Tribunal Criminal Tribunal for the Former Yugoslavia

Page 6479

1 Tuesday, 12 June 2007

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.00 a.m.

6 JUDGE ROBINSON: Mr. Tapuskovic.

7 MR. TAPUSKOVIC: [Interpretation] Good morning, Your Honours.

8 Thank you for giving me the floor.


10 [Witness answered through interpreter]

11 Examination by Mr. Tapuskovic: [Continued]

12 Q. Mr. Maunaga, you know that we started this conversation

13 yesterday. I'm kindly asking you to speak as slowly as possible and I

14 will also try to abide by this, because if we do not follow this

15 procedure, it will not go well.

16 MR. TAPUSKOVIC: [Interpretation] Can I please pick up where we

17 left off yesterday, and can we also please have 65 ter document 2872, and

18 if it can be enlarged so that numbers can be legible.

19 Q. Mr. Maunaga, yesterday you said that at one point you went to a

20 position where you acted as an observer. Can you explain what happened

21 which prompted you to leave the position in your house and the

22 circumstances that you lived in to go to that particular place. Do you

23 know when the army of Republika Srpska was established?

24 A. The army of Republika Srpska was established in mid-May, sometime

25 between the 12th and the 19th of May.

Page 6480

1 JUDGE ROBINSON: Mr. Tapuskovic, you had asked another question,

2 and I think this is the problem when you ask more than one question. I

3 was more interested in the first question, which is his explanation as to

4 what prompted him to leave the position in his house and the circumstances

5 that he lived in. What prompted him to go to that particular place?

6 Witness, can you answer that?

7 THE WITNESS: [Interpretation] I didn't leave my home. I joined

8 the army of Republika Srpska that was established at the time. My motives

9 were to take part in the defence of my property, lives and people with

10 whom I was living.

11 JUDGE ROBINSON: Where did you act as an observer?

12 THE WITNESS: [Interpretation] Yesterday I showed point A on the

13 map, and this is where I was deployed as an observer.

14 JUDGE ROBINSON: What were your functions as an observer?

15 THE WITNESS: [Interpretation] My function was to observe the area,

16 to see the deployment of forces, the movement of enemy forces, the

17 establishment of fortifications facing our territory, and to pass on this

18 information to the command in charge.

19 [Trial Chamber confers]

20 JUDGE ROBINSON: Mr. Tapuskovic, we have heard of another type of

21 observer in this case and that's the observer who is sent when mortars are

22 being fired, and I wondered whether he had any of these functions or

23 whether he was simply somebody observing the enemy and passing on reports

24 to his headquarters.

25 MR. TAPUSKOVIC: [Interpretation] There was mention, Your Honour,

Page 6481

1 of observers and the witnesses explained this. I exactly wanted to ask

2 the witness to explain what was he observing from his post. That was my

3 intention. But I first wanted to hear that he already at that point had

4 joined the army of Republika Srpska and, of course, I would like to hear

5 his explanation about what he was observing from that post.

6 JUDGE ROBINSON: Yes. Proceed.

7 MR. TAPUSKOVIC: [Interpretation]

8 Q. Mr. Maunaga, when you were deployed at this position, what weapons

9 did you have?

10 A. I personally wasn't issued any weapons. I was issued actually a

11 rifle for my self-defence against any incursions. I also had binoculars,

12 a radio set, a military telephone, a map and a compass.

13 Q. From that post where you were at the time, what were you able to

14 observe? Can you tell the Judges that?

15 A. The Mojmilo hill was visible from that post.

16 Q. Who controlled the Mojmilo hill at the time when you were

17 observing it?

18 A. At that time, and throughout the war, the Muslim forces controlled

19 the peaks and we had a part of Mojmilo on the slopes facing Nedzarici

20 where our troops were controlling the waterworks.

21 Q. When was that?

22 A. In June.

23 THE INTERPRETER: Could the witness please speak slowly.

24 JUDGE ROBINSON: Did you hear that? The interpreter is asking you

25 to speak more slowly.

Page 6482

1 MR. TAPUSKOVIC: [Interpretation]

2 Q. Mr. Maunaga, I am really asking you: Do not speak fast. Speak

3 slowly. Otherwise nothing will be recorded.

4 For how long were these people deployed next to the waterworks and

5 experienced what you said they experienced?

6 A. Roughly up until mid-June 1992.

7 Q. And from then on, who took control of these positions on Mojmilo?

8 A. Exclusively Muslim forces.

9 Q. Can you mark on the map this hill called Mojmilo?

10 A. That will be it.

11 Q. Yesterday you said that this hill, Gavrica Brdo, from which you

12 observed the territory, was approximately 650 metres high. With regard --

13 with respect to you, do you know the height of Mojmilo?

14 A. Between 680 and 690 metres.

15 Q. From that position, viewing towards Grbavica and Dobrinja but most

16 of all towards Grbavica and other parts of the city surrounding Grbavica,

17 what were you able to see, if anything?

18 A. You can't see anything over Mojmilo because Vraca, Debelo Brdo and

19 other places are beyond it. You cannot see anything. You can see only

20 one part of Dobrinja.

21 Q. Please slow down. It is completely futile if you speak too fast.

22 So what part of Dobrinja were you able to see?

23 A. One could see only the frontal parts of buildings in Dobrinja

24 because the viewing angle with respect to distance was very small.

25 Q. And this part of Dobrinja that you were able to see, how far was

Page 6483

1 it from the airport?

2 A. It's immediately across the airport and you can see the first

3 buildings there on the line, so the distance would be about 50 metres, up

4 to 100 metres.

5 Q. Tell me, do you know for how long the airport was under the

6 control of the army of Republika Srpska?

7 A. Until July 1992.

8 Q. And what happened then?

9 A. The airport was handed over to UNPROFOR in order to allow for the

10 arrival of humanitarian aid.

11 Q. Can you show us approximately the parts of Dobrinja that you were

12 able to see?

13 A. Roughly speaking.

14 Q. And where is the airport?

15 A. It's here.

16 Q. Can you mark the line with the letter B.

17 A. [Marks].

18 Q. And then mark Dobrinja with a letter D.

19 A. [Marks].

20 Q. And Mojmilo with a letter M.

21 A. [Marks].

22 Q. How far was Gavrica Brdo hill from Mojmilo or, rather, Dobrinja?

23 A. Approximately 4 kilometres from Mojmilo, and 2.5 to 3 kilometres

24 from Dobrinja.

25 Q. What were you actually able to see in Dobrinja?

Page 6484

1 A. Well, actually, what I could see were only the frontal parts of

2 Dobrinja and the buildings there, and the rest one could see were just the

3 tops of other buildings.

4 Q. Thank you. Tell me, please, after the airport had been handed

5 over to UNPROFOR or, rather, international forces, did any of the officers

6 come to your position at Gavrica Brdo?

7 A. Yes. General Mladic himself used to come.

8 Q. Why did he come? Can you tell us that?

9 A. First of all, he held meetings with people in Vojkovici,

10 explaining the reasons for handing over the airport. After that, he

11 dropped by our observation post and ordered the other units to take

12 particular care that nothing should happen at the airport. He even said

13 there shouldn't be a stone or a rock thrown at the airport.

14 Q. Can you show us where the separation lines were between the VRS,

15 with respect to Mojmilo, but can you show us where the separation lines

16 were between the VRS and the ABiH?

17 A. This is it.

18 Q. Please, what have you marked with the letter A?

19 A. That's the place at Krtelji and that was the Special Police

20 headquarters.

21 Q. Thank you. With the place that had been marked with a G, Gavrici

22 Brdo, as you said, it was facing Mojmilo. What else was it facing?

23 A. Igman.

24 Q. Can you show us where Igman is on this map?

25 A. No. It is not shown here.

Page 6485

1 Q. Can you see Hrasnica?

2 A. No. You can see but a small part of Hrasnica.

3 THE INTERPRETER: The interpreter didn't catch the toponym.

4 MR. TAPUSKOVIC: [Interpretation]

5 Q. Where was Igman compared to Hrasnica, or, rather, how far was

6 Hrasnica from your observation post?

7 A. About 2 kilometres.

8 Q. Where is Igman compared to or in relation to Hrasnica?

9 A. Igman begins at Hrasnica. That's where the foot is.

10 Q. Therefore, from the hill marked with a G, you were observing

11 positions of the army of Bosnia-Herzegovina which were where?

12 A. We observed their lines. Therefore, it was in Donji Kotarac.

13 Q. Can you show us where that is?

14 A. There. We could also see parts of Butmir and Cigansko Maselj

15 [phoen].

16 Q. Stop there, please. When you say Cigansko Maselj, a Roma

17 settlement, what are you trying to say? Who resided there?

18 A. Until the beginning of the war, the Roma lived there, who probably

19 had built their houses there illegally. However, the Muslim forces used

20 that to place their recoilless gun and a mortar in their houses, as well

21 as several machine-guns. Therefore, they turned a civilian target into a

22 military one at the expense of the Roma.

23 Q. What was the focus of military activity? Can you explain to us

24 what the activities were that were taking place at that time?

25 A. There weren't many infantry attacks. They mostly opened fire from

Page 6486

1 artillery pieces.

2 Q. Does that go for both sides?

3 A. Yes, both sides. Of course, an action causes a reaction.

4 Q. Where did the army of Bosnia-Herzegovina usually open their fire

5 from? You were at Gavrica Brdo and Mojmilo and Igman were there, but

6 where did they usually fire from?

7 A. From several directions. Usually from Igman, from the Kovaci

8 settlement in Hrasnica; they used mortars there. From the Roma

9 settlement, there was a recoilless gun and a mortar there. The Butmir

10 settlement, there was a mortar group there.

11 Q. What about Mojmilo?

12 A. I am getting there. I'm just waiting for the transcript. There

13 was a group of houses between the airport and Dobrinja. We called them

14 the Fulina houses and they had guns there. And of course from Mojmilo.

15 They were guided by pointers from the top. And they also used

16 machine-guns to target Dobrinja.

17 Q. Thank you. At that time, at the outset, what weaponry was there

18 on the side of the VRS?

19 A. Of course, we had weaponry. After the JNA had been disbanded and

20 the VRS formed, we assumed positions. There were several tanks and

21 several Pragas.

22 Q. You had a telephone device, as you said. What could you see from

23 the Mojmilo hill and what was the information you passed on to those who

24 were supposed to take action?

25 A. That's the answer that I can give to the Judges. My job was to

Page 6487

1 observe, to follow where the fire was coming from. I had to provide grid

2 reference and forward that to the command.

3 Q. During those days, were you able to observe something that you

4 could share with us, something that remains etched in your memory?

5 A. I noticed something I will never forget. In mid-August, a

6 howitzer began operating at Igman. The calibre was probably 150

7 millimetres. It is a long-range piece.

8 JUDGE HARHOFF: Which year is this?

9 THE WITNESS: [Interpretation] 1992. I did my utmost to try and

10 locate the howitzer. I finally succeeded. I located it at Igman. The

11 exact location is called Radiljavaca [phoen].

12 MR. TAPUSKOVIC: [Interpretation]

13 Q. During those days, were you able to hear something over the radio,

14 something that had to do with that?

15 A. Of course. That's why I knew the calibre, because they boasted in

16 public that a sultan was brought to Igman and that it was brought there by

17 Dajda and that we were going to feel what a 150-millimetre gun actually

18 means in real terms.

19 Q. What did you relay to the people that you were supposed to relay

20 information to?

21 A. Of course, I provided a grid reference and I awaited some sort of

22 a reply. There was an attempt on our part to destroy the howitzer but we

23 failed. Our range proved too short. The next day, since the Muslims

24 realised that we pinpointed the location and they knew that we were

25 observing from the Gavrica hill, since they had a commanding view from

Page 6488

1 Igman - they were higher than we were - they started with the barrage of

2 shells, an enormous number of shells. I was wounded on that occasion, and

3 the very same shell killed my friend, Nenad Vaskovic.

4 Q. What sort of injury did you sustain and what happened

5 subsequently?

6 A. I was seriously injured to my stomach. Basically I had my

7 intestines in my hands. I was also injured to one of my arms and both

8 legs.

9 Q. Where were you treated?

10 A. The first emergency operation was executed at Pale. Since we

11 couldn't go via Zlatiste, I was taken via Tvrdimic, which took three

12 hours. The other operations happened in Belgrade, in their emergency

13 centre. I had another five operations there.

14 Q. Thank you. Can you tell us, how long did the treatment take?

15 A. I returned on the 10th of March 1993.

16 Q. Were you able to participate in any observing activities or combat

17 activities for that matter at all?

18 A. No. I was demobilised. May I add something?

19 Q. Go ahead.

20 A. I just wanted to say that after the first operation at Pale, I was

21 awakened from a coma by the howitzer shots because they were targeting

22 Olovnica and the Presidency at Pale.

23 THE INTERPRETER: Interpreter's correction: The hospital and the

24 Presidency at Pale.

25 MR. TAPUSKOVIC: [Interpretation]

Page 6489

1 Q. What is the distance between Igman and Pale?

2 A. As the crow flies, about 20 kilometres.

3 Q. Can you tell us the exact name of that 155-millimetre howitzer?

4 You said they called it Sulejman.

5 A. No, sultan.

6 Q. Sultan. But what is the military designation?

7 A. I think it's a Nora.

8 Q. When you concluded your treatment, where did you go? What did you

9 do afterwards?

10 A. After the treatment, and after I spent several months at home, in

11 November I went to Trnovo. It says "November" in the transcript whereas

12 it should be August. I was appointed hotel manager at Trnovo.

13 Q. What were your duties at Trnovo and for how long did you perform

14 them?

15 A. The title "manager" didn't mean much at the time, since it had to

16 do with the returning of population to Trnovo and providing accommodation

17 for them, and it was an attempt to regain a semblance of ordinary life.

18 MR. TAPUSKOVIC: [Interpretation] So as not to forget, I wanted to

19 go back to the situation we see on the map. We should assign it a Defence

20 Exhibit number.

21 JUDGE ROBINSON: Yes. We admit it.

22 THE REGISTRAR: As D223, Your Honours.

23 MR. TAPUSKOVIC: [Interpretation]

24 Q. Mr. Maunaga, at the time you were at Trnovo working as the

25 manager, what was the situation among the population like?

Page 6490

1 A. It was critical. Those people had been driven away in 1992 and

2 were now returning to their homes, trying to reconstruct their houses, and

3 they were visibly impoverished.

4 JUDGE HARHOFF: When was this?

5 THE WITNESS: [Interpretation] From August 1992 until June 1994.

6 It's within that time. The most pressing issue was food.

7 MR. TAPUSKOVIC: [Interpretation]

8 Q. Can you tell me something about the time after that, the summer of

9 1994? What was happening with you? What were you doing?

10 A. During that summer, I stayed with my wife who was pregnant at the

11 time.

12 THE INTERPRETER: Could the witness's other microphone be turned

13 on as well. Thank you.

14 JUDGE ROBINSON: Would you turn on the other microphone. The

15 interpreter is having difficulty hearing.

16 MR. TAPUSKOVIC: [Interpretation]

17 Q. Mr. Maunaga, after that period that you spent with your pregnant

18 wife in the summer of 1994, were you subsequently given some sort of a

19 task? And what was it?

20 A. Because of the needs of the municipality of Ilidza, which was

21 split into two, the eastern and the western part, I was tasked to organise

22 an office that would liaise with UNPROFOR and humanitarian organisations.

23 Q. At the time, with whom did you have contacts most frequently,

24 since you had to do that and since that was your task?

25 A. The central office was situated in Ilidza.

Page 6491

1 Q. Can you show us where that is on the map. Now we have a clean

2 map, 2872. I think I requested this to be saved and I think it has been.

3 If it hasn't been saved, then we can add these new markings. So please

4 show us where Ilidza is and where this central office is.

5 A. It's here, in the Serbia Hotel.

6 Q. And where was your office?

7 A. My office was in Kasindol. It's here. Here.

8 Q. Please mark that with the letter --

9 JUDGE ROBINSON: Just a minute.

10 [Trial Chamber confers]

11 JUDGE MINDUA: [Interpretation] Mr. Tapuskovic, I'm sorry to

12 interrupt you, but before we get on to another topic and before we change

13 this map - I imagine that the President would like to intervene as well -

14 but I have a general question to put to you.

15 Telecoms are very important when it comes to the reliability of

16 information that an observer transmits to the command of his unit and as

17 well to the command of the SRK, and of course it's very important to make

18 sure that the orders received by the command be transmitted to the base.

19 So I noticed that the witness had at his disposal a radio as well as a

20 military telephone or field phone; on page 3, line 13 of the transcript,

21 and on page 8, line 24 of the transcript. We once talked about the phone

22 in this courtroom.

23 So I would like to know the following: Could the witness inform

24 me what is the difference between his radio, the radio set in English, and

25 the military phone? And I would like to know if that phone was a land

Page 6492

1 line or was it a mobile phone?

2 MR. TAPUSKOVIC: [Interpretation]

3 Q. Mr. Maunaga, can you please answer?

4 A. Yes. I'll answer that. It's not a difficult question. A radio

5 set is used exclusively in the field, and it's been adjusted for

6 intercepting. The military telephone has only one wire connecting one

7 telephone to another, so basically only two persons can communicate over

8 this phone at a time. A special cable is extended from the centre all the

9 way to the observation post. And that was precisely the reason why I was

10 wounded, because I was in the open and I was laying down this cable.

11 JUDGE MINDUA: [Interpretation] And the radio? What kind of a

12 radio did you have? Was it a walkie-talkie? Was it something else? What

13 kind of a system was it?

14 THE WITNESS: [Interpretation] It was a standard military radio

15 device that one carries on one's back, and it was used very rarely.

16 JUDGE MINDUA: [Interpretation] And my last question to you: So

17 you were in contact with your command and you knew that your command was

18 in regular contact with the command of the Sarajevo-Romanija Corps; is

19 that right?

20 THE WITNESS: [Interpretation] Yes.

21 JUDGE MINDUA: [Interpretation] Thank you very much, Witness.

22 JUDGE ROBINSON: Mr. Tapuskovic, the Chamber is troubled by the

23 relevance of this evidence. We have been listening to this witness for

24 over an hour and we haven't heard much that is relevant to the charges.

25 You must bring the witness to evidence that relates to the indictment.

Page 6493

1 MR. TAPUSKOVIC: [Interpretation] I only wanted to describe the

2 general circumstances in which everything started, and on account of what

3 the witness was saying these questions can be interesting for other

4 witnesses as well, as pointed out by His Honour Judge Mindua.

5 This witness's evidence should demonstrate the situation in the

6 indictment period with regard to the people living in that area, what

7 shortages they had to endure, what fears they had to endure. As somebody

8 who in this particular period of time was involved exclusively in civilian

9 affairs and cooperation with UNPROFOR, he's a well-suited person to tell

10 us about the condition in which the people were living at the time,

11 particularly in the indictment time period, and the problems that existed

12 then even with regard to weapons and everything else. He can also tell us

13 what was happening in the period and the counts in the indictment against

14 Dragomir Milosevic. So he can tell us quite a lot.

15 JUDGE ROBINSON: But not all so, I mean, that is what he is to

16 tell us about. It seems to me to be less important, the conditions in

17 which the people were living. We are interested in evidence that will

18 help us to determine the innocence or guilt of the accused. Peripheral

19 matters will not help us very much. So if he has evidence about the

20 charges in the indictment, let us hear it.

21 MR. TAPUSKOVIC: [Interpretation] Your Honours, the central point

22 here was the intention of the VRS to terrorise the people living in the

23 parts of Sarajevo controlled by the ABiH. This witness can tell us very

24 much about the fears and the plight of his people who lived there as a

25 result of the incidents cited in the indictment, including the people who

Page 6494

1 were living in the area under the VRS control in Sarajevo itself, and what

2 kind of suffering they had to endure, which were not at all different from

3 everything that was happening in those places: Who was holding these

4 hills, who was deployed on these hills, which is the basic foundation of

5 this indictment; that is to say, that one army had its positions on the

6 hills and relentlessly fired at civilians in order to instill terror in

7 them.

8 The Defence wants to prove that it was quite the opposite, that it

9 was not true, and to provide evidence, even through the evidence presented

10 by the Prosecution, about who was on the hills. The Defence believes that

11 in 80 per cent of cases it has been shown who was on the hills and the VRS

12 was at the foot hills doing nothing other than defending their positions

13 and being compelled to respond to what was happening in military terms.

14 Therefore, this witness was living with civilians --

15 JUDGE ROBINSON: Let us hear that evidence. If he has evidence

16 about who was on the hills, that's very relevant, yes.

17 MR. TAPUSKOVIC: [Interpretation] This is precisely the point that

18 I have reached, Your Honour.

19 [Trial Chamber confers]

20 JUDGE ROBINSON: Yes. Well, let us get on with it.

21 MR. TAPUSKOVIC: [Interpretation]

22 Q. Mr. Maunaga, we have come to the point when you began working with

23 UNPROFOR on humanitarian aid. In order to address the issue that I have

24 been warned about - and I have to comply with the Court's request and shed

25 light on this - can you first show me or, rather, explain where these two

Page 6495

1 offices were. What was the most pressing matter in those days? How did

2 you obtain medicines, for example?

3 A. The most important problem was medicines and control and

4 prevention of contagious diseases. The warehouses were at the airport,

5 and if a delivery was to be made in the western part of Ilidza, we had to

6 go around town for about 100 kilometres in order to get these medicines.

7 And that was precisely the reason for setting up this office, in order to

8 cut short the route of delivery.

9 Q. So where did you take over the medicines?

10 A. After the office was set up, the medicines were delivered directly

11 to the hospital in Kasindol from the airport.

12 Q. Was there any reason for you to go to Ilidza? Because the

13 headquarters was there during the period that you were involved in these

14 duties.

15 A. Of course, it is only logical for me that I had to go there on a

16 weekly basis and submit reports on my work.

17 Q. So which route did you have to take? Can you show the Judges on

18 the map, without drawing it.

19 A. I first had to go to Pale, then Sumbulovac, then Vogosca, and then

20 Ilidza. So I had to take a round-about road through the wood.

21 MR. TAPUSKOVIC: [Interpretation] Your Honours, can we please save

22 this map and admit it as a Defence exhibit.

23 THE WITNESS: [Interpretation] Can I add something about the map?

24 I made a mistake when I marked my office. It was actually here.

25 MR. TAPUSKOVIC: [Interpretation]

Page 6496

1 Q. Can you please mark it with a letter D?

2 A. [Marks].

3 MR. TAPUSKOVIC: [Interpretation] Can this map be admitted as a

4 Defence exhibit, please.


6 THE REGISTRAR: As D224, Your Honours.

7 MR. TAPUSKOVIC: [Interpretation]

8 Q. Now, in order to reach Ilidza, were you able to go across the

9 airport?

10 A. No.

11 Q. Where did you go, which route did you take, and who was dominating

12 the hills that you had to pass by in order to reach Ilidza?

13 A. I had to pass from Kasindol through Dobrinja and I had a problem

14 already there. Then Mojmilo, Trebevic, Colina Kapa. Then there was a

15 safe part of the road to Grdonj, and then descending down to Vogosca

16 exposed one to constant fire from Hum and Vogosca, and then the situation

17 was rather stable up to Ilidza.

18 Q. So what did it look like from Vogosca to Ilidza? How long was

19 that particular section?

20 A. Perhaps about 10 kilometres.

21 Q. During your travel, who was in control of the elevations all

22 around?

23 A. The Muslims at Hum and at Zuc, in the direction of Mijatovica

24 Kosa.

25 Q. All right. Do you know when General Dragomir Milosevic became

Page 6497

1 commander of the Sarajevo-Romanija Corps?

2 A. I don't know exactly but I think it was sometime in August 1994,

3 at least that's what I'd heard.

4 Q. What was the situation at the time --

5 THE INTERPRETER: The interpreters couldn't get the last part of

6 the question.

7 THE WITNESS: [Interpretation] The heavy weapons had been withdrawn

8 by February. This had been organised by UNPROFOR. This was a relatively

9 peaceful period.

10 MR. TAPUSKOVIC: [Interpretation]

11 Q. Thank you. When you say "peaceful," what exactly are you trying

12 to say?

13 A. What I'm trying to say is that there were no serious operations at

14 the time. There was a cease-fire on. And there were just sporadic

15 incidents. No more than that.

16 Q. When was it that you had this peaceful period in 1994?

17 A. I remember because of the school year. I think it went on until

18 about October 1994.

19 Q. What is it about the school year that you're trying to tell us?

20 A. Well, that's what I did. I looked after the local population.

21 Children went to school, for example, in Vojkovici. Vojkovici. And when

22 this began, in about October 1994, the offensives, there were regular

23 activities by browning from Igman on the school.

24 Q. What did you do in your capacity as a humanitarian worker?

25 A. I asked UNPROFOR to set up some sort of protection for the school

Page 6498

1 building, to go there themselves and guard the building.

2 Secondly, I asked for fuel for the ferrying of peoples. We

3 couldn't just leave them there in the school building under fire. The

4 idea being to take them across to the barracks. I then had a meeting with

5 the airport commander, Colonel Oberto, who approved this.

6 Q. Which officers of the army of Republika Srpska did you talk to

7 about this, the whole thing?

8 A. For the most part, those were liaison officers. That was my only

9 communication with the army. There was no need for any other form of

10 communication.

11 Q. All right. So you say the offensive was launched or, rather, the

12 fighting began in October. What did it look like? Where exactly did this

13 go on?

14 A. As for this area, the focus was near Trnovo. There was fierce

15 fighting going on there.

16 Q. Did you perhaps at the time hear anything that reminded you of

17 your own experience back in 1992?

18 A. Yes. I was touring the positions held by our soldiers, along with

19 members of an association called the Serb Sisters. It's a women's

20 association. My task was to take them to see the soldiers, bring them

21 food and encouragement. I then heard those same howitzers or maybe

22 similar ones.

23 MR. TAPUSKOVIC: [Interpretation] I would like to show the witness

24 a document, DD001737.

25 Q. You've been speaking about these weapons, but please have a look

Page 6499

1 at this document. Who was it produced by, what date does it bear, what's

2 it in reference to, and, lastly, who signed it? Can you have a look,

3 please.

4 Sir, Mr. Maunaga, it's a rather short document. Can you read the

5 date, the substance and the signatory, in that order, please.

6 A. The 18th December 1994, signed by General Rasim Delic.

7 Q. And what's it in reference to?

8 A. I see that it's in reference to precisely what I have been talking

9 about.

10 Q. What exactly?

11 A. 152 howitzers.

12 Q. Which you heard firing again at this time; is that what you're

13 saying?

14 A. I heard the sound of the howitzer being fired.

15 MR. TAPUSKOVIC: [Interpretation] Can this document be exhibited,

16 please.

17 JUDGE ROBINSON: Just a minute.

18 [Trial Chamber confers]

19 JUDGE ROBINSON: Mr. Docherty, we are still considering the

20 relevance of much of this evidence, and it really goes to the root of the

21 Defence case because, of course, it's not enough really to show that the

22 Serbs were also suffering. But I believe what the Defence is saying is

23 not just that the Serbs were suffering but that the terror with which you

24 have charged their client was caused by the ABiH themselves. And so he's

25 bringing evidence, for example, this order by General Delic, which has to

Page 6500

1 do with the placement of howitzers, to show that the ABiH were in a

2 position to inflict terror.

3 I find it a very, very difficult question because unless I can

4 reconcile the issue of the relevance, much of the Defence case will remain

5 very questionable. But I observe that the Prosecutor does not raise any

6 questions about relevance and, indeed, cross-examines on the evidence that

7 has been adduced. But I would like to get the views of Mr. Waespi and

8 yourself, or you, since your handling this witness, on this issue which

9 the Chamber is finding very, very difficult to reconcile.

10 MR. DOCHERTY: Thank you, Mr. President.

11 I have not raised a relevancy objection so far because the Chamber

12 has been asking questions concerning the relevancy of the testimony and so

13 I considered any objections or submissions that I would have made to have

14 been redundant, quite frankly.

15 With regard to the line of defence that you outlined in your

16 question to me, I have not heard that evidence. I have heard evidence

17 that the Serbian population suffered. The Prosecution has never denied

18 that the Serbian population suffered. That was the first half of what you

19 outlined.

20 The second half of what you outlined, however, that the terror

21 with which the accused is charged was in fact caused by the ABiH, I have

22 not heard evidence coming from the Defence regarding that. So far this

23 morning, with all respect to the witness who I know went through a

24 terrible experience in the war, he has testified that he, a soldier in

25 uniform, was wounded while performing a military task. This was from, he

Page 6501

1 submits, a 152-millimetre howitzer. We now are shown an order from about

2 two years later saying that a 152-millimetre howitzer is to be taken from

3 some unspecified place - it is not set out in the order - undergo some

4 unspecified modifications - it is not set out in the order - and then

5 taken back to the place from whence it came.

6 I cannot connect those dots into a colourable submission that

7 terror was caused by the ABiH and that is but one example. I do not -- I

8 do not contest that if evidence of the sort you described was coming in,

9 it would have relevance. My submission is simply that it is not coming

10 in.

11 With regard to the Prosecution's cross-examinations, without

12 getting into matters of strategy, I would say that we cross-examine on

13 those points - speaking for myself, I think I have to limit it to that;

14 Mr. Waespi might be able to speak team-wide - cross-examine on those

15 points that do have relevance and so, for example, I think that most of my

16 cross-examinations have been centred upon the question of who controlled

17 the hilltops. We've probably spent more time on that than on any other

18 individual topic, although there have been some other things that have

19 come up with regard to the testimony of other witnesses.

20 JUDGE ROBINSON: Thank you.

21 [Trial Chamber confers]

22 JUDGE HARHOFF: Mr. Tapuskovic, the Chamber really wants to

23 understand your case, and we are struggling to find out just how the

24 evidence that you are now suggesting to us can support what we believe is

25 your case.

Page 6502

1 Just a short while ago, the President once again expressed the

2 views of the Chamber of what we think it is that you are trying to prove

3 to us, and if the President's interpretation and the Chamber's

4 interpretation of this is correct, then I have to ask you just how is it

5 that, for instance, this order by General Delic can show that the terror

6 was really caused by the ABiH. I have difficulties in understanding that,

7 and I kindly ask you to help me out, to understand better how this

8 evidence can support the view.

9 MR. TAPUSKOVIC: [Interpretation] Your Honour, Judge Harhoff, Your

10 Honours, the Chamber, perhaps the best way to explain this would be to use

11 the present example. You have witness Drazen Maunaga before you. At the

12 beginning of the war he experienced what he experienced. He described

13 that for our benefit. I did not mean to adduce those very documents. I'm

14 sure you trust this witness. You see what this is about. And now you

15 have the same person. At one point in time there had been a lull; there

16 had not been many clashes. Even international observers - I'm not going

17 back to that now - had been saying that by October it had been relatively

18 peaceful. This is also in some of the OTP exhibits and I'm not going into

19 everything else that we the Defence have been talking about. You have

20 this witness at this point in time. The weapons were moved to a different

21 location and now he hears these weapons firing again. This person before

22 you hears the same thing again. How is it possible for this person not to

23 experience stress, fear, perhaps for his own life?

24 What I'm trying to prove is this: Firstly, the key issues

25 regarding who was holding which positions, I am convinced the Defence will

Page 6503

1 succeed in showing many things in a different light than they were

2 presented in the Galic trial. It's precisely about the atrocities

3 suffered by the civilian population because of the fighting on both

4 sides.

5 The best indicator is a person like the present witness who

6 experienced this himself. You can use the presence of this witness to

7 help you realise what the fears were that were involved in a conflict like

8 that, especially those fears that prevailed among the people between May

9 and the end of the war, during the large-scale BH army offensive and the

10 NATO bombing. Those fears prevailed. And I'm not going into other

11 aspects of those fears which is something that we shall be trying to

12 prove.

13 So when we speak of terror, this is something that's difficult to

14 distinguish. This sort of situation creates suffering on the part of all

15 citizens, such as the present witness. I could have brought hundreds of

16 witnesses but there is no time for that. It's that simple. I have only

17 produced a handful of witnesses, such as the present one, to testify to

18 these matters. But I hope the Defence will be successful in showing that

19 they too -- well, that's at least what I believe, of course. I'm not the

20 one who can claim that this has been finally resolved or not. What the

21 cases looked like that were presented are pattern cases, what exactly what

22 was going on, even those 30 or so cases, beyond a reasonable doubt. That

23 when we talk about terror, there can be no distinction made between fears

24 felt by any person alive.

25 Why would a nation inflict something like this upon themselves,

Page 6504

1 hurt themselves and hurt others, too? Regardless of the historical,

2 strategic and other circumstances, these people in late 1994, 1995, 1996,

3 whatever was going on, whatever their desires were at the time, had no

4 urge whatsoever to launch into any sort of action whatsoever, especially

5 as the only objective allegedly was to target civilians.

6 You will be hearing other witnesses. This witness is the best

7 example for you what it means to own a weapon such as this one that has a

8 range of 30 kilometres and you actually listen to it while it's flying

9 through the air. This is just one piece of evidence. We've been able to

10 track down a lot of evidence like this. This is a sure sign of sowing

11 fear among one's own population. Those citizens of Bosnia who were under

12 the control of the BH army, maybe they didn't hear a weapon like this

13 being used but it could have targeted them too. This sort of weapon, this

14 sort of firing, caused fear on both sides of the ethnic divide. So I

15 think this should be something for you to judge.

16 JUDGE HARHOFF: We will take into consideration what you have

17 said. I hope by the end of your case I will understand it better, but I

18 think at this moment we should move on. Thank you.

19 JUDGE ROBINSON: Yes. We have four minutes before the break.

20 We'll admit the document.

21 THE REGISTRAR: As D225, Your Honours.

22 MR. TAPUSKOVIC: [Interpretation]

23 Q. Mr. Maunaga, what happened at the end of this time that you were

24 talking about, August, December, the offensive? So, as I said before,

25 what happened at the end?

Page 6505

1 A. There was a ceasefire sometime in December, late December, I

2 think.

3 Q. What about this time period? I'm not sure how long it went on

4 for. Can you tell us that first, please.

5 A. There was a cease-fire that we felt was some sort of a preparation

6 for a new offensive that would eventually be launched against us.

7 Q. How do you mean that?

8 A. It went on until sometime in June.

9 Q. How did you use that lull for your humanitarian work? What were

10 you actually able to do during that period, in terms of, for example, food

11 or firewood?

12 A. We brought supplies to families. We made sure they were safe

13 throughout the winter. UNPROFOR gave us a hand. We took supplies to

14 hospitals. There were infections because of the surplus of garbage.

15 Different sorts of infectious diseases were rife, and they helped us a lot

16 with that.

17 We also brought water to the lower slopes around Sarajevo,

18 especially because there were many refugees living there who had escaped

19 from the fighting. We also went to Kasindol, but those slopes had no

20 running water and obviously this required assistance by UNPROFOR.

21 In addition to food shipments, it was also about actually

22 distributing these shipments. So that is mostly what we did.

23 MR. TAPUSKOVIC: [Interpretation] Your Honours, I have very few

24 questions left. If we could have the break now for me to go through my

25 questions again to see if I can drop any, maybe that might cut the whole

Page 6506

1 thing short. And it is half past 10.00, after all.

2 JUDGE ROBINSON: Well, not quite, but we'll take the break.

3 --- Recess taken at 10.28 a.m.

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

5 JUDGE ROBINSON: Yes, Mr. Tapuskovic.

6 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honour.

7 Q. Mr. Maunaga, perhaps we can go over a couple of things before we

8 finish so that you can explain something to the Judges. You said that

9 there was a lull between December and June. When you said that, what was

10 the first thing that came to your mind?

11 A. I meant to say that there were no intensive combat activities in

12 that period.

13 Q. During that period, did you have contact with the population? For

14 example, did you go down to Grbavica?

15 A. Of course I moved about all those parts, and every second or third

16 day I went to Grbavica.

17 Q. Can you tell me, what did Grbavica look like in terms of layout of

18 its geographic position? How did you feel down there?

19 A. Grbavica is in a depression in relation to the Muslim positions.

20 One could always hear small-arms fire; therefore, one always moved around

21 Grbavica with fear. The people who lived there knew of certain routes

22 that they were supposed to take, but unless you were familiar with those,

23 you were risking your life.

24 Q. Mr. Maunaga, can you tell me whether you ever managed to reach the

25 population of Nedzarici?

Page 6507

1 A. As I said, I often went to Ilidza. However, I didn't dare to go

2 to Nedzarici, although I had friends and family there. I didn't know a

3 way in and how to move around that part, because that part was very

4 exposed to combat activities.

5 Q. Thank you. When you talked to the people at Grbavica and

6 Nedzarici, what would they usually tell you?

7 A. What was particularly interesting was that the fear was present

8 all the time, but it intensified during that period, because the people

9 had a feeling that the other side was gaining in strength and that they

10 were getting ready to drive them away from those parts.

11 An additional factor was the stories one could hear from the

12 people who came from inside the city, who could tell about the atrocities

13 in the city, about torture, and people disappearing overnight. And then

14 they would always ask me, since I had contacts with foreigners, whether

15 there was any possibility for me to secure a visa for them or to do

16 anything so that they could be -- they could leave the area. And the same

17 goes for all of the parts in the eastern territories around Sarajevo.

18 Q. What happened in June, since you mentioned June a minute ago?

19 A. In June there was a large offensive in the area of Trnovo and

20 Nisici.

21 Q. What did all that look like?

22 A. I cannot put it in strictly military terms but the intensity of

23 fighting was great, and I know that because everyone who was able to

24 fight, all able-bodied people, were included in the defence.

25 Q. And you, as someone who dealt in civilian affairs, did you have

Page 6508

1 any specific tasks at that time?

2 A. When the offensive began, my contact with the UNPROFOR and

3 international organisations ceased. Therefore, I was assigned a new role,

4 to organise civilian protection, because it was a matter of survival in

5 that area, and all able-bodied people were supposed to take part in the

6 defence. We even had to count on the elderly and women to harvest and to

7 cut grass, to secure firewood for the winter, for had we not done that we

8 would have put our own existence into question.

9 Q. How long did that last?

10 A. It lasted all the way until the Dayton agreements.

11 Q. What happened after the Dayton Accords? Did you manage to return

12 to your apartment in the centre?

13 A. No, never. I guess the people living there wouldn't like to see

14 me come back because I knew a lot about them.

15 Q. What happened with the people of Grbavica, Nedzarici, Dobrinja,

16 Ilidza, the people who used to live there?

17 A. After the Dayton Accords, they all left those areas because they

18 feared the new authorities that were to be appointed.

19 Q. Since your house was in Kasindol, it is close to Vojkovici.

20 Concerning the people who used to live there, did they sustain any

21 civilian or military casualties? Can you tell us in brief?

22 A. Yes. I made surveys; I collected data to provide to the

23 international organisations, to be able to show what the number of

24 casualties was, what the number of those who had their limbs amputated due

25 to the war was. Therefore, I know that in Kasindol there were about 130

Page 6509

1 killed and some 20 civilian casualties; in Vojkovici, around 150 killed

2 and around 30 civilian casualties. I don't have information for Trnovo.

3 Q. Thank you, Mr. Maunaga.

4 MR. TAPUSKOVIC: [Interpretation] This concludes my

5 examination-in-chief.

6 JUDGE ROBINSON: Mr. Docherty?

7 Cross-examination by Mr. Docherty:

8 Q. Good morning, Mr. Maunaga.

9 A. Good morning.

10 Q. Mr. Maunaga, my name is John Docherty. I'm one of the lawyers on

11 the Prosecution side of this case. I know that the events that you are

12 testifying to are very difficult for you, but it is necessary that I ask

13 you a few questions but I don't think this will be all that terribly

14 long.

15 If you have any question about what I am saying or if you don't

16 understand, please ask me to clear it up rather than guessing at what I

17 may be asking you. Is that all right?

18 A. Yes, it is.

19 Q. I want to talk with you a little bit about your military career,

20 Mr. Maunaga. What was the highest rank that you held in the

21 Sarajevo-Romanija Corps?

22 A. I held no rank.

23 Q. You were a private soldier?

24 A. A regular soldier, a private.

25 Q. Could you tell us, please, what company you were in? And then

Page 6510

1 just so you know where I'm going, I'm going to go up the chain and ask you

2 what battalion you were in, what brigade you were in. So let's start at

3 the bottom. What company were you a member of?

4 A. I was a member of the reconnaissance company.

5 Q. And was the reconnaissance company assigned to any particular

6 battalion; and if it was, could you tell us, number 1, which battalion

7 and, number 2, the name of the commanding officer?

8 A. I don't know the exact hierarchy but I think my company was under

9 direct command of the brigade commander.

10 Q. And when you say "the brigade," is that the 1st Sarajevo Infantry

11 Brigade or is it some other brigade?

12 A. The 1st Sarajevo.

13 Q. And at the time that you were a member of the 1st Sarajevo

14 Infantry Brigade, who was its commanding officer, please?

15 A. Veljko Stojanovic.

16 Q. And then lastly, sir, when you did your national service in the

17 Yugoslav People's Army, what was the rank that you held and what was the

18 kind of duty that you performed?

19 A. I was a private, trained as a scout.

20 Q. So much the same type of duties that you later performed with the

21 SRK when you were on the hill of Gavrica.

22 A. Yes, certainly. That's the training that I had.

23 Q. As a private soldier, you had duties to perform, probably quite

24 important duties, but you yourself were obviously not in daily contact

25 with the senior leadership of the Sarajevo-Romanija Corps. Am I correct

Page 6511

1 in that?

2 A. Yes. I had no contact with them, or if there was any, it was

3 seldom. I only had to relay information.

4 Q. And in order to relay information, you described the equipment

5 that you had up on the hill and I'll just go through that again and ask

6 you to affirm that this is correct.

7 You had a pair of binoculars; correct?

8 A. Yes.

9 Q. A map?

10 A. Yes.

11 Q. A compass?

12 A. Yes.

13 Q. And for communications, you had a military telephone and you also

14 had a radio set. Do I have that right, Mr. Maunaga?

15 A. Yes, yes.

16 Q. And is the reason that you had two different means of

17 communicating, both a military telephone and a radio set, because it was

18 important that your information get to the commanders behind your

19 position?

20 A. Yes, of course. Yes.

21 Q. And the information that you gathered concerning the dispositions

22 of the army facing you were, as far as you know, sent back up a chain of

23 command to be used by military decision-makers; is that correct?

24 A. Yes.

25 Q. When you came on duty each time that you did, did you test your

Page 6512

1 radios -- your radio and your military telephone to make sure that they

2 were working properly?

3 A. Yes. It is one of the basic tasks.

4 Q. And the information that you gathered, who did it go to? Who were

5 you communicating to?

6 A. To the communications centre with the command.

7 Q. You said "with the command." With the command of what? Of the

8 brigade? Of some other unit?

9 A. The brigade command of the 1st Sarajevo Corps.

10 Q. And so far as you know, the brigade command then used the

11 information you gave them, together with other things, of course, to fight

12 the war and to decide which troops would go where, which weapons would go

13 where, and other sorts of military decisions; is that correct, sir?

14 A. Yes, it is.

15 Q. And during your time with the Sarajevo-Romanija Corps, did you

16 observe it to have a properly functioning chain of command in which more

17 senior officers gave orders to less senior officers who in turn gave

18 orders to private soldiers?

19 A. I didn't bother to follow how the chain worked but I suppose so.

20 Q. Did you ever see any indication that the chain was not working?

21 A. No.

22 Q. The Sarajevo-Romanija Corps was in -- when it was in the JNA, was

23 the old 4th Corps of the Yugoslav People's Army; is that correct, Mr.

24 Maunaga?

25 A. I don't know that.

Page 6513

1 Q. Are you aware that the -- are you aware that the Sarajevo-Romanija

2 Corps took over many of the military assets and many of the officers of

3 the 4th Corps of the JNA?

4 A. I am aware that the equipment that was left by the JNA was taken

5 over. I don't know about any officers, though.

6 Q. When you joined the Sarajevo-Romanija Corps in 1992, who was the

7 commanding officer of the corps, if you remember?

8 A. I think it was General Galic.

9 Q. And General Galic was a career JNA officer; is that correct?

10 A. I think this is a bit leading. I don't know.

11 Q. Mr. Maunaga, it's all right to lead on cross-examination, but I

12 understand your concern.

13 You were wounded and out of the army by late in 1992, am I right

14 about that?

15 A. Yes.

16 Q. Have you had an opportunity before coming to testify to read over

17 the amended indictment, the document that brings the charges in this case?

18 A. Unfortunately, no.

19 Q. If you haven't had an opportunity to read over the indictment, are

20 you aware from any other source that the charges in this case concern a

21 period of time beginning approximately two years after you left the corps?

22 A. I know that it pertains to the period of command of General

23 Milosevic, since he is the accused in this case.

24 Q. And you know that General Milosevic was in command of the corps

25 beginning in about August of 1994; correct?

Page 6514

1 A. Yes, it is.

2 Q. So while you were in the army, you did not have daily contact with

3 senior decision-makers, and after you left the army is when the period of

4 time concerning this case begins; is that correct?

5 A. Yes.

6 Q. When you were giving your direct testimony, you testified with

7 regard to a hill called Mojmilo, and I have a couple of questions

8 concerning Mojmilo.

9 First of all, did I understand you properly, did you say that the

10 SRK or the VRS, as part of controlling the lower slopes, also controlled

11 the municipal waterworks?

12 A. In a certain period, the VRS did control not the municipal but the

13 city waterworks, rather. It was until June. And then we withdrew our

14 soldiers from there because they were being killed there regularly.

15 Q. When you say "the city waterworks," is the city in "city

16 waterworks" the city of Sarajevo?

17 MR. TAPUSKOVIC: [Interpretation] Your Honours?

18 JUDGE ROBINSON: Yes, Mr. Tapuskovic?

19 MR. TAPUSKOVIC: [Interpretation] I can see in the transcript that

20 June is mentioned, and that is what the witness mentioned, but the

21 Prosecutor's question was -- well, I think it had to do with the year. So

22 we have June but of what year?

23 JUDGE ROBINSON: What year is this, Witness?

24 THE WITNESS: [Interpretation] 1992.

25 JUDGE ROBINSON: Yes, Mr. Docherty?

Page 6515


2 Q. Now, also with regard to Mojmilo, you have not read the amended

3 indictment in this case, but are you aware, Mr. Maunaga, from maybe some

4 other source that the sniping incidents alleged in this case are in

5 several clustered areas within the city of Sarajevo? And I'll just

6 mention two of them: Marin Dvor and Sedrenik.

7 Let's start with Marin Dvor. Do you know that area from the time

8 that you spent living in the city of Sarajevo? Do you know what I mean

9 when I say "Marin Dvor"?

10 A. Yes. I know Marin Dvor.

11 Q. And what about Sedrenik?

12 A. Vaguely. I went there very rarely, maybe once or twice.

13 Q. And do you know that Sedrenik is below a hill called Sharpstone?

14 A. I'm not particularly familiar with that area. I didn't go there

15 often. I don't know.

16 Q. All right. If you're not familiar with it, we won't ask -- I

17 won't ask you questions about that area. But with regard to Marin Dvor,

18 do you know the S-curve in the tram tracks that's roughly in front of the

19 Holiday Inn on Zmaja od Bosne?

20 A. Yes, I know that curve.

21 Q. And from Mojmilo, a rifleman, a sharp-shooter, could not hit that

22 S-curve because there are buildings in the way; isn't that correct? In

23 particular the Holiday Inn.

24 A. I don't know. I never looked at this part from Mojmilo and I

25 think it's far away.

Page 6516

1 Q. Just to make clear, you would say that Marin Dvor is far away from

2 Mojmilo?

3 A. Well, it is far away but it's within range.

4 Q. Okay. It's within range, as long as there is a clear shot from

5 there; is that correct? And also, that you are saying you don't know

6 whether there is a clear shot or not, never having yourself looked.

7 A. Yes.

8 Q. Mr. Maunaga, you also, in your direct evidence, talked about the

9 period of time after you left the army, when you were moving about from

10 area to area, and in particular, I want to talk with you about the route

11 that you described and marked on the map going sort of around the

12 perimeter of the city. Do you know the chunk of direct testimony I'm

13 referring to?

14 A. No. I don't understand.

15 Q. Let me see if I can help. Do you know the road that runs from

16 Lukavica to Pale?

17 A. Yes.

18 Q. And it may be because I misunderstood your direct testimony, but

19 did you testify that in moving around the city, and in particular in going

20 to Ilidza, you had to drive all the way around town and I think part of

21 your route was on the Lukavica-to-Pale road? Does that help and did I

22 understand properly?

23 A. Yes.

24 Q. And you were able, on roads, to travel all the way around town

25 from Lukavica to Pale and then on around the north end of Sarajevo and

Page 6517

1 down into Ilidza; is that correct?

2 A. It's all called a road. However, one had to take a forest road to

3 get to Ilidza and these were very inaccessible roads. That would be it.

4 Q. I'm not saying that it was easy, but I'm saying that it was

5 possible and that you did it. Is that correct?

6 A. It was possible but with a great risk. I said parts and sections

7 of the roads were constantly exposed to activities and the risks were

8 high.

9 Q. And on the southern side of town, where the Lukavica-to-Pale

10 segment is, what I want to concentrate on, that road runs along a ridge

11 line that is to the south of Sarajevo; am I correct?

12 A. Yes.

13 Q. And that road, keeping that road open was very important to the

14 Sarajevo-Romanija Corps, was it not, because if that road was cut,

15 physical communication between Lukavica and Pale would have been

16 impossible.

17 A. Yes.

18 Q. And, in fact, throughout the war, other than occasional raids by

19 the ABiH that were repulsed, that road was never permanently cut by the

20 ABiH, was it?

21 A. That's right.

22 Q. And as you drive along that road, you are fairly high up, with a

23 commanding view over the city of Sarajevo. And again I'm referring to the

24 Lukavica-to-Pale segment. Is that correct, Mr. Maunaga?

25 A. Well, not exactly. There is a very short section from which

Page 6518

1 Sarajevo can be seen. Otherwise, you pass behind a hill or the visibility

2 is reduced because of the woods.

3 Q. Two follow-on questions to that, sir.

4 First of all, the section from which Sarajevo can be seen, could

5 you tell us where that section is, please? I'm not going to ask to you

6 mark on a map. Just describe it in words, please.

7 A. It's a section after Zlatiste up to the Osmice curve or even a

8 shorter section. I didn't look upon Sarajevo from that point, never

9 during the war. I just tried to pass as quickly as possible along that

10 section.

11 Q. And then my second follow-on question, Mr. Maunaga, deals with the

12 lowered visibility from either hills or from the woods. During your time

13 in the army, did you ever -- either the JNA or the Sarajevo-Romanija

14 Corps, did you ever get trained on mortars?

15 A. No.

16 Q. Even if you weren't trained on mortars, did you ever hear mortars

17 referred to as indirect-fire weapons?

18 A. I don't understand what indirect fire is.

19 Q. Indirect fire, Mr. Maunaga, would mean that the mortar crew does

20 not need to see their target in order to fire at it because the mortar

21 shell goes up in the air on a parabolic curve and then comes back down to

22 earth, and as long as they have an observer to radio back corrections to

23 the fall of a shot, they can engage a target without seeing it. Do you

24 agree that a mortar crew can shoot at things, in fact can hit things, that

25 they cannot see?

Page 6519

1 A. Yes. I'm aware of that, and that is basically how they operate.

2 Q. Mr. Maunaga, I think the last thing I want to speak with you about

3 this morning is the airport. You remember that you gave testimony that

4 General Ratko Mladic came to, was it, your position, or is this something

5 that you heard about, and talked about shooting at the airport? Do you

6 remember that?

7 A. He came to our position to warn us not to even think about

8 shooting or even throwing a stone. And there was no shooting because it

9 was a VRS position.

10 Q. So when was it that General Mladic -- I don't think you gave this

11 in your direct testimony. When was it that General Mladic gave this

12 speech?

13 A. It was in July. I don't know the exact date, but I think it

14 coincides with the date when the airport was handed over, or maybe a day

15 before that date.

16 Q. And so when you say "July," the handover of the airport was in

17 July of 1992. Was it around then?

18 A. Yes, yes, yes.

19 Q. Did you hear General Mladic yourself or did you hear about what he

20 had said from other people?

21 A. I heard it myself.

22 Q. I want to explore for a moment, Mr. Maunaga, how that was put into

23 practice.

24 First of all, are you aware that during the trial of General

25 Galic, there was evidence of shooting from SRK positions of civilians

Page 6520

1 seeking to cross the airport? Have you heard that before?

2 A. Not to my knowledge.

3 Q. And are you aware that the allegations are that that came from

4 various SRK-controlled hills around the airport?

5 A. I don't know about that, but I don't think there was any activity

6 aimed at the airport.

7 MR. DOCHERTY: Could we see Prosecution Exhibit 667, please.

8 Q. Mr. Maunaga, on the screen in front of you there is a document.

9 On the right-hand side it's in B/C/S. Is it big enough that you can read

10 it?

11 A. It's better now.

12 Q. I'm going to ask you, Mr. Maunaga, just take a minute, read it

13 over, and when you're ready to answer a couple of questions about it, just

14 let me know. And I'm particularly interested in the first three

15 paragraphs.

16 A. As far as I can see, this is from 1994. I really have nothing to

17 do with this and I have no knowledge of this kind of military

18 information. I was involved in civilian affairs.

19 Q. Right. I called for this document, Mr. Maunaga, because you said

20 a few minutes ago that, "I don't think there was any activity aimed at the

21 airport." Do you see the paragraph that begins, "Through contacts with

22 UNPROFOR representatives, we have obtained information that in the Ilidza

23 area, they spotted four Bofors, anti-aircraft guns."

24 JUDGE ROBINSON: Mr. Tapuskovic?

25 MR. TAPUSKOVIC: [Interpretation] Your Honours, the witness already

Page 6521

1 said that he had no military role in that period, that he was involved in

2 civilian affairs. What he said about the period while he was at the

3 observation post refers to the first half of 1992. About this period, he

4 says that he has no information about military affairs; therefore, he

5 cannot give evidence on this because he knows nothing about these issues.

6 MR. DOCHERTY: May I respond, Mr. President?


8 MR. DOCHERTY: Mr. President, with respect, Mr. Tapuskovic's

9 submission misses the point. We have had evidence from this witness that

10 General Mladic gave direction that the airport was not to be fired upon.

11 I don't know that the witness said that there was any time limit upon that

12 injunction. I now have a document indicating that there were in fact

13 weapons along the axis of flight of UNPROFOR aircraft landing at the

14 Butmir airport, which is the Sarajevo airport in the Butmir neighbourhood,

15 and I think it's perfectly appropriate to put it to the witness. If the

16 witness doesn't know, the witness doesn't know, but I don't see any bar to

17 putting this to the witness in light of the evidence he's given concerning

18 General Mladic's speech.

19 JUDGE ROBINSON: Nor do I. Please answer the question.


21 Q. And Mr. Maunaga, the pending question was: Do you see the

22 paragraph beginning, "Through contacts with UNPROFOR representatives, we

23 have obtained information that in the Ilidza area they spotted four

24 Bofors, anti-aircraft guns, deployed along the axis of the flight path of

25 UNPROFOR aircraft landing at the Butmir airport." Do you see that?

Page 6522

1 A. Yes, I do.

2 Q. A Bofors gun is a 20-millimetre anti-aircraft weapon; is that

3 correct? Do you know that from your time in the army?

4 A. It's not correct. A Bofors gun is a 40-millimetre

5 single-barrelled gun used on ships.

6 Q. Well, I think it's safe to say that if they are near the Sarajevo

7 airport, they are probably not being used for naval purposes. They can

8 certainly be modified -- be pressed into service to shoot at other things;

9 is that correct, sir?

10 A. It can fire at other things. It shouldn't be mounted on a ship.

11 You can put it on a tree or on a stump.

12 Q. And this is a document that comes from the Sarajevo-Romanija Corps

13 command; is that correct?

14 A. That's what I see in the letterhead.

15 Q. The Sarajevo airport is in the area of Sarajevo, the district, the

16 neighbourhood, called Butmir; is that correct?

17 A. Yes.

18 Q. And having these weapons in the landing path at Butmir airport is

19 not consistent with what you say General Mladic told you on that day back

20 in 1992, is it?

21 A. Well, I don't know whether these operations and actions took

22 place. I can say that a majority of the runway from both ends was held by

23 the Muslim forces, so I don't understand who was firing. You're asking me

24 details and I'm telling you that I don't know anything about military

25 affairs. They had Dobrinja on the one side and Butmir on the other side

Page 6523

1 and there was a tunnel underneath.

2 Q. You say that you don't know if these guns were used. You

3 testified, I believe, that guns and ammunition were precious commodities

4 in the SRK. Did you talk about that?

5 A. I didn't say anything about that. I'm not saying anything about

6 that. What I don't know I'm not going to speak about.

7 Q. Well, let me put it to you this way and perhaps this is something

8 you do know: Was the SRK so rich in weaponry and ammunition that four

9 Bofors guns could be put somewhere and not used?

10 A. I don't know about that. First of all, I don't know if they

11 existed at all. I don't know. And secondly, even if they had been

12 deployed, I don't know if they were used. Through my contacts with

13 UNPROFOR, I never received such a protest.

14 MR. DOCHERTY: Mr. President, that may be all the questions I

15 have. Could I have one moment to check my notes?


17 [Trial Chamber confers]

18 JUDGE ROBINSON: Mr. Docherty?

19 MR. DOCHERTY: That concludes my cross-examination,

20 Mr. President.

21 Thank you, Mr. Maunaga.

22 JUDGE HARHOFF: Mr. Witness, can I put a last question to you, and

23 that is a question that comes out of your testimony about the city

24 waterworks. The reason I'm asking is that we have heard that it was

25 difficult not only for the population living within Sarajevo but also for

Page 6524

1 the population living outside Sarajevo to actually get water. We have

2 evidence that water trucks had to be driven into Sarajevo to provide fresh

3 water to the population living there.

4 So my question is: What was actually the function of the

5 waterworks at Mojmilo which you referred to? Did that waterwork control

6 the access of fresh water to the city of Sarajevo or to the local region,

7 both within the confrontation lines and also outside the confrontation

8 lines? Or were there several waterworks around the city and so you would

9 have to close all of them in order to prevent the people from inside or

10 even outside Sarajevo to get fresh water? What was the function of the

11 waterworks at Mojmilo specifically? Can you clarify that?

12 THE WITNESS: [Interpretation] Sure. I was dealing with that issue

13 for a while because the water problem was an obvious problem throughout

14 the area.

15 What we are looking at Mojmilo was no waterworks. There were

16 reservoirs from Ilidza to Mojmilo used for the irrigation of the lower

17 lying town areas. There are several waterworks that enter Sarajevo from

18 other areas. One is from Jahorina Bistrica, the other is from Tilava -

19 there is a tunnel through Mojmilo - and the third is Bacevo and the

20 reservoirs at Mojmilo.

21 It is from that water reservoir that both the Serb and Muslim part

22 of town got their water. There was an attempt being made throughout to

23 supply sufficient amounts of water to both, since these were mutually

24 dependent things. If one party had no water, then the other party had no

25 water either. I hope that answers your question.

Page 6525

1 JUDGE HARHOFF: It does in part because my next question would

2 be: Then what happened actually to the waterworks or to the reservoirs in

3 Mojmilo? Were they emptied and never refilled or the tubes that let the

4 water down, were they destroyed? What happened to the Mojmilo reservoir?

5 THE WITNESS: [Interpretation] For a brief while, they were under

6 the control of the army or, rather, being guarded to keep anything from

7 happening to them. So the army held that responsibility up until June

8 1992. And the waterworks remained in operation, in operational order,

9 throughout the war. It was never destroyed.

10 JUDGE HARHOFF: So are you saying that at least the areas which

11 were provided with water from the Mojmilo reservoirs, that those areas at

12 least, they had water throughout the war?

13 THE WITNESS: [Interpretation] I don't know if there was sufficient

14 water but the waterworks remained intact, and it was under the control of

15 their army. It was probably a problem to do with pumps, in terms of water

16 capacity and whether it could actually get sufficient amounts of water

17 across to Mojmilo.

18 JUDGE HARHOFF: Which then transforms into the question that I put

19 to you before; namely, were the reservoirs in Mojmilo filled with water

20 during the war, from 1992 to 1994-5? Do you know? If you don't know,

21 then please just say so.

22 THE WITNESS: [Interpretation] I don't know everything but I know

23 that they were operational. Once they'd filled them enough, probably

24 there was sufficient water to get supplies through to everyone. The water

25 problem wasn't resolved before Dayton. We ourselves didn't have

Page 6526

1 sufficient water supplies.

2 JUDGE HARHOFF: No. I know it was hard for both parties. Thank

3 you very much, Mr. Witness.

4 JUDGE ROBINSON: Mr. Tapuskovic?

5 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honours.

6 Re-examination by Mr. Tapuskovic:

7 Q. Mr. Maunaga, speaking of water, His Honour Judge Harhoff asked you

8 about outside Sarajevo, what the problem was. Where is Grbavica,

9 Nedzarici, Dobrinja? Where are those?

10 A. In the town itself.

11 Q. All right. So there was a water problem, for example, where the

12 Presidency is. Was there a water problem at Grbavica at the same time?

13 A. Naturally.

14 Q. But let me go back to what you were cross-examined on by the OTP.

15 So you head out from Lukavica. How long would it take you to reach that

16 small area and by what route from which you could see Sarajevo, from which

17 there was a view of Sarajevo, the road to Pale, wherever you were? What

18 was it like in relation to the lie of the land, and where exactly does

19 that road go?

20 A. The road goes below Vraca, Miljevici, and then the bend.

21 Q. Below Vraca, below Miljevici, all right. But I'm asking you in

22 terms of the lie of the land, where do you go? All these places that you

23 pass on the way, do you have a view of Sarajevo, Grbavica, or any other

24 section of Sarajevo from those places?

25 A. There are no views along that road except for that very small

Page 6527

1 section that was constantly under fire.

2 Q. What about while you were at that observation post, that brief

3 time, what you explained to us previously? Did you ever take that road at

4 the time?

5 A. No.

6 Q. All right. So you passed this small section from which you could

7 see Sarajevo, and where do you get to next?

8 A. There is a wooded area next, but you couldn't see anything. From

9 Colina Kapa you could see the road and they kept firing away at us.

10 Q. How long is the road through the woods that you're referring to?

11 A. The one under fire or the entire route?

12 Q. The entire route through the woods.

13 A. I think about 15 kilometres.

14 Q. Thank you. Something else about one of the questions that you

15 were asked by the OTP. From that observation post at which you were, were

16 you able to observe a single position in the city of Sarajevo itself,

17 Grbavica, for example, or any other section of Sarajevo?

18 THE INTERPRETER: The interpreters didn't hear the answer.

19 MR. TAPUSKOVIC: [Interpretation]

20 Q. From where you were --

21 JUDGE HARHOFF: What was your answer to the question?

22 THE WITNESS: [Interpretation] No, I couldn't see.

23 THE INTERPRETER: Could counsel please not speak at the same time

24 as the witness? The interpreters are unable to hear the witness as he

25 answers the question. Thank you.

Page 6528

1 JUDGE ROBINSON: Mr. Tapuskovic and the witness, don't overlap.

2 MR. TAPUSKOVIC: [Interpretation] I asked him whether he could see

3 Grbavica or any other area of Sarajevo and he said no, not a single one.

4 That's what he said. He said, "I did not see a single area of the city

5 itself." That's what he said and it wasn't recorded. I can tell you

6 because I understand the language.

7 MR. DOCHERTY: Mr. President --

8 MS. ISAILOVIC: [Interpretation] Mr. President, only to make things

9 clear. When one says, "the city itself," I believe that what the witness

10 said would be rather translated by "downtown." I'm not a language expert

11 but I believe that it's not quite the same thing, the city itself and

12 downtown or centre.

13 So what Mr. Maunaga said was "centre de la ville" in French,

14 so "uzi dio grada" in B/C/S, or "downtown," as I would say, in English.

15 It may be that these are only nuances but sometimes they do change things

16 dramatically, because part of our case is also not to make any difference

17 between, say, Grbavica as part of the downtown area, centre de la ville de

18 Sarajevo and, say, Marin Dvor.

19 This is why we are very sensitive to these issues related to

20 translation. And here again, I can't -- I don't know how my own words are

21 being translated, of course. It may be that there are two Judges who

22 understand me in French and I'm really -- I'm keen for the Presiding Judge

23 understanding me, too. I want things to be understood by the Defence and

24 also by the witness.

25 JUDGE ROBINSON: All right. You say that the witness referred to

Page 6529

1 downtown or the city centre. Let's see now whether Mr. Docherty has

2 another nuance.

3 MR. DOCHERTY: I don't know if I have a nuance, Mr. President.

4 What I have is an objection to the question. Mr. Tapuskovic's question,

5 beginning on page 49, line 1: "Something else about one of the questions

6 that you were asked by the OTP. From that observation post at which you

7 were, were you able to observe," and so forth and so on. Mr. President, I

8 did not ask him about sight-lines from his observation post; I asked him

9 about sight-lines from Mojmilo; I asked him about the view from the

10 Lukavica-to-Pale road. And I'll also add that in his direct examination,

11 the witness was asked about this and said that he could see Dobrinja,

12 which is in contradiction to the answer he just gave. But my objection is

13 that this was not raised on cross-examination.

14 JUDGE ROBINSON: Are you saying that -- well, it wasn't raised in

15 the way that Mr. Tapuskovic says it was raised but it may have been raised

16 in some other way.

17 MR. DOCHERTY: No, my point is stronger. The question that he is

18 asking now relates to a subject that was not raised at all in

19 cross-examination, not in one way or another. He's asking him about

20 sight-lines from his observation post. I did not ask him about that. His

21 observation post was south of the airport. I asked him about the

22 Lukavica-to-Pale road. That's miles away. I asked him about Mojmilo

23 hill. That's also a long way away. And also Mr. Tapuskovic did ask in

24 direct examination about what he could see from that observation post and

25 I'll just submit that the witness gave a different answer. He said he

Page 6530

1 could see Dobrinja. Now he's saying he couldn't see anything.

2 JUDGE ROBINSON: You didn't ask about the observation post.

3 MR. DOCHERTY: I did not ask about sight-lines from the

4 observation post, no, Mr. President.

5 JUDGE ROBINSON: No, no, not sight-lines from the observation

6 post. I'm asking you: Did you not ask questions about the observation

7 post?

8 MR. DOCHERTY: I asked him what equipment he had in the

9 observation post, and we went through map and compass and telephone and so

10 forth and so on, and I don't remember any other questions about the

11 observation post.

12 JUDGE ROBINSON: Well, it seems we have two issues, one of

13 translation and one more substantive.

14 Mr. Tapuskovic?

15 MR. TAPUSKOVIC: [Interpretation] Your Honours, one thing you

16 should bear in mind when you deliberate, what I'm trying to ask is about

17 the question because the OTP asked about indirect firing and information

18 on indirect firing by shells, and that if any information obtained from

19 him could be used on other targets, something along these lines, an

20 interesting question by the OTP. Whether the observation post could get

21 information about indirect firing, along these lines I think it is highly

22 appropriate for me to deal with this. Could he give any sort of

23 information for indirect firing?

24 [Trial Chamber confers]

25 JUDGE ROBINSON: I'm going to ask the witness, Mr. Maunaga, what

Page 6531

1 could you see from the observation post?

2 THE WITNESS: [Interpretation] I could see Mojmilo hill, Dobrinja,

3 the settlement known as Dobrinja, the buildings more to the front only. I

4 could see the airport, Donji Kotarac, the beginning of Butmir, Sokolovic

5 Kolonija, Hrasnica and Igman.

6 JUDGE ROBINSON: Yes. Mr. Tapuskovic?

7 MR. TAPUSKOVIC: [Interpretation] Thank you.

8 Q. Mr. Maunaga, could you provide any sort of information, given your

9 location, that could be used for indirect firing at targets? Talking

10 about the centre of town, the downtown area, the city itself, whichever

11 you like.

12 A. No, I was certainly in no position to do that.

13 Q. What about the radio device you were using? Did that device make

14 it possible for you to retrieve information?

15 A. No. We hardly ever used radio communications. It was only once

16 when the phone lines were disrupted.

17 Q. I'm not sure if I will be allowed this next question but it's

18 about this: Did you hear anything about what the Sarajevo media were

19 saying about how somebody from the positions held by the army of Republika

20 Srpska was firing at targets inside the city itself?

21 MR. DOCHERTY: I object to that question as beyond the scope of

22 cross-examination.

23 JUDGE ROBINSON: Yes. Not allowed.

24 MR. TAPUSKOVIC: [Interpretation] Thank you. I have no more

25 questions.

Page 6532

1 [Trial Chamber confers]

2 JUDGE ROBINSON: Mr. Maunaga, you did receive very serious

3 injuries during the conflict.

4 THE WITNESS: [Interpretation] That's true.

5 JUDGE ROBINSON: What is the state of your health now?

6 THE WITNESS: [Interpretation] I'm handicapped. I'm an invalid. I

7 have health problems with my stomach and with my arm.

8 JUDGE ROBINSON: Well, the Chamber sympathises with you and we

9 wish you good health.

10 Your evidence has been concluded. We thank you for coming to the

11 Tribunal to give it, and you may now leave.

12 THE WITNESS: [Interpretation] I wish to thank the Presiding Judge

13 and the Chamber for your patience and your trust in me as a witness.

14 [The witness withdrew]

15 JUDGE ROBINSON: The next witness, Mr. Tapuskovic?

16 MR. TAPUSKOVIC: [Interpretation] Your Honours, our next witness is

17 Goran Kovacevic, but before he's brought in, if we could please deal with

18 a number of procedural matters that will be raised by my colleague? It's

19 about some documents, if we may.


21 MS. ISAILOVIC: [Interpretation] Thank you very much, Your Honour.

22 I would like to talk about some documents that were filed as ID

23 documents, documents that were filed and that obtained an identification

24 number because there was no translation. Those documents are translated

25 now and this is why -- or, rather, I would like to rectify something.

Page 6533

1 Some documents are translated. One document that had obtained an ID

2 number, D00206, that document had obtained an identification number

3 because it did not have a translation, but I would like to ask if this

4 document could be filed as evidence, as Defence evidence.

5 JUDGE ROBINSON: What is it?

6 MS. ISAILOVIC: [Interpretation] Excuse me. I gave the number

7 right. D00260.

8 MR. WAESPI: Yes. I just see from the entry that it's a combat

9 report dated 20th June 1995 by ABiH Brigadier Fikret Prevljak, and I need

10 to see the exhibit. If the only issue was translation, then we don't have

11 an objection to the admission of this document.

12 [Trial Chamber confers]

13 JUDGE ROBINSON: Yes. That was the issue, translation. We admit

14 it.

15 THE REGISTRAR: Your Honours, the document marked for

16 identification as D206 becomes Exhibit D206.

17 MS. ISAILOVIC: [Interpretation] I would also like to mention that

18 with regard to the documents that are already admitted as Defence

19 exhibits, such as D82, D83 and D160, as well as D69, these documents were

20 also not translated, but we have now received the translation of these

21 documents and those translations are in the e-court system. They are

22 entered into the e-court system. Thank you.

23 [Trial Chamber confers]

24 JUDGE ROBINSON: Ms. Isailovic, we will just do a little check to

25 ensure that translation was the issue, and a little later on, we'll give

Page 6534

1 the decision.

2 MS. ISAILOVIC: [Interpretation] Your Honour, once again, I do not

3 know if I was clear. The last four documents that I mentioned, these

4 documents are already admitted as evidence. They were already admitted

5 into evidence, but we are requesting that you take knowledge of the fact

6 that the translation is entered into e-court.

7 JUDGE ROBINSON: Very well. Yes. So they are already exhibited.

8 MS. ISAILOVIC: [Interpretation] That's correct, Your Honour.

9 JUDGE ROBINSON: The next witness is Mr. Goran Kovacevic.

10 [The witness entered court]

11 JUDGE ROBINSON: Let the witness make the declaration.

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

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


15 [Witness answered through interpreter]

16 JUDGE ROBINSON: You may sit.

17 You may begin, Mr. Tapuskovic.

18 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honour.

19 Examination by Mr. Tapuskovic:

20 Q. Please state your first and last name.

21 A. My name is Goran Kovacevic.

22 Q. Mr. Kovacevic, I would like to ask you to speak slowly and to pay

23 attention to the cursor on the screen, because once it has stopped it

24 means that the interpretation of my question had been completed. And if

25 you pause, it will make us move more efficiently through the examination.

Page 6535

1 Mr. Kovacevic, you were born on the 9th of December 1964.

2 A. Yes.

3 Q. You were born in Sarajevo, in the part which at that time was

4 called Rajlovac.

5 A. Yes.

6 Q. You completed your elementary and high school in Sarajevo.

7 A. Yes.

8 Q. You worked at the Pretis factory in Vogosca until the outbreak of

9 the conflict; is that correct?

10 A. Yes.

11 Q. First of all, could you explain to the Chamber which is the high

12 school you completed? That's the first thing.

13 A. It was a vocational school for an explosives technician.

14 Q. When did you start working with that factory? Or, rather, ever

15 since you completed your education, you were employed with the factory; is

16 that true?

17 A. I began working at the factory in 1972. I worked until the 4th of

18 April 1992.

19 THE INTERPRETER: Interpreter's correction: I began working at

20 the factory in 1982.

21 MR. TAPUSKOVIC: [Interpretation] Now we have the correct version

22 in the transcript.

23 Q. Throughout that period, you produced what?

24 A. We were not producing anything but, rather, assembling mines and

25 explosives for the need of the Yugoslav People's Army and for export.

Page 6536

1 Q. You told us when you stopped working. Prior to that, who were the

2 people working in the factory? And first and foremost, I wanted to know

3 something about the workers there.

4 A. If you mean whether there were civilians or military personnel

5 because it was a purpose industry, I would tell you that we were all

6 civilian. There were no military people there. It was just a factory

7 that produced for the needs of the Ministry of Defence.

8 Q. How many workers did the factory employ before the war?

9 A. The entire factory, which was split into several sectors, there

10 were 5.000 to 6.000 people. In the purpose part, which had to do with

11 assembly, some 900 to 1.000 people.

12 Q. In peacetime, where did the products go?

13 A. As I said, it was used by the Yugoslav People's Army, and,

14 pursuant to certain contracts concluded by the Ministry of Defence, for

15 export throughout the world.

16 Q. Can you tell us about any distribution in the former republics,

17 when it comes to the former Yugoslavia or, rather, the SFRY?

18 A. As I said, the factory was directly controlled by the Ministry of

19 Defence and they distributed the products according to their needs.

20 Therefore, I guess the products went to all of the republics, to various

21 storage locations.

22 Q. Can you tell me who the people were who were in charge of certain

23 areas? Who were the people organising things in the factory at the time?

24 A. If you mean the managing staff, those were mainly chemical

25 engineers, ballistics experts, from the civilian sector. Even those who

Page 6537

1 represented the Ministry of Defence during various controls and to take

2 over the products were civilians; that is, the military control sent by

3 the Ministry of Defence also comprised civilians alone.

4 JUDGE ROBINSON: Mr. Tapuskovic, it's time for the break.

5 --- Recess taken at 12.21 p.m.

6 --- On resuming at 12.44 p.m.

7 JUDGE ROBINSON: Please continue, Mr. Tapuskovic.

8 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honour.

9 Q. Mr. Kovacevic, before the break you told us a few things. Among

10 others, you said that you worked in the factory until the 4th of April

11 1992. What happened then?

12 A. On that day, the 4th of April 1992, I came to work as usual.

13 However, since there was an incident in the centre of town in front of the

14 government building and the Holiday Inn, many workers failed to appear.

15 We went to the factory restaurant and one of the managers came from the

16 purpose part of the factory and he told us that we were to go home. He

17 also told us that they would call us when it would be necessary for us to

18 return to work. And from that moment on, I didn't go to the factory.

19 If I may --

20 Q. Just a second. After that day, you didn't enter the factory; is

21 that correct?

22 A. Not as a worker.

23 Q. What happened during that day after the workers had left?

24 A. We went home and waited for someone to call us. The manager told

25 us that it would be broadcast via the media when the workers were supposed

Page 6538

1 to return to their work posts. However, six or seven days passed. In the

2 meantime the Special Police forces of the MUP of Bosnia-Herzegovina

3 entered the premises or, rather, a part of the Special Forces, because by

4 that time the police had already split into the Muslim and the Serb part.

5 Q. Thank you. Which part of the police entered the Pretis factory?

6 A. The Pretis factory, well, the Muslim part of the police entered

7 the factory. They were commanded by Dragan Vikic.

8 Q. What happened?

9 A. What happened was that early in the morning, they went through the

10 cargo entrance of the factory. They secured that part of the factory,

11 entered it with some trucks, and took away mines and explosives. We don't

12 know what the quantity was.

13 Q. Can you tell us what type of mines and explosives were there in

14 the factory, considering its production?

15 A. The factory had its own warehouses, temporary warehouses, which

16 were never completely full because one batch would leave as another would

17 come in. It would either be sent to the army or for export. You could

18 find all types of products there, everything we produced, classical

19 weaponry, 57 millimetres up to 152 millimetres.

20 As concerns the missile programme, we had 90-millimetre anti-tank

21 rockets, Osa 1 and Osa 2; then we had 128-millimetre rockets called Plamen

22 A, fire A; then 128-millimetre rocket-type Oganj. All those were in the

23 warehouses. On top of that, we also produced parts for Orkan. It was not

24 a part of the serial production. And we also produced aircraft bombs.

25 Q. Thank you. It was early in the morning. What happened then?

Page 6539

1 Where did the trucks go to?

2 A. They went towards the city.

3 MR. TAPUSKOVIC: [Interpretation] Your Honours, I didn't follow the

4 transcript. I think the witness said aircraft bombs FAB and that is not

5 to be found in the transcript.

6 JUDGE ROBINSON: Aircraft bombs FAP, F-A-P? F-A-P or F-A-B?

7 MR. TAPUSKOVIC: [Interpretation] B, F-A-B. Your Honours, that

8 wasn't entered into the transcript. I know that this is difficult work

9 for interpreters because of the speed - and we are to be blamed for that -

10 but when we were double-checking the transcript a while ago, we saw that

11 some things were missing. It is impossible for us to react at any given

12 moment to all the omissions. For example, this to us was an important

13 matter and I had no time to pay attention to it.

14 In any case, I will try to speak as slowly as possible and I will

15 ask the witness to pay attention, particularly when mentioning numbers, to

16 the screen so as to see whether everything has been entered.

17 JUDGE ROBINSON: Mr. Tapuskovic, you should know that the

18 transcript is routinely corrected. Are you aware of that?

19 MR. TAPUSKOVIC: [Interpretation] Yes, I am. But during

20 examination, it creates confusion. I know that it is difficult and that

21 it is revised later. Thank you. Let us proceed slowly.

22 Q. It was in the morning of that day. Did anything else happen that

23 day?

24 A. Yes. That day --

25 Q. Just a second. It seems that Judge Harhoff has a question.

Page 6540

1 JUDGE HARHOFF: Yes, because I didn't fully understand whether the

2 Muslim part of the police took away only mines and explosives or whether

3 they also took all the weaponry that was present in the warehouses.

4 THE WITNESS: [Interpretation] In the Pretis factory, there was no

5 weaponry, only mines, explosives and ammunition.

6 JUDGE HARHOFF: But I thought -- I'm just checking the transcript

7 now, but I thought you just told us a while ago that there were all sorts

8 of interesting things in the warehouses. You said that there were all

9 types of products there, "everything we produced, classical weaponry, 57

10 millimetres up to 152 millimetres." And some "90-millimetre anti-tank

11 rockets, Osa 1 and Osa 2; then we also had 128-millimetre rockets called

12 Plamen," and so on and so forth. All of this, was that also taken by the

13 Muslim police?

14 MR. TAPUSKOVIC: [Interpretation] Your Honour, Judge Harhoff, this

15 is what I was talking about a moment ago. In my language, he was crystal

16 clear that there was only ammunition produced, that there was no

17 weaponry. You can see for yourself what sort of confusion it can create.

18 He was talking about the fact that they produced ammunition for those

19 types of weaponry, and in the transcript one gathers that the very pieces

20 were there. But this is all ammunition for such weapons. This is the

21 type of misunderstanding we can have. And in the end we would end up with

22 a transcript which would state that there was weaponry of all sorts and

23 kinds there. But this was a factory that produced ammunition for weapons.

24 The only thing that was taken away was ammunition.

25 JUDGE HARHOFF: And all of the ammunition was taken away? That

Page 6541

1 was my question.

2 Witness, was everything emptied from the Pretis factory, including

3 what was to be found in the warehouses?

4 THE WITNESS: [Interpretation] As I said a moment ago, I don't know

5 what the quantity was. I didn't do the inventory. I don't know about any

6 quantities. Perhaps a part of it was taken away or -- in any case, I

7 don't know how much.

8 MR. TAPUSKOVIC: [Interpretation]

9 Q. How far is your house from the factory?

10 A. Three to 4 kilometres away.

11 Q. The things you just said, could you observe that yourself or was

12 it in your settlement? In any case, how did people know about that?

13 A. Well, it is like this: Since it was early in the morning, no one

14 would have known about it. However, after the incursion of the Special

15 Police and after they took away the mines and explosives and ammunition,

16 and then the local Green Berets from Kobilja Glava entered the factory,

17 trying to do the very same thing. But by that time the factory security

18 managed to reorganise and a skirmish ensued. There were wounded.

19 The first time there were two incursions by the Special Forces and

20 the third incursion was an attempt by some armed civilians. The security

21 forces prevented them. One could hear a fire exchange and a few hours

22 later I went to the factory. That's how I found out. I learned that from

23 my co-workers who worked in the security part of the factory.

24 Q. Do you know who the victims were? You said that there was an

25 exchange of fire?

Page 6542

1 A. With our security force, there were no casualties. I think there

2 were some wounded, though; I saw it on TV three or four days later. I saw

3 some wounded lads in the Kosevo Hospital. I don't know what their names

4 are but there are recordings. It was in the media.

5 Q. Perhaps you could explain something else to me, but first I need

6 to show you a map and we'll try to depict that for the Judges.

7 MR. TAPUSKOVIC: [Interpretation] Could we please show a 65 ter

8 document, 02829. It is an UNPROFOR map.

9 Q. While we are waiting, can you tell the Judges who Vikic was at the

10 time and what he became afterwards.

11 A. Mr. Dragan Vikic at the time, and later as well, was a commander

12 of the Special Police unit of Bosnia-Herzegovina.

13 Q. What kind of operations did they take part in?

14 A. It is well known what special military or police units are

15 expected to do. In our case, they took part in these riots or sabotage

16 actions and things like that, as far as I knew. But I came across them

17 during the war.

18 Q. Was MUP involved in combat actions as well?

19 MS. EDGERTON: Your Honours?


21 MS. EDGERTON: With respect, and I haven't risen to this point,

22 but with respect that goes far, far away from anything set out in this

23 witness's 65 ter summary.

24 JUDGE ROBINSON: Mr. Tapuskovic?

25 MR. TAPUSKOVIC: [Interpretation] Your Honours, this was a strictly

Page 6543

1 and explicitly cited incident which bears enormous significance for the

2 army -- for the arming of the army, and it is also strictly mentioned in

3 the summary relating to this witness, and he's talking about the things

4 that deserve your attention.

5 Perhaps this last question, but before that I don't see -- this

6 incursion into the factory by special MUP units and the seizure of weapons

7 was something mentioned in the summary, as something that this witness is

8 going to talk about, and I don't see anything inappropriate in relation to

9 the issue we are facing, especially since he mentioned that there were air

10 bombs that may have been taken on that occasion, among other things.

11 MS. EDGERTON: And it was --

12 JUDGE ROBINSON: You want to be heard again, Ms. Edgerton?

13 MS. EDGERTON: It was in fact the very last question I had risen

14 on, whether or not the MUP was involved in combat actions.

15 JUDGE ROBINSON: Yes, but I'll allow the question.

16 Proceed.

17 MR. TAPUSKOVIC: [Interpretation]

18 Q. Mr. Maunaga, the President allowed this question to be asked.

19 A. My name is Kovacevic, not Maunaga.

20 Q. My apologies. I am a bit senile.

21 A. Throughout the war, MUP was directly involved in the conflict.

22 Q. Thank you. That will be enough.

23 Now, after that incident, the shooting, the seizure of weapons,

24 what happened next? Can you first please show us your house, Vogosca and

25 the factory.

Page 6544

1 A. This is Vogosca. The factory was --

2 Q. You have to put a mark on the map, please, and this will be saved.

3 A. Yes. The factory is here.

4 Q. I think it's better -- it will be better if you put a circle.

5 A. And this is where my house is.

6 Q. So, please, what happened after these incidents that you have just

7 described, the ones that took place in early April? What did you do?

8 What did other people do? Can you tell us what happened next?

9 A. That was in April. In April, people used to pass through my

10 neighbourhood, expelled from Buca Potok.

11 THE INTERPRETER: Could the witness please slowly give the names

12 of the families.

13 MR. TAPUSKOVIC: [Interpretation]

14 Q. Could you first please slowly give the names of the family that

15 had been expelled or left Buca Potok, after you have shown us where this

16 Buca Potok is.

17 A. This is Buca Potok, and the families who fled in April or were

18 expelled from Buca Potok - as far as I know, there were many families -

19 were Odzakovic, Zivkovic, Rakic, Stevanovic. I know about the Stevanovic

20 family. There were two brothers. One of them was injured on that

21 occasion and the other was killed. His name was Milojica Stevanovic and

22 the wounded one was Negos. They all passed through my neighbourhood over

23 the Zuc plateau because that was the only escape route for them.

24 Q. Can you please draw a line along that route.

25 A. [Marks].

Page 6545

1 Q. What did they tell you?

2 A. They told me that the attack had occurred sometime in the morning,

3 as far as I remember. There was a brief skirmish. Given the fact that

4 the Serb families in the area were heavily outnumbered, there were

5 casualties and there were wounded persons. Those who managed to get

6 across the Zuc plateau escaped. As for those who didn't, I really don't

7 know what became of them.

8 Q. Can you please give us a brief and swift account of what happened

9 in May?

10 A. In May 1992, I think early in May, around the 10th of May, the

11 army of Republika Srpska was established.

12 Q. What did you do?

13 A. At the time, meaning throughout May, the barracks in the centre of

14 Sarajevo remained blocked, under siege. An agreement had been reached for

15 the military to leave Bosnia-Herzegovina by the 19th of May 1992. This

16 agreement was complied with. All the town centre barracks, the Marshal

17 Tito barracks, the Viktor Bubanj barracks, the Jusuf Dzonlic barracks, the

18 Jajce barracks, and the command of the 7th Military District at Bistrik,

19 all those were surrendered to the Muslim side.

20 Q. What did you do in those circumstances?

21 A. In my neighbourhood, people started organising themselves under

22 the control of the Territorial Defence Staff. The Rajlovac barracks was

23 being transferred to its eventual destination. They were moving out. So

24 we set up units; rather, the TO staff organised units, armed fighters,

25 using the weapons left over after the JNA had evacuated the Rajlovac

Page 6546

1 barracks.

2 And if I may just finish this, this was a training centre for JNA

3 air forces -- air force. There were no heavy weapons being kept there.

4 Those were just the sort of planes, model planes, used for training and

5 anti-aircraft guns of very small calibre. There were no heavy weapons.

6 If there had been any, the military would have taken it away with them.

7 Q. However, let me ask you something else. After you had organised

8 yourselves, were there any weapons left behind by the JNA outside these

9 barracks in the area? Did you see any other serious weapons?

10 A. I didn't myself. I was just an ordinary soldier at the time and I

11 had no information to indicate whether there were any such things lying

12 around. There was no need for me to know.

13 Q. So what did those people eventually do? Who were the fighters

14 belonging to those units in your own neighbourhood?

15 A. Those were just local residents. Just to clarify matters for both

16 you and the Chamber, this area was an ethnically Serb area. There were no

17 Muslims residing there; not within a 20-kilometre radius, in fact.

18 Therefore, those were locals. The fighters along the front lines were

19 actually standing in front of their own homes, as it were.

20 Q. Before I seek additional explanations about what went on in June,

21 can you just tell us how many people from Buca Potok went on to those

22 places that you indicated? And do you know what was going on in Pofalici

23 in relation to this?

24 A. People were leaving every day. Nobody knows exactly how many

25 people. This was when the clashes first started and it was still possible

Page 6547

1 to leave the area through the woods, across the Zuc plateau. This area,

2 it's woodlands basically and people kept leaving every day. The previous

3 example that I gave you was because of the attack, because of the

4 clashes. But later on, even when there were no clashes, people were

5 leaving the area. They were feeling unsafe.

6 You're asking me about Pofalici. It was sometime in mid-May, the

7 15th or the 16th, that Pofalici was attacked. I believe, well, based on

8 my recollection, this was several days after the Marshal Tito barracks had

9 been evacuated. Straight after that Pofalici was evacuated, and this was

10 a predominantly Serb settlement. However, they enjoyed the support of

11 forces from the centre of town itself and they expelled the people living

12 there. I know about the specific cases where the families of some of my

13 friends were killed. One of them, Djordje Elek eventually found the bones

14 belonging to his parents, but Zoran Mikelic [as interpreted] never did.

15 Q. Fine. Thank you. What happened after all of this in June? What

16 happened in the area where you lived and where your neighbours lived? Did

17 any further clashes erupt after that, if you could please explain that for

18 us?

19 A. It's not Zoran Mikelic; it's Pikulic. And Djordje, his last name

20 is Elek. I did say it, didn't I? And now that I remember this, at the

21 beginning of my evidence, it said 1972 instead of 1982, when I started

22 working in that factory.

23 Q. Fine. Thank you very much. We've now set the record straight.

24 Can you tell us anything about June, please, anything to do with

25 the positions? Was there now a confrontation line there?

Page 6548

1 A. From the beginning of 1992 to June 1992, there was a large-scale

2 offensive on Zuc hill, which is where I was deployed at the time as a

3 soldier of the army of Republika Srpska. The offensive continued for two

4 days. On day 2, the morning of day 2, I myself was wounded and taken to

5 Pale, and then from Pale to Belgrade. Therefore, I can't tell you

6 anything about June.

7 Q. Where was it that you were wounded? Which part of your body, I

8 mean.

9 A. My stomach.

10 Q. Where did you go next? Which route did you take?

11 A. At the time, the then-not-international but now-international

12 Sarajevo airport was under the control of the Serb army. I crossed the

13 runway to Lukavica and then from there to Pale and then from Pale by

14 helicopter on to Belgrade. When I returned --

15 Q. Just a minute, please. How long did you stay in hospital for?

16 A. My treatment officially ended on the 8th of August 1992.

17 Q. All right. So how did you go back?

18 A. I went back through the hills above Sarajevo and not across the

19 runway. The runway had been surrendered to UNPROFOR by this time. So I

20 went back through Pale, through the mountains, through Visevice, Sedrenik,

21 Vogosca, Rajlovac.

22 Q. Were there any problems when you eventually reached your home?

23 A. No, not at the time. But when I went to Sokolac for medical

24 check-ups, I had to take a different route - Pretis, Poljine.

25 Q. If you could please just draw a rough line on the map to indicate

Page 6549

1 the route.

2 A. It was like this.

3 Q. That's fine. That's fine. All right. Any problems?

4 A. Well, this route was under fire permanently because it was near

5 the confrontation lines.

6 Q. Right. Thank you. All right. You arrived on the 8th of August.

7 Can you please draw the confrontation line separating the army of

8 Republika Srpska on the one hand and the BH army on the other? And I'm

9 referring to your own area, the area in which you lived.

10 A. At the time the confrontation line ran like this.

11 Q. Just a minute, please. What time are you talking about, after

12 you'd left or once you returned?

13 A. Both. The confrontation line remained until the 12th of June

14 1993.

15 Q. Thank you. All right. As of 12th of June 1993, where was it?

16 A. Just the way it's drawn, the red and yellow lines. They didn't

17 budge until the end of the war.

18 Q. And what were you at the time?

19 A. I was -- I was a platoon commander.

20 Q. Can you indicate the place along these confrontation lines drawn

21 there in red and yellow, as you say, where your platoon was positioned.

22 A. [Marks].

23 Q. Can you please put the letter S over that section of the line.

24 A. [Marks].

25 Q. Can you mark the location of your house with the letter K.

Page 6550

1 A. [Marks].

2 Q. Can you mark the location of the Pretis factory with a letter L.

3 A. [Marks].

4 Q. Can you please mark Buca Potok with the letter B.

5 A. [Marks].

6 Q. And then the line from Buca Potok to your house with the letter

7 M.

8 A. [Marks].

9 Q. And then the blue area with a W.

10 A. [Marks].

11 Q. All right. Who was the commander of your company?

12 A. Mr. Sinisa Krsman.

13 Q. All right. Now, show me and mark for me - use a different

14 colour - the positions along this confrontation line held at the time by

15 soldiers belonging to that company.

16 A. [Marks].

17 Q. Yet another line, right next to it, to mark the area held by the

18 battalion, the battalion that the platoon and companies were subordinated

19 to, naturally.

20 A. [Marks].

21 Q. What about towards Vogosca?

22 A. [Marks].

23 Q. All right. The positions that you held -- geographically, there

24 is no other way for me to ask this question. What was your position in

25 relation to the places held at the time by the BH army?

Page 6551

1 A. It was like this: In the area of responsibility of my platoon,

2 this is a mountainous area, woodlands mostly. You can see Zuc hill, a

3 wooded area; that was on my side. And then this line that I marked here,

4 which remained until June 1993, that's in a river valley, and in 1993, it

5 shifted back by about 500 metres. And there was a hill there called

6 Sokolje, which is a continuation, so to speak, of Zuc. It shows that one

7 hill and some houses on the slopes of Sokolje and those were the last

8 houses this side of the hill. And then the confrontation line continued

9 on to the road in Rajlovac.

10 Q. Can you please draw that for us.

11 A. This is the road, the highway, and above it is Sokolje hill, which

12 sort of encloses the entire area. And then when the confrontation line

13 went through the barracks, it went underneath the railroad track, while

14 above it there was the highway, the motor road, at a higher altitude. And

15 then the whole settlement, Bielsko Brdo, sort of rises in terms of

16 altitude from the barracks, our line through the barracks and Rajlovac,

17 through the field, through the field. So each and every point was larger

18 in relation to our lines or our positions.

19 Q. Points? What points are you talking about?

20 A. All of our points were lower down in relation to those occupied by

21 the Muslim army, which later became the army of the Republic of Bosnia and

22 Herzegovina.

23 Q. All right. Just tell me, what exactly could you see from there,

24 from all those positions along the red line, the ones occupied by your

25 battalion throughout the war?

Page 6552

1 A. The line was established back in 1993 and remained throughout the

2 best part of the war. So from my area of responsibility, I saw Zuc hill,

3 Sokolje hill and the wood behind us, as well as the trenches of the Muslim

4 units across the way from us, needless to say. Much in the same way, from

5 the area of responsibility of the battalion, you could see the front row

6 of houses on the slopes and their transfer places.

7 Q. Can you please describe briefly how the combat operations looked.

8 MR. TAPUSKOVIC: [Interpretation] He was talking about trenches and

9 it says "transfer" on the record, "transfer place." And he was talking

10 about trenches.

11 Q. Right? Trenches?

12 A. Yes.

13 Q. I mean --

14 JUDGE ROBINSON: Trenches.

15 MR. TAPUSKOVIC: [Interpretation]

16 Q. How far were your trenches from their trenches?

17 A. Depending on the terrain, the distance was normally between 100

18 metres and 200 or 300 metres in certain places, but it all depended on the

19 lie of the land. Along my own line, the distance was about 100 to 120

20 metres.

21 Q. Across the positions, what exactly could you see?

22 A. Just the hill and the woods.

23 Q. Do you know when General Dragomir Milosevic became commander of

24 the Sarajevo-Romanija Corps?

25 A. I'd be at a loss for the exact date. I know it was late summer,

Page 6553

1 possibly early autumn. I think late summer 1994.

2 Q. How would you describe the period after he became commander, in

3 terms of any combat operations going on?

4 A. Generally speaking, as far as 1994 is concerned, I can say this:

5 Following the withdrawal of heavy weapons, there had been an agreement

6 about that. Sometime in February 1994, a cease-fire took effect and it

7 was complied with until the end of that year, winter, possibly October,

8 when an offensive was launched at the Nisic plateau. As a rule, there

9 would be active provocation along our confrontation lines around Rajlovac

10 after that, although we did go and help out with certain parts of the

11 Nisic front at the Nisic plateau.

12 Q. When did that stop?

13 A. I think the offensive was first launched in October and ground to

14 a halt by the end of December, I'd say, with small interruptions, brief

15 interruptions. It went on for two months. It was sometime in December.

16 I can't remember if a truce was signed or anything like that, but it did

17 go on until nearly mid-1995.

18 Q. Sir, Krsman, he was your superior commander; right?

19 A. Yes.

20 Q. What sort of orders would you normally get from him in your

21 capacity as platoon commander?

22 A. The orders normally came down to routine matters. There was no

23 need to emphasise that one should be careful using up ammunition, although

24 from our positions we couldn't really fire all that much. We didn't have

25 a clear line of sight to begin with. It was only if we came under an

Page 6554

1 attack and then we would fire back.

2 Q. What if you realised that there was some sort of danger?

3 A. It was exactly that type of situation that he addressed. He told

4 us that it was only in this type of situation that we should start firing,

5 when regrouping or, for example, if our positions came under attack or,

6 for example, if we realised that the enemy was bringing in fresh forces.

7 These were the only situations he said in which we should go into action.

8 There were examples like that in my part of the front.

9 Q. Would you always wait for them to start firing first, or given the

10 manoeuvres that were going on all the time, did you sometimes do things

11 yourselves?

12 A. No, no. Most certainly not. We observed their activities and

13 whenever we realised that they were about to do something, we would open

14 fire.

15 Q. All right. A cease-fire has now been agreed. Do you get any

16 orders from Krsman regarding that?

17 A. The orders were passed along orally. He would tour the line and

18 then platoon commanders would meet, company commanders, and he would

19 convey these orders to us orally, to be careful about unnecessary waste of

20 ammunition, not to fire without an order, even when provoked.

21 Q. I would like to show you a Defence document. It has been admitted

22 already. It's D214.

23 MR. TAPUSKOVIC: [Interpretation] Yes, yes, please. Your Honours,

24 could this map be saved the way it is?

25 JUDGE ROBINSON: Yes. Can it be saved?

Page 6555

1 MR. TAPUSKOVIC: [Interpretation] Defence exhibit.

2 JUDGE ROBINSON: An exhibit, yes.

3 THE REGISTRAR: Your Honours, this will be admitted as Exhibit

4 D226.

5 MR. TAPUSKOVIC: [Interpretation] Can we please have 214, D214,

6 brought up for the witness.

7 Q. Look at the date, please. Can you tell us what it is and can you

8 please tell us what the document is about? Please pay close attention to

9 paragraph 4. And is that the same thing that Sinisa Krsman told you?

10 A. This is exactly what I was talking about. He told me not to open

11 fire unless there was a surprise attack, and in any other situation, when

12 we deemed it necessary to open fire, we should first seek approval from

13 the operations centre of the brigade command. That's exactly what it

14 says.

15 Q. Thank you. Can you describe what the situation was like after

16 December and how long the situation continued for, the one that you

17 described.

18 A. After December, as I said, probably some sort of a cease-fire had

19 been agreed and it literally looked like a cease-fire until sometime in

20 mid-May when all these acts of provocation started, and when we, the

21 soldiers along the front line, started learning about this. At the time,

22 I must say a lot of Serbs managed to leave town. They used their

23 connections; they escaped across the lines.

24 So we had received information to indicate that the BH army was

25 about to launch a full-on offensive, a large-scale offensive. We found

Page 6556

1 out about this sometime in May and then it wasn't before mid-June - I

2 think the 15th or the 16th - that a veritable offensive got off the

3 ground, I think all along the front line, well, certainly along my part,

4 but I know it was all along the front line, all positions.

5 Q. But as long as the cease-fire was still on - and we have to finish

6 in several minutes - can you explain about the areas in which you were

7 moving at the time? What exactly was the situation regarding fuel,

8 electricity?

9 A. It wasn't just about that period. This is something that I forgot

10 to say earlier on. In addition to these clashes, the whole war, with the

11 exception of when the power lines, for example, were destroyed during the

12 fighting, the supply never ceased. There was a power station in Rajlovci

13 that supplied electricity to the city and the areas under Serb control.

14 There was the Sarajevo gas station and they could open the supply

15 line or cut off the supplies, but this normally didn't happen because

16 those were all under UNPROFOR control. And then there were the centre

17 warehouses of humanitarian aid for the entire Sarajevo area, and this all

18 ran smoothly.

19 Q. Humanitarian aid warehouses for Serbs and Bosniaks, Muslims, alike

20 was in Rajlovac; right?

21 A. Yes, that's right.

22 Q. Did it reach its destination?

23 A. Why not? Drivers would pick up shipments at the warehouse; they

24 would load it on to their vehicles and drive it into town.

25 Q. What about in the middle of combat, when the power lines were

Page 6557

1 destroyed? What happened then?

2 A. I remember this one particular cease-fire. The power lines

3 collapsed on Zuc hill, from artillery fire, so - and they had probably

4 agreed about this - people from the Muslim part of Sarajevo came to fix

5 it, experts, and they worked with our experts to fix the power lines

6 there. And this was sometime late in 1992, the cease-fire that I'm

7 talking about.

8 MR. TAPUSKOVIC: [Interpretation] Your Honours, I think we are

9 approaching the end of today's session.

10 JUDGE ROBINSON: All right. We will adjourn until tomorrow.

11 --- Whereupon the hearing adjourned at 1.44 p.m.,

12 to be reconvened on Wednesday, the 13th day of

13 June, 2007, at 9.00 a.m.