army of Yugoslavia.
2 JUDGE ROBINSON: And do you know who manufactured optical sights
3 for the Serb army?
4 THE WITNESS: [Interpretation] I don't know whether they were
5 produced at all. Any production is not under the control of the army but
6 of the Ministry of Defence. Whether optical sights were produced or not,
7 I can't tell you. There was a factory before the war which served the
8 needs of the entire state of Yugoslavia and during the war it was under
9 the control of the BiH army. Whether they continued their production
10 during the war I can't tell you. Before the war they did produce optical
12 JUDGE ROBINSON: Yes, Mr. Sachdeva.
13 MR. SACHDEVA: Thank you, Mr. President.
14 Q. Witness, I was just asking you about your time at the SRK command
15 Lukavica barracks from January through to the end of the war, and --
16 MR. SACHDEVA: Mr. President, I feel we need to go into private
17 session again, I'm sorry.
18 JUDGE ROBINSON: Private session.
19 [Private session]
10 [Open session]
11 MR. SACHDEVA:
12 Q. Witness, how many floors did the Lukavica barracks have?
13 THE REGISTRAR: Your Honours, we are in open session.
14 THE WITNESS: [Interpretation] I don't know what you mean.
15 MR. SACHDEVA:
16 Q. I'm asking you how many storeys or floors did the Lukavica
17 barracks have.
18 A. The Lukavica barracks occupies an area of approximately 100
19 hectares, approximately. I'm not an expert, but I would say that that is
20 the area. And there are several buildings in that area. I wouldn't know
21 their number. So we can't talk about any floors.
22 Q. Wasn't the operations department or the operations room on the
23 ground floor of the barracks? Is that right? Do you remember that?
24 A. I believe that either I am getting a wrong interpretation or your
25 questions are rather imprecise. I don't know what the problem is.
1 Q. I'm asking you whether the operations department of the SRK
2 command was in the ground floor of the barracks. If you don't know,
3 that's fine. If you do know, please tell me the answer.
4 A. Again, you're very imprecise. The operations centre of the
5 command of the Sarajevo-Romanija Corps was on the ground floor of a
6 building, not in the barracks. A barracks is a rather large term where a
7 building is just one facility, one building.
8 Q. So it was in the building that housed the command of the
9 Sarajevo-Romanija Corps; is that right?
10 A. Yes.
11 Q. And it was in the same building that Dragomir Milosevic had his
12 office; is that right?
13 A. Yes.
14 Q. And Mr. Krsmanovic's unit, that is your unit, was that in the same
15 building, too?
16 A. No.
17 Q. Where was that office?
18 A. That unit was located in the Turist Hotel in Pale. That's where
19 its base was. I and Lieutenant-Colonel Solar shared an office in a
20 building in the Lukavica barracks.
21 Q. And Mr. Krsmanovic, was he also in that building or are you saying
22 that he was at Pale?
23 A. During 1995, I saw Mr. Krsmanovic maybe on three or four
24 occasions. We did not share the same location. He was in command of the
25 rear echelon from the Turist hotel in Pale.
1 Q. Did yourself or Mr. Solar participate --
2 JUDGE ROBINSON: Ms. Isailovic? Sorry.
3 MS. ISAILOVIC: [Interpretation] Thank you very much,
4 Mr. President. Just one thing regarding once again the rear echelon in
5 the Turist hotel, because even Judge Harhoff realised that there was a
6 confusion systematically so between logistics and what could be that
7 echelon which is behind or sort of shifted compared to the normal command
9 JUDGE ROBINSON: So what are you saying should be the translation?
10 MS. ISAILOVIC: [Interpretation] Well, as far as I'm concerned, in
11 English, I would say, "the logistics command post," but I'm not an expert.
12 It's not the same. There are two different terms.
13 JUDGE ROBINSON: Thank you. Mr. Sachdeva?
14 MR. SACHDEVA: Perhaps we can move into closed session -- private
15 session, Mr. President.
16 JUDGE ROBINSON: Private session.
17 [Private session]
20 [Open session]
21 THE REGISTRAR: Your Honours, we are back in open session.
22 MR. SACHDEVA:
23 Q. Witness, okay now I'm understanding. Your office was on the same
24 floor as the general, General Milosevic. Can you confirm that?
25 A. Yes.
1 Q. And what floor was that? Can you tell the Court? Was it the
2 second floor? Was it the first floor? Of that building.
3 A. The building had a ground floor and the first floor, and we were
4 located on the first floor of that building, on the first floor.
5 Q. So that would be the top floor?
6 A. Yes, the top floor.
7 Q. And when you went into the office of Dragomir Milosevic, General
8 Milosevic --
9 MR. TAPUSKOVIC: [Interpretation] Your Honours?
10 JUDGE ROBINSON: Yes, Mr. Tapuskovic?
11 MR. TAPUSKOVIC: [Interpretation] We don't know the period of time
12 that is being dealt with when we're talking about all this. What period
13 of time is my learned friend referring to? Four years is a rather long
14 period of time.
15 JUDGE ROBINSON: Yes, Mr. Sachdeva? What period of time does this
16 relate to?
17 MR. SACHDEVA: Mr. President, I started asking the witness about
18 his time at Lukavica barracks, when he was stationed there from January
19 1995 through to the end of the conflict.
20 JUDGE ROBINSON: Thank you.
21 MR. SACHDEVA:
22 Q. Witness, you told the Court earlier that -- in response to a
23 question from the President about air bombs, you told the Court that you
24 heard about these bombs from the Muslim press, being fired into Sarajevo.
25 Do you remember saying that?
1 A. Not from the press. We did not receive any press. I said that I
2 heard it on the Muslim radio.
3 Q. And when you went into General Milosevic's office, did he also
4 have such means available, i.e. a radio and a television? Were those
5 contraptions present at the office?
6 A. Mr. Prosecutor, I've told you that I heard that at the beginning
7 of July 1995. I had a car radio. In my car, I had a radio, and I heard
8 it on the radio. I don't know what Mr. Milosevic heard or what others
9 had. I can only tell you what I heard. He may have heard it himself.
10 Maybe not. I'm a witness. I have declared that I would speak the truth
11 and that's what I'm telling you. I can't share anybody else's truth with
13 Q. I'm not asking you what General Milosevic heard. I'm simply
14 asking you that in his office was there a television in his office?
15 A. I suppose so. After such a long time, after 12 or 13 years, I
16 can't tell you whether there was a TV set. Maybe there was. There
17 probably was. And at times there was electricity and at times there
18 wasn't. That's all that I can tell you.
19 Q. And I understand that from General Milosevic's office there was a
20 view from his window on the city of Sarajevo, particularly Dobrinja; is
21 that correct?
22 A. As far as I know. I believe that from his office, you could not
23 see Dobrinja. You may be could see just one corner of Dobrinja, but I
24 would have to go back to that office to see exactly what he could see.
25 From my windows, I could see Mojmilo and I can't really tell you what one
1 could see from his window. It was on the other side of the building and
2 his office was facing Mount Igman. I really can't tell you with any
3 certainty whether he could see even a corner of Dobrinja.
4 Q. Presumably, though, as you've testified that you used to go into
5 his office, if there were, when bombs used to fall on Sarajevo, and in
6 Dobrinja, Mr. Milosevic would have been able to see the effects of those
7 bombs, that is the smoke rising from the ground; isn't that right?
8 A. Mr. Prosecutor, I've told you I never saw a bomb, a shell. I
9 never saw any action by shelling. I told you what I had heard. I was not
10 in such places where I could see any bombs. And as for Mr. Milosevic,
11 whether he saw something or not, I really can't tell you. I can't speak
12 on behalf of anybody else. Can I?
13 JUDGE ROBINSON: You were not being asked that. As I understand
14 it, you were being asked to say whether based on the knowledge, the
15 familiarity that you had with Mr. Milosevic's office, whether Mr.
16 Milosevic would have been able to see the bombs, the effects of the bombs,
17 and the smoke rising from the ground, from his office.
18 THE WITNESS: [Interpretation] I don't think so. I don't think he
19 could see anything from that office. Behind the building where the
20 command was located there was a theatre. The building had only one floor,
21 one floor and a half, and I really can't tell you what exactly he could
22 see from there. I believe that he could not see much from there.
23 JUDGE ROBINSON: Yes, Mr. Sachdeva.
24 MR. SACHDEVA:
25 Q. Witness, we spoke earlier about these meetings at the command and
1 of course, you told the Court that you wouldn't attend, but did the
2 persons that attended these meetings, did they ever discuss with you the
3 subject matter of these meetings?
4 A. I am a desk officer. What the chiefs were talking about at the
5 meetings, there is a principle of subordination in the military and the
6 chain of command is very well known. You have a commander, chief of
7 departments and then further on. If you think that some of these chiefs
8 talked about something, there was no need for that. I had my chief, I was
9 accountable to him. He gave me orders and I carried orders. That's how
10 it is.
11 Q. You were a desk officer, that's right but you also drafted or
12 requested documents for General Milosevic; did you not?
13 A. As I said, based on the requests from subordinate units of the
14 Sarajevo-Romanija Corps, based on their requests, the requests were
15 forwarded to the Main Staff of the army of Republika Srpska. Based on the
16 Main Staff's orders, ammunition was taken over in -- during a certain
17 period, the logistics organ of the SRK had a small ammunition depot under
18 their control and from that depot they could directly distribute
19 ammunition to certain units.
20 Q. And some of these requests were signed and sent out by the
21 commander, General Milosevic; isn't that right?
22 A. It is obvious that a commander issues orders. Certain things that
23 he ordered that related to the logistics I may have seen; I may not have
24 seen. I cannot tell you now. But in principle, some of the documents
25 were sent to the logistics command post at Pale, and some we -- some
1 documents were -- Colonel Solar and I were familiar with, probably
2 containing the information that Commander Milosevic thought we should
4 Q. In fact, General Milosevic ensured that he knew precisely the
5 requests that were going out to the Main Staff and it was him that made --
6 that gave the orders for the distribution of weapons within his command,
7 within his corps, within the SRK; isn't that correct?
8 A. He gave orders on rare occasions. In the majority of cases, as
9 far as I know, the orders for distribution of ammunition were issued by
10 Colonel Aleksa Krsmanovic. Also, the Chief of the Technical Service, Mr.
11 Antun Sinkovic, or the Chief of the Operations and Logistics, Mr. Solar,
12 could have issued these orders, but that was in most cases.
13 The war ended 12 years ago. You should understand that. And I
14 cannot tell you exactly who signed the documents. Whatever was under the
15 jurisdiction of the logistics was signed by the Assistant Commander for
16 Logistics, Mr. Aleksa Krsmanovic. In his absence, someone else may have
17 signed the documents.
18 Q. Let's talk about Mr. Krsmanovic. You knew him well, did you not?
19 A. Yes.
20 Q. And I take it that he took his job and responsibility seriously
21 and professionally?
22 A. It is difficult for me to say at this moment. I expected you to
23 ask me that. It is not very nice to speak ill about your superior. After
24 his son was killed in 1992, Mr. Krsmanovic acted strangely at times. His
25 son was killed in 1992, and I'm telling you that after that,
1 Mr. Krsmanovic behaved strangely in certain periods.
2 Q. He remained the commander of the unit up until the end of the war,
3 did he not, within the Sarajevo-Romanija Corps, the commander of your
5 A. Yes, yes.
6 Q. And as far as you were aware, when you had dealings with him, he
7 was a professional?
8 A. He was a communications officer per establishment and he worked in
9 the personnel department. He came to us from the personnel department as
10 a third commander. The first commander was Colonel Bosko Pasic --
11 THE INTERPRETER: Could the witness please slow down when listing
13 JUDGE ROBINSON: Just a minute, Witness. You're speaking too
14 fast. The interpreter is having difficulty following you.
15 MR. SACHDEVA:
16 Q. Witness, I'm sorry, I'm going to interrupt you, but I want us to
17 concentrate on Mr. Krsmanovic in his role as the commander of your unit up
18 until the end of the war.
19 Now, it is right, is it not, that Mr. Krsmanovic, in taking his
20 job seriously, would have to be aware of all the ammunition requests that
21 came to him and he would have to understand fully the workings of his
22 unit? Isn't that right?
23 A. He should have known. All these documents should have arrived on
24 his desk, as he was assistant commander for logistics.
25 Q. And in his role he would have had regular communication or in fact
1 meetings with General Milosevic; isn't that also right?
2 A. I cannot answer this question. I don't know how often they were
3 in touch. I said that in 1995, I didn't see Colonel Aleksa Krsmanovic
4 more than five or six times, ten at the most. He was in Pale.
5 Q. I'm not asking you what you know and what you saw. I'm simply
6 asking you in terms of the hierarchy, that his role, the role that he
7 occupied, would have necessitated regular meetings with the general and
8 the commander of the Sarajevo-Romanija Corps. Would you agree with that?
9 A. Yes.
3 JUDGE ROBINSON: Mr. Tapuskovic?
4 MR. TAPUSKOVIC: [Interpretation] Your Honours, so far we have
5 adhered to a rule that when something is being put to a witness, that he
6 first be told what kind of document is in question, where something is
7 being read from, before reading the document itself. We didn't hear at
8 all what this is all about. What document are we talking about? What
9 statement? When was it given and by whom? And only after that can
10 something be read out loud.
11 This is how we practised during these proceedings. However,
12 Mr. Sachdeva started reading immediately something. We, as the witness,
13 don't know what the document in question is. I think it would have been
14 more appropriate to tell the witness what the document is and then ask him
15 to comment.
16 JUDGE ROBINSON: He did say that this was a statement to the
17 Bosnian authorities in February 1996. Perhaps a little more would be
18 quite in order.
19 MR. SACHDEVA: As you've ordered, Mr. President. But also I fear
20 that -- are we in open session? I fear that we need to go into private
21 session and possibly the last paragraph should be redacted. I apologise
22 for that.
23 JUDGE ROBINSON: Private session, then.
24 [Private session]
11 Page 6437 redacted. Private session.
22 [Open session]
23 THE REGISTRAR: Your Honours, we are back in open session.
24 MR. SACHDEVA:
25 Q. Witness, it may be the case that brigade commanders could redeploy
1 weapons to another brigade within the SRK. However, you would agree that
2 the general, General Milosevic, would have been informed of that
4 A. I really cannot answer that question. I was not an officer and
5 there was no need for me to be involved in that. I didn't receive this
6 type of information. I was never in contact with the officers in charge
7 of other affairs such as deployment of equipment, et cetera. I don't know
8 where weapons of the army of Republika Srpska or the Sarajevo-Romanija
9 Corps were deployed.
10 Q. But, Witness, did you not sign documents on behalf of General
11 Dragomir Milosevic with respect to the deployment of weaponry or requests
12 for weaponry? You did that, didn't you?
13 A. As far as I know, and if my memory serves me well, I didn't sign a
14 single document during the war. I cannot be categorical. It lasted for
15 four years. But there were so many superior officers who signed the
16 documents. It wasn't my duty to do so, especially not on behalf of
17 General Milosevic. He had his staff, and I was very low down the chain of
19 Q. Actually, I apologise. What I actually meant to ask you was that
20 you drafted documents for Dragomir Milosevic. You may not have signed
21 them, but you drafted documents for Dragomir Milosevic's signature.
22 That's correct, isn't it?
23 A. For the documents relating to the logistics, that is to the supply
24 of units, it did happen that I prepared some of them.
25 Q. And I'm going to show you some documents now for the next ten or
1 15 minutes or so, but before I do that I wanted to talk to you about your
2 evidence with respect to the weaponry the ABiH had and the weaponry the
3 SRK had. You recall that you told the Court just before I started
4 examining you that you went to where you used to live, I recall, in May
5 1995, and you said that you saw the results of a hundred shells falling in
6 that area. Do you remember that?
7 A. Yes.
8 Q. And you also said that you were surprised that the ABiH had that
9 many weapons. Do you remember saying that?
10 A. Yes.
11 Q. But you never saw any document, or you never came across any
12 evidence that suggested the ABiH were superior in terms of weaponry, did
14 A. No. I didn't see any documents, but I saw with my own eyes these
15 hundreds -- I didn't count them- - but a larger quantity of heavy
16 artillery weapons that fell at 100 metres from my house.
17 Q. Let's just stick to what I asked you, please. And I think you've
18 confirmed your answer that you never saw any document. In fact, you told
19 the Court when you went to Lukavica barracks in May 1992 that the weapons
20 that were contained in the barracks were -- in fact, you said there were a
21 great number of tanks and howitzers and heavy weaponry. Do you remember
22 saying that?
23 A. Yes.
24 Q. And you also know that the factory of Pretis was controlled by the
25 VRS; is that right?
1 A. Yes.
2 Q. And the factory of Pretis produced weapons and ammunition for the
3 SRK, didn't it?
4 A. The factory of Pretis produced ammunition, not weapons. It
5 produced ammunition and for 50 years before the war, it worked to meet the
6 needs of the former state. That is why it was established and that is
7 what it produced before the war. It did have some production during the
8 war, but these were minor quantities, negligible quantities, compared to
9 what it did before the war.
10 Q. I'm only asking you about the war, the time during the war, and
11 it's correct that the Pretis factory produced ammunition for the SRK,
12 that's right, isn't it?
13 A. I will give you an answer to this question. According to its
14 position and state Vogosca was not under the jurisdiction of the SRK. Its
15 a factory that operated on economic principles. In order for it to
16 survive it needed money. Please allow me to give you an answer. I will
17 answer your question. It was under the jurisdiction of the Ministry of
18 Defence of the Republika Srpska.
19 Q. I'm not asking you under whose jurisdiction it was, I'm simply
20 asking you whether the factory at Pretis produced weapons for the
21 Sarajevo-Romanija Corps. That's all I'm asking you. Do you agree or
23 A. The interpreters are not translating properly. Not weapons. I
24 said ammunition. Pretis did not produce weapons. It produced ammunition
25 for the army of Republika Srpska.
1 Q. And you also know that in May 1992, the warehouse at Faletici, the
2 majority of weapons that were contained in that warehouse were taken over
3 by the VRS; that's correct, is it not?
4 A. I cannot answer that question. I was in a different place at the
5 time. I said that on the 28th of May 1992, I became a member of the
6 logistics organ. And I didn't receive any information of that nature at
7 the time.
8 Q. You never heard that was the case in spite of the fact that you
9 weren't there, you never heard that? You never heard that the Faletici
10 warehouse was guarded by JNA guards in that period?
11 A. There was no need for me to know that.
12 Q. And the 27th logistics base was in Sokolac, was it not?
13 A. Yes. Its headquarters was in Sokolac.
14 Q. And you said that it supplied the ammunition and weapons to the
15 Sarajevo-Romanija Corps and the Drina Corps; is that right?
16 A. Yes.
17 Q. So it's correct that the Sarajevo-Romanija Corps had access to
18 ammunition and weapons from a variety of sources; is that right?
19 A. Well, one can say that but in principle, if you allow me, I can
21 Q. I'd just simply want you to answer the question: Did they have
22 access or not?
23 A. Part of the ammunition, at the time when there were no combat
24 activities, the logistics organ of the command of the SRK kept the
25 ammunition in their warehouse within the compound of the 27th logistics
1 base in Pale. So for the most part, the ammunition depot was in Pale, in
2 the Jahorinski Potok barracks.
3 Q. And --
4 MR SACHDEVA: Mr. President, we need to go into private session. I
6 JUDGE ROBINSON: Yes. Private session.
7 [Private session]
11 Pages 6444-6450 redacted. Private session.
1 [Open session]
2 THE REGISTRAR: Your Honours, we are back in open session.
3 MR. SACHDEVA:
4 Q. Witness, I am -- I apologise for all the procedural discussions,
5 and I'm going to go back to my question just so you can refresh your
6 memory. Again, it is a question that has been asked by the Presiding
7 Judge in the Galic case, His Honour Judge Orie, to your supervisor, and
8 Judge Orie asked your supervisor, and I quote, "I'm not asking about ...
9 but specialised warehouses where greater amounts of ammunition and/or
10 weaponry was stored. You told us about Faletici and how it went with
11 Faletici, but similar warehouses of similar sizes, were they also within
12 BiH-held territory? And your supervisor answered, as far as I know they
13 weren't. There wasn't such big warehouses in Sarajevo."
14 And I'm asking you would you agree with that testimony?
15 A. Not relation to this particular case. May I clarify?
16 JUDGE ROBINSON: Yes.
17 THE WITNESS: [Interpretation] This is my own experience. I saw
18 ammunition that they used to fire, the stories about there not being any
19 warehouses. You can set up a warehouse in any basement. They obviously
20 had far more ammunition than we did.
21 MR. SACHDEVA:
22 Q. Well, let me put it this way. This is something that you are
23 assuming, you don't know, do you? This is based on your assumptions?
24 A. I told you I'm a civilian. I wasn't privy to the number or
25 location of warehouses, ammunition warehouses, in Sarajevo. I'm still
1 not. There were the police as well, and they had their own police
2 warehouses. Other people would be better placed to know that sort of
3 thing. I certainly wouldn't.
4 Q. Very well, you don't know, do you?
5 A. Yes, I don't.
6 Q. I'd now like to bring up a document, it's 65 ter 03217. And
7 perhaps rather than going into private session, we could just ensure that
8 the document is not broadcast. Witness, do you see a document there on
9 your screen?
10 A. Yes.
11 Q. And you see that this is a document that emanates from the
12 Sarajevo-Romanija Corps command?
13 A. Yes.
14 Q. And you see at the bottom that it is signed by your colleague?
15 A. Yes.
16 Q. And you would agree that this is a valid and authentic document?
17 A. May I have a look first, go through the document so that I may
18 actually address it?
19 Q. You may look at that but just -- I'm asking you with respect to
20 the form and -- the form, does it appear to you to be an authentic
21 document from the Sarajevo-Romanija Corps?
22 A. As far as its form is concerned, I'd say yes.
23 Q. And if you look at the list of ammunition that has been ordered to
24 be delivered to the 3rd Sarajevo Brigade, if you see down the list --
25 A. Yes, I've had a look.
1 Q. You see that it talks about 40 pieces for a mortar, an 82
2 millimetre mortar, do you see that there?
3 A. Yes.
4 Q. And you know that 82 millimetre mortars are weaponry that -- that
5 is heavy and also part of the weapons exclusion zone agreement. You know
6 that, don't you?
7 A. Sir, Mr. Prosecutor, you obviously don't see the date on this
8 document when this document was produced. It's the 16th of June 1995. On
9 that day, the BH army attacked the positions of the army of Republika
10 Srpska with everything they had. Only a stupid person would not use any
11 weapons they had to defend themselves from an enemy attack. You had to
12 use everything that you had to defend from the BH army attacks. This 82
13 millimetre mortar, it's a play thing as compared to everything else that
14 was actually used in that war.
15 Q. And you also see that there was a request for 13.200 pieces of
16 6.62 millimetre bullets and 5.400 pieces for 7.9 millimetre sniper
17 bullets? You see that there as well?
18 A. Yes, yes.
19 Q. And you also see that the paragraph at the bottom, it specifically
20 states, that these quantities of ammunition are intended for units of the
21 SRK at the northwestern part of Sarajevo war theatre and it cannot be
22 issued without the personal approval of the corps commander, the corps
23 commander being General Milosevic; isn't that right?
24 A. Yes.
25 MR. SACHDEVA: And Mr. President, I tender this document.
1 JUDGE ROBINSON: Yes. We admit it and we'll take a break.
2 THE REGISTRAR: Your Honours, this will be admitted as P766.
3 --- Recess taken at 12.20 p.m.
4 --- On resuming at 12.43 p.m.
5 JUDGE ROBINSON: Mr. Tapuskovic? You have a point to pick?
6 MR. TAPUSKOVIC: [Interpretation] First of all, let me tell you
7 something about the time for this witness. He has to travel today. He's
8 been here for a week. And I believe that we should bear in mind the time
9 that the Prosecution still has. In my view they have already spent all
10 their time.
11 JUDGE ROBINSON: Mr. Sachdeva, of the time allocated to you, you
12 have another ten minutes.
13 MR. SACHDEVA: Thank you, Mr. President. I would ask your leave
14 to go beyond the ten minutes, if possible. In the Prosecution's
15 submission, there are several documents that he would have been privy to
16 that, in my submission, are important for Your Honours.
17 JUDGE ROBINSON: And how much beyond the ten minutes?
18 MR. SACHDEVA: Mr. President, I think I would require another 20
19 to 25 minutes.
20 JUDGE ROBINSON: Yes. Very well. Yes. That would give us enough
21 time because the re-examination, I don't imagine, would be unduly long.
22 JUDGE HARHOFF: Be as fast as you can.
23 MR. SACHDEVA: I will, Your Honour. Could we now have 65 ter
24 02319 brought up on the screen and again not to be broadcast, please.
25 That appears to be the wrong document. It's 65 ter 03219. Yes, that's
1 the one. Thank you.
2 Q. Witness, do you see a document there on your screen?
3 A. Yes, I do.
4 Q. Again, can you confirm that this is, in its form it is an
5 authentic document from the Sarajevo-Romanija Corps command?
6 A. In its form, yes, but it hasn't been signed by Mr. Milosevic. I'm
7 not familiar with the signature.
8 Q. And the document is a request for ammunition for combat actions,
9 is it not?
10 A. Yes.
11 Q. And at the bottom of the page, General Dragomir Milosevic's name
12 is there, as a commander, do you see that?
13 A. Yes.
14 Q. And do you see the initials SM? I take it that this was drafted
15 by your colleague? Don't mention the name because we are in open session
16 but --
17 A. Yes.
18 Q. And you see that General Dragomir Milosevic has asked the VRS Main
19 Staff to supply the SRK with, amongst other things, 200 pieces of 76
20 millimetre bullets. Do you see that there?
21 A. Yes, I can see it.
22 Q. 600 pieces for an 82 millimetre mortar? That's number 3?
23 A. Yes, yes.
24 Q. And at the bottom, we see in number 15 and 16, we see the request
25 for in total 30 pieces of FAB aerial bombs. Do you see that there?
1 A. Yes.
2 Q. Now, in your evidence-in-chief to -- when were you asked questions
3 about air bombs by Mr. Tapuskovic, your evidence was that at that time I
4 knew and this was in early June 1995, you say that you knew there was no
5 need for these type of weapons; that is air bombs. Do you remember saying
6 that in evidence?
7 A. Yes.
8 Q. So I take it then that your evidence is that General Dragomir
9 Milosevic is asking for weapons that he does not intend to use? Is that
10 what you're saying?
11 A. I don't know. This was signed by another person. And the request
12 was made to the Main Staff of the army of Republika Srpska. This is a
14 Q. Yes, we can see that it is a request but I'm asking you --
15 A. Yes.
16 Q. -- given your work in this unit and your knowledge of this issue,
17 it is not the case, is it, that General Milosevic would be asking for
18 weapons he does not intend to use? Would you agree with that?
19 A. I can't answer that. I was not the one to decide what would be
20 used. You have to ask somebody else. A request was indeed made for this
21 type ammunition. I will subscribe to that but that's all.
22 Q. And witness, you know that at this time in fact your evidence has
23 been that there was intensive combat operations ongoing in Sarajevo.
24 That's right, is it not?
25 A. Yes.
1 Q. Is it also right that General Milosevic would not have the time to
2 request for specific weapons if he did not intend to use them? In other
3 words, he would not be making frivolous requests, would he?
4 A. Mr. Prosecutor, sir, if you had been there at the time, you would
5 have addressed St. Peter to help you. We were attacked by a corps with
6 the strongest units from other corps, and you would you ask for anything
7 that could be of assistance in defending yourself. After this request, I
8 don't know whether this was approved or not. I don't know what happened
9 next. I see that the document was signed by somebody. I don't know that
10 my colleague from the office --
11 JUDGE ROBINSON: Mr. Sachdeva and Mr. Tapuskovic, there is a
12 matter I wish to bring to your attention. Number 15 on the B/C/S has FAB
13 105, and then 20. Number 15 in the English translation has FAB and then
14 italicised, "aerial bombs." So the question is -- what explains this
15 inconsistency? You may not be able to explain it, Mr. Sachdeva.
16 MR. SACHDEVA: Mr. President, the term FAB is a Russian
17 abbreviation and it stands for Fugasnaya Avionskaya Bomba.
18 JUDGE ROBINSON: Which means?
19 MR. SACHDEVA: Which, in my submission, means aerial bomb.
20 JUDGE ROBINSON: Well, I believe you qualify now for the Russian
21 booth, if we had one, Mr. Sachdeva.
22 MR. SACHDEVA: Mr. President, I'll ask the witness some questions.
23 JUDGE ROBINSON: Yes.
24 MR. SACHDEVA:
25 Q. Witness, you have earlier said in your evidence that the
1 Sarajevo-Romanija Corps did not have aircraft. You remember telling the
2 Court that?
3 A. Yes.
4 Q. So you would agree that these FAB aerial bombs would not have been
5 dropped from planes?
6 A. Yes.
7 Q. And in your time at the Sarajevo command, when you worked there,
8 it's correct, isn't it, that these air bombs were modified by way of
9 attaching rockets to the bombs and they were launched from trucks, weren't
11 A. I can't answer that question. I performed my duties in my office.
12 I did not fire a single bullet during the war let alone having been in a
13 position from which fire was opened and especially from pieces like this.
14 I did not need to inspect any positions. That was not my duty. I
15 performed my duties, and I told you exactly what those duties were. And
16 I'm not familiar with this at all.
17 Q. Witness, I didn't ask you whether you fired bullets during the
18 war, which is what you have told the Court. I'm asking you whether you
19 know whether these air bombs were modified for use at the city of
20 Sarajevo. What do you say about that?
21 A. I can't answer your question.
22 Q. Are you saying you can't answer it because you don't want to, or
23 you can't answer it because you don't know?
24 A. Because I don't know.
25 Q. You know, though, that these air bombs were -- firstly you know
1 that they were requested by the commander of the SRK, that's clear, is it
3 A. Yes.
4 Q. And it's also clear that he -- they would not be able to be
5 dropped on Sarajevo by airplanes, you will agree with that as well?
6 A. Yes.
7 Q. And you agree that they were modified, therefore, for their
8 deployment, weren't they?
9 A. No.
10 MR. SACHDEVA: Mr. President, I ask that this document be tendered
11 into evidence.
12 JUDGE ROBINSON: Yes.
13 THE REGISTRAR: As P767, Your Honours.
14 MR. SACHDEVA: I also ask now, again not to be broadcast, that 65
15 ter 02557 be brought up on the screen, please.
16 Q. Witness, there is another document on your screen. And again, can
17 you confirm that it emanates from the Sarajevo-Romanija Corps command?
18 A. Can the document be scrolled down, please, so I can see its
19 entirety? In form, it seems to be all right, but I can't see the
20 signature, I don't know who signed it.
21 Q. I'll show you the signature in a moment, if we can just go back up
22 to the top, please. Witness, if you look at the top you'll see that it
23 was dated on the 27th of July 1995. You see that there, right?
24 A. Yes.
25 Q. And again, well, I can show you the signature, if we go to the
1 next page. You see General Milosevic's name there, don't you, as the
3 A. Yes.
4 Q. And again, the initials SM refer to your colleague that we spoke
5 about earlier? Isn't that right?
6 A. Yes.
7 Q. And he drafted this document, did he not?
8 A. Yes.
9 Q. And you would agree with me that this is a request for again
10 replenishment of ammunition to be used by units engaged in combat? You
11 agree with that?
12 A. Yes.
13 Q. And if we go back to the first page, please?
14 JUDGE HARHOFF: Who signed the document?
15 MR. SACHDEVA:
16 Q. Witness, do you know whose signature that is?
17 A. I assume that it was Cedo Sladoje, the Chief of Staff, who signed
18 this document. It seems to me that he signed it but I'm not sure.
19 Q. Thank you for that. If we go back to the first page, please?
20 Witness, under A you see at the end number 22, you see again there is a
21 request for ten pieces of FAB 250 kilogram bombs? Do you see that there?
22 A. Yes.
23 Q. And so I'm asking you, in light of the document we saw before this
24 one and this one, is it still your evidence that air bombs were not used
25 in Sarajevo? Is that what you're telling the Court?
1 A. I repeat: I don't know whether they were used or not. They were
2 requested and obviously there were none to be had, because such requests
3 were repeated, and I don't see a document showing that they were ever
4 delivered. This is a request which went out of any proportions. This was
5 never accounted for in any of the storages. There were no bombs accounted
6 for in any storages. You can make any request you want, but it never says
7 that the request was either approved or that it was delivered.
8 Q. Are you saying that General Dragomir Milosevic would make these
9 requests to the Main Staff frivolously and the request would not be
10 granted? Is that what you're saying?
11 A. What I'm saying is this: On that same day, Mr. Milosevic was
12 hospitalised in Belgrade for an eye surgery and I went on my honeymoon.
13 This was signed by his deputy Cedo Sladoje, the Chief of Staff. He
14 requested the quantities that he thought were necessary because attacks
15 were expected at the Trnovo front line and they indeed happened
16 subsequently. As for what was approved, I can't tell from this document
17 because this is merely a request.
18 Q. Was it the case that requests were sent to the Main Staff and that
19 they were dismissed out of hand? Is that what you're saying?
20 A. No.
21 Q. And if we look also in section A, you will see there is also a
22 request, as you said, by the Chief of Staff, for 90 -- 9.000 pieces of
23 sniper bullets, 7.9 millimetre bullets. Do you see that there?
24 A. Yes.
25 MR. SACHDEVA: Mr. President, I ask that this document is also
1 admitted into evidence.
2 JUDGE ROBINSON: It will be admitted.
3 THE REGISTRAR: Your Honours, according to the record, this is
4 already in evidence as P729.
5 JUDGE ROBINSON: Very well.
6 MR. SACHDEVA: Then I'd like to ask for 65 ter 02829 to be brought
8 JUDGE ROBINSON: Mr. Tapuskovic is on his feet.
9 MR. TAPUSKOVIC: [Interpretation] Your Honours, I believe that we
10 are now talking about another 25 minutes, the 25 minutes that were
11 allocated to the Prosecutor are over. I've been following the time.
12 JUDGE ROBINSON: Well, you have become my time keeper.
13 Mr. Sachdeva, another five minutes.
14 MR. SACHDEVA: Thank you, Mr. President. I understood I'd been 20
15 minutes. I'll finish shortly. If I could have 65 ter 02829 brought up on
16 the screen, please. That does not appear to be the document that I asked
17 for. It's my fault. I apologise. It's 03207 is the 65 ter number.
18 That's the one. Thank you.
19 Q. Witness, here we have another document and again this is an
20 authentic document from the Sarajevo Corps command, is it not?
21 A. Yes.
22 Q. And it's dated the 24th of August 1995; is that right?
23 A. Yes.
24 Q. And you see the title is, "Issuing units with air bombs." Do you
25 see that there?
1 A. Yes.
2 Q. And it goes on to say, "Pursuant to the decision of this command's
3 organs," that is the Sarajevo-Romanija Corps command, "issue air bombs for
4 the needs of units according to the following quantities." That's my
5 word, "quantities," but according to the following. And the list is quite
6 clear. There is an order to issue 12 pieces of 105 -- FAB 105, and 14
7 pieces of FAB 250. You see that there?
8 A. Yes.
9 Q. And you see it's signed by Cedo Sladoje?
10 A. No.
11 Q. You see that it's signed --
12 A. I apologise. I'm not clear about the signature. This was not
13 signed by Mr. Cedo Sladoje. His name is split, but it seems that this is
14 Solar's signature, actually.
15 Q. Very well. You see his name there and again, SM refers to your
16 colleague; isn't that right?
17 A. Yes.
18 Q. Now, I ask you again: Does this document, this document with
19 specific instructions to issue air bombs, is it still your evidence that
20 air bombs were not used in the Sarajevo theatre by the Sarajevo-Romanija
21 Corps, or is this document another one of those frivolous requests?
22 A. Mr. Prosecutor, this is one in a series of documents. It says to
23 be issued but it doesn't say to be used. It says to be issued according
24 to this list.
25 Q. Witness, I've showed you three documents now and in those three
1 documents there has been requests for air bombs. You would agree with
2 that, won't you?
3 A. I agree.
4 MR. SACHDEVA: Mr. President, I ask that this document be entered
5 into evidence.
6 JUDGE ROBINSON: I believe there you must end now, Mr. Sachdeva.
7 Because you've had the time, about a half an hour. Yes.
8 THE REGISTRAR: Your Honours, this will be admitted as P768.
9 JUDGE ROBINSON: Mr. Tapuskovic?
10 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honours. Let me
11 try and be very brief. I would like to ask for a document but I don't
12 want it to be publicly broadcast. This is P729, which has just been shown
13 to the witness recently.
14 Re-examination by Mr. Tapuskovic:
15 Q. Witness, could you please look at the date first?
16 A. 27 July 1995.
17 Q. Can you tell me what do you know about the combat activities at
18 the time?
19 A. The Muslim forces were attacking the positions of the army of
20 Republika Srpska, by and large in the Trnovo theatre of war.
21 Q. Can you please look at the middle of the document where it says
22 the parts that we hereby we -- and can you read it slowly, please?
23 A. It says here, "Please note that the units in the southwest part of
24 the Sarajevo theatre were and are under constant attack and that we need
25 ammunition urgently. The organ of this command shall be further described
1 by the organ of the command with at the Trnovo theatre of war."
2 Q. As you have just explained, this was requested, ammunition was
3 requested, for which theatre of war?
4 A. For the Trnovo theatre of war which means that the combat
5 activities spilled over to the Trnovo theatre of war and there were combat
6 activities also going on in other theatres of war, for example Ilidza, the
7 contact parts.
8 Q. Thank you. Can you now look at the document P766?
9 MR. TAPUSKOVIC: [Interpretation] Your Honours, again, it has been
10 omitted from the transcript that the battle was also going on in Nisici.
11 It only says Ilidza. These are two completely separate things. It should
12 read Nisici and Ilidza, not just Ilidza.
13 JUDGE ROBINSON: Thank you for that correction.
14 MR. TAPUSKOVIC: [Interpretation]
15 Q. The document 5766 should also not be broadcast out of the
16 courtroom. P766. Could you please look at the date?
17 A. 16 June 1995.
18 Q. Thank you. You've already explained that.
19 A. Yes.
20 Q. Which place is mentioned in the introduction, for which area is
21 this intended? Can you please look at the introduction before the list of
23 A. It says Semizovac deliver to Semizovac.
24 Q. Can you tell me where Semizovac is? Can you show it on the map?
25 Can you point to it and then go back to your seat.
1 A. Yes, I can. Mr. President, on 17 and 18 June 1995 the Muslim
2 forces interrupted a road from Semizovac to Srednja. They crossed the
3 road here. And for that reason, these quantities of ammunition were
4 requested and with superhuman efforts the positions had been reinstated.
5 If Mr. Milosevic had not been there, not a single Serb would have survived
6 in this theatre of war. If I would not have survived, I would not be here
7 today to testify.
8 Q. There is not what I wanted from you?
9 A. I thought it was necessary for me to say that.
10 Q. Can you please look at the document further on? The penultimate
11 passage, can you please read it?
12 A. It says the units are duty-bound to.
13 Q. Can you please slow down?
14 A. I apologise.
15 JUDGE ROBINSON: You must slow down and don't overlap.
16 THE WITNESS: [Interpretation] Units are duty-bound to strictly
17 account for the use of ammunition because the possibilities for
18 replenishment from a high level are still limited.
19 MR. TAPUSKOVIC: [Interpretation]
20 Q. And what does it say in the last passage please?
21 A. The remaining quantities of the ammunition pursuant to the
22 approval will be issued to the units on the Trnovo axis and for the
23 reserve of the Sarajevo-Romanija Corps.
24 Q. Thank you very much. I have no further questions for this
25 witness, Your Honours.
1 JUDGE ROBINSON: Witness, that concludes your evidence. Thank you
2 for coming to give it. You may now leave.
3 THE WITNESS: [Interpretation] Mr. President, I'd like to thank for
4 having been given an opportunity to come before this Trial Chamber to
5 testify and to tell the truth, and I would like to thank you for having
6 given me an opportunity to tell you what I experienced. Thank you very
8 [The witness withdrew]
9 JUDGE ROBINSON: Next witness, please?
10 MR. TAPUSKOVIC: [Interpretation] The next witness is Drazen
12 [The witness entered court]
13 JUDGE ROBINSON: Let the witness make the declaration.
14 THE WITNESS: [Interpretation] I solemnly declare that I will speak
15 the truth, the whole truth and nothing but the truth.
16 WITNESS: DRAZEN MAUNAGA
17 [Witness answered through interpreter]
18 JUDGE ROBINSON: You may sit and you may begin, Mr. Tapuskovic.
19 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honours.
20 Examination by Mr. Tapuskovic:
21 Q. Again, I'll try to go through my questions about his background as
22 fast as possible.
23 Sir, can you tell us your name for the record? Can you tell us
24 your name?
25 A. My name is Drazen Maunaga.
1 Q. Mr. Maunaga, I would kindly ask to you speak slowly so that your
2 words may be recorded properly. Were you born on the 26th of June 1964,
3 in Banja Luka in Bosnia-Herzegovina?
4 A. Yes.
5 Q. And you have resided in Sarajevo since 1973?
6 A. Yes.
7 Q. You completed elementary education, grammar school, and higher
8 school for tourism in Sarajevo in 1990?
9 A. Yes.
10 Q. And you served in the JNA, which was your civic duty at the time,
11 as early as 1983 upon the completion of grammar school?
12 A. It was in 1984. I went to the army in 1983 and I completed my
13 service in 1984.
14 Q. How old were you then?
15 A. 20.
16 Q. And then until the beginning of 1992, did you have any contacts
17 with the Yugoslav army?
18 A. No, none whatsoever.
19 Q. When did you start working?
20 A. I had a private company co-owned with my mother, so I already
21 started working while I was a student. I was very busy in 1990 after I
22 finished my university studies.
23 Q. What kind of job did you do?
24 A. My mother had a company with another partner, and I was in the
25 accountancy, and I expanded my business to tourism and I set up a travel
2 Q. Where was your office?
3 A. It was in the city of Sarajevo.
4 Q. I also have to show to you a map in order to demonstrate all of
5 this to the Judges. This map has been used here quite often. It's 65 ter
7 Will you be able to read this map as it is?
8 A. Yes, I will.
9 Q. Can you show us where your office was?
10 A. Yes, I can. Approximately here.
11 Q. Can you please put a letter K.
12 A. Which letter?
13 Q. K.
14 A. [Marks].
15 Q. And where did you reside?
16 A. In two places. I had a flat in the centre.
17 Q. Show us.
18 A. In the very centre of the town. Shall I put a letter C next to
20 Q. No. Put a letter S.
21 A. And I had a family house in Kasindol.
22 Q. Can you show us --
23 A. Roughly speaking, here.
24 Q. Can you put a letter M next to it, please.
25 A. [Marks].
1 Q. Always put a letter next to the mark, not over the mark.
2 A. [Marks].
3 Q. Thank you. Can you tell me now what started happening at the
4 beginning of the year? Just please be brief. Tell the Judges what was
5 happening in early 1992 and possibly what happened before that.
6 A. I spent a lot of time in the city because of my business and my
7 social connections, so I spent most of my time in the centre socialising
8 with people I knew about -- I knew a lot about what was happening.
9 Q. Please slow down.
10 A. At the beginning of the year, one could feel that there were
11 groupings in the town along ethnic lines.
12 Q. Can you please elaborate?
13 A. People gathered together in groups. Whoever was not a member of
14 your ethnic group, you didn't speak in front of them so that they wouldn't
15 know what you're talking about.
16 Q. So did you manage to find out anything? Can you explain to the
18 A. Yes, of course. In conversations with my acquaintances I learned
19 a lot of things about how Muslims were organising themselves, about the
20 Green Berets. They talked in front of me because I presume they thought I
21 was a Croat because of my name. This is the name more common among
22 Croats, Drazen, and my last name sounds like a Muslim name.
23 Q. And so what did you learn?
24 A. I found out that the Green Berets had already been established,
25 that they expected to overrun the town and things like that. That would
1 be it.
2 Q. Did something start to happen?
3 MR. DOCHERTY: Mr. President?
4 JUDGE ROBINSON: Yes, Mr. Docherty?
5 MR. DOCHERTY: Understanding, as I do, that this -- that it is the
6 practice of this Tribunal to admit hearsay evidence, nevertheless I do
7 think that with regard to the answer that begins at line 19 of page 82, we
8 ought to have who told the witness this, the approximate date that the
9 witness was told this, the source of the information, something more
10 than, "I heard," no date, no name, no location.
11 JUDGE ROBINSON: Is that the sentence beginning, "In conversation
12 I learned lots of things ..."?
13 MR. DOCHERTY: "In conversation," yes, that's the sentence I'm
14 referring to. It appears to be a conversation with an unknown person on
15 an unknown date, and the source's basis of knowledge appears also to be
16 unknown, at least as far as what has been elicited from the witness so
17 far. And I respectfully put it to the Court that this is a textbook
18 example of rumour.
19 JUDGE ROBINSON: Well, tell us, Witness, how did you acquire this
20 information about the Muslims? In what circumstances?
21 THE WITNESS: [Interpretation] I knew a lot of people in the city.
22 Sarajevo is not a big town and people know each other, and we generally
23 knew what was happening in everybody's private lives. By socialising with
24 various people, I acquired this kind of information.
25 MR. TAPUSKOVIC: [Interpretation] Your Honours, Mr. President, may
1 I put a question?
2 JUDGE ROBINSON: Yes.
3 MR. TAPUSKOVIC: [Interpretation].
4 Q. I wanted to curtail this. However, my learned friend, the
5 Prosecutor, had an objection.
6 Now, Witness, please concentrate, and if we have to speak about
7 this, let us hear -- give us the names of your friends and acquaintances.
8 With whom did you speak and how did you acquire this information?
9 Therefore, we have to spend some time on this. Try to focus and give us
10 at least some of the names of the persons who gave you this information
11 relating to what was in the offing, as you put it.
12 A. For example, from the Svrakic family. I think that's enough.
13 Q. Tell us what you learned.
14 A. I learned that the Green Berets were being set up.
15 Q. Mr. Maunaga, please give us a detailed account of what you heard
16 from them, for example, because the Prosecutor is insisting on this, and
17 tell us the date.
18 A. It may have been February or March 1992. These are my friends
19 from high school. And in contacts with them, I heard that they were
20 engaged in certain activities relating to the organisation of the Green
21 Berets, which I found quite strange at the time because I didn't expect
22 something like that.
23 Q. And then?
24 A. So this was confirmed by the killing of the wedding party in
25 Bascarsija. I realised that they indeed existed. And that was the reason
1 for me to leave the town.
2 Q. When did you leave the town?
3 A. Immediately after the killing of the members of the wedding party.
4 Q. When did that take place?
5 A. It was in April -- no, beginning of April 1992.
6 Q. Are you sure?
7 A. End of March or beginning of April.
8 Q. Very well. So where did you go?
9 A. I went to my family house.
10 Q. The one that you showed us?
11 A. Yes, yes.
12 Q. Did you ever go back to the flat where you used to live and to the
13 workplace where you were employed?
14 A. No.
15 Q. What happened next at the place where you arrived? What was going
16 on among the residents of the neighbourhood where you were living? Tell
17 us the name of the neighbourhood and please explain in more detail your
18 conversations with certain individuals and what was going on there. I
19 didn't want to insist on this, but never mind, we are going to spend
20 sometime on that. What was the atmosphere prevailing there?
21 A. As soon as I came there, I expected to find a more secure
22 situation, which meant that people were organising themselves to protect
23 themselves because there were riots taking place. I found myself among my
24 relatives and neighbours, who were terrified, disorganised.
25 Q. Thank you. Which period are you talking about?
1 A. That's the beginning of April, and throughout April.
2 Q. What was happening in April? Were there any particular incidents?
3 A. In April, people were trying to obtain weapons because they feared
4 what was imminent. There were roadblocks. However, they couldn't find
5 any weapons. In April, the MUP, the police in Sarajevo, was split.
6 Q. Thank you. Can you show the location?
7 A. This happened at the level of the whole of Sarajevo. However,
8 what I saw, there was a complete disarray in the centre of the Special
9 Police, which was situated here, roughly speaking. How shall I mark it?
10 Q. First put the mark.
11 A. [Marks].
12 Q. Put a letter A and explain what happened there.
13 A. That was an ammunition depot. Both Muslims and Serbs burst into
14 it at the same time looking for weapons because neither side, I presume,
15 had any weapons. I know about this side. And a certain quantity of
16 weapons were taken and taken to Kasindol and Butmir with the Muslims.
17 People were virtually exchanging weapons among themselves at that period.
18 They all took it to their respective parts and this was the initial
19 quantity of weapons that arrived in Kasindol.
20 Q. You said that this was the police warehouse of the Special
21 Police. When both the Muslims and Serbs were taking away rifles, were
22 there any clashes on the spot between them?
23 A. Not at the time. There were no clashes. They were collecting the
24 weapons at the same time and dragging it to their respective parts.
25 Q. Can you tell us more detail so that we have full report and
1 information about this?
2 A. After that, since this was an insufficient quantity of weapons,
3 that had been for certain purposes of guards and there was one rifle to
4 ten men, people tried to find different ways. They went to the barracks
5 and tried to seize weapons there.
6 Q. Tell me what happened next? You were there. Did anything happen
7 in May? We talked about April.
8 A. Well, at the very beginning of May, I think that the Pofalici
9 incident happened and that there were first battle and that the Serbian
10 population rebelled in that area. A lot of people crossed over to our
11 part. We tried to provide them with shelter. The entire families were
12 there. And this instilled quite a strong fear.
13 Q. Apart from refugees coming, what else happened to them while this
14 thing in Pofalici was going on?
15 A. According to their reports, terrible things happened. There were
16 many killings. People died in all these parts on the slopes of Hum and
17 Zuc, under the Muslim pressure they had to flee. Whoever decided to
18 remain there were killed. They -- their stories were horrifying and this
19 instilled further fear among the population and among us.
20 Q. What happened in the first days of May?
21 A. I don't know exactly. My memories of May are related to Pofalici
22 and Dobrovoljacka Street.
23 Q. Well, tell us about Dobrovoljacka Street?
24 A. The army was withdrawing from the barracks or rather the command
25 at the Bistrik. The column was cut in two. A lot of soldiers were taken
1 prisoners and many of them were killed. I don't know the exact number.
2 And this demonstrated the perfidiousness and the honour of the opposing
3 army, because this -- there were guarantees given for this withdrawal,
4 that it would be safe and secure, in order to effect the exchange of
5 President Izetbegovic.
6 Q. In addition to Dobrovoljacka Street, were you aware of what was
7 happening elsewhere where the JNA barracks were?
8 A. The barracks were constantly under pressure and there were
9 attempts to break into them, to take and seize weapons, and thereby to arm
10 the other side. The Marshal Tito barracks was also evacuated.
11 Q. When did the JNA withdraw?
12 A. Sometime in mid-May. The Yugoslav People's Army withdrew in
13 mid-May and abandoned their positions and left.
14 Q. How did you learn about all these things from the place where you
15 stayed and were you able, by moving around, to see anything for yourself?
16 A. From the place where I was, I could see many things. I was living
17 in that area, and I was close to the barracks. I see a lot of things
18 taking place.
19 Q. Since the Prosecutor is insisting on what you saw, can you please
20 tell us briefly what you saw? And I also believe that you should tell us
21 what you actually saw.
22 A. After the withdrawal of the army --
23 Q. No. In the course of the withdrawal of the army.
24 A. -- I saw that the army had left and there were some weapons left
25 behind. People who were there, who were not trained or were self-trained,
1 took these weapons and tried to establish some kind of safety zone for
2 themselves, and I joined them sometime in May, after seeing all these
3 events and I went to Gavrica hill.
4 Q. Just a moment, just a moment. How did it happen that you decided
5 to join in and why did you do that?
6 A. Having observed all the events that were taking place, I decided
7 to join in because that was a must. I had to protect my area. I had to
8 protect my land. I defended my house. I defended my graves.
9 Q. Can you tell us whether this ever assumed a -- the form of an
10 organisation? Do you know when the army of Republika Srpska was
12 A. I believe it was in late May or maybe mid-May, towards late May.
13 Q. Where were you at the time?
14 A. Since I had joined the army, I found myself on the hilltop called
15 Ilinica or Gavric hill, as an observer.
16 Q. Can you please shows us where that hill is on the map?
17 A. This would be it. [Marks]
18 Q. Can you put a letter G next to your mark?
19 A. [Marks]
20 Q. What was the number of that elevation and how high was it?
21 A. It was about 600 metres.
22 Q. Can you tell us exactly if you can read it on the map?
23 A. No, I can't read it on the map. It is not indicated. It was not
24 more than 650 or maybe even 630 metres, as far as I can remember.
25 MR. TAPUSKOVIC: [Interpretation] Your Honours, could this map be
1 kept in this form. This is not my final exhibit, but I believe our time
2 is up for the day, so can we keep the interim form of this map until my
3 further questions tomorrow?
4 JUDGE ROBINSON: Yes. And we'll adjourn until tomorrow.
5 --- Whereupon the hearing adjourned at 1.45 p.m.,
6 to be reconvened on Tuesday, the 12th day of June,
7 2007, at 9.00 a.m.