1 Wednesday, 06 November 2002

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.04 a.m.

5 JUDGE ORIE: Good morning to everyone in and around the courtroom.

6 Madam Registrar, would you please call the case.

7 THE REGISTRAR: Case Number IT-98-29-T, the Prosecutor versus

8 Stanislav Galic.

9 JUDGE ORIE: Thank you, Madam Registrar.

10 Yes, before we start this morning, Mr. Piletta-Zanin, we had a

11 problem yesterday on a question you put to the witness, whether it was on

12 the road or down the road. And you indicated it might have been a

13 translation problem as far as the testimony of the witness was concerned.

14 It was a translation problem, but in a totally different respect. That

15 is, that the question as you put it in French to the witness, where you

16 said "sous la route," was in the English translation as "on the road." So

17 therefore, it was the translation of your question that caused some

18 confusion. But there was -- it was -- you're perfectly right that it was

19 a translation matter rather than anything you would have not precise in.

20 MR. PILETTA-ZANIN: [Interpretation] Thank you very much, indeed,

21 Mr. President. But it is very hard for me to listen to the questions and

22 to look at the people and to ask the questions and to watch the

23 transcript. Thank you.

24 JUDGE ORIE: We all have similar problems where we are trying to

25 catch all the languages, if possible, for me only two of them. But the

1 matter has been settled, and your question represented perfectly what the

2 witness would have said according to the French and the English

3 transcript.

4 Mr. Usher, could you please -- Mr. Ierace, you're on your feet.

5 MR. IERACE: Thank you, Mr. President. Firstly, I have those

6 colour photographs which I could hand up at this stage. It's of the

7 Orthodox church. We have added an A to the end of the exhibit number to

8 distinguish them. They are P3753A. I hand up those copies.

9 Secondly, in relation to this witness, we again had a problem with

10 the 65 ter summary. It refers to incident 22 but gives no inkling at all

11 of what the witness would say about that incident. I have spoken to my

12 learned colleague this morning about that, and we have been given some

13 information which hopefully will cover it. But I simply wish to emphasise

14 the difficulty the Prosecution is placed in in not having an appropriate

15 summary of facts pursuant to the directions which you have given. It

16 should have been provided to us in writing a long time ago.

17 Secondly, we were told a few days ago that the witness would be

18 shown some photographs which came into evidence through the Prosecution

19 witness Henneberry. The 65 ter summary gives no suggestion at all as to

20 how those photographs could be relevant. I've spoken to my learned

21 colleague about that this morning, and I'm told that the witness may have

22 met Mr. Henneberry or did meet Mr. Henneberry in May, had something to

23 say about his character. And that's as far as it goes. So Mr. President,

24 in summary, we still have significant problems in terms of 65 ter

25 summaries coming from the Defence. Thank you.

1 I should add to the photographs show gun positions at Lima 7, and

2 Mr. Henneberry, in other photographs standing alongside military

3 equipment. And we've had to refresh our memory on what evidence

4 Mr. Henneberry gave without any assistance about what the witness might

5 say about his evidence. Thank you.

6 JUDGE ORIE: Yes. Are you going to ask to put questions to the

7 witness in respect of the testimony of Mr. Henneberry?

8 MS. PILIPOVIC: [Interpretation] Your Honour, no. I just want to

9 inform the Chamber that Saturday, we spoke to the witness. And in the

10 summary and the information about the cooperation in the presence of

11 UNPROFOR in the part of city where she lived, the witness at one point

12 said that they had a good cooperation and that she remembered some people

13 and she remembered the name of a man called Patrick. And then the Defence

14 showed her a photograph where Mr. Patrick could be seen, and she said she

15 recognised him. So I just informed the Prosecution about this, that

16 perhaps within the questions about the cooperation with UNPROFOR and the

17 assistance in -- bearing in mind her profession, what kind of cooperation

18 they had. And on Saturday, I informed in a brief note my colleagues that

19 she will also be speaking about the presence of UNPROFOR in the part of

20 city where she lived and worked during the conflict.

21 JUDGE ORIE: No more specifics about the witness Henneberry as far

22 as I understand. Yes. Well, then the consequences of whatever

23 shortcomings in the 65 ter might not be dramatic at this moment in respect

24 of this witness.

25 MR. IERACE: Thank you, Mr. President.

1 Mr. President, just another technical matter, I'm pleased that I

2 have a new laptop at the Prosecution Bench this morning. I would be even

3 more pleased if I were able to log on and make it work. I have tried and

4 have some difficulties. So perhaps whilst --

5 JUDGE ORIE: I'm sure that the technicians provide you not only

6 with the hardware, but also make it work. Anyone else that needs a new

7 laptop?

8 MR. PILETTA-ZANIN: [Interpretation] No. Mine is still very

9 ancient, as it always has been. And I just want to add two things: The

10 Prosecution has just demonstrated brilliantly that like every day we have

11 questions regarding detail. And linguistically, it is going rather well.

12 But the second thing is the Defence is waiting more and more impatiently

13 for the answers to the questions that the Defence asked in a language of

14 the Tribunal regarding the cooperation between the parties and the

15 uncontested points and we are awaiting this from the Prosecution. Thank

16 you.

17 JUDGE ORIE: Yes. The Chamber has noticed that sometimes the

18 parties have expectations from each other which are not always fulfilled.

19 But I take it that proper attention will be paid to it.

20 Then, let's try and get the witness into the courtroom.

21 Mr. Usher, could you please assist.

22 [The witness entered court]

23 JUDGE ORIE: I did hear you in a language which I do not

24 understand, but I do understand the words "dobro jutro", so "dobro jutro"

25 to you as well. And you can hear me in a language you understand?

1 THE WITNESS: [Interpretation] Yes.

2 JUDGE ORIE: Yes. May I remind you that you are still bound by

3 the solemn declaration you gave yesterday at the beginning of your

4 testimony. The examination by Defence counsel will now continue. Please

5 proceed, Ms. Pilipovic.

6 WITNESS: WITNESS DP7 [Resumed]

7 [Witness answered through interpreter]

8 Examined by Ms. Pilipovic: [Continued]

9 Q. Good morning, Witness.

10 A. Good morning.

11 Q. Witness, yesterday at the end of the day, we were cover a question

12 that you didn't give the answer to. You said that on the 15th of April,

13 1992, after the duty that lasted for 25 days, you stopped going to work

14 because in the institution where you worked some strange things were

15 happening. Could you tell us very briefly what was so strange for you and

16 that this strange things were a reason that you didn't go to work?

17 A. I'm sorry, just one thing. I said it was mid-April. I'm not

18 quite sure which day it was. I'm not quite sure which date this was. On

19 that day, I noticed, just like my other colleagues, that within the

20 closure of the hospital, there were some persons present that we didn't

21 notice before. There was specifically -- particularly dressed, and it was

22 unthinkable to see someone on a motorcycle driving around the hospital

23 compound considering that there shouldn't be so much noise around the

24 hospital. People were going with berets with some insignia, and some of

25 these persons were also armed.

1 Q. Thank you. Witness, after you stopped going to work, can you tell

2 us that day in April 1992, did you continue to work in another place?

3 A. After my last day at work, I was at home. I was waiting to get a

4 call to come back to work because my work time was specific. I worked

5 25-hour shifts. But because my neighbours knew that I was a nurse, what

6 happened was that there was an explosion near my house. And the -- and

7 they said that my neighbour, Mirko Stupar, was wounded. And they asked me

8 to come and administer first aid, to bandage his wound.

9 Q. Thank you, Witness. Now that you've told us that you assisted

10 your neighbour who was wounded, could you tell us when that was?

11 A. It was in the second half of April.

12 Q. Can you tell us how was he injured?

13 A. I don't know anything about weapons, but they told me that it was

14 a grenade launcher, and that it was fired from the other side, from our

15 neighbours.

16 Q. When you say that was a grenade launcher, that it was fired from

17 the other side from your neighbours, are you telling us in that part of

18 town where you lived, was there some kind of partition, division?

19 A. Not until then. But one street was specific. On one side, Serbs

20 lived on one side, and on the other side Muslims lived. It was just one

21 ordinary street. And until that point, we always had good relations. I

22 didn't know many people around there, but I knew some people.

23 Q. Witness, can you tell us, what was the part of the town or the

24 locality where you lived?

25 A. That is a part of the airport locality. This is local commune

1 Roza Hadzivukovic.

2 Q. Can you tell us if in 1992, after assisting your neighbour, were

3 you engaged anywhere?

4 A. After that event, I got a call to create some kind of an

5 outpatient clinic, a kind of surgery. And myself and a neighbour, who is

6 also a nurse.

7 Q. Your engagement and the establishment of a clinic, together with

8 your neighbour, you said that was upon a call. Who called you?

9 A. That was -- these were the people who organised themselves to

10 defend our building. It was a kind of Crisis Staff, a kind of Territorial

11 Defence.

12 Q. So if I understand you correctly, you joined the Territorial

13 Defence of your local commune?

14 A. Yes.

15 Q. When you told us that you, together with your neighbour, you

16 established a kind of team, you formed a kind of team, can you tell us if

17 you had a location where you were, where you did this?

18 A. It was a house, I think it was a Serbian house. Some people, and

19 they had tenants on the lower floor. And these tenants left so what we

20 did was we made a kind of first-aid room. We only had some bandages, just

21 minimum requirements.

22 Q. Thank you, Witness. Can you tell us, in September 1992 --

23 A. Yes.

24 Q. -- So that will be from 1992 through to 1994, where were you and

25 where were you engaged?

1 A. From 1992, that is, from April, the second half of April, that is,

2 until the end of April, I was near my house. That is in the -- at the

3 airport locality. After that, a medical corps was created within

4 Nedzarici, for the entire area. And I joined that group. There were

5 several nurses there. We didn't have a doctor.

6 Q. Witness, can you tell us, this medical corps as you called it and

7 this large group of nurses, where were you? Where was your accommodation?

8 Did you have any location inside Nedzarici where you were stationed?

9 A. That was in the barracks. It used to be a medical clinic. It was

10 like a surgery as part of the barracks, and that's where we established

11 the medical corps.

12 Q. Thank you.

13 Witness, can you tell us whether throughout the time, from 1992 to

14 1994, as a nurse, were you in the medical corps in the barracks?

15 A. For a while, we were in the barracks, but we had problems. Our

16 security was at risk in this respect. And then we moved to the faculty of

17 theology, that is, to the convent.

18 Q. Witness, can you tell us, when did you go to the faculty of

19 theology? When did you move there?

20 A. I don't know the exact date. I think it was in June -- no, no. It

21 was in May, I'm sorry. It was in May.

22 Q. Could you be precise; which year?

23 A. 1992.

24 Q. When you moved to the faculty of theology in May 1992, can you

25 tell us if this faculty of theology had been used by someone?

1 A. Yes. Yes, priests used it. Religious personnel used it.

2 Q. Can you tell us until when were they there at the faculty of

3 theology?

4 A. Until the end of April, I think, because just a little bit before

5 we entered, they left.

6 Q. When you told us that you came as part of the medical corps, the

7 medical department, to the faculty, at the end of May, you personally, how

8 long did you stay at the faculty of theology?

9 A. I was there until 1993, mid-1993.

10 Q. In that period, from May 1992 until mid-1993, while you were at

11 the faculty of theology, can you tell us whether as part of that

12 institution there were some other services apart from you in the medical

13 department, those who were -- who else was in that building?

14 A. Yes. There was a group of mortars [Realtime transcript read in

15 error "motors"], of mortar crews, people who were serving the motors, and

16 an armoured unit.

17 Q. Did you, as a member of the medical corps, did you have a need to

18 be engaged in that period in terms of assisting people?

19 A. Yes, of course.

20 Q. Witness, when you say "of course," can you tell us, what was the

21 reason that you felt the need to assist people?

22 A. At that time, there were many wounded and many people killed.

23 Q. Witness, can you tell us, did you have any vehicles that you used?

24 Was it necessary to engage vehicles?

25 A. We had several vehicles because every vehicle that we had didn't

1 last very long.

2 Q. When you say that you had several vehicles and that neither of

3 them last very long, what did you mean by that?

4 A. Yes, the first vehicle that we had, it was an ambulance. It was

5 an old vehicle, like a Lada vehicle but slightly longer. It was quite

6 old. And it was riddled with bullets. After that, we had to improvise

7 other vehicles that were not made for that purpose, so we had to make an

8 addition in order to put in the stretcher.

9 Q. When you say that these vehicles were riddled with bullets, can

10 you give us an example in which situation were these vehicles exposed to

11 fire?

12 A. To start with, from April 1992, we did not, near the institution

13 where we could take the severely wounded, we didn't have a place close by

14 but we had to go across the runway, across the airport. We went [Realtime

15 transcript read in error "won't"] to the Kasindol hospital, which was

16 located --

17 Q. Thank you. While you were at the faculty of theology, you told us

18 that there was an armoured unit there. Can you tell us, and do you have

19 any knowledge, whether as part of that armoured unit, there were vehicles?

20 A. Yes.

21 Q. Can you tell us what kind of vehicles they were?

22 A. [Inaudible]

23 JUDGE ORIE: Could you please repeat the answer because the

24 interpreters could not hear you. Perhaps you'll come a bit closer to the

25 microphone so that the interpreters can hear you better.

1 Would you please repeat your answer on the question: "What kind

2 of vehicles these were"?

3 THE WITNESS: [Interpretation] APC.

4 MR. PILETTA-ZANIN: [Interpretation] Mr. President, just one thing:

5 To say this for the transcript, and I'm doing it now. In line 10, 9, of

6 the current page, I'm not sure that at the end of line 9 it should not

7 be -- it should not read as [In English] "we won't."

8 JUDGE ORIE: It's "we went."

9 MR. PILETTA-ZANIN: [Interpretation] That's right. And I just

10 wanted to clarify this.

11 JUDGE ORIE: Yes. And the last part of that answer was either

12 inaudible or -- you told us about the Kasindol hospital, and you were

13 about to say where it was located. Where was that located?

14 THE WITNESS: [Interpretation] Yes. It was located near -- it is

15 located near Lukavica. That is, you had to go across the runway. There

16 was a corridor during the war, and it was on the other side.

17 JUDGE ORIE: Yes. Thank you.

18 Please proceed, Ms. Pilipovic.

19 MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

20 Q. Witness, you told us that within your building, an armoured unit

21 was accommodated which had APCs, as you said. Can you tell us how many

22 APCs there were?

23 A. Three.

24 Q. Those three APCs, were they used by you as members of the medical

25 corps?

1 JUDGE ORIE: There seems to be a problem hearing. Could you

2 please repeat the question, Ms. Pilipovic.

3 MS. PILIPOVIC: [Interpretation] Yes.

4 Q. Witness, the APCs, the vehicles that were within your premises,

5 were they housed there?

6 A. Yes.

7 Q. Did you, as members of the medical corps, have a need to use them,

8 you personally?

9 A. In 60 per cent of the cases, they had to assist us.

10 Q. When you say "in 60 per cent of the cases they had to assist you,"

11 can you tell us -- give us an example of the way in which they helped you?

12 A. When shooting was intensive, we didn't dare go because our safety

13 was at risk. In that case, we had to use the APC to go and fetch the

14 wounded.

15 Q. When you say that you used the APC to get the wounded, can you

16 tell us how frequently you and your colleagues extended aid to wounded

17 persons?

18 A. Many times a day. During one day, we would have to go two or

19 three times to extend aid in 1992. Later on, it was less intense, less

20 frequent.

21 Q. So you're telling us that in 1992, several times a day, and then

22 in 1993, not quite so frequently?

23 A. I said not as frequently as in 1992. If I understood your

24 question correctly.

25 Q. Let me clarify. In 1993, you said that you didn't go as

1 frequently as in 1992. Can you tell us how frequent it was in 1993, if

2 you said that in 1992 it was many times a day, several times a day? What

3 was the incidence in 1993? Was it every day or once a week?

4 MS. MAHINDARATNE: The witness said "two or three times a day" in

5 1992, not "several times".

6 JUDGE ORIE: Yes. I do agree with you. On the other side, I

7 don't think that that would create great confusion.

8 Please proceed, Ms. Pilipovic.

9 MS. PILIPOVIC: [Interpretation] I think, Your Honour, that the

10 witness said during the day, several times in 1992.

11 JUDGE ORIE: Yes. I think it says somewhere two or three times

12 but then it says many times. But let's just proceed. I don't think that

13 this would create -- that this would confuse the witness, and that's what

14 it is about.

15 Please proceed.

16 MS. PILIPOVIC: [Interpretation] Thank you.

17 Q. So please, will you answer my question regarding 1993. How

18 frequent was it in 1993 that you extended aid to the wounded?

19 A. I can't give you the numbers. I'm afraid you didn't understand

20 me. It was -- there was shooting every day, and it was in that context

21 that I answered your question, whether the crew of the APCs assisted us to

22 fetch the wounded. There were cases when we could cross the meadow,

23 extend first aid, and reach a spot where we were safe by car.

24 MR. PILETTA-ZANIN: [Interpretation] Mr. President, the transcript.

25 Again, in the English transcript there is a gap. There is a gap, I must

1 say what I heard in line 14, it was --

2 JUDGE ORIE: We usually do not -- it's uncontrollable, so if

3 there's a gap, please point at it and ask the witness to repeat what the

4 witness said at that moment because we cannot check what was said or what

5 was not said. So please point to the gap and we'll ask the witness to

6 repeat what she said.

7 MR. PILETTA-ZANIN: [Interpretation] Yes, Mr. President. But it is

8 important for the follow-up of the cross-examination of Ms. Pilipovic.

9 This gap on page 13, line 14, the witness indicated the frequency, and it

10 was very clear from what she said.

11 JUDGE ORIE: Yes, so we'll ask her to repeat what she said. You,

12 according to the English transcript said: "I'm afraid you didn't

13 understand me. It was, and then there was a certain part which does not

14 appear in our transcript. And then you continued, there was shooting

15 every day. Could you tell us again what you said. So after you said "I'm

16 afraid you didn't understand me," it was?

17 THE WITNESS: [Interpretation] I said that you didn't understand

18 me.

19 JUDGE ORIE: Yes.

20 THE WITNESS: [Interpretation] As I understood the question of

21 Mrs. Mara, it was whether the crew of the APCs assisted us. And I was

22 answering the question with respect to the APC. Was that your question?

23 JUDGE ORIE: Perhaps, Ms. Pilipovic, if you be informed by

24 Mr. Piletta-Zanin what actually is missing, then you perhaps clarify the

25 issue. Please proceed.

1 MR. PILETTA-ZANIN: [Interpretation] Yes, Mr. President. The words

2 used by the witness that are missing which was "every day."

3 JUDGE ORIE: Mr. Piletta-Zanin, I think it was quite clear that I

4 do not allow you, if something does not appear in the transcript, to tell

5 us what the witness said.

6 MR. PILETTA-ZANIN: [Interpretation] Sorry.

7 JUDGE ORIE: It's, of course, on the basis of the experience of

8 the last few days. So would you move to your next subject, Ms. Pilipovic.

9 I gave you in advance a warning not to tell us what the witness said. I

10 did not allow it to you, so move to your next subject, Ms. Pilipovic.

11 MS. PILIPOVIC: [Interpretation] Yes, Your Honour.

12 Q. Witness, you told us that you extended aid every day during 1992,

13 during the day frequently, that there were a large number of wounded. Can

14 you tell us whether the institution in which you worked was exposed to the

15 activities --

16 JUDGE ORIE: Yes, Ms. Mahindaratne.

17 MS. MAHINDARATNE: The witness did not use the word "every day."

18 This is a follow-up from --

19 JUDGE ORIE: Yes, what happens as a matter of fact is I invited

20 you to ask the witness to repeat what she said because it seems to be

21 important. I did not allow Mr. Piletta-Zanin to tell us what the witness

22 said. If it's really of that great importance you always could check us

23 during the break on the original tapes if you want to do that. But Ms.

24 Pilipovic, the only thing you now did is to repeat what -- in your answer

25 when you said: "Perhaps you do not understand me," were you're telling

1 that on a daily basis, you were assisted by those who had the APCs or did

2 you say that on a daily basis, you would go out and assist the wounded

3 people? What exactly did you say?

4 THE WITNESS: [Interpretation] Let me explain. Sometimes, it would

5 happen that there was a lot of shooting, so it was risky for us to go, so

6 we used the APC. And sometimes we were able alone with an ambulance to

7 reach a particular spot which wasn't so risky. Every place was risky, but

8 still, there were places that we could access the wounded. Is that what

9 you meant, Your Honour?

10 JUDGE ORIE: Yes. Let me just have a look.

11 Let me just seek to clarify the issue. You told us that sometimes

12 you used the ambulance when there was not intensive shooting, so you dared

13 to go without the assistance of the APCs. Could you tell us first for

14 1992, you told us that you would go out many times, two or three times a

15 day. Would that be usually with the APCs or usually with the ambulance,

16 or what would be the balance between the two?

17 THE WITNESS: [Interpretation] With both means. I beg your pardon.

18 May I explain.

19 JUDGE ORIE: Yes, please.

20 THE WITNESS: [Interpretation] -- What I consider to be important.

21 There was wounding every day. The position is such that we didn't know

22 exactly where the front lines were. We knew where the greatest risk was,

23 and when we were informed that we had a wounded person to attend to, if

24 there is a lot of shooting, then we had to request the assistance of an

25 APC if the person had been seriously wounded. Sometimes if the wounds

1 were not so serious, we would wait for the shooting to subside, and then

2 we would go to that position up to a point that we considered to be safe.

3 Have you understood me?

4 JUDGE ORIE: I did understand you. And then now for 1993, because

5 you told us that you went out not as frequent as in 1992. You told us for

6 1992 that it was many times, two, three times a day. What would be the

7 frequency in 1993?

8 THE WITNESS: [Interpretation] Sometimes there would be a pause for

9 one day, but there was wounding in 1993 and in 1994 and in 1995. I was in

10 Nedzarici until 1993. After that, I was in a hospital, and then I can

11 tell you about that period when I was in hospital.

12 JUDGE ORIE: Do I understand you well that you say it was on a

13 daily basis, although not on every single day, that you went out?

14 THE WITNESS: [Interpretation] Logically.

15 JUDGE ORIE: And how many times a day?

16 THE WITNESS: [Interpretation] Several times.

17 JUDGE ORIE: Several times. You said it was in 1993, it was less

18 frequent, not as frequent as in 1992. You told us that in 1992, it

19 was -- you said many times, and you also said two or three times a day.

20 Could you tell us how many times a day in 1993 on average?

21 THE WITNESS: [Interpretation] I can't answer in that way.

22 Whenever it was necessary. I cannot remember now how many times during

23 the day. I can't tell you how many times every day.

24 JUDGE ORIE: But you said not as frequent as in 1992. That is

25 correct?

1 THE WITNESS: [Interpretation] In 1993, our men were organised in a

2 slightly different manner because of the events that took place, they

3 could distinguish what was urgent and what was not urgent, in which

4 situations we could wait for the shooting to subside. Have I made myself

5 clear?

6 JUDGE ORIE: Yes, I think you did so. So my last question in this

7 respect, in 1993, would you also use both an ambulance, if possible, and

8 an APC, if necessary?

9 THE WITNESS: [Interpretation] We used the ambulance every day, and

10 the APC only when it was risky for us to go in an ambulance.

11 JUDGE ORIE: Yes, please proceed, Ms. Pilipovic.

12 MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

13 Q. Witness, before, we discussed this difference between 1992 and

14 1993, I asked you whether the building of the theology faculty was exposed

15 to what I would call "activities" of weapons.

16 A. Yes.

17 Q. When you say "yes," can you tell us from which positions and how

18 frequently the fire came? Do you know from which positions fire was

19 opened at the building in which you were?

20 A. I don't know that.

21 MS. MAHINDARATNE: Mr. President.

22 JUDGE ORIE: Yes.

23 MS. MAHINDARATNE: The witness never said the fire came. That is

24 an interpretation by the Defence counsel. Witness only said that the

25 building was exposed to activities. That's all.

1 JUDGE ORIE: Yes. And then Ms. -- Yes, what activities did you

2 have in mind apart from being exposed to fire coming from somewhere else?

3 MS. MAHINDARATNE: Mr. President, my objection is based on the

4 fact that it's leading. Perhaps the counsel should ask the witness.

5 JUDGE ORIE: Yes. I'm afraid that the trial would then take

6 another year. I think it's perfectly well asked. If there's a small

7 leading element in it, it's not something that could create -- that would

8 not influence the witness in such a way that it would be not acceptable.

9 Please proceed, Ms. Pilipovic.

10 MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

11 Q. Witness, did you say that you didn't know from which positions

12 fire was opened at the building in which you were?

13 A. Yes, that's what I said.

14 Q. Witness, do you have any knowledge or do you remember that a

15 certain point in time your building and you were photographed?

16 A. Yes.

17 Q. Did you personally own those photographs?

18 A. Yes.

19 MS. PILIPOVIC: [Interpretation] Your Honour, before I show the

20 witness these photographs, I should like to ask the witness to tell us, if

21 she can, when the building in which you were staying was photographed.

22 Q. That is, what is the date of those photographs?

23 A. 1992.

24 MS. PILIPOVIC: [Interpretation] Your Honour, the Defence, with

25 your permission, would like to show the witness these photographs that the

1 witness tells us are her own property, in her personal possession, and

2 that they were photographs taken in front of the building of the theology

3 faculty.

4 JUDGE ORIE: Ms. Pilipovic, I've no problem that you show the

5 photographs, but that you tell the witness already what she will testify

6 about the photographs is not -- you're going to tell us where they were

7 taken, et cetera. If you would just show the photographs and then put

8 questions to the witness.

9 MS. MAHINDARATNE: Mr. President, before that, if I may be

10 permitted to see the photographs because we have been given notice of

11 photographs. I wonder whether they are the same.

12 JUDGE ORIE: Yes, I take it that these are the same photographs

13 that you disclosed to the Prosecution, Ms. Pilipovic?

14 MS. MAHINDARATNE: Additionally, Mr. President, if I may point out

15 that in the 65 ter summary, there's no mention whatsoever of the

16 theology -- faculty of theology. In fact, the only mention is that of a

17 hospital in Nedzarici, Zica hospital. So this is completely new material.

18 JUDGE ORIE: Is there any mention of the faculty of theology in

19 any of the summaries, Ms. Pilipovic?

20 MS. PILIPOVIC: [Interpretation] Your Honour, in our summary, we

21 said that the witness was employed in the hospital as of 1993. But we did

22 notify the Prosecution, and the summary says that she was a member of the

23 Territorial Defence in the area in which she lived. And that she worked

24 as a nurse.

25 JUDGE ORIE: Yes. That's another word for an answer that is no,

1 isn't it? Ms. Pilipovic, the faculty of theology has played a

2 considerable role in the examination of many witnesses in this Court. It

3 would have been appropriate to mention that this witness has stayed in the

4 building for quite some time. That would have been appropriate in a

5 summary.

6 Let's just now first check whether the photographs are the same. I

7 take it -- when did you receive these photographs?

8 MS. MAHINDARATNE: Two days ago, Mr. President, when this witness

9 was supposed to come.

10 JUDGE ORIE: Yes.

11 MS. MAHINDARATNE: Yes, Mr. President, we have received them.

12 JUDGE ORIE: Yes, please proceed.

13 Perhaps we should -- would you please take it from the ELMO. And

14 Ms. Pilipovic, if you asked for facial distortion, it's --

15 MS. PILIPOVIC: [Interpretation] Yes, Your Honour, could we go into

16 private session.

17 JUDGE ORIE: Yes, we can turn into closed session. And may we

18 have a redaction for the, especially for the video. It did not go on the

19 ELMO.

20 Private session will do.

21 [Private session]

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17 [Open session]

18 JUDGE ORIE: We are in open session. We'll adjourn until 11.00.

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

20 --- On resuming at 11.03 a.m.

21 JUDGE ORIE: Before we continue, and in order to avoid whatever

22 confusion, where the English transcript, before the break, talks about

23 motors and motor crews near to the faculty of theology, it should be

24 mortars.

25 Please proceed, Ms. Pilipovic.

1 MS. PILIPOVIC: [Interpretation] Your Honour, my colleague will

2 continue with this witness.

3 JUDGE ORIE: Mr. Piletta-Zanin --

4 MR. PILETTA-ZANIN: [Interpretation] If I have your permission,

5 thank you, Mr. President.

6 Examined by Mr. Piletta-Zanin:

7 Q. Madam Witness, good morning.

8 A. Good morning.

9 Q. Could you please tell us, if you know, a little about the

10 cooperation between your service and the UN forces. What do you know

11 about it? What could you tell us about that, please?

12 A. I told you that in the initial period in 1992, that is, from the

13 moment I was engaged, in the vicinity of the hospital, there was no

14 institution for surgeries in April 1992. At the end of April 1992, the

15 Zica hospital was formed but it didn't have a surgery theater. So that

16 when we judged a patient to be serious, we had to cross the airport runway

17 to go to the Kasindol hospital. At first, we crossed normally because at

18 first, I don't know until when, the Serbs were at the airport. Later,

19 foreigners arrived at the airport, and they had control over it. And we

20 would inform them - I don't know who exactly - that we had a serious

21 patient. We would go to the entrance to the runway. We would report to

22 them. They would have to examine -- look at the patient and judge for

23 themselves what kind of patient he was, and then they would give us

24 permission to cross the runway. We were often accompanied by an APC until

25 we left the runway, and then we would enter an area like a neutral area, a

1 no man's land, I suppose. I do know that on -- the Serbs were on one side

2 and the Muslims were on the other. And then we would drive the patient to

3 the Kasindol hospital.

4 Q. Thank you. Regarding the use of this neutral area, when you were

5 entering with your vehicles, were there any incidents? And if yes, can

6 you tell us anything about them briefly.

7 A. The first time I crossed the area, that is, the runway, I know the

8 man -- the name of the man. I shall never forget that. His name was

9 Klimenta Dusan. And as we were crossing, the Serb forces I think were

10 still there. I'm not sure. This was in the month of May. And they opened

11 fire at our vehicle. So that night, we didn't dare return. It was

12 already dark.

13 Q. I'll stop you there. Thank you very much. Was your vehicle hit

14 by the shots; yes or no?

15 A. Yes, it was.

16 Q. Thank you. Were you able to establish, judging by the side from

17 which those shots came and hit the vehicle, where they were coming from?

18 A. From the right-hand side.

19 Q. Was there a village or a district to the right of your vehicle at

20 the time of the shots?

21 A. The Butmir district.

22 Q. Thank you very much. Do you know what type of weapon was used to

23 fire at you, as medical personnel, while you were at the airport?

24 MS. MAHINDARATNE: Mr. President --

25 A. I don't.

1 JUDGE ORIE: Yes.

2 MS. MAHINDARATNE: No evidence has been led that the vehicle was

3 marked as a medical vehicle.

4 JUDGE ORIE: The question reads: "Do you know what type of weapon

5 was used to fire at you, as medical personnel?" Perhaps it might be

6 unclear. Perhaps you could ask the witness first whether the car was

7 recognisable as -- by any sign that it was transporting wounded.

8 MR. PILETTA-ZANIN: [Interpretation] Yes.

9 Q. Witness, you spoke to us a moment ago -- no, I'll withdraw that.

10 The time that those shots were fired, was there any sign on your APC or

11 whatever it was that could identify it as a medical vehicle; yes or no?

12 A. We were crossing using an ambulance. We were crossing the airport

13 in an ambulance. And all our ambulances, whether they were improvised or

14 not, always bore the Red Cross mark on them. Sometimes in the form of a

15 flag --

16 Q. Thank you very much. For reasons of time, I'm interrupting you.

17 You have answered the question, but I would still like you to be more

18 precise. Later, after this attack, nobody was able to establish by the

19 calibre of the holes, if any, what kind of weapon was used from Butmir.

20 Yes or no?

21 MS. MAHINDARATNE: Leading question, Mr. President.

22 JUDGE ORIE: Mr. Piletta-Zanin, I hardly have ever seen --

23 MR. PILETTA-ZANIN: [Interpretation] I will rephrase it.

24 JUDGE ORIE: -- Yes, but would you also refrain from doing it

25 because it's of no use to first put a leading question to the witness and

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1 then to rephrase it because the damage has been done then already.

2 Yes, perhaps I would...

3 An earlier question to you was, Ms. DP7, whether you knew what

4 weapon was used when you were driving on the runway of the airport from

5 the Butmir area.

6 THE WITNESS: [Interpretation] Your Honour, we just felt it whiz,

7 the bullet whizzing past, but what kind of bullet it was I really don't

8 know. It was sufficient for us to hide and to accelerate and move on,

9 full speed. And because of this incident, we didn't dare return that same

10 night across the runway.

11 JUDGE ORIE: Yes. Did it hit the car, or you said you heard it

12 whiz while passing by the car. Was the car hit or was the car not hit?

13 THE WITNESS: [Interpretation] The vehicle was hit. The glass

14 broke into tiny pieces. And when we left, we could see the holes in the

15 vehicle. But what kind of weapon, I don't know.

16 JUDGE ORIE: Yes. Please, then, move to your next subject,

17 Mr. Piletta-Zanin.

18 MR. PILETTA-ZANIN: [Interpretation] Thank you very much.

19 Q. Just another question to make things quite clear: Do you know at

20 the time who held the Butmir village?

21 A. Yes.

22 Q. Could you tell us who it was?

23 A. Muslim soldiers.

24 Q. Still talking about -- no, we'll come to that later.

25 Madam Witness, in the area of Nedzarici, did you know of an institution

1 that was known as an old people's home, Dom Staraca in Serbian?

2 A. Yes.

3 Q. Do you know where it was situated?

4 A. The old people's home was close to the school I attended for four

5 years.

6 JUDGE ORIE: Yes, Ms. Mahindaratne.

7 MS. MAHINDARATNE: Mr. President, in the 65 ter summary, there is

8 no reference to the old people's home either. So -- or the school. This

9 is all new material which has not been -- we have not been given notice of

10 this evidence.

11 JUDGE ORIE: Yes. Before --

12 MR. PILETTA-ZANIN: [Interpretation] Mr. President --

13 JUDGE ORIE: Is my understanding correct that we discussed at

14 least a couple of days ago, I think it was approximately one week ago, an

15 article in direct relation to the old people's home and of which we --

16 MR. PILETTA-ZANIN: [Interpretation] Mr. President.

17 JUDGE ORIE: Yes.

18 MR. PILETTA-ZANIN: [Interpretation] I would like to clarify this

19 type of problem for the last time. I've already spoken of this, and the

20 next time I will appeal to the presidency of the newly formed association

21 of attorneys. In English, we would like to inform you, et cetera, that

22 this witness will, yes, this witness will testify on the presence of

23 UNPROFOR forces at Nedzarici. We know where they were before the 3rd of

24 September, 1993. This was the subject of an animated debate in this

25 courtroom. If we are now told that the text is not clear even though we

1 mentioned this, this is false, once again. And the next time, I will

2 appeal to the representative of the attorneys' association because this

3 cannot continue in this way.

4 JUDGE ORIE: Mr. Piletta-Zanin, strong words do not necessarily

5 make strong arguments. So to whom you're going to appeal, this Chamber

6 will wait and see if it is -- if it does concern us.

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 [redacted]

12 [redacted]

13 [redacted]

14 The objection is denied.

15 May I -- your argument was not that it was said at a late stage;

16 the argument was that you were not informed about it. That is as far as I

17 can see in a letter of the 2nd of November, not true. So please, would

18 you continue, Mr. Piletta-Zanin.

19 MR. IERACE: Mr. President, might I have the opportunity to

20 respond to that. Excuse me.

21 Mr. President, we don't have that letter. I have a letter of the

22 3rd of November, which states that this witness will testify about the

23 presence of UNPROFOR forces in Nedzarici and in collaboration with

24 them -- excuse me, Mr. President.

25 [Prosecution counsel confer]

1 MR. IERACE: I correct myself, Mr. President. We do have that

2 letter. I apologise.

3 JUDGE ORIE: Then, yes --

4 MR. PILETTA-ZANIN: [Interpretation] Mr. President, I should like

5 to intervene, please.

6 JUDGE ORIE: Yes.

7 MR. PILETTA-ZANIN: [Interpretation] I should like to intervene,

8 Mr. President. This is not the first time --

9 JUDGE ORIE: Mr. Piletta-Zanin, I am not -- it's perfectly clear

10 that if an objection is based on a letter which has been sent to the

11 Prosecution and if the objection is based on absence of knowledge of the

12 content of that letter and if the next thing is that the Prosecution says

13 that they did not receive that letter, and has to correct itself one

14 minute later, then we lost a couple of minutes. I would say approximately

15 the same number of minutes we lost yesterday when there was an objection

16 which did find no basis in the transcript. It's up to me, then, to tell

17 the Prosecution that this is a waste of time, just as it was a waste of

18 time yesterday. The most important thing is that this will not happen,

19 not by any party, and we'll now continue with the testimony of this

20 witness. And there's no use in one party using, although it might be

21 fairly justified under these circumstances, using strong words against the

22 other.

23 Please proceed. It's the Chamber who expressed the words just

24 spoken. Please proceed.

25 MR. PILETTA-ZANIN: [Interpretation] Thank you, Mr. President.

1 Thank you very much.

2 Q. Madam Witness, I should like to come back to the question that I

3 raised. Where was this institution? You answered "next to your school."

4 But in order to localise it, could you please give us the name of the

5 street that we know that we're talking about the same thing.

6 A. I don't know the exact name of the street but I do know where it

7 is situated.

8 Q. Very well. Could you tell us whether it is situated to the south

9 of Nedzarici, in the north of Nedzarici, or maybe close to this or that

10 district that you're familiar with, facing such and such a district?

11 A. We would come from our institution, that is, from the faculty of

12 theology --

13 Q. No, let me interrupt you. Do you know whether this institution

14 for the elderly was facing a particular district; and if so, which one?

15 A. Close by was the institute for blind children.

16 Q. Very well. Thank you very much. In relation to this institute

17 for the elderly, and if you know, could you tell us which -- what was the

18 ethnicity of the people there on the assumption that they were still there

19 when you were staying in Nedzarici?

20 A. There were people, old people, of all ethnicities were housed

21 there. There were old people, but there were a couple who were younger

22 that I met during the war.

23 Q. Thank you. Madam Witness, do you know whether this institution

24 was used for any other purposes than to provide accommodation for the

25 elderly?

1 A. I don't know.

2 Q. Do you know whether international institutions were able to visit

3 this location? I'm specifically referring to UNPROFOR.

4 A. I do know. We would see them frequently as the trucks, large

5 trucks, would arrive. And I assume they were delivering food and

6 medicines to them.

7 Q. Do you know whether these people from UNPROFOR used that building

8 for other purposes than to provide humanitarian aid?

9 A. I do know that they checked what was happening in our district,

10 that they were controlling what was happening in our district.

11 Q. Very well. When you told us that they controlled what was

12 happening in your district, did you ever hear or see a delegation of the

13 UN forces come to the convent or the theology faculty to protest?

14 A. I don't know that.

15 Q. When you tell us that you don't know, does that mean that you

16 never heard of it or that you have no knowledge of it?

17 MS. MAHINDARATNE: Mr. President, I object.

18 JUDGE ORIE: Yes.

19 MS. MAHINDARATNE: The witness has answered "I don't know." And

20 thereafter, it's not fair for the Defence counsel to ask the witness to

21 elaborate on that question further.

22 JUDGE ORIE: Well, we usually allow, if the answer is "I don't

23 know that" to see whether this is positive knowledge of nonoccurrence, or

24 whether this is just ignorance on whether it happened. Let me just, if I

25 would ask you, whether it was raining this morning and you say "I don't

1 know," then it depends on whether you have been outdoors and have been

2 able to observe whether it was raining or not, or that you just didn't

3 notice -- well, there are different ways of saying I don't know. So we

4 always accept it that the next question could be to have been confirmed

5 whether it's positive knowledge of nonoccurrence or that it's just lack of

6 knowledge whether it occurred or not.

7 Please proceed.

8 MR. PILETTA-ZANIN: [Interpretation] Thank you, Mr. President.

9 JUDGE ORIE: My example was not a very good one, but I'll find out

10 a better one if you need one. Please proceed.

11 MR. PILETTA-ZANIN: [Interpretation]

12 Q. Witness, I will put the same question slightly differently, and

13 perhaps you can give me a yes or no answer. Did you ever hear that

14 protests were formulated by these UN forces while you were staying at the

15 theology faculty; yes or no?

16 A. No.

17 Q. Thank you very much.

18 MR. PILETTA-ZANIN: [Interpretation] Could we now place on the

19 ELMO, in agreement with the Prosecution, Mr. President, the photographs

20 from Exhibit P3274, and we can begin the one -- the last figures being 95,

21 of which the last figures are 95. It relates to incident 22 on which both

22 parties have already discussed, which both parties have discussed.

23 Could we focus on the spot where the arrow is, please. Thank you

24 very much.

25 Q. Witness, to your right, there is a photograph. My first question

1 is: Do you recognise this spot? Yes or no.

2 A. Yes.

3 Q. Thank you very much. Witness, do you recognise, more

4 specifically, the buildings, the small houses appearing right beneath the

5 arrow in the middle of the photograph? Yes or no.

6 A. Yes.

7 Q. Thank you. Witness, those houses, could you tell this Chamber at

8 the time of the events, that is, at the time of the war, which party had

9 control of them? In whose hands was it?

10 [redacted]

11 [redacted]

12 [redacted]

13 Q. I'm very grateful. I will be grateful not to tell us anything at

14 all that relates to your own personal experiences.

15 Very well. Thank you. Witness, with the topographical knowledge

16 that you have, I'd like to ask you the following question: Do you know or

17 do you recognise the location from which this photograph may have been

18 taken? The intersection in the foreground of the picture; yes or no.

19 A. This part, towards the arrow --

20 Q. Witness, I apologise. If you can recognise it, just say yes or

21 no. If you can, just say yes. If you can't, then say no.

22 A. Yes.

23 Q. Thank you very much. Witness, now this is the question, and I'd

24 like you to focus because I believe that you could answer with a yes or

25 no. From the background of the photographs, so I'm saying the background

1 of the photograph, behind the line or the lines of small houses that we

2 see in the background, was it possible, according to your knowledge of

3 this area, to fire horizontally with a rifle, for instance, and to hit the

4 intersection that we see in the foreground of the photograph; yes or no?

5 A. No.

6 Q. Thank you very much. Why, why was this a direct hit not possible

7 as we say, according to your knowledge of the area?

8 A. These houses belonged to Muslims. And much further behind were

9 Serb houses that went as a kind of on a slope. They were lower than these

10 houses here.

11 Q. Thank you very much. Madam, close to the arrow that you have in

12 the centre of the photograph, is there any facility, symbolic, cultural,

13 anything like that at all, religious?

14 A. Yes, there is a mosque.

15 Q. What do you know about this mosque during the war? I'm talking

16 about possible -- probable destruction or no destruction in relation to

17 the mosque. What do you know about it?

18 A. I don't know about it.

19 Q. Thank you very much.

20 MR. PILETTA-ZANIN: [Interpretation] No further questions -- no,

21 just a moment. Yes, very last question.

22 Q. Witness, could you please tell us if you know how many civilians,

23 as far as you know, were in the area that you covered suffered -- were

24 wounded, were physically hit by -- during the operations, war operations?

25 A. Civilians, well, I don't know the exact number, but I know there

1 were many.

2 Q. When you say "many," could you please -- no, I'll rephrase. When

3 you say "many," could you give us any information about the location where

4 these persons were wounded? Was this, for instance, near a confrontation

5 line or more in the rear?

6 A. In the rear.

7 MR. PILETTA-ZANIN: [Interpretation] No further questions. Thank

8 you.

9 JUDGE ORIE: Thank you, Mr. Piletta-Zanin.

10 Ms. Mahindaratne, is the Prosecution ready to cross-examine the

11 witness?

12 MS. MAHINDARATNE: Yes, Mr. President.

13 JUDGE ORIE: Please proceed.

14 Cross-examined by Ms. Mahindaratne:

15 MS. MAHINDARATNE: The photographs may be left with the witness

16 for a moment. Mr. President, with the permission, may the witness be

17 shown photograph C of the same series.

18 JUDGE ORIE: Of the same sequence. Could the other photograph be

19 returned -- or do you need that as well?

20 MS. MAHINDARATNE: Yes, Mr. President.

21 JUDGE ORIE: Okay.

22 MS. MAHINDARATNE:

23 Q. Madam, you have two photographs before you. Do you agree that

24 photograph numbered C is a close-up of photograph numbered B?

25 A. Yes.

1 Q. Now, if you examine the two houses you can see in photograph C,

2 would you agree that they are the very same houses which are below the

3 arrow on photograph number B? Madam, I'm referring to those two little

4 houses below the arrow in photograph number B. Are they the very same as

5 those big houses in photograph number C, those two houses?

6 A. I don't know. I can't understand where the arrow is.

7 Q. If you examine photograph numbered B, you will see an arrow, black

8 arrow.

9 A. I can see it.

10 Q. There are two houses, small houses, below that arrow. Could you

11 see that?

12 A. This part here? You mean this part here?

13 Q. Yes.

14 A. Yes. This is an arrow which shows, points --

15 JUDGE ORIE: Could the photograph, if the witness points at a

16 certain part of the photograph, it should be put on the ELMO so that we

17 can see where she points at.

18 THE WITNESS: [Interpretation] I'm sorry. I'm not quite certain

19 what you mean. Do you mean these houses here?

20 MS. MAHINDARATNE:

21 Q. Yes, these two houses below the arrow. If you just place your

22 pointer on those two very small houses you see below the black arrow.

23 Yes, I'm referring to those two houses.

24 A. These ones here. These are houses that belonged to Muslims.

25 Q. Yes, that is right. Now, if you examine photograph number C,

1 which is a close-up of the same picture, you will see those two same

2 houses bigger than in photograph number B. If you could perhaps --

3 A. Yes.

4 Q. -- Place that photograph on the ELMO.

5 JUDGE ORIE: It is on the ELMO.

6 MS. MAHINDARATNE:

7 Q. You agree they are the same houses?

8 A. Yes.

9 Q. Do you know when those two houses were built?

10 A. In which period of time? I don't know.

11 Q. Were those two houses there during the period September 1992 to

12 August 1994?

13 A. I did not go down there to look at these houses. I really don't

14 know. I know there was a smaller house. Whether this was rebuilt, I

15 really don't know. Whether it had had an extension put on, I really don't

16 know.

17 Q. Madam, were you there during this period? [redacted]

18 [redacted]

19 [redacted]

20 [redacted]

21 [redacted]

22 [redacted]

23 [redacted]

24 [redacted]

25 [redacted]

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 Please proceed, Ms. Mahindaratne.

8 MS. MAHINDARATNE: The photographs may be returned, Mr. President.

9 No, if it can be kept there for a moment. Thank you.

10 Q. Madam, if you look from that position into the distance, would you

11 agree that you would be looking down that street towards the direction of

12 Nedzarici?

13 A. No, I wouldn't agree with you. It's a view towards the houses at

14 the airport settlement. They were part of the Nedzarici district, but

15 they were separated by water. It is more towards the settlement across

16 the water. [redacted]

17 [redacted]

18 [redacted]

19 [redacted]

20 JUDGE ORIE: I don't know. This street is not in relation to your

21 identity as far as I'm aware of. But, Ms. Mahindaratne, perhaps we should

22 clarify that there's no misunderstanding whatsoever as to whether the

23 witness recognises the exact locations that appear on this photograph.

24 MS. MAHINDARATNE:

25 Q. Madam, could you identify this particular area? When you said you

1 did identify this area, what is this street? You testified about this

2 area in your examination-in-chief. What is this street? What is the name

3 of this street?

4 A. This is Roza Hadzivukovic Street.

5 MR. PILETTA-ZANIN: [Interpretation] Mr. President, bearing in mind

6 the previous answer of the witness, and I'm going to check it, [redacted]

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 [redacted]

12 [redacted]

13 [redacted]

14 MS. MAHINDARATNE: Mr. President, I will not pursue this line of

15 questioning. I will move on to another subject.

16 JUDGE ORIE: Yes, please do so.

17 MS. MAHINDARATNE:

18 Q. Madam, earlier you said that your knowledge of English was very

19 little, to use your own words. Is that correct?

20 A. Yes.

21 Q. When you say "very little" would you be able to communicate in

22 English with an English-speaking person, a person who speaks in English?

23 A. Not well. Perhaps I would be able to understand a word or two and

24 then perhaps if it is a very short question, I could answer.

25 MS. MAHINDARATNE: Mr. President, I withdraw that question. I'm

1 sorry, I don't intend to pursue this particular line of questions either.

2 JUDGE ORIE: Please proceed to your next subject,

3 Ms. Mahindaratne.

4 MS. MAHINDARATNE: Mr. President, Mr. Ierace will take over from

5 this point.

6 JUDGE ORIE: Yes. Mr. Ierace.

7 MR. IERACE: Thank you, Mr. President.

8 Cross-examined by Mr. Ierace:

9 Q. Madam, had you been to the institute of theology before the war?

10 A. Before the war, yes.

11 Q. Had you been inside any of the buildings before the war?

12 A. Faculty of theology had a library which was accessible to all the

13 citizens, particularly those who went to that school, citizens of all

14 ethnic background. And we were all able to have a membership card and to

15 use the books from the library.

16 Q. I take it you had a membership card and you used the library, is

17 that correct, before the war?

18 A. I don't remember. I went to the library, yes.

19 Q. Well, there were some 50.000 books in that library, weren't there?

20 A. Yes.

21 Q. Is it correct to say that the complex of the institute consisted

22 of four buildings?

23 A. I can make a drawing of what the convent looked like, if you want.

24 Q. Yes, that would be good.

25 A. There was a complex --

1 MR. IERACE: Mr. President, perhaps the witness could be given a

2 sheet of paper and a pen.

3 JUDGE ORIE: Yes. Mr. Usher, you certainly have a piece of paper.

4 I take it that you'll invite her to draw something. If that could be done

5 on the ELMO, that would be preferable. Please proceed.

6 MR. IERACE: All right.

7 Q. Now, firstly, do you agree that there were four buildings?

8 A. I will clarify, and then you can establish whether it's true or

9 not. Is that okay?

10 Q. Yes, that's fine.

11 A. This is the entrance that you went in through the gate. This was

12 the main entrance gate. It was like a corridor, like a hallway. From

13 that part, this was a slightly higher building. You went into that

14 building. And this part here went this way. And it was a lower building.

15 This is where the exit was where we sat. Now, from this large part, there

16 was a hallway, a corridor, which was a second part. The back part and the

17 front part. So this part in the middle was empty. That was a garden. On

18 the side where some other facilities -- ancillary facilities. Is that

19 okay?

20 Q. Yes, that's good. Now, one of those buildings was essentially

21 accommodation for the students. Is that correct?

22 A. If you mean the lower building -- no, the taller building, the

23 higher building was the one for students, and the lower building, as far

24 as I know, because I was in one of the rooms, I think that used to belong

25 to the lecturers of this faculty and during the war it burnt down.

1 Q. All right. If you possibly could keep your answers as short as

2 you can, I would appreciate it because we don't have much time. Have you

3 shown on the diagram the tallest --

4 A. Very well.

5 Q. -- Building that had the accommodation? Is that already on the

6 diagram?

7 A. Yes. The taller building faced the Vojnicko Polje. You

8 understand?

9 Q. All right. Could you please point to it with the pointer on the

10 diagram.

11 A. This is the taller building.

12 Q. Don't mark anything yet.

13 JUDGE ORIE: Yes. Could you please carefully listen. If you're

14 asked to point at something, do it with the pointer. And if you're asked

15 to mark something or to draw something, do it then with the pen. Yes,

16 please.

17 MR. IERACE:

18 Q. I think you told us that you --

19 MR. IERACE: I'll withdraw that.

20 Q. Was that a four-storey building?

21 A. No. Three storeys.

22 Q. Do you mean a ground floor with three storeys on top or do you

23 mean a ground floor with two storeys on top?

24 A. Ground floor, had a kind of mezzanine, and it was like a one

25 floor. I think there were three floors -- three storeys. We didn't go

1 all the way up, to that part we didn't go much.

2 Q. Please listen to the question. Do you mean ground floor, and then

3 above the ground floor, another three storeys? Or if you don't know

4 because you didn't go up, then just tell us that.

5 JUDGE ORIE: Perhaps the witness is not aware of the difference,

6 the whole system of the ground floors.

7 There are two different ways of expressing yourself. If you say a

8 three-storey building, some people mean to say that there's a ground floor

9 and then three storeys up. Other people use that term for indicating that

10 there was a building with one ground floor and then two storeys up. So if

11 you say a three-storey building, was it a ground floor plus three or was

12 it a ground floor plus two?

13 THE WITNESS: [Interpretation] Three storeys, the building had

14 three floors. Believe me, I didn't count the storeys. I didn't go all

15 the way up. I know it's a taller building compared to the one where we

16 were. You understand?

17 JUDGE ORIE: Yes.

18 MR. IERACE: All right. That will do.

19 Q. Would you please place the letter A inside that building, the one

20 we have just been discussing, on the diagram.

21 A. [Marks] It's this part here.

22 Q. Thank you for that. Now, was there another building which

23 contained the kitchen?

24 A. Kitchen?

25 Q. Please place a K inside that building, after you have drawn it.

1 A. I didn't draw this very well.

2 Q. That's all right. Did that building have just a ground floor, or

3 did it have more floors on top of the ground floor?

4 A. There was another floor.

5 Q. All right. Now, was there a building which had in it a church and

6 theatre?

7 A. No.

8 Q. You said earlier, I think, that there was a building which had a

9 room in it where the lectures were. Did you say that?

10 A. No, I didn't say that.

11 Q. I'm sorry, all right. Was there a building which seemed to have,

12 before the war, accommodated the teachers?

13 A. Yes.

14 Q. All right. Would you please place inside that building, if it

15 already appears in the sketch, the letter B.

16 A. [Marks]

17 Q. Now, I think there is another building between the A and the K on

18 the sketch. What was inside that building? What was it used for before

19 the war, if you know?

20 A. In that part, this lower part, there was an amphitheatre.

21 Q. An amphitheatre. All right. Do you know if there was a chapel in

22 that building before the war?

23 A. I don't know. But I do know that -- may I? May I clarify

24 something.

25 JUDGE ORIE: Yes.

1 THE WITNESS: [Interpretation] In respect to this question. But

2 there was a room on the side of the building, somewhere around here, the

3 one that I'm drawing just now. And it was one room that we, in the

4 beginning, used when we had a dead person. And this is where we would

5 prepare him, wash him, and then he would be transported to the Vlakovo

6 cemetery. So this may have been a chapel before the war; I don't know.

7 MR. IERACE:

8 Q. All right. In the building which had the amphitheatre, please

9 place the letter C.

10 A. [Marks].

11 MR. IERACE: And whilst that's being done, may I ask the

12 Madam Registrar to prepare to be shown to the witness photograph P3279T,

13 and the ERN ending in the number and letter 3A.

14 Q. Thank you for that. Now, there was a courtyard in the middle of

15 those buildings. Is that correct?

16 A. Yes.

17 Q. By the time you arrived in the faculty, I think you said that was

18 around April of 1992, is that correct, that you arrived?

19 A. No. That was the end of May, but I couldn't tell you the exact

20 date.

21 Q. All right. Were the books there in the library?

22 A. I don't know that.

23 MR. PILETTA-ZANIN: [Interpretation] Mr. President, I object to

24 this question. I really don't see the relevance of this. First of all,

25 there were 50.000 works, and now whether to find out whether the books are

1 in order on the shelves. I really don't see the relevance of the

2 Prosecution's question. Thank you.

3 JUDGE ORIE: The question has been put and the question has been

4 answered, but if you could inform us about the relevance, Mr. Ierace.

5 MR. IERACE: Mr. President, perhaps it could be done in the

6 absence of the witness.

7 JUDGE ORIE: Yes, if it's -- I'd rather -- will you continue in

8 this line, because then we have to deal with it now.

9 MR. IERACE: No.

10 JUDGE ORIE: We'll perhaps hear from you later and there's no use

11 to ask the witness to leave the courtroom at this very moment. So please

12 proceed.

13 MR. IERACE: Thank you.

14 Q. The institute was a Catholic educational institution, wasn't it?

15 A. Yes.

16 Q. If you don't know this, please tell me. It was of the Franciscan

17 order of the Catholic church. Is that correct?

18 A. I don't know. I don't know what they were called. It was a

19 faculty of theology. That's how we called it.

20 MR. IERACE: All right. Might the photograph be shown to the

21 witness, if Madam Registrar has it.

22 JUDGE ORIE: Yes, Mr. Usher, could you please assist.

23 THE REGISTRAR: P3279T, with the ERN ending 3A?

24 MR. IERACE: Yes. Could the photograph be placed on the ELMO.

25 Q. In the photograph before you, do you recognise the institute as it

1 appeared after the war?

2 A. I'm sorry, I didn't understand the question.

3 Q. In the photograph, in the photograph, do you see the institute?

4 That is, the faculty of theology, or the institute of theology?

5 A. [Indicates]

6 Q. Thank you.

7 MR. IERACE: The witness now points to the white building

8 one-third down the middle of the photograph.

9 Q. Which of the buildings is that, having regard to the sketch that

10 you've given us?

11 A. It is the highest building, the one with three storeys.

12 Q. And on your sketch, I think you indicated that with the letter A.

13 Is that correct?

14 A. Yes, that's it.

15 Q. All right. Now, is the height of the building, as best you can

16 tell, as it appears in the photograph, the height of the building as it

17 was when you first arrived at the institute after the war commenced?

18 A. I don't understand what you're saying, what you really mean.

19 Whether it was enlarged, expanded or not, was that your question?

20 Q. No.

21 MR. IERACE: I'll withdraw that question.

22 Q. Was that building damaged while you were there? And I think you

23 said you were there until sometime in 1993.

24 A. Yes.

25 Q. Was it damaged by shells, do you know?

1 A. Yes.

2 Q. And did the shells damage the wall that we can see in the

3 photograph? If you don't know, please say so.

4 A. I don't know whether that part was damaged by them.

5 Q. Was there any damage done to the roof of the building, do you

6 know, that is, this particular building?

7 A. I never climbed up. I didn't go to that part of the building.

8 Q. All right. But in which of the buildings did you spend most of

9 your time, having regard to the sketch that you've done? Was it A, B, C,

10 or K?

11 A. In building B and building K, and on the ground floor of building

12 B and in the basement of the whole building.

13 Q. All right. Which side of the complex or which corner of the

14 complex -- I withdraw that. Are you familiar with the -- I'll withdraw

15 that.

16 Are you able to tell us which side or corner of the building faced

17 towards the old people's home?

18 A. Side A, towards the old people's home. Is that what you're

19 asking? No, I'm afraid I don't understand your question.

20 Q. Okay. The buildings roughly form a squarish shape with a

21 courtyard in the middle. I want to get some idea of the direction of the

22 building as it appears on the sketch. Are you familiar with the points of

23 the compass in terms of how the building was laid out? Can you tell us,

24 for instance, which side or corner of the building faced north?

25 MR. PILETTA-ZANIN: [Interpretation] Objection, Mr. President.

1 JUDGE ORIE: Yes.

2 MR. PILETTA-ZANIN: [Interpretation] The testimony of the witness a

3 moment ago was that she was unable to find her bearings in relation to

4 north, south, et cetera. I think that is what she said.

5 JUDGE ORIE: Let's just see whether we can -- if you look at your

6 sketch, and if you wanted to look at the home for the elderly people, in

7 which direction on this sketch you would have to look? Could you please

8 point to that direction with the pointer.

9 THE WITNESS: [Indicates]

10 JUDGE ORIE: Yes, that's from the building from where you were

11 looking. But then you can look either this way or this way. From what

12 direction from this building would you look in order to see the home of

13 the elderly people?

14 THE WITNESS: [Interpretation] Slightly to the left. It would be

15 facing somewhere here like that. In the direction of that building.

16 JUDGE ORIE: The building is pointing from the building with a

17 letter A in it --

18 MR. IERACE: Perhaps an arrow might help.

19 JUDGE ORIE: Yes, could you please put an arrow there, how you

20 would have to look if -- what you just indicated with the pointer, could

21 you please make an arrow in that direction you just indicated.

22 MR. IERACE: All right. Thank you for that.

23 Q. Now, please look at building K. That's the building that you told

24 us earlier had the accommodation for the teachers. Was that a building

25 which had a ground floor and one floor above it?

1 A. I said that the teachers were accommodated in building B. And as

2 for building K, I don't know who was accommodated there. There were small

3 rooms, and who was staying there, I don't know.

4 Q. You're quite right. I apologise for that. Yes, building B. Did

5 that have a ground floor -- I'm sorry. Did that have a ground floor and

6 one floor above the ground floor, building B?

7 A. Yes.

8 Q. Have you seen the institute since the war ended?

9 A. I'm sorry, which institute are you referring to? Did I see the

10 building?

11 Q. Yes, these buildings, the faculty of theology or the institute of

12 theology.

13 A. Since the end of the war, only when I was passing through towards

14 the Stup intersection I might see a corner of it. But I didn't go inside.

15 It wasn't on my way.

16 Q. All right. I suggest to you that building B, since the war, has

17 had a floor added to it. If you don't know, that's fine. Just tell us.

18 A. I don't know.

19 Q. All right. Now, have you heard of the term "White Eagles,"

20 referring to an element of the Bosnian Serb army?

21 A. I've heard from the media. After the war, in articles after the

22 war -- may I continue. But during the war, we didn't have electricity.

23 We didn't have water.

24 Q. So are you saying that you hadn't heard of the White Eagles until

25 after the war? Is that what you're saying?

1 A. No, I didn't say that. I heard of the White Eagles, but what kind

2 of units they were, I don't know.

3 Q. Okay. You've told us that you arrived at the faculty of theology

4 in May. You think you said late May. Is it possible that you're mistaken

5 about the time and that, in fact, it was after -- sometime after the 8th

6 of June, 1992?

7 A. No.

8 Q. I suggest -- well, first of all, you've mentioned a basement in

9 one of the buildings. In fact, did all of the four buildings have

10 basements?

11 A. Yes.

12 Q. I suggest to you that on the 8th of June, 1992, the Serb army

13 occupied the building and detained staff in the basement for 30 hours.

14 What do you say about that?

15 A. I don't know anything about that. I do know, when we arrived at

16 that building, the building was empty.

17 Q. Again, I ask you, are you absolutely positive that you were there

18 from May of 1992, or could it have been --

19 MR. PILETTA-ZANIN: [Interpretation] Mr. President.

20 MR. IERACE: [Previous translation continues]... finish the

21 question.

22 JUDGE ORIE: Yes, first finish the question, and then wait to

23 answer that question.

24 MR. IERACE:

25 Q. Are you absolutely positive that you were there from sometime in

1 May 1992, and that it wasn't sometime after the 8th of June, 1992, that

2 you arrived? That's the question.

3 MR. PILETTA-ZANIN: [Interpretation] Mr. President.

4 JUDGE ORIE: Yes.

5 MR. PILETTA-ZANIN: [Interpretation] Objection. The witness has

6 answered very clearly to the question, "would it be possible that," she

7 answered very clearly. And to repeat the question seems to me contrary to

8 the principles of courtesy that we need to respect in this Chamber, in

9 this courtroom. I'm sorry.

10 JUDGE ORIE: May I ask the witness to leave the courtroom for a

11 second.

12 [The witness stands down]

13 JUDGE ORIE: Mr. Ierace, usually if a question is put to a witness

14 and it has been answered, there's no need to repeat that. So I take it

15 that you have a specific reason why you again want to put the same

16 question to the witness. Could you please explain.

17 MR. IERACE: Yes, Mr. President. It essentially involves Rule 90.

18 We have cause for inquiries to be made since we became aware of the role

19 of the institute in the Defence case. And what I am putting to the

20 witness are the fruits of our inquiries. I anticipate that in due course,

21 we will have a statement from a relevant witness with photographs which

22 will be served on the Defence and we will seek leave to call this witness

23 in -- at the appropriate time, in the case in rebuttal by the Prosecution.

24 It's incumbent upon me to put what I'm aware of at this stage to the

25 witness as to what that evidence might be. And I'm simply giving out of

1 fairness an opportunity to the witness to reconsider her evidence on when

2 it was that she arrived there. She has told us that whenever it was, the

3 staff had left, and therefore there's a conflict between my information

4 and her evidence so far.

5 JUDGE ORIE: Yes. So you're telling us that you'll present

6 evidence that contradicts the statement of the witness that the building

7 was empty when she entered that, and therefore you'd like to be sure that

8 the answer she gives on the date on which she entered the building is a

9 correct answer.

10 The Chamber will allow you to repeat this question to the witness.

11 Mr. Usher, could you please. Under Rule 90[H], you're supposed to put to

12 the witness what your case is in this respect. Please do so.

13 MR. IERACE: Mr. President, having regard to your last

14 observation, are you saying that you want me to do it in a particular

15 formula of words such as I put to you, or is it not sufficient to simply

16 put the proposition the way I have.

17 JUDGE ORIE: Yes, you can simply -- it must be clear for the

18 witness.

19 MR. IERACE: Yes, yes.

20 Q. All right. Now, are you absolutely positive that it was sometime

21 in May and not sometime after the 8th of June, 1992 that you went to the

22 faculty of theology and commenced your period of work there?

23 A. I'm sorry. I said at the beginning what I said. It was ten years

24 ago. I can't remember the exact date. I can tell you roughly in such and

25 such a period. If I had some sort of notes about the period, I would be

1 able to tell you. When I had a list of the wounded, I would be able to

2 tell you. But I don't have that.

3 Q. I understand it was a long period of time ago. And that's why I'm

4 asking you if you could simply answer, yes or no, are you positive that it

5 was May and not sometime after the 8th of June, 1992, that you arrived

6 there? Are you positive or not?

7 A. I'm not positive as to the exact date.

8 Q. So it could have been after the 8th of June, 1992. Is that

9 correct?

10 A. I don't know.

11 Q. All right. Now, in relation to building number A on your sketch,

12 at any stage while you were there, did you see heavy artillery positioned

13 in some of the rooms?

14 A. I don't understand. What do you mean when you say "heavy

15 artillery"?

16 Q. All right. By heavy artillery, I mean large guns, not mortars,

17 much larger than that, with long barrels, taking shells, large shells?

18 Did you see anything fitting that description in building A at any stage

19 whilst you were working at the faculty?

20 A. At the beginning of my testimony, I said that our movement was

21 restricted. We kept to our premises where the clinic was. And we didn't

22 go into building A. And also, I need to say that I have no understanding

23 of weapons. All I am is a medical nurse, so I can't give you an answer.

24 Q. All right. Having regard to that answer, are you saying that

25 building A was off-limits to the medical staff?

1 A. There was no prohibition was needed. It was unsafe for us to walk

2 around there, especially as we were women.

3 Q. Was building A occupied by the army?

4 A. The army, the guys from the APC and the mortar, went around there,

5 but where exactly they went, I don't know. I don't know. They were

6 soldiers. Now, where they went, I don't know.

7 Q. All right. Did you see -- I'll withdraw that.

8 MR. IERACE: Excuse me, Mr. President.

9 Q. In relation to building K, at any stage while you were there, was

10 there a tank inside the building?

11 A. A tank. What do you mean?

12 Q. I mean a tank with caterpillar wheels and a big gun turret coming

13 out of it, a military tank?

14 A. This building, this building, while I was there, was closed.

15 Q. Did you ever go into the building, that is, building K?

16 A. In that building, building K, I lived on the first floor of that

17 building, building K.

18 Q. You tell us it was closed. You tell us you lived on the first

19 floor. My question was, was there a tank in the building; yes or no?

20 A. I didn't see one.

21 Q. Did you ever see a tank anywhere in that complex of buildings

22 whilst you were there?

23 A. No.

24 MR. IERACE: Excuse me, Mr. President.

25 Nothing further, Mr. President.

1 MR. PILETTA-ZANIN: [Interpretation] Mr. President.

2 JUDGE ORIE: Mr. Piletta-Zanin.

3 MR. PILETTA-ZANIN: [Interpretation] This implies that we can

4 respond, but I'd like the witness to leave for a very few seconds, leave

5 the courtroom.

6 JUDGE ORIE: Yes. Mr. Usher, could you please escort the witness

7 for 30 seconds out of the courtroom.

8 Respond to what exactly?

9 [The witness stands down]

10 MR. PILETTA-ZANIN: [Interpretation] Mr. President, because we

11 didn't want to make an incident, and in view of what the Prosecution has

12 indicated, we received the other day, that is quite recently, when that

13 witness arrived in The Hague, a list of people who died that this person

14 knew directly or indirectly. I will take the liberty of saying, and as

15 the witness is out, I can say so, that the dates, that some of those dates

16 are prior to the period of the 8th of June, 1992. As we didn't know that

17 the Prosecution was going to call new witnesses, and to insist on this

18 problem of dates, it didn't occur to us to produce this document. What we

19 think we should do, to avoid the Prosecution calling other witnesses

20 possibly, that in the break, we copy this list for everyone. We produce

21 it, and we ask the witness questions about it. That is whether she knew

22 such and such a person who died before the 8th of June, which will

23 certainly clarify things finally.

24 JUDGE ORIE: [Previous translation continues]... Clear to me how

25 exactly do these questions arise from the cross-examination? That's not

1 clear to me.

2 MR. IERACE: Mr. President, could I assist?

3 JUDGE ORIE: Yes.

4 MR. IERACE: Given that the witness finally responded effectively

5 that she wasn't certain of the time that she arrived there, I will not

6 take any issue with that. In other words, I accept that she may well have

7 arrived at the faculty at some stage after the 8th of June, 1992. That

8 doesn't mean that we won't be calling further evidence in rebuttal, or at

9 least seeking to do so.

10 JUDGE ORIE: Yes. Mr. Piletta-Zanin, it's still not quite clear

11 to me that you say this is a list of people of which the witness would

12 have known and people that died. How does that -- this arise out from the

13 cross-examination? Could you please --

14 MR. PILETTA-ZANIN: [Interpretation] Mr. President, the list that I

15 have here is a list of deceased with the dates of their death. If this

16 person, this witness, who was active in this medical team intervened and

17 knew some of these people that were wounded before the 8th of June, that

18 will show that her memory is correct and that she arrived during May

19 rather than in June. And as this point was raised only during the

20 cross-examination, that is, the date prior or after the 8th of June, we

21 didn't produce this document.

22 JUDGE ORIE: Can you know someone that died only when you arrived

23 at the faculty of theology before the 8th of June? It's still not clear

24 to me. Is this a list of people who died in the faculty of theology? Is

25 this -- please indicate to me how --

1 MR. PILETTA-ZANIN: [Interpretation] I'll be glad to. This is a

2 list of people who died in Nedzarici connected to the activities of this

3 witness. If this witness may have treated such and such a person before

4 the 8th of June in Nedzarici and during her stay there, then we will know

5 that she arrived there before the 8th of June, 1992. That is the gist of

6 the questions that we could try and show, to see whether the witness

7 remembers being in touch with these people, whether she treated them or

8 maybe carried -- washed their bodies after they had died. So this would

9 give us very precise chronology. So with your permission, we would show

10 her this list.

11 JUDGE ORIE: [Previous translation continues]... That was 1992,

12 wasn't it? I see a list with a lot of dates, with -- on which --

13 MR. PILETTA-ZANIN: [Interpretation] It's a list of wounded.

14 JUDGE ORIE: It's a different list from the one we received. We

15 received one list. But still, you say if you arrive early, it's about

16 Nedzarici. Well, is there any opposition from the Prosecution? I still

17 have difficulties in understanding what the relation is.

18 MR. IERACE: Well, Mr. President, in the interests of saving time,

19 I don't object to it if that assists.

20 JUDGE ORIE: Yes, okay. So there's no objection. You're allowed

21 to do so. But please, first, demonstrate clearly what is the issue,

22 because it's still not clear to me, but that might be a lack of

23 understanding. I'll ask my colleagues during the break whether they could

24 explain to me what it is exactly about.

25 We'll adjourn until 10 minutes to 1.00.

1 --- Recess taken at 12.28 p.m.

2 --- On resuming at 12.53 p.m.

3 JUDGE ORIE: Mr. Piletta-Zanin,, unfortunately, the other judges

4 could not give me a better understanding of what the list would mean, but

5 whether the witness arrived after the 8th of June or before the 8th of

6 June certainly is a matter that has arisen in cross-examination. So you

7 can ask the witness questions about that. And we'll see what the list can

8 do or not can do.

9 Mr. Usher, would you please escort the witness into the courtroom.

10 [The witness enter court]

11 MR. PILETTA-ZANIN: [Interpretation] Thank you.

12 Re-examination by Mr. Piletta-Zanin:

13 MR. PILETTA-ZANIN: [Interpretation] I would be grateful to the

14 usher if he could take these documents and distribute them, not only to

15 the Chamber but also to the witness.

16 I have to say that the Prosecution has received this document

17 beforehand in order to have time to prepare during the break.

18 Q. Witness, do you recognise this list that you see before you; yes

19 or no?

20 A. I do.

21 Q. Who drafted this list?

22 A. This was done by a man who worked at the command, who had this

23 list.

24 Q. Thank you. Witness, is it true that we can read from the

25 right-hand column "date of the wounding"? Yes or no.

1 A. No. These are the dates when people were killed, the date.

2 Q. I'm sorry. Yes. These are dates of when the people died. You're

3 perfectly right. I'm sorry. Dates of birth for the second column?

4 A. The first column is the date of birth, and then on the right-hand

5 side, the date when they were killed.

6 Q. Thank you. And then of course, the lists of names of persons.

7 Witness, could you please focus on the first 14 names on this list, from 1

8 to 14. Could you please read them. No, no, to read them -- to read them

9 to yourself.

10 Have you done it?

11 A. Yes.

12 Q. Thank you. Witness, in relation to these first 14 names, is there

13 one that you were brought to, to treat this person; yes or no?

14 A. Yes.

15 Q. Could you tell us which one?

16 A. That is number 2, and number 6.

17 Q. Thank you.

18 A. I don't recall any more.

19 Q. Thank you. Are you certain of the two names that you told us

20 about?

21 A. 100 per cent.

22 Q. Why is that?

23 A. Milan Aleksandrovic lived near me. He's a neighbour of mine.

24 Q. I'm going to stop you here. So he was wounded. Can you tell us

25 where? Where was he wounded before he died, of course? And where did you

1 treat him? Where did you extend him aid?

2 A. He died near his house. I don't recall exactly how he was

3 wounded, with what. I know that it was a head injury.

4 Q. Very well. Where did you treat him, in which facility?

5 A. Near his house.

6 Q. Thank you. I'm going on to another subject, Witness, now.

7 At the bottom of the list, could you please have a look at the

8 bottom of the list.

9 Can you see that there are 134 names there, just like I can? Yes

10 or no.

11 A. Yes.

12 Q. Thank you. Are there names of women on this list, please?

13 A. No. As far as I know, no.

14 Q. Do you know if these persons were civilians or military personnel?

15 MS. MAHINDARATNE: Mr. President, the Defence was permitted

16 specifically to go into this aspect of the date of arrival of the witness

17 at the facility, and now Defence counsel is going beyond that.

18 JUDGE ORIE: Mr. Piletta-Zanin, you asked to use this list in

19 order to further explore the matter of the date of the arrival --

20 MR. PILETTA-ZANIN: [Interpretation] That's true.

21 JUDGE ORIE: -- And that's an issue that has arose. So would you

22 please, then, move to your next subject.

23 MR. PILETTA-ZANIN: [Interpretation] Mr. President, it's true, I

24 accept the objection. It's true, and I'm going to go on to another

25 subject.

1 JUDGE ORIE: Please do so.

2 MR. PILETTA-ZANIN: [Interpretation] Thank you very much.

3 Can we put on the ELMO with the assistance of the usher the

4 photograph which has a number 96, ending in 96, representing the street

5 depicting the incident number 22.

6 THE REGISTRAR: [Previous translation continues]...

7 MR. PILETTA-ZANIN: [Interpretation] Yes, it was the same one as

8 before, P3274. But since it has three elements, I have to say it's the

9 third element of this exhibit with a number ending in 96.

10 Q. Very well. Witness, just a clarification. Thank you.

11 This street that we see in the middle of the photograph, so that

12 everything is clear, could you please point it -- point at it with a

13 pointer so that we know we're speaking about the same thing.

14 A. [Indicates]

15 Q. Thank you. Could you point at the street.

16 A. [Indicates]

17 Q. Very well.

18 MR. PILETTA-ZANIN: [Interpretation] The witness pointed at the

19 street in the centre.

20 Q. In which district is it located? Could you tell us?

21 A. This is the lower part, that is, looking from Dobrinja IV. No,

22 that is from the Muslim houses. That is Dobrinja.

23 THE INTERPRETER: Microphone, counsel, please.

24 MR. PILETTA-ZANIN: [Interpretation] Thank you. Thank you.

25 Q. Do you know, considering that now we know that this is located in

1 Dobrinja, do you know exactly the name of this street? If you don't know,

2 just say "I don't know."

3 MS. MAHINDARATNE: Mr. President, the witness has already answered

4 that in cross-examination.

5 JUDGE ORIE: The witness has answered this question.

6 MR. PILETTA-ZANIN: [Interpretation] Mr. President --

7 JUDGE ORIE: [Previous translation continues]... Of the -- in the

8 presence of the witness, or should we ask the usher to --

9 MR. PILETTA-ZANIN: [Interpretation] The witness may leave if we

10 are going to be cautious.

11 JUDGE ORIE: I again advise you to leave the courtroom, but we'll

12 see you back.

13 [The witness stands down]

14 JUDGE ORIE: Yes, Mr. Piletta-Zanin.

15 MR. PILETTA-ZANIN: [Interpretation] Mr. President, the reason for

16 my intervention is the following: The witness mentioned two names of

17 streets. But we do not think it was perfectly clear, and since this

18 witness said that she was having some difficulty in finding her bearings

19 in space, we wanted to make absolutely sure that she wasn't confusing this

20 street with the street that was mentioned as the Rozi -- I can't read it

21 very well. Hadzi or something street.

22 JUDGE ORIE: May I suggest that this road could be confused with

23 the name you just mentioned because it's a different one. The witness

24 testified, as a matter of fact, that the name of the street was the name

25 you just mentioned. So therefore, perhaps I'll verify with the name of

1 the street whether she is certain about that and that we have -- although

2 the question has been put to her.

3 MS. MAHINDARATNE: As I recall, Mr. President, the witness did not

4 say anything about being uncertain of the area. She specifically in fact,

5 if Defence counsel give a reference as to the portion of the evidence

6 where she mentioned she was uncertain about the area.

7 JUDGE ORIE: No, I think that's about east, west, north, and south

8 where she said it had difficulties in orienting herself. You've asked the

9 witness whether she recognised this without asking what street it was,

10 then in cross-examination it was asked. But we could -- I will ask the

11 witness to see whether she is certain about whether the street is --

12 MR. PILETTA-ZANIN: [Interpretation] Yes, gladly.

13 JUDGE ORIE: Guide me to where I exactly find it. It was

14 something about Rozi. Let me just see whether I can find it.

15 MR. PILETTA-ZANIN: [Interpretation] I will do my best. Just a

16 moment, please.

17 JUDGE ORIE: Just in order to avoid whatever confusion, I read

18 that the answer was Rozi Hadzivukovic Street [sic]. Is that a proper

19 pronunciation of what has been said? Or sometimes the names do -- okay.

20 Then, Mr. Usher --

21 MS. PILIPOVIC: [Interpretation] Yes, Your Honour, it is.

22 JUDGE ORIE: If you tell me how it's pronounced, then I will

23 gladly follow your instructions.

24 MS. PILIPOVIC: [Interpretation] Your Honour, you said it

25 correctly. [redacted]

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 [redacted]

8 Mr. Usher, could you please escort the witness into the courtroom.

9 [The witness entered court]

10 MR. PILETTA-ZANIN: [Interpretation] Mr. President.

11 JUDGE ORIE: Yes.

12 MR. PILETTA-ZANIN: [Interpretation] The reference that you're

13 looking for, that is 52.18 according to my transcript.

14 JUDGE ORIE: I've got it on my screen now.

15 We'll turn into closed session just -- private session just for

16 one second.

17 [Private session]

18 [redacted]

19 [redacted]

20 [redacted]

21 [redacted]

22 [redacted]

23 [redacted]

24 [redacted]

25 [redacted]

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4 [redacted]

5 [redacted]

6 [redacted]

7 [Open session]

8 JUDGE ORIE: Please proceed, Mr. Piletta-Zanin.

9 MR. PILETTA-ZANIN: [Interpretation] Thank you very much.

10 Q. I would like to have -- just a moment, please.

11 [Defence counsel confer]

12 MR. PILETTA-ZANIN: [Interpretation] Mr. President, could we again

13 have on the ELMO Exhibit Number P3279T. I'm going to show it to...

14 JUDGE ORIE: It might be a good idea, Mr. Piletta-Zanin, next time

15 to give the numbers already to the registrar so that she could prepare for

16 it. If there are any other documents that I would like shown to the

17 witness --

18 MR. PILETTA-ZANIN: [Interpretation] Yes, Mr. President, gladly.

19 We are busy with the copying, but this is the photograph.

20 THE REGISTRAR: This exhibit number has several photographs. Is it

21 3A that you are referring to?

22 MR. PILETTA-ZANIN: 3A, that's correct, yes.

23 [Interpretation] Can we also have near the witness the sketch that

24 she made which doesn't have a number yet. Could this document be placed

25 near the witness, please.

1 THE REGISTRAR: I will give the number now. The number is P3754.

2 MR. PILETTA-ZANIN: [Interpretation] Thank you very much.

3 Q. Witness, you can see a white building between two red walls.

4 Could you remind us what it is.

5 A. Faculty of theology.

6 Q. Thank you.

7 Witness, between this white building and the two buildings that

8 are high buildings with red bricks, is there, yes or no, this famous old

9 people's home? What I mean is, in the view, in the axis of the view

10 between these buildings?

11 A. I don't see it here.

12 Q. Very well. But my question wasn't whether you were able to see

13 it, but whether it is there. Perhaps it is there, perhaps we know that

14 something is there but we can't see it. In this segment that we see of

15 Nedzarici, is it there, yes or no, or is it hidden by the walls?

16 A. It's hidden somewhere.

17 Q. Very well. In relation to the sketch that you made earlier,

18 Witness, could you please put it --

19 MR. PILETTA-ZANIN: [Interpretation] Please, could Mr. Usher put it

20 back on the ELMO.

21 Thank you.

22 Q. You told us that this arrow represented the view that one would

23 have, I believe, on the Alipasino Polje district. Is that correct? Or

24 more specifically, in the direction of the old people's home.

25 MS. MAHINDARATNE: Mr. President, I object. I cannot recall the

1 witness stating this. The Defence counsel says you told us that this

2 arrow represented the view, and goes on. The witness, as I recall, did

3 not say it.

4 JUDGE ORIE: "The direction in which you had to look, if you

5 wanted to look at the old people's home." Yes, that's approximately the

6 same, and it could hardly create any confusion I think the way Mr.

7 Piletta-Zanin put it.

8 Please proceed, Mr. Piletta-Zanin.

9 MR. PILETTA-ZANIN: [Interpretation] Thank you very much.

10 Q. In relation to the buildings that you marked with A, do you

11 remember what was the length of the wall which was to the right of the

12 arrow? That is the outside wall, what was the length of the wall

13 approximately?

14 A. I find it difficult to say.

15 Q. Very well. I'll put the question differently. This wall that

16 you -- where you've put the arrow, did it have several openings, many

17 openings, one single opening? If you can remember.

18 A. From that building --

19 Q. Witness, please take your pointer. Your pointer. Thank you.

20 Point it at the wall.

21 A. [Indicates]

22 Q. That's right.

23 MR. PILETTA-ZANIN: [Interpretation] The witness is pointing to the

24 top wall of building A.

25 Q. This building with this wall, as far as you can remember,

1 this -- how long was that part of the wall approximately?

2 A. I don't know exactly. But it's a building with a lot of windows.

3 Q. Very well. This building -- thank you.

4 I'll go back to what you said on page 68, line 15. Could you show

5 us, please, the places that were out of bounds to you, with your pointer,

6 please? You said that there were places that you didn't go to.

7 MS. MAHINDARATNE: Mr. President, I object. The witness did not

8 say that --

9 JUDGE ORIE: Yes, but, if you would have listened to the second

10 line of Mr. Piletta-Zanin's question, his first question was where you

11 were forbidden to go, and the second was where you did not want to go. So

12 that's the last question.

13 So the question is, could you indicate those parts of the building

14 where you would not go, with the pointer, please, yes.

15 THE WITNESS: [Interpretation] Building A. Because of my own

16 personal safety, and all my other colleagues also didn't want to go close

17 to any openings.

18 MR. PILETTA-ZANIN: [Interpretation].

19 Q. Thank you very much. You said that we didn't want to go there

20 because we were women. And I am quote what you said on page 68, line 15.

21 Why did you make that remark? Why did you refer to women in this

22 particular case?

23 A. As you know, we women never served in the army before the war.

24 And for our own safety and because of constant shelling, we didn't know

25 how to behave when fire was opened. So the safest thing to do was to

1 retreat, not to go outside when there was shooting, but to stay within an

2 area that was safe. That's what I had in mind.

3 We had our own surgery, and we kept -- we stayed there. When a

4 wounded man came, we would go out and do our duty.

5 Q. Madam Witness, during those shelling, did you feel fear? What

6 were your feelings in general terms?

7 A. Of course, every person when threatened is afraid. My sister was

8 wounded.

9 MR. PILETTA-ZANIN: [Interpretation] No further questions, Your

10 Honour. Thank you.

11 JUDGE ORIE: Thank you, Mr. Piletta-Zanin.

12 Judge Nieto-Navia has a question for you.

13 Questioned by the Court:

14 JUDGE NIETO-NAVIA: Madam, you have the photograph, have a look on

15 it, please. And the sketch. Now put the sketch on the ELMO, please.

16 Could you point to the wall or to the side of the building that

17 you see on the photograph. Could you point to that wall on the sketch.

18 Which is the side of the building A that you see?

19 A. The left-hand side. The building on the left.

20 JUDGE NIETO-NAVIA: The one with the arrow, or another wall? Which

21 one?

22 A. The arrow is, as I showed it. Can I show it to you?

23 JUDGE NIETO-NAVIA: Yes.

24 A. This building is higher than the other buildings where we were.

25 And this is the building with the openings. And we were in quite a

1 different building.

2 JUDGE NIETO-NAVIA: My question is a different one. The wall of

3 the building that you can see in the photograph, which is the wall in your

4 sketch?

5 A. On A, it is the building A on the sketch.

6 JUDGE NIETO-NAVIA: Building A has four --

7 A. This one. This one.

8 JUDGE NIETO-NAVIA: The same of the arrow, the same one.

9 A. Yes.

10 JUDGE NIETO-NAVIA: Okay, thank you.

11 JUDGE ORIE: Judge El Mahdi also has a question for you.

12 JUDGE EL MAHDI: Thank you, Mr. President.

13 [Interpretation] I would like to clarify a point, please. When

14 you said that at the faculty, there were mortars and mortar crews.

15 A. In answer to the question who was present at the theology faculty,

16 I said that there was the medical corps, a mortar company, and an armoured

17 unit. That's what I said.

18 JUDGE EL MAHDI: [Interpretation] Yes. And the firing of the

19 mortars that were situated within the compound of the faculty, close to

20 the buildings, where did the fire come from that were responding to enemy

21 fire?

22 A. Usually when this happened, there would be shelling of the

23 settlement. And as soon as the shelling started, we would retreat to the

24 basement or to premises that didn't have any glass openings. We could

25 hear the shelling, but I cannot recognise -- I can't tell you exactly how

1 it went. There was shooting, definitely. But who did what and how often,

2 I'm unable to say. We would withdraw to shelters. As soon as there was

3 combat activity, whether it was shooting or shelling, we would seek

4 shelter. So that I can't tell you. I don't know that. We didn't see

5 when shots were fired.

6 JUDGE EL MAHDI: [Interpretation] I understand, Madam. But my

7 question was where those mortars were positioned, those mortars that you

8 didn't see. Yes, perhaps you heard them. You heard the noise. The

9 mortars, the shells being fired, where were those mortars? Were they

10 close to the building or under the roof or where? Where were the mortars

11 positioned, if you know?

12 A. I do know. Those mortars were in the front part, in this frontal

13 area, more to the right. And because those mortars were targeted, they

14 were probably looking for them, we didn't use that exit, nor did we move

15 around in that area.

16 JUDGE EL MAHDI: [Interpretation] Did you hear gunshots? I'm not

17 talking about mortars now, shots coming from the faculty, possibly in

18 response to enemy fire? Automatic weapon fire or rifle fire, any weapons

19 being fired?

20 A. One could hear shots all over. What type of weapons were being

21 used, I really don't know. There were bullets all over coming from

22 everywhere, so the best thing to do was to seek shelter.

23 JUDGE EL MAHDI: [Interpretation] Yes. And would you hear

24 individual shots, single shots, one or two?

25 A. I was unable to judge. I don't know that. I can't say. I don't

1 know how. I don't know what exactly you mean, whether I heard it. I

2 heard shots. Now how, who was firing at who, I really don't know.

3 JUDGE EL MAHDI: [Interpretation] No, I'm not talking about the

4 engagement. I'm talking of an isolated shot, a single shot, two shots.

5 Not necessarily in a combat, in a battle.

6 A. Yes, one could hear such shots. On one occasion, when I was going

7 to visit my parents, my sister and I, we had to find our way between

8 buildings and meadows because we didn't dare take the main road. On one

9 occasion, a bullet whizzed by our head, it hit against concrete --

10 JUDGE EL MAHDI: [Interpretation] I apologise, Madam. I'm talking

11 about the time you spent at the faculty, while you were there. The

12 faculty of theology. Did you hear shots coming from the building itself?

13 A. No. I didn't hear that.

14 JUDGE EL MAHDI: [Interpretation] Thank you, Madam.

15 JUDGE ORIE: I've got a question for you as well. You have been

16 shown two photographs where you appear on it. Could you indicate on the

17 sketch you made, if it is on the sketch, which part of the building this

18 is. Where do we find it on your sketch? Could you please point to it.

19 A. It's this part. We were sitting here. This was a sheltered area,

20 sort of protected. This is the entrance into that building, and this

21 building, a part of this building can only be seen. Only a part of the

22 building can be seen. So this is the back part.

23 JUDGE ORIE: Back part, facing down on the sketch. Is that

24 correct?

25 A. Yes, yes. Here. Here.

1 JUDGE ORIE: Yes. Are these two pictures taken more or less at

2 the same moment or...?

3 A. Those photographs all were taken at more or less the same time,

4 yes, all of them.

5 JUDGE ORIE: Yes. Do you remember approximately at what time of

6 the day this was? Was it in the morning, was it in the afternoon? Do you

7 remember the occasion at all when this photograph was taken?

8 A. Around mid-day. I think around noon. I'm not sure of that. I'm

9 not quite sure.

10 JUDGE ORIE: Yes. Thank you very much for your answer.

11 This was my last question. This concludes your testimony in this

12 Court. The Court is aware that you have travelled a long way to come here

13 and to answer all questions put to you, both the questions of the parties

14 and questions of the Bench. I'd like to thank you for that, and I wish

15 you a safe trip home again.

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

17 JUDGE ORIE: Could you please escort the witness out of the

18 courtroom.

19 [The witness withdrew]

20 JUDGE ORIE: We've got ten minutes left. I wonder perhaps first

21 we deal with the documents, and then see whether there's any other

22 outstanding issue, and perhaps not ask the next witness to come in.

23 Madam Registrar, could you please assist us in identifying the

24 documents tendered.

25 THE REGISTRAR: P3754, diagram drawn by witness. D1782, under

1 seal, pseudonym sheet. D1783, list containing 134 names.

2 JUDGE ORIE: Yes, Mr. Piletta-Zanin, having regard to the

3 questions and the answers in respect of this list, does the

4 Prosecution -- does the Defence want to tender it?

5 MR. PILETTA-ZANIN: [Interpretation] Yes, Mr. President. Because I

6 think it definitely clarifies the problems of chronology, and that will

7 certainly avoid the necessity of the Prosecution for rebuttal, at least on

8 this point.

9 JUDGE ORIE: It's not quite clear to me. I have listened

10 carefully to the questions, and I think the witness said that she

11 recognised two names, number 2 and number 6. And you asked more

12 specifically about number 2. Then she said that she treated that person

13 close to his house. So it's not clear to me, but perhaps you could

14 explain it to us, how this gives an answer to when the witness arrived at

15 the faculty of theology to work there as a nurse.

16 MR. PILETTA-ZANIN: [Interpretation] Yes, Mr. President. I should

17 perhaps begin with that, but it appears that this list was drafted by an

18 official, as she said, of the medical unit, if I understood her correctly.

19 And therefore, as this list contains the names of people wounded prior to

20 the 8th of June, 1992, and that among those 14 persons, the witness

21 treated at least two. Then one can accept that she was active in that

22 medical unit prior to that date in June, and that is why to the Defence

23 the situation seems to be clear.

24 JUDGE ORIE: Yes. It's clear to me what inferences the Defence

25 draws from this list. So you insist on tendering, so it's tendered.

1 Madam Registrar, next document.

2 THE REGISTRAR: D327 and D328, both photographs and both under

3 seal.

4 JUDGE ORIE: No objections? Then these documents have been

5 admitted into evidence. The pseudonym sheet and the two --

6 MR. IERACE: Mr. President, I'm sorry to interrupt. We're just

7 trying to clarify those photographs. If you could just allow us a moment.

8 Thank you, Mr. President, no objection.

9 JUDGE ORIE: Yes, D327, D328 also admitted under seal.

10 Are there any issues the parties wanted to raise during the next

11 five minutes? This is not an invitation to invent something. But yes,

12 please, Mr. Ierace.

13 MR. IERACE: Thank you, Mr. President. I've received a letter

14 this morning from the Defence which has been copied to the Trial Chamber.

15 In the letter, the Defence effectively invites the Prosecution to

16 continue -- excuse me. To continue to deal with them, to negotiate with

17 them, on the subject of agreed facts. The situation at the moment is that

18 the -- some weeks ago, the Prosecution provided a list of 38 proposed

19 facts for discussion. We haven't received a response. If

20 Mr. Piletta-Zanin prefers to read them in French or Serbian or whatever,

21 I'm sure he's had sufficient time to have them translated.

22 The position of the Prosecution, Mr. President, is simply this:

23 That we're happy to discuss this issue with the Defence. We feel that we

24 have done more than enough, given that at this juncture the Defence has

25 heard the Prosecution evidence. We take the view that it's a matter for

1 them to tell us what in the Prosecution case they agree. In our

2 respectful submission, if Rule 90 had been complied with by the Defence,

3 we would know that anyway, and we don't quite clearly having regard to the

4 Defence evidence we have heard. If you wish us to do anything in relation

5 to this issue, we will do it. But subject to that, I cannot think of

6 anything we can sensibly do at this stage to advance this issue. I note

7 the Defence has sought a certificate of appeal in relation to your

8 direction that we meet to see if we could discuss things. So

9 Mr. President, I'm really in your hands on this issue.

10 JUDGE ORIE: Yes. Let me just. The Prosecution has proposed

11 certain facts on which to agree, and it has not led to an agreement. If,

12 Mr. Piletta-Zanin, you want to talk with the Prosecution, would that be a

13 starting point for such a discussion, or would you propose that you

14 provide a list of facts that you would agree upon? I mean, if you want to

15 agree upon something, I'm not saying that you want, if you about you want

16 to discuss that, you need a starting point. Is the starting point

17 provided by the Prosecution an acceptable one, and if not, does the

18 Defence intend to propose another starting point for such discussions?

19 MR. PILETTA-ZANIN: [Interpretation] Mr. President, very briefly, I

20 have nothing against the fact that the Prosecution is speaking on my

21 behalf. I thank them for this.

22 JUDGE ORIE: Let's come to the --

23 MR. PILETTA-ZANIN: [Interpretation] But I cannot accept -- I was

24 just checking the translation. But I cannot accept that they say the

25 opposite to what I wrote. What the Defence wrote is simply the following:

1 We are awaiting responses to very specific questions, and that's all.

2 They haven't -- we don't invite the Prosecution to continue, but simply to

3 provide answers.

4 JUDGE ORIE: [Previous translation continues]... Tomorrow 7.30 in

5 my chambers, the parties may tell me exactly what issues are still

6 outstanding on which they expect a response from the other side, and what

7 will be the starting point for any further discussion on these issues.

8 MR. PILETTA-ZANIN: [Interpretation] Mr. President --

9 JUDGE ORIE: We'll adjourn unless there's a specific aspect.

10 MR. PILETTA-ZANIN: [Interpretation] Yes, Mr. President. On a

11 number of occasions, we saw that members of the Prosecution were not

12 informed of what was going on in their own camp, and to avoid these type

13 of problems, we would like all members of the Prosecution to be present so

14 that we shouldn't be told later on, "I wasn't there, I didn't know, I'm

15 sorry." We will be present, and I'd like them to be present, all of them.

16 JUDGE ORIE: I expect two members of each party to be present,

17 lead counsel included. I do understand that this might be very

18 inconvenient. I usually avoid to make any personal notes, but I'll not be

19 able to bring my children to school tomorrow either.

20 Yes, Mr. --

21 MR. IERACE: Could I respectfully suggest that the meeting be

22 between myself and only the senior trial attorneys. Is it not

23 appropriate, and given that this is an important issue, and that surely

24 the senior trial attorneys should attend and no one else?

25 JUDGE ORIE: We'll start with two members of each team. And if

1 that would not be an efficient way of dealing with the matter, the

2 Chamber, not myself, the Chamber will consider whether it would be a good

3 idea to continue with lead counsel only.

4 We'll adjourn until tomorrow morning, 9.00, same courtroom.

5 --- Whereupon the hearing adjourned

6 at 1.44 p.m., to be reconvened on Thursday,

7 the 7th day of November, 2002,

8 at 9.00 a.m.

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