Tribunal Criminal Tribunal for the Former Yugoslavia

Page 8836

 1                           Tuesday, 2 November 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.03 a.m.

 5             JUDGE KWON:  Good morning, everyone.

 6             Doctor, do you hear me?

 7             THE WITNESS: [Interpretation] I can hear you very well.

 8             JUDGE KWON:  Thank you.  Good morning to you, Doctor.

 9                           WITNESS:  YOUSSEF HAJIR [Resumed]

10                           [Witness testified via videolink]

11                           [Witness answered through interpreter]

12                           [French interpretation on English channel]

13             THE WITNESS: [Interpretation] Good morning.

14             JUDGE KWON:  We are hearing the French translation.

15             Okay, let's continue.

16             THE ACCUSED: [Interpretation] Thank you.

17                           Cross-examination by Mr. Karadzic: [Continued]

18             MR. KARADZIC: [Interpretation]

19        Q.   I should like to go quickly over some matters that I believe can

20     be answered with a yes or no, to make things more efficient.

21             First of all, do you know that I issued a great number of orders

22     concerning the protection of civilians, the observation of International

23     Humanitarian Law, et cetera?

24        A.   No.

25        Q.   Thank you.  Tell me, what was the population of Dobrinja?

Page 8837

 1        A.   Before the war, around 40.000.  During the war, I believe it was

 2     around 25.000.  Nobody can give you a precise answer to that, but these

 3     are approximate figures.

 4        Q.   Thank you.  Did you go to attend meetings of the Command of the

 5     155th Brigade?

 6        A.   Never.  They never asked me, and I never went, nor was I part of

 7     the command, finally.

 8        Q.   How about your deputy?  He was commander of the Medical Service.

 9     What was the name of that doctor, the deputy director?

10        A.   Dr. Zlatko Kravic.  First it was Dr. Radoncic, and then Zlatko

11     Kravic as chief of the Medical Section of the brigade.

12        Q.   Was he invited to meetings of the command?

13        A.   Honestly, I never asked him, and he never told me that he went to

14     such meetings.

15        Q.   Thank you.  Let me summarise, then.

16             You did not receive regular daily combat reports?

17        A.   No.

18        Q.   And you were not involved in the planning of operations, nor in

19     their later analysis?

20        A.   I'm not a soldier, really, nor would I know how to analyse

21     military operations, nor would I know how to plan them.  That's not my

22     job.  I never wanted to interfere with jobs I know nothing about.

23        Q.   Were you informed, officially or in any other way, of

24     developments in the theatre of war?

25        A.   Sometimes somebody would drop by and tell us what's going on, but

Page 8838

 1     nothing official.

 2        Q.   Thank you.  Could you now take your amalgamated statement.  I'll

 3     try to go quickly over certain paragraphs.

 4             In your book, you said you had 1200 or so surgeries and around

 5     6.000 minor surgeries in the out-patient clinic, including 1.000-plus

 6     peacetime injuries and around 5.000 wartime injuries.  That is

 7     approximately 6200 surgeries in total.  Now, why do larger numbers appear

 8     in your statement; 5.000 major surgeries and 16.000 patients in total?

 9        A.   You see, about exact numbers of injuries and surgeries, I don't

10     know those exact numbers, and nobody will ever know, because no precise

11     records were kept.  We never wanted to waste time on that.  I don't know

12     what happened to four or five protocols that went missing and we never

13     could trace, whether somebody stole them or whatever happened.  All I had

14     was what I had to hand.  As for the lost protocols, we tried to track

15     them down.  We involved the police as well, but we never found them.

16     That's the reason for this confusion about numbers.

17        Q.   Thank you.  In fact, it appeared to me that in a population of

18     30.000, 16.000 would have gone through your clinic.  Yesterday, you

19     mentioned that there were some people who passed through the tunnel and

20     got injured there.  Was the frequency of passages through the tunnel so

21     high that you could get so many patients out of these people?

22        A.   The tunnel was 120, 130 centimetres high and it was 800 metres

23     long.  You could not stand up properly.  You would hit iron beams.  It

24     was simply that you had to go through that tunnel for such a long time,

25     maintaining a completely unnatural posture.  You can imagine how many

Page 8839

 1     people passed in both directions.  Injuries were frequent.

 2        Q.   How many people went through?

 3        A.   Well, people went through to get to the other side to visit their

 4     families, or to get groceries, to find food, to give their children --

 5     there are so many reasons why people went to the tunnel.  Nobody would do

 6     it just like that, because it was dangerous.  You never knew when you

 7     would be hit by a shell while entering or leaving.  Nobody went there on

 8     a whim or for enjoyment.  It was because of dire need.

 9        Q.   Thank you.  Did entire units of the 1st Corps leave the city and

10     come back through that tunnel?

11        A.   Honestly, I personally never saw anything like that.  It's

12     possible, but I've never seen it.

13        Q.   Where would they assemble if they had to go through the tunnel?

14     What would be the assembly point?  Because they couldn't go all together.

15     They would have to go one by one; right?

16        A.   Correct.

17        Q.   So first of all they would have to gather somewhere close to the

18     entrance to the tunnel?

19        A.   If what you're saying is true, then that would be right.  They

20     couldn't go in all at once.

21             THE ACCUSED: [Interpretation] Could we now see 1D2686.  I hope

22     you will see it in your e-court.

23             MR. KARADZIC: [Interpretation]

24        Q.   Have you ever heard of Nedzad Ajnadzic [Realtime transcript read

25     in error "Inadzic"]?

Page 8840

 1        A.   I believe Nenad Ajnadzic was commander of the 1st Corps.  I'm not

 2     sure.

 3        Q.   That's right.  Could we now take a look at our electronic mail.

 4     I believe we are now going to get this exhibit.

 5             The record should be corrected.  The name should be spelled as

 6     A-J-nadzic, instead of I.

 7             Could you now take a look at this text, where it says the tunnel

 8     was dug out and its purpose was to provide a safe way for providing

 9     logistical support to units in Sarajevo, but also a connection with the

10     free territory of the BH.  That's the paragraph after the enumeration of

11     these systems.

12        A.   I don't see it.  It doesn't matter.  In any case, it's possible.

13     Yes, the purpose of the tunnel was to make things easier, to make it

14     easier to get in and out, not only for civilians, but for soldiers, when

15     necessary.

16             THE ACCUSED: [Interpretation] Can we see the next page, please.

17     Sorry, that's a different document.

18             MR. KARADZIC: [Interpretation]

19        Q.   On this page, we see there were D and B structures connecting

20     Dobrinja and Butmir, passing through -- below the runway of the Sarajevo

21     Airport?

22        A.   Yes.

23        Q.   The task was entrusted to the BH Army, the 1st Corps, and in the

24     beginning of 1993, in the greatest secrecy, they started digging the

25     tunnel?

Page 8841

 1        A.   Can I comment?

 2        Q.   Certainly.

 3        A.   Before digging the tunnel, you see, you cannot hermetically close

 4     in 300.000 people in an area.  If you had left the corridor open, you,

 5     maybe half of the people would have left, because everybody had needs.

 6     They had children to feed, they had families.  Before the tunnel was dug

 7     out, people simply ran across the runway.  Many people were hurt by

 8     sniper fire from the Serbian side, and if not from the Serbian side, then

 9     by the French Battalion that was responsible for that runway.  What do

10     you expect, if you close a person in their own home without letting them

11     walk, breathe?  Really, Colleague Karadzic, it's not realistic to expect

12     that.

13             THE ACCUSED: [Interpretation] Can we have this page admitted so

14     I can call another one?

15             JUDGE KWON:  What page is it, Mr. Karadzic; 257?

16             THE ACCUSED: [Interpretation] Yes, and that's Exhibit 1D2686,

17     marked for identification.

18             JUDGE KWON:  I take it there's no objection from the Prosecution.

19             MS. SUTHERLAND:  No objection to it being marked for

20     identification, Your Honour.

21             JUDGE KWON:  Yes, that will be marked for identification.

22             THE REGISTRAR:  As MFI D856, Your Honours.

23             THE ACCUSED: [Interpretation] Thank you.

24             Can we get 1D2687.

25             MR. KARADZIC: [Interpretation]

Page 8842

 1        Q.   Do you know, Dr. Hajir, that the Serbian side had offered

 2     corridors for civilian traffic and commercial traffic, on the condition

 3     that no military assets or forces be allowed to use these corridors?

 4        A.   This is the first I hear of it.

 5        Q.   I'm afraid they kept many things from you, or perhaps you were

 6     too busy and were unable to find out.

 7        A.   That may well be, but somebody would have spoken up.  You see,

 8     people were coming and going all the time.  People were passing through

 9     hospital in great numbers.  Somebody would have said something.  I never

10     heard of anything like that, really.

11        Q.   Could you take a look at this page 259, where it says:

12             "In the night, when the tunnel was completed, 600 soldiers, under

13     full equipment, passed through it immediately, and they went directly to

14     Mount Igman to stop the aggressor's offensive.  At the same time in the

15     same night, around five tons of military materiel and equipment was

16     delivered to Sarajevo the same way."

17        A.   I can't see it, but what's your question?

18        Q.   Is it consistent with what you said a moment ago, that the

19     through-put of this tunnel was very high, both for soldiers and

20     civilians?

21        A.   Very possible.

22             THE ACCUSED: [Interpretation] Can we have this admitted?

23             JUDGE KWON:  It will be admitted in the same number, and we'll

24     mark it for identification.  It's a part of the same book, isn't it?

25             THE ACCUSED: [Interpretation] Yes, but it's just a different

Page 8843

 1     page, 259.  Also, 258 and 259 we can admit.  Thank you.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   In paragraph 8 of your statement, you say that Dobrinja, in the

 4     beginning, was not completely surrounded, and do you agree that, in view

 5     of the tunnel, it was never completely encircled, just like Sarajevo

 6     wasn't, because the traffic through the tunnel was quite substantial?

 7        A.   I mentioned the time when the war began.  With the opening of the

 8     tunnel, it was a little bit, but, you know, the capacity of the tunnel

 9     and the possibility of allowing the traffic through was quite limited.

10        Q.   Thank you.  I wanted to ask you:  For some of your assertions --

11     for all of your assertions, do you have proof or are these your

12     impressions?  Very often, you, yourself, say that, It is my impression.

13     For example, in paragraph 14, the last sentence states that it was your

14     impression that the Serbs only wanted to kill, and that is one of the

15     reasons they did not take Dobrinja.  Were they able to kill you easily at

16     the check-point at Vraca?

17        A.   Yes, they could have.  But then how to explain the sealing off of

18     the town, the hermetical closing off of the town, especially Dobrinja?

19     Dobrinja was a residential area.  There were no factories, there was

20     nothing there.  How can you fire?  And you know that there are children

21     there, the elderly, women, who are defenceless.  I had a child, seven or

22     eight years old, shot by a sniper directly in the heart.  I mean, the

23     sniper could have seen that this was a child.  I am speaking openly,

24     Colleague.  These are facts that were happening that I could observe

25     around me, so these are not my impressions.

Page 8844

 1        Q.   All right.  But do you know that the other side, the side of the

 2     Army of Bosnia and Herzegovina, or, actually, more the police, was also

 3     active in sniper killings of Serbs and Muslims?

 4        A.   I know that there was several attempts to attack Nedzarici, not

 5     for the purpose of occupation, but for the purpose of clearing those

 6     sniper nests.  This is from what I understood, as far as a number of

 7     these actions that were not successful because of poor co-ordination.

 8     You say, Organise this, Organise that.  These few brigades that were on

 9     the line were unable to co-ordinate and carry this out and to secure a

10     safer passage through Mojmilo or other parts of town.

11        Q.   Do you agree that Nedzarici was a purely Serbian neighbourhood,

12     with private homes that were mostly -- that mostly had a ground floor and

13     first floor?

14        A.   Yes.  The majority, yes.

15        Q.   Do you agree that this settlement was inferior in relation to

16     Vojnicko Polje, Alipasino Polje, where they had high-rise buildings of

17     some 10, 15 storeys?

18        A.   Absolutely, yes, but that is proof that they did not want

19     Nedzarici, because they could have.  It seems to me these two or three

20     brigades that were around could have taken Nedzarici.  They just wanted

21     to get rid of the sniper nests that were constantly firing at people.

22     Well, at least, this is what I know.  I'm telling you what I know.

23        Q.   You agree, probably, that the Serbs could probably have captured

24     Dobrinja, but they didn't do that because there would have been many

25     civilian casualties; isn't that right?

Page 8845

 1        A.   Yes, with the military force that they had and three military

 2     barracks, they could have easily taken it in the beginning, and there

 3     wouldn't have been that many civilian casualties then.

 4        Q.   Thank you.  I'm concerned with this first sentence from

 5     paragraph 14, that:

 6             "The Serbs were absolutely targeting civilians."

 7             Is this an impression or are you able to give us some kind of

 8     evidence for this assertion?

 9        A.   Yesterday, you showed a paper where you could see injured people.

10     They were all fighters.  You didn't show all the papers that you had that

11     would show that there were tenfold more civilians.  What can I say?

12             When you tried to save lives, for the most part, people are

13     coming -- actually, very few soldiers came, compared to the number of

14     civilians that came.  And I'm telling you, because I know, I was there, I

15     could see what was happening.  What would be my impression if the

16     situation that I had was like that?

17        Q.   Thank you.  And the next sentence says that:

18             "There were no military units there in the beginning, and there

19     was no organised army."

20             Is this the reason why you concluded that civilians were harmed,

21     rather than soldiers?

22        A.   Absolutely, Mr. Karadzic.  I am telling you, definitely, there

23     were none.  Like you said, there was the Patriotic League, the 110th, the

24     140th.  Believe me, I would have seen that, people would have told me.

25     There was nothing like that in Dobrinja.  These were young men, 20 years

Page 8846

 1     old, that would come, who were changing clothes and taking pistols and

 2     rifles.  They didn't have any heavy weapons.  This is the kind of thing I

 3     saw in Dobrinja.  I'm not saying that there weren't heavier weapons in

 4     other places, but there were some lighter weapons that were used among

 5     protesters.  There was multi-barrelled weapons.  Perhaps I saw a tank --

 6     I never saw a tank on this side.  So this is mostly what I saw.

 7             THE INTERPRETER:  The interpreters note we are having difficulty

 8     understanding the witness.

 9             MR. KARADZIC: [Interpretation]

10        Q.   I understand that you were busy, you were unable to see that.  Do

11     you know how many fighters of the 155th Brigade, which existed before

12     August 1992 under a different name, how many fighters of the 155th

13     Brigade were wounded?

14             JUDGE KWON:  Before you answer, Dr. Hajir:  Yes, Ms. Sutherland.

15             MS. SUTHERLAND:  Perhaps the witness's microphone needs to be

16     turned up, because the interpreters are having trouble understanding the

17     witness.

18             JUDGE KWON:  Yes, I was just about to pay attention to that.

19             Could you, Dr. Hajir, speak to the microphone.  Yes.  A bit

20     closer, yes.  And please put a pause between your answer -- between the

21     question and your answer, kindly.

22             Yes.  Could you answer the question?

23             THE WITNESS: [Interpretation] I think that I already answered.  I

24     don't know.

25             MR. KARADZIC: [Interpretation]

Page 8847

 1        Q.   I'm afraid they didn't hear you.  So it's not in dispute that the

 2     brigade existed.  Yesterday, we showed a document that in August, as

 3     already finished, completed brigade, it became part of the 1st Corps, and

 4     Muslim information indicates that the brigade had 5.000 fighters.  How

 5     many of these men or fighters in that brigade were killed and how many

 6     were wounded?

 7        A.   I really couldn't tell you that.  I really don't know.  We never

 8     did any kind of statistical calculations.  You can see that all the

 9     statistical data, the numbers are problematic, and there was much more,

10     in terms of numbers, than what is stated in books.

11        Q.   Thank you.  In the case of General Perisic, on the 29th of

12     January, 2009, on page 2998, you said that you didn't differentiate

13     between civilian and military casualties or patients; is that correct?

14        A.   We never differentiated between people.  People were there, and

15     they needed help if they were hurt, so we didn't make any distinctions.

16     If you make a difference on one side, then there will be a difference

17     made on the other side.  One needs to treat everybody equally on all

18     sides.  And I think that, in that sense, I acted properly.

19        Q.   All right, thank you.  I agree with you.  It's a fact that many

20     fought in civilian clothing, as you, yourself, confirmed yesterday.  Can

21     you please tell me, these 5.000 soldiers, how did they move around in

22     Dobrinja?  There were four large battalions and there were two others,

23     one engineering one and another one, I don't what kind it was.  How did

24     they move around and manoeuvre around Dobrinja, in such a small area?

25     They must have been very visible and something that would grab the

Page 8848

 1     attention of the Serbian Army.

 2        A.   I never saw any gathering, moving around, and walking in

 3     Dobrinja.  I don't know of any barracks belonging to the Bosnian Army,

 4     either.  Things like that weren't there.  They didn't gather at the

 5     command, either.  There were about one or two men at the command who were

 6     guarding the commander, guards.  As for the rest, I really don't know

 7     where they were.  Probably, everybody was at home, mostly.  Those who

 8     were coming from town later, I don't know where they were billeted.  I

 9     really don't know.

10        Q.   If they were at their homes, does that mean that that was their

11     combat deployment or disposition, to be in their buildings?

12        A.   Well, where would the people go?  They couldn't walk around, they

13     couldn't go home.  I mean, it doesn't mean that it was their wartime

14     disposition or assignment to stay at home.

15             THE ACCUSED: [Interpretation] Can I look at 1D1100 now, please,

16     so that you can see what that looked like on the 23rd of May, 1992,

17     precisely what you were saying, where all the fighters were assembled in

18     Dobrinja.

19             MR. KARADZIC: [Interpretation]

20        Q.   Were there any trenches or any roads that they could have used

21     otherwise?  I mean, this is a major --

22             JUDGE KWON:  Yes, Ms. Sutherland.

23             MS. SUTHERLAND:  I'm sorry for interrupting, Your Honour, but can

24     Mr. Karadzic direct me to the exhibit which says there was 5.000 Muslims

25     in the 155th Mountain Brigade, please?

Page 8849

 1             JUDGE KWON:  The Chamber was discussing that.

 2             But, Doctor, Mr. Karadzic put several questions to you on the

 3     basis that there were 5.000 Muslim fighters in the region.  Can you

 4     confirm that?

 5             THE WITNESS: [Interpretation] Absolutely not.  I really don't

 6     know.  I mean, if you count the auxiliary services, logistics, and

 7     drivers, and whatnot, I still think that you wouldn't get 5.000.  I don't

 8     think so.  Anyway, like I said, we never counted, nobody ever told me

 9     anything like that, so I don't know the exact number.  But I'm saying

10     that this number of 5.000 cannot be.  It's too high a number for that

11     area.

12             JUDGE KWON:  Can you give us a rough idea how many soldiers there

13     would be, roughly?

14             THE WITNESS: [Interpretation] Whatever I were to tell you, it

15     wouldn't be the truth.  It wouldn't even be close to the truth.  I really

16     don't know.

17             JUDGE KWON:  Thank you.

18             THE WITNESS: [Interpretation] Sorry.

19             MR. KARADZIC: [Interpretation]

20        Q.   We agree that there were four battalions.  Do you agree that a

21     battalion numbers between four to six companies?

22        A.   Mr. Karadzic, I really don't know how many companies a battalion

23     should have.  I really don't know.  I'm not avoiding an answer.  I'm just

24     telling you what I know.  And what I know, I will gladly tell you.  What

25     I don't know, I don't know.  I thought that yesterday we had put a full

Page 8850

 1     stop to that.

 2             JUDGE KWON:  You confirmed yesterday, did you not, that there

 3     were four battalions?

 4             THE WITNESS: [Interpretation] He mentioned six battalions.  What

 5     I know, I think that there were four battalions.  I don't know if there

 6     were more.  I never heard of that.  I wasn't from where those battalions

 7     were, and I don't know where they were, you know.

 8             JUDGE KWON:  Thank you.

 9             Mr. Karadzic.

10             MR. KARADZIC: [Interpretation]

11        Q.   Do you agree, Dr. Hajir, that there was a command of the 155th

12     Brigade there with the HQ units, the commands of four battalions with

13     their staff units, and the commands of 15 to 17 companies with their

14     staff units?

15        A.   Where?  Are you thinking of Dobrinja?

16        Q.   That's the 155th.  It was deployed?

17        A.   Yes, yes, that's correct, it did exist.

18        Q.   Thank you.  Can we now look at this document.  We do have a

19     translation.  This is an intelligence report of the 23rd of May, which

20     states that:

21             "Just in the Zikice Jovanovica Spanca Street at numbers," and it

22     gives the odd numbers here, also the even numbers - there are some 20

23     numbers, "that there were strong concentrations of Green Berets.  On each

24     floor, there were two members of the Green Berets in order to prevent the

25     movement and communication between the residents."

Page 8851

 1             And so on and so forth:

 2             "About 40 per cent of the Serbian population moved out of those

 3     buildings."

 4             And so on.  These are armed with automatic rifles, machine-guns,

 5     snipers, hand-grenades, and they are being supplied with food every day.

 6             Did they conceal so many things from you that you didn't know

 7     this?

 8        A.   I am telling you -- I don't know how to convince you.  This is

 9     absolutely unknown to me.  Perhaps I would have known more had I asked.

10     I really never wanted to ask where they were, who they were, what they

11     were doing.  I was doing my job, the task that I set myself, and I did

12     that properly.  As for how others were doing their job and what they did,

13     please don't ask me about that, because I know very, very little of

14     things that were going on around me.

15             THE ACCUSED: [Interpretation] Thank you.  I understand that.

16             JUDGE KWON:  Yes, Ms. Sutherland.

17             MS. SUTHERLAND:  Again, I'm sorry for interrupting.

18             It was my understanding that Mr. Karadzic called up 1D01101.  Is

19     that the document we're supposed to be looking at, because I don't see

20     the information contained therein that he's been stating.

21             THE ACCUSED:  No first was 1100, and next will be 1101.

22             MS. SUTHERLAND:  I'm sorry.  Thank you.

23             THE ACCUSED: [Interpretation] Can we have this document admitted?

24             JUDGE KWON:  Ms. Sutherland.

25             THE REGISTRAR:  Your Honours, if I may, 1D1100 has been admitted

Page 8852

 1     as Exhibit D330.

 2             JUDGE KWON:  Yes.

 3             THE ACCUSED: [Interpretation] Thank you.  I didn't know it's

 4     admitted.

 5             Can we now see 1D1101.  And also information as to its status; is

 6     it already an exhibit?  There it is.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Dr. Hajir, can you look at it?  It's another intelligence report

 9     of the 23rd of May.  It says the Green Berets are stationed in the

10     elementary school Petar Dokic in Cengic Vila.  And about Dobrinja, it

11     says:

12             "We also received intelligence that Osman Lunja and a certain

13     Prutinja harassed 29 Serbs from the Remzije Pehlimanovica Street.  A

14     certain Serif, known as Kise, from Dobrinja, imprisoned 10 individuals,

15     10 Serbs, and was aided by a certain Haris ...," and they tortured the

16     prisoners as well:

17             "On that occasion, they singled out Milorad Djurdjevic just

18     because he was originally from Foca.  They forced the prisoners to admit

19     they had been snipers, and they also inquired as to where prominent Serbs

20     were located."

21             Did you hear of this man Kise?  He was notorious in Dobrinja.

22        A.   I know this Kise, but I know nothing about this incident.  This

23     Kise man is a braggart, arrogant, full of himself.  He came by a few

24     times.

25             THE ACCUSED: [Interpretation] Thank you.

Page 8853

 1             Can we have this admitted?

 2             JUDGE KWON:  I don't see a basis to admit this, Mr. Karadzic.

 3     The doctor knows Kise, but nothing else.  I don't see the point of

 4     putting this to the doctor.

 5             THE ACCUSED: [Interpretation] All right, I understand.  The

 6     doctor, himself, said he didn't know about these things going on, so we

 7     can try it with someone else.

 8             Thank you, Dr. Hajir.  We'll move on through your statement.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Could you help us remember how many of these incidents there were

11     involving several or more casualties?  We know about one football-match,

12     and we know about the line of people queuing for humanitarian aid.  How

13     many incidents were there where civilians were hurt in larger numbers,

14     let's say more than three or more than five?

15        A.   You can see it in my book.  As far as information reached me, I

16     describe very honestly every incident and how many people were hurt.

17     Whether seven or eight people were hurt in each one of them, I don't

18     really know, but it was really deliberate.  People were targeted while

19     waiting for water, while queuing for humanitarian aid.  Doesn't that tell

20     you anything?  It's not only military targets; it was civilian targets,

21     no matter how wretched and miserable these people were, and you never

22     took the trouble to condemn such actions.

23        Q.   I'm afraid you're not very well informed.  I did condemn them,

24     and I asked for investigations.  And we'll demonstrate, concerning a few

25     incidents, exactly who fired.  But since you mentioned that a thousand

Page 8854

 1     civilians were killed in Dobrinja, we have to identify in which incidents

 2     this happened, how this happened.  These had to be dramatic events if a

 3     thousand civilians were killed over 1200 days, whereas there were whole

 4     months passing without a single person killed.

 5             So apart from the football-match and the queue for humanitarian

 6     aid, which feature in my indictment, are there any more incidents

 7     involving massive casualties that we can identify?

 8        A.   Mr. Karadzic, every day injured people came to the hospital.

 9     After two or three years, we still don't have complete statistics, but

10     there was not a single day passing without at least 10 or 15 injured

11     people coming to be treated.  I don't know what kind of military or

12     non-military events they got hurt in.  These statistics are not reliable.

13     I'm just telling you that nobody really was concerned with numbers at

14     that time.  I told you what our priorities were, to what extent we had

15     our hands full.  One of these massacres, remember from my book, this

16     woman, Dr. Krlic, came to help out, and she found her son dead.  He got

17     killed while helping an elderly woman carry water.  How would you react

18     if that happened in the Serbian part of Sarajevo, in a Serbian area?

19        Q.   I agree with you.  Every death is a tragic event for that person

20     and for his or her family.  But we have to deal with statistics here,

21     which you say are not reliable, so we have to take this number of 1.000

22     dead civilians as a very relative number?

23        A.   It could be even more.

24        Q.   Where would they be buried?

25        A.   Mr. Karadzic, the parks were full of graves.  There was one

Page 8855

 1     graveyard in Dobrinja 3 that was so packed there was not an inch of land

 2     to dig anymore.  People buried bodies outside their homes, in their

 3     yards, in their gardens.  It's tragic when you pass through the street,

 4     any street, and see all the places where people are buried.

 5        Q.   Thank you.  We saw on that footage yesterday several graves along

 6     the road.  A thousand graves would be something like the

 7     Arlington Cemetery.  Why don't we see, in any movies, in any newspapers,

 8     a photograph like that, showing at least 100, if not 1.000, graves?  How

 9     come there are no pictures showing large graveyards full of civilian

10     graves?

11        A.   Now, how would I know that?  I did not take any pictures.  I

12     never even went out to look.  But the number of dead is large.  Some

13     people were just driving their dead away somewhere in the city.  Some

14     families came belatedly to pick up the bodies and bury them.

15             If you're talking about pictures, there is a place close to C-4,

16     close to the occupied airport settlement, where there was a large

17     cemetery, for instance.  Maybe Serbs took more pictures than we did.

18        Q.   The Serbs would take that the airport neighbourhood was

19     liberated, whereas you say it was occupied?

20        A.   No, I'm talking about C-4, which is close, next to the airport

21     neighbourhood.  C-4, if you know where that is, comes before the airport

22     neighbourhood and then follows C-5.  On one side, there is the Nedzarici

23     village, and on the other side, there are multi-storey buildings.

24        Q.   Do you agree that we should take into account and acknowledge the

25     statistics kept by the BH Army, both in terms of the numbers of the 155th

Page 8856

 1     Brigade and in terms of the number of "sahids"?  That's what they called

 2     martyrs, that's what they call their dead who got killed in the fighting,

 3     as opposed to civilians?

 4        A.   Yes, if you use the term properly, but that term was also used

 5     for civilians.  We were forced to be there by violent means.  We were

 6     being shot at.  And although in terms of religion, they cannot be really

 7     considered as "sahids," martyrs, but they were still considered as such.

 8        Q.   But if the families received certificates of privatizations and

 9     awards, and if they were granted amounts normally allocated to "sahid"

10     families, can we then take it that these people were fighters, rather

11     than civilians, because civilian families got smaller amounts?

12        A.   You keep talking about rewards.  Take me, for instance, the kind

13     of work that I did for all the people there, and you know what I got in

14     return?  They closed my hospital.  And they did give me the 6th of April

15     decoration, that's true.  The Serbs gave it to me, but nothing more.  I

16     just went back to the clinical centre to a position lower than I occupied

17     before.  What kind of reward did I get?  I'm just asking you because you

18     keep talking about these rewards.  I, for instance, wasn't part of the

19     SDA.  I wasn't part of any party.  Maybe that's the reason, maybe that's

20     the general approach.  I wouldn't know.

21        Q.   Dr. Hajir, I believe your contribution is priceless, from a

22     humanitarian point of view, but I'm trying to establish here how many

23     dead were civilians and how many dead were soldiers.  Do you know that

24     the state provided tombstones free of charge for "sahids," which they

25     didn't do for civilians?

Page 8857

 1        A.   I know that that was the case in Kovaci and in some other places,

 2     they provided tombstones for people who got killed in the fighting.

 3        Q.   Do you know that the BH Army commissioned 40.000 aiming devices

 4     for "sahids," and 39.000 were actually delivered?

 5        A.   No, I don't know that, really.

 6        Q.   You mentioned Zelimir Vidovic.  I'm really sorry about him.  He

 7     was my football player.  I was in Sarajevo when he played.  But have you

 8     heard about Josip Bukal?  He played for the Zeleznice Team.

 9        A.   Yes, we were friends.  He came to see me more than once.

10        Q.   Do you know that Josip Bukal, who, by the way, is a Croat,

11     rescued a large number of Serbs from Dobrinja, and these people owe him

12     their lives and are very grateful to him?

13        A.   I really didn't hear about that.  But all of us would save people

14     when we could, and I did when I could.  I never refused anyone.  I never

15     failed to do whatever I could for people.  I believe that Bukal would do

16     the same, but I really, to tell the truth, didn't see that Serbs were in

17     danger.  There was a discussion we had with the Serbs who were on the

18     staff.  We were talking amongst us, and there were some people who were

19     unhappy about some incidents and quarrels internally, but it was all on

20     the verbal level.  Take this Djurdjica Juric, who worked with us.  Her

21     daughter was shot by a sniper from your side.  She came there, and I

22     offered her an apartment close to the hospital so that she can be nearby.

23     She refused because she lived in another flat with her family.  Her

24     father-in-law was killed outside his home.  That's next to that school

25     which is half Serbian, half Muslim.  I don't know the name of the school.

Page 8858

 1     They lived very close by, in an apartment building.  Bukal is a great

 2     humanist, and I believe, easily, that he helped whenever he could.

 3             I really didn't see that Serbs were in any danger.  If I had seen

 4     anything like it, I would have done all in my power to help them.

 5        Q.   I don't doubt that for a minute.  And if you had been commander

 6     of Dobrinja, it would have been much better.

 7             But you say, in paragraph 42 of your statement, that there were

 8     120 and more injured at the football-match.  130 to 140 persons injured.

 9        A.   Yeah, probably more than that.

10        Q.   But in the Galic case, on page 1716, lines 17 to 24, you said

11     there were 35 soldiers injured and 55 civilians, and that 6 soldiers and

12     5 civilians got killed.

13        A.   I'm sorry, I really don't remember.

14        Q.   Thank you.  Do you remember reprimanding or asking the commander

15     of the 155th Brigade why he had organised that football-match close to

16     the front-line?

17        A.   It was a huge folly, and I told him so the same day.  But he said

18     they wanted it.  What could I do?  I said, You were the commander, you

19     should have stopped it.  There is just a line of buildings separating

20     that football pitch from the front-line, from the Serbian lines.  He

21     should have been replaced, in fact, just before that, but he was,

22     instead, appointed commander -- re-appointed commander.

23        Q.   In paragraphs 48 to 51 --

24             JUDGE KWON:  Just a moment.

25             Yes, Ms. Sutherland.

Page 8859

 1             MS. SUTHERLAND:  I'm sorry.

 2             The proposition that Mr. Karadzic just put to the witness that he

 3     said in the Galic case on page 1716 that 35 soldiers were injured and --

 4     35 soldiers were injured and 55 civilians, and that 6 soldiers and 5

 5     civilians got killed, that's actually Ms. Filipovic reading out a

 6     document, and I can't quite now work out which document it is, but it

 7     wasn't the witness's answer.

 8             JUDGE KWON:  In any event, the witness said he didn't know.

 9             Let's move on, Mr. Karadzic.

10             MR. KARADZIC: [Interpretation] Thank you.

11        Q.   In paragraphs 48 through 51, you speak about problems with water.

12     Did you know that the government of the federation, that is, the Sarajevo

13     Muslim Croat government, created, deliberately, huge disruptions in water

14     supply?

15        A.   I didn't know that.  In fact, I don't know.  But how would they

16     be able to do that?  Why would they do that?  Leaving people without

17     water is the same as killing them.

18        Q.   Did you know that water supply depends on electricity supply, and

19     whenever the transformer station in Bacevo is hit, the water supply

20     stops?

21        A.   You know, I never gave any thought to the routes of water supply.

22        Q.   Did you know that we never closed the water from Jahorina, from

23     Bistrica, but we actually shared with Sarajevo, a little bit for Pale and

24     a little bit for Sarajevo, and the only water restrictions came from

25     Bacevo, from the Bosna River source, because of electricity cuts?

Page 8860

 1        A.   I didn't know that.  Well, you can put yourself in my place.  You

 2     know, what would you think?  There was constantly a shortage of water,

 3     but we had water supplies.  Mr. Dusko, who is a very good friend of

 4     mine - he's deceased now - he obtained a 25.000-litre water cistern for

 5     the needs of the hospital.  We brought that to the shopping centre, and

 6     we connected it to the water supply.  So when the water was cut off, we

 7     would have water.  In the beginning, we would bring it in buckets from

 8     the well.  Later, we resolved it in this way.  And what you are saying, I

 9     really don't know.  I would have liked -- I really would have liked -- I

10     even listened to "SRNA" regularly.  Thousands of things that happened in

11     front of your very eyes, they would turn 180 degrees around.  Serbs, who

12     were leaving in order to be accepted wherever they were going, were

13     labelling and saying things because of political interest.  Mr. Karadzic,

14     you have to differentiate between what is true and what isn't.  There is

15     a significant difference.

16             I mean, there was a case that happened in front of my eyes, and

17     then in "SRNA" that event would be presented 180 degrees differently and

18     it would be against the Muslims.  That's why I stopped listening.

19        Q.   Thank you.  Do you know that these 300.000 -- 350.000 citizens

20     from paragraph 50 included 50.000 to 70.000 Serbs?

21        A.   I know that there was a large number of them, but I don't know

22     how many.

23        Q.   And do you believe that we would have abused those 50.000 to

24     70.000 Serbs only to harm the rest of the population that was Muslim and

25     Croat?  Would we have done something like that deliberately?

Page 8861

 1        A.   Practice indicates that you did.  You were shooting.  Do you know

 2     how many Serbs were killed from these shells?  I mean, my heart really

 3     pains when I think of all the large number of Serbs and their families

 4     that were casualties because of this, not just Muslim families.  And I'm

 5     saying this because I know.  These were wonderful people who were full of

 6     goodness.

 7        Q.   Thank you.  And here, in paragraph 56, you talk about the suicide

 8     rate.  Is it correct that during your stay there, there were five to six

 9     suicides?

10        A.   There weren't more than that, at least not to my knowledge and

11     what was reported to the hospital.

12        Q.   Do you know that, annually, the average rate of suicide is 15

13     applied to 100.000 citizens in Serbia?  In Slovenia, this rate is 27, and

14     for Vojvodina, 2, and for Hungary and Finland, it's 28?

15        A.   Mr. Karadzic, this figure is quite small.  I spoke in -- I was

16     surprised, myself.  I mean, there wasn't a significant suicide rate.  I'm

17     also surprised.  I think that the rate of suicides now is much higher

18     than it was during the war.  I'm talking about Dobrinja, at least.

19        Q.   All right, thank you.  In paragraph 59, it happened that you say

20     that the Serbs were preventing civilians from leaving Sarajevo.  Do you

21     know that Serbs always asked for free passage of civilians, and that the

22     Muslim side did not allow that?  And there is evidence of that also with

23     the United Nations.  Did you know this?  Or perhaps you didn't know that,

24     but you said this?

25        A.   Do you think if I had known that, I would have left my three

Page 8862

 1     daughters and my wife in Sarajevo?  I would have contacted you, if

 2     possible, or anyone else in Republika Srpska, and I would have asked for

 3     anything just to get them out of there.  I spent many sleepless nights

 4     because of them.  And in spite of being tired and working hard, I had to

 5     be thinking about my family.  And had I been able to get those folks of

 6     mine out, I would have done so to spare them the misery.

 7        Q.   Thank you.  But this was a well-known fact.  We were constantly

 8     appealing, through General Morillon and others, and it was constantly in

 9     the media.  Mrs. Plavsic also was requesting freedom of movement, and we

10     also signed, in Geneva and in London, several times the commitment to

11     allow civilians to leave the zone of combat, and we respected that.  But

12     Mr. Izetbegovic said that he was not going to permit Sarajevo to empty

13     itself.  I'm sorry you didn't know that, but it is a fact.

14             Here in paragraph 60 --

15             JUDGE KWON:  Do not make speeches.

16             Dr. Hajir, do you agree?

17             THE WITNESS: [Interpretation] Yes, with what he said?  Well, I

18     said I didn't know what he was saying, I don't know if I agree or not.  I

19     was in the position that I was in.  Thousands of people every day were

20     passing by.  I mean, I don't know.  I don't agree with that.

21             MR. KARADZIC: [Interpretation] Thank you.

22        Q.   In Article 60 -- I mean, in paragraph 60, you are thinking about

23     what the objective of the Serbs was.  If I were to tell you that the

24     United Nations, and the witness confirmed that here, stated that the

25     objective of the Serbs was to keep the 1st Corps in Sarajevo until a

Page 8863

 1     political solution was reached, does that then explain why the Serbs did

 2     not capture specific neighbourhoods, such as Dobrinja, or Sarajevo,

 3     itself?

 4        A.   I don't think that -- I mean, they took whatever -- I'm sorry.

 5     You are trying to approach and present this from your point of view, and

 6     that is your side.  I am trying to talk about things as an individual,

 7     about things that I took part in and where I tried to help.  So I really

 8     cannot agree that that was so.

 9        Q.   Thank you.  I am sorry about your heart attack, from Article 61,

10     but do you agree that in these more recent statements of yours, in a way,

11     the number of victims has grown, the number of operations, the number of

12     wounded?  How did it happen that in later statements, and

13     Article 164 - this is more recent information dating from February of

14     this year - there is a kind of inflation of the number of victims?  The

15     number of victims, the figures are bigger.

16        A.   The war was at its most intense in 1993 and 1994, so even in the

17     summer of 1992, the numbers were not lower, either.  But a higher

18     intensity of the war was then, so it's logical to expect a greater number

19     of victims as well.

20             JUDGE KWON:  Yes, Ms. Sutherland.

21             MS. SUTHERLAND:  Your Honour, I think the witness has

22     misunderstood the question.  But nothing has been inflated.  This has all

23     been taken from prior testimony and/or prior statements of Dr. Hajir, the

24     information contained in the amalgamated witness statement.

25             JUDGE KWON:  What paragraph was it?

Page 8864

 1             MS. SUTHERLAND:  Your Honour, Dr. Karadzic -- Mr. Karadzic is

 2     just saying, generally, how come the figures are inflated now in the

 3     amalgamated statement, taken in February 2010, as opposed to prior

 4     statements and prior testimony.  What I'm saying is there's no inflation

 5     in this statement; all of the figures come from either prior testimony or

 6     prior statements provided by the witness.

 7             JUDGE KWON:  Mr. Karadzic referred to Article 164, which I

 8     couldn't follow.  What is it, Mr. Karadzic?

 9             THE ACCUSED: [Interpretation] Generally speaking, this article

10     gave me some kind of cue, it prompted me, because this statement, new

11     information provided on the 25th of February, 2010, and then I remembered

12     that there were 35 and 55 wounded, 35 soldiers and 55 civilians, and that

13     there were 6 killed and 5 civilians killed in the football-match.  Later,

14     it appears that there were 140 wounded and 14 killed, so I was just

15     interested how this --

16             JUDGE KWON: [Previous translation continues]... what we dealt

17     with minutes ago, when you clarified, Ms. Sutherland.

18             MS. SUTHERLAND:  Your Honour, none of the new information

19     provided by the witness on the 25th of February relates to figures of

20     people killed or wounded during the war.  What Mr. Karadzic keeps

21     repeating about these 35 wounded or 55 wounded is a document that was put

22     to Dr. Hajir by the Defence counsel in the Galic case, and it was a

23     document, I think, that was actually signed by one of the military

24     commanders.  But it wasn't anything that Dr. Hajir has ever said.  And

25     his answer -- the question, a large portion of the document was read out,

Page 8865

 1     and then the question was:

 2             "Sir, you told us that Ismet Hadzic, after that event, would come

 3     to the hospital?"

 4             To which the witness replied:  "Yes."

 5             That's what he was replying yes to was the question that the

 6     commander came to the hospital, not in relation to the number of dead and

 7     wounded, because he said earlier in the transcript in Galic -- at

 8     page 1708, it was put to him that roughly 140 people were admitted and

 9     there were 13 or 14 people killed:

10             "Did you note --"

11             The question was:

12             "Did you note --" this is in cross-examination -- "for these

13     people, whether these were soldiers or civilians?

14             "A.  To be quite honest, we never took note of whether a patient

15     was a military man, a civilian, or anything else.  We didn't take note of

16     that."

17             JUDGE KWON:  Thank you, Ms. Sutherland.

18             Mr. Karadzic, I think it's time for you to wrap up your

19     cross-examination.

20             THE ACCUSED: [Interpretation] If I can have a little bit more

21     time, just a few more questions which could be answered with a yes or a

22     no.  It would really be a pity not to complete this cross-examination.

23     There is a large number of statements.  Many have now been relativised,

24     so I must ask the doctor if he knew about some crucial events.

25             JUDGE KWON:  I didn't understand that.  I think you can conclude

Page 8866

 1     in 10 minutes, Mr. Karadzic.

 2             THE ACCUSED: [Interpretation] I will try, and I'm going to ask

 3     Dr. Hajir that we proceed with Yes or No whenever possible.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Did you know that Mr. Izetbegovic declared a general mobilisation

 6     on the 4th of April, 1992?

 7        A.   I cannot remember the date, but he did declare a general

 8     mobilisation.

 9        Q.   Thank you.  Did you know that Hasanefendic in April, on the 12th

10     of April and the 29th of April, on two occasions, thus ordered attacks on

11     the JNA, and the blocking of all barracks, and the barricading of all

12     roads?

13        A.   No.

14        Q.   Do you know, do you recall that on the 2nd of May, near the

15     Skenderija Bridge, several soldiers were killed, their cars were burned?

16     They were on their way to evacuate soldiers from the JNA hall.

17        A.   I saw that in the news, but I wasn't nearby.

18        Q.   Thank you.  Do you recall that on the 3rd of May in Dobrovoljacka

19     Street, there was a large massacre where half the JNA column -- of a half

20     a JNA column that was withdrawing?

21        A.   I heard that there was an incident.  I didn't hear of any

22     massacre.  I wasn't there, so I didn't see it, I didn't -- I wasn't

23     there, so I really cannot give you any opinion on that.

24        Q.   Thank you.  Did you know that Alija Delimustafic, the minister of

25     internal affairs, already on the 4th or 5th of May, accused Avdo Hebib,

Page 8867

 1     Ganic, Kljujic, and others of declaring war against the JNA and

 2     initiating a war against the JNA?

 3        A.   I didn't really know.  I didn't know about that, no.

 4             THE ACCUSED: [Interpretation] May I now look at 1D13 -- I'm

 5     sorry, first we will look at 1092.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Did you know about the abuses of ambulance vehicles, that the

 8     army used ambulances in order to transport soldiers to positions, and so

 9     on and so forth?

10        A.   I really don't approve of that, and I never had any part in such

11     things.  I don't even know if this happened.  Our ambulances from

12     Dobrinja were never abused.  They were always marked.  They were always

13     shot at.  There are big holes, small holes on the cars.  Those vehicles

14     were marked.  Never, ever did we ever abuse that.  I don't know about

15     other such cases with ambulances.

16        Q.   Thank you.  I completely believe you, but this official note

17     states that in your neighbourhood, close to you in Ilidza, the

18     Green Berets, already on the 4th of May, 1992, abused vehicles marked as

19     ambulances with the red cross.  They used them for combat purposes.  Do

20     you see this official note?

21        A.   Which one is it?  Is it this one?

22        Q.   There's a Serbian and an English version.

23        A.   Yes, I see it.

24        Q.   Thank you.  Do you agree that this could have made the transport

25     of your wounded to Sarajevo even more difficult, for which in the

Page 8868

 1     beginning you easily made agreements with Serbian check-points?  Later,

 2     this was more difficult.  Could such incidents have contributed to this

 3     distrust?

 4        A.   Yes, of course they could have, but they could have also

 5     inspected the cars, looked at the situation, and allowed the people

 6     through, pursuant to the agreement.  This co-operation was severed, to

 7     the detriment of all of us, Serbs, Muslim, Croats, because those people

 8     could have received better treatment, better care, in a more -- in a

 9     better-equipped institution.  So this was to the detriment of all of us.

10     There is the Geneva Conventions.  They condemned such things, misuses of

11     medical vehicles and firing at such medical vehicles.  However, these

12     medical -- these Geneva Conventions were not respected, neither from your

13     side and, I believe in certain cases, on the Muslim side too.

14     Unfortunately, things are like that.

15             May I comment, Mr. Karadzic?  You have give some -- been given

16     some space.  May I also get some moments to give you my impressions about

17     all of that?

18        Q.   Well, I would rather for us to meet when I return.  Impressions

19     don't help us much.  We need information and knowledge here.  I think

20     that this would be nice.  Unfortunately, we don't have enough time.

21             Is it correct that your 30 to 40 employees, the hospital staff,

22     were members of the B and H Army?

23        A.   Correct.  There were 43, and that's why this misunderstanding

24     occurred.  There were 43 members of the armed forces who were perhaps

25     given an assignment, but they didn't go anywhere.  They continued working

Page 8869

 1     in the hospital.  But at one point, there were 158 staff.  The number

 2     fluctuated all the time.  Some people came, some people went away.

 3     People came from town to help out.  Muslims and Serbs left the hospital

 4     on their own errands.  The number varied all the time.  We received

 5     everyone, however.  And I don't see why something offered by the army

 6     would be refused.  In that general poverty and misery, if anything can be

 7     received, then let it.  But I wanted to register the hospital officially

 8     so that people get at least an allowance from the Ministry of Health.

 9        Q.   Did you have a course of military surgery for your staff members?

10        A.   You see, in Dobrinja, Kuzmanovic and many other Serbs, very nice

11     young men with whom I worked and met socially, Dr. Vranic organised, when

12     the war in Croatia began, a course of military surgery, and at the

13     beginning we were laughing.  Nobody believed we'd ever need it.

14     Interpersonal relations were still good among all ethnic communities.

15     But in my hospital, I had to start from scratch because 90 per cent of

16     staff were absent.  First of all, I had to get hold of basic equipment.

17     The first surgery I did with Dr. Vranic lasted seven hours.  Transport

18     was a problem.  Blood transfusions were a problem.  I had to send my

19     staff to the Institute for Transfusions to teach them the basics.  We had

20     a crash course in emergency surgery.  All sorts of things needed to be

21     done preliminarily before the hospital took off.

22             THE ACCUSED: [Interpretation] Can this page be admitted, please?

23             JUDGE KWON:  Dr. Hajir, the document which is in front of you,

24     called a memo, says that the Green Berets were in possession of two vans

25     with Red Cross insignia on them.  Did you know or hear such facts?

Page 8870

 1             THE WITNESS: [Interpretation] Never.  I neither approve, nor have

 2     I ever heard of anything like that.

 3             You see, there's one thing with Mr. Karadzic.  He ascribes and

 4     blames everything on Green Berets.  There are --

 5             JUDGE KWON:  Doctor, you said, did you not, that this could have

 6     contributed to distrust?  Did you say that on a hypothetical basis?

 7             THE WITNESS: [Interpretation] What do you mean; those vehicles?

 8             JUDGE KWON:  Yes.  And in answering the question by the accused,

 9     Dr. Karadzic, you confirmed that it might have contributed to distrust,

10     so I was wondering whether you confirm that such abuses of ambulances

11     really took place.

12             THE WITNESS: [Interpretation] No, I did not confirm that, Judge.

13     I'm just speaking, in very general terms, about using humanitarian

14     vehicles for war purposes.  I know nothing about this specific incident.

15             JUDGE KWON:  Mr. Karadzic, we don't see a basis to admit this

16     document.  And I think it's time to conclude --

17             THE ACCUSED: [Interpretation] Very well.

18             JUDGE KWON:  -- your cross-examination.

19             THE ACCUSED: [Interpretation] Can I ask one more question?

20             Can we see 1D135.

21             MR. KARADZIC: [Interpretation]

22        Q.   Dr. Hajir, you considered yourself, after November 1994, no

23     longer a member of the BH Army, that is, the 155th Brigade?

24        A.   That's correct.

25        Q.   But if you look at this document, they continue to consider you,

Page 8871

 1     as of the 9th of June, 1995, a member of the brigade.  And in this

 2     report, concerning Operation Vranduk, involving the detachment called

 3     El Mujahid, information is provided to the General Staff of the BH Army

 4     about foreign nationals in Sarajevo, and it says:

 5             "Hasan Nemar, member of the 101st Brigade, Mustafa Bakou, member

 6     of the 101 Brigade, Khachouf, Habib, member of the 152nd Brigade, and

 7     Youssef Hajir, member of the 155th Brigade."

 8             They don't say anything unkind about you, but they have nothing

 9     good to say about the others.  Do you know any of the people on that

10     list?

11        A.   I still know Hasan and Mustafa, the first two on this list.  The

12     first one is an agronomy engineer who used the plot of land between

13     Alipasino Polje and Cengic Vila.  You know, there's a mosque there now

14     and a disco.  That area used to be empty, and he used it as a vegetable

15     garden to feed people.

16             I know Mr. Bakou now, but I didn't know him during the war.  I

17     didn't even know such a man existed.  As for Mr. Khachouf, I don't know

18     him at all.

19             Now, that they considered me a member of the 155th Brigade in

20     1995, that's certainly a mistake.  If I had been, I would be receiving a

21     larger pension.  The truth is that I was not a member at that time.  If I

22     had been, perhaps it would have been better for me, my pension would be

23     higher.

24             THE ACCUSED: [Interpretation] Can we see the next page to see the

25     signature and the reason why the El Mujahid Detachment got angry with the

Page 8872

 1     BH Army.

 2             If we could zoom in on the last-but-one paragraph.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   It says:

 5             "The attitude of the El Mujahid Detachment towards the BH Army is

 6     characterised by a general lack of trust, which dates back to the events

 7     in autumn, 1992, when, in the course of capturing Cekrcici village, they

 8     were wedged because the BH Army did not secure their flanks."

 9             Do you know where Cekrcici is?

10        A.   Yes.  I passed by several times.  I really don't know anyone from

11     the El Mujahid Detachment.  I heard of their existence, but I really

12     don't know these people.  I don't know what they did and how they worked.

13     I have no clue.

14             THE ACCUSED: [Interpretation] Let me thank you, Dr. Hajir, for

15     all that you've done as a doctor for Serbs, Muslims, and Croats alike,

16     and for your testimony as well.

17             May this document be admitted?

18             JUDGE KWON:  We'll mark it for identification.

19             THE REGISTRAR:  As MFI D857, Your Honours.

20             JUDGE KWON:  Without having to have a break -- yes,

21     Ms. Sutherland.

22             MS. SUTHERLAND:  I'm sorry.

23             The Prosecution does have a translation of that that we can send

24     to the Defence to up-load into e-court.  And I just note that in

25     Dr. Karadzic's question, he said:

Page 8873

 1             "They don't say anything unkind about you, but they have nothing

 2     good to say about the others."

 3             In fact, after the four individuals are named, the sentence says:

 4             "We reported on them already in our documents.  The persons in

 5     question lived in the Republic of Bosnia-Herzegovina before the

 6     aggression.  We do not have at our disposal information on these persons

 7     that is of interest, in terms of intelligence."

 8             I think Dr. Karadzic was overstating what was, in fact, in the

 9     document.

10             JUDGE KWON:  I take it there's no objection to admitting that.

11     We'll just admit it.

12             THE ACCUSED: [Interpretation] May I -- may I just explain?

13             When I said, About you, They don't say anything about you, unkind

14     about you, I meant the four of them.  But the other members of the

15     El Mujahid --

16             JUDGE KWON:  It's not necessary.

17             Ms. Sutherland, do you have re-examination?

18             MS. SUTHERLAND:  Sorry, Your Honour.  I was --

19             JUDGE KWON:  I asked whether you --

20             MS. SUTHERLAND:  No, Your Honour, I don't.  I'm sorry, I was

21     discussing something with Mr. Reid, and I apologise.

22             JUDGE KWON:  Thank you.

23             Dr. Hajir, that concludes your evidence.  Thank you very much for

24     your taking time to give your testimony again to the Tribunal, and now

25     you are free to go.

Page 8874

 1                           [The witness withdrew]

 2             JUDGE KWON:  Well, unless there's other matters to raise, that

 3     will be it for today, and we will resume tomorrow at 2.15.

 4             The hearing is now adjourned.

 5                           --- Whereupon the hearing adjourned at 10.34 a.m.,

 6                           to be reconvened on Wednesday, the 3rd day of

 7                           November, 2010, at 2.15 p.m.