1 Tuesday, 24 July 2007

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.02 a.m.

5 JUDGE ROBINSON: Mr. Tapuskovic, I understand you have a matter or

6 some matters to raise.

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

8 Yes, I do have two matters that I want to deal with.

9 The first is something that pertains to witness T-19. We sought

10 protective measures for him, and pursuant to your decision those measures

11 were approved. Now that the witness is about to appear in court he would

12 like to give evidence without any protective measures. So first the thing

13 I would like you to do before he comes in the courtroom, I would like to

14 ask you whether you are prepared to approve this change; and the second

15 matter pertains to the evidence of other witnesses to be heard.

16 Witness T-60 is already in The Hague. He is due to be examined

17 tomorrow. He arrived last night and I will be proofing him for his

18 testimony, but the last two witnesses T-57 and T-25, will be arriving

19 tomorrow evening around 9.00 p.m.. You know that there is a rule in place

20 to protect the witnesses. The witnesses cannot be proofed immediately

21 upon their arrival, but, if necessary, I can do the proofing by midnight

22 with those two witnesses. But I would like to ask you, if possible, to

23 hold the -- our session on Thursday, the 26th in the afternoon. I believe

24 that it would be possible because not many trials are going on. That

25 would enable me to proof my witnesses properly.

1 So these were two issues that I wanted to raise and to ask your

2 assistance on.

3 JUDGE ROBINSON: Well,, as for the first, trials are ordinarily

4 public, so we naturally would have no difficulty with that.

5 For the second, I will have to consult. But is there any

6 difficulty with the Prosecution?

7 MR. WAESPI: No, Mr. President.

8 [Trial Chamber confers]

9 JUDGE ROBINSON: Well, the Prosecution doesn't have a problem,

10 but, of course, Mr. Tapuskovic, this comes very late, and many persons

11 would have made arrangements for travel. But I have to ask you, how long

12 do you think this witness will be? The two witnesses.

13 MR. TAPUSKOVIC: [Interpretation] Two witnesses, yes, I have two

14 witnesses ready for today, and that should take us through the whole day.

15 JUDGE ROBINSON: No, no, I'm talking about Thursday afternoon.

16 Thursday afternoon when you're asking that we sit -- instead of sitting in

17 the morning. I'm trying to see whether we can accommodate you. So, in

18 that regard, I'm asking how long will the witnesses take?

19 MR. TAPUSKOVIC: [Interpretation] Under the circumstances, I will

20 try to take even less time that you have allotted to me so that we can

21 complete their evidence so that they don't have to come back.

22 I have a total of two and a half hours, I think.

23 JUDGE ROBINSON: For both witnesses?

24 MR. TAPUSKOVIC: [Interpretation] Or --

25 MS. EDGERTON: Your Honours, just looking at the time statement

1 that was circulated and if I'm not mistaken, we're talking about the two

2 witnesses for Thursday who would be T-25 and T-60. For T-25, there's an

3 hour and a quarter allotted for each party, and for T-60 an hour and a

4 half allotted for each party presently.

5 MR. TAPUSKOVIC: [Interpretation] No, no. Your Honours. My

6 learned colleague does not have all the information at her disposal.

7 Because Witness T-60 will be examined tomorrow and I have just one witness

8 for tomorrow, because the other two will be arriving later with -- due to

9 some extraordinary efforts put in by the Victims and Witnesses Unit, they

10 will be able to arrive tomorrow night. So, for Thursday I have witnesses

11 T-57 and T-25 lined up. I think one of them is due to testify for half an

12 hour and the another one for a bit longer. I think that we already have

13 this information, and I don't think that we will have any problems

14 finishing their evidence so that they don't have to appear before this

15 Trial Chamber again.

16 MS. EDGERTON: I stand corrected. That's correct. T-57 is

17 allotted half an hour for each party and T-25 an hour and a quarter for

18 each party.

19 JUDGE ROBINSON: So that makes three and a half hours.

20 MS. EDGERTON: At best, just under one full court day.

21 [Trial Chamber confers]

22 JUDGE ROBINSON: Mr. Tapuskovic, I believe we will have to stop at

23 6.00. So we'll have to try to conclude the testimony of both witnesses by

24 6.00 p.m.

25 Could we start earlier?

1 JUDGE HARHOFF: Is that okay?

2 MS. EDGERTON: Prosecution certainly available to start earlier.

3 JUDGE ROBINSON: Can we start earlier? What are the logistics

4 involved in starting earlier?

5 [Trial Chamber and registrar confer]

6 JUDGE ROBINSON: I understand there is a courtroom available.

7 JUDGE HARHOFF: I need 15 minutes.

8 JUDGE ROBINSON: The problem is that my colleague here, Judge

9 Harhoff, is -- he's in a case in the morning, so.

10 JUDGE HARHOFF: [Previous translation continues] ... For 15

11 minutes. But I need 15 minutes between the two.

12 [Trial Chamber confers]

13 JUDGE ROBINSON: All right. With a tremendous effort and worthy

14 effort on the part of Judge Harhoff, he has agreed that we can start at

15 2.00 p.m. So he will have a 15-minute break after the end of his first

16 trial.

17 MR. TAPUSKOVIC: [Interpretation] Thank you. I will endeavour to

18 complete my examination in even less time than allotted to me with the

19 exception, of course, of this witness who is due to give evidence for only

20 half an hour, that's T-57, half an hour. That's really the time that I

21 have to use as efficiently as is possible, and I will also try to use

22 all my time as efficiently as possible.

23 JUDGE ROBINSON: Very well. We will start at 2.00 p.m. on

24 Thursday and finish at 6.00.

25 Then let the witness be brought in.

1 [The witness entered court]

2 JUDGE ROBINSON: Let the witness make the declaration.

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

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

5 WITNESS: VLASTIMIR GLAVAS

6 [Witness testified through interpreter]

7 JUDGE ROBINSON: You may sit.

8 And you may begin, Mr. Tapuskovic.

9 Examination by Mr. Tapuskovic:

10 MR. TAPUSKOVIC: [Interpretation] Thank you once again, Your

11 Honours.

12 Q. Sir, you first have to state your full name to the Chamber, to the

13 Judges, to the Prosecution. And I would therefore like to devote the

14 first few questions to your background, your personal details.

15 Could you please tell the Judges your full name?

16 A. Yes. Vlastimir Glavas.

17 Q. You were born on the 20th of March, 1964?

18 A. Yes.

19 Q. In Hadzici, in the municipality of Sarajevo, in Donja Bioca?

20 A. Yes. Donja Bioca, municipality of Hadzici. That's one of the

21 municipalities in Sarajevo.

22 Q. You have to wait for me to complete my question fully and please

23 observe the cursor on your screen. When it stops, then you can start your

24 answer.

25 You completed your elementary education in Tarcin, Hadzici and

1 Sarajevo?

2 A. Yes.

3 Q. You graduated from the high school in Hadzici in Sarajevo?

4 A. Yes.

5 Q. At the time when the conflict broke out, you were a haulier, you

6 had your own private business?

7 A. Yes.

8 Q. At that time you lived in your family home in Hadzici, in

9 Donja Bioca?

10 A. Yes.

11 Q. I have to warn you once again. Please don't answer before you see

12 that the cursor has stopped, otherwise we're going to have problems. I

13 explained this to you yesterday during our proofing session.

14 Witness, could you please explain to the Judges what units were

15 you in at one point and when?

16 A. It was in late 1993. I was at Ilidza, in the Ilidza police

17 station.

18 Q. How many police officers were there in this police station?

19 A. There were 21 police officers in the station where I was.

20 Q. Sir, you must not start answering immediately when I complete my

21 question. You have to wait for five or six seconds before you start your

22 answer. You have to pay attention to this cursor, otherwise the

23 interpreters are going to be in trouble, the Defence is going to be in

24 trouble and so will the Chamber.

25 You said 21?

1 A. Yes.

2 Q. In what area is that?

3 A. Ilidza. Ilidza that was the reserve police station at Ilidza, my

4 station.

5 Q. You're going too fast again. Please focus on the screen in front

6 of you and don't start your answer before the cursor has stopped.

7 So did you know at all anything about the police units that were

8 there in various police units in the area of responsibility of the

9 Sarajevo-Romanija Corps?

10 A. Well, about four to 500 people in the area of the entire CSB

11 Sarajevo, the Security Services centre Sarajevo.

12 Q. And what kinds of duties did you have as a police officer when you

13 joined them in 1993?

14 A. After I was released from the Silos camp, I was in a very bad

15 shape. And after I recuperated a couple of months later, I joined this

16 station, where I mostly worked in the duty room, because I was not fit to

17 go to the line.

18 Q. Could you explain to the Judges how long did you spend in the camp

19 and why were you in such a bad shape at the time when you joined the unit?

20 MS. EDGERTON: Your Honours.

21 JUDGE ROBINSON: Yes, Ms. Edgerton.

22 MS. EDGERTON: I would submit that his time in detention in the

23 Silos camp and treatment there is irrelevant to this trial against

24 General Milosevic.

25 JUDGE ROBINSON: Would you explain how it is relevant, Mr.

1 Tapuskovic.

2 MR. TAPUSKOVIC: [Interpretation] I will be dealing with his stay

3 in the Silos camp later. He spent time there, and that pertains to the

4 very outbreak of the conflict, the reasons why he was arrested. The

5 circumstances in which the conflict broke out. I want to bring him to

6 this time. I knew that the Prosecution would be objecting. I wanted

7 first to bring him to the time-period relevant for the indictment. But

8 the Chamber always allowed me to deal with what was happening at the

9 outbreak of the conflict with other witnesses. This is very important for

10 this case, highly relevant, because it speaks to the suffering that those

11 people went through in those camps.

12 If the Chamber deems that to be irrelevant, then, I don't think

13 that I should have dealt with any other issues that pertain to the

14 outbreak of the conflict. If it is not irrelevant for -- to determine why

15 this man was placed under arrest, when he joined the forces to defend his

16 home and then was put in a camp for that reason --

17 JUDGE ROBINSON: [Previous translation continues] ... I would

18 think you can deal with the circumstances leading to his detention, but

19 his actual detention and what happened to him in detention I would think

20 is not particularly significant.

21 MR. TAPUSKOVIC: [Interpretation] Your Honour, I will be guided by

22 what you just said, but my next few questions will perhaps clarify this

23 matter.

24 Q. Sir, could you please describe to us what condition were you in,

25 why were you unable to join in any action at this time?

1 A. After seven months of detention in the Silos camp I weighed 40

2 kilos, and I had had 75 kilos at the beginning.

3 Q. Thank you. And what did you do at first in this police station?

4 A. I was a duty officer.

5 Q. And when were you able -- but first, tell me, this police force,

6 the 21 police officers, what did they do in the police station and in the

7 Ilidza area?

8 A. We did police work.

9 Q. And who was in charge, who was the head?

10 A. My immediate superior was Dragisa.

11 THE INTERPRETER: Interpreters did not catch the last name of the

12 superior.

13 MR. TAPUSKOVIC: [Interpretation]

14 Q. And when did you start joining --

15 JUDGE ROBINSON: Mr. Tapuskovic, the interpreter didn't hear the

16 last name of the superior. You said your immediate superior was Dragisa.

17 What's the last name?

18 THE WITNESS: [Interpretation] Dragisa.

19 JUDGE ROBINSON: Is there another name? Is that the only name?

20 THE WITNESS: [Interpretation] Kapetina. That's what I said.

21 MR. TAPUSKOVIC: [Interpretation]

22 Q. Sir, do you remember when Dragomir Milosevic became the commander

23 of the Sarajevo-Romanija Corps?

24 A. Yes. It was sometime in early August 1994.

25 Q. And in what combat actions of the Sarajevo-Romanija Corps did you

1 participate first?

2 A. That was on the Nisici plateau.

3 Q. When was it?

4 A. In late 1994, October/November, something like that.

5 Q. And your police unit that had 21 officers, under whose command was

6 it on such occasions?

7 A. We were part of the Ilidza Brigade.

8 Q. And could you tell us how many such events were there in

9 October/November and all the way to the end of the year that you

10 participated in?

11 A. Three, four, five clashes at the time.

12 Q. And in those clashes that you took part in, were there any

13 casualties, civilian or among the soldiers, in this area?

14 A. Yes. A colleague of mine, Nenad Kuvac was killed. And later on,

15 when he was buried he had been chained.

16 Q. Well, it's not quite clear. I didn't understand what you mean and

17 the Chamber cannot understand what you mean. Was he chained at the

18 position or what?

19 A. He was wounded and he was dragged away. And after a month, he was

20 exchanged, and then it was ascertained that his legs had been chained.

21 Q. You are mentioning the death of your colleague. But were there

22 any other victims among the soldiers or civilians at the time in Hadzici,

23 Nisici, Ilidza where you participated?

24 JUDGE ROBINSON: Yes, Ms. Edgerton.

25 MS. EDGERTON: So far, Your Honour, the witness has actually only

1 said he took part in actions at the Nisici plateau and he hasn't cited any

2 other locations. So perhaps the question could be rephrased so that the

3 answers could be properly founded.

4 JUDGE ROBINSON: Yes, Mr. Tapuskovic, reformulate.

5 MR. TAPUSKOVIC: [Interpretation]

6 Q. In addition to the conflicts and clashes at Nisici, since you were

7 present in Ilidza, were there any clashes in that period of time around

8 Hadzici and in Ilidza in particular, where you were a part of the -- of a

9 police station?

10 A. Yes. But I said at the start that I was assigned to the front

11 lines more rarely than others due to the condition I was in.

12 Q. This is precisely why I'm putting this question to you. Since you

13 spent more time in Ilidza and went to Nisici only rarely due to your

14 health condition, my question for you was whether in the fighting at

15 Nisici, Ilidza, and Hadzici there were any victims among soldiers, in

16 civilians, specifically in -- in the areas that were quite densely

17 populated.

18 A. Yes. At Ilidza and Hadzici, as these were areas that were under

19 daily shelling, there were quite a few victims among civilians.

20 Q. However, before we proceed to talk about the fighting, in the

21 time-period we have just referred to and in the subsequent period, when

22 did you take up arms for the first time and what were the circumstances

23 surrounding this event?

24 A. I took up arms for the first time before these clashes broke out.

25 The conflict in Hadzici began on the 10th and the 11th of May. I lived in

1 a village 12 kilometres away --

2 JUDGE ROBINSON: Ms. Edgerton.

3 MS. EDGERTON: I take it we're talking about 1992 now?

4 JUDGE ROBINSON: What time is this?

5 MR. TAPUSKOVIC: [Interpretation] Your Honours, we're speaking of

6 the early days of the conflict, of 1992. Unless we deal with these

7 matters none of the subsequent events can be understandable. I am in a

8 situation where I cannot at all begin to work as a Defence counsel --

9 JUDGE ROBINSON: I didn't understand -- I didn't understand

10 Ms. Edgerton to be objecting on that basis. She simply wanted to know the

11 time, the year. It's 1992, is it?

12 MR. TAPUSKOVIC: [Interpretation] Yes. We're talking about 1992.

13 JUDGE ROBINSON: Yes, well, proceed.

14 MR. TAPUSKOVIC: [Interpretation]

15 Q. Can you go on explaining what you've just started to explain

16 before you were interrupted.

17 What were the circumstances in which you first took up arms. You

18 mentioned a date, I believe, and it was quite evident which year you had

19 in mind.

20 A. I said that the conflict in Hadzici started already on the 10th or

21 11th of May.

22 Q. Which -- of which year?

23 A. 1992.

24 Q. Can you tell us, then, what prompted you to take up arms. What

25 happened?

1 A. Buses were passing through my village every day, holding members

2 of the Muslim army. They attacked the part of Hadzici held by the Serbs.

3 Q. Can you explain what the situation was in your village. Can you

4 be more specific, please.

5 JUDGE ROBINSON: Yes.

6 THE WITNESS: [Interpretation] Yes --

7 JUDGE ROBINSON: Just a minute.

8 MS. EDGERTON: Your Honour, I seem to be on my feet constantly on

9 matters of relevance but I'm rising again on the relevance of this portion

10 of the testimony. We had begun in 1994 leading into 1995 the period of

11 the indictment, but with respect, Your Honours, I would submit the reason

12 why somebody takes up arms in 1992 is irrelevant to the case against

13 General Milosevic.

14 JUDGE ROBINSON: Yes, Mr. Tapuskovic.

15 MR. TAPUSKOVIC: [Interpretation] This has been the situation so

16 far. When I started dealing with 1992, the Prosecution and in particular

17 my learned friend here from the Prosecution, would stand up and object

18 that this was not covered by the -- the case against Mr. Milosevic or,

19 that rather that I should also deal with the roots of it. Now that I'm

20 trying to deal with the roots of the conflict which led to the events

21 involving Mr. Milosevic, I'm being prevented from doing that as well.

22 I believe that I'm led to explain each and every time what the

23 relevance of my questions is all the time and I have been doing this. I

24 believe that the goal behind such an attitude of my learned friends is

25 simply to obstruct what I'm trying to get from the witness. Is it not

1 relevant to know what was going on in 1992, why he was arrested and how he

2 was treated as a prisoner? Then if it is not really relevant then I have

3 no place being here. I would be more than happy to have started dealing

4 with the 10th of August, 1994, rather than with anything else. But I'm

5 constantly being asked here --

6 JUDGE ROBINSON: Thank you.

7 [Trial Chamber confers]

8 JUDGE ROBINSON: Mr. Tapuskovic, you may continue with the

9 examination, but I must say that I find it strange that you would spend so

10 much time on contextual historical matters. In my view, the case is not

11 going to be determined on what happened in 1992. Move on to the period

12 that is relevant, most relevant to the indictment. So continue, but I

13 don't believe that your client is going to benefit from dwelling on these

14 contextual and historical matters.

15 MR. TAPUSKOVIC: [Interpretation] I'm not dealing with the

16 background of the case. I'm dealing with the fate this man has suffered.

17 Let me tell you something else.

18 JUDGE ROBINSON: Just continue.

19 MR. TAPUSKOVIC: [Interpretation] I wanted to deal with matters

20 that are relevant to this person without touching on any historical

21 matters.

22 JUDGE ROBINSON: Just get on with it.

23 MR. TAPUSKOVIC: [Interpretation] Of course, Your Honours. You can

24 even censure me in this, but have I the duty to pursue my Defence case in

25 the way I deem relevant and of course it will be up to you to decide

1 whether these matters were relevant or not. I believe that the fate that

2 has -- this man has suffered is quite relevant. If you believe that it is

3 out of place for me to do that, I am in your hands. If you believe that

4 I'm dealing with the historical background rather than with any relevant

5 matters, then I am in your hands to decide what I should do next.

6 JUDGE ROBINSON: I told you to carry on. Why don't you carry on

7 and stop arguing. Carry on.

8 MR. TAPUSKOVIC: [Interpretation]

9 Q. Can you tell me when you were engaging in the fighting on those

10 rare occasions when your health condition permitted you to, what kept you

11 going in all these actions?

12 A. What kept me going was the fear, the suffering and the hardship

13 that I experienced in the Silos camp. I wanted to make sure that I never

14 ended up in their hands again, in the hands of those that tortured me.

15 Q. At those moments, did you harbour any specific intentions with

16 regard to the civilians on the other side? This is as far as I can go in

17 putting this question to you.

18 A. I never, ever did anything to harm anyone. I wouldn't do so now.

19 I felt pity for the civilians of Muslim, Serb and Croat ethnicities of all

20 of them, regardless of their religious beliefs.

21 Q. Can you tell us what the circumstances leading to your arrest

22 were?

23 A. I was arrested because I wielded a rifle, and I had a rifle simply

24 to defend myself.

25 Q. And how long were you in captivity?

1 A. Seven months.

2 Q. Which camp was that?

3 A. The Silos camp at Tarcin.

4 Q. What happened to you at a certain point in time?

5 JUDGE ROBINSON: Mr. Tapuskovic, I have already ruled earlier that

6 I did not want to hear that. Move on to something else. You have led

7 evidence as to the circumstances leading to his arrest and he

8 was in detention. Then move on to -- move on to the next area of your

9 examination.

10 MR. TAPUSKOVIC: [Interpretation] The next topic could be whether

11 the prisoners were used as human shields with a view to protecting the

12 army of Bosnia-Herzegovina in their actions. Were prisoners used as human

13 shields in the actions mounted by the BH army, if you will allow the

14 question.

15 JUDGE ROBINSON: Ms. Edgerton.

16 MS. EDGERTON: Well, actually, Mr. Tapuskovic directed the

17 question to Your Honours, as to whether or not you would allow it. I'm on

18 my feet over the same objection, absolutely the same objection, Your

19 Honour; it's irrelevant. These things are all right for contextual

20 matters that might help us all better assess the background to the

21 indictment against the accused. But this isn't a trial, with respect,

22 Your Honours, about who started the war, why someone decided to fight or

23 what abuses might have been perpetrated in detention facilities not under

24 the control of the man who is presently on trial, Your Honour, and outside

25 of the period of the indictment.

1 [Trial Chamber confers]

2 JUDGE ROBINSON: The Chamber is not allowing the question.

3 MR. TAPUSKOVIC: [Interpretation] Thank you.

4 Let me think about this, whether I have any questions left at all.

5 Yes, I do.

6 Q. Tell me, you spoke of the clashes and fighting in 1994. What were

7 the subsequent developments like? What was the situation like in late

8 1994 and in early 1995?

9 A. As I said, in late 1994 there was fighting going on which was

10 followed by a truce. The truce lasted until early May or thereabouts.

11 Q. What happened next?

12 A. Next came an offensive by the Muslim forces against the

13 territories held by the Serbs.

14 Q. What was it like and how long did it last, approximately?

15 A. It lasted from early May until September.

16 Q. Since I have to go through this more quickly and deal with matters

17 of relevance, what happened on the 28th of August, 1995, in the area where

18 you lived?

19 A. On the 28th of August, 1995, I got married. It was the day of my

20 wedding at Vrelo Bosne, Ilidza municipality.

21 Q. What time was the wedding to take place and what happened?

22 A. Well, among Orthodox Serbs the Feast of the Assumption is a major

23 feast. There was a mass. And my wedding was scheduled to take place at

24 around 12.00, ten minutes past 12.00.

25 Q. And what happened?

1 A. As the wedding ceremony drew to a close, as the wedding guests

2 started leaving the church, shells started falling from the direction of

3 Igman all around the church and my wedding guests.

4 Q. How many shells fell?

5 A. Three shells fell in the immediate vicinity of the church, and a

6 total of about 12 -- 12 shells fell in the broader area.

7 Q. Thank you. And how many wedding guests were injured and was

8 anyone killed?

9 A. 47 people were wounded, and one person was killed. That was my

10 wife's cousin.

11 Q. Let me show you a document, DD00-3178, and I would like you to

12 answer some questions.

13 MS. EDGERTON: Your Honours.

14 JUDGE ROBINSON: Yes, Ms. Edgerton.

15 MS. EDGERTON: This is obviously probably the most difficult time

16 of this witness's life and if is going to be prolonged by going through

17 questions about this document which is an investigative report on the

18 incident prepared by the RS CSB, the RS police forces, I'm quite happy

19 that Mr. Tapuskovic tender the document. I don't have any objection.

20 JUDGE ROBINSON: Do you want to tender the document?

21 MR. TAPUSKOVIC: [Interpretation] No. Your Honours, no, not before

22 the witness is able to confirm some things in this document, and not

23 before I have dealt with some issues in this document, because I don't

24 want to just gloss over those things. This is why this witness wanted to

25 talk about this, why he decided to do so without protective measures. I

1 may not be tendering this document, but I think that my learned colleague

2 cannot really manage the way I present my case. Because if we can't hear

3 this, this is the 28th --

4 JUDGE ROBINSON: She's just trying to be helpful --

5 MR. TAPUSKOVIC: [Interpretation]

6 Q. Could you please look at --

7 JUDGE ROBINSON: But you must know that Ms. Edgerton was only

8 trying to be helpful because the witness is obviously in some pain and

9 grief over this and he's upset, so she was trying to spare him more of

10 that upset. That's all she was trying to do, it seems to me. Not to

11 manage your case.

12 MR. TAPUSKOVIC: [Interpretation] The witness had been upset enough

13 during his nine months stay in the camp, you did allow him to describe

14 this. But He wants to describe this because is this the 28th of August,

15 and despite Judge Harhoff's wishes, I will be presenting this. I have

16 already cut down my examination. You are in charge of it, but so if you

17 believe --

18 JUDGE ROBINSON: Get along with it. Get along with it.

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

20 is nothing here but -- let me not go into anything here.

21 JUDGE HARHOFF: I have not raised my voice at all. I have no

22 objections.

23 JUDGE ROBINSON: Proceed, Mr. Tapuskovic.

24 MR. TAPUSKOVIC: [Interpretation]

25 Q. Witness, sir, could you please look at this document. Look at the

1 date and the heading. The date and what it says in the subject

2 line -- no. To cut this short, what is the -- the title of this document?

3 What you see here, official report, do you see that? Can you tell us what

4 is it?

5 A. The ministry --

6 Q. No, no, no.

7 A. The official report in the afternoon hours of the 28th of August,

8 1995, the criminal investigation service of this CSB was informed that

9 between 12.30 and 1300 hours on the same day, a number of mortar shells

10 were fired from the positions of the so-called army of Bosnia-Herzegovina

11 at the Serbian Orthodox church devoted to Saint Sava in the Vrelo Bosne

12 settlement, in front of which there were at the time a mass of believers

13 and a wedding party, as well as at the neighbouring settlements, Vrelo

14 Bosne and Plandiste in the Ilidza municipality and that a number of

15 persons were injured.

16 Q. Thank you.

17 A. May I ...

18 Q. Now could we please look at page 2 in the English version and page

19 2 in the B/C/S version, the second paragraph, if you could just read the

20 first couple of sentences there.

21 MR. TAPUSKOVIC: [Interpretation] Your Honours, the witness has

22 some problems, some needs, and perhaps it would be a good idea -- did I

23 understand you correctly?

24 The witness must leave the courtroom for a couple of minutes

25 because he has bladder problems.

1 JUDGE ROBINSON: We'll take a short adjournment. Five minutes.

2 --- Break taken at 10.00 a.m.

3 --- On resuming at 10.09 a.m.

4 JUDGE ROBINSON: Yes, Mr. Tapuskovic.

5 MR. TAPUSKOVIC: [Interpretation] Thank you.

6 Q. Sir, so we're on page 2 now, second paragraph. Could you please

7 just read this. Read aloud.

8 A. "The explosion of these shells" --

9 Q. Just a moment. I said the second paragraph. That starts with the

10 words "the explosion." Is this where you started?

11 A. No, no, I did not.

12 Q. Could you please start there?

13 A. "The explosion of these shells killed Jadranka Vitor, born in

14 1961, mother of two underage children, residing in Hadzici, while 46

15 persons were seriously or slightly wounded in the church yard and six

16 persons in the Vrelo Bosne and Plandiste settlements. At the same time,

17 the facade of the western wall of the church was damaged by shrapnel in

18 about 30 places."

19 Q. Thank you. You looked at the photographs that were appended to

20 this file and do these photographs, because I don't want to exhibit them,

21 correspond with the site and the scenes that could be observed there after

22 this incident?

23 A. Yes, precisely.

24 Q. Thank you. You said that ten or 12 shells fell?

25 A. Yes.

1 Q. Were any of your relatives, your closest relatives, wounded?

2 A. Yes. In this shelling, my father was wounded and so were my two

3 brothers, my cousin, and a little girl who was also my cousin. She was

4 one and a half years old.

5 Q. Thank you.

6 MR. TAPUSKOVIC: [Interpretation] I would now like to tender this

7 whole document into evidence. It's been translated into English and there

8 are photographs that are attached to it. There's no need for me to show

9 those photographs in courtroom. They contain the -- among them is a

10 photograph of the dead body of this woman and I would like now to like to

11 tender this document DD00-3178, into evidence.

12 JUDGE ROBINSON: Yes, Ms. Edgerton.

13 MS. EDGERTON: The -- I would have no objection, as I had

14 indicated previously, to the translated text of the document which is

15 seven pages without any photographs because I have not seen the

16 photographs being tendered into evidence.

17 JUDGE ROBINSON: So what you are saying, then, is you -- you

18 object to the photographs being tendered?

19 MS. EDGERTON: I've simply not seen them and, in any case, if they

20 are photographs of what is described in a detailed version in this

21 official -- in a detailed way in this official report, they're simply

22 redundant. So I'm happy if the seven-page report is admitted into

23 evidence.

24 JUDGE ROBINSON: We'll admit everything.

25 MS. EDGERTON: Thank you.

1 THE REGISTRAR: As Exhibit D343, Your Honours.

2 MR. TAPUSKOVIC: [Interpretation] Just a few more questions. I

3 would like to try and finish before the break.

4 Q. This was at 12.30 and 1.00, according to this record. What did

5 you do afterwards, you and all the others?

6 A. After the shelling, we drove the wounded people to the Zica

7 hospital.

8 Q. Thank you. And could you tell me, first of all, were you yourself

9 injured?

10 A. I and my wife were not wounded. We were the only members of the

11 close family who were not wounded. All the rest were wounded and my

12 brother was hospitalised for ten days.

13 Q. Did you learn anything from the media during the afternoon?

14 A. I heard -- I heard it in the media that there had been a massacre

15 at Markale, so to speak.

16 Q. Do you remember, this was at 12.30, around 1.00, 12.30, 1.00, do

17 you remember what was it said in the reports? At what time did this

18 incident at Markale take place?

19 A. As far as I can remember, it was at 11.00 or ten past 11.00.

20 Q. Thank you. And do you know anything about air bombs?

21 A. I only know about that when NATO air-strikes -- when NATO carried

22 out air-strikes against Serbian positions.

23 Q. And when was that in relation to the 20th of August, 1995?

24 A. It was two or three days.

25 Q. And since I have some more time, I would like to ask you to tell

1 me, Ilidza and this place where you were, what was it -- its geographic

2 position in relation to its environs?

3 A. Ilidza and Hadzici are surrounded, were surrounded on all sides by

4 the Muslim forces because they held the highest ground, the BH army held

5 the highest ground. And shellings were a daily occurrence in Hadzici and

6 Ilidza.

7 Q. Could I please ask you not to hit the desk because it can be

8 heard.

9 What did the civilians do in order to protect themselves against

10 the BH army fire?

11 A. Some concrete walls were put up, I don't know how to describe it,

12 in order to protect the population against shells and snipers.

13 Q. I would now like to show you one photograph and ask you whether it

14 has anything to do with Ilidza. That's DD00-4233.

15 A. Yes, this is in the direction of Stup.

16 Q. Who held the positions at Stup, and I mean the military positions?

17 A. The forces of the BH army.

18 MR. TAPUSKOVIC: [Interpretation] I wish to tender this document

19 into evidence as a Defence exhibit. And this was my final question in

20 relation to this document.

21 Can we please have DD00-4233 admitted into evidence?

22 JUDGE ROBINSON: Yes.

23 THE REGISTRAR: As Exhibit D344, Your Honours.

24 Q. Thank you, witness.

25 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honours.

1 JUDGE ROBINSON: Ms. Edgerton is there any cross-examination?

2 MS. EDGERTON: One moment to double-check, please, Your Honours,

3 if you could indulge me with my colleague Mr. Waespi.

4 [Prosecution counsel confer]

5 [Trial Chamber confers]

6 MS. EDGERTON: I would hope only about ten minutes worth of

7 questions, Your Honours, no longer.

8 JUDGE ROBINSON: Yes.

9 Cross-examination by Ms. Edgerton:

10 Q. Sir, I'd like to go back to that unfortunate incident we spoke

11 about with the shelling, with regard to the shelling which followed your

12 wedding ceremony. And I note that in your testimony you read out

13 something from a document that's been exhibited saying that, in fact I'll

14 read exactly to what you wrote: The official report in the afternoon

15 hours of 28 August, the criminal investigation service of the CSB was

16 informed that between half past 12.00 and 1.00 on that day, a number of

17 mortar shells were fired from the positions of the so-called army of

18 Bosnia and Herzegovina at -- in fact, the area where your ceremony had

19 taken place.

20 Do you remember reading that?

21 A. Just now?

22 Q. Yes.

23 A. Well, yes.

24 Q. So how, sir, do you know that fire had come from territory held by

25 the army of Bosnia and Herzegovina? How do you know that?

1 A. I know because the forces of the BH army were up at Igman. They

2 held Igman and that was where the shells came from.

3 Q. So -- and you've said in your testimony that Hadzici and

4 Ilijas -- sorry, Ilidza were in fact surrounded as you described it, by

5 forces of the army of Bosnia and Herzegovina; correct?

6 A. Yes.

7 Q. So, in fact, what you're saying is since you were surrounded,

8 it's logical to assume that when a shell lands in your area, it comes from

9 the people who are surrounding you; is that correct?

10 A. Yes.

11 Q. Thank you. I'd like just then to move on one final area, and it's

12 with respect to the photograph that you spoke about before which showed

13 passive anti-sniping barricades in an area with which you were familiar.

14 And I would just like to know whether you have any knowledge at all of

15 similar barricades being erected in areas of Bosnian-held territory

16 nearby.

17 A. Well, what do I know about it. Yes, there were some down there.

18 Q. That's because you had seen them, had some glimpses of them; is

19 that correct?

20 A. Yes.

21 Q. And I would just like to show you a couple of pictures of these

22 sort of barricades that come from the area of Bosnian-held Dobrinja and

23 ask, based on your recollection, if it's consistent with what you saw?

24 MS. EDGERTON: And those would have ter number 03473, please.

25 Might need to turn the picture -- there.

1 Q. Is that generally consistent with the type of things that you

2 might have seen on - if I can call it that way - the other side, as well

3 as on your side?

4 A. I don't know where this is.

5 Q. It's in Bosnian-held Dobrinja, sir, and it was taken in very early

6 1996. And my only question is: Is this generally consistent with what you

7 might have seen and perhaps -- there's a couple of photographs here.

8 Perhaps we could move to the next page in this list, in this series.

9 JUDGE ROBINSON: Mr. Tapuskovic.

10 MR. TAPUSKOVIC: [Interpretation] Your Honours, I don't know if

11 this was slip of the tongue, because it says here that it was taken in

12 1996. What has it got to do with anything? It says here that it was in

13 Dobrinja. That was Bosnian-held territory, if I understand English

14 correctly, and then it says 1996. Was it in -- taken in 1996 and, if so,

15 what does it relate to?

16 JUDGE ROBINSON: Well, yes, I'd like to ask the same question too.

17 Is it in 1996 and what is the relevance of it?

18 MS. EDGERTON: The pictures were taken in early February 1996,

19 Your Honours, immediately prior to the reintegration and as the witness

20 had said, he was aware of similar passive anti-sniping barriers being

21 erected in Bosnian-held territory and he had seen some from time to time.

22 I'm simply asking if this is consistent with what -- with his

23 recollection, with what he had seen at the time.

24 [Trial Chamber confers]

25 JUDGE ROBINSON: We don't consider it relevant, Ms. Edgerton.

1 MS. EDGERTON: Fine, thank you, Your Honours.

2 If you could remove the picture from the screen.

3 I don't have any other questions then, Your Honours.

4 JUDGE ROBINSON: Yes, and I presume you have no re-examination.

5 MR. TAPUSKOVIC: [Interpretation] I would have just several

6 questions. I don't know if we have time. I only need a couple of

7 minutes.

8 JUDGE ROBINSON: On what? I mean, there was hardly any

9 cross-examination.

10 MR. TAPUSKOVIC: [Interpretation] Well, precisely because of the

11 questions my learned friend put to the witness about what he was able to

12 see from Ilidza in the direction of any -- in any direction concerning

13 Muslim-held territory. Yes, thank you.

14 Re-examination by Mr. Tapuskovic:

15 Q. [Interpretation] Witness, were you able to see anything from

16 Ilidza as concerns the Bosnian-held part of Sarajevo, were you able to see

17 any of these territories?

18 A. Not from Ilidza.

19 JUDGE ROBINSON: Ms. Edgerton.

20 MS. EDGERTON: With respect, Your Honours, that has nothing to do

21 with the two questions that I put to the witness.

22 JUDGE ROBINSON: I think -- unless you have other questions we are

23 stopping. Do you have other questions?

24 MR. TAPUSKOVIC: [Interpretation] I don't have other questions.

25 But my learned friend from the Prosecution asked the witness whether he

1 was able to see such scenes in Bosnian-held territory as was shown in the

2 photograph. No part of Bosnian-held territory could be seen from Ilidza

3 because of the Stup hill, Sokolje, Mojmilo and so on and so forth.

4 JUDGE ROBINSON: Thank you. Thank you. Thank you.

5 Witness, that concludes your testimony. We thank you for coming

6 to the Tribunal to give it. And you may leave now with us as we take the

7 break.

8 THE WITNESS: [Interpretation] Thank you very much.

9 --- Recess taken at 10.31 a.m.

10 [The witness entered court]

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

12 JUDGE ROBINSON: Mr. Waespi, the witness is going to make his

13 declaration.

14 Let the witness make his declaration.

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

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

17 WITNESS: SLOBODAN BJELICA

18 [Witness answered through interpreter].

19 THE INTERPRETER: Can the other witness's microphone be switched

20 on, interpreter's note.

21 JUDGE ROBINSON: Please switch on the second microphone. And

22 Mr. Tapuskovic, you may begin. But, Mr. Waespi, did you have a point.

23 MR. WAESPI: Yes, a procedural issue, but we can deal with it at

24 the end of this witness's testimony.

25 JUDGE ROBINSON: You may begin then, Mr. Tapuskovic.

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

2 Examination by Mr. Tapuskovic:

3 Q. [Interpretation] Witness T-4. I have to introduce myself. You

4 know that I'm Defence counsel for Mr. Dragomir Milosevic. We have already

5 discussed the matters we will deal with today. Can I remind you that you

6 have to wait for my question to be entered into the transcript, which you

7 see in front of you on this screen before you start answering. Do you

8 understand?

9 A. I do.

10 Q. Can you please state your name to the Trial Chamber.

11 A. Slobodan Bjelica.

12 Q. You were born on the 18th of March, 1952?

13 A. Yes.

14 Q. In Sarajevo?

15 A. Yes.

16 Q. You completed your primary school, your secondary graphic design

17 school, in Sarajevo, as well as the administration college?

18 A. Yes.

19 Q. Before the start of the conflict in Bosnia-Herzegovina and in

20 Sarajevo, you worked for the Assembly of Bosnia-Herzegovina and the

21 government of Bosnia-Herzegovina, as head of graphic design?

22 A. Yes.

23 Q. Can you tell us, sir, how long you worked for the government of

24 Bosnia-Herzegovina?

25 A. I worked there until the end of April 1992.

1 Q. And why did you stop working there at the end of April 1992?

2 A. As I came to work on the 28th of April of 1992, in the government

3 building, I came across armed men there, men I didn't know. I went past

4 them, and got into my office. I was called by a colleague of mine who

5 told me with the very best of intentions that I ought to leave the

6 premises as I had no business being there.

7 Q. Before that date, did you experience anything in the flat you had

8 in Sarajevo?

9 A. Yes. I had a flat at what is today Kolovarska Street --

10 Darovalaca Krvi Street. Men came to my flat allegedly searching for

11 weapons. They accused me of being a sharpshooter, of wielding a sniper. I

12 had never owned any weapons and I thought I'd be safe if I went to the

13 government building and joined the colleagues I worked with there.

14 Q. In order to make matters you're testifying about clear, I have to

15 use a map of Sarajevo briefly, which is document 65 ter, document 2872.

16 Could you show us where the government building was and where your

17 flat was? I should also like you to indicate those places with circles

18 and you will also place some letters next to that in due time.

19 MR. TAPUSKOVIC: [Interpretation] Can it be zoomed in a bit?

20 Q. Please indicate where the government building was.

21 A. [Marks]

22 Q. Can you mark it with the letter "V". Please circle the place

23 where your flat was and mark it with the letter "K".

24 A. [Marks]

25 Q. After the events of April, where did you go?

1 A. I went to Miljevici, where my parents were. I was -- I really

2 felt bad about everything that had happened. And then afterwards, I went

3 to the government building.

4 Q. No, please, wait. Now that you have indicated this, can you

5 indicate the location of Miljevici on this map. Where your family flat

6 is. It's somewhere in the south, I believe, and you seem to be looking at

7 the top of the map.

8 A. [Marks]

9 Q. Please mark it with the letter "M".

10 A. [Marks]

11 Q. You say you went there to your parents' home?

12 A. Yes.

13 Q. Please take it slowly. You came to your parents' home; is that

14 right?

15 A. Yes.

16 Q. Did you ever return to the flat you had in Sarajevo?

17 A. No.

18 Q. On your arrival at your parents' home, what did you do next?

19 A. In the morning, I went to the government building where I was

20 charged with preparing and editing the official bulletin.

21 Q. Please, please. You said the government building. Did you go

22 back to the government of the -- did you go back to the government of

23 Bosnia-Herzegovina -- wait, please, till I put the question. I'm really

24 surprised at hearing your answers in view of your profession.

25 When you said the government, which government did you have in

1 mind?

2 A. The government of the Serbian Republic of Bosnia-Herzegovina, as

3 it was called at the time.

4 Q. Again, you hastily answered before my question was entered into

5 the transcript. Please wait for my question to be entered in the

6 transcript fully before you answer.

7 What did you do then in the government of Republika Srpska and

8 where was the building located?

9 A. The government of Republika Srpska was located at Pale.

10 Q. What were your duties in the government of Republika Srpska?

11 A. I --

12 Q. Please wait. You're a journalist. How come you're finding it

13 difficult to deal with such a situation. You're faced with it everyday.

14 Please take it slowly.

15 Can I have your answer now?

16 A. I was editing the official bulletin, the Official Gazette of

17 Republika Srpska, where laws and by-laws of Republika Srpska were

18 published.

19 Q. Which route would you take to reach Pale?

20 A. I had to take the Miljevici-Lukavica-Tilava route.

21 Q. Wait a moment, please. Why are you mentioning Lukavica in this

22 context? Did Lukavica have anything to do with the duties you had to

23 perform?

24 A. I had to take that route in order to reach Pale.

25 Q. Can you draw this route on the map, and I will have a question for

1 you.

2 Please find Lukavica first. Is that really difficult?

3 A. It's not shown on this map.

4 Q. Can you please approximate the route?

5 A. I can't draw the route, because there is no Lukavica, Tilava or

6 Trebevic. I really can't do that on this map.

7 JUDGE ROBINSON: Mr. Sachdeva.

8 MR. SACHDEVA: Mr. President, perhaps the map can be saved and

9 then scrolled down where I would imagine the route can be -- can be found.

10 JUDGE ROBINSON: Can that be done?

11 Yes. Well, let's do that then.

12 THE REGISTRAR: This will be Exhibit D345, Your Honours.

13 JUDGE ROBINSON: No, no. There was a suggestion that the map be

14 scrolled down and then save it. Save it. Yes, you can save it, yes. But

15 we're not admitting it yet.

16 THE REGISTRAR: I apologise.

17 JUDGE ROBINSON: Okay.

18 MR. TAPUSKOVIC: [Interpretation] I don't think it's possible. I

19 think we have to save it in the format in which it is now but I'm sure the

20 court officers will be able to explain that better than I can. But now we

21 have no markings at all.

22 [Trial Chamber and registrar confer]

23 JUDGE ROBINSON: I'm told it has been saved.

24 MR. TAPUSKOVIC: [Interpretation] Very well.

25 Q. Can you please draw the route on the map; namely, the route you

1 took in doing your job, which we will discuss from Miljevici across

2 Lukavica to Pale?

3 MR. TAPUSKOVIC: [Interpretation] It has to be zoomed in a bit

4 further and scrolled down.

5 Q. And now I believe you can do that, right?

6 A. I have Miljevici and Lukavica. I don't have Tilava, oh no, I have

7 Tilava as well.

8 Q. What have you drawn there? This isn't something that I asked

9 from you. What is it?

10 A. This is the route I took.

11 Q. So how would you reach Pale from all these locations?

12 A. I took a detour to Tvrdinici, Zvorovi [phoen], beneath Jahorina

13 down to Pale.

14 Q. Can you draw an arrow indicating where all that is in relation to

15 the locations you have marked.

16 A. [Marks]

17 Q. And then you would next go to Pale. Can you mark the arrow with

18 the letter "P"? What do the circles represent?

19 A. The places. The place from which I set out, the place I passed

20 through and then the place I reached before I moved on.

21 Q. So you couldn't go directly from Miljevici to Pale?

22 A. No, I couldn't.

23 Q. Right. Now explain this, why were you not able to go there

24 directly?

25 A. We weren't able to go across Trebevic because the forces of the

1 BH army from the observation post, from Zvesdra, I will tell you now what

2 it is called, they fired on the road. They kept it under their control

3 and we couldn't take it.

4 Q. You mentioned Trebevic. Can you tell us more specifically which

5 section of the road that is?

6 A. Zlatiste.

7 Q. Wait for the question to finish. Go ahead.

8 A. Zlatiste, Ravne, Brus, and that would take us to Pale.

9 Q. What was going on on the road or, rather on the section of the

10 road passing through Zlatiste?

11 A. Zlatiste and Andza's house as it was called, were held by the

12 BH army with heavy weaponry.

13 Q. You said that Zlatiste and Andza's house were under the control of

14 the BH army; is that right?

15 A. Yes, yes.

16 Q. Can you please give it a thought. The road across Zlatiste, in

17 whose hands was it?

18 A. The road across Zlatiste was held by the BH army. It controlled

19 the road from Colina Kapa.

20 Q. But the very road, who controlled the road itself?

21 A. The road was held by the army of Republika Srpska.

22 Q. When you say that the road was under the control of the army of

23 Bosnia and Herzegovina, what do you precisely mean?

24 A. What I meant was that from Colina Kapa, there was constant fire on

25 the road making it impossible for anyone to move along the road on foot,

1 let alone in a vehicle.

2 JUDGE ROBINSON: Mr. Tapuskovic, I must caution you that

3 you -- sometimes you come fairly close to cross-examining your witness.

4 MR. TAPUSKOVIC: [Interpretation] Your Honour, I think that the

5 witness actually failed to understand some of the questions I asked, and

6 perhaps this caused me to get close to the cross-examination style. But

7 he, in fact, did not understand what I wanted to get from him, and I asked

8 for some clarifications. I wasn't leading him in any way. I will try to

9 avoid that at any rate.

10 JUDGE ROBINSON: Proceed.

11 MR. TAPUSKOVIC: [Interpretation]

12 Q. In all those years, did you ever pass through Zlatiste at all?

13 A. No.

14 Q. Thank you.

15 MR. TAPUSKOVIC: [Interpretation] Could those two maps be saved in

16 this form as a Defence exhibit.

17 JUDGE ROBINSON: Mr. Sachdeva.

18 MR. SACHDEVA: Mr. President, just a clarification as to the

19 period. I understand that the witness is speaking about the period 1992

20 to 1995 when he answers the question, all those years. So, is the

21 evidence that during the conflict he never took that road? I'm not sure

22 of the time-period.

23 JUDGE ROBINSON: Well, as for the latter I think can you ask that

24 in cross-examination.

25 But will you just clarify the time-period that you're speaking of,

1 Witness?

2 THE WITNESS: [Interpretation] This is the time-period between 1992

3 and 1995. But at times it was possible to pass through during cease-fire

4 periods, and that was sometime between August 1994 and January 1995,

5 something like that.

6 JUDGE ROBINSON: Yes, Mr. Tapuskovic.

7 MR. TAPUSKOVIC: [Interpretation] Could both maps be saved as a

8 Defence exhibit then.

9 JUDGE ROBINSON: Yes.

10 THE REGISTRAR: As exhibits D345 and D346, respectively, Your

11 Honours.

12 MR. TAPUSKOVIC: [Interpretation]

13 Q. So could you tell the Judges how long you remained working in the

14 Republika Srpska government, working on the publication of the Official

15 Gazette of Republika Srpska?

16 A. Until the 13th of March, 1993.

17 Q. And what did you do then?

18 A. I founded Sarajevske Srpske Novine, the Sarajevo Serbian paper at

19 Grbavica.

20 Q. And how did you get to work in those days, what route did you

21 take?

22 A. I went from Miljevici via Vraca to Grbavica.

23 Q. Every day?

24 A. Yes, every day.

25 Q. Please don't answer immediately.

1 And what was your experience in 1993, 1994, 1995, as you took this

2 road?

3 A. On this map where I drew in the Miljevici-Lukavica route in the

4 area of the memorial park at Vraca, it was very difficult to pass through

5 there in the vicinity of Debelo Brdo because of the shelling and gun-fire

6 from Debelo Brdo. I failed to mention that when I talked about the route

7 that I took to Lukavica. That route also passes through Vraca, and it

8 goes down to Grbavica.

9 Q. And from the memorial park which was under threat, as you just

10 described to us and then onwards to Grbavica, how did you move? Was it

11 safe to move there?

12 A. No. It was not safe, because the road dips down and it goes

13 towards Sarajevo. It's the Debisa Nujica Street, I think it was called.

14 There were some blankets put up, some curtains so that people would be out

15 of sight as they moved down towards Grbavica and then warnings were posted

16 about sites that were targeted by snipers.

17 Q. And could you please tell me, did you have to -- or, rather, how

18 often did you go to Grbavica because of your job?

19 A. I went down to Grbavica and came back every day five or six times.

20 Because of my job, I had to bring the materials to -- to the desk.

21 Q. Did you at any time have weapons as you went to work and came back

22 home or when you moved anywhere else?

23 A. No. I was never armed.

24 Q. Can you please tell me what did you actually do in this newspaper

25 that was called Sarajevske Srpkse Novine?

1 A. I edited the newspaper. In order to inform the population about

2 the developments at the front, the confrontation lines, what was

3 happening at Grbavica, Vojkovici, Lukavica, in those areas, Pale and so

4 on, the quantities of humanitarian aid that had come in.

5 Q. Thank you. Were you in charge of the distribution of this

6 information?

7 A. Yes.

8 Q. And could you tell us who did that this information reached, this

9 information that you had, and that you then disseminated, who did it

10 reach?

11 A. The information could reach the citizens and the troops.

12 Q. Thank you. Which citizens, which troops?

13 A. The citizens of Republika Srpska.

14 Q. Did you try to disseminate this information to some other

15 recipients?

16 A. Yes. We often wanted to disseminate this information, those

17 reports to various media outlets that -- whose crews would come to

18 Grbavica. But the newspapers and the reports in them did not reach as far

19 as Belgrade let alone any further.

20 Q. And were you visited by people from major media houses in the

21 world and what would happen when they came, in the sense that I've been

22 asking you about, and what you have been answering?

23 A. Yes, yes, of course. CNN came. Most of the major houses would

24 come and we would give them our information, show them the photographs,

25 but it was never made public. They never ran any of it.

1 Q. And what was -- what stories did they run that you as the editor

2 of this newspaper, as you as the editor were able to notice? What did

3 those large media houses publish always?

4 A. I personally believe that the media that came to the area

5 of -- controlled by the Republika Srpska army and the BH army, that they

6 had applied different standards. From the areas controlled by the BH

7 army, all the reports were published, and very little was published of

8 what was going on in the Republika Srpska army controlled areas.

9 Q. Do you remember an event in March 1995, in Grbavica?

10 A. Yes.

11 Q. Please go slow. Nothing will get recorded in the transcript.

12 A. Yes, two girls were killed in front of the shopping building. We

13 gave photographs to the media. They took the photographs away, and nobody

14 ran any reports on this incident.

15 Q. And because of the fighting, were there any civilian casualties at

16 Grbavica and did you get any information about Lukavica, Hadzici,

17 Nedzarici, Dobrinja, did you get any information?

18 A. Yes. We'd receive reports almost daily. There were casualties in

19 Grbavica, lots of casualties, in Ilidza, Nedzarici, Lukavica.

20 Q. Thank you. And did you try through the media, the TV channels or

21 the reporters that came to see you to disseminate any of the information

22 that pertained to the civilian casualties on the side controlled by the

23 Republika Srpska army?

24 A. Well, we tried. We definitely tried. But was a single picture

25 ever published in any media or anywhere. Pictures that would show how

1 badly Grbavica had been burned down, a part of Lukavica, Nedzarici, Otis,

2 and so on. Nothing was published at all, never.

3 Q. Do you remember, did you have the figures for the casualties,

4 civilian casualties in Grbavica alone?

5 A. Some 30 civilian casualties or so at Grbavica.

6 Q. In what period?

7 A. In the period --

8 JUDGE ROBINSON: Mr. Sachdeva.

9 MR. SACHDEVA: Mr. President, there must be a foundation

10 established for the witness to give these answers. On what basis did he

11 establish the figures of civilian casualties.

12 JUDGE ROBINSON: Yes, Witness, what's the basis for your knowledge

13 of this information?

14 THE WITNESS: [Interpretation] On the basis of the death notices

15 that were published and through my own personal knowledge.

16 MR. TAPUSKOVIC: [Interpretation] May I continue?

17 JUDGE ROBINSON: Yes.

18 MR. TAPUSKOVIC: [Interpretation]

19 Q. Did you actually see some of those incidents in which civilians

20 were killed? Were you an eye-witness of any such incident?

21 A. Yes. Dragan Bjelica was killed in Grbavica, in Radnicka Street in

22 front of my car. Majstorovic Zelko was killed at Dervisa Novica Street

23 above a staircase. Those two girls that were killed at Grbavica.

24 Bosko Radan at Grbavica.

25 Q. Thank you, thank you. It's not necessary. You've told us enough.

1 Could you please tell us whether you saw what happened with the

2 houses and the apartments that were there in Grbavica?

3 A. Well, any apartments in the first row of houses facing the

4 Miljacka and the separation line, nobody could live there, and it was

5 impossible to get in there, inside those buildings.

6 Q. Let me show you a photograph.

7 MR. TAPUSKOVIC: [Interpretation] DD00-5358.

8 THE INTERPRETER: Interpreter's correction, 4358.

9 MR. TAPUSKOVIC: [Interpretation]

10 Q. Witness, what building is this?

11 A. The sky-scraper next to the Miljacka. Opposite Bristol.

12 Q. How far was this from your workplace at Grbavica?

13 A. It's 100 metres away from my flat.

14 Q. Can you tell the Judges where the damage comes from. Were you an

15 eye-witness of the events that caused this and can you tell us what caused

16 the damage?

17 A. I only saw the building on fire. It was set alight by explosives.

18 I'm not a specialist in heavy weapons and such-like things.

19 Q. You said that it was hit by heavy weaponry?

20 A. Yes.

21 Q. Were there any casualties in these flats as a result of these

22 activities?

23 A. Of course there were.

24 MR. TAPUSKOVIC: [Interpretation] Can this photograph be admitted

25 into evidence.

1 JUDGE ROBINSON: Mr. Sachdeva.

2 MR. SACHDEVA: Mr. President, firstly, the -- I'd like to inquire

3 as to the time-period. 1992, 1993, 1994, 1995, when did this take place

4 and I'm -- well, okay. I'll proceed in cross on those other issues. But

5 at least to have a time-period, I would be grateful, Mr. President.

6 JUDGE ROBINSON: What's the time-period?

7 THE INTERPRETER: Microphone, please.

8 JUDGE ROBINSON: What's the time-period? Witness, what time are

9 you speaking of here?

10 THE WITNESS: [Interpretation] 1993.

11 JUDGE ROBINSON: Yes, we'll admit it, yes.

12 THE REGISTRAR: As Exhibit D347, Your Honours.

13 MR. TAPUSKOVIC: [Interpretation]

14 Q. I will show you another building, and let me ask you this: Was

15 this the case with most of the buildings at Grbavica? I will not mention

16 all the places, but let me show you DD00-4232, which is another building.

17 I will complete my examination quite soon.

18 What building is this, Witness?

19 A. This is the Unioninvest building.

20 Q. What were other buildings at Grbavica like in 1994 and 1995

21 through to the end? Were there any activities at the time which caused

22 damage to these buildings?

23 A. Yes, there were. There were more buildings, such as this one,

24 that were damaged by heavy weaponry, which was active both in 1994 and

25 1995.

1 MR. TAPUSKOVIC: [Interpretation] Can this photograph be admitted

2 into evidence, please.

3 JUDGE ROBINSON: What was the date of this bombing? Witness, do

4 you know?

5 THE WITNESS: [Interpretation] Are you referring to this particular

6 building or to all?

7 JUDGE ROBINSON: Well, this one.

8 THE WITNESS: [Interpretation] This one was set on fire in 1992.

9 JUDGE ROBINSON: Mr. Sachdeva.

10 MR. SACHDEVA: Mr. President, in fact, counsel has not -- has not

11 actually asked the witness on what basis he knows that this building was

12 set alight, was he there. There has been no foundational questions for

13 this photograph, in my submission.

14 JUDGE ROBINSON: Mr. Tapuskovic, why don't you ask these

15 questions? Because it is true that we take in hearsay evidence, but the

16 reliability of the evidence is strengthened if you lay a foundation for

17 the witness's knowledge.

18 MR. TAPUSKOVIC: [Interpretation]

19 Q. First, Witness, throughout the time-period from 1992 through 1993,

20 1994 to 1995, were you an eye-witness to the burning of this particular

21 building and other buildings? Did you yourself see these events as they

22 unfolded at the time?

23 A. I was born near Grbavica. I grew up there. Even when I worked at

24 Pale, I would come to Grbavica every day, because I had relatives there.

25 I had friends and colleagues there, work associates.

1 Q. All those years you saw this building on fire as well as hundreds

2 of other buildings burning in Grbavica.

3 A. Yes.

4 Q. And you know that many people were killed in activities such as

5 this one on the part of the BH army?

6 A. Yes.

7 JUDGE ROBINSON: Well, that's a leading question, isn't it? And

8 you know that many people were killed. You have to do better than that,

9 Mr. Tapuskovic.

10 JUDGE MINDUA: [Interpretation] Witness, of course we have seen

11 pictures of these destroyed buildings, but I would like to know if you

12 would be able to tell us who burnt those buildings, who set these

13 buildings on fire?

14 THE WITNESS: [Interpretation] I don't know who would be able to

15 set fire to their own home, flat, or house. It's very difficult to talk

16 about these things. It's inconceivable. There were mostly Serbs living

17 there, although there were quite a few Muslims and Croats as well. I

18 really don't see how else it could have been but for the BH army -- but

19 the BH army.

20 JUDGE MINDUA: [Interpretation] When these buildings were

21 destroyed, was there an exchange of fire or was it during a

22 cease-fire; do you know?

23 THE WITNESS: [Interpretation] This happened mostly during an

24 exchange of fire, although quite a few occasions it would also happen

25 during cease-fires. I would often hear conversations between soldiers of

1 Republika Srpska and officers about the enemy side not adhering to the

2 truce and that this compelled them to return fire. I also know that at

3 some point in time the VRS army was strictly prohibited from firing

4 because they lacked weapons and ammunition, as a result of the supply

5 lines with Serbia having been severed, the supply lines of ammunition,

6 food, and all the other necessities.

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

8 MR. TAPUSKOVIC: [Interpretation] Since the witness saw these

9 events personally, can this photograph be admitted into evidence?

10 JUDGE ROBINSON: Mr. Sachdeva.

11 MR. SACHDEVA: Mr. President, actually, I don't object to the

12 admission. But, in my submission, it is not correct that the witness has

13 given evidence that he saw this building set alight when it was initially

14 set alight -- in fact, the question by counsel was first -- the witness,

15 throughout the time-period 1992 through to 1993, 1994, 1995, were you an

16 eye-witness to the burning of this particular building and other

17 buildings. Do you -- did you yourself see these events as they unfolded at

18 the time. And the answer was: I was born near Grbavica, I grew up there.

19 Even when I worked at Pale, I would come to Grbavica every day because I

20 had relatives there. I had friends and colleagues there, work

21 associates.

22 In my submission, there is no direct answer to the question which

23 contained two or three components as to whether he saw this building set

24 alight initially.

25 As I said, I don't object to the admission but I can't see how

1 this witness can add anything to this photograph, in my submission.

2 JUDGE ROBINSON: Well, Witness, did you actually see this building

3 set on fire?

4 THE WITNESS: [Interpretation] Of course -- well, I saw the

5 building as it was on fire, because it was burning for two days.

6 JUDGE ROBINSON: Well, yes, in any event, we'll admit it.

7 THE REGISTRAR: As Exhibit D348, Your Honours.

8 MR. TAPUSKOVIC: [Interpretation]

9 Q. What do you know about the building called Soping?

10 A. I know that Biljana Plavsic lived in that building. It's a

11 sky-scraper that was targeted from all sorts of weapons. There were only

12 civilians there, nobody else.

13 Q. What does the word "Soping" mean?

14 A. Well, it was a small shopping mall.

15 Q. What happened to the civilians who would go to this Soping

16 building?

17 A. Half of the civilians were moved out because there had been

18 victims among them and were found accommodation elsewhere. They moved to

19 Lukavica.

20 Q. Tell me, a moment ago you said that some sites were marked as a

21 dangerous because of sniper fire; is that right?

22 A. Yes.

23 Q. Let me show you a photograph, DD00-4269.

24 What does this round say, this circle say?

25 A. Beware of snipers.

1 Q. How many such sign posts did you see at Grbavica?

2 A. At least 50 of them.

3 MR. TAPUSKOVIC: [Interpretation] Can DD00-4269 be admitted into

4 evidence as a Defence exhibit.

5 JUDGE ROBINSON: Yes. Yes.

6 THE REGISTRAR: As Exhibit D349, Your Honours.

7 MR. TAPUSKOVIC: [Interpretation] Your Honours, if I can be allowed

8 to show another photograph to the witness and put some questions to him

9 concerning the photographs and some other matters. He mentioned those

10 protective screens. Perhaps he can explain what can be seen on the

11 photograph I have here, which is DD00-4270.

12 Q. Witness, do you know what building this is? Is this what you were

13 referring to a moment ago when you mentioned protective screens, screens

14 that were to protect passers-by?

15 A. Yes, this building is located at the upper end of

16 Lenjenska Street. Some of my work associates had flats there, and I would

17 go there to help them move out. First we had these fences, as you can

18 see, these walls and later on we would put up blankets.

19 Q. Did you have to move in the same way this person we can see in the

20 photograph is moving?

21 A. But of course. All of us had to walk around Grbavica this way.

22 Q. And what is this fence facing? What -- from which direction does

23 it protect?

24 A. From the Wilson Promenade to the Bosnian government building, the

25 faculty of philosophy, the Museum of the Revolution, this is what this

1 fence is facing. It's facing the Miljacka river.

2 Q. And could you explain to the Judges in what time-period between

3 1992 and 1995, or rather the 21st of November of 1995, in what time-period

4 did the buildings at Grbavica suffer the most damage as we saw it here and

5 on other photographs, in what period?

6 A. In 1992.

7 Q. Actually, I asked you something else. In 1992, that doesn't mean

8 anything. What happened in the summer of 1995?

9 A. In the summer of 1995 there was a cease-fire. I think it was

10 supposed to be in force until May, but the BH army forces launched a

11 fierce attack against us. I think it was at the Djukica Potok and

12 Zlatiste and Grbavica, the whole of Grbavica. Quite a lot of the

13 Republika Srpska army troops were killed and I think that the line in the

14 direction of Trebevic, Mount Trebevic was actually penetrated.

15 Q. I'm not asking you about military issues. I'm asking you about

16 civilians and buildings in Sarajevo -- no, not in Sarajevo -- or, rather,

17 yes, in Sarajevo, in Grbavica.

18 A. Well, I don't understand your question. What do you mean what was

19 happening?

20 Q. Well, you mentioned the fierce attack you started talking about

21 the military impact of the attack. But I want to ask you this combat that

22 took place after May, what impact did it have on the civilian life, the

23 civilian buildings?

24 A. I know that the faculty of forestry was shelled. I also know that

25 a large building called Mis was also shelled. The people started moving

1 out of Grbavica along those lines.

2 Q. I don't have any further questions, but I would like to ask this

3 photograph that's on our screens now to be admitted into evidence.

4 That's DD00-4270.

5 JUDGE ROBINSON: Yes, we admit it.

6 THE REGISTRAR: As Exhibit D350, Your Honours.

7 MR. TAPUSKOVIC: [Interpretation] Thank you, Witness. And Your

8 Honours, thank you. I have no further questions.

9 JUDGE ROBINSON: Mr. Sachdeva.

10 MR. SACHDEVA: Thank you, Mr. President

11 Cross-examination by Mr. Sachdeva:

12 Q. Good -- it's just -- good afternoon, Mr. Bjelica. My name is

13 Manoj Sachdeva and I'm a lawyer for the Prosecution and I shall ask you a

14 couple of questions, actually more than a couple of questions today.

15 Firstly, can I just -- may I just confirm with you that you were

16 the editor of the Sarajevske Srpkse Novine from 1992 through to 1995, in

17 other words during the whole period of the war; is that right?

18 A. From the 13th of March, 1993.

19 Q. Right, right, that's correct. And then up until 1993, you worked

20 at the Republika Srpska government in Pale; is that right?

21 A. Yes.

22 Q. And the newspaper that you edited, was it -- was it a

23 civilian -- was it -- yes, a civilian publication, if I put it that way?

24 A. Yes.

25 Q. But you gave evidence that it was distributed throughout the

1 military, at least in Sarajevo; is that right?

2 A. No, that's not what I said. The military could not distribute the

3 paper. We distributed the -- the civilians distributed it, but just a

4 couple of copies would reach the troops at the front line, at the

5 confrontation line.

6 Q. Yes, I don't believe my question was that the military

7 distributed. But you agree that the military would receive copies of your

8 newspaper?

9 A. Yes.

10 Q. And you gave evidence also that you -- you stated that the

11 international media applied different standards when they were covering

12 the area controlled by the army of Bosnia-Herzegovina and the area

13 controlled by the Sarajevo-Romanija Corps. You remember saying that, sir?

14 A. Yes.

15 Q. And of course to -- to establish that or to make that

16 determination, you would have to be monitoring the international media on

17 a regular basis; is that right? When you could.

18 A. Well, when I could, that's what I did.

19 Q. So I take it, then, you're referring to the reports from these

20 international media companies, as you said CNN and other major companies,

21 you're referring to the reports of the shelling and sniping of the

22 civilians within the city of Sarajevo, in other words, within the area

23 controlled by the ABiH. Is that right, sir?

24 A. I didn't understand your question.

25 Q. I'm just trying to establish, sir on what basis you are speaking

1 about the differing standards and what I'm suggesting to you is that the

2 international media would -- would compile reports or stories about the

3 shelling and sniping or the suffering of civilians inside the city of

4 Sarajevo more than the -- the suffering of Serb civilians in -- in the

5 Serbian part of Sarajevo. Is that -- is that what you mean, sir?

6 A. Yes. And through the Bosnia-Herzegovina TV.

7 Q. So you were also monitoring the TV from Bosnia-Herzegovina; is

8 that right?

9 A. Yes.

10 Q. Now, may I ask you, sir, that at any time during the conflict were

11 you a soldier with the 1st Sarajevo Brigade, within the Sarajevo-Romanija

12 Corps?

13 A. No, not a single day.

14 Q. And I take it you never carried a weapon, did you?

15 A. I never carried a weapon.

16 Q. So in terms of the specific military operations or the -- the

17 exact locations of the confrontation lines and SRK positions, you really

18 don't have complete knowledge of that, do you?

19 A. I do have knowledge about the separation lines because I went

20 there to interview soldiers and officers.

21 Q. And how often would you go to the confrontation lines to

22 interview soldiers and officers?

23 A. Well, I went from one battalion and then to another battalion, and

24 I would spend ten to 15 days there.

25 Q. And are you speaking about the battalions within the 1st Sarajevo

1 Brigade? In other words, south of the Miljacka in Grbavica, Vraca,

2 Trebevic? Is that right?

3 A. Yes. Vogosca, Ilidza, that's where I went.

4 Q. And you visited all these positions from 1993 through to 1995; is

5 that correct?

6 A. Yes.

7 Q. And I take it that visiting the confrontation lines would have

8 been a dangerous endeavour, considering there was a war going on?

9 A. I have to tell you that it -- I had to drive 150 -- 130 to 150

10 kilometres to get from Grbavica to Ilidza. It was an arduous road.

11 Q. And yet, sir, you gave evidence that you never once took the

12 Lukavica-Pale road, in other words the Zlatiste road, is that right, or

13 did you in fact travel on that road, sir?

14 A. Please, when I went from Grbavica, Lukavica, Tilava, Trebevic and

15 then below Mount Jahorina, I don't remember what this place was called,

16 and then I would get to Pale. And from Pale through Nahorevo, I visited

17 all the lines and by the time I got to Vogosca, I had to take a detour to

18 get back to Ilidza. I didn't take the Zlatiste-Trebevic road.

19 Q. You never took that road throughout the conflict; is that right?

20 A. I have to tell you one thing. During the cease-fire in 1994 - I

21 don't know when it was - a bus with school children headed from Zlatiste

22 to Trebevic and five or six children were wounded by a shell that was

23 fired by the BH army, and I did pass through this road a couple of times

24 during the cease-fire. That's what I said. So I didn't say that I never

25 ever took this road.

1 Q. Well, perhaps your earlier answer was not recorded properly but I

2 have it that you never took that road. But, okay, I understand you now,

3 that you did indeed take that road.

4 Incidentally, when you said that the bus was hit, how did you know

5 that the bus was hit by the army of Bosnia-Herzegovina?

6 A. Because it was fired from Colina Kapa and my son was on this bus.

7 He went on a school trip with his class. He was in the 8th grade at that

8 time.

9 Q. I take it that because the ABiH had positions at Colina Kapa it's

10 only -- it's a logical conclusion that the fire came from that position;

11 is that right?

12 A. Yes.

13 Q. Now, as you spent much time in Grbavica and you've given evidence

14 about particular buildings that -- that were hit, you also mentioned that

15 some of them or one of them was hit during an exchange of fire. So I take

16 it that on occasions the Sarajevo-Romanija Corps would also fire into the

17 city. Is that right?

18 A. No, no, never from the Grbavica area. Yes, with infantry weapons,

19 but never with heavy weapons because there weren't any there.

20 Q. So they did fire from Grbavica with infantry weapons into the

21 city; is that correct, sir?

22 A. Yes.

23 Q. Since you have told the Court that you visited the front lines in

24 Grbavica, do you know where the Sarajevo-Romanija Corps fired from in

25 Grbavica?

1 A. I don't know.

2 Q. Did you not visit Sarajevo-Romanija Corps positions in Grbavica

3 when you interviewed the soldiers, sir?

4 A. Yes, I did. I visited them, the front lines. That's what I said.

5 I said that I visited the front lines.

6 Q. So where did the Sarajevo-Romanija Corps soldiers fire -- where in

7 Grbavica did they fire from into the city? So you've given evidence about

8 fire coming from the ABiH on territory that you yourself were not present,

9 and now I'm asking you about fire from Grbavica where you visited

10 regularly, where you interviewed soldiers, where you went to the front

11 lines, and you are telling the Court that you don't know from which

12 positions the Sarajevo-Romanija Corps fired from?

13 A. The exchange of fire, infantry fire, was from the positions where

14 the wall is. That's where the trenches were, along the Miljacka river.

15 Q. Sir, the buildings that we saw earlier in court and indeed the

16 Soping building that you gave evidence about, isn't it -- isn't it

17 correct, sir, that in those buildings there were Sarajevo-Romanija Corps

18 soldiers positioned there?

19 A. I think that there were no troops there because it's a civilian

20 building which is quite far from the front line.

21 Q. Did you ever go to the Soping building, sir, in the period

22 1994/1995?

23 A. Yes, yes, I did go.

24 Q. And you said earlier that civilians had been moved out from that

25 building. You remember saying that, sir?

1 A. Yes, I said that the civilians had moved out, and the Soping

2 building, it's not just one building. It's a whole complex but this

3 building that we were talking about it's the high-rise building, a

4 sky-scraper.

5 Q. Indeed, indeed. And the complex buildings when the civilians

6 moved out and when you went there, you must have seen Sarajevo-Romanija

7 Corps soldiers in those buildings, sir, I put it to you.

8 A. I don't understand the question. Well, there could have been no

9 soldiers there because it was far from the front line. What would the

10 soldiers be doing in that building? I don't understand. I -- I said what

11 I -- what I saw. What would the soldiers be doing in that building

12 because it was so far from the front line.

13 Q. When did you go to the building, sir? Do you remember the year or

14 the date, in fact?

15 A. Well, every five or six days I would go there and -- but I didn't

16 enter into the building. The building was burnt down. Why would I go in

17 there? I just passed by.

18 MR. SACHDEVA: Mr. President, might I have one second.

19 [Prosecution counsel confer]

20 MR. SACHDEVA:

21 Q. Sir, following on from my previous line of questioning, with

22 respect to the photographs that we saw, is it not correct that the

23 buildings were destroyed because the Sarajevo-Romanija Corps had soldiers

24 and weaponry in those buildings?

25 A. It didn't have any weapons there. It's impossible to keep weapons

1 at the Soping building because it was far from the front line and the

2 Unioninvest building at Vrbanja Most -- it was the bridge there, it had

3 already burned down so I can't see what they would be doing there.

4 Q. Sir --

5 A. And you couldn't open fire from there.

6 Q. Sir, you were never in the military, were you, during the war?

7 A. I never was in the military, sir.

8 Q. And during the war you never handled a sniper rifle or an infantry

9 rifle, did you?

10 A. I did not, sir.

11 Q. And I take it that you never fired a mortar from a mortar round,

12 did you?

13 A. I don't know even know what that is.

14 Q. And I take also that you do not have any knowledge of military

15 strategy or other military issues that ordinarily soldiers and commanders

16 would have to concern themselves with; isn't that right?

17 A. No, I do not.

18 MR. SACHDEVA: Mr. President, that's the cross-examination.

19 JUDGE ROBINSON: Yes.

20 Any re-examination, Mr. Tapuskovic?

21 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honours, I have

22 no questions in re-examination.

23 JUDGE ROBINSON: Witness, that concludes your evidence. We thank

24 you for giving it. And you may leave with us as we take the break now.

25 MR. TAPUSKOVIC: [Interpretation] Your Honours, I don't have any

1 questions -- any witnesses for today.

2 JUDGE ROBINSON: I see. Well, we'll adjourn until tomorrow at

3 9.00.

4 MR. WAESPI: I just have a very short procedural issue, Mr.

5 President.

6 We received on 20th of July, a filing by the Defence requesting

7 the admission under Rule 92 bis of three witness statements, and we -- the

8 Prosecution doesn't have any objection to these witness statements coming

9 in. They don't concerns acts and conduct of the accused, and also

10 obviously a recurring issue, they mostly concern the preindictment

11 period. So it's an issue of relevancy but if these witnesses would come

12 today and could testify there would hardly be any cross-examination on

13 these issues. So we have no objection to these coming in via 92 bis

14 without cross-examination. And we also do have no objection to the

15 protective measures suggested for witness T-20. I take it that means that

16 the witness statement would come in, if decided by Your Honours, under

17 seal.

18 The other two witnesses are T-40 and T-44.

19 Thank you, Mr. President.

20 JUDGE ROBINSON: Thank you. Yes.

21 We'll adjourn until tomorrow at 9.00.

22 --- Whereupon the hearing adjourned at 12.21 p.m.,

23 to be reconvened on Wednesday, the 25th day of July,

24 2007, at 9.00 a.m.

25