Tribunal Criminal Tribunal for the Former Yugoslavia

Page 31461

 1                           Friday, 14 December 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

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

 6             JUDGE KWON:  Good morning, everyone.

 7             Mr. Nicholls, please continue.

 8             MR. NICHOLLS:  Good morning, Your Honour.  Actually, having gone

 9     through the transcript and discussing things, I have no further questions

10     at this time.

11             JUDGE KWON:  Thank you, Mr. Nicholls.

12                           WITNESS:  LUKA DRAGICEVIC [Resumed]

13                           [Witness answered through interpreter]

14             JUDGE KWON:  Mr. Karadzic, do you have any re-examination?

15                           [Defence and accused confer]

16             THE ACCUSED: [Interpretation] Just a moment, your Excellencies.

17     Bear with me.  I did not expect that I would be invited to do so

18     immediately.

19             Yes, a few short questions.  Good morning, Excellencies.  Good

20     morning everybody.  Good morning Colonel, sir.

21                           Re-examination by Mr. Karadzic:

22        Q.   [Interpretation] Good morning, Colonel.

23        A.   Good morning, Mr. President.  Good morning to everybody.

24        Q.   First of all let me ask you about the procedure to report crimes

25     to the prosecutor's office?  Who is it who reports crimes to the

Page 31462

 1     prosecutor's office, which structure in a unit?

 2        A.   Pursuant to our rules as far as I can remember at this moment,

 3     but I believe that I will be right if I say that from the company

 4     commander down to every officer is duty-bound to draft a report and to

 5     hand it over to the prosecutor's office if they have a legal expert in

 6     their unit, i.e., in their command.  It is that legal expert who drafts

 7     that report.  Every officer who learns of a crime is duty-bound to

 8     examine it if possible, but he has to report it.  It has to be done by a

 9     professional in that unit.

10             Having done that, they have to report to their superiors about

11     that.

12        Q.   What is the role of the military police in that?

13        A.   I can't give you any details.  However, in that case the military

14     police are used by the security organ of the command.  I know

15     approximately, but I don't want to go into detail of what the police need

16     to do.  In any case, it has -- the police have to follow the orders of

17     the commander and investigate the case.

18        Q.   Thank you.

19        A.   I apologise.  If the report has already reached the prosecutor's

20     office, the prosecutor will be in charge -- in charge of the

21     investigation process.

22        Q.   Thank you.  You were shown a telegram by Colonel Masal, and you

23     saw how he interpreted the verbal words of General Mladic.  Every ethnic

24     community over there has some derogatory terms.  How were we referred to

25     by Muslims?

Page 31463

 1        A.   We are referred to as "vlasi."

 2        Q.   Thank you.

 3        A.   There are many such terms which are customary, but they do not

 4     reflect the gist.  It all depends on the objective which people want to

 5     achieve.  In our documents issued by the organ for moral guidance, there

 6     are also elements of propaganda based on the truth.  In other words,

 7     there are very few instances -- or, rather, it is not very realistic.  It

 8     is somewhat coloured.

 9        Q.   Are all Croats Ustasha for us or some are not?

10        A.   No.  The Ustasha are only those who were soldiers in the

11     Independent State of Croatia, i.e., in the state which was based and

12     which arose from the traditions of the Independent State of Croatia.

13        Q.   Thank you.  When it comes to the Turks, Skender Kulenovic, Mesa

14     Selimovic, Osman Karabegovic, are they Turks?

15        A.   No.

16        Q.   Who are Turks in colloquial terms?

17        A.   In colloquial terms --

18        Q.   Does this refer to civilians or soldiers?

19        A.   It refers to soldiers.

20        Q.   Is there another even worse derogatory term which is used for

21     Muslim civilians and soldiers?

22        A.   I believe that you're referring to the term "balija."

23        Q.   Thank you.  One more question.  I believe that some of the

24     confusion arose with regard to the question as to whether the aerial bomb

25     was launched from the ground or from the lorry.  Did you make a

Page 31464

 1     distinction when you said that you didn't know whether it was from the

 2     ground or from the lorry?

 3        A.   I did not see where it was launched from and how.  I never saw

 4     that launch.  Therefore, I don't know where the launch is mounted,

 5     whether it is mounted on a lorry, on a platform, on the ground.  In any

 6     case, it is not mounted on an aircraft.

 7        Q.   Thank you.  Colonel, sir, this is all I wanted to ask you.

 8        A.   Mr. Presiding Judge, may I say something?

 9             JUDGE KWON:  About what, Mr. Dragicevic?

10             THE WITNESS: [Interpretation] Well, first of all, I would like to

11     thank you for having intervened yesterday about the event in Gojcevic

12     village.  However, last night I had problems because I believe that it

13     was not completely elucidated.  Those were people who originated from

14     that village and who left for Croatia before 1991 and since there was a

15     census, they declared themselves as people who hailed from that village,

16     but it is only certain that they left before 1991.  In other words, the

17     information about the number of people does not apply to the village of

18     Gojcevic who lived there in 1993 and in 1994.

19             And let me tell you that no single house was torched.  There was

20     no need to torch any houses over there.

21                           [Trial Chamber confers]

22             JUDGE KWON:  Mr. Nicholls, would you like to pose further

23     questions with respect to comments he made right now?

24             MR. NICHOLLS:  No, Your Honour.  Thank you.

25             JUDGE KWON:  Thank you.  Then that concludes your evidence,

Page 31465

 1     Mr. Dragicevic on behalf of the Chamber I thank you for coming to The

 2     Hague to give it.  Now you're free to go.

 3             THE WITNESS: [Interpretation] Thank you.

 4                           [The witness withdrew]

 5             THE ACCUSED:  If I may, Excellencies, just while witness is

 6     outside, that is wrong with those censuses from Croatia.  It says that

 7     inhabitants of Croatia originating from Bosnia.  [Interpretation] I could

 8     have stated that in Serbian as well.  The fact is that this creates

 9     confusion.  There are original documents, there are original census

10     documents in Bosnia, as well.

11             JUDGE KWON:  Very well.  You can use that later on.

12             Before -- yes.  We'll bring in the next witness.  In the

13     meantime, I was informed by the Registry that the translation of

14     Exhibit D2634 MFI has been uploaded, so I note that that would be

15     admitted in full.

16             The next witness is Mrs. Andjelkovic Lukic?

17             MR. ROBINSON:  That's correct, Mr. President.

18             JUDGE KWON:  And Mr. Karadzic, you will lead live this expert

19     witness.

20             MR. ROBINSON:  That's correct.

21                           [Trial Chamber and Registrar confer]

22             JUDGE KWON:  He was supposed to -- I was told that he was

23     supposed to arrive at the Tribunal at quarter to 10.00.  We will rise and

24     then as soon as he arrives, if we could be informed accordingly.

25             We'll rise.

Page 31466

 1                           --- Break taken at 9.15 a.m.

 2                           --- Upon commencing at 9.46 a.m.

 3                           [The witness entered court]

 4             JUDGE KWON:  Would the witness take the solemn declaration.

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

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

 7             JUDGE KWON:  Thank you, Dr. Andjelkovic Lukic.  Please be seated

 8     and make yourself comfortable.

 9                           WITNESS:  MIRJANA ANDJELKOVIC LUKIC

10                           [Witness answered through interpreter]

11             JUDGE KWON:  Mr. Karadzic, for the purpose of scheduling, you

12     will take about an hour for your examination-in-chief?

13             THE ACCUSED: [Interpretation] I believe that I won't take more

14     than that.

15             JUDGE KWON:  Then we'll have a break after the -- your

16     examination-in-chief is over, and then we'll have the -- we'll hear the

17     cross after the break.

18             Yes.  Please proceed, Mr. Karadzic.

19             THE ACCUSED: [Interpretation] Thank you, Excellency.

20                           Examination by Mr. Karadzic:

21        Q.   [Interpretation] Good morning, Dr. Andjelkovic Lukic.

22        A.   Good morning.

23        Q.   Did you provide us with a copy of your CV?

24        A.   Yes.

25             THE ACCUSED: [Interpretation] Could we please have 1D21079 in

Page 31467

 1     e-court.  Could we have the English version as well, please.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Could you please briefly present your CV to us.  First of all,

 4     tell us what your education is and what your profession is based on that

 5     training, what your doctorate was, what kind of work you did.

 6        A.   I have a degree in technology and engineering.  I graduated in

 7     Belgrade.

 8             THE INTERPRETER:  Interpreter's note:  The witness will have to

 9     speak slower.

10             JUDGE KWON:  Doctor, since your testimony is to be translated, if

11     you could slow down a bit more and put a pause between the question and

12     answer, and could you kindly repeat your answer, Doctor.

13             THE WITNESS: [Interpretation] This is the way it is:  I graduated

14     from high school, and then I graduated from the University of Belgrade.

15     It was the Faculty of Technology and Metallurgy, and I got my Masters

16     Degree at the department of organic chemistry, and I got my doctorate in

17     the field of explosives.  I worked at the military technical institute

18     from 1974 until 1989.  That's when I got my Masters Degree.  And then

19     from the Military Technical Institute I went to work in another research

20     institute.  In the military technical institute I was involved in

21     studying new explosives and new technologies, the processing of

22     explosives, then their elaboration into weaponry and explosives, TNT, and

23     studying their characteristics.  So this was research based on knowledge

24     about explosives.

25             Then I went in 1989 to work up until 2000 when I retired in the

Page 31468

 1     technical experimental centre.  Over there I worked on the verification

 2     and testing of various weapons containing explosives.  At the technical

 3     experimental centre I received my doctorate.  For many years I was a

 4     member of the scientific council and I continued my research work.  I

 5     wrote several monographs in the field of explosives, and also quite a few

 6     professional publications that I presented in my CV.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   I believe that it doesn't say here in line 4 that this scientific

 9     council was also the scientific and teaching council.  Can you tell us

10     what the difference is?

11        A.   Well, it's not a technical and teaching -- or, rather, it is not

12     research and teaching.  If it were the VMA, which is also a teaching

13     institution, that would have been different, but I was member of the

14     scientific council of the centre and before that also at the VTI.

15        Q.   Thank you.  What did this have to do with practical questions of

16     applying your knowledge concerning weapons?  How was this used in the

17     Yugoslav Army?

18        A.   Members of the scientific council were - how shall I put this? -

19     eminent scholars from these institutions, and for the most part they

20     based their work on the development of new scientific methods and also

21     developed various resources.  Also, they were mentors for people who were

22     getting their masters and doctoral degrees.

23        Q.   Thank you.  This component experimental, did that have any kind

24     of concrete -- concrete effect on the Army of Yugoslavia?

25        A.   This experimental or testing institute was a pre-eminent

Page 31469

 1     institution for testing weapons.  All new equipment that was supposed to

 2     be commissioned in the JNA had to go through this channel.  Not a single

 3     piece of equipment could be used in the JNA unless it had been seriously

 4     and extensively tested at the Technical Testing Centre.

 5             Now, what does this involve?  Technical documentation,

 6     construction documentation, all standards that have to do with each and

 7     every detail.

 8        Q.   Doctor, could I just ask you, please, to speak a bit slower,

 9     because we would really like to have each and every word of yours

10     recorded in this transcript.

11        A.   I do apologise.

12        Q.   So what was done finally?  You say that no piece of equipment

13     could be -- well, what did this imply?

14        A.   Once a piece of equipment is tested very extensively, then a

15     special licence is issued -- or, rather, a special document introducing

16     this piece of equipment into the weaponry of the JNA at the time.

17     Without this kind of extensive testing for all components of each and

18     every piece of equipment, no piece of equipment could have been included

19     in the JNA weaponry; that is to say, the weapons they had available to

20     them, if I can put it that way.

21        Q.   Thank you.  How was this reflected on the possibility of

22     manufacturing this?

23        A.   As far as manufacturing is concerned, there was the military

24     industry, product specific as it was called.  It was highly developed in

25     the then SFRY.  It had units that co-operated with the military technical

Page 31470

 1     institute and -- and they co-operated with the military technical

 2     institute and developed certain assets regardless of whether it's

 3     ammunition or vehicles.

 4             Then before they would test a particular piece at the Technical

 5     Testing Centre, they had their own facilities where they would test a

 6     particular piece of equipment, and once they had done that, then it would

 7     be brought to the centre where preliminary testing would be conducted,

 8     and then it would be checked.  If everything was all right, then it could

 9     be studied in its final stage.  So this was a rather serious procedure.

10        Q.   Thank you.  What was the international reputation of the Yugoslav

11     military industry at the time?

12        A.   The military industry of the SFRY was among the best in the

13     world.  It was a renowned institution, and I think that it ranked fifth

14     among weapon exporters in the world, especially artillery, ammunition,

15     vehicles, tanks, the M-84 tank, for instance, that was the crown, if you

16     will, of the then military industry of the SFRY.  So it enjoyed quite a

17     reputation both in Europe and beyond.

18        Q.   Thank you, Dr. Andjelkovic Lukic.

19             THE ACCUSED: [Interpretation] Your Excellencies, may I tender

20     this CV?  Can it be admitted.

21             MR. GAYNOR:  No objection.

22             JUDGE KWON:  Yes.

23             THE REGISTRAR:  It shall be assigned Exhibit D2661.

24             THE ACCUSED: [Interpretation] Thank you.

25             MR. KARADZIC: [Interpretation]

Page 31471

 1        Q.   Dr. Andjelkovic Lukic, can you tell us what the Defence team

 2     asked you to do for the Defence, what kind of research?

 3        A.   The Defence team asked me a while ago to carry out, of course in

 4     co-operation with my colleagues, a review and analysis of two reports of

 5     my colleague Berko Zecevic that pertained to the use of bombs in urban

 6     areas in Sarajevo.  One of these reports is from 1995, and the other one

 7     is from 2007.

 8        Q.   Thank you.

 9             THE ACCUSED: [Interpretation] Can we please call up 1D6820 in

10     e-court.

11             MR. KARADZIC: [Interpretation]

12        Q.   Is this your report Dr. Andjelkovic Lukic?

13        A.   Yes.

14        Q.   Was anything redacted here?  All right.  Sorry.  Sorry.  We did

15     that.  Actually, we redacted things that were not contained in the

16     indictment against me because they were unnecessary.  However, the

17     indictment was amended several times, and that's why all of this

18     happened.

19             Can I ask you whether it is correct that Mr. Zecevic, in his

20     findings, presented the following thesis:  That classical explosive

21     charges of air-bombs that the JNA and the Army of Republika Srpska had

22     and that were Yugoslav made, that these classical charges were replaced

23     by the so-called RAE explosive, and could you tell us in simple terms

24     what this report of his contained, the one that is being challenged by

25     the Defence, and then I will put some specific questions regarding these

Page 31472

 1     differences.

 2        A.   The thesis of my colleague Zecevic was that air-bombs were used.

 3     I'm sorry, I seem to have lost the thread.

 4        Q.   How were they manufactured, these bombs, or, rather, how were

 5     these explosive charges changed?

 6        A.   Ah, all right.  First of all, as far as air-bombs were concerned,

 7     those that already existed in the weaponry of the JNA, TNT was used as a

 8     charge, and that is how they were manufactured, filled with TNT.  It was

 9     physically impossible to replace this TNT and to put air explosives in

10     there quite simply because these casings of air-bombs are much thicker

11     than the casings of containers that contain air explosives.  So it is

12     quite impossible that warheads could be an aerosol explosive.

13        Q.   We'll get to that.  I just wanted to ask you something.  What was

14     supposed to be done to a bomb, what was supposed to be modified on the

15     bomb, on the warhead itself, in order to replace this?

16        A.   Well, the assumption is -- the assumption is, but it is highly

17     unlikely, to get the explosive out, to melt it, if you will, and then

18     when this warhead or casing is cleaned in this way, if you will, then you

19     put ethylene oxide inside.  That's the aerosol explosive that is most

20     often referred to.  And then in the middle a cylinder called charge

21     should be put in with classical explosives, say 10 to 15 per cent of the

22     mass of the overall explosive.  And then there would be a detonation of

23     this middle charge which would open the warhead, and then this aerosol

24     would be released.  And that is absolutely impossible in the case of

25     casings of warheads of air-bombs because they are so thick.

Page 31473

 1        Q.   Did I see a sketch somewhere in your report of what you described

 2     to us just now, and can you help me with that?

 3        A.   Can I get my paper out of my bag now, please?

 4        Q.   I hope that the Chamber will --

 5             THE ACCUSED: [Interpretation] May I?

 6             JUDGE KWON:  By all means, Doctor.

 7             THE WITNESS: [Interpretation] Thank you.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Could you please assist the Registry and tell us the page where

10     that can be found.

11             THE ACCUSED: [Interpretation] I apologise to the interpreters.

12             THE WITNESS: [Interpretation] It is an image, image 29.  Image

13     29.  In my report it is on page 57, and in Mr. Zecevic's report it is --

14     do I have to provide you with that page as well or is it enough if you

15     have my page?  But I think that the -- there is a discrepancy of one or

16     two pages in respect of my report.  In any case, it's image 29.

17             THE ACCUSED: [Interpretation] Can we have that image on the

18     screen.

19             THE WITNESS: [Interpretation] Well, now, what was your question?

20             MR. KARADZIC: [Interpretation]

21        Q.   My question was this:  Here we can see a charge.  What charge is

22     that?

23        A.   The -- based on the particles that were found belonging to an

24     air-bomb, Mr. Zecevic here drew an image of a rocket projectile with a

25     warhead, and he assumes that the charge was aerosol explosive.  The

Page 31474

 1     warhead depicted in this way is a warhead which corresponds to the casing

 2     of an air-bomb.  So this cannot be a container filled with liquid

 3     explosive because there is a thickening at the top, as you can see.

 4     There is a thickening at the bottom, and on average the thickness of a

 5     casing in bombs is about 10 millimetres in the narrowest part and then

 6     towards the top this increases by two or even by three times.  I don't

 7     know much about that but I know that the increase in the thickness is

 8     significant at the top as well as at the bottom.

 9             In the middle what you see as a darker part is a classical

10     explosive charge.  What is the function of that classical explosive?  The

11     function is as follows:  The middle part of the classical explosive at

12     any given moment when a bomb comes to -- to a certain distance, there's a

13     special way of functioning of that bomb.  It does not function as an

14     aircraft bomb that is thrown and detonated.  This is a bomb which has

15     special demands in terms of altitude.  It has certain measuring devices

16     which determine the height and the distance of the bomb from the ground

17     which is 5 to 10 metres depending on the target.

18             And then the inner part explodes, that inner part, and the

19     explosion is aimed at breaking up the container which contains the

20     aerosol explosives.  And when that container is broken, then the aerosol

21     explosive which is liquid at 0 degrees centigrade and at 20 degrees is a

22     gas, that becomes a cloud, and then there's a special detonator which

23     initiates the explosion, enters the cloud and it initiates the explosion.

24     The size of that cloud is about 20 to -- 15 to 20 metres in diametre.

25     The pressure in that cloud according to literature is about 20 to 30

Page 31475

 1     bars, and I calculated based on the speed of the detonation of 1500 to 20

 2     or even 3000 metres in a second.  My calculations say that the pressure

 3     in that cloud is between 5 and 20 bars.  I have to say here that

 4     according to literature, referring to explosives and their action, and

 5     which is something that I learned in my profession, and I noticed it very

 6     well, are not always in correlation with the experiment.  They are always

 7     higher.  I really don't know why.

 8             THE INTERPRETER:  Could the witness please be asked to slow down.

 9             THE WITNESS: [Interpretation] I know when I dealt with my

10     explosives and when I examined the speed of detonation, when I had all

11     the conditions that were present in literature --

12             THE INTERPRETER:  Kindly slow down.  The witness is speaking very

13     fast.

14             THE WITNESS: [Interpretation] -- the speed of detonation, so I

15     believe --

16             JUDGE KWON:  Could you slow down again.  It's very difficult for

17     the interpreters to keep up with you, in particular we are dealing with

18     such expert matters.  Shall we --

19             THE WITNESS: [Interpretation] I apologise.  I apologise again.

20             JUDGE KWON:  Could you repeat your --

21             THE INTERPRETER:  The interpreter's note:  We did not miss

22     anything, but we kindly ask the witness to slow down.

23             JUDGE KWON:  So could you start again from the speed of

24     detonation.

25             THE WITNESS: [Interpretation] Very well.  I'll try and slow down.

Page 31476

 1     When that cloud spreads, a special initiator of the explosion enters the

 2     cloud and initiates the explosion in the cloud, which means what we get

 3     is an explosive cloud.  The speed of detonation of that cloud, i.e., the

 4     speed by which the chemical reaction spreads through that cloud is

 5     between 1500 and 3000 metres per second, and the pressure of the

 6     detonation is between 20 to 30 bars.  However, when I calculated based on

 7     the thickness of the ethylene oxide which was 89 at 20 degrees, and based

 8     on the speed of the detonation according to literature, I obtained a

 9     pressure of detonation ranging between 5 and 20 bars, i.e., the median

10     pressure of 11 bars.

11             I must intervene at this point, and I must say that what we find

12     in literature is never in correlation with what we obtain in experimental

13     situations, and I know that very well from my own experience.

14             MR. KARADZIC: [Interpretation]

15        Q.   Thank you.  First of all, I would like to ask you this:  How

16     would it be possible to empty the casing from TNT and replace the content

17     by partially hard and partially liquid explosives as is represented in

18     here?

19        A.   Yes.  Air-bombs contain liquid trotyl.  That trotyl melts at 82

20     degrees.  Thus melted, it can be transported into the casing of a warhead

21     and then its manufacture is finished.  In order to pour out, i.e., to

22     melt that trotyl from the warhead which weighs between 100 and 250

23     kilogrammes and which contains between 39 to 105 melted trotyl, requires

24     a lot of work and effort.  That warhead has to be lifted to an elevated

25     position, the lower part has to be unscrewed, and water steam which has

Page 31477

 1     to be heated up to 90 degrees centigrade, the trotyl has to be melted

 2     layer by layer.  It has to be collected in a container and then it has to

 3     be removed.  It is a very painstaking job which doesn't pay at the end.

 4     It is pointless at the end of the day.  And then those empty casings are

 5     filled with containers with aerosol explosives.  Again, this doesn't make

 6     too much sense because I've just told you -- I've just explained to you

 7     the techniques of the casing of an air-bomb in -- on average -- on

 8     average is about 10 millimetres, which means that in -- that the central

 9     charge which is in the middle of liquid explosive would not have enough

10     power and strength to break up that casing in the first place, because

11     the container in which liquid explosive is placed, its thickness is about

12     2 to 3 millimetres, and that's a big difference in terms of the casing of

13     the warhead.

14        Q.   Thank you.  You mentioned a certain height.  What did you mean

15     when you say that at a certain height this aerosol bomb will explode?

16     How does that reflect on the point of contact with the soil?

17        A.   Aerosol bombs are primarily constructed to make passages through

18     jungles, for example.  When the Americans first arrived in Vietnam and

19     Cambodia, they did that.  The principle of action of this air-bomb is as

20     follows:  An aircraft drops an aircraft bomb at a certain level or a

21     certain height.  A parachute opens.  Those are such manipulations to

22     allow the aircraft to get away from the bomb as quickly as possible.  A

23     parachute thus opens, and at the same time the altitude metre switches

24     itself on, and after a certain time that determines at which height or at

25     which level the central charge will be detonated.  That bomb usually

Page 31478

 1     comes 5 to 10 metres away from the target, and it all depends on what the

 2     target is, whether it s a bunker or making a road through a minefield and

 3     so on and so forth.

 4             When that bomb opens after the central charge explodes and when

 5     the container opens and bigger fragments of tin start falling out, then

 6     from special places on the warhead which sometimes can be a tail fin near

 7     the parachute, the fuses ignite a fire in the cloud, and that cloud falls

 8     onto the ground and with its pressure it prompts certain actions.

 9             This is primarily made to destroy personnel, to destroy bunkers,

10     and that bomb is made in such a way to leave larger facilities intact,

11     but at the same time it destroys the enemy forces in the pockets around

12     those facilities such as bunkers and trenches and so on and so forth.

13             There is no way to save yourselves from that cloud.  When it

14     falls on the ground, all the living beings are damaged by that cloud.

15     They can suffer major injuries from that cloud, which means that its

16     lethal properties are active in three-quarters of its diametre.  Usually

17     the casualties are affected by the blast effect.  The temperatures are

18     high, up to 3.000 degrees centigrade, and injuries consist of burns and

19     similar injuries.  And if the impact area is near a building, you can see

20     charred windows and doors.  Unfortunately, I had an opportunity to be an

21     expert witness for explosions from methane which is also an aerosol that

22     is used as a charge for such bombs.

23        Q.   Thank you.  Before we deal with the effects, I wanted to ask you

24     whether the ratio between the charge and the thickness of the casing,

25     does it also influence the fragmentation of the casing?

Page 31479

 1        A.   Of course.  One always has to be borne -- take into account that

 2     there is about 30 to 40 per cent of the explosive with respect to the

 3     weight of the casing.  In aircraft bombs the situation is the same.  For

 4     example, when the weight is 100 kilogrammes, there is 39 kilogrammes of

 5     explosive.  So the ratio is some -- between 30 to 40 per cent.

 6             I get carried away.  30 or 40 per cent of explosive with respect

 7     to the weight of the casing.  What happens with the destructive bombs?

 8     When the secondary explosive explodes in the casing, i.e., when trotyl

 9     explosive explodes, the casing is fragmented due to the chemical reaction

10     which happens in the explosive when it is initiated.  That means that the

11     explosive is initiated when it receives a heat impulse from the primary

12     explosive, from the propellant.  A very quick chemical reaction develops.

13     It advances through the explosive and releases a high quantity of warmth,

14     and warm, hot gases are developed under pressure.  They destroy the metal

15     body, and they have a destructive effect when -- and that casing also has

16     a lethal effect due its fragments.

17        Q.   Thank you.  Can you help us with this:  It seems to me on the

18     basis of your remarks so far that the explosion of liquid explosives

19     happens only after fragmentation -- or, rather, the breaking of the

20     container.  Does the liquid explosive take part in fragmentation or does

21     this happen after -- after, you know, what you said, when the liquid gas

22     got out?

23        A.   Yes, the basic difference in terms of how these classical

24     explosives function and these liquid explosives is as follows:  Trotyl,

25     now I'm speaking about that, has sufficient energy in it, its molecules

Page 31480

 1     have sufficient energy, so it can react on land, in air.  It doesn't need

 2     oxygen.  It reacts within the casing and fragments the casing.  This

 3     air-bomb consists of compounds that have one or two atoms of oxygen,

 4     C2H4O specifically in this case, that's the structural formula.  It

 5     doesn't have enough oxygen; therefore, it cannot burn.

 6             When the container is opened, I mean as far as fuel-air

 7     explosives are concerned, the role of the casing is not the same as in

 8     cases of classical bombs, that is to say including fragmentation.  Here

 9     the casing is used only as clothing, if you will, for liquid explosive,

10     and then when it is opened, then this liquid explosive has to be

11     triggered off in some way in order to take oxygen from the air and then

12     start burning.  So that's the difference.  Solid explosives do not need

13     oxygen.  This is an adiabatic process, but the case of liquid explosives,

14     that is not the case.  There has to be oxygen for it to react.  Those are

15     the basic differences.

16        Q.   Let me help the interpreters.  And you can help, too.  Adiabatic,

17     line 5, would you translate it that way?

18             THE INTERPRETER:  Interpreters note:  That's what we said.

19             THE WITNESS: [Interpretation] Yes.  That is a situation when

20     there is no exchange of energy with the environment.  The change occurs

21     within the body itself without the participation of the external

22     environment.  That is an adiabatic process.

23             MR. KARADZIC: [Interpretation]

24        Q.   Thank you.  Can you tell us what happens if the quantity of

25     explosive that is supposed to fragment a casing is smaller than

Page 31481

 1     necessary?

 2        A.   This container with the liquid explosive; right?  Well, nothing

 3     can happen.  I mean, well, if it is less than what is prescribed, there

 4     cannot be fragmentation.  There's simply not enough strength.

 5        Q.   Thank you.  Did you come across any information to the effect

 6     that the Army of Republika Srpska was technically and technologically

 7     capable of replacing these two explosives, replacing TNT with this liquid

 8     explosive?

 9        A.   Something like that did exist in the SFRY, in the JNA, only in

10     one particular overall institution.  It was an institute in Tivat.  It

11     was called Sava Kovacevic, and nowhere else.  Otherwise, it would have

12     been very, very risky to embark on any such thing.  They had all the

13     necessary technical equipment for doing something like that.  Otherwise,

14     I did not know of any capability of the army of the Republika Srpska to

15     do something like that.  That is a very painstaking job, and ultimately

16     it is unnecessary.

17        Q.   Thank you.  When you said that it doesn't really pay off, what

18     did you mean?

19        A.   I meant energy consumption.  Also, if there is a proper piece of

20     ammunition, why would one make something different with a very uncertain

21     outcome?  I mean, what would be the point of all of that?  I don't see

22     the actual point of something like that.

23        Q.   Thank you.  In Yugoslavia, either the SFRY or in the

24     Federal Republic of Yugoslavia were air-bombs fully researched, and were

25     they ever introduced as a standard weapon of the JNA or, rather, the VJ?

Page 31482

 1     Aerosol, I mean.  Oh, it said here air-bomb, whereas I said aerosol.

 2        A.   Since I spent my entire career working with explosives and during

 3     the second part of my career I also tested quality, I can say with a high

 4     degree of responsibility that something like that never reached my desk.

 5     Why?  At the Technical Testing Centre I was the only expert for

 6     explosives.  As I said a moment ago, in order for a piece of equipment to

 7     be admitted into the JNA, it had to go through all the necessary testing

 8     starting with documentation, construction and technical documentation.

 9     That is to see how the piece was constructed, what the standards involved

10     were.  Each and every expert had their own fields.  I covered the field

11     of explosives.  So everything that had to do with explosives had to reach

12     my desk.  It could go no further until I initialed it.  During my career

13     until the year 2000, I did not receive any such thing at my desk, and I

14     can say with full responsibility that something like that did not exist

15     in the weaponry of the JNA.

16        Q.   Thank you.  In line 18 did you say that you were the only expert?

17        A.   Yes, I said I was the only expert.

18        Q.   Thank you.  Can you tell us what the consequences would be shown

19     by a pathology or postmortem on a living creature who would fall victim

20     to one of these explosives and if you would compare that to someone who

21     would be a victim of another explosive rather than the one we're talking

22     about?

23        A.   I'm a layperson, but I think I can describe that.  Destructive

24     bombs, lethal weapons with thick casings, have a lethal -- or, rather, a

25     destructive effect and are lethal as far as personnel are concerned.

Page 31483

 1     That is shrapnel, different open wounds and so on.  Everything that can

 2     be assumed what can happen to a human being when hit by a metal object

 3     that is moving at such high speed.

 4             On the other hand, as far as aerosol explosives are concerned, or

 5     fuel-air explosives, primarily they have a blast effect on human beings

 6     more than is the case in the former.  So there are injuries sustained by

 7     internal organs, the brain, ears, lungs, heart.  The lungs and heart can

 8     stop altogether.  Air can penetrate veins and so on.  So wounds from

 9     fuel-air explosives are usually due to a blast effect.

10             Also, there can be burns, because this cloud is very hot, 2000 to

11     3000 degrees.  So in my view, one of the dominant effects of this cloud

12     are actually burns, and I had occasion to see that when I was an expert

13     witness with regards to such explosives.

14        Q.   Doctor, thank you.  Can we just explain this, transcript page 22,

15     line 11.  It says that you're a layperson.  What is it that you're a

16     layperson for?

17        A.   Layperson as far as wounds are concerned.  I'm not a physician.

18     So when I talk about wounds, injuries, I am saying that as a layperson.

19     I'm not a doctor.  I'm not a physician.  That's how I meant that.

20        Q.   Secondly, you mentioned eyes and the transcript does not reflect

21     eyes.  What happens with eyes in case of these two explosives?

22        A.   As far as these classical explosives are concerned, the wounds

23     are as if they were inflicted by a bullet, let me put it that way.  And

24     as far as these liquid explosives are concerned, these wounds are due to

25     pressure.  That is to say that there is pressure.  The eyes can fall out

Page 31484

 1     of the sockets.  Then there can be -- then lungs can also be injured.  I

 2     mean, all of these are the effects of the blast effect.  Because the

 3     pressure in that cloud is -- well, 50 to 20 bar, and literature says 20

 4     to 30 bar, but I just did the calculation now.  All right.  This

 5     pressure, when compared to the pressure when a -- when classical

 6     ammunition explodes, classical TNT explosives, it's much less.  When

 7     trotyl explodes, it is 200 kilobar.  Imagine 200 times 10 to the third.

 8     So the pressure of fuel-air explosives is up to 20 bar.  But this goes on

 9     a bit longer, this pressure, a few milliseconds.  When compared to the

10     pressure from classical explosives, that is much shorter.  And that is

11     what I have to say about the blast effect of these fuel-air explosives.

12     Perhaps it's more pronounced than as far as classical explosives are

13     concerned, although it does exist there as well but if they are closer to

14     the centre of explosion.

15        Q.   Thank you.  How do these explosives behave in relation to

16     physical solid obstacles or, rather, shelters, if a human being, a living

17     creature were to be behind something like that?

18        A.   The diametre of their clouds is from 17 to 20 metres.  My

19     colleague mentions the diametre of even 30 metres.  There is no shelter

20     there for human beings, none whatsoever.  Why?  Because this explosive --

21     this explosive cloud, this cloud that exploded if I can put it that way,

22     penetrates everywhere.  If in one area there is a cloud and if it

23     detonates, then no one can be saved from that.  You cannot stand behind a

24     pillar, for instance, because it sinks everything like a fluid or liquid

25     does, whereas in the case of classical explosives, a shelter can be found

Page 31485

 1     from the blast.  You can stand behind a pillar, behind some kind of

 2     concrete shelter, and then the blast can just pass -- or, rather, bypass

 3     that obstacle.  And then if a man is sheltered or is hiding there can

 4     remain unharmed.  Things like that have happened.  That's the difference

 5     between the two blast effects.

 6        Q.   Thank you.  Did you have an opportunity of seeing for yourself

 7     and recording any kind of pathology findings or postmortems or

 8     descriptions of a site where such an explosion took place involving high

 9     temperatures, what the effects were on the environment and also were

10     there pathology findings for human beings or other living creatures that

11     would confirm that this fuel-air explosive had been used in Sarajevo?

12        A.   First of all, I would like to start by dealing with physical

13     remains of an explosion.  The primary thing is when a container with

14     fuel-air explosive explodes, large parts of the metal casing are

15     separated, 300 by 400 millimetres.  That is to say it's like pieces of

16     tin that would be on site.  That was not found anywhere.  This was not

17     even reviewed theoretically in the reports that I looked at, the

18     fragmentation of a casing with fuel-air explosive.  Nowhere in these

19     materials did I observe that in addition to destruction effects were

20     shown of burning, combustion.  These are dominant effects in addition to

21     destruction, in addition to the blast effect.  There's also burning.  I

22     didn't see that anywhere.

23             As far as these post-mortems are concerned, I did not have an

24     opportunity of seeing that anywhere.  I didn't see any burns, any cases

25     of burns.  I saw two or three cases.  I didn't see more.  But there was

Page 31486

 1     no reference to any person who had been wounded or killed had suffered

 2     burns, and that would have to happen if there was a burning cloud, if I

 3     can put it in such picturesque terms.  That is what this explosion is

 4     called when that kind of explosive explodes.

 5        Q.   Thank you, Doctor.  Did you correct anything, or did you amend

 6     your basic findings?

 7        A.   Yes, I did.  I added something.  I sent that addition to you.

 8             THE ACCUSED: [Interpretation] I like to call up 1D6816 in

 9     e-court.  And I will tender both documents after we have finished with

10     them.  1D6816.

11             THE WITNESS: [Interpretation] Yes.  I have that.  It has three

12     pages, and I have them all.

13             MR. KARADZIC: [Interpretation]

14        Q.   Can this errata be replaced by the word "addendum"?  The title is

15     "Errata."  Did you correct anything or did you add anything?

16        A.   In my copy the title is an addition to the expert analysis.  I

17     don't know how this was admitted.

18        Q.   It was translated as "errata."

19        A.   Well, that's okay.  I have no objection to that.

20        Q.   Can you tell us briefly what your addition was?

21        A.   You can see in figure 1 that my colleague in his report that he

22     drafted in 2007, on page --

23        Q.   Which colleague is that?

24        A.   Mr. Berko Zecevic, my colleague who drafted a report in 2007, on

25     page 06067086 showed a photo in his report - it's image 99, and in my

Page 31487

 1     addendum it's image 1 - and he described the differences, and he also had

 2     some footnotes about the remains of the propellant of the modified bomb

 3     FAB-250 found when the building in Dositejeva Street was targeted.  He

 4     doesn't mention the number of that building.

 5        Q.   In the same document.

 6             THE ACCUSED: [Interpretation] To help the participants in the

 7     proceedings, the reference is 1D6838, page 73 in e-court.  That's the

 8     reference for the expert's words, and that's the Serbian version.  And

 9     the doctor provided the ERN page.  Page 73 in the Serbian version,

10     1D6838.

11             MR. KARADZIC: [Interpretation]

12        Q.   I apologise, Doctor.  Please continue.  I just wanted the

13     participants to be able to follow you.

14        A.   Thank you.  The rocket engines in my figure 1 is something that

15     Berko Zecevic found in Dositejeva Street according to him.  Figure two

16     depicts the same object from a different angle and that was found in

17     Geteova 5 or Cetinjska 5 in Sarajevo.  On the following page of my

18     supplement figure 3 depicts the remains of the engine that was found in

19     Dositejeva Street number 4A.  What we see in figure 3 and in figure 1,

20     those things do not resemble each other at all.

21             In my expert report, what you see under figure 3 are the remains

22     of rocket engines in Dositejeva Street.  In -- this is what is found in

23     Berko Zecevic's report, and this is how the engines look when they're

24     separated, whereas in figure 1 he put them together, and they resemble --

25     not only do they resemble, but they are the same engines that are found

Page 31488

 1     in figure 2, and that is what exists in the 1995 report that concerns

 2     Geteova Street.

 3             Furthermore, on the following page is a figure from his document,

 4     figure 99, and you can see footnote 8, the remains of the propellant of

 5     the modified bomb found when a building in Dositejeva Street was

 6     targeted.

 7             And below that you can see the racketised [phoen] bomb, FAB-250.

 8     The photos were taken by the Dutch unit of the SFOR where you can see the

 9     warhead FAB-250, and my colleague Zecevic in his report expressly claimed

10     that it was charged with fuel-air explosive and not only FAB-250 but also

11     FAB-100 which you can see in my report here, and he says in his report

12     that it is a pity that one could not find a single bomb that could be

13     de-elaborated or deconstructed in order to identify the explosive within.

14             And in his reports -- in both of his reports, in several places

15     he shows the FAB-100 bomb which was found as an unexploded, and now the

16     FAB-250 bomb which also was not activated, and my question to my esteemed

17     colleague Berko Zecevic is this:  How come the warheads of those rockets

18     that were found were not reconstructed in order to establish or to refute

19     the opinion that it contained fuel-air explosives?

20        Q.   Thank you.  When we talk about modified air-bombs, is something

21     really modified on the bomb itself?

22        A.   In this case that we considered here, the only thing that was

23     modified was the propellant.  The bomb was not thrown from an aircraft,

24     but, rather, something was mounted to that bomb, certain motors or

25     engines which propelled it to the place where it was supposed to explode,

Page 31489

 1     and that was the modification that was made.  Those modifications did not

 2     constitute the replacement of a solid explosive by fuel-air explosive.

 3     At least based on the findings that I analysed here.  I didn't find any

 4     such thing, nothing to that effect.

 5        Q.   Thank you.  On page 69, i.e., on Mr. Zecevic's report page, can

 6     you look at the words ODAB and KREMA in the right-hand side part of the

 7     photo.

 8        A.   Yes, I can see that.

 9        Q.   As 082.

10        A.   The previous page, please.  Is this it?

11        Q.   There is a comparison between the FAB-250 and ODAB-500 and in the

12     photo itself it says, "KREMA the rocket rear view"?

13        A.   You know what?  Despite my best intentions, despite all of my

14     efforts, as I was reading his report I could not understand what my

15     colleague, Berko Zecevic, understood when he used the term "KERMA."  I

16     understand the ODAB-500, it's a Russian air-bomb which is thrown from an

17     aircraft and just a while ago we saw its image, but when it comes to

18     KREMA I really could not understand what he was talking about.  I don't

19     know because that word does not ring a bell.  I don't know what he meant

20     when he used the term "KREMA."

21             There was a hint to the Russian-made bomb, the Russian KREMA.  I

22     really did not understand from his report what he was alluding to, and I

23     even put that as part of my report, that his explanation of KREMA really

24     didn't mean anything to me.

25        Q.   Just one word, Dr. Andjelkovic Lukic.  In his report, did

Page 31490

 1     Dr. Zecevic provide any evidence that fuel-air bombs were used during the

 2     war in Bosnia-Herzegovina?

 3        A.   Based on my research and examination of those two reports, I did

 4     not find anything that would have been typical of an explosion of

 5     fuel-air explosives.  In other words, in his reports, he did not describe

 6     even the fragments of such a destructive bomb.  He stated that there were

 7     no fragments, and based on that he concluded that all the bombs were

 8     fuel-air bombs.  My colleague Zecevic's claims that those were fuel-air

 9     bombs was based on the absence of fragments.  However, if the fuel-air

10     bombs had been used, one would have had to find at least a few larger

11     fragments of containers, because those are light particles whose speed is

12     not very high because the fuel-air explosive does not have such a high

13     speed in order to be able to propel those particles very far.  So the

14     particles of that container if fuel-air explosives had been used should

15     have had to have been found.  Absolutely they would have had to have been

16     found.

17             On the other hand, in the facilities where FAB destructive bombs

18     were used, in addition to the destruction effects which should not have

19     had been so large as I saw them, one would have also had to have noticed

20     some charred remains of wooden surfaces such as furniture and doors and

21     windows to show that there was flame, because flame is one of the

22     dominant features of fuel-air explosives.  I claim that with full

23     responsibility because I had occasions to see the effects of explosions

24     of natural gas in residential homes which has the same destructive effect

25     as fuel-air explosives.  So -- another thing, burns were not noticed on

Page 31491

 1     people who were injured.  No big tin particles were found, and they

 2     should have been.  And that is my conclusion.  Based on those very

 3     significant pieces of evidence, I can say that fuel-air bombs were not

 4     used in Sarajevo.  And he confirms that himself in a written form in one

 5     part of his written report.

 6             JUDGE KWON:  Just for the record, where do we see the word

 7     "KREMA" in Mr. Zecevic's report?

 8             THE ACCUSED: [Interpretation] Your Excellencies, on the left side

 9     of the screen, the bottom right photo it says on the photo itself,

10     "KREMA-4, rocket rear view."

11             JUDGE KWON:  Thank you.

12             MR. KARADZIC: [Interpretation]

13        Q.   One more question, madam.  We see the term ODAB-500 here.  What

14     is the weight of that Russian-made air-bomb?

15        A.   They weigh over 500 kilos, and together with -- actually, their

16     mass is 520 kilogrammes, and the charge weighs about 200 kilos of

17     fuel-air explosive.  The thickness of their casing is up to 3

18     millimetres.  The casings are thin.  Therefore, they are thrown from an

19     aircraft.  They have a parachute, and they have everything that I already

20     described, altitude metre, the secondary fuse that are activated within

21     the cloud and detonate it.  But they are much bigger, of a bigger size,

22     and they are much, much more destructive and lethal.  That asset is

23     rather lethal.

24        Q.   That weight, would it require a somewhat different propellant if

25     it was not thrown from an aircraft but, rather, launched from a launcher?

Page 31492

 1        A.   I never reflected on that.  Its weight is much too big to be

 2     launched from a launcher.  Under bullet point 9, Mr. Zecevic in one place

 3     says that its weight without fuel is 706 kilogrammes, and in another

 4     place it says that ODAB-500 weighs about 250 kilos.  You see, he

 5     frequently changes the characteristics of that bomb.  At places it's 706

 6     without fuel and in other places 520.

 7             However, be it as it may, it's a very heavy bomb, and if you were

 8     to add engines or motors to it, it would weigh even more, and I don't

 9     know what kind of a launcher it should -- should it be to launch it.

10     Those would have to be very special launchers that would be able to carry

11     such a huge weight.

12             I believe that it could not be launched from the ground,

13     although -- well ...

14        Q.   Thank you, Dr. Andjelkovic Lukic.

15             THE ACCUSED: [Interpretation] Your Excellencies, may I tender the

16     redacted report, the redacted expert report by

17     Dr. Mirjana Andjelkovic Lukic which is 1D6820 here, as well as its

18     supplement which is 1D6816.

19             JUDGE KWON:  Mr. Gaynor.

20             MR. GAYNOR:  No objection, Mr. President.

21             JUDGE KWON:  Yes.  We will admit both.

22             THE REGISTRAR:  The report should be assigned Exhibit D2662, and

23     the corrigenda shall be assigned Exhibit D2663.  Thank you.

24             JUDGE KWON:  Thank you.  We will have a break for half an hour

25     and resume at 11.35.

Page 31493

 1                           --- Recess taken at 11.03 a.m.

 2                           --- On resuming at 11.35 a.m.

 3             JUDGE KWON:  Yes, Mr. Gaynor, please proceed.

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

 5                           Cross-examination by Mr. Gaynor:

 6        Q.   Good morning, Dr. Andjelkovic Lukic.

 7        A.   Good morning.

 8        Q.   Now, Dr. Andjelkovic Lukic, you told us earlier that you worked

 9     at the Technical Testing Centre from around 1989 until 2000 or was it

10     2002?

11        A.   Until 2000.  I was retired in 2000.

12        Q.   Your CV says 2002, but I'll take 2000.  So during those 11

13     years --

14        A.   Wait a minute.  Let me see.  Just a moment, I need to see.  Maybe

15     it was a slip.  Yes.  I'm sorry.  Until 2002.

16        Q.   Thank you.  Now, during those 13 years you were undoubtedly

17     involved in the testing of many different kinds of weapon systems and

18     many different kinds of munitions.

19        A.   Yes.

20        Q.   And in your evidence today, you -- as you put it, not a single

21     piece of equipment could be used in the JNA unless it had been seriously

22     and extensively tested at the Technical Testing Centre.

23        A.   That is correct, yes.

24        Q.   In your evidence earlier, you described some of the steps of the

25     testing process, and in your report you also refer to other steps.  You

Page 31494

 1     refer to prototype, you prefer to test production run, you refer to

 2     testing of batches for consistency.  Could you help me understand the

 3     process of testing of any new weapon system from the moment when an

 4     initial blueprint is produced until it is approved for service in the

 5     JNA.

 6        A.   Let me try to explain.  First of all, the time of development

 7     from the idea to develop this idea until it is developed takes seven to

 8     eight years.  That's an optimal amount of time during which you make all

 9     the documentation, test all the materials, and there are a lot of steps

10     in between until you make an initial sample that needs to be tested on

11     the testing ground of the factory itself.  They have such testing grounds

12     also, but they also use the grounds of the Technical Testing Centre if

13     they don't have their own for such an asset.  So the factory that

14     produces the asset registers them first as sample pieces.  That is

15     usually 10 to 20 samples.  It could be more if it's profitable for them,

16     but it's not often the case, because the production is very expensive and

17     you try to be as rational as possible.  Those are sample pieces on which

18     testing is done.

19             The testing is for efficiency and for their fitness to technical

20     requirements.  That means effect on the target, how it acts on the

21     target, it be an ammunition or another type of weapon.  Now I'm talking

22     about explosives.  Whether the explosive is well placed in the asset,

23     whether it gives good results in terms of penetration, et cetera.

24             When you finish the testing with sample pieces and the

25     documentations, because it's not only the asset itself, it's a huge

Page 31495

 1     amount of documentation documenting the construction.  For instance, if

 2     it's an artillery round or a bomb or a cumulative article with optimal

 3     penetrating force, all this has a complete documentation, and for every

 4     document in that set you have a standard.  If it's about steel, then what

 5     kind of steel.  If it's tested.  If it's an explosive, what type of

 6     explosive.  What its characteristics are, pyrotechnics of it,

 7     anti-corrosion protection, so all the elements that can affect the

 8     efficiency and the life of this asset.  All that is recorded in the

 9     technical documentation.  We even have a standard for paints.  It has to

10     be anti-corrosive.  It must not produce any effects when exposed to

11     light, et cetera.  It goes into the greatest detail.

12             Then later when you check all that, when the experts from the

13     Technical Testing Centre see that this construction and technical

14     documentation is all right, that the asset produced on the testing

15     ground, the effects that have been envisaged, then we can think about

16     multi-series -- sorry, zero series.  After the testing follows the zero

17     series, which means that the production has been mastered, the asset goes

18     to the factory and is definitively produced there.  After that, it goes

19     back for testing to the Technical Testing Centre so that if certain

20     shortcomings have been noticed on the sample pieces, and that usually

21     happens, we have to see whether these shortcomings have been redressed

22     and removed, and if that is the case, we proceed with the zero series and

23     make a final assessment.  It happens that an asset is rejected because it

24     is not good or it needs to be improved.  That means that it did not

25     produce the desired required effects.  However, usually it is approved,

Page 31496

 1     and when the zero series is approved, then it goes into production.  That

 2     is the usual lengthy process.

 3             THE ACCUSED: [Interpretation] Can I help with the transcript?  On

 4     this page 35, Dr. Andjelkovic Lukic said Pala series, and then she said

 5     that the time for development is five to seven years, whereas the record

 6     says seven to eight years.

 7             JUDGE KWON:  Doctor, do you confirm that?

 8             THE WITNESS: [Interpretation] Five to seven years, yes, yes.  It

 9     takes five to seven years.  That means a total number of seven years or a

10     total number of eight -- seven years.

11             THE ACCUSED: [Interpretation] "Pala series" should be "failed

12     series."

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

14     confirm the name of the first series.  We heard it as zero series.  We

15     don't understand the Pala series.

16             JUDGE KWON:  Will you take that up.

17             MR. GAYNOR:  Certainly.

18        Q.   Dr. Andjelkovic Lukic, you referred to in your evidence zero

19     series; is that correct?

20        A.   Yes.

21        Q.   Now, Dr. Andjelkovic Lukic, this entire process that you've

22     described, does that take place prior to a phase of test firing of the

23     weapon system in order to create firing tables?

24        A.   As far as the firing tables are concerned, I told you that I've

25     never done that.  I've never even come close.  The only thing I can tell

Page 31497

 1     you is that sample pieces precede the zero series.  The zero series is

 2     the one that confirms that the asset has met all the requirements,

 3     tactical and technical requirements, and also in terms of construction

 4     and technical documentation.  As for the rest, it is understood that all

 5     that is all right, and if you say firing tables, I have never dealt with

 6     that.  I am an expert in explosives.  I only looked at the effect on

 7     explosives in the asset in which it is placed, whether it functions in

 8     the way that I expected it to from the construction documentation.

 9        Q.   Now during your service at the JNA Military Technical Institute

10     between 1974 and 1989 and your further 13 years at the Technical Testing

11     Centre, you unquestionably became aware of the concept of firing tables;

12     is that right?

13        A.   That is something that my colleagues in artillery and ballistics

14     do.  I have nothing to do with it.  Of course I know they exist and they

15     are necessary, indispensable, but I really have nothing to do with it.  I

16     deal exclusively with explosives.  I'm somebody who worked to study

17     explosives and their characteristics and monitored how those explosives

18     act when fired on a plate on the testing ground or when fired from an

19     artillery weapon, but I know nothing about these firing tables.  That's

20     not what I'm expert in.  I'm a technologist, a chemical engineer.  I

21     didn't even have that as a subject at the university.

22        Q.   You'll nevertheless accept on the basis of your very extensive

23     experience in the JNA that new munitions and new weapon systems were

24     subjected to hundreds and in many cases thousands of test firings in

25     order to create comprehensive and reliable firing tables?

Page 31498

 1        A.   I have to tell you this again:  As far as firing tables are

 2     concerned, I cannot provide you with any information because I don't know

 3     even approximately how many times something needs to be fired.  I'm not a

 4     ballistics person, but I know when you test an asset, we always try to do

 5     it in the most economical way as far as my line of work is concerned,

 6     because testing is expensive.  We try -- in fact, we tried to spend as

 7     little money and resources to get as accurate results as possible, but I

 8     really don't know anything about ballistics, and I cannot tell you

 9     anything that could be relevant to this trial.  I'm really, really sorry.

10        Q.   Now, I think you confirmed in your evidence in chief, but it's

11     right, isn't it, that a new weapon system would not be deployed by the

12     JNA without going through this comprehensive testing system as well as

13     test firings; is that right?

14        A.   Let me tell you one thing.  When you test a large system like a

15     new artillery weapon or a vehicle, a whole team of people is engaged in

16     it.  We experts are little cogs in the wheel.  I for instance am one who

17     contributes to the process, but overall speaking, there is one main

18     person surrounded by a team who manages the whole system.  And of course

19     not a single asset was included in the arsenal before passing through

20     very comprehensive research and testing.  At least while I worked in the

21     Technical Testing Centre that never happened.  I don't know what the

22     situation is now.

23        Q.   I want to move to the subject now of air-bombs generally

24     speaking.  You're familiar with the FAB-100 and the FAB-250?

25        A.   Yes.

Page 31499

 1        Q.   Now, I'll just quickly go through a few matters that I think we

 2     can agree on.  First of all, they were both unguided air-bombs, that is,

 3     there was no GPS or laser or any other kind of guidance system?

 4        A.   Those bombs are unguided air-bomb like modern air-bombs which can

 5     have GPS, laser guidance, and other guidance, remote guidance, but I

 6     believe in most armies today there exist those unguided bombs that are

 7     launched, dropped by an aircraft on a target; such are FAB-100 and

 8     FAB-250, they are unguided air-bombs.

 9             THE ACCUSED: [Interpretation] Line 14 should read "unlike modern

10     bombs," not "like modern bombs."

11             JUDGE KWON:  Thank you.

12             MR. GAYNOR:

13        Q.   Now, Dr. Andjelkovic Lukic, we can agree, I think, that both the

14     FAB-100 and FAB-250 are designed to be dropped from the aircraft and to

15     strike the ground at a near vertical angle?

16        A.   Yes, of course.  That's how they were designed.

17        Q.   Now, the casings of these bombs can be made of different metals

18     with different densities; is that right?

19        A.   No, because those casings of bombs have a precisely prescribed

20     composition, because they had passed through certain testing that I

21     talked to you about earlier, and they have a specified type of steel

22     which I cannot name now, but it's all clearly written in the

23     documentation.  It cannot be just any old metal.  It has to have certain

24     solidity and specified percentages of steel and carbon and all the other

25     additives, and it has to have prescribed sturdiness.  You cannot put into

Page 31500

 1     that composition whatever you like.  There is a specified composition and

 2     that's it.  There are no deviations.  So that they have clearly defined

 3     composition of metal that has to be a constant.  It's prescribed and

 4     specified.  There can be no departure from that.

 5        Q.   Can we agree that the FAB-250 comes in more than one variety?

 6     For example, the FAB-250 M-72 contains 96 kilogrammes of TNT, and the

 7     FAB-250 M-79 contains 105 kilogrammes of TNT.

 8        A.   Yes.  One of them is an older modification with less explosives,

 9     97, and the other one has 105 kilos of explosive.  That's FAB-250.

10     That's a later generation, and you are correct, it's 105 kilogrammes of

11     TNT.

12        Q.   Now, in the Military Technical Institute in Belgrade, did you

13     occasionally test and approval air-bombs for use?

14        A.   The testing of air-bombs was finished in that year when they were

15     nominated in 1979 and 1972, and that was finished then and it's no longer

16     tested.  Let me tell you why, because every factory -- I'm sorry.

17        Q.   We're under a little bit of time pressure so I'd just like to

18     carry on if I can.  Could you just tell us briefly, would a FAB-100 or

19     FAB-250 air-bomb, generally speaking, be intended for dropping onto a

20     predominantly civilian urban area?

21        A.   You know if that is your intention -- what do you mean dropping

22     it on an urban area?

23        Q.   What I mean is are they approved for use for dropping from an

24     aircraft onto a predominantly civilian urban area?

25        A.   These bombs fall under destructive bombs and they are designed

Page 31501

 1     for easily determined targets.  That means bunkers, fortifications, for

 2     creating a passage, perhaps, for certain military targets.  So that these

 3     bombs have exclusively the nature of being designed for destroying enemy

 4     fortified facilities.  Not in terms of underground warehouses but surface

 5     fortifications like depots storing certain equipment or bunkers.

 6        Q.   Now, I'd like to move on to the subject of modified air-bombs.

 7             THE ACCUSED: [Interpretation] In line 9, it's not "easily

 8     determined," but "easily fortified" or "lightly fortified."  I do not --

 9     I believe that the better translation would be "lightly fortified."

10             THE INTERPRETER:  Interpreter's note:  We are pretty sure that

11     we've heard correctly the witness.

12             THE ACCUSED: [Interpretation] The word was "lako utvrdjeni."  I

13     don't think the translation is correct.  The problem is that this word

14     may mean both "determined" and "fortified" in our language.  The verb

15     "utvrdjeni" means "to determine," but it also means "to fortify."

16             JUDGE KWON:  Doctor, do you follow?  Did you say that the --

17     these bombs were designed for easily determined targets, or could you

18     clarify what that means?

19             THE WITNESS: [Interpretation] Shall I say it?

20             THE ACCUSED: [Interpretation] Easy to note targets or lightly

21     fortified?

22             THE WITNESS: [Interpretation] Shall I answer?  Am I to answer?

23             JUDGE KWON:  Yes, Doctor.

24             THE WITNESS: [Interpretation] There are very well military

25     fortified targets such as underground depots that you cannot destroy with

Page 31502

 1     one bomb.  You cannot even damage them with one bomb.  But there are

 2     other surface fortifications that can be neutralised by such bombs.  So

 3     the latter depots, to put it in military terms, are more lightly

 4     fortified.  But these are depots that have a certain strength.  They are

 5     not built like residential buildings, but they have a certain sturdiness

 6     because they house military equipment.  So we can call them lightly

 7     fortified.

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

 9        Q.   Now, I'd like to move on, as I said, to the subject of modified

10     air-bombs.  From your report and from the report which you contributed to

11     along with Mrs. Subotic and Mr. Poparic concerning modified air-bombs,

12     and from the report that you contributed to along with Mrs. Subotic and

13     Mr. Poparic concerning the evidence of Berko Zecevic and Richard Higgs, I

14     think we can agree in 1994 and 1995 the VRS fired modified FAB-100 and

15     FAB-250 air-bombs at the very least into the city of Sarajevo using

16     ground launched rockets that were attached to those air-bombs?

17        A.   In my report I did not contest that.  Of course, these things

18     existed and you can see that from the report.  However, yes --

19        Q.   I think I'll move on.  You also do not contest that these weapon

20     systems existed in different configurations.  For example, there was the

21     FAB-100 with one rocket motor or three rocket motors.  There was the

22     FAB-250 with different numbers of rocket motors.

23        A.   Yes.  FAB-100 was mainly with one rocket motor, but they could

24     occur with three motors which is in my report, and you can see it in

25     Mr. Berko's report, and it was with three rocket motors.

Page 31503

 1        Q.   And these different systems have different weights and different

 2     propulsive forces, don't they?

 3        A.   As for explosive force, it is contained in the bombs, in FAB-100

 4     and FAB-250.  That is, its explosive force.

 5        Q.   And my point was that the propulsive force is different.

 6     Obviously if its being propelled by three rockets, the propulsive force

 7     would be different than if it was propelled by two rockets or one rocket.

 8     I'm sure we can agree on that.

 9        A.   You know what?  According to some technical logic I could agree

10     with you, but I cannot say anything more about that to you because this

11     is really not my field.  I'm not a ballistics person.  I mean, there is a

12     technical logic, yes.

13        Q.   I want to go back to your periods working in the testing and

14     approval of munitions.  If you were asked to approve for use an unguided

15     air-bomb to be propelled in a rocket-assisted configuration, you would

16     expect that kind of system to be thoroughly and extensively tested before

17     being approved for use?

18        A.   My role was not to deal with the entire system.  I explained to

19     you a moment ago that there were these so-called system engineers who

20     were in charge of the system.  They were the ones who decided whether

21     they would apply this in this way or that way.  My task was only to see

22     whether the explosive in the asset had certain irregularities that could

23     lead to an undesirable explosion or to some kind of excessive thing so

24     that people who operate these pieces might fall victim in some way.  I

25     wanted to see whether the trotyl was properly charged, whether there were

Page 31504

 1     any voids.  Sometimes I even had to X-ray all of this to see whether

 2     everything was done properly.

 3             So really, I cannot give you the kind of answer that I would like

 4     to give you from the point of view of a scientist, if you will.

 5        Q.   Now, do you accept that if an institution as sophisticated as the

 6     Military Technical Institute in Belgrade were to be presented with a new

 7     weapon system such as a modified air-bomb where that weapon system came

 8     in different varieties with different weights, different numbers of

 9     rockets, different types of rockets, the proper thing to do would be to

10     rigorously test each and every one of those variations, including

11     hundreds of test firings, before it could be approved for use?

12        A.   When I spoke previously, I said -- I explained this to you, what

13     the procedure was when studying a particular piece of equipment.  This

14     procedure does not differ greatly from one asset to another.  If it was

15     an expensive asset, efforts were made not to squander any money, because

16     all of this does cost money.  So when these systems were being tested -

17     how do I put this? - this was done part by part.  The warhead would be

18     studied first by the artillery experts, and I would also be in these

19     teams that, say, worked on warheads.  Then also the propulsion,

20     colleagues who work on gunpowder and other such materials, then also the

21     fuse was studied by colleagues whose line of work that is, and so on.  So

22     all of this is done gradually to get to the final testing, and all of

23     this with a view to economising, not squandering resources, not to fire I

24     don't know how many projectiles in order to test something that --

25        Q.   Dr. Andjelkovic Lukic during your period at the

Page 31505

 1     Military Technical Institute and in the course of your conversations and

 2     dealings with your colleagues at the Military Technical Institute, did

 3     you ever hear of the testing of modified air-bombs by that institute?

 4        A.   I will tell you the following:  In the reports compiled by

 5     Mr. Berko, my distinguished colleague, I found a reference to 50 bombs

 6     with fuel-air explosives in Pretis.  There is one illogical thing that I

 7     have to draw your attention to here and that's the following:  In the

 8     opinion of my colleague Berko this was 1991 or 1992 when they were made,

 9     and in his CV my colleague Berko says that in 1988, he talked to

10     Mr. Zoran Maksimovic who worked in Vinca, and in 1989, he left his work

11     on these fuel-air explosives because the experiments did not yield

12     expected results.

13        Q.   Doctor, I'm -- my question is about the testing of modified

14     air-bombs systems.  I would like you to answer with a simple yes or no

15     whether during your period at the Military Technical Institute and in the

16     course of your conversations and dealings with your colleagues at the

17     Military Technical Institute, did you ever hear of the testing of

18     modified air-bombs by that institute?  I need a verbal response, please.

19        A.   No.  No.  No, I did not, because it is certain that if I had

20     heard about that or if that had been done, it certainly would have come

21     to me for verification, or I would have been made aware of it.  I never

22     had that on my desk.  That is a fact.

23        Q.   Now, during the course of your preparation of the three reports

24     to which you contributed and during the course of your duty at the

25     Military Technical Institute, did you ever hear of the extensive and

Page 31506

 1     proper testing of modified air-bombs systems in Bosnia or anywhere in

 2     Serbia outside your institute?

 3        A.   Again, I don't have an answer to this question.  I have not heard

 4     about this.  I don't know anything about this, because from 1989 onwards

 5     I worked at the Technical Testing Centre and there was no mention of

 6     that.  I really do not know anything about that.

 7        Q.   Now, I'd like to move, if I may, to the question of the ODAB.  In

 8     your report, at paragraph 6.18, which is on page 64 of the original and

 9     page 72 in English.  You say that during the war in Bosnia and Croatia,

10     the Croatian Army possessed the Russian ODAB-500 fuel-air bomb and fired

11     such a bomb from a MiG 21 towards forces of the ARSK, I think it is.

12        A.   As for the forces of the Republic of the Serb Krajina, the Knin

13     Krajina, the Croats did that during Operation Storm against them.  And

14     then it says here -- it is written here this was recently made public on

15     the 14th of April, 2012, that they have these bombs, and that near

16     Petrinja above Serb positions during Operation Storm from a MiG 21 such

17     bombs were ejected.  In the early 1990s, these bombs were obtained in the

18     area of the former USSR.

19        Q.   Now, you clearly accept that the Croatian Army had access to the

20     ODAB-500 fuel-air bomb, but you appear to exclude the possibility that

21     the VRS also had access to the ODAB-500 fuel-air bomb.

22        A.   Yes, but I also quote a Croatian paper here as well,

23     Mr. Ivo Pukanic is the person I quote.

24        Q.   Yes.  Sorry.  Let me say -- are you in a position to absolutely

25     exclude the possibility that the VRS also had an ODAB-500 at the same

Page 31507

 1     time that the Croatian Army had an ODAB-500 fuel-air bomb?

 2        A.   I exclude that because they were opposing sides.  I do exclude

 3     that.  I wouldn't believe that.

 4        Q.   All right.

 5             MR. GAYNOR:  I want to bring up, please, P1313.

 6        Q.   Now, this document is dated the 23rd of July, 1995, and it's to

 7     the SRK corps command.  Now, this refers to at the -- the manufacture at

 8     the maintenance and repair depot Hadzici of an air-bomb launcher for up

 9     to 500 kilogrammes, which is of a much higher quality than any so far?

10             JUDGE KWON:  Why don't you zoom in a bit further so the doctor

11     can see the content.

12             THE WITNESS: [Interpretation] Yes, please.  I do thank you.

13             MR. GAYNOR:

14        Q.   I'd like to ask you a couple questions about this.  First of all

15     it talks about making a launcher at the maintenance and repair depot in

16     Hadzici.  Now, that doesn't sound like a standard production line method

17     for producing a precise launching device, does it?

18        A.   No.  Hadzici did not manufacture launchers.

19        Q.   Well, according to this document that's where they were creating

20     this document which is described as being a --

21        A.   Please, I -- I'm not in a position to see this properly.  Oh,

22     yes, now --

23             JUDGE KWON:  For the moment why don't we collapse the English.

24     Yes.  Okay.

25             THE WITNESS: [Interpretation] Fine.  Excellent.  Thank you.

Page 31508

 1             Well, let me tell you.  I did not really have any connections

 2     with Hadzici, to tell you the truth.  And what is the year?  Let me just

 3     take a look.  '90-something -- no, it's 1995.  No, at that time I was at

 4     the TOC.  So I really do not have anything to do with this, but I do not

 5     exclude the possibility that that was done.  I really have nothing to do

 6     with this and cannot really say anything about this.

 7        Q.   We certainly can't exclude the possibility that the VRS was

 8     preparing a launcher for modified air-bombs much bigger than the FAB-250

 9     or the FAB-275?

10        A.   No.  No.  Just a moment, please.  Can I have a look at this

11     again.  It says here set up a commission --

12             THE INTERPRETER:  Interpret's note:  We can no longer hear the

13     speaker.  Can the witness kindly speak into her microphones, please.

14             JUDGE KWON:  Doctor, we'll print out this document and hand it

15     over to you.  It may be easier to you.  And you are kindly requested --

16             THE WITNESS: [Interpretation] Thank you.

17             JUDGE KWON:  You are requested to speak to the microphones.

18             THE WITNESS: [Interpretation] Thank you.  Yes.

19             As far as I can see, what is stated here is that technically the

20     launcher was not approved.  It had not been improved either, but it is

21     being suggested here by way of an order that someone should issue an

22     order to set up a commission and to see what the consumption of FAB-100

23     or 250 should be and then to be deployed in one of the units.  So this is

24     not only a reference to a 500 kilogramme launcher.  Obviously it was not

25     all right.  Obviously it did not pass the test.  Obviously it says here

Page 31509

 1     that it has to be checked further in terms of its function.  So obviously

 2     this was not right, and --

 3        Q.   My point is simply this:  On the basis of this document you are

 4     not in a position to exclude the possibility that the VRS was preparing

 5     to launch modified air-bombs much greater than the FAB-100 or the

 6     FAB-250?

 7        A.   But it cannot be asserted either that that launcher had been --

 8     well, you cannot see it from here.  It was part of the intention, but you

 9     do not see from here that it had been completed.  I cannot see it from

10     here, because something else needs to be tested; right?

11        Q.   I'd like to move on, please.

12             MR. GAYNOR:  Could we have, please, 65 ter 24351, please.

13             THE ACCUSED: [Interpretation] Line 13, the doctor said the

14     launcher had been mastered.  They did not hear it or they did not

15     understand it, so perhaps she should explain it.

16             JUDGE KWON:  Do you confirm that you said the launcher had

17     been -- had not been mastered well?

18             THE WITNESS: [Interpretation] Yes, that is what is written here.

19     I'm just reading what is written here.

20             JUDGE KWON:  Very well.  Please continue, Mr. Gaynor.

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

22        Q.   Now, Mr. -- sorry.  Dr. Andjelkovic Lukic, on the screen in front

23     of you you see a photograph of some objects.  Do you -- can you tell us

24     what those objects are?

25        A.   Well, these objects look like some kind of bombs, and there's a

Page 31510

 1     man -- or, rather, two men that are doing something around them, and

 2     there's some motors on them, and that would be it.

 3        Q.   Can I ask you to hazard a guess as to what kind of bomb that is?

 4     I'm referring to the bomb section.

 5        A.   I have to say here that this is a photograph from a newspaper

 6     article that speaks about the destruction of these assets, but I don't

 7     know exactly where this is or what this is.  I just know that this was

 8     written in a periodical, that these assets were written about in this

 9     periodical.  That is what I can say by way of my own information.

10             THE ACCUSED: [Interpretation] Can we kindly ask for the

11     provenance of this photograph?  Can Mr. Gaynor provide us with the

12     provenance of this photograph?

13             JUDGE KWON:  We'll come to that.

14             MR. GAYNOR:  Yes, we'll come to that in a moment.

15        Q.   Dr. Andjelkovic Lukic, can you just look at the black part of the

16     air-bomb.  Tell us on the basis of your extensive experience

17     approximately what weight is that air-bomb?

18        A.   Well, on the basis of the photograph, I cannot say exactly.  I

19     cannot say exactly.  In relation to this man, it doesn't seem too big to

20     me either to tell you the truth.  Well, it's a photograph.  I cannot say

21     exactly.

22        Q.   Would you be able to tell us, for example, whether it's a 250,

23     275?

24        A.   Well, perhaps 250, perhaps.  That's what it looks like.  But I

25     cannot tell you exactly.  I mean, you know, this is a photograph.

Page 31511

 1        Q.   Now --

 2        A.   It's not a technical drawing.

 3             MR. GAYNOR:  Can I pull up, please, 65 ter number 24350.  This is

 4     only available in the English language, so I'm going to tell you what it

 5     is, Dr. Andjelkovic Lukic.  This is a press release from an organisation

 6     called UXB International Inc., dated January 24th, 2011, relating to the

 7     destruction in Bosnia of, among other things, F-58 areal-fuel bombs,

 8     FAB-275 and areal-fuel rocket modified bombs RFAB-275 M-91, and for the

 9     benefit of everyone, this is an English language point, Doctor, the word

10     "areal" is spelled a-r-e-a-l, which mean pertaining to an area.

11             Doctor you do accept now that these are FAB-275 fuel-air bombs,

12     modified for delivery, using rockets?

13        A.   I would just like to say something here.  I have seen this

14     article.  I am familiar with this article.  There are 68 pieces referred

15     to here that are prepared to be destroyed, and since there are so many of

16     them and Mr. Berko said that there were 50 of them and that they had been

17     developed, what about the rest?  Where are the rest?  This is to say that

18     obviously these were the ones that were not good out of the 50 that

19     Mr. Berko mentioned that were there in the depot in Modrica or Glamoc or

20     wherever and that they were destroyed.  This is a newspaper article that

21     I have seen.  I know about this article.  So there were 68 there that

22     were destroyed.  That is to say that all of those that had been

23     manufactured, and Mr. Berko wrote here that there were 50 of them, they

24     had been destroyed because obviously they did not yield certain results.

25     That is my opinion about that.

Page 31512

 1        Q.   When I asked you to hazard a guess as to what size that bomb was

 2     you said it was probably a 250.  In fact it's a 275.  That's a forgivable

 3     error, would you accept?

 4        A.   Well, perhaps plus, minus 20 kilogrammes.

 5        Q.   It's a mistake that one can easily make when looking at an

 6     unexploded bomb.

 7        A.   Yes, yes.

 8        Q.   It's a mistake which one can even more easily make when looking

 9     at the remnants of an exploded FAB-275?

10        A.   No.  I've already explained this.  If that is it as it is, and

11     they said that it's the 68 -- I mean, I don't know that.  I told you that

12     that did not reach my desk.  That means that it was done somewhere else.

13     Maybe that is what Mr. Berko is speaking about.  However, the difference

14     is in the casing.  Over here the casing cannot be -- well, you see here

15     that it differs physically from the casing of an air-bomb.  That is

16     not -- well, this is something different.  It's not an air-bomb.  If it

17     were to detonate then there would have to be bigger fragments left and

18     also this white particle would have to be found, what you see on it, but

19     I did not find that anywhere in these reports or in this what I did.

20     This was not found anywhere.  No photograph that is even close to what is

21     depicted here.

22             You know what?  Had it detonated, it would have had to leave

23     larger fragments, say this big, like this piece of paper or half of it,

24     but none of that was found on the ground on the basis of the reports that

25     I looked at.

Page 31513

 1        Q.   Well, I put it to you that somebody looking at the exploded

 2     remains of a FAB-275 modified air fuel bomb could very well actually

 3     mistake that for a FAB-250 areal bomb filled with a fuel-air mix, by

 4     areal in this sense I mean by a air-bomb.

 5        A.   You believe that there could have been a confusion between an

 6     air-bomb and this if somebody is looking at it?  If somebody is looking

 7     at fragments?  No.  No way.  That could not have happened.  Why?  Because

 8     as I said a moment ago, an air-bomb, a FAB-250, it has thicker walls, if

 9     you will, and these thick walls cannot be broken by a central charge.

10     That is to say it is impossible for a FAB-250 with trotyl to be filled

11     with these containers with this FAE explosives.  I mean, this is just a

12     newspaper article.  It was written just like that in a rather

13     sensationalist manner.  But you cannot see that here.  You cannot see the

14     same form of a warhead as in the case of a 250 warhead.  The difference

15     is considerable.

16        Q.   You're --

17             MR. GAYNOR:  Mr. President, I'd like to tender photograph and the

18     press release at this stage.

19             MR. ROBINSON:  No objection.

20             JUDGE KWON:  Yes.  We'll admit them.

21             THE REGISTRAR:  65 ter 24351 --

22             MR. GAYNOR:

23        Q.   Dr. Andjelkovic --

24             THE REGISTRAR:  -- will be assigned --

25             JUDGE KWON:  No, just a second.  Shall we give the number now.

Page 31514

 1             THE REGISTRAR:  Shall be assigned Exhibit P6052, and the article

 2     24350 shall be assigned Exhibit P6053.  Thank you.

 3             MR. GAYNOR:

 4        Q.   While we're on this point, Dr. Andjelkovic Lukic, you referred in

 5     your evidence in chief to the fact that fuel-air bombs are usually

 6     delivered using a parachute in order to allow the aeroplane to escape the

 7     danger zone before detonation of the fuel-air bomb.

 8        A.   Yes, that's right.

 9        Q.   Now, a parachute in that kind of environment would unquestionably

10     be tested with the intention that the bomb be dropped from an aircraft

11     onto the ground; correct?

12        A.   Everything that is put into weaponry, parachutes included, I

13     mean, I assume this is done by any army, JNA included, yes, it has to be

14     tested.

15        Q.   And do you accept that parachute tested in that kind of

16     environment is therefore tested for a vertical drop?  It is not tested

17     with the intention that the air-bomb be used as a surface-to-surface

18     weapon describing a parabola from the point of firing to the point of

19     impact?  Do you accept that?

20        A.   What do you mean, the point from where it is fired on the ground?

21        Q.   My point is this --

22        A.   Yes.  Go ahead.

23        Q.   The parachute on a fuel-air bomb is not designed to be used in a

24     surface-to-surface configuration, is it?

25        A.   Well, I -- no, I really cannot give you an accurate answer to

Page 31515

 1     that.  It's used from a plane, but as for ground to ground, surface to

 2     surface, I really could not say.  I really don't know.

 3             MR. GAYNOR:  I'd like to call up now, please, 1D25159.

 4        Q.   This is a report authored by Zorica Subotic in co-operation with

 5     you and Mile Poparic.

 6             MR. GAYNOR:  Can we go, please, to page 43 in English and page 45

 7     in B/C/S.

 8        Q.   Now, do you accept veracity of the report that you co-authored?

 9             MR. GAYNOR:  Sorry, the page numbers are page 43 in English and

10     page 45 in B/C/S.

11             THE WITNESS: [Interpretation] Will I accept what?

12             MR. GAYNOR:

13        Q.   Do you accept the veracity of that report?

14        A.   Yes, of course.  Yes, I accept it.

15        Q.   I'd like to read out a portion of it says:

16             "Several years before the war broke out in BiH, the Pretis

17     factory began developing FAB-275 fuel-air bombs.  Just before the start

18     of the war in BH, production of the first 60 bombs was completed, but due

19     to the war beginning they were not tested.  During the war, a number of

20     these bombs were fitted with four Grad rocket motors each."

21             Now, I would like to put to you a few conclusions that we can

22     draw from that.  The first is that Pretis had the ability before the war

23     even started to produce FAB-275 fuel-air bombs.

24        A.   That is what Mr. Berko wrote, that 50 were produced in 1990 or

25     1991.  Whether he was correct in the figure, whether it was really 50, I

Page 31516

 1     cannot go into that.

 2        Q.   I think -- I think it's common ground essentially that Pretis had

 3     the capacity, the technical capacity, to create fuel-air bombs.  It did,

 4     in fact, create fuel-air bombs.  A number of those fuel-air bombs were

 5     fitted with Grad rockets, and those bombs were used during the conflict

 6     even though they had not been properly tested.

 7        A.   I did not see in the report any evidence about that, any evidence

 8     that they were produced.  I told you that that never passed my desk in

 9     the Technical Testing Centre, because in 1991, 1992, the JNA was still in

10     existence, and if it had been done in those years, it would have, I

11     believe, passed my desk, but I never saw it.

12             JUDGE KWON:  Just a second.  I'm not sure if Doctor is aware that

13     this is part of her report.

14             MR. GAYNOR:  I'll -- can we go to page 1 of this report in

15     English and B/C/S.  Thank you, Mr. President, for pointing that out.

16             THE WITNESS: [Interpretation] Yes, yes.  Yes.

17             JUDGE KWON:  Very well.

18             MR. GAYNOR:

19        Q.   You confirm that we are looking at your report?

20        A.   Yes.  It's a part of my report that I wrote in co-operation with

21     my colleagues, but probably -- yes, this is my report.

22        Q.   And you accept --

23        A.   But this passage that was inserted was done without my knowledge.

24     I'm not denying it.  I'm not saying I don't accept.  I just overlooked

25     it.  It passed me by.

Page 31517

 1             THE ACCUSED: [Interpretation] Can we see that if perhaps this is

 2     a quotation from some other paper?  Where are the sources for this?  Can

 3     we see the footnotes?

 4             JUDGE KWON:  Mr. Karadzic, then it is for -- that matter is

 5     something you should take up in your re-examination.

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

 7        Q.   Now, I think your evidence, Dr. Andjelkovic Lukic, on fuel-air

 8     bombs is that they have a much thinner casing than a conventional

 9     air-bomb.  That's your position.

10        A.   Yes.

11        Q.   So a weapon which is designed as a fuel-air bomb such as the

12     FAB-275 cannot be used as a conventional weapon, I assume you accept.

13        A.   Of course it cannot be used as a conventional weapon.

14        Q.   Can --

15        A.   You cannot --

16        Q.   Can we deduce then that the FAB-275 fuel-air bomb was exclusively

17     a fuel-air bomb and not a conventional bomb?

18        A.   We can deduce that, but we can also deduce -- we can also

19     conclude, in fact, that fragments of it have not been found or recorded

20     in these reports that I studied.

21             MR. GAYNOR:  Can I pull up please P2652.

22        Q.   As you see, Doctor, this is documents dated 17th of November,

23     1994, and it is type signed by Ratko Mladic.  It states under the

24     paragraph marked 1:

25              "A vehicle with launcher for launching FAB-275 is to be sent

Page 31518

 1     immediately to the Pretis enterprise.

 2              "Once the launcher is available, the crew is to report to

 3     Major Krsmanovic latest by 0830 hours on 18 November 1994."

 4             You accept that this shows that the FAB-275 was, in fact,

 5     employed by the VRS?

 6        A.   From this we can only see that they prepared it, not that they

 7     launched it.

 8             MR. GAYNOR:  Could I call up, please, P1296.

 9        Q.   This is a document dated the 19th of April, 1995, and it appears

10     to be addressed to the command of the 27th Logistics Base and Pretis

11     holding company, and it comes from the centre for logistics of the VRS

12     Main Staff.

13             If you look down the document, you can see in the second last

14     typewritten line there is a reference to six units of the FAB-275, and a

15     little below that you can see handwriting which says "FAB-275."  Do you

16     see that?

17        A.   We can see FAB-100.  That much I can see.  And there is also --

18     it's good now.  FAB-250 --

19        Q.   Could you --

20        A.   When I click it, it's moving.  I suppose, so there is also --

21             JUDGE KWON:  Please do not click it.  We have printed it out

22     again for you.  It is coming to you.

23             THE WITNESS: [Interpretation] Thank you.

24             MR. GAYNOR:

25        Q.   Dr. Andjelkovic Lukic, you can see that in this document the VRS

Page 31519

 1     Main Staff has ordered Pretis to begin producing adapters and slides for

 2     all of these air-bombs, including the FAB-275, which we know to be a

 3     fuel-air bomb.

 4        A.   Is that the document I've just been given?  "For their

 5     completion" it says, so that three be built into one FAB and then the

 6     amount of motors needed for their completion.  FAB-275, six pieces.

 7     "Their transport for completion will be regulated later."

 8        Q.   Dr. Andjelkovic Lukic, I put it to you on the basis of the

 9     document you've seen that you are not in a position to exclude the

10     possibility that the VRS used FAB-275 air -- fuel-air bombs in the

11     Sarajevo area, are you?

12        A.   I exclude that possibility because I've never seen evidence of

13     it.  Why?  Because I never saw those white markings or the thin casings

14     or the burnt fragments.  None of that is recorded in the Berko Zecevic

15     report.  Based on that, I can say they were not used.

16             As far as the rest is concerned, I haven't seen anything but the

17     two reports of my colleague Berko Zecevic, and based on that I can say

18     that I have never encountered the use of FAB-275.

19        Q.   Now, I just want to clarify the nature of your knowledge and

20     expertise.  You've clarified that you are an expert exclusively in the

21     explosive properties of substances that explode, including fuel-air and

22     TNT.

23        A.   As an explosive expert, I am familiar with phenomena of

24     explosives, not only the classical one, TNT, but also liquid explosives,

25     because I've had occasion to see on site what it looks like when I

Page 31520

 1     studied the causes and effects of explosions of natural gas in a house,

 2     and I did that not once but several times.  So I am familiar with the

 3     effects of gas explosives.

 4        Q.   Dr. Andjelkovic Lukic, can I ask you, have you ever in fact

 5     filled an empty FAB-250 bomb casing with a fuel-air mix and attempted to

 6     explode it?

 7        A.   I don't understand what you're asking.  Did I personally fill a

 8     FAB-250 and tested it?  Could you please clarify?

 9        Q.   That's my question.  Have you personally been involved or heard

10     of the testing of a FAB-250 bomb casing filled with a fuel-air mix,

11     anywhere, any time?

12        A.   Your question -- I'm sorry, but I do have to clear up what, in

13     fact, you're asking.  Is the casing of FAB-250 -- or, rather, was that

14     casing filled with fuel-air explosive, or did I see that?  I really don't

15     understand the question.  I apologise.

16        Q.   Let's go through this fairly -- fairly swiftly, hopefully, you

17     were aware that Pretis produced large quantities of the FAB-250 air-bomb;

18     correct?

19        A.   Yes.  That was in its production programme.

20        Q.   Do you accept that Pretis would have had within its stocks large

21     quantities of empty FAB-250 bomb casings?

22        A.   No.  Pretis never had empty casings.  And not just Pretis.  It's

23     not the practice to stock empty casings.  They are immediately filled

24     with trotyl and stored.  Why?  Because trotyl has the capacity to remain

25     stable for ten or so years, and there's no need to keep -- to stock empty

Page 31521

 1     casings.

 2        Q.   Dr. Andjelkovic Lukic, your evidence has focused on the question

 3     of whether TNT could have been removed from a 250 casing and fuel-air mix

 4     could have been inserted instead, and I'm asking you to consider an

 5     alternative scenario where you take an empty 250 casing and you fill it

 6     with fuel-air mix.

 7        A.   Oh, now I understand.  No, that's impossible for purely physical

 8     reasons.  I said a moment ago that the casings are of different

 9     thickness.  The middle part of the explosive is in too small an amount to

10     be able to break through the casing of an air-bomb, so that this

11     possibility, to the best of my knowledge, does not exist.  How could you

12     fill that casing with fuel-air explosive?  You would have to add a

13     container inside.  It could not be filled directly with fuel-air charge.

14     It's really an improbable situation.  You would need to fill one

15     container and put it in another container, or devise a container in the

16     same shape as the casing and then hermetically place it inside.  This

17     does not sound logical or acceptable to me.  No, I don't think that would

18     have been possible.

19        Q.   Dr. Andjelkovic Lukic, I'm entering the final phase of my

20     questions, but I simply want to put it to you that you are not in a

21     position to exclude the possibility that the VRS took empty FAB-250

22     casings, may have filled them with a fuel-air mix, and may have used

23     fuel-air mix within an empty FAB-250 casing.  You have not provided any

24     evidence to exclude that possibility?

25        A.   I have said a moment ago the thinnest 10 millimetre casing, and

Page 31522

 1     there are also those of 20 millimetres, cannot be broken by a charge like

 2     that, which is just 10 per cent of the whole mass.  It does not have the

 3     strength to break through that casing.  It was impossible to fill such a

 4     casing with fuel-air explosives.  That's all I can tell you.

 5        Q.   And as for the breaking of the bomb, we don't know if your theory

 6     is correct because nobody's ever done that experiment in your weapons

 7     facility to your knowledge.  Isn't that right?

 8        A.   You know, theory guides experiments.  All my knowledge about the

 9     strength, the force of this explosive, this -- this explosive is

10     relatively weak compared to trotyl.  Physically it is really impossible

11     to fill those casings with fuel-air explosive, to operate it that way.

12     It is just from the point of view of physics impossible because of the

13     thickness of the casing, because of the force of the explosive, because

14     of the way it would have to be packed inside.  It cannot be placed

15     directly into the casing.  I don't know.  It sounds completely

16     inconceivable to me, illogical, and impossible ultimately.

17        Q.   My last few questions on this.  You were -- you can answer this

18     just with a yes or a no.  You were in Belgrade for the duration of the

19     conflict in Bosnia; is that right?

20        A.   Yes.

21        Q.   You have never had an opportunity to inspect any unexploded

22     modified air-bombs that landed in Sarajevo during the conflict?

23        A.   I don't understand.  Of course I had no occasion to see them with

24     my own eyes, but you can make conclusions based on --

25        Q.   You did not have the opportunity to inspect any remnants from

Page 31523

 1     exploded air-bombs either?

 2        A.   I did see exploded bombs on the testing ground, a large number of

 3     them.  Exploded in what sense?  Of course I saw their effect, the

 4     fragments --

 5        Q.   Dr. Andjelkovic Lukic, I'll modify my question.  You did not

 6     inspect any remnants of exploded modified air-bombs fired onto Sarajevo,

 7     did you?

 8        A.   I couldn't, because I wasn't in Sarajevo in 1995, and these

 9     reports that were written, I look at the reports.  I looked at all the

10     photographs.

11        Q.   Doctor -- Doctor, as I said, you can answer these with a yes or a

12     no as the case may be.

13             JUDGE KWON:  Just one -- let's clarify one of her answers.

14             Doctor, you said that you didn't have any occasion to see the

15     unexploded modified air-bombs with your own eyes, but you could make

16     conclusion based on what?  It was not reflected in the transcript.

17             THE WITNESS: [Interpretation] Yes.  Based on documents.  But let

18     me just say one thing here.  It's not an issue of unexploded bombs,

19     because when they're unexploded, you can see all of it.  When it's

20     exploded, you can only see the destruction.

21             I don't understand the question about unexploded bombs.  I've

22     never seen them, and in the reports I only read about exploded bombs, one

23     FAB-100 and one FAB-250 that Mr. Zecevic keeps mentioning in his reports,

24     but he never tested that explosive to make sure that it's indeed the

25     explosive he claims was inside.

Page 31524

 1             MR. GAYNOR:

 2        Q.   Now, Dr. Andjelkovic Lukic, in your report you analyse a great

 3     number of specific incidents.  Is it correct that you did not carry out a

 4     site visit to any of those incident sites?

 5        A.   That's correct.  I did not.  It's in Sarajevo.  I didn't go

 6     there.

 7        Q.   It follows that you did not personally have access to or test any

 8     of the material gathered from those incident sites?

 9        A.   This report written by Mr. Berko was written in 2007.  That other

10     report was written in 1995.  In both reports, there are a lot of

11     inconsistencies that Mr. Berko himself, who was on the site, recorded

12     inconsistencies in his 2007 report.  So based on his report and the other

13     reports of -- that were written and all the photographs, I could conclude

14     what it was all about without going to the site.

15        Q.   And you did not interview any persons who were present at the

16     incident sites at the times of those incidents?

17        A.   I said I didn't.  I only studied both reports in Belgrade.  I had

18     no personal contacts in Sarajevo.

19             MR. GAYNOR:  No further questions, Mr. President.

20             JUDGE KWON:  Thank you.  Do we need to have a break or would you

21     like to continue?

22             THE ACCUSED: [Interpretation] I will need 15, perhaps 20 minutes.

23     Maybe we should have a break before that?

24             JUDGE KWON:  How long do you think you need for your

25     re-examination?

Page 31525

 1             THE ACCUSED: [Interpretation] Not more than 15 to 20 minutes at

 2     the most.

 3             JUDGE KWON:  Then shall we break for 15 minutes in order to

 4     conclude a bit earlier than usual?

 5                           [Trial Chamber and Registrar confer]

 6             JUDGE KWON:  I was advised to take at least 20 minutes' break.

 7     We will resume at 25 past.

 8                           --- Recess taken at 1.03 p.m.

 9                           --- On resuming at 1.27 p.m.

10             JUDGE KWON:  Yes, Mr. Karadzic.

11             THE ACCUSED: [Interpretation] Thank you.

12                           Re-examination by Mr. Karadzic:

13        Q.   [Interpretation] Dr. Andjelkovic Lukic, can you tell the

14     Trial Chamber whether there are any other lethal weapons that are fuel

15     rocketed within the armament of Yugoslavia?  What kind of rockets are

16     there?

17        A.   I really wouldn't know that.  I can't tell you because that is

18     not within my purview.  There are rockets such as the one on the M-84

19     tank, but that's a cannon ammunition.  There are also zoljas.  There are

20     Osas, but that's beyond the scope of my expertise.  I wouldn't be able to

21     tell you exactly what kind of rockets there were.

22        Q.   Was there a Grad rocket as well as a Luna rocket?

23        A.   Yes, there were such things.

24        Q.   Globally speaking, what does a rocket of that kind consist of?

25        A.   It has a warhead and it has a motor that propels it to a certain

Page 31526

 1     target.  That's as much as I know as a technical expert.

 2        Q.   Of these two parts, which part is your concern?

 3        A.   Only the warhead with explosives.

 4        Q.   Who is the one that tests the propellants?

 5        A.   They are tested by people who are concerned with propellants,

 6     either gunpowder or other types of fuel.  This is a special profession, a

 7     special line expertise.

 8        Q.   You never tested anything like that?

 9        A.   No.  No, that was not what I did.

10        Q.   You were asked whether you ever tested modified air-bombs, and

11     you said that such modified air-bombs has never appeared on your table.

12     Could you please be more precise?  What would it be that would be

13     modified in a bomb of that kind?

14        A.   If you consider that a modified bomb, which is a bomb with liquid

15     charge and an explosive charge, if that is what you consider when you say

16     a modified bomb, I've never seen any such thing, and I have never tested

17     any such thing.  I've never reviewed documents to see whether everything

18     is according to standards.  I had never encountered such assets.

19        Q.   Does that mean that a bomb with rocket motors is a modified bomb?

20        A.   That doesn't have to be the case.  Although the answer would be

21     yes.  How shall I put it?  Artillery weapons that I'm familiar with as a

22     result of my profession have warheads and have rocket propellants, and if

23     such an air-bomb has a rocket propellant, it can also be considered as a

24     modified bomb, but only in those terms.  That would be the only element,

25     the rocket motor that is attached to it.  It cannot be considered as a

Page 31527

 1     modified bomb if the only thing that differs is the kind of explosive in

 2     it.  Then it's an entirely different thing.

 3        Q.   Were you ever asked -- was there any need for you to test the

 4     well-known air-bomb in which the only thing that was changed was

 5     propellant?

 6        A.   There was no need to test an air-bomb that has already been

 7     tested, because all the fragments for its construction, which means all

 8     the elements of its construction starting with the body, the detonator,

 9     the explosive, all that exists in the construction documents, and every

10     time when a new bomb was manufactured, all those elements had to be

11     respected.

12             THE ACCUSED: [Interpretation] And now can we look at 1D25159.

13     The Serbian page that I want is 43.  I don't know whether the English

14     page was the same.  We saw that document only awhile ago.  The Serbian

15     page 45, and I don't know whether the English page corresponds.

16        Q.   In this passage, it says that there were some bombs FAB-275.

17     Could you please read the last sentence and could you read it aloud.

18        A.   "In December 2011, 58 FAB-275 aircraft bombs were destroyed in

19     Glamoc.  These rockets had been fitted onto 24 bombs.  So out of the 60

20     FAB-275 aircraft bombs produced, 58 were destroyed in 2011 while no more

21     than two were used in the war, and neither of these two bombs were used

22     in Sarajevo."

23        Q.   Thank you.  Do you adhere by the claims in this report?

24        A.   Yes, I do, because in the report that I drafted I never said that

25     there were aerosol bombs in Sarajevo.

Page 31528

 1             THE ACCUSED: [Interpretation] And now I'd like to call up P6052.

 2     It's a P document, P6052.  The record is correct.  Can we zoom in on the

 3     tail fins.

 4             Dr. Andjelkovic Lukic, have you ever encountered such remains in

 5     the documents that you studied and reviewed?  Have you ever encountered

 6     such remains of an air-bomb that was launched in Sarajevo?

 7        A.   I've already told you that I have not encountered any such things

 8     in the documents that I reviewed.

 9        Q.   What would these motors be, do you know?

10        A.   Really, I can't tell you.  I'm not familiar with these motors, so

11     I wouldn't be able to tell you what kind of motors these are.

12        Q.   Thank you.  I'm not going to ask you to speculate, although

13     Mr. Gaynor did ask you to speculate.

14             The central barrel, could it contain a parachute?  Could this be

15     an original fuel-air bomb?

16        A.   Really, it's very difficult to say that based on a photo.  I

17     would be speculating, whatever I told you.  I really can't see anything.

18        Q.   Fair enough.  Just one more question in that respect.  Did you

19     know -- do you know that before the war and during the war in Republika

20     Srpska whether there were some testing grounds where artillery weapons

21     could be tested and where rockets could be tested as well?

22        A.   The JNA had a lot of testing grounds in the former Yugoslavia.

23     There were some in Macedonia, and there were some in Bosnia-Herzegovina

24     as well.  In Bosnia-Herzegovina, there's a large testing ground known as

25     Kalinovik.  Its equipment was modest, but the conditions there were quite

Page 31529

 1     good for testing artillery ammunition.  That's where they tested tank

 2     ammunition, 125 millimetres.  I remember that.

 3        Q.   You're talking about things that happened before the war.

 4        A.   Yes, before the war.

 5        Q.   Thank you.  Do you know who controlled Kalinovik during the war

 6     in Bosnia?

 7        A.   As far as I remember, Kalinovik was under Muslim control, but I'm

 8     not sure.  I wouldn't be able to tell you, because I really don't know.

 9        Q.   Before the war was there any testing near Glamoc?

10        A.   Well, these are some grounds -- I don't know.  I just know about

11     the big ones, Kalinovik, the ones in Macedonia, Krivolak.  I know of

12     Nikinci, then Centa was mentioned, but really, I don't know of others.

13     That is what I know as far as these testing grounds are concerned and

14     that's where I went myself, but for the rest --

15        Q.   Thank you.  For your information, Kalinovik was always under our

16     control.

17        A.   I really don't know.

18             MR KARADZIC: [Interpretation] Thank you very much,

19     Dr. Andjelkovic Lukic for your contribution to these proceedings.

20             THE WITNESS: [Interpretation] Thank you.

21             JUDGE KWON:  Doctor, Judge Baird has a question for you.

22                           Questioned by the Court:

23             JUDGE BAIRD:  Doctor, in the course -- in the course of putting

24     his case to you, Mr. Gaynor put a suggestion, and I didn't get your

25     response.  I shall repeat that suggestion for you.  He put to you:

Page 31530

 1             "As for the breaking of the bomb, we don't know if their theory

 2     is correct, because nobody has ever done that experiment in your weapons

 3     facility to your knowledge?"

 4             Do you recollect that suggestion?

 5        A.   As far as I can remember, the question was whether an F-250

 6     casing can be fitted with fuel-air explosive.  My answer was no, because

 7     the central charge that initiates the fuel-air, that's how it goes out,

 8     it is too weak.  It cannot break this strong steel casing.

 9             JUDGE BAIRD:  Well, I don't think that was exactly the suggestion

10     that I was after.  I shall repeat it:

11             "As for the breaking of the bomb, we don't know if your theory is

12     correct because nobody has ever done that experiment in your weapons

13     facility to your knowledge?"

14        A.   Such an experiment, that is to say to put into the casing of a

15     FAB-250 air-bomb, to put this kind of explosive and to -- well, that

16     would be unacceptable, let me put it that way.  Let me not say anything

17     else.  It is unacceptable because in advance one knows that this casing

18     was not meant for a fuel-air explosive because of its physical

19     characteristics, because of the thickness of the metal and the type of

20     steel used that has to be appropriate for trotyl.

21             JUDGE BAIRD:  Fair enough.  Thank you.

22             THE ACCUSED:  May I?  Just one question on the basis of --

23                           [Trial Chamber confers]

24             JUDGE KWON:  Yes.  Judge Baird suggests to allow you to put that

25     question.  Yes.  Please go ahead, Mr. Karadzic.

Page 31531

 1                           Further Re-examination by Mr. Karadzic:

 2             MR. KARADZIC:  [Interpretation]

 3        Q.   Dr. Andjelkovic Lukic, a moment ago you responded to

 4     His Excellency Mr. Baird that it is well known that this is not

 5     sufficient.  Now I am asking you about experience with air-bombs with

 6     classical charges that were insufficient or of poor quality or was the

 7     explosive of poor quality and what happens then?

 8        A.   I have to say that when there are charges with explosive, then

 9     the requirements are very strict for the quality of the explosive,

10     because if the explosive is not good, that is to say if it has some

11     shortcomings, cracks, and so on, there can be incomplete detonation.  So

12     one knows in advance that the explosive has to be absolutely properly put

13     into the casing so that there would be no failure during targeting.  That

14     means, for instance, if an air-bomb was not to be exploded properly, if

15     it could not function properly, if there could be the so-called

16     deflagration, that is to say insufficient detonation.  So that is well

17     known and that is why this is taken into account.  And also, it is

18     therefore well known that if this kind of charge were to be put in an

19     air-bomb, it would not yield the kind of effects that are expected.  It

20     is quite senseless to put into such a bomb that kind of explosive.

21             THE ACCUSED: [Interpretation] Thank you.

22             JUDGE KWON:  Well, that concludes your evidence,

23     Dr. Andjelkovic Lukic, and I appreciate your coming to The Hague to give

24     it.

25             THE WITNESS:  Thank you.

Page 31532

 1             JUDGE KWON:  Now you are free to go.

 2             THE WITNESS: [Interpretation] Thank you.

 3                           [The witness withdrew]

 4             JUDGE KWON:  There are a couple of matters I'd like to deal with

 5     now.  The first thing is Prosecution's motion to exclude in part the

 6     evidence of Mirko Sosic, requesting that the Chamber order the exclusion

 7     of certain paragraphs.

 8             The accused filed his response stating that he does not oppose

 9     the motion and that he would delete the said paragraphs and relevant

10     associated exhibits.  So in light of this response, I'm wondering whether

11     the Prosecution is minded to withdraw its motion.

12             MR. TIEGER:  Yeah.  We consider that a resolution, Mr. President.

13     Thank you.

14             JUDGE KWON:  Thank you.  Second issue relates to the accused's

15     motion for videolink for Miroslav Gagovic, filed on the 12th of December.

16     Probably today -- yes, today the Prosecution filed its response not

17     opposing the motion.

18             Having been satisfied with the inability of the witness to travel

19     to The Hague due to his health condition and the relevancy of his

20     expected testimony, the Chamber will grant the motion and instruct the

21     Registry to take all necessary measures to implement this decision.

22             Are there any matters to raise at the moment?  Then otherwise --

23             MR. TIEGER:  No, Mr. President.  Thank you.

24             JUDGE KWON:  The hearing is adjourned.

25                           --- Whereupon the hearing adjourned at 1.47 p.m.,

Page 31533

 1                           to be reconvened on Monday, the 17th day

 2                           of December, 2012, at 9.00 a.m.