Tribunal Criminal Tribunal for the Former Yugoslavia

Page 18131

 1                           Thursday, 1 September 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 9.01 a.m.

 6             JUDGE KWON:  Good morning, everyone.

 7             Good morning, Mr. Witness.  If you could take the solemn

 8     declaration, please.

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

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

11                           WITNESS:  KDZ-603

12                           [Witness answered through interpreter]

13             JUDGE KWON:  Thank you.  Please be seated and make yourself

14     comfortable.

15             Sir, I would like to inform you on behalf of the Chamber that you

16     will be testifying today with the benefit of pseudonym, image and voice

17     distortion, this means that there will be no reference to your real name

18     or information which might reveal your identity to the public or media.

19     The audiovisual record of your testimony which is broadcast to the public

20     will have a distorted image, I think we can show it right now, like this,

21     and distorted voice to ensure that your identity is protected and the

22     transcript, while available to the public, will always refer to your

23     pseudonym.

24             Do you understand, sir?

25             THE WITNESS: [Interpretation] I do.

Page 18132

 1             JUDGE KWON:  Thank you.  Mr. Gaynor?  Good morning to you.

 2             MR. GAYNOR:  Thank you, Mr. President.  Good morning.

 3                           Examination by Mr. Gaynor:

 4        Q.   Good morning, Witness.

 5        A.   Good morning.

 6             MR. GAYNOR:  Could I please call up 65 ter 90267, which is not to

 7     be broadcast.

 8        Q.   And Mr. Witness, two days ago, did you have the opportunity to

 9     review, with the assistance of an interpreter, and with me, a witness

10     statement?

11        A.   Yes.

12        Q.   Did you make some corrections to that statement and then sign it?

13        A.   Yes.

14        Q.   On the screen in front of you, could you confirm that you see

15     your name and your date of birth?

16        A.   Yes.

17        Q.   On the screen in front of you, is that a copy of the first page

18     of the statement which you reviewed and signed?

19        A.   Yes.

20        Q.   Now, since you signed that statement, you've informed me of one

21     other clarification which I'll make now for the record.  On page 5 at

22     paragraph 23, your statement says that you saw 20 bodies in Drum.  Is it

23     correct that you personally observed 10 bodies in Drum on the day of the

24     massacre?

25        A.   I saw 10 bodies.

Page 18133

 1             THE ACCUSED: [Interpretation] Objection to the qualification.

 2     I would ask Mr. Gaynor not to qualify that as a massacre until we see

 3     that it actually was a massacre.

 4             JUDGE KWON:  I thought he was referring to his statement, what --

 5     to what he said in his statement.  Mr. Gaynor?

 6             MR. GAYNOR:  Yes, I was referring to the statement which

 7     describes the events in Drum as a massacre.  I was referring to page 5,

 8     paragraph 23.

 9             THE ACCUSED: [Interpretation] But in the paragraph there is no

10     mention of a massacre, I think.

11             MR. GAYNOR:  Very well, elsewhere, it's referred to as a massacre

12     but I take Mr. Karadzic's point.  I would like to make one other

13     correction, which is an ERN number which appears on page 10 at

14     paragraph 37, line 3, the ERN number 0101-8994 should read 0101-8984.

15        Q.   Mr. Witness, subject to those corrections, do you adopt that

16     statement as your evidence, and if you were asked questions on the same

17     subjects today, would you provide the same answers?

18        A.   Yes.

19             MR. GAYNOR:  I tender the statement under seal, Mr. President.

20             JUDGE KWON:  Yes, it will be admitted under seal.

21             THE REGISTRAR:  As Exhibit P3262, under seal, Your Honours.

22             MR. GAYNOR:  I'll now read, for the benefit of the public, a

23     summary of the statement.  The witness gave evidence of the killing by

24     Serb forces of Muslim men in Drum, a Muslim hamlet on the outskirts of

25     Vlasenica town on the 2nd of June, 1992.  Serb police came to Drum in

Page 18134

 1     late May 1992 and demanded over loudspeakers that the Muslims surrender

 2     their weapons.

 3             The witness's house in Drum was located on raised ground

 4     affording an excellent view of the village.  From there, early on the

 5     2nd of June, 1992, he saw heavily armed men lying hidden in the grass and

 6     around the village.  Upon the arrival of an armoured vehicle, the men

 7     broke cover and the witness then saw an extended chain of soldiers emerge

 8     from cover.  The armoured vehicle went along the road through Drum

 9     firing, and the soldiers went from house to house, dragging people out of

10     their houses.  The witness describes several incidents where he saw

11     soldiers shooting men in front of their houses with bursts of machine-gun

12     fire.

13             The women, children and old men of the village were ordered to

14     congregate at a particular location.  While the surviving villagers were

15     held there under armed guard, a police car came.  The driver of the

16     police car was a man known by the nickname Car.  The person with Car wore

17     a reserve police uniform and carried a sniper rifle.  There was also a

18     military jeep.  The villagers were loaded on to a bus amid a barrage of

19     insults relating to their Muslim ethnicity and driven to Susica camp.  As

20     the bus left Drum, the witness could see bodies lying around the village

21     of men who had been killed in the attack.  He names ten of the victims.

22             At Susica camp, Serb soldiers ordered the Drum villagers off the

23     bus and into a warehouse which was eventually filled with around

24     1.000 other non-Serbs.  For the first days at Susica there was no food.

25     On the third day, men from Vlasenica municipality came to Susica to issue

Page 18135

 1     permits to those detainees who agreed to sign a statement saying that

 2     they were leaving the municipality voluntarily.  About 800 detainees

 3     signed such statements, were loaded on to buses and driven away.

 4             During that period, the witness also -- the witness saw girls

 5     being taken away and returned sometime later.  He also saw detainees who

 6     appeared to have been beaten, after having been interrogated at the SUP

 7     building in Vlasenica.  The witness spent 28 days in Susica and was then

 8     transferred to Batkovic camp.  He was detained there with 1.600 other

 9     detainees until he was exchanged on 7 December 1992.

10             That ends the summary.

11        Q.   And now I have just one or two questions for you, Mr. Witness.

12             The first concerns the disarmament of your village before the

13     killing took place.  Could you confirm whether weapons were handed in

14     when the Serb police came to your village?

15        A.   Well, it was just those who had a licence for hunting weapons,

16     nobody else had any weapons.  I saw two people handing in the weapons.

17     They took them to the SUP.  Nobody else in the village had weapons.

18        Q.   I want you to take -- take you to the day of the attack itself,

19     the 2nd of June, 1992.  Did you at any time, prior to or during the

20     attack, see anyone among your neighbours or among the inhabitants of Drum

21     offer any kind of resistance to the soldiers carrying out the attack?

22        A.   No.

23             MR. GAYNOR:  I have no further questions for the witness.  There

24     are no associated exhibits.  The Batkovic list which is referred to at

25     page 10 of the witness's statement has been admitted as P3213.

Page 18136

 1             JUDGE KWON:  Thank you, Mr. Gaynor.

 2             MR. GAYNOR:  Thank you, Mr. President.

 3             JUDGE KWON:  Sir, you will be further asked by the accused,

 4     Mr. Radovan Karadzic, in his cross-examination.  Are you ready,

 5     Mr. Karadzic?

 6             THE ACCUSED: [Interpretation] Yes.  Good morning, Excellencies.

 7     Good morning to everyone.

 8                           Cross-examination by Mr. Karadzic:

 9        Q.   [Interpretation] Good morning, Witness, sir.

10        A.   Good morning.

11        Q.   I would like to ask you, earlier you said that nobody had weapons

12     in Drum other than hunting weapons; is that right?

13        A.   Yes.

14        Q.   And that there was no resistance; is that right?

15        A.   Right.

16        Q.   Is it true that Drum is a village close to Vlasenica, that it's a

17     part of the local commune, the greater local commune of Piskavica, and

18     that it's a Muslim-dominated settlement and local commune?

19        A.   Yes.

20        Q.   So in your statement, on page 2, paragraph 2, you say that the

21     population of Drum was Muslim with just a few Serbs living in the area,

22     mostly on the outskirts.  This is your formulation, mostly on the

23     outskirts, or was that suggested to you?

24        A.   The first house was a Serbian house and then outside of Drum

25     there were five or six Serbian houses.  We were in the middle, closer to

Page 18137

 1     Vlasenica than to Piskavica.

 2        Q.   You were born in Rovasi; is that correct?

 3        A.   Yes.

 4        Q.   Rovasi and Drum, were they organised militarily before the war,

 5     if you know?

 6        A.   I don't know.

 7        Q.   When you say that there were no weapons in Drum, would it then be

 8     more correct to say that you don't know if there were or weren't, rather

 9     than knowing that there weren't any?

10        A.   Well, I didn't see any.

11        Q.   One of our previous witnesses, who luckily was not protected

12     here, said that Drum, the Muslims in Drum, were better organised than the

13     Muslims in Vlasenica.  What do you say to that?

14        A.   I don't know that.

15        Q.   And did he speak something that was not true?

16        A.   Well, you can ask him.

17        Q.   Did you know imam or hodza Munib Ahmetovic?

18        A.   Yes.

19        Q.   And do you know that the imam worked to provide weapons to the

20     Muslim people including those in Drum?

21        A.   No.

22        Q.   And did you know that there was a Crisis Staff in Drum, a Muslim

23     Crisis Staff, for the entire Vlasenica area and that meetings were held

24     there and weapons were being prepared?

25        A.   No.

Page 18138

 1        Q.   Do you know who Ferid Hodzic is and where the house of his father

 2     is?

 3        A.   I do know Ferid, but I don't know where his father's house is.

 4        Q.   Do you know that Ferid was appointed and a self-appointed

 5     commander of Muslim paramilitary forces in Vlasenica?

 6        A.   No.

 7        Q.   Do you know that there was a Patriotic League Green Berets in

 8     Vlasenica, that Ferid Hodzic, together with the chief of police, was

 9     forming a secret army of Vlasenica?

10        A.   Well, I don't know.  I didn't see that.

11        Q.   And do you know Tutic, who has a shop in Piskavica?

12        A.   No.

13        Q.   And do you know Hasan Dautovic from Piskavica?

14        A.   No.

15        Q.   How far is Piskavica from where you were?

16        A.   It's about 400 metres from my house to Piskavica.

17        Q.   And do you know Nezir Alicevic?

18        A.   Yes.

19        Q.   And his brother Huso?  You said that you saw him get killed?

20        A.   Yes.

21        Q.   Do you know Bego Puric?

22        A.   Yes.

23        Q.   Puric Bego from Drum?  He lives in Drum?  No?

24        A.   No.

25        Q.   Thank you.

Page 18139

 1             THE ACCUSED: [Interpretation] Can we see 65 ter 8852 in e-court,

 2     please?  I'm sorry, can we have 1D4063.

 3             1D4063, please, first, and then we will go back to your

 4     statement.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   This is a statement of imam Efendi Munib Ahmetovic, the hodza

 7     that you knew, and you can see that in this first box it states, in the

 8     beginning of 1992, he was summoned, he was approached by the former

 9     police station commander, Fadil Turkovic, who was the commander of the

10     police at the time, and offered him Kalashnikovs at a price of

11     1.500 marks per piece.  And then later it says:

12             "In February I was called by Mustafa Imamovic, Zubovic Sahib and

13     Ferid Hodzic, who introduced themselves as the Crisis Staff.  We went to

14     Hodzic Ferid's house in Drum, where they asked me to swear and then they

15     offered me to do some work for them about arming the Muslim people.

16     I agreed and we decided," and so on and so forth.

17             Can we look at the next page, please?

18             And, sir, you can see this was on the 23rd of April, the hodza

19     had already told all these things to the police.  And then up here, he is

20     explaining to whom he gave those 10 or 11 automatic rifles and rifles,

21     and you can see how many of them are from Drum, Alicevic Nezir, Nezir's

22     neighbour in Drum, he doesn't know his name, it's probably Huso, because

23     we checked, then Hasan in Piskavica, Tutic in Piskavica, and so on and so

24     forth.  And you say that they didn't have weapons.  Is that correct?

25        A.   I didn't see any.  I wasn't really dealing with that.  Nobody

Page 18140

 1     informed me that they were issuing them or not issuing them, selling them

 2     or not selling them.  I don't know that.

 3             THE ACCUSED: [Interpretation] Can we scroll down a little bit,

 4     please?

 5             JUDGE KWON:  Mr. Karadzic, this is an example how you waste your

 6     time.  The witness says he doesn't know.  There is no point of continuing

 7     this part with the witness.  You can call other witnesses to rebut the

 8     witness's evidence or credibility later on.

 9             THE ACCUSED: [Interpretation] I didn't see it.  [No

10     interpretation].

11             JUDGE KWON:  I don't think we get the interpretation.  Could you

12     repeat, Mr. Karadzic?

13             THE ACCUSED: [Interpretation] Yes.  With all due respect, this

14     witness asserts that they didn't have any.  I am proving that they did.

15     And his answer is not correct.  It would be more correct to say that he

16     doesn't know.

17             JUDGE KWON:  The thing is that you're not proving, you're just

18     arguing with the witness.  The witness said he didn't see or he didn't

19     know.  Then, that's his answer and you just get on with it.

20             THE ACCUSED: [Interpretation] Thank you.

21             MR. KARADZIC: [Interpretation]

22        Q.   In your statement of the 30th of May, 2000, this is 65 ter 8852,

23     on page 2, you say that Serbian families started to evacuate, to flee

24     from Vlasenica, which at that point in time made Vlasenica have a very

25     high Muslim population.

Page 18141

 1        A.   No.  I didn't see any Serbs being moved from Vlasenica.

 2        Q.   Well, let's look at the statement.

 3             JUDGE KWON:  Why don't you upload 8852, and Mr. Karadzic and

 4     Mr. Witness, please put a pause between your questions and answers,

 5     because both of you are speaking the same language and which have to be

 6     translated into either English or French.  So, please slow down and put a

 7     pause before you start answering or questioning.

 8             Yes, Mr. Karadzic.

 9             MR. KARADZIC: [Interpretation] Thank you.

10        Q.   While we are looking for the place, I'm going to tell you how

11     that sounded.  It said Serb families began to evacuate from Vlasenica,

12     which made Vlasenica predominantly a Muslim town, and then later you said

13     Muslims also began to evacuate and go to Kladanj.  It was very tense,

14     there was a lot of confusion, a lot of stories, and it was impossible to

15     know what the best thing would be to do.  Did you know about that?

16        A.   I know that a week before you could get a certificate for those

17     Muslims who wanted to go from Vlasenica from Kladovo.  There was no other

18     way to leave.  Otherwise, there was a possibility that those who knew

19     could leave through the woods.

20        Q.   Serbian version on page 5, what was just said, and we are now

21     going to look for the part in English.  English page 8, with this number.

22     Can you look at paragraph 4.

23             "When the Bosnian Serbs took Zvornik, a month before Vlasenica,

24     we really started to worry as to what will happen to us, because in this

25     uncertainty, people started to leave Vlasenica.  Serb families started to

Page 18142

 1     evacuate" --

 2             JUDGE KWON:  I think I see this exact, almost identical para in

 3     para 5 of his amalgamated statement.  Yes, please continue.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Before the conflict broke out, did both Serb and Muslim families

 6     begin to leave Vlasenica and more so the Serbs?

 7        A.   I didn't see who of the Serbs left.  The Muslims were leaving.

 8     If they had an approval to go to Kladanj or permission and others went

 9     through the woods.

10        Q.   We are talking about the time before the conflict broke out.  Did

11     you not say that the Serbian families were moving out of Vlasenica as it

12     says here, or is this not your statement?

13        A.   Well, only if they were leaving on their own, because of the

14     uncertainty.  There were more Muslims in Vlasenica municipality but there

15     was no weaponry, nobody was putting up any resistance.

16        Q.   What I'm worried about, Witness, sir, is that if the words that

17     are in this statement are yours?  Do you stand behind the words?  Do you

18     know what you said?

19        A.   Well, if some Serbs were leaving Vlasenica, they were leaving

20     voluntarily so that they would be safe until they would see what was

21     going on in Vlasenica.

22        Q.   But you don't remember saying this; is that right?

23        A.   Well, I didn't see them leaving.  I mean, I don't have anything

24     to remember or not.

25        Q.   Very well.  You said in your statement of the 6th of July, 1994,

Page 18143

 1     on page 1, it's the same number of this but the page has to be somehow

 2     different, we will see.  You say that the aggression when it was carried

 3     out in Vlasenica and so on and so forth, who said that -- who told you

 4     that as aggression?

 5        A.   The aggression was to cleanse all the Muslim people from the

 6     municipality of Vlasenica.  Young people killed, women and children to

 7     camps, and then free territory.

 8        Q.   Who said that to you, Mr. Witness?

 9        A.   Well, I don't know their first and last names.  I mean, what do

10     you think, that I go and look for them now?  I mean, over there, in front

11     of the camp, there were so many people.  I was in the hangar.  Some

12     people said who went out would never go back, and somebody else said

13     that, well, maybe they will come back in about ten years, I don't know.

14     I didn't see them out there.  I just heard their words.

15             JUDGE KWON:  Why don't you upload Exhibit P3262.  But not

16     broadcasting.  And why don't you show the witness para 5?  We can show

17     the first page first.

18             Sir, this is the witness statement of which you confirmed the

19     veracity with Mr. Gaynor.  I show you para 5 of this statement.  Do you

20     have a B/C/S version as well?

21             MR. GAYNOR:  The amalgamated statement is only in English.

22             JUDGE KWON:  Yes, I will read it to you.

23             "When Zvornik fell to Bosnian Serbs, a month before Vlasenica, we

24     really started to worry as to what might happen.  Because of this

25     uncertainty, people started to leave Vlasenica."  And you say, "Serb

Page 18144

 1     families started to evacuate out of Vlasenica, becoming a Muslim majority

 2     town.  Muslims also started to evacuate as well and go to Kladanj."

 3             Can you confirm that this is true or this is what you didn't see

 4     at all?

 5             THE WITNESS: [Interpretation] Yes.

 6             JUDGE KWON:  Please continue, Mr. Karadzic.

 7             MR. KARADZIC: [Interpretation] Thank you.

 8        Q.   You said that up until the 16th of April you worked in

 9     Bosna Putevi at Sokolac as a guard; is that right?

10        A.   Yes.

11        Q.   You said that the Novi Sad Corps came to Vlasenica and you said

12     that they didn't do any harm to anyone.

13        A.   Yes.  At Drum, no, and I don't know about the rest.

14        Q.   You said that in May, the relations between the Muslims and the

15     Serbs in Vlasenica were still good, right?

16        A.   Yes.

17        Q.   Further on, you said that in May -- or, rather, in April and May,

18     Serbs asked to have weapons surrendered and they said that nothing would

19     happen to the inhabitants of the villages there, right?

20        A.   Right.

21        Q.   That happened in the following way.  There was a loudspeaker on a

22     vehicle and the driver of that vehicle was a Muslim, right?

23        A.   That's right.

24        Q.   Do you know that the mentioned hodza was in that same vehicle and

25     that he also appealed that weapons be surrendered and that he took the

Page 18145

 1     police to persons to whom he had personally given weapons?

 2        A.   No.

 3        Q.   Thank you.  In your testimony earlier on -- I don't know whether

 4     I can say this actually.  1D4157, pages 7351 and 7352, you said that you

 5     had not seen anyone surrender their weapons, right?

 6        A.   I only saw two hunting guns brought in.

 7        Q.   Thank you.  Then you said that the forces of the Bosnian Serbs

 8     attacked the village of Drum?

 9        A.   Yes.

10        Q.   On the 2nd of June, 1992.  And that that was the first attack in

11     that zone and the first village that was cleansed in the operation for

12     all of one month, right?

13        A.   That's right.

14        Q.   Do you agree, did you see on television or did you know that war

15     in Bosnia started two months before that?

16        A.   No.  I just know what happened in Drum.

17        Q.   But you mentioned yourself that Zvornik happened on the

18     8th of April, Bijeljina on the 31st of March.  You didn't mention that

19     actually but I'm just reminding you of that.

20        A.   I don't know.  I did not keep records like that.  I just know

21     that until the 1st of June I was fine at home, and as of the 2nd of June,

22     everything cleansed.

23        Q.   You say that an offensive started at 7.00, but at 6.20, and then

24     until 7.00, you were in front of your house and you watched all of that,

25     right?

Page 18146

 1        A.   Yes.

 2        Q.   You say that you saw a rather large group of people on the

 3     balcony of the Panorama Hotel, you saw them looking at Drum, right?

 4        A.   Yes.

 5        Q.   Do you know that in the Panorama Hotel, the command of the

 6     Territorial Defence was stationed there and, well, also the forces of

 7     Army of Republika Srpska?

 8        A.   No.

 9        Q.   Do you know that from Drum, that command was fired at every day,

10     this command that was at the Panorama Hotel?

11        A.   I don't know.

12        Q.   Did you hear yourself that some officer asked a soldier over the

13     radio what kind of bullets were coming from Drum?

14        A.   No.  It wasn't over the radio.  When there was this group where

15     we were, men and women, when Car was the first to pass by and then there

16     was a military agree jeep and then this general came up, I don't know,

17     whatever he was, he had these epaulettes, and he asked the first person

18     right next to him he said, "How is the shooting going, how did that

19     bullet reach Panorama?"  And he said, "I don't know.  Call that person

20     who has a radio.  They are up front."

21        Q.   Ah-ha.  What is your interpretation of this?  How can this

22     officer not know what type of bullet that was?

23        A.   I don't know.  Ask him.

24        Q.   In one of your statements, you said that soldiers entered houses,

25     and in another statement, you said that they did not enter houses, or

Page 18147

 1     that -- you did not see that?

 2        A.   I just saw this cleansing of Drum.  They entered houses to see

 3     whether there were any men there and then they would take them out and

 4     kill them.  If they did not find a man, that man would survive because

 5     they hadn't seen him.

 6        Q.   You were not hiding, though?  You thought that you were not a

 7     member of any political party and that you were not armed and that

 8     therefore you were not in any kind of danger; is that correct?

 9        A.   Yes, yes.  And I also had no weapons whatsoever.

10        Q.   All right.  And what do you think, who was in danger?

11        A.   Well, it depends who came up and what kind of a person that was,

12     whether they let them go, like this woman in a military uniform, she saw

13     me and she said, "Go ahead.  There is this group of women in front of

14     Djoga's house."  And there was a soldier walking behind her, and she

15     said, "Take him there, because somebody will kill him."  And I found

16     about 20 women there, two men.  I stopped there and they went on to

17     Piskavica.

18        Q.   Oh, I see.  So three men and about 20 women and children were

19     singled out, whereas they went on to Piskavica, right?

20        A.   Yes, there was a total of 28 of us.  We boarded buses, the women

21     came from some of the houses there, but there were only the three of us

22     men.

23        Q.   What was the criterion according to which the three of you were

24     singled out whereas they were chasing everybody else?

25        A.   I found those two on the road there, about 100 metres ahead of

Page 18148

 1     me.  I don't know how they singled us out.  I know that I survived.  As

 2     for them, I didn't ask them.

 3        Q.   There is a bit of unclarity involved.  From where were you

 4     watching all of this that was happening in Drum?  Were you sitting in

 5     front of your house or were you watching this from your house?

 6        A.   I was in front of the house, in front of the door, outdoors.

 7        Q.   Thank you.  So you're just sitting there in front of your house

 8     and there is shooting all over?

 9        A.   I was sitting there, and when the APC came and when they were

10     moving, I did not move anywhere.  (redacted) I could not

11     move anyway, but when I saw them taking people out of houses, it wasn't

12     easy for me.  I had no idea how I would fare but I mean, whatever, that

13     was my fate.

14        Q.   At one point you say that you saw soldiers take out Hadzo

15     Malesevic, take him out of his house, and they were shooting?

16        A.   Right on the steps, that's where he fell, the steps of his house.

17        Q.   Beforehand you said that some woman called Slavica shot him?

18        A.   No, no.  Slavica is the one who took me prisoner and who told the

19     soldier to take me away.  She was above Hadza's house.  She walked across

20     my land.

21        Q.   What I'm saying now, you said in your own statement.

22             MR. GAYNOR:  Could I have a reference, please, for the earlier

23     evidence?

24             THE ACCUSED: [Interpretation] That's exactly what I was about to

25     say right now.

Page 18149

 1             MR. KARADZIC: [Interpretation]

 2        Q.   This is your statement, yes, yes.  Actually this is what you

 3     stated during your testimony on the 9th of March, 2010, 1D4157, I think.

 4     7358 through 59.  Those are the page numbers.  I beg your pardon.  That's

 5     something different.  This was the statement of the 6th of July, 1994.

 6     That is 8852.  65 ter 8852.

 7             MR. GAYNOR:  Perhaps Mr. Karadzic could identify the sentence

 8     that he's referring to.

 9             THE ACCUSED: [Interpretation] Page 1 of the Serbian version.

10     Last paragraph.

11             JUDGE KWON:  Are we talking about the para which may be identical

12     to para 13 of his amalgamated statement?  We'll see.

13             THE ACCUSED: [Interpretation] Please let us not have this

14     broadcast.  I don't actually have the amalgamated statement so it is

15     possible.  I have a computer problem so ... page 3 and then it continues

16     on page 4.  That's the English version.  And that is probably the case in

17     the amalgamated statement as well.

18             MR. GAYNOR:  This section from the 1994 statement is not, in

19     fact, a part of the amalgamated statement.

20             MR. KARADZIC: [Interpretation]

21        Q.   So you say that you recognised Slavica Matic and a Romanian from

22     Dragasevac and you say you don't know his name?

23        A.   Yes, Dragasevac.

24        Q.   And Slavica was taking Hadzo Malesevic out, and as he was walking

25     down, she killed him with a burst of gunfire.  She fired into his back.

Page 18150

 1     That's what you said.

 2        A.   I saw a soldier take hajja out and the soldiers who were below

 3     the road, below his house, were there, and Slavica was walking below my

 4     house, 50 metres away.

 5        Q.   So what you said earlier on, this is actually the 30th of May,

 6     2000, that's not correct, right?

 7        A.   I know what I said.

 8        Q.   Is this what you were saying?  Is this your statement?

 9        A.   Yes.

10        Q.   So this is not correct.  Up here it says that the date is the

11     6th of July, 1994.  So what you said then is not correct?

12        A.   I know that Slavica took me prisoner and I did not see her kill

13     Hadzo.  Enver and Meho fell before she came there.

14        Q.   Very well.  Thank you.  How is it that you don't know the last

15     name of this Omer whose house they also entered?

16        A.   I don't know.  (redacted)

17        Q.   In your statement of the 30th of May, 2000, on page 3, you say

18     that this was systematic and thorough killing?

19        A.   Yes.

20        Q.   Who gave you this wording, this formulation?

21        A.   I saw this with my very own eyes.

22        Q.   What does systematic and thorough killing mean in your books?

23        A.   It means --

24             THE INTERPRETER:  Interpreter's note:  Could the witness please

25     repeat his entire answer.  Thank you.

Page 18151

 1             JUDGE KWON:  Sir, the interpreters couldn't hear you because your

 2     answer was overlapped with the interpretation of the question, so could

 3     you kindly repeat your answer.

 4             THE WITNESS: [Interpretation] I saw this with my very own eyes.

 5     They were cleansing Drum.  All the men were being killed.  If people were

 6     hiding, and if they managed to hide, they managed to survive.  So they

 7     cleansed all the men, they killed all the men, and the women and children

 8     were taken to camps, towards Kladanj, that's what I saw with my very own

 9     eyes.  No one said to me, "Go and kill this person or go and kill that

10     person."

11             MR. KARADZIC: [Interpretation]

12        Q.   Sir, you said this was systematic and thorough killing.  Did you

13     offer that wording?

14        A.   No.  It was killing, killing whichever men they found, they

15     killed him.

16        Q.   What's the population of Drum and what's the population of

17     Piskavica, the local commune?

18        A.   I don't know.  I didn't count them.  (redacted)  The

19     first house was Rocevic, Serb one, then Roja [phoen].  I did not count

20     the villagers, I worked out in the field, but there were more than

21     100 houses in that area up to Piskavica.

22        Q.   And in Piskavica itself?

23        A.   Maybe 50 houses and there were some hamlets, Alihodzici and

24     another hamlet, Brijeg or Brdo, in the direction of Sadici and Durici

25     which were further away from my position.

Page 18152

 1        Q.   Thank you.  So you saw that ten people were killed and there were

 2     28 of you on the bus; is that correct?

 3        A.   Yes.

 4        Q.   And you say -- you called this systematic and thorough killing?

 5        A.   Yes.

 6        Q.   Where were the Muslim fighters?

 7        A.   I don't know.

 8        Q.   Where were the other inhabitants out of several thousand?

 9        A.   I don't know.

10        Q.   Did Slavica kill Meho and Ekrem?

11        A.   No.

12        Q.   But you stated that in one of your statements dated 6th of July,

13     1994, on page 2?

14        A.   There were two men in front of her before -- before she came to

15     Meho's house and this was 50 metres away from where I was standing.

16        Q.   And you observed all this.  How long did it take, this whole

17     operation?

18        A.   Until they came to me, it took 20 minutes.  Everything took place

19     below Hadzo's house.  They made this chain from Alihodzici to Vlasenica.

20     The only house they didn't touch was Rocevic, the Serb house.  I sat in

21     front of my door.  I did see what I did see.  I saw five people taken out

22     of their homes and five were killed in front of Nezir's cafe on the

23     plateau.  They probably started fleeing but failed.  I don't know.

24        Q.   Can we turn to page 2 of this document?  You said in your

25     statement that you saw Slavica kill Meho and Ekrem five metres from the

Page 18153

 1     house.  And now you state that this is not correct.

 2        A.   There were soldiers there, they were firing.  I don't know

 3     whether her bullet killed those.  There was a soldier entering the house,

 4     emerging from the house, then climbing to the first floor, and then took

 5     out Meho and Ekrem.  And then another soldier came to Fadil's house, took

 6     him out.  They went from house to house.  In those houses where they

 7     could see there was no one in there, they would move on.

 8        Q.   Meho's wife and other women joined others on the bus that took

 9     you away?

10        A.   Meho's and Fadil's women, Seka emerged when they were killed and

11     Faketa walked past her husband.  Two sons of her and a son-in-law and

12     two brothers-in-law started fleeing and they were killed in front of

13     Nezir's cafe.

14        Q.   A tall soldier told Faketa, "Go to Djoga's [phoen] house"?

15        A.   In front of Djoga's house.

16        Q.   Thank you.  What was the distance between you and those houses?

17        A.   Fadil's house is ten metres away from mine, and between my ground

18     and Meho's or the fence of Meho is also ten metres.

19        Q.   Did you know that the Muslim army in those days had planned and

20     had started a major offensive in different locations around Vlasenica all

21     in preparation of their offensive against Sarajevo on the 8th of June?

22        A.   I don't know.

23        Q.   Did you know that from the 27th of May, attacks had been

24     intensified.  For instance, a column of trucks of the bauxite mine was

25     attacked, six drivers were killed.  Did you know about that?

Page 18154

 1        A.   No.

 2        Q.   Did you know that they massacred civilians in the Serb village of

 3     Metaljka?

 4        A.   No.

 5        Q.   Did you know that Drum was supposed to be the staging post for

 6     the attack against Vlasenica?

 7        A.   No.

 8             THE ACCUSED: [Interpretation] Could we please take a look at

 9     1D01 -- 04068, please?

10             MR. GAYNOR:  I'll just note this hasn't been listed on the

11     Defence list of cross-examination documents.  There is no objection to

12     its use.

13             JUDGE KWON:  Can you explain why it was so, Mr. Karadzic?

14             THE ACCUSED: [Interpretation] Excellencies, we are very few and

15     overloaded with work and this pace of two witnesses per day is

16     exhausting.  I'm not tendering this.  I just want us to see the situation

17     as reflected here.

18             JUDGE KWON:  Please proceed, Mr. Karadzic.

19             MR. KARADZIC: [Interpretation]

20        Q.   Sir, this is dated 31st of May, and the Mirsad Sulejmanovic gives

21     a statement to the police.  He stated that he was working as a -- in a

22     warehouse in Skugrici and he describes the attack on the Serb village of

23     Metaljka, involving people from Donja Cerska, Gornja Mahala, et cetera,

24     et cetera, and was carried out on the 2nd June of 1992.  And he also says

25     that several people took part in desecrating the tombstones, et cetera,

Page 18155

 1     et cetera.  Could we please turn to the next page?

 2        A.   Am I supposed to answer?

 3        Q.   Yes.  Did you know that Muslim army activities in that area were

 4     daily and intensive?

 5        A.   No.

 6        Q.   Well, this is relevant for a subsequent period.  Let's leave it.

 7     Thank you.  Let me read to you a description of those activities so that

 8     we can elicit from you whether you knew anything about those.  On the

 9     4th of May --

10             JUDGE KWON:  Just a second.  One, whether it's of any point, but

11     you said you are going to read something, a description of something.

12     You need to let us know where you are reading from.

13             THE ACCUSED: [Interpretation] On the previous page, it says they

14     attacked against the village of Metaljka, the Muslim attack against the

15     village of Metaljka.

16             JUDGE KWON:  So you are reading a passage in Mr. Sulejmanovic's

17     statement?  Very well.

18             THE ACCUSED: [Interpretation] Yes.

19             JUDGE KWON:  Please proceed, Mr. Karadzic.

20             MR. KARADZIC: [Interpretation]

21        Q.   We no longer need this document.  I'm not going to go very deep

22     into this, Witness.  My statement is that this whole area is aflame with

23     activities of the Muslim forces.  There are daily attacks against Serb

24     villages.  Are you aware of that?

25        A.   No.

Page 18156

 1        Q.   27th of May, sabotage against enemy column at Konjevic Polje,

 2     enemy suffered great losses, and the communication between the two towns

 3     was severed.  27th of May, a sabotage against the power lines.  Do you

 4     know that?

 5        A.   Yes -- no.

 6        Q.   Do you know that there were power cuts?

 7        A.   Yes.  We thought that you severed the power lines to the Muslims.

 8        Q.   Then the attack against Redzici, sabotage against enemy forces

 9     and vehicles.  Did you know about that?

10        A.   No.

11        Q.   28th of May, attack on Jezica, MTS was captured.  28th of May,

12     Postolje and Prodric [phoen] we drove out the Chetniks?

13        A.   Where?

14        Q.   That's in the area of Birac but in the direction of

15     Konjevic Polje and Cerska?

16        A.   I never heard about that.

17        Q.   Do you know where Banjevici is located?

18        A.   No.

19        Q.   29th of May -- you know where Konjevic Polje is?

20        A.   Yes.

21        Q.   53 Chetniks were killed, and 15 bodies the Serbs could not take

22     out from the area.  Did you know about that?

23        A.   No.

24        Q.   29th of May, offensive against the Kravica, eight Chetniks were

25     killed.  Did you know about that?

Page 18157

 1        A.   No.

 2        Q.   29th of May, attack of Muslims against the Jasikovaca and

 3     Magasici.  Did you know about that?

 4        A.   Well, they are 40 or 50 kilometres away from Vlasenica.  There

 5     was no TV broadcast, I did not any news beyond Drum [as interpreted].

 6     I did not have any TV or radio to listen to such news.

 7        Q.   Do you know where Vitorog is?

 8        A.   No.

 9        Q.   Let me tell you how this action in Drum was taken.  2nd of June,

10     in Drum, a sabotage was effected against enemies, that was the

11     headquarters being attacked?

12        A.   No, there was no shooting when I woke up around 6, and what I saw

13     was a chain of one kilometre from Alihodzici towards Vlasenica.  There

14     were no villages there.  There was no resistance, there was no shooting,

15     but they scheduled this cleansing of Muslim population for that day.

16     From Drum and beyond, some 1.000 people were brought from Sadici,

17     Alihodzici and the other villages that I did not visit and the -- of

18     course, combat troops went further and they cleansed the area of Muslim

19     population.

20        Q.   How do you know that this decision was taken?

21        A.   No.  You commanded.  You are supposed to know about that

22     decision.  You took it.

23        Q.   You do not know that a decision was taken.  You just surmise?

24        A.   Well, I know the effect, that there were no Muslims since 1992.

25     I stayed in the area for another month and then went further to

Page 18158

 1     Batkovici.  I could tell you that there were no Muslims left in Drum or

 2     around Drum from that day on.

 3        Q.   There is this passage where you say -- let me read in English, so

 4     that it can be interpreted for you.

 5             "[In English] The military officer asked the soldier what kind of

 6     bullets were coming at Vlasenica from Panorama, to which the soldier

 7     answered, 'There is a radio station there.  You should find out from

 8     them.'"

 9             [Interpretation] You said that in your testimony,

10     Stanisic-Zupljanin case, 9th of March, 2010, 1D4157, that would be

11     page 7364 and 7365.  Right?

12        A.   I said when the military jeep and the military patrol came in,

13     there was some general there with them.  I asked a man in the camp where

14     was that general from?  And I got a reply, "From Nis."  There was one man

15     who guarded us while we waited for the bus.  He -- there was talk about

16     this type of ammunition which flew from Panorama, and the man said, "Ask

17     the man with the radio," and then they moved on.

18        Q.   Is this the same Nezir Alicevic?  Are there two of them or just

19     one?

20        A.   I know of one Nezir Alicevic only.

21        Q.   Thank you.  This is the Nezir that hodza mentions in the context

22     of supplying him with arms and ammunition?

23        A.   I don't know.  I did not engage in such activities.  Nobody

24     offered me anything.  I did not serve in the JNA.  (redacted)

25     (redacted)  I could not handle weapons.  I was not interested in

Page 18159

 1     politics and --

 2        Q.   Thank you.  Were Huso and Nezir brothers?

 3        A.   Yes, brothers.

 4        Q.   Are their houses adjacent to one another?

 5        A.   Yes.

 6        Q.   Thank you.  So 28 of you were driven to Susica.  How many

 7     soldiers were there on the bus, as sentries?

 8        A.   Some ten reserve policemen.

 9        Q.   Thank you.  So on the bus, there were mainly women, children and

10     elderly men; correct?

11        A.   There was a total of 28 of us, and we were the first to enter

12     Susica.  When we came there, there was nobody else there.

13        Q.   When you came to Susica, Susica did not exist thus as a prison

14     but it was getting set up just then?

15        A.   Yes, I found ten people down there in front of the door as we

16     were coming out of the bus.  The bus couldn't go across the little bridge

17     next to the hangar.  There was a small river.  There was a small bridge.

18     You couldn't go by car.  You had to go by foot.  We went out there.  We

19     went in there, inside, go in the hangar.  We went to the hangar.  Nobody

20     was in the hangar.  I counted 28 of us, there were a total of 28 of us.

21     Then later by night, people came.  There were a thousand of them there.

22     They were being brought from Piskavica, Sanici, Donja Piskavica, I don't

23     know, Bacino Brdo, surrounding area of Vlasenica, people from there.

24        Q.   Thank you.  In a number of statements, you said that the hall was

25     unprepared, that there were a lot of things in there, that it was dirty,

Page 18160

 1     that it needed to be prepared before people could stay there; is that

 2     correct?

 3        A.   Yes.  All that was inside were empty shell cases.  There was just

 4     nothing on the bare floor of the hangar, and we stayed there for a month.

 5        Q.   And then you helped to clean it?

 6        A.   We just took out the cases.  There was no more cleaning done.  If

 7     you had a coat you took it off and then you sat on the concrete or lie

 8     down.  Sometimes they would close even the windows, not just the doors,

 9     you couldn't breathe.  And then after seven to 10 days they brought about

10     220 people from Papraca.  They were in a school somewhere.  I asked them.

11     Then they were in the Vlasenica school centre, so they were brought

12     there.  They were the first ones to be taken to Batkovici.  This is the

13     Kalesija municipality, Osmaci.  I don't know those villages where they

14     were from.

15        Q.   Thank you.  And these were detainees from the fighting that was

16     up there; is that right?

17        A.   I don't know.  I don't know.  I didn't see any of that.  I don't

18     know.  I just asked those people, "Where were you from," and they said

19     the municipality of Kalesija.

20        Q.   Thank you.  They told you don't worry, you are going to be saved,

21     you will have no problems, you are going to stay here for two days, and

22     then you are going to be exchanged for Serbs from the other side; is that

23     correct?

24        A.   Yes.  You will be two days in Susica and then you will be

25     exchanged for Serbs in Kladanj.  Serbs will come from Kladanj, but this

Page 18161

 1     never happened.  I spent 28 days and this exchange never happened.  On

 2     the second or the third day they came from the municipality, the same

 3     person who issued permits to leave the municipality of Vlasenica, that

 4     you had to go through check-points near Sekovici, I don't know where that

 5     was, I didn't go there.  From the tunnel towards Kladanj there was a Serb

 6     check-point to let you through and that you left on your own to go over

 7     there.  Well, then, I didn't go anywhere, I didn't pass through anywhere.

 8     I didn't ask for the permission.  I believed I was an honest man.

 9     I didn't dirty my hands anywhere so that's why I stayed.  First they said

10     that there were be some exchanges, there were no exchanges, and then

11     after when people were collected to go to Batkovic, they said there was

12     no food in Vlasenica.  We went to Batkovic, Sekovljani [phoen] came with

13     us, there was a commander from Montenegro there.

14        Q.   And these permits, were they required at the check-point, could

15     you get past with them?

16        A.   I don't know.  I couldn't tell you, I don't know what happened to

17     the people, those who went and whether they passed through or not.

18     I didn't go so I don't know.

19        Q.   And you didn't ask for permission, so you weren't given one?

20        A.   Yes.  I didn't ask for one, that's correct.

21        Q.   And now that you're talking about the check-points, is it correct

22     that at the outskirts of Drum, before the conflict broke out, the Muslim

23     side held a check-point?

24        A.   No.

25        Q.   Can we --

Page 18162

 1             JUDGE KWON:  Do you have many more questions, Mr. Karadzic?

 2             THE ACCUSED: [Interpretation] Well, I haven't even exhausted that

 3     hour and I hope I am going to get enough time to ask questions of the

 4     witness.  All right, I'm going to skip some things.

 5        Q.   You were told thus that there wasn't enough food in Vlasenica.

 6     Were you told that the Muslim side did not wish to exchange you and that

 7     they were asking weapons and food in exchange for you, they were not

 8     willing to give up the Serbs?

 9        A.   On the bus, when we were leaving Batkovic, this person who is on

10     the bus, they called him Crnogorac, Montenegrin.  He had some black suit

11     on him.  He had these pockets, two or three grenades in those pockets.

12     He had a kind of jacket, a pistol, I don't know what it's called, it was

13     a bit bigger than a pistol.  And he said, "Listen, well, I've brought you

14     here, you have food here as much as you want to eat, there is work, you

15     have to work.  And in the morning, we submitted a request to Alija to

16     exchange you for our Serbs, where he caught them.  He said, 'I am not

17     giving my own away.  Those who surrender to the Serbian forces you can

18     kill them, and in exchange for yours, you can give them some grenades and

19     a sack of flour.'  We did not wish to accept that and that's how they

20     brought us here."  This is what they told us on the bus when we came to

21     Batkovic.

22        Q.   Thank you.  Is it correct that while you were in Susica, very

23     quickly food supplies were established?  You were receiving one meal from

24     the military kitchen Vlasenica?

25        A.   As far as food was concerned, it was bad.  Only food that was

Page 18163

 1     left over from the soldiers, that they were delivering to the fighters on

 2     the front and that was returned and other leftovers were given to us.

 3     Sometimes there was no bread, sometimes there was.  But as for food, it

 4     was really bad.  If we didn't have any people who would send food --

 5     I didn't leave further than the bridge.  I mean there was always a couple

 6     of loaves of bread, it was homemade bread that was made at home.  It

 7     wasn't bought.  So there was also something like that, but the food was

 8     bad.

 9        Q.   Well, this was brought by the neighbouring population; is that

10     right?

11        A.   I don't know where it was brought in from.  I don't know, I mean

12     bread was brought in, we would break it up and distribute a piece.

13     Especially those who came from Kalesija, they didn't eat for two days,

14     they were very hungry.  They -- we wanted to give them bread.  They were

15     more hungry than we were, the local inhabitants.

16        Q.   Thank you.  And this taxi driver, Prlja, is he a Serb or a

17     Muslim?  There was a taxi driver, Prlja, who told you, "Give me that

18     gold," so that nobody would kill you for that gold?

19        A.   He was a Serb.

20        Q.   And did he keep this gold?

21             JUDGE KWON:  Mr. Karadzic, your time was up about two minutes

22     ago.  It's time for you to conclude.  So please conclude before we break.

23             MR. KARADZIC: [Interpretation] Thank you.

24        Q.   And did he keep the gold for you?

25        A.   I never saw him with my own eyes again.  He took it, I didn't see

Page 18164

 1     him.  After he took it, I didn't see him afterwards, and if I did happen

 2     to see him, I would go up to him and tell him, ask him where is that,

 3     that and that.  As far as I'm concerned, nobody touched me in Susica.  In

 4     Batkovic nobody touched me either.  (redacted)

 5     (redacted)

 6     (redacted)  As for beatings, I was never beaten by

 7     anyone.  I would have said had I been beaten.

 8        Q.   Is it correct that people freely applied if they wanted to go to

 9     Kladanj or Cerska and that most of the women applied and the elderly; is

10     that right?

11        A.   Yes, just to get out of the camp, so that they weren't there any

12     more.  They would apply to go anywhere.  It doesn't matter.  They said

13     there were people in Cerska.  They wanted to go to Cerska.  I didn't hear

14     it, but all they wanted to do was leave the Susica camp.

15        Q.   And Cerska, was that also part of the Vlasenica municipality?

16        A.   Yes, yes, yes, it's part of the Vlasenica municipality.

17        Q.   Some went to Kladanj.  The majority of women applied, except some

18     20 women because they wanted to wait to see what would happen with their

19     daughters; is that right?

20        A.   The bus came in the morning to drive to Kladanj.  Ten women said,

21     in the hangar, "We are not going until you return our daughters to us who

22     were taken out in the evening."  At about 10.00, two soldiers came and

23     they picked you, you, you, you, you go out.  The women asked where are

24     they going.  They said that they were going to some old man's place to

25     clean the house, so they were quiet.  In the morning when the bus came to

Page 18165

 1     drive away, the women stood aside and said, "We are not leaving until

 2     they return our children to us."  A policeman came, he was Serb policeman

 3     from before in the municipality of Vlasenica, I don't know his name.  He

 4     said, "Mothers, what are you waiting for?"  They -- then he went to some

 5     little house and in ten minutes, I don't know whom he called, but in

 6     ten minutes, these ten girls were back at the gate.

 7        Q.   Thank you.  And you said that they did not look as if they were

 8     mistreated, that they looked normal; is that right?

 9        A.   Well, they looked normal.  They came to the door, they didn't

10     enter the hangar.  They just came and then immediately they entered the

11     bus.  I don't know where they went.  I don't know if they went to Kladanj

12     or somewhere else.  I never wanted to volunteer to ask to leave the camp,

13     doesn't matter where.  I wanted to stay in Vlasenica because I didn't do

14     anything wrong to anyone.

15        Q.   Thank you.

16             THE ACCUSED: [Interpretation] Can we just have a minute in

17     private session, please?

18             JUDGE KWON:  Very well.  Let's go into private session briefly.

19                           [Private session]

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 18166

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8                           [Open session]

 9             THE ACCUSED: [Interpretation] Excellencies, please, at least

10     until the break because I have to ask about Batkovic.  I'm not finished.

11             JUDGE KWON:  We are supposed to take a break at 20 past in

12     regular sitting.  And your time was up, but yes, I will allow you put

13     some questions about Batkovic.  Conclude in three or four minutes.

14             MR. KARADZIC: [Interpretation] Thank you.

15        Q.   You said that in Susica and Batkovic, people applied -- actually

16     reported to work.  They were out of the camp in Batkovici for as long as

17     three months.  They were taken by one or two guards.  They would return

18     fattened, well-fed, and they would bring food back from those jobs; is

19     that right?

20        A.   Yes.

21        Q.   They could report to work and they did not have to report to

22     work; is that right?

23        A.   These 30 people who went somewhere to Serbia, they were asking

24     for people to build a school.  There was a general, he had six soldiers

25     with him from the reserve police, and he told them nicely, "Take these

Page 18167

 1     people somewhere to build a school."  These carpenters, different kinds

 2     of workmen, and tradesmen applied, and he told them, he told them

 3     nicely -- I listened in the hangar when he said, "These 30 people you

 4     have take care of.  If there is shelling you have to catch them in your

 5     hands, but nothing can harm these people."  And these people were taken

 6     in a jeep to this assignment.  They were away for three months, and when

 7     they came back after three months, each one of them brought 20 to 30 cans

 8     of Spam, goulash, all of that looked very nice.  They said they didn't do

 9     anything.  There was a shift, a month and a half, and then another month

10     and a half shift came.  They took them to villages, fed them well.  They

11     gave them pie to eat.  They also gave me food.  I didn't go out of the

12     hangar.  I'm an invalid, I didn't have to work.  They gave me these cans.

13     They gave me cigarettes, 30 boxes of cigarettes, those people especially

14     who didn't smoke.

15        Q.   Other than these 30 people, did many others go for harvesting, to

16     bring in the crops, to cooperatives, and they said that they had it good

17     there and they brought back food?

18        A.   Yes, they went out to work every day, because there were about

19     25 to 30 of us who were disabled, we didn't work.  The others did go to

20     work and they would get a meal there, a good one.  I don't know what they

21     had, but because I didn't work, I had food that was worse.  But they gave

22     me some food as well.  I guess they knew me from Vlasenica, so that was

23     why.

24        Q.   So in Batkovic nobody beat you?

25        A.   No, nobody did.

Page 18168

 1             THE ACCUSED: [Interpretation] Thank you, your Excellencies, I

 2     believe that I cannot try your patience.

 3             JUDGE KWON:  Thank you, Mr. Gaynor, do you have any

 4     re-examination?

 5             MR. GAYNOR:  No, thank you, Mr. President, no questions.

 6             JUDGE KWON:  Sir, that concludes your evidence.  On behalf of

 7     this Chamber and the Tribunal as a whole, I would like to thank you for

 8     your coming to The Hague to give it.  Now you are free to go.

 9             We will rise altogether.  Given the pace of the proceedings, the

10     Chamber is minded to take a longer break.  Half an hour.

11             THE WITNESS: [Interpretation] I thank you.

12             JUDGE KWON:  We will resume at five to 11.00.

13                           [The witness withdrew]

14                           --- Recess taken at 10.26 a.m.

15                           --- On resuming at 11.05 a.m.

16             JUDGE KWON:  Yes, Mr. Gaynor.

17             MR. GAYNOR:  Mr. President, I wanted to advise the Court of a

18     scheduling issue which has arisen.  Perhaps we could go into private

19     session, briefly.

20             JUDGE KWON:  Yes.  May the Chamber go into private session.

21                           [Private session]

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 18169

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18                           [Open session]

19             JUDGE KWON:  Yes, Mr. Gaynor, call your next witness.

20             MR. GAYNOR:  Thank you, Mr. President, the next witness is

21     Mr. Suad Dzafic.

22             JUDGE KWON:  If we include Mr. Mandic, who was a Chamber witness,

23     this witness, Mr. Dzafic, will be the 100th witness in total.

24             MR. GAYNOR:  Yes, indeed, he bears that distinction.  Thank you,

25     Mr. President.

Page 18170

 1                           [The witness entered court]

 2             JUDGE KWON:  If the witness could take the solemn declaration,

 3     please.

 4             THE WITNESS: [Interpretation] I solemnly declare that I will

 5     speak the truth, the whole truth and nothing but the truth.

 6                           WITNESS:  SUAD DZAFIC

 7                           [Witness answered through interpreter]

 8             JUDGE KWON:  Good morning, Mr. Dzafic.  Please be seated and make

 9     yourself comfortable.

10             THE WITNESS: [Interpretation] Good morning.

11             JUDGE KWON:  Thank you.  Yes, Mr. Gaynor.

12             MR. GAYNOR:  Thank you, Mr. President.

13                           Examination by Mr. Gaynor:

14        Q.   Mr. Dzafic, yesterday did have you an opportunity to review an

15     amalgamated witness statement with the assistance of an interpreter?

16        A.   Yes.

17             MR. GAYNOR:  Could I call up, please, 65 ter 90268.

18        Q.   And you had the opportunity to make some corrections and

19     additional comments to that statement and then you signed it; is that

20     correct?

21        A.   Yes, yes.

22        Q.   On the screen in front of you, do you see the first page of the

23     statement that you signed?

24        A.   Yes.

25        Q.   Do you adopt that statement as your evidence and if you were

Page 18171

 1     asked questions on the same subjects today, would you provide the same

 2     answers?

 3        A.   Yes.

 4             MR. GAYNOR:  I'd like to tender that statement, Mr. President.

 5             JUDGE KWON:  Yes.  It will be admitted.

 6             THE REGISTRAR:  As Exhibit P3263, Your Honours.

 7             MR. GAYNOR:  I'll now read a summary of the statement for the

 8     benefit of the public.

 9             Mr. Dzafic is from the village of Vitkovici in Bratunac

10     municipality.  He returned from Serbia to his home village in March 1992.

11     His statement concerns the Serb takeover of Bratunac town and other

12     villages in the municipality in April and May of 1992.

13             He describes the disarmament of the Muslim population, the

14     destruction of their homes, and their transfer from their villages to

15     places of detention, including the football stadium in Bratunac, the

16     Vuk Karadzic school and the MUP prison in Bratunac town.  He was told by

17     Serb soldiers that the SDS leadership in Bratunac had hired

18     paramilitary soldiers to kill as many Muslims as they could.  The witness

19     became aware of the killing of more than 60 Muslim villagers in Glogova

20     on 9 May 1992, and the transfer of the surviving villagers to Bratunac.

21             On the 17th of May, 1992, the police chief came to the witness's

22     village and asked the inhabitants to hand in any weapons that they owned.

23     He took four Muslim men to the police station in Bratunac for

24     questioning.  On the morning of the following day, 18th of May, 1992,

25     Serb neighbours, armed and in camouflage uniform, and units from the

Page 18172

 1     Novi Sad Corps, surrounded the village and informed the villagers that

 2     they could not live there any longer.  Mr. Dzafic and his fellow Muslim

 3     villagers were put onto buses and transferred to the football stadium in

 4     Bratunac and later to Vlasenica.

 5             Each bus had an armed guard on board.  At Vlasenica, the buses

 6     were approached by a group of about 30 armed soldiers in full combat

 7     gear, some of whom were wearing insignia of Arkan's Tigers and

 8     Beli Orlovi and other special units.

 9             The military-aged men and five minors were taken to the Vlasenica

10     MUP prison by soldiers.  32 military-aged men and the five minors were

11     detained there until 21st of May, 1992.

12             During this time, they were beaten and maltreated by Serb

13     soldiers.

14             On the 21st of May, the detainees were ordered out of their cell

15     by two police officers and placed on buses where soldiers confiscated

16     their personal belongings including money and documents.  The bus headed

17     in the direction of Bratunac, accompanied by an armoured vehicle and

18     four cars.  It stopped on the outskirts of the village of Nova Kasaba

19     where the detainees were ordered off the bus by a man known as Makedonac

20     and then executed.  The executioners then searched for survivors and shot

21     them in the head.  Mr. Dzafic lay on the ground pretending to be dead

22     until the soldiers left.  He then fled to Muslim-held territory.

23             Mr. Dzafer discusses a document sent by SJB Milici to CSB

24     Sarajevo which refers to the summary execution of a group of 25 Muslims

25     from Bratunac municipality at Nova Kasaba on 21st of May, 1992.

Page 18173

 1             That ends the summary.

 2        Q.   Mr. Dzafic, I'll now ask you a couple of questions on some

 3     subjects which arise in your statement.  I want to take you first of all

 4     to the moment when you were taken out of your cell at the Vlasenica MUP

 5     prison and placed on a bus.  Who placed you on that bus?

 6        A.   When we got out of the prison cell, we were boarded onto buses.

 7     However, an APC appeared, four passenger cars and uniformed soldiers got

 8     out of those vehicles.  On one of these vehicles, that was a white Lada

 9     Niva, there were skulls that were drawn on that vehicle, and also there

10     was an inscription saying, "Bijeli Orlovi, White Eagles."  When we

11     boarded the buses, Pero Mitrovic, a neighbour of mine whom I know

12     personally, appeared.  He used to work in Belgrade.

13        Q.   Can I stop you there for a moment, Witness?  Who exactly was it

14     that took you from your cell in the Vlasenica MUP prison and brought you

15     onto the bus?

16        A.   When we were leaving the prison cell, there were two policemen

17     who came and told us to get out of the cell, stand in a column and leave.

18     There were five minors who they singled out and they stayed behind.  As

19     we were getting on to the bus, Makedonac, the Macedonian, that is his

20     nickname, that's what they call him, Makedonac, he walked up to us and

21     ordered us to get everything out of our pockets, money, documents,

22     everything, not to have anything left in our pockets.  That is when --

23        Q.   Can I interrupt for a moment there?  Where you said documents,

24     what kind of documents did he instruct you to hand up?

25        A.   Personal documents.  IDs, money, that kind of thing.

Page 18174

 1        Q.   Did anyone explain to you why you had to surrender your

 2     identification documents and your personal belongings?

 3        A.   At that moment no one explained anything.  However, on the bus, a

 4     man in uniform walked in and said that we would no longer be needing

 5     that.

 6        Q.   You describe in your statement the transfer of the bus, transfer

 7     of you and your fellow prisoners on the bus until you got to Milici where

 8     you stopped.  Could you describe what happened when the bus stopped at

 9     Milici?

10        A.   Transfer from Vlasenica to Milici was such that the bus did not

11     stop anywhere.  It only stopped in Milici by a tavern.  I personally

12     noticed that this Pero was sitting in front of that tavern and there were

13     some policemen there too, in police uniforms.  One policeman walked up to

14     the bus from that tavern, he walked up to the front door of the bus and

15     said to that Pero -- I mean it wasn't far away, the tavern and the bus.

16     And he said to Pero, "Let me kill them.  Let me finish them off so you

17     don't have to take them any further."  And Pero said "No.  We are in

18     charge and we are responsible for them."  And all of that took a few

19     minutes.  And then the bus set out towards Kasaba again.

20        Q.   Now, did any of the Serb policemen at Milici make any attempt to

21     protect you or to negotiate with Pero to secure your protection?

22        A.   No.

23        Q.   You said the bus left Milici and set off towards Kasaba.  Could

24     you describe what happened when the bus arrived at Kasaba?

25        A.   When the bus arrived to the entrance into Kasaba, it stopped

Page 18175

 1     there.  When it stopped, the front door opened.  I heard an order to walk

 2     out of the back door, groups of four or five men.  As soon as that was

 3     uttered the back door opened.  The first group that sat by the back door

 4     walked out.  As they were walking out, as they were walking off the bus,

 5     as they started walking across a field there, they were shot at

 6     immediately.  And that's how these groups got out, groups of four or five

 7     men.

 8             My turn came, I was in the last group.  My brother was with me,

 9     my cousin, another cousin, and that cousin's relative, Hajrudin, Arif and

10     Galib.  As we were by the back door, Galib said to us, "You see, we are

11     walking into our death."  I tried to say something to him but no words

12     could come out of my mouth.  As I got off, I heard this order to run

13     across the field.  At that moment, I just felt something warm going

14     through me, and that's when I fell.  All of a sudden, I heard Pero and

15     Makedonac squabbling, saying something like, "We shouldn't be doing this

16     right by the main road."

17             Then, when they noticed that there were people who were still

18     alive, they shot them to make sure that they were dead.

19             My brother lay next to me, so he was alive too.  I heard them

20     say, "One of them is showing signs of life."  Then I closed my eyes again

21     and I kept silent, because I thought that they had noticed me.  However,

22     they came to my brother, they finished him off, they didn't touch me.

23     All of a sudden somebody ordered that they get into the vehicles, the

24     vehicles were ignited, then there was silence.  I got up.  As I got up,

25     I felt great pain.  I started walking across the field, but this pain

Page 18176

 1     made me lie down again.  Again, I got up.  I was in such great pain that

 2     I could not even remain lying down.  I was bleeding heavily.  As I walked

 3     across the field, I noticed Ibrahim Muminovic, who was also alive.  He

 4     said to me, "Suad, I cannot stand on my feet.  My legs have been cut

 5     off."  However, I could not answer anything to that.  I continued walking

 6     across that field to a river.  I crossed the river, trying to save

 7     myself.  I came across some Muslim houses.

 8             However, as I got up and as I walked across the field, fire was

 9     opened and they fired at me from a hill that was nearby.  However, I went

10     on walking.  I didn't know where they were firing from.  I just felt

11     these bullets.  Not knowing where I was going, I came across these Muslim

12     houses.  I was walking on my own for a while, and all of a sudden,

13     Muslims took me in.  And took me to the next village.  And that's where

14     they --

15        Q.   Thank you for that account.  Apart from you, how many other men

16     survived the execution?

17        A.   Two other men survived the execution, Rahman Karic and

18     Sadam Mujic.  However, they are no longer among the living, since the

19     fall of Srebrenica.

20        Q.   Do you have any information as to what happened to them after the

21     fall of Srebrenica?

22        A.   I don't know anything.

23             MR. GAYNOR:  Now, that ends the examination-in-chief,

24     Mr. President.  I have one associated exhibit to tender and that is the

25     MUP document described at paragraph 67 of the statement.  The correct

Page 18177

 1     65 ter number for this has been apprised to Your Honours and it is 10772.

 2     The 65 ter number which appears in paragraph 53 is erroneous, but

 3     I tender 65 ter 10772.  Thank you.

 4             JUDGE KWON:  It appears at para 67?

 5             MR. GAYNOR:  Yes, Mr. President, that's correct.

 6             JUDGE KWON:  Thank you.  You referred to footnote number.  Yes,

 7     thank you.  That will be admitted.

 8             THE REGISTRAR:  As Exhibit P3264, Your Honours.

 9             MR. GAYNOR:  Thank you, Mr. Witness.  Thank you, Mr. President.

10             JUDGE KWON:  Thank you, Mr. Gaynor.  Mr. Dzafic, you will be

11     further asked by the accused, Mr. Karadzic, in his cross-examination.

12     Yes, Mr. Karadzic.

13                           Cross-examination by Mr. Karadzic:

14        Q.   [Interpretation] Thank you.  Good morning, Mr. Dzafic.

15             JUDGE KWON:  I need to give you some advice.  Because both of you

16     are speaking the same language, could you please put a pause before you

17     start answering the question put by Mr. Karadzic, by the accused, for the

18     benefit of the interpreters and us.  Thank you.

19             MR. KARADZIC: [Interpretation]

20        Q.   I wish to express my sympathies and compassion and support to you

21     in view of everything that you've been through.  Now I would like us to

22     shed some more light on certain things.  You returned to Bratunac from

23     Serbia in March 1992, right?

24        A.   Yes.

25        Q.   What was the reason for your return?

Page 18178

 1        A.   The reason was the following:  I worked in Serbia, and on the

 2     radio I heard that something was happening in Bosnia.  That is to say,

 3     I heard that there was some killing in Sarajevo.  However, I decided to

 4     return to my native town and that's how I returned.

 5        Q.   Are you speaking about the killing of a member of a Serb wedding

 6     party in Bascarsija?

 7        A.   At that moment, I did not know who it was that had been killed.

 8     I had just heard that someone had been killed.  I didn't realise that it

 9     was a Serb who was a member of a wedding party.  I didn't know who was

10     killed.  I just heard that someone was killed.

11        Q.   Thank you.  How much time had you spent in Serbia until then?

12        A.   About three years.  That is to say, it wasn't all of three years

13     without ever going back.  I would work and then I'd go back home a bit

14     and then I'd go back again and things like that.

15        Q.   Thank you.  I'm asking you about that because I would like to

16     know whether you were aware of war preparations in the municipality of

17     Bratunac?

18        A.   No.

19        Q.   Once you arrived, did you find out, because that was a current

20     thing, that an agreement had been reached to transform Bratunac into two

21     municipalities, a Serb and a Muslim municipality respectively?

22        A.   Well, I wasn't all that sure about these two municipalities.

23     I don't really understand that.  I heard that they had split up.  The

24     MUP, the members of the MUP who were ethnic Serbs got out of the MUP

25     building and they founded their own MUP.  As for dividing the

Page 18179

 1     municipality into two, no.  I didn't know about that.  But the split up

 2     in the MUP, that did happen.  As for the municipality, if that is what

 3     you're referring to, then I guess that would be that.

 4        Q.   Thank you.  The Muslim MUP remained in the building of the old

 5     station, whereas the Serbs, did they establish their own station in the

 6     same building or in a different building?

 7        A.   No.  The Serbs established their own station in a different

 8     building.

 9        Q.   Thank you.  Were you aware of the organisation of the

10     Patriotic League and the Green Berets and the arming of Muslims in

11     Bratunac?

12        A.   No.

13        Q.   On several occasions, you said that there weren't any weapons.

14     However you confirm that your father and another relative had weapons,

15     right?

16        A.   I confirmed that there was no illegal arming.  As for the weapons

17     that my father and these relatives and neighbours had, these were weapons

18     for which they had permits.  That is to say, pistols and hunting guns.

19        Q.   In your statement of the 20th of June, 2000, you said that you

20     had heard but not seen that some Serb had killed a Muslim, right?

21             THE INTERPRETER:  The interpreter did not hear the witness's

22     answer.

23             JUDGE KWON:  The interpreters could not hear your answer.  Could

24     you repeat it, Mr. Dzafic?

25             THE WITNESS: [Interpretation] Yes.

Page 18180

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Thank you.  You said that before the JNA came, Mico Stojic and

 3     Nedeljko advised you not to go any further than your own houses, not to

 4     go into the woods, and also to surrender weapons, if you had any; is that

 5     right?

 6        A.   Yes.

 7        Q.   What was their assessment?  What was this danger that existed in

 8     the forest?

 9        A.   I don't know.  They know.  They thought that we were armed, but

10     ultimately it turned out that we had not had any weapons.

11        Q.   The two persons Mile Stojic and Nedeljko are Serbs from the Serb

12     Territorial Defence; is that correct?

13        A.   Yes, these were my neighbours.

14        Q.   Serbs?

15        A.   Yes.

16             THE INTERPRETER:  Could the witness please speak closer to the

17     microphone?  Thank you.

18             MR. KARADZIC: [Interpretation].

19        Q.   You said in your statement --

20             JUDGE KWON:  Just a second.  Mr. Dzafic, if you answer could you

21     come closer to the microphone?  Thank you.

22             MR. KARADZIC: [Interpretation]

23        Q.   In your statement dated the 15th of June, 1993, to state security

24     in Tuzla, you claimed that your village had already handed in the

25     weapons; is that correct?

Page 18181

 1        A.   Yes.  Those which were subject to permits, those pistols and

 2     hunting guns, this is the weapons I referred to.  There were no other

 3     weapons.  Let us make this clear.  The weapons that people possessed with

 4     permits for possession of such firearms.

 5        Q.   Thank you.  And in your statement from 2000, and I believe it's

 6     found its way into the amalgamated statement dated 12th June 2000,

 7     paragraphs, 5, 6, 7, 8, 10 and 11, you confirmed that you'd heard about

 8     those, that these were not your firsthand information?

 9        A.   Which information?

10        Q.   Information about incidents at the beginning of April, described

11     in paragraphs 5 to 11.

12        A.   I do not understand at all what you're on about.

13        Q.   Well, this means that I'll have to show this statement to you to

14     make clear what I mean.

15             THE ACCUSED: [Interpretation] To wit, if we could retrieve this

16     document, please, 65 ter 20532.  Could it be please shown on e-court?

17     The next page, please.

18             JUDGE KWON:  I think they are identical to the passages in the

19     amalgamated statement, para 5.  Yes.

20             MR. KARADZIC: [Interpretation]

21        Q.   Sir, you'd heard that Serbs had taken Zvornik and then you say

22     that the Novi Sad Corps proceeded towards Bratunac or moved on to

23     Bratunac.  Did you know that JNA had been deployed in Bosnia long before

24     that and that it had moved from Croatia, from where it had withdrawn, and

25     that they did not come from Novi Sad?

Page 18182

 1        A.   I don't know where they came from.  These were Novi Sad Corps

 2     members.  It made no sense for Novi Sad Corps to be deployed in Bratunac

 3     and in Zvornik and in Bosnia.  What was the reason for its deployment in

 4     Bosnia-Herzegovina?

 5        Q.   Mr. Dzafic, did you know that the JNA at the time was still the

 6     legitimate and the only legitimate military force until the 19th of May?

 7        A.   Yes, I do know that, but a corps from Serbia had no cause for

 8     coming to Zvornik and Bratunac to establish law and order.  There were

 9     closer corps that could have done the job.  What was the reason for a

10     corps from Novi Sad and Serbia to come all the way to Bosnia?

11        Q.   I see that this is important for you.  Did you do your national

12     service?

13        A.   Yes.  Yes, this is important for me, and I asked myself how come

14     that Novi Sad Corps found its way to be deployed in Bratunac and Zvornik?

15        Q.   Where did you do your national service?

16        A.   In Cacak.  Did you hear?  In Cacak.

17        Q.   Oh, how come you came to Cacak when you hailed from Bosnia?

18        A.   Well, that was still Yugoslavia at the time.

19        Q.   A-ha.  So on the same basis, Novi Sad Corps could be deployed

20     everywhere throughout Yugoslavia because defence was still unified at the

21     time?

22        A.   No.  The Novi Sad Corps was stationed at Novi Sad.  If they came

23     from Novi Sad to Bratunac, that means that they were on a mission there.

24     I do understand some things about that.

25        Q.   Let's clarify this.  Did you know that military districts did not

Page 18183

 1     coincide with republican borders?

 2        A.   I did not understand you.  Military district borders did not

 3     coincide with republican borders?

 4        Q.   With republican borders.

 5        A.   I don't understand.

 6        Q.   Do you know that the military territorial division in Yugoslavia

 7     did not coincide with republican borders?  For instance, that one

 8     military district could cover the territory of several republics or that

 9     in a certain republic you could have several military districts so that

10     military district boundaries did not coincide with borders of republics?

11        A.   I don't understand.  For instance, the Sarajevo Corps was located

12     at Sarajevo, in Sarajevo.

13        Q.   And no where else outside Sarajevo?

14        A.   I'm not sure about that.  I don't believe.  So if Novi Sad Corps

15     was named Novi Sad Corps, they were headquartered at Novi Sad.  If the

16     Sarajevo Corps had to come to Novi Sad, it must have been on a mission

17     with a certain task.

18        Q.   Mr. Dzafic, the headquarters was in Sarajevo, but its territory

19     went to Slavonski Brod in Croatia and Osmine, Dalmatia, which means that

20     district borders are not the same as republican borders.  Do you know

21     that Novi Sad Corps was deeper in Bosnia and that in withdrawing towards

22     Serbia it arrived to Bratunac from the central part of Bosnia?

23        A.   But what was the task of the Novi Sad Corps in Bosnia?

24        Q.   Let's leave this subject.

25        A.   Let's leave this subject.  It makes no sense to discuss.  Let's

Page 18184

 1     discuss what I personally had gone through.  Well, what you are saying is

 2     important but less important.

 3        Q.   In paragraph 6 of your statement you state that a Serb MUP was

 4     established and you say that Muslims were fired from their jobs.  Were

 5     Muslims fired from the Serb MUP or from the Muslim MUP?

 6        A.   It could be a slight mistake in this.  Muslims stayed on their

 7     jobs in the MUPs.  Serbs separated from them and established their own

 8     Serb MUP.  And maybe people working in factories and in municipal bodies

 9     who were Muslims were fired.  Maybe this is what it refers to.  But

10     Serb -- Muslim policemen who worked at the MUP stayed in -- on their jobs

11     and the Serbs separated themselves.

12        Q.   Thank you.  Do you know that it was offered for the Muslims to

13     establish their own municipality, so that the clerks and public servants

14     from the municipality could be transferred to the Muslim municipality and

15     the Serb clerks and civil servants could be employed by the Serb

16     municipality?

17        A.   I don't know about that.

18        Q.   Well, this is important, Mr. Dzafic, because --

19             JUDGE KWON:  Please slow down and put a pause.

20             Yes, Mr. Karadzic.

21             MR. KARADZIC: [Interpretation]

22        Q.   But that's important, Mr. Dzafic, when you say that the Muslims

23     were fired, whereas I'm telling you they were not fired.  I'm telling you

24     that the Serbs fired themselves from the joint municipality and the

25     Muslims rejected to -- the offer to establish their own municipality.  Do

Page 18185

 1     you know about that?

 2        A.   I was not at those meetings, and I'm -- I was not aware of that.

 3        Q.   You say in paragraph 9 that local Serbs residing in Bratunac

 4     joined the paramilitary units.  Could you please help us distinguish

 5     between JNA reservists, that most Serbs joined, and the paramilitary

 6     units, and to describe both, what kind of uniforms they wore, what kind

 7     of insignia, and whether any local Serb joined the latter.  Do you know

 8     that Serbs heeded all reserve JNA mobilisation orders and that the

 9     Muslims and the Croats did not heed such orders?

10        A.   Is your question whether Serbs heeded mobilisation orders and the

11     Muslims and Croats did not?

12        Q.   Yes.

13        A.   In which period?

14        Q.   In 1991 and 1992, up to the outbreak of war.

15        A.   I never -- I was never personally mobilised by anybody.

16        Q.   When you arrived to Bosnia, did you know that all Serb

17     able-bodied men were in JNA reserve, although they resided at home but

18     they were part of the reserve JNA forces?

19        A.   Well, they went to the combat zones in Croatia.

20        Q.   They were in reserve, of course they went to the front line in

21     Croatia, but they were there in reserve to be sent wherever they were

22     needed.

23        A.   Why they were in reserve?  What was the threat?

24        Q.   Let's leave that, Mr. Dzafic.

25        A.   Let's leave that, Mr. Karadzic.  Let's discuss those things that

Page 18186

 1     I suffered.

 2        Q.   We will come to that.  You discussed these things.  I'm

 3     discussing what you discussed.  You said that local Serbs in Bratunac

 4     joined the paramilitary units.

 5        A.   Yes, they did.

 6        Q.   Were they also reserve JNA personnel?

 7        A.   Yes, they were.

 8        Q.   Is there a difference between reserve JNA and paramilitary units?

 9        A.   Well, reserve JNA was there until the military or the JNA came

10     out on the 18th or 19th of May.  All of them went into reserve units.

11     Some went to paramilitary units.  Some went to Arkan's Tigers, some to

12     White Eagles.

13        Q.   But this is what we want to clarify.  Up to the 19th May, the JNA

14     was there and they were reserve JNA as Territorial Defence which was

15     under the jurisdiction of the JNA; is that correct?

16        A.   Whose Territorial Defence?

17        Q.   Each unit of Territorial Defence was under the hierarchy of the

18     JNA?

19        A.   Why wasn't I then a member of such Territorial Defence?

20        Q.   Mr. Dzafic, you worked in Serbia, so nobody called you.

21        A.   Why my relatives were not?  Why my brothers were not called up?

22     Why none of us were deployed?  For what reason?  Why wasn't it ethnically

23     mixed?

24        Q.   Mr. Dzafic, this is the crux of the matter.  They were not called

25     up because they didn't want to, because throughout 1991 and 1992, they

Page 18187

 1     rejected any form of cooperation with the JNA.  If you're not familiar

 2     with that, then I'll have to clarify the matters that you are discussing.

 3        A.   Do you have any documents that anybody rejected such call-ups?

 4        Q.   There are plenty, and recommendations of the BH Presidency not to

 5     heed the call-up papers.  Let's describe those paramilitary units in ways

 6     as to distinguish them from reserve JNA.

 7        A.   Listen to me.  Let's make this one thing clear.  If I worked in

 8     Serbia and this is the reason why I was not called up to Territorial

 9     Defence, what was the reason why my relatives, cousins and brothers did

10     not receive call-up papers?  I would have known that somebody had called

11     them into the Territorial Defence.  They would have told me.  Let me

12     finish.  Most probably irrespective of my work in Serbia, I had to be

13     deployed in Territorial Defence, but I never received any call-up papers.

14     I don't know whose Territorial Defence it was and who organised it.

15             JUDGE KWON:  Do you see paragraph 9 of your statement,

16     Mr. Dzafic, in front of you?  You are saying there that local Serbs in

17     Bratunac joined the paramilitary units.  And the question for you was to

18     describe the paramilitaries you said in this paragraph.  Was it different

19     from the JNA reservist unit?  That was the question.  Can you answer the

20     question, Mr. Dzafic?

21             THE WITNESS: [Interpretation] Yes.  They did -- there were

22     differences between them.

23             MR. KARADZIC: [Interpretation]

24        Q.   How could you distinguish them from one another?  What kind of

25     uniforms they wore, what kind of insignia they wore?

Page 18188

 1        A.   Reserve JNA personnel were dressed normally in JNA uniforms.  The

 2     others wore uniforms which were different.  They wore insignia of

 3     White Eagles or Arkan's Tigers.  There were some others.  I can't

 4     remember all of them.  So they wore some insignia.

 5        Q.   You mentioned skull with a cross bones on a vehicle.  Would that

 6     insignia correspond to that, what you're --

 7        A.   Yes, that's the insignia of White Eagles.  The vehicle bore that

 8     symbol of a skull and criss-crossed bones and then some crosses and the

 9     words "White Eagles" was on that white Lada Niva vehicle.

10        Q.   And among them, there were few local people, mainly they were not

11     from Bratunac?

12        A.   What people are you referring to?

13        Q.   The paramilitaries, the White Eagles, people wearing those

14     insignia which were other than JNA insignia.

15        A.   The people who came to the prison to fetch us, to execute us,

16     well, if you're meaning them, I will explain everything.

17        Q.   No.  I'm discussing your time at Bratunac before arrest, before

18     transfer.  You said that there were paramilitary formations in Bratunac

19     and that certain Serbs joined them.  Was a majority of Serbs in JNA

20     reserve and were the majority of paramilitary units from somewhere else?

21        A.   The paramilitary units - I heard people talk - included not only

22     people from the municipality of Bratunac but from all over the place.

23     There were members or people who joined those paramilitary units from the

24     territory of the municipality of Bratunac.  Whereas reserve JNA

25     personnel, they were transferred into the Territorial Defence of the

Page 18189

 1     Republika Srpska, and you know quite well when this was established and

 2     you know that it existed.

 3        Q.   Thank you.  You said that soldiers did not maltreat anybody.

 4        A.   I can tell you that when the Novi Sad Corps came to the village

 5     looking for weapons, they did not maltreat anybody.  They treated

 6     everybody fairly.  One officer was flabbergasted about why they were

 7     brought there.  They would sit down with us, discuss matters, talked with

 8     us at -- a certain amount of time and then went back.  And I'm referring

 9     to the Novi Sad Corps soldiers who had come to our village to take away

10     the weapons.

11        Q.   Thank you.  You say that they were there for an hour and never

12     maltreated anybody and then went out.

13        A.   Yes, I cannot be specific about the time but they were fair.

14     They sat down, talked with us, and they were -- they couldn't believe why

15     they were brought there.  They were simply confused about why they were

16     there at all.

17        Q.   Thank you.  Then you said that from the 10th of May onwards,

18     after what happened in Glogova, the Serb Territorial Defence often came

19     to visit your village, more often than before that; is that correct?

20        A.   Yes, yes.

21        Q.   Thank you.  And they would stay there briefly and go back, right?

22        A.   Well, sort of.  They would sit and talk to us as well.  All these

23     people were our neighbours.  I knew them personally.  They were not

24     people from elsewhere.

25        Q.   Thank you.  Dusko and Brano came to Vitkovici from Osamsko and

Page 18190

 1     told you, that's what you say, that you should escape from the village,

 2     and that they would give you a sign when it's safe, that they would fire

 3     an M-53 as a sign for you to go back.

 4        A.   It's correct but what are you --

 5             MR. GAYNOR:  Could I have a reference for that, please,

 6     Mr. Karadzic?

 7             THE ACCUSED: [Interpretation] This is a statement of

 8     Mr. Suad Dzafic of the 15th of June, 1993.  I think that I called it up a

 9     moment ago.  It is 20565.  The year is 1993.  That is to say, when he got

10     to Muslim-controlled territory.

11             MR. KARADZIC: [Interpretation]

12        Q.   You said that they said to you that you should not separate, that

13     you should stay in the forest, and that they would fire from this M-53,

14     thus giving you a sign that the village is safe and that you can go back.

15        A.   Yes, but I want to have it shown here, in Bosnian, in the Bosnian

16     version, so that I see it.

17             THE ACCUSED: [Interpretation] 20565.  That's the 65 ter number,

18     20565.  It is a handwritten document that was typed up.  I think it's on

19     page 2.

20             THE WITNESS: [Interpretation] What do you mean, handwritten?

21     This is typewritten.

22             MR. KARADZIC: [Interpretation]

23        Q.   Did you give a handwritten statement that was later typed up?

24        A.   These people took a statement from me.  They were typing it up.

25     I probably signed a typewritten statement.  Because this is a copy.  This

Page 18191

 1     is not the original.

 2        Q.   Please, take a look at what it says here:

 3             "Brano Djuric -- Dusko and Brano Djuric, neighbours of ours, who

 4     were both between 15 and 17 years old, told us that Milan Djuric said

 5     that we should flee from the village into the woods."

 6        A.   Yes, yes, that is the way it was.  That is what they said to us,

 7     that we should flee into the woods seeking shelter, that is to say, while

 8     things were happening in Krasan Polje and Glogova.  To seek shelter in

 9     the forest and they would send us a sign as to when it would be safe to

10     go back to the village.

11        Q.   Thank you.  And who was this danger coming from so this Milan

12     Djurkovic told you to seek shelter and that he would let you know who

13     when it would be safe?  Who was it that was doing this?  Was it these

14     paramilitaries?

15        A.   Believe me, I don't know.  They probably know when or from whom

16     this danger was coming.

17        Q.   Let us not have this admitted.  I'm going to read it to the end.

18     This is what you say.

19             "The sign for us to return was if Milan Djurkovic opened a short

20     burst of fire from his M-53 light machine-gun, then that would be the

21     sign that we could return to the village.  This is what he did.  Golub

22     then took us to our village, Dzafici, which had not been torched."

23             Is this Golub a Serb?

24        A.   Yes, he is.

25        Q.   Was he also in the Serb Territorial Defence?

Page 18192

 1        A.   Yes, he was.

 2        Q.   Thank you.  Then Mijo Stojic and a certain Milan came and another

 3     three or four members of the Serb police in uniform, to inform you about

 4     what had happened in Krasno Polje.  And they told you that

 5     Hajran Demirovic, from town, had been killed because he allegedly made

 6     rifles by hand.  Right?

 7        A.   Everything that this statement contains is what I said, and it is

 8     correct.  We can go on reading it for two hours but this is exactly the

 9     way it was.  Everything I said was true.  There is no need for me to

10     repeat what I had already said.  All of that is true.

11        Q.   Then you said that paramilitary formations then did not take

12     anyone prisoner.  After they had received weapons from villagers, right?

13        A.   I am telling you about my village.  They didn't take anyone

14     prisoner from there.

15        Q.   Thank you.

16             THE ACCUSED: [Interpretation] If the learned Mr. Gaynor needs

17     this, that is what was said in the trial of President Slobodan Milosevic.

18     I think that it's the transcript of the 27th of June, 2003, and the page

19     is 23236 -- or, rather, 12 through 22.

20             MR. KARADZIC: [Interpretation]

21        Q.   Further on, you say that the Serb police all the -- from the 10th

22     until the 18th of May patrolled the village; is that correct?

23        A.   May what?

24        Q.   From around the 10th of May, when what happened happened in

25     Glogova.  After that they patrolled the village?

Page 18193

 1        A.   Yes, they did.

 2        Q.   Thank you.  And you say that because of all of that, you began to

 3     feel unsafe, and that these same people came and promised that nothing

 4     would happen to you; is that correct?

 5        A.   Yes, that is correct.  Let me clarify that a bit.  I felt unsafe,

 6     of course.  Serbian police, there were no Muslim members of the police

 7     force.  Well, one had to feel unsafe.  And that is true that they did

 8     come and tell us that nothing would happen to us.

 9        Q.   And did you say that they asked for Mehmed Alija Salihovic

10     because he allegedly was training the Green Berets?

11        A.   Yes, I said that I heard that.  Usually they looked for all the

12     more educated, more powerful people.  This Mehmed Alija Salihovic was a

13     professor in Bratunac.  So all of these people who had senior posts,

14     well, they looked for them, they charged them of being involved with some

15     units, the Green Berets, but I do not even know if there were any

16     Green Berets in Bratunac municipality or that any units were trained.

17     Really, I don't know of that.

18        Q.   Thank you.  I can accept that, but you don't know that there

19     weren't such things either, right?

20        A.   Well, as for my village, there were no such things there.

21        Q.   And you also said that you heard that Mr. Habibovic was killed

22     but that you didn't see that; is that correct?

23        A.   Yes.  Well, could you please repeat that?  Which gentleman?

24        Q.   Mr. Habibovic.  I would have to call up the document to see what

25     the first name was.  Never mind.  Well, I can explain --

Page 18194

 1        A.   Well, I can explain if we are talking about Fadil Habibovic.

 2     It's true that he was taken away and killed.  I didn't see it but he was

 3     taken away and killed and he hasn't appeared since.  He was with me on

 4     the bus.  He was taken off the bus, brought back, taken off again, and he

 5     wasn't seen again.  This is if we are talking about Fadil Habibovic.

 6        Q.   Thank you.  And this Rahman Karic, was he on some list for having

 7     a light machine-gun and that his brother did not hand in his weapons or

 8     weapon?

 9        A.   Yes, I heard that he was on some list that the Serbs had, that he

10     was charged of having an old machine-gun from World War II.  I knew

11     Rahman Karic personally.  He was my neighbour.  He didn't have one

12     definitely.  I mean I'm not sure if he had one.

13        Q.   Thank you.  And were there any occurrences of Serbs and Muslims

14     crossing the Drina River because of the tensions, because they felt

15     insecure, were they running to Serbia?

16        A.   Well, I know Serbs were running away.  I don't know if the same

17     applied to Muslims.  I don't know if you know of anyone among the Muslims

18     who actually crossed.  Perhaps you know that but I personally don't.

19        Q.   And how many Serbs fled, do you remember?

20        A.   Well, they were running away, they would go and they would come

21     back.  They would go during the night and return during the day.  I heard

22     that from the municipality of Bratunac this happened.  Also from my

23     village they would leave in the evening, women and children, and then

24     most of the men actually stayed behind.  I'm just telling you about what

25     I know and what I heard.

Page 18195

 1        Q.   And did you understand that to mean that there was also fear and

 2     insecurity amongst them too?

 3        A.   Well, probably there was.  But I don't know.  I'm asking myself

 4     for what reason.  Well, later, it turned out that there was no danger.

 5        Q.   Then you say that on the 17th of May, the Territorial Defence

 6     surrounded the village and that you were told that you should not go off

 7     anywhere from the main road and that nothing would happen to you, and

 8     this was told to you by the commission headed by Milomir Babic?

 9        A.   17th of May?

10        Q.   1992.

11        A.   Yes, yes, I know it's 1992.  I'm talking about 1992.  Yes, on the

12     17th of May we were informed not to go anywhere, not to run away, that

13     nothing would happen to us.  But then on the 18th of May, in the morning,

14     at 9.00, first the electricity was cut, and then information arrived that

15     we had to leave the village, that we can take whatever we could carry

16     with us, to go down to the main road where the buses would be waiting for

17     us.  And this is what we did.

18             But when we were leaving, a few people were in the village who

19     informed us, but when we were leaving the houses, I noticed that there

20     were a lot of soldiers coming out of the surrounding woods who continued

21     to loot the homes, to take away the cattle.  This happened very shortly

22     after we left.  We weren't -- we were hardly on the buses when all of

23     this began.  There was firing all around.  Nobody was killed.  Nobody was

24     wounded.  Nobody was mistreated.  I must say that.

25             Then when we reached the buses down there, Milan -- well, I don't

Page 18196

 1     know if it's Milan.  Babic, Milenko Babic, personally I heard him repeat

 2     it again:  "If you have weapons," still he did not believe, he said,

 3     "write it on a piece of paper and hand it in.  You don't have to say who

 4     had the weapons, just say where they are and there will be no problems."

 5     This happened while we were boarding the buses on the 18th of May.

 6        Q.   Thank you.  And were you told that you could -- they could not

 7     protect you unless you all assembled in one place and that you needed to

 8     go to the stadium because it would be easier to protect you there?

 9        A.   No.  They didn't tell us that they couldn't protect us.  They

10     said, "You're leaving, you have to leave the village."  So my village in

11     the Bratunac municipality was the last to be emptied.  It wasn't a large

12     village, it's true.  The whole village was emptied on the 18th of May, in

13     the municipality of Bratunac.  However, people were assembling from other

14     villages who did not leave when people were being expelled from the

15     villages.

16        Q.   Mr. Dzafic, we had a witness here who testified that you were

17     informed to assemble at the stadium so that they could protect you, and

18     that there was no army, no soldiers were escorting you.  Did you go by

19     yourselves or were you escorted by soldiers to the bus?

20        A.   Which witnesses did you have?

21        Q.   Well, I don't know if it was a protected witness or not but the

22     Trial Chamber knows this.

23        A.   Well, let's just clarify this a bit.  I'm talking about my own

24     village.  From my own village, no one came to testify.  And that's the

25     truth.

Page 18197

 1        Q.   Is it true that Jasmin Muminovic had some sort of camouflage

 2     equipment and that he was taken to Vlasenica for interrogation?

 3        A.   Yes.  This did happen.  When we were separated from our families

 4     in Vlasenica, from the buses, all the able-bodied men were taken off the

 5     bus.  They returned a couple of elderly men and they left us able-bodied

 6     men including Jasmin Muminovic, who had a rucksack, a kind of bag,

 7     multi-coloured bag.  They asked him where did he get that from?  But he

 8     tried to explain that a few days before that, he just came back from

 9     serving his term of duty in the JNA and that he brought the uniform and

10     everything with him.  But he didn't manage to explain all of that to them

11     because they hit him so much and they took him away to the police station

12     for interrogation at the MUP.

13        Q.   Is it true that you were interrogated about who killed judge

14     Goran Zekic, and if it was correct that you recalled that he was killed

15     on the 8th of May in an ambush when he was going to make some sort of

16     agreement, peace agreement?

17        A.   I heard that he was killed.  I don't remember the exact date.

18     When we were detained in the prison cell, yes, they beat us and they

19     asked us who killed -- who killed him, do you know who killed him?  This

20     is the kind of things that they were asking us about.

21        Q.   Thank you.  You said in your statement of the 15th of June, 1993,

22     that they beat you for a whole ten minutes, and then someone from the

23     hall ordered the soldiers to stop beating you and to leave the room.  Is

24     that correct?

25        A.   Yes.  That's correct.  This happened just when they brought us to

Page 18198

 1     prison.

 2        Q.   Thank you.  Is it correct that local Serbs told you that you

 3     needed to just stick it out for a little bit until they got rid of these

 4     people from outside and that then you would be safe?

 5        A.   Yes.  This is what a policeman or a soldier told us in prison.

 6     "If you stick it out and nothing bad happens to you until the end of

 7     May," because then he said the mercenaries are the ones who kill and

 8     loot, and they need to -- they should be leaving by late May, and then

 9     probably after that, you would be safe.

10        Q.   Thank you.  And is it correct that later you found out that

11     Jasmin Muminovic was a volunteer in the war in Croatia against the Serbs?

12        A.   What?  I beg your pardon?  I didn't understand the question.

13     Could you please repeat it?  Jasmin to have been a volunteer in the

14     Croatian army?  No, no.  Can you please explain that when you put the

15     question?  Are we talking about Jasmin Muminovic?  You said that he was a

16     volunteer on the Croatian side.

17        Q.   That he participated in the war in Croatia.

18        A.   Well, you said that he was a volunteer on the Croatian side.

19     That's what you said, if I heard you correctly.

20        Q.   Do you know that there were many Muslims from Bratunac who were

21     volunteers on the Croatian side in Croatia?

22        A.   I don't know, but now we are talking about Jasmin Muminovic.  How

23     can you say that when the young man had served his military term of duty

24     and was on the side of the Serbs in Croatia?  You're saying that he was

25     on the Croat side.  I'm asking you, where did you get this information

Page 18199

 1     from?  Do you have any documents?  We can document, all of us can

 2     document, on whose side Jasmin was, a member of whose side he was.  Until

 3     he completed his term of duty.

 4        Q.   You said that your father and brother were taken to Kladanj or

 5     Tuzla with a group of women and children, or was it Jasmin's father and

 6     brother who were taken away to Kladanj?

 7        A.   Well, I don't know.  It probably says so in the statement whose

 8     brother and whose father.  You cannot put questions like that.  You

 9     cannot induce me to say something that is not correct.

10        Q.   Can we look at page 4 of this document?

11        A.   I can explain everything but don't lead me to say something that

12     is not true.  All the things that I experienced, that I lived through,

13     I'm talking about them and that is true.  My truth cannot be denied,

14     that's for sure.

15        Q.   Well, I'm just trying to understand the situation and I'm trying

16     to show the Trial Chamber what the situation was.

17        A.   I'm sure the Trial Chamber understands the situation.  You're

18     just trying to provoke me.  There is no way that you can manage to

19     provoke me, even if I were here for five nights and five days.  What

20     I experienced, Mr. Karadzic, is something that did not ever happen to you

21     for sure.

22        Q.   Well, let's look at what it says here.  Perhaps you're right.  It

23     says somebody came after those who made you sing Chetnik songs left.

24             "After they left, the door was unlocked, and then after 30

25     minutes, a policeman entered the room where we were locked telling us not

Page 18200

 1     to sing and asking us who was Muminovic Jasmin's brother and father.

 2     They stood up and they were taken outside of the room, the mentioned

 3     policeman in answer to our question said that they would be transported

 4     to Novi Sad.  However, later, I found out that thanks to Jasmin's

 5     participation at the front in Croatia as a member of the JNA, the father

 6     and brother were transported to Kladanj and Tuzla, together with a group

 7     of women and children."

 8             All right, so you are right, he was in the JNA.

 9        A.   Yes, I'm right and I'm always right, and there is the document.

10     And for sure, had he been a member of the Croatian army, who would have

11     released him?  So again I'm telling you, I only am speaking the truth.

12     You cannot induce me to say something that is not true.  All I'm going to

13     be doing is telling the truth.  And, Mr. Karadzic, don't even try to do

14     that.  It's no good.  It would be no good.

15             And these questions, I can simply not answer them.  I just simply

16     want to talk about things that I personally experienced, what happened to

17     me.  As for what I heard and what I saw, perhaps it's important to you.

18     Well, it's important to me as well.  But these things that I personally

19     experienced, if you ask me about that, I'm going to answer that, and

20     other things.  I don't know if there is any need for any more.

21     Everything has already been told and proved.

22             JUDGE KWON:  Thank you, Mr. Dzafic.

23             Mr. Karadzic, if you have more questions on relevant issues, it's

24     time for you to come to those issues.  You have ten minutes to conclude

25     your cross-examination.

Page 18201

 1             THE ACCUSED: [Interpretation] Thank you.  I think everything is

 2     relevant your Excellencies so that we can form a picture.  The witness is

 3     not only talking about the events surrounding the execution.  He talks

 4     about many other things.  This is a part of his statement.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   You said that the bus was surrounded by a group of people whom

 7     you identified as Arkan's Tigers and the White Eagles; is that correct?

 8     The bus where you were on the 18th of May -- actually, the 21st of May.

 9        A.   The 21st of May in Vlasenica.  Let me help you a little bit.

10        Q.   Uh-huh.  And what were you told when you were boarded on the

11     buses?  Where were you supposed to be going?

12        A.   When we came out of the prison, they said that we should be going

13     to be exchanged, or perhaps -- I don't know.  But when the bus was going

14     towards Bratunac, I was thinking about all kinds of things.  I was even

15     thinking perhaps that they would return us home.

16        Q.   And what did the policeman tell you, the one who came in, that

17     you were going back home; is that right?

18        A.   I have to look.  This was 18 years ago.  I cannot remember every

19     detail.  I'm sure you don't recall every detail either.  I can look if

20     you show me where I said that.  Let me see that.

21        Q.   In the testimony -- in your testimony in the Krajisnik case on

22     the 11th of February, 2004, at 7 -- at page 748 to page 749, you said

23     that a policeman entered and said that you were going back home.

24        A.   Where did he enter, to the bus?  Into the bus or into the cell?

25        Q.   I think he entered the room.

Page 18202

 1        A.   It's a cell.  It's not a room.  A room is where you sleep in and

 2     a cell is for prisoners.

 3        Q.   I'm reading from the English, it says, to the room he told you to

 4     come out one by one and to go back home.  Is that correct?

 5        A.   Yes.  It's like that, definitely.

 6        Q.   Then --

 7        A.   Well, when we were coming out of the cell, nobody told us, of

 8     course, that we were going to be executed, that we were going to be

 9     killed, nothing like that.  They said that we were leaving.  But I found

10     it a bit suspicious when they separated the five underage young men and

11     left them behind.

12        Q.   But then you are mentioning some Macedonian from Prilep.  Which

13     formation did he belong to?

14        A.   I think that he belonged to some kind of sabotage unit from

15     Vukovar.  Going by what the people said in the municipality of Bratunac,

16     by the stories there, that Macedonian person killed a lot of people in

17     the Vuk Karadzic hall.  I'm just telling you what I heard, I didn't see

18     it.  Plenty of people said that.  He's from Prilep.  His nickname is

19     Makedonac, the Macedonian.  Somebody told me and I seem to recollect

20     that, that his name or his last name is Vance [phoen].  I'm not sure

21     about that.

22        Q.   Thank you.  And when you say after -- in your answer to

23     Mr. Gaynor's question and in your answers, you talk about Serbian

24     soldiers.  When you say that, do you mean this Macedonian person as well?

25     Are all of these people Serbian soldiers as far as you were concerned?

Page 18203

 1        A.   All of them, of course, all of them, as long as they are killing

 2     Muslims.

 3        Q.   Thank you.  If he is a Serb by ethnicity you call him a Serb

 4     soldier?

 5        A.   No, no, no, no, no.  I did not say that if he's a Serb he's a

 6     soldier.  Probably not all Serbs were soldiers.  I did not say that all

 7     Serbs were soldiers.

 8        Q.   Thank you.

 9        A.   I never mentioned anything like that.  I mean, a person cannot

10     remember everything.  It's been quite a while.

11        Q.   Thank you.

12        A.   Put a question to me.  I see that you're not interested in what

13     I've experienced, and your time will be up and --

14        Q.   We are getting to that, Mr. Witness.  So when you say Serb

15     soldiers, was this Macedonian a Serb soldier too?

16        A.   This Macedonian was a member of the Vukovar sabotage platoon.

17     Now, if you have information as to who belonged to this Vukovar sabotage

18     platoon, what their ethnicities were, then you know.  I'm not quite sure,

19     I cannot say for sure.

20        Q.   Thank you.  What about Arkan's men, are they Serb soldiers?

21        A.   Yes, yes.  Arkan's men, yes.  The White Eagles.

22        Q.   The White Eagles, are they Serb soldiers?

23        A.   Yes, they are.

24        Q.   Thank you.

25             THE ACCUSED: [Interpretation] Can we now have that document that

Page 18204

 1     was admitted?  I think that's the only one.  I think it's 65 ter 10772

 2     but it's already been assigned a P number.  It's the last P number.  Can

 3     we have that document?

 4             JUDGE KWON:  Exhibit 3264, P3264.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Do you see this, Mr. Dzafic?  Do you see that the chief of the

 7     public security centre of Sarajevo, the local one, at the time Milici

 8     belonged to Sarajevo, or, rather, Sokolac, the seat was at Sokolac, on

 9     the 25th of July, the chief asked for information about that particular

10     event.  Because it says here, reference here document, highly

11     confidential, number such and such, dated the 25th of July, 1992.  Is

12     that right?

13        A.   That is what is written there, yes.

14        Q.   On this first page, is there a description of that event that

15     occurred and that you survived?

16        A.   Yes.  Precisely.  However, there is a small correction to be

17     made.  It wasn't 25 men that were killed then.  There were 29 who were

18     killed.  Whereas 32 were taken out to be executed and 29 were killed and

19     three survived.  So this report says that, but there are some things that

20     were not reported on.  The report says that Serb policemen tried to stop

21     this group.  I don't know whether they did try.  I could not notice that

22     they had tried.  If they did try, the Serb policemen, then why did this

23     member of the Serb police walk up to the bus and say to Pero Mitrovic,

24     while we were by the tavern, "Let me kill all of them, let's get this

25     done and over with"?

Page 18205

 1        Q.   This man, did he wear a police uniform and do you know that he is

 2     a policeman?  Because he's wearing a uniform?  Or do you know him

 3     personally?

 4        A.   I did not know him personally.  The man was wearing a police

 5     uniform, a policeman, a regular policeman, blue police uniform.  That's

 6     what he was wearing.  If all men could wear that, then they are all

 7     policemen.  I am trying to say that he personally wore a police uniform.

 8     I did not know him and that's it.

 9        Q.   Thank you.  This report, does it mention the same things, the

10     White Eagles, the Vukovar unit, there is no reference to Arkan's men; is

11     that correct?

12        A.   Yes.  Yes, that's it.

13        Q.   Did they have an APC and did they have heavy weaponry?

14        A.   Yes, there was a white APC -- or, rather, a camouflage APC.  Over

15     here there is only a reference to one Golf, a red one, Bijeljina

16     registration plates.  However, there was another Golf and two Lada Nivas.

17     This other red Golf had Zvornik licence plates, Pero Mitrovic drove that.

18     As for this Lada, I cannot remember its licence plate but it -- one of

19     these Ladas had "Bijeli Orlovi" written on it and the skull that

20     I mentioned as well.

21        Q.   Do you see that what it says here, that at that point in time,

22     the police station had six members that were armed and that this group

23     that had the APC was heavily armed and that they were much stronger?

24        A.   That is what is written here, but I cannot understand that a

25     police station has only six men.  I mean, I just want to explain this.

Page 18206

 1     I did not notice any attempt whatsoever.  I did not notice any attempt

 2     whatsoever that -- to have things prevented or stopped.  If an attempt

 3     had been made of that kind -- when we were stopped by that tavern that

 4     was very brief.  Any kind of attempt to negotiate and to stop people from

 5     doing this, that would have had to take time.  Whereas this was very

 6     fast.

 7        Q.   These men from that group, were they conciliatory or were they

 8     cruel?

 9        A.   Which group?  The perpetrators?

10        Q.   The perpetrators, yes.

11        A.   Were they what?

12        Q.   Were they conciliatory, could you talk to them, or were they

13     arrogant and cruel?

14        A.   As far as I am concerned, and what my personal view is, I don't

15     know how I describe these people really.  I do not know how to describe

16     them.  If I were to describe them here now, it would be ugly for me to

17     speak about what these people were like.  But that policeman who wore a

18     uniform, nothing, nothing, nothing, he was no better than them.  The one

19     who walked up to this bus, how can he be a good man if he walked up to

20     the bus and said, "Come on, Pero, let me finish them off.  You don't have

21     to take them any further."  That cannot be a conciliatory man.  How can

22     that be a good man?

23        Q.   Mr. Dzafic --

24             JUDGE KWON:  The time is up.  Your last question, please.

25             MR. KARADZIC: [Interpretation]

Page 18207

 1        Q.   Last question, Mr. Dzafic.  A moment ago, did we agree that you

 2     do not know that he was a policeman except for what you're saying, that

 3     he wore a blue uniform?

 4        A.   I've explained that.  I don't know him personally.  He was

 5     wearing a uniform, a policeman's uniform.  I explained that to you.  And

 6     that is what I stated, and that's the way it is.

 7        Q.   Thank you.  I have no further questions.  Thank you for your

 8     testimony, and please do not feel attacked.  I'm not attacking you.  I'm

 9     seeking the truth.

10        A.   Okay, Mr. Karadzic you did not ask me many questions -- I mean,

11     you did not ask me any worthy questions.  You did not ask me about these

12     policemen that are on those lists there.  Those who beat us in prison,

13     Sladjan Pajic and Goran Gajic, all of these ugly things that happened to

14     me, you barely asked me any questions about that.

15        Q.   You said that in your statement.  I am not disputing that, that

16     someone hit you, until I bring witnesses to testify about that.  I am not

17     challenging that there was shooting but we have to see who was that was

18     shooting.

19        A.   Yes, yes, but then you're saying did anyone beat me, that there

20     is evidence, I have wounds on my body.

21             JUDGE KWON:  Thank you, Mr. Dzafic.  Mr. Gaynor, do you have

22     re-examination?

23             MR. GAYNOR:  No re-examination.  Thank you, Mr. President.

24             JUDGE KWON:  Thank you.

25             Thank you, Mr. Dzafic.  That concludes your evidence.  On behalf

Page 18208

 1     of the Chamber, my colleagues and the Tribunal as a whole, I would like

 2     to thank you to come to The Hague yet again to give it.  Now you are free

 3     to go.  Please have a safe journey back.

 4             THE WITNESS: [Interpretation] Thank you, too.  Thank you.

 5             JUDGE KWON:  The witness may be excused.

 6                           [The witness withdrew]

 7             JUDGE KWON:  The next witness we will hear in closed session?

 8             MR. GAYNOR:  The next witness will not be testifying today, but

 9     he will be appearing in accordance with the protective measures Your

10     Honours ordered which is in closed session, as I recall.

11             JUDGE KWON:  But the next witness will be available now?

12             MR. GAYNOR:  It depends on his health and we will confirm -- he

13     won't be available to testify today, and we certainly hope he'll be

14     available to testify tomorrow.  The second witness for tomorrow should be

15     available also, so we should be able to hear two witnesses tomorrow.

16             JUDGE KWON:  So your suggestion is to hear the evidence of those

17     two tomorrow --

18             MR. GAYNOR:  Correct, Mr. President.

19             JUDGE KWON:  -- not today.

20             MR. GAYNOR:  That's right.

21             JUDGE KWON:  Very well.  Then we are -- before we adjourn for

22     today, I would like to issue an oral ruling in relation to the status of

23     the "Request for International Legal Assistance in Hearing Witnesses via

24     Video Conference Link," filed confidentially and ex parte on the

25     1st of August, 2011, by the Court of Bosnia and Herzegovina.  The

Page 18209

 1     ex parte status was lifted by the order of the duty judge of

 2     2nd of August, 2011.  In his submission dated 4th of August, 2011, the

 3     accused requested, inter alia, that the matter be reclassified as public.

 4     In its "Decision on Request for Assistance of the Court of Bosnia and

 5     Herzegovina Pursuant to Rule 75 bis," issued confidentially on 9 August

 6     2011, the Chamber invited the BiH court to indicate why the request

 7     should remain confidential.

 8             The Chamber has now been informed by the BiH Court that the Court

 9     did not intend for its request to be regarded as a confidential

10     submission.  In light of this, the Chamber orders that confidentiality be

11     lifted on the following, and that each reclassified as public.

12             1:  The Court of Bosnia and Herzegovina's "Request for

13     International Legal Assistance in Hearing Witnesses via Video Conference

14     Link," filed on 1st of August, 2011.

15             2:  The "Prosecution's Response to Confidential Request for

16     Assistance," filed on 3rd of August, 2011.

17             3:  The accused's submission, entitled, "Submission of

18     Radovan Karadzic," filed on 4th of August, 2011.

19             4:  The Chamber's "Decision on Request for Assistance of the

20     Court of Bosnia and Herzegovina Pursuant to Rule 75 bis," issued on

21     9th of August, 2011.

22             Unless there are other matters to be raised, we will adjourn for

23     today.

24             Tomorrow, 9.00.

25                           --- Whereupon the hearing adjourned at 12.39 p.m.,

Page 18210

 1                           to be reconvened on Friday, 2 September 2011,

 2                           at 9.00 a.m.